Interpretation ID: aiam2840

Mr. Irving A. Cohen, Goulston & Storrs, One Federal Street, Boston, MA, 02110; Mr. Irving A. Cohen
Goulston & Storrs
One Federal Street
Boston
MA
02110;

Dear Mr. Cohen: This is (sic) responds to your May 26, 1978, letter asking severa questions about the applicability of Standard No. 302, *Flammability of Interior Materials*, to your client, a fabric manufacturer.; In your first question, you ask whether the National Highway Traffi Safety Administration (NHTSA) alone regulates the flammability of seat covers or whether other agencies are involved. We know of no other agency involved in the regulation of motor vehicle seat covers.; Your second question asks whether the manufacturer of the fabric or th manufacturer of the vehicle or seat cover would be responsible for compliance with the standard. Since Standard No. 302 is a vehicle standard, the manufacturer of the vehicle would be responsible for ensuring compliance with it, not the manufacturer of the fabric. For replacement seat covers, the installer of those covers, if it is a repair business, manufacturer, or dealer, would be required to ensure that it was not rendering inoperative compliance of the original seat covers with Standard No. 302 and would be responsible for installing only complying seat covers.; Your final question asks who is responsible for recalls and othe agency requirements, the vehicle manufacturer or the fabric manufacturer. Once again, since this is a vehicle standard, the vehicle manufacturer must comply with our requirements, not the fabric manufacturer. In conclusion, your client as a manufacturer of fabric is not responsible for compliance with the agency's flammability standard or the recall and remedy regulations.; Sincerely, Joseph J. Levin, Jr., Chief Counsel