Interpretation ID: nht72-6.57

DATE: 08/07/72

FROM: RICHARD B. BYSON -- NHTSA ASSISTANT CHIEF COUNSEL

TO: LOUIS C. LUNDSTROM -- DIRECTOR GM ASE

TITLE: NONE

TEXT: Dear Mr. Lundstrom:

This is in reply to your letter of July 17, 1972, concerning the application of Motor Vehicle Safety Standard No. 302. Flammability of Interior Materials, n1 to radio speaker cones. You request clarification of an interpretation we sent to American Motors dated June 9, 1972, wherein we stated that "stereo speaker . . . cones incorporated into a door or rear shelf would be considered part of a 'trim panel' and 'compartment shelf,' respectively. You particularly request clarification of the phrase "incorporated into.

The NHTSA's position is that a speaker cone, while not generally subject to Standard No. 302 (we assume that it is not an "energy-absorbing" component), will be subject to the standard if it is "incorporated into" a component that is subject to the standard. We would consider a speaker cone to be "incorporated into" a trim panel or compartment shelf if the cone forms a portion of the surface of the panel or shelf. We would not consider a speaker cone merely attached to an enumerated component, but situated wholly underneath (shelf) or behind (trim panel) its surface to be subject to the standard.

I trust this clarifies our position.

Yours truly,