Interpretation ID: nht78-1.45

DATE: 03/10/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Recreation Vehicle Industry Association

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 10 1978

Mr. Edmund C. Burnett Recreation Vehicle Industry Association 5272 River Road, Suite 400 Washington, D.C. 20016

Dear Mr. Burnett:

This responds to your January 18, 1978, letter asking several questions about the applicability of Standard No. 302, Flammability of Interior Materials, to several vehicle components that you submitted.

First you ask whether padded material used for the top portion of a dashboard would be considered to fall within the ambit of the standard. As you stated in your letter, the National Highway Traffic Safety Administration has determined that a dashboard is considered a front panel and is included within the components subject to the standard. Therefore, since the padding you propose to use on the top of the dashboard constitutes part of the dashboard it is required to comply with all of the requirements of the standard.

In your second question you ask whether the same material mentioned in question 1 would be required to comply withe the standard when used as a seat cushion. Paragraph S4.1, which lists the components covered by the standard, specifically includes seat cushions. Therefore, any material used for this purpose is required to comply with the standard.

In regard to both of the above questions, you ask whether a dashboard or seat cushion consisting of vinyl stitched at varying intervals to padding would be subject to two tests - one for the vinyl and one for the padding. Paragraph S4.2.1 states that: "any material that does not adhere to other material(s) at every point of contact shall meet the requirements of S5.3 when tested separately." When the vinyl is stitched to the padding in the manner outlined in your letter, the vinyl does not adhere to the material at every point of contact. Accordingly, the materials must be tested separately.

Your questions 3 and 4 require no response since the materials to which you refer must be tested separately, not as composite materials.

In your question 5, you correctly state that the two top materials would be required to be tested separately. If as installed in the vehicle the third layer of material would fall within 1/2 inch of the occupant compartment, then it too would be tested in accordance with the requirements. It does not matter that this material would not be within 1/2 inch of the surface when the stitching is removed for testing of each component separately. In a related question you ask whether the stitching itself would be tested. Since the stitching is part of the seat cushion, it is subject to the requirements and since it does not adhere at every point of contact, it should be tested separately. From the standpoint of practicality, however, the stitching cannot be tested separately in the prescribed manner, and is usually simply tested as part of the material itself.

Finally you submitted a section of headlining material and question whether it would be required to comply with the requirements. This material falls within the list of components covered by the standard and, therefore, must comply with all of the requirements. The material that you submitted is composed of two layers joined at every point of contact and would be tested as a composite material.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel