Interpretation ID: aiam0916
Chief Chemist
Textile Rubber & Chemical Company
14241 East Alondra Boulevard
La Mirada
CA
90638;
Dear Mr. Pomeroy: This is in response to your letter of November 3, 1972, to our Regiona Administrator, Region IX, San Francisco, California office concerning the test procedures of Federal Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; You state that in the test procedure described in paragraph S5.3, yo see 'no room for the bunsen burner to stand' when a carpet specimen 14 inches long is in the center 'of all inside dimensions of the box.' The source of your interpretive difficulty with respect to the test procedure appears to be your assumption that the carpet specimen should be placed in the center 'of all inside dimensions' of the test cabinet. The test procedure only specifies that the specimen be mounted 'in a horizontal position, in the center of the cabinet.'; The standard does not specify a particular means for positioning th bunsen burner tube or for positioning the test specimen above the top of the burner tube, because there are a variety of satisfactory means used for this purpose. The specimen holder should be in the center of the cabinet with the closed end contacting the end of the cabinet.; Since the bunsen burner is used with the air inlet shutoff, it is i effect a 3/8 inch inside diameter tube with a metering valve. There is no reason why such a device, without the bunsen burner base, may not be permanently mounted inside the cabinet for convenience.; You also ask whether bottled propane gas can be substituted for natura gas. The answer to this question is that your choice of what gas to use is a matter within your own discretion. The standard simply specifies that for our compliance testing, the gas supplied to the burner will have 'a flame temperature equivalent to that of natural gas.'; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;