Interpretation ID: nht87-2.21

TYPE: INTERPRETATION-NHTSA

DATE: 06/23/87

FROM: DOUG COLE -- NATIONAL VAN CONVERSION ASSOCIATION INC

TO: STEVE KRANTZKE -- NHTSA/

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A32, STANDARD 302; LETTER DATED 06/29/87 FROM JONATHAN JACKSON TO DOUG COLE; LETTER DATED 06/22/87 FROM ROSE M TALISMAN TO DOUG COLE; LETTER DATED 06/08/87 FROM ROSE TAL ISMAN TO DOUG COLE

TEXT: Hi Steve!

It was a pleasure talking with you and thanks again for a speedy returned call. George Shiflett recommended I contact your office about an issue that has arisen from a Certification program that National Van Conversion Association (NVCA) sponsors. The i ssue surrounds the question of "compliance with FMVSS #302".

A part of NVCA's Certification includes the physical gathering of random samples of fabrics, foams, carpets, and other flammable items that van conversion firms use in vehicles. These samples are then channeled to an accredited testing firm for destruct ive testing to verify compliance with FMVSS #302. NVCA has found many samples, according to the tests performed, not to be in compliance with FMVSS #302. The manufacturers of these samples vehemently oppose NVCA's findings and insist that their samples are indeed in compliance with FMVSS #302.

In an effort to double check NVCA's test procedures, I contacted four major testing laboratories recommended by the American Association of Motor Vehicles Administrators. Half of those contacted suggested that NVCA's test methods were correct and the ot her half disagreed. Each half was quite certain they were right. The issue appears to be about when to use (or not to use) support wires in conjunction with the FMVSS #302 test. NVCA doesn't use any support wires in its test; some fabric manufacturers use support wires in their tests. In many (not all) instances, these support wires are an influence on whether a material passes or fails the FMVSS #302 test. Will you please clarify for us whether to use or not to use the support wires?

I have enclosed copies of test procedures from NVCA's testing lab, a fabric manufacturer, Ford, and Fisher Body Division of GM for your review. Also enclosed is a copy of a letter NVCA will include with its communications with conversion firms (in the c ase of a FMVSS #302 failure, per NVCA's current test methods). If you see anything that we need to alter immediately, please contact me; if not, I realize your interpretations, comments, opinions, rulings, or whatever may take some time to formulate and NVCA will proceed as normal until we hear from you. Your assistance in this matter will be greatly appreciated by many involved. If I can provide any additional data or be of service in any way, please call on me.

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