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Interpretation ID: Kim.1

    Mr. Jongsoo Kim
    Senior Researcher
    Korea Automobile Testing & Research Institute (KATRI)
    #625, SamJon-Ri, Sonmgsan-Myun
    Hwasung-Si, Gyeonggi-Do, Korea (445-871)


    Dear Mr. Kim:

    This responds to your e-mail to Coleman Sachs of the Office of Vehicle Safety Compliance in which you seek clarification regarding the manner in which air bag cushion material is tested under Federal Motor Vehicle Safety Standard (FMVSS) No. 302, Flammability of Interior Materials. Specifically, you asked whether the air bag material is tested in an uninflated (pre-deployment) or inflated (post-deployment) state. As discussed below, the standards test requirements apply to air bag cushion materials in an uninflated state.

    By way of background, the National Highway Traffic Safety Administration is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment. Standard No. 302 sets forth burn resistance requirements for materials used in the occupant compartment of motor vehicles, in order to reduce deaths and injuries associated with vehicle fires caused by matches, cigarettes, or some other source. In general, the standards test procedures provide for a component specimen to be burned in a metal cabinet, and in order to meet the requirements of the standard, such materials may not exceed a specified burn rate within 60 seconds from the start of timing.

    Paragraph S4.1 of the standard delineates the types of materials covered by the standard. That listing includes 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. Paragraph S4.1 does not specifically address whether an air bag is tested in a pre-deployment or post-deployment state. Moreover, this issue has not been addressed in FMVSS No. 302 rulemakings. We do not read into the standard a test condition that the air bag be deployed prior to testing. Accordingly, when conducting testing under FMVSS No. 302, the agency will test the air bag cushion material in its uninflated (pre-deployment) state.

    If you have further questions, please feel free to contact Eric Stas of my staff at (202) 366-2992.

    Sincerely,

    Stephen P. Wood
    Acting Chief Counsel

    ref:302
    d.5/17/06