Torbjrn Waerme

Immeuble Atria

2, rue du Centre

93 051 Noisy Le Grand


Dear Mr. Waerme:

This responds to your e-mail request for an interpretation of Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials. You ask whether cables and electrical harnesses under the front passenger/driver seat are to be tested regarding flammability. Based on the information you provided to the agency and the analysis below, our answer, which is limited to the specific situation you present, is yes.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards (FMVSS) that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the Safety Act establishes a self-certification process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. This letter interprets FMVSS No. 302 based on our understanding of the information you have provided.

You explain that the seat cushion and seat back have electronics built into the foam. You state: In this specific case electronics are built in to the foam cushion/back and harnesses [containing four cables] are exiting the cushion/back foam. These harnesses will be attached under the seat, sometimes close to the metallic frame supporting the foams. You ask about cable harnesses that come out of (exit) the seat cushion and seat back and that connect to an electronic application under the seat.

Section 4.1 of FMVSS No. 302 lists the components in the vehicle occupant compartment that must comply with the flammability resistance requirements of S4.3. The listed components are: seat cushions, seat backs, seat belts, headlining, convertible

tops, arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, mattress covers, and any other interior materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash. Our longstanding interpretations of FMVSS No. 302 have stated that materials incorporated into components that are listed in S4.1 are subject to the standard. Examples of incorporated components include an air bladder that is attached to a mattress cover, July 3, 1997 letter to Mr. Dean Knapp; an instruction sleeve that is attached as a permanent part of a sun visor, August 31, 1973 letter to Ms. Dianne Black; material intimately joined with a listed material, October 11, 1972 letter to Mr. David Humphreys. (Copies of the letters are enclosed.)

Seat cushions and seat backs are listed in S4.1. The cable harness you described is incorporated into the seat cushion and seat back. It does not matter that the harness itself is outside of the cushion or seat back because the harness is permanently attached to the seat cushion or seat back by way of the electronic cables that constitute an integral part of the seat. Because the harness is incorporated into the seat cushion or seat back, it is subject to the flammability resistance requirements of FMVSS No. 302.

I hope this information is helpful. If you have other questions, please contact

Ms. Deirdre Fujita of my staff at 202-366-2992.

Sincerely yours,

Anthony M. Cooke

Chief Counsel