Mr. Michael J. Kroll
Safety Engineering Laboratories, Inc.
27803 College Park Drive
Warren, MI 48093-4879

Dear Mr. Kroll:

This responds to your April 16, 1996 letter asking about the applicability of Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials (49 CFR '571.302), to various materials in the interior of a vehicle. You ask a number of questions about the standard which we have rephrased below, followed by our answers.

Question: Are materials located under the dash (instrument panel) required to meet the FMVSS 302 requirements? Examples of materials located under the dash are: defrost ducts, air distribution ducting, demister tubes and hoses, insulation on wiring, sound deadening materials, electronic and/or electrical component enclosures. Many of these materials are not visible directly but are accessible via heater/defrost outlets and radio speaker grills.

Answer: Section S4.1 of Standard No. 302 lists the components in the vehicle occupant compartment that must comply with the flammability resistance requirements of paragraph S4.3. The components listed 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, 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. Under S4.1 and S4.2 of the standard, any portion of these components that is within 2 inch of the occupant compartment air space must meet the standard=s requirements.

The materials you list are not included in S4.1. Thus, they do not have to comply with Standard No. 302.

Question: Are materials located within the passenger compartment on or near the fire wall required to meet Standard 302? These include heating/ventilation/air conditioning (HVAC) ducting, carpeting, sound deadening materials, and electronic or electrical component enclosures. On many vehicles, the HVAC ducting material below the dash is clearly visible and intimately associated with other exposed materials such as carpeting and sound deadening material.

Answer: Some materials located on or near the fire wall are subject to Standard 302. Among the items listed in S4.1 of the standard are floor coverings and engine compartment covers. The standard applies to HVAC ducting material that is part of carpeting used as a floor covering or part of the engine compartment cover. The standard also applies to foam directly under the dash coverings, since the agency considers such foam to be padding that is designed to absorb energy on contact by occupants in the event of a crash. This assumes that the HVAC and foam material is within 2 inch of the occupant compartment air space.

Question: Section S4.2 states that AAny portion of a single or composite material which is in 2 inch of the occupant compartment air space shall meet the [flammability resistance] requirements of S4.3.@ Does S4.2 apply to all materials in the occupant compartment air space?

Answer: No, S4.2 only specifies which portions of those components listed in S4.1 must meet the flammability resistance requirements.

Question: Does S4.2 apply to: (i) materials located under the dash and exposed to the occupant compartment air space, (ii) on the fire wall near and/or on the floor of the occupant compartment, (iii) foams directly under vinyl or cloth coverings on seats, (iv) foam directly under dash coverings, and (v) foam used to line the interior of HVAC ducts?

Answer: Standard No. 302 applies to materials on the fire wall near or on the occupant compartment=s floor, foams directly under vinyl or cloth coverings on seats, and foam directly under dash coverings. It does not apply to materials (other than padding) located under the dash and exposed to the occupant compartment space, assuming these materials are not listed in S4.1, or to foam used to line the interior of HVAC ducts.

Question: Does S4.2 apply to composite materials, such as a foam backing on a vinyl headliner tested as a composite?

Answer: Yes, and the composite vinyl headliner is subject to S4.2.2. That section specifies that AAny material that adheres to other material(s) at every point of contact shall meet the requirements of S4.3 when tested as a composite with other material(s).

Question: Does S4.2 apply to a foam backing of a cloth headliner where the foam is not attached to the headliner?

Answer: Yes, and the headliner would be tested subject to S4.2.1, which specifies that AAny material that does not adhere to other material(s) at every point of contact shall meet the requirements of S4.3 when tested separately.@

Question: Does S4.2 apply to any material underneath the carpeting where the total thickness of the carpeting and backing is less than 2 inch?

Answer: Because S4.2 applies to any component in S4.1 that is within 2 inch of the occupant compartment air space, it applies to listed materials such as a floor covering, up to 2 inch.

Question: Under what basis or criteria are some materials within the occupant compartment air space excluded?

Answer: See answer to question one. Section S4.1 of Standard No. 302 provides a comprehensive list of materials subject to the standard. Any material not on this list is not subject to the standard.

I hope this answers your questions. If you have any further questions, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

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