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Interpretation ID: Sealing_screen000519

    Ms. Erika Z. Jones
    Mayer, Brown, Rowe & Maw LLP
    1909 K Street, NW
    Washington, DC 20006-1101


    Dear Ms. Jones:

    This responds to your January 7, 2005, letter asking about Federal Motor Vehicle Safety Standard (FMVSS) No. 302, Flammability of interior materials. You ask if a sealing screen attached to an exterior door panel would be subject to FMVSS No. 302. Our answer is no.

    In your letter, you state that the sealing screen is installed between the door trim panel and the exterior door panel. It does not adhere to the door trim panel at any point, and is physically attached only to the exterior door panel. You state that the sealing screen serves the purpose of protecting the space behind the exterior door panel from moisture leaks and is not designed to absorb energy from an occupant in a crash. The sealing screen is within 13 millimeters (mm) of the occupant compartment air space.

    FMVSS No. 302 applies to new motor vehicles, and specifies burn resistance requirements for particular components, listed in S4.1 of the standard, used in the vehicle occupant compartment. Of those components, any portion of a single or composite material which is within 13 mm of the occupant compartment air space must meet the burn limit requirements of S4.3 of the standard. The components listed in S4.1 are:

    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.

    The question presented by your letter is whether we would consider the screen you described as a "trim panel, including door, front, rear, and side panels". Our answer is no. The screen is attached solely to the exterior door

    panel and is not incorporated into the interior door trim panel. We therefore conclude that it is not part of a "trim panel". Since the screen would not be part of a component listed in S4.1, it is excluded from FMVSS No. 302.

    If you have any additional questions please contact Mr. Chris Calamita of my staff at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    ref:302
    d.2/24/05