Interpretation ID: nht80-2.11

DATE: 04/22/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: MPI, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This confirms your April 9, 1980, telephone conversation with Roger Tilton of my staff in which you asked whether a styrofoam board that lies beneath a layer of polyurethane foam would be required to comply with the flammability requirements of Standards No. 302, Flammability of Interior Materials.

As Mr. Tilton explained to you, the standard applies to seating components such as yours only to the extent that they fall within 1/2 inch of the occupant compartment air space. This requirement is specified in paragraph S4.2 of the standard. You indicated that your styrofoam board would not fall within 1/2 inch of the compartment because the polyurethane cover will always be thicker than 1/2 inch. Assuming this is true, your styrofoam board would not be required to comply with the standard.