Interpretation ID: nht91-5.23

DATE: August 12, 1991

FROM: Frank Kenney -- Sporting Tailors Manufacturing Co.

TO: Office of the Chief Councel (Counsel) -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10-21-91 from Paul Jackson Rice to Frank Kenney (A38; Std. 302); Also attached to copy of 49 CFR 571.302, pages 517-519: Standard No. 302, Flammability of interior materials; Also attached to letter dated 6-29-90 from Paul Jackson Rice to Ed McCarron of Western Star Trucks Inc. (Std. 302)

TEXT:

We are planning to manufacture roll bar or "Bikini Tops" for off road Vehicles such as Jeep Wranglers. We are presently clothing manufacturers and this would be a new product line we would becoming involved with. We, therefore, have, some questions for you.

Since this is an "after market product", it is our understanding that the roll bar tops must conform to automotive code #302 which has to do with passing flammability requirements. We have resolved this problem by imparting a flame retardent element between the vinyl roll bar top and the brushed nylon black backing fabric ass per the enclosed sample. (The vinyl top fabric is bonded to the brushed nylon tricot black fabric and the flame retardent is sandwiched between the two fabrics.)

Our question is the following: (Please refer to diagram of the roll bar top and the fabric sample enclosed)

Would the binding fabric strips sewn all around the edges of the roll bar top to lend stability and finished appearance also be required to have a flame retardent element added to the back of the strips as well?

Since the bonded roll bar vinyl top fabric bonded to the brushed nylon tricot fabric with the flame retardent sandwiched between IS ACTUALLY LYING BETWEEN THE STICHED BINDING STRIP, would it be required to make the strip flame retardent as well? Would we not be duplicating our efforts?

We would greatly appreciate your response to this at your very earliest convenience.

We understand that we must conform to 49 CFR Part 566 manufacturer identification and if there would be anything else that would apply to this after market product, please advise us.

The last question we pose to you is the following: If we supply a tote bag to the consumer in order that the roll bar top may be kept clean while not in use, would this tote bag also be required to conform to Automotive code #302:

We thank you in advance for your comments and information.