Interpretation ID: aiam4415
Gerry Baby Products
12520 Grant Drive
Denver
Co 80233;
Dear Mr. Miller: This responds to your September 25, 1987, letter to Mr. Val Radovich o NHTSA's Office of Vehicle Safety Standards and your October 19, 1987 letter to my office concerning paragraph S4.2.1 of Safety Standard No. 302, *Flammability of Interior Materials*.; You ask whether the thread that is used in the manufacture of a sea cushion is tested as part of the component. The answer is yes. In a March 10, 1978 interpretation of Standard No. 302, NHTSA recognized that stitching that does not adhere at every point of contact should be tested separately under S4.2.1. However, the agency also determined that, from the standpoint of practicality, the stitching cannot be tested separately in the prescribed manner. NHTSA thus concluded that stitching will be tested as part of the material itself.; Please contact us if you have further questions. Sincerely, Erika Z. Jones, Chief Counsel