Interpretation ID: aiam0866
TERRALAB
5221 Major Street
Salt Lake City
UT
84104;
Dear Mr. MacGregor: This is in reply to your letter of August 31, 1972, to Robert C O'Connell, Region VIII Administrator for the National Highway Traffic Safety Administration, concerning the application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. You raise several questions in your letter which are restated below.; 1. 'Does the standard apply to wood paneling used on the interior o campers, trailers, and mobile homes?'; The standard applies to passenger cars, multipurpose passenge vehicles, trucks, and buses. This does not cover trailers, a vehicle class that includes mobile homes among its members, but it does cover campers which are mounted on new chassis. Accordingly, wood paneling used as a component or portion of a component described in Paragraph S4.1 of the standard and installed in campers mounted on new chassis would be subject to the requirements of the standard.; 2. You ask whether the standard applies to the studs used to fasten th wood paneling to the structural framework.; The studs used to fasten the wood paneling to the structural framewor of campers mounted on new chassis are not listed in Paragraph S4.1 of the standard, nor are they incorporated into a component listed in Paragraph S4.1. Consequently, the studs would not be subject to the requirements of the standard.; 3. 'Does the standard apply to plastic door molding?' Paragraph S4.1 does not list door molding as one of the interio components that must meet the requirements of the standard and, therefore, door molding is not covered.; 4. 'Does the standard apply to carpeting, and if so, if the carpetin is tacked to the flooring, does the flooring have to be tested for flammability?'; Paragraph S4.1 lists 'floor coverings' among the components required t meet the requirements of the standard. Since carpeting is a floor covering, it would have to meet the requirements of the standard. The flooring underneath the carpeting would not be considered a 'floor covering' and, accordingly, would not have to meet the requirements of the standard.; 5. 'If the paneling or flooring, either separately or as a subassembly has to be tested, is it tested by this procedure, or a more applicable procedure such as ASTM E251, etc.?'; The flooring, as stated above, is not subject to the requirements o the standard when it is covered by a floor covering such as carpeting. While a manufacturer may test for conformity to the standard as he thinks best, whether his product conforms to the standard will be determined by the NHTSA by means of the test procedures specified in the standard. Manufacturers who use procedures different from those in the standard should correlate the results obtained from such tests with those that would be obtained by the procedures recommended by the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel.