Interpretation ID: aiam2294
Independent Textile Testing Service
Inc.
P. O. Box 1948
1499 Murray Avenue
Dalton
GA
30720;
Dear Mr. Setter: This is in response to your letter of February 18, 1976, concernin testing procedures pursuant to Federal Motor Vehicle Safety Standard No. 302, *Flammability of Interior Materials*.; As you point out, S5.1.3 of the standard provides that thin, hea resistant wires are used to support a 'specimen that softens and bends at the flaming end so as to cause erratic burning.' One of your customers asserted that support wires should be used in testing his materials, and you have asked when the use of support wires is appropriate.; Your interpretation of the standard in this case is commendable, an your test practices are calculated to demonstrate clearly the exercise of due care that a particular product complies with Federal motor vehicle safety standards. However, an NHTSA July 19, 1971, interpretation of Standard No. 302 (copy enclosed) permits use of support wires when any bending of the tested material occurs. At the time of that interpretation, it was believed that the support wires would not influence the test results.; More recent testing by the agency demonstrates that the support wire do significantly affect burn rates, and the agency intends to issue an interpretative amendment of the standard that will limit use of support wires.; Thank you for your responsible approach to testing products that ar required to conform to Federal motor vehicle safety standards.; Sincerely, Frank Berndt, Acting Chief Counsel