Interpretation ID: aiam0933
Manager
Quality Control
The Stearns & Foster Co.
Cincinnati
OH
45215;
Dear Mr. Haynes: This is in reply to your letter of November 15, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to innerspring mattresses you are going to produce for use in motor homes. You raise four questions in your letter which are restated below.; >>>1. 'Under S4.2 of the Standard, do we test the surface materia only, or is tufting considered bonded, sewed, or mechanically attached to underlying material?'<<<; Paragraph S4.1 of the standard lists mattress covers only, and thi would include the tufting since the tufting is incorporated into mattress covers. Consequently, we would treat the underlying material as separate, and only test mattress covers together with the tufting.; >>>2. 'If it is considered mechanically attached, how do we prepare specimen for test?'<<<; Since only mattress covers in this case must meet the requirements o the standard, the question of the tufting's 'mechanical attachment' to underlying material does not arise. Accordingly, you would prepare test specimens of mattress covers together with the tufting in the manner in which it appears in the vehicle as described in Paragraph S5.2 of the standard.; >>>3. 'The sleeping compartment is without a door and at the rear o both a 22 foot and a 25 foot motor home. Is this area considered in the occupant compartment?'<<<; The occupant compartment of a motor home includes any part designed t be occupied by persons. It would include the sleeping compartment irrespective of whether there is a door separating the sleeping compartment from the driver's compartment.; >>>4. 'Must all the material of the mattress, excluding the innersprin unit, pass the test independently, or is Article C of Section S4.2 about protective padding?'<<<; Paragraph S4.1 of the standard lists mattress covers only. Since S4. only refers to items listed in S4.1, it does not include the mattress stuffing.; Yours truly, Richard B. Dyson, Assistant Chief Counsel