Interpretation ID: nht80-3.50

DATE: 09/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Stanley Electric Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

SEP 24 1980 NOA-30

Mr. H. Miyazawa Director, Automotive Lighting Engineering Department Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Miyazawa:

This responds to your August 4, 1980, letter asking whether several vehicle components would be required to comply with Standard No. 302, Flammability of Interior Materials. In particular you ask whether a headlining lamp, a courtesy lamp installed on a door panel, or various pilot indicator lamps and meters installed in the front panel must comply with the requirements.

As you stated in your letter, Section S4.1 of the standard lists the components required to comply with the standard. Further, that section states that materials designed to absorb energy on contact by occupants must comply with the standard. Since the components that you mention are not listed in S4.1 and since they do not appear to be designed to absorb energy on contact by an occupant, we conclude that they are not required to comply with the standard.

Sincerely,

Frank Berndt Chief Counsel

August 4, 1980

Att.: Mr. James B. Gregory Administrator

U. S. Department of Transportation National Highway Traffic Safety Administrator Washington, D. C. 20590 U. S. A.

Re.: The Components to which FMVSS No.302 is Applied

Dear Mr. Gregory,

In FMVSS No.302 S4.1., the following is prescribed and the components to which this standard applies are mentioned.

S4.1 The portions described in S4.2 of the following components of vehicle occupant compartments shall meet the requirements of S4.3: Seat cushions, seat backs, seat belts, headlining, convertible tops, arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, mattress covers, and 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.

We would like to ask you whether the following components are applied to by this standard.

1. Room lamp installed on the headlining

2. Courtesy lamp installed on the door panel

3. Various pilot indicator lamps and various meters installed on the front panel

Thanking you in advance for your cooperation,

Yours faithfully,

Stanley Electric Co., Ltd.

H. Miyazawa Director, Automotive Lighting Engineering Dept.

ha/ha