Interpretation ID: nht88-1.40

TYPE: INTERPRETATION-NHTSA

DATE: 02/12/88

FROM: FRANK H. MILLER -- GERRY BABY PRODUCTS QUALITY ENGINEER

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/02/89 FROM STEPHEN P. WOOD -- NHTSA TO FRANK MILLER -- GERRY BABY PRODUCTS; RED BOOK A33; FMVSS 302

TEXT: Dear Ms. Jones:

This is in further reference to my communication to you dated October 19, 1987 and also to your response received December 3, 1987. Both were in reference to paragraph S4.2.1 of Safety Standard No. 302, "Flammability of Interior Materials".

I appreciate your response regarding the testing of threads used in the manufacture of seat cushions and testing them as a part of the component and now would like to know if the binding we use on the edges of the cushion should also be tested as a part of the material. We currently test it as an independent entity but it would ease our testing if it were to be done as a portion of a cushion assembly.

Thank you for your attention to this matter.

Sincerely,