Interpretation ID: aiam3252
MPI
Inc.
P.O. Box EE
Coldwater
MS
38618;
Dear Mr. Wood: This confirms your April 9, 1980, telephone conversation with Roge Tilton of my staff in which you asked whether a styrofoam board that lies beneath a layer of polyurethane foam would be required to comply with the flammability requirements of Standard No. 302, *Flammability of Interior Materials*.; As Mr. Tilton explained to you, the standard applies to seatin components such as yours only to the extent that they fall within 1/2 inch of the occupant compartment air space. This requirement is specified in paragraph S4.2 of the standard. You indicate that your styrofoam board would not fall within 1/2 inch of the compartment because the polyurethane cover will always be thicker than 1/2 inch. Assuming this is true, your styrofoam board would not be required to comply with the standard.; Sincerely, Frank Berndt, Chief Counsel