Interpretation ID: aiam3731
R.V. Account Executive
Kinder Division
Congoleum Corporation
2323 South 17th Street
P.O. Box 1207
Elkhart
IN 46515;
Dear Mr. Scott: This responds to your letter to Mr. Kratzke of my staff, asking for a interpretation concerning Safety Standard No. 302, *Flammability of Interior Materials* (49 CFR S571.302). Specifically, you asked whether innerspring mattresses used in motor homes are subject to the requirements of that standard. You also asked for a definition of the term 'mattress cover.'; Section S4.1 of Standard No. 302 lists the components that are covere by the standard. That list states that mattress covers must comply with the standard's requirements, but not the innerspring mattress itself. Hence, the innerspring mattress with which you are concerned is not subject to the flammability requirements of Standard No. 302. As your letter noted, those mattress (sic) are subject to certain flammability requirements issued by the Consumer Product Safety Commission.; We have previously defined the term 'mattress cover' as including bot a cover that is used generally to enclose a mattress for cleanliness or sanitary purposes *and* the ticking permanently attached to the mattress to enclose the mattress filling or core. Both of these items would have to meet the requirements of Standard No. 302.; Should you have any further questions or need more information on thi subject, please contact Mr. Steve Kratzke of my staff at (202) 426- 2992.; Sincerely, Frank Berndt, Chief Counsel