Interpretation ID: nht75-3.12

DATE: 03/07/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: YKK Zipper (U.S.A.) Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 13, 1975, in which you ask whether zippers fall under the purview of Federal Motor Vehicle Safety Standard No. 302.

S4.1 of the standard states that the following components of passenger cars, multipurpose passenger vehicles, trucks, and buses must meet its requirements:

Seat cushions, seat backs, seat belts, headlining, convertible tops, arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, mattress covers, and any other interior materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash.

To the extent that a zipper in a part of any of these components, it would fall within the ambit of the standard while recreational vehicles are not currently covered by Standard No. 302, the National Highway Traffic Safety Administration issued on November 15, 1974, a Notice of Proposed Rulemaking to extend the coverage of the standard to include recreational vehicles (copy enclosed).

You should also be aware that other rulemaking relevant to the coverage of the standard is underway and will soon be published in the Federal Register. For this reason, we recommend you subscribe to either the Government Printing Office Safety Standard subscription service or an equivalent commercial service as detailed in the enclosure.

SINCERELY,

YKK ZIPPER (U S A) INC

February 13, 1975

Chief Council NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

We are manufacturers and suppliers of zippers and zipper chain to the Recreational Vehicle Industry and are confronted with a problem regarding Specification FMVSS-302 - Flammability Act.

We need a legal interpretation as to whether or not zippers are exempt from this 302 Spec. . No one is the R.V.I. Industry seems to have a clear concept as to the exemption or the inclusion of zippers.

The zipper industry feels that zippers are exempt from 302 as they are also exempt in the important field of Infants Wear (DOCFF 3-71).

Since time is of the essence we would appreciate a clear and concise legal interpretation immediately. Your attention to this matter will be most appreciated.

Thank you.

VICE PRESIDENT, SALES