Interpretation ID: nht87-3.35

TYPE: INTERPRETATION-NHTSA

DATE: 12/03/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Frank Miller -- Gerry Baby Products

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Frank Miller Gerry Baby Products 12520 Grant Drive Denver, CO 80233

This responds to your September 25, 1987 letter to Mr. Val Radovich of 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 seat 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 poin t 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 a s part of the material itself.

Please contact us if you have further questions.

Sincerely,

Erika Z. Jones Chief Counsel

September 25, 1987

To: Mr. Val Radovich Office of Vehicle Safety Standards National Highway Traffic Safety Admin. 400 Seventh Street, S.W. Washington, D.C. 20590

From: Frank Miller Gerry Baby Products 12520 Grant Drive Denver, CO 80233

Dear Sir:

This inquiry is in regards to the flame retardancy requirements of FMVSS 302, specifically S4.2.1. A question has been brought up about the thread that is used in the manufacture of the seat cushion.

Is the thread considered to be part of the composite?

Thank you for your time.

Sincerely,

Frank Miller Quality Engineer

October 19, 1987

Office of Chief Counsel NHTSA 400 Seventh St. S.W. Washington, D.C. 20590

Dear Sir/Madam:

To satisfy our specifications we need written legal interpretation of the term "composite" as used in FMVSS 302.

Our feeling is that as long as the sewn seat meets the requirements, the thread and/or binding does not have to meet the requirements if tested separately. We feel this way because the thread and binding in the Gerry Guardian Car Seat adheres to the seat cushion at every point of contact.

Your response to this matter will be greatly appreciated.

Sincerely,

Frank Miller Quality Engineer