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Interpretation ID: aiam0440

Mr. J. Wuddel, Ing., Westfalische Metall Industrie KG, Hueck & Co., 4780 Lippstadt, Postfach 604, West Germany; Mr. J. Wuddel
Ing.
Westfalische Metall Industrie KG
Hueck & Co.
4780 Lippstadt
Postfach 604
West Germany;

Dear Mr. Wuddel: This is in reply to your letter of August 20, 1970, concerning Moto Vehicle Safety Standard No. 302 (Docket 3-3, Notice 4) 'Flammability of Interior Materials.' You ask whether 'plastic materials such as those covering control lamps, for the control lamps themselves, for the control knobs and for the interior lights must also meet the same requirements.' The components you list are not specifically enumerated in S4.1 of the standard, and are not required to meet the standard's burn- rate requirements unless they are 'any other interior materials. . . that are designed to absorb energy on contact by occupants in the event of a crash.' (See the last sentence of S4.1, copy enclosed) This will depend on the particular configuration of the vehicle in question, and the manufacturer must determine, based on the design of his vehicle, whether the components you describe fall within the quoted language.; In answer to your second question, the NHTSA neither requires no provides prior approvals for motor vehicles or motor vehicle components. Questions concerning these approvals should be directed to the jurisdiction, such as the State of California, which you mention, that is involved.; Sincerely, Lawrence R. Schneider, Chief Counsel