Interpretation ID: aiam3792
Vice President and General Manager
J. F. Enterprises
Inc.
Box 583
Wakarusa
IN 46573;
Dear Mr. Troxel: This responds to your recent letter to Mr. Steve Kratzke of my staff asking for a clarification of the requirements of Federal Motor Vehicle Safety Standard No. 302, *Flammability of Interior Materials* (49 CFR S571.302). Specifically, your company manufactures innerspring mattresses, some of which are used in motor vehicles. You noted that the mattress covers on those mattresses for use in motor vehicles must comply with the flammability requirements of Standard No. 302, and that you had interpreted the mattress cover to consist only of the covering applied over the finished mattress. Hence, under your interpretation, Standard No. 302 would not apply to the ticking used as the outside of the mattress. However, you were told by several ticking manufacturers that a recent decision by this agency stated that ticking used on mattresses for use in motor vehicles must also satisfy the flammability requirements of the standard. It is correct that the ticking must satisfy Standard No. 302's flammability requirements.; The mattress cover has been interpreted by this agency to include bot a covering put over a finished mattress and the permanent mattress ticking since Standard No. 302 became effective. Hence, the information that this was a recent decision by this agency is incorrect. For your information, I have enclosed a 1973 letter to the Recreational Vehicle Institute setting forth this interpretation over ten years ago.; Should you have any other questions about the applicability of Standar No. 302 to your products, please do not hesitate to contact Mr. Kratzke at this address or by telephone at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel