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Interpretation ID: nht89-2.89

TYPE: INTERPRETATION-NHTSA

DATE: 08/31/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: MARK RECCHIA -- FIAT RESEARCH AND DEVELOPMENT U.S.A. BRANCH

TITLE: NONE

TEXT: Dear Mr. Recchia:

This responds to your telephone call asking about an apparent inconsistency between the requirements of S4.1 of Standard No. 302, Flammability of Interior Materials, and NHTSA's laboratory procedures for flammability compliance tests (June 1973). You as k whether the laboratory procedures are correct in specifying that all materials found in the vehicle occupant compartment must meet the flammability resistance requirements of the standard. I regret the delay in responding. The answer is no.

Paragraph S4.1 of Standard No. 302 sets forth a listing of the components of vehicle occupant compartments that must be certified as complying with the flammability resistance requirements of paragraph S4.3. Paragraph S4.1 includes a reference to "any o ther interior materials . . . that are designed to absorb energy on contact by occupants in the event of a crash." That paragraph represents a complete listing of all components in new vehicles that must comply with the flammability resistance requiremen ts. Any component not identified in paragraph S4.1 is not subject to those requirements.

Paragraph 10.1 of NHTSA's laboratory procedures also lists the components of vehicle occupant compartments that must meet Standard No. 302. That listing was intended to include only the components described in S4.1 of the standard, but inadvertently mak es a general reference to "[a]ny other materials" in the vehicle interior compartment (item number 19) without including the modifying clause, "that are designed to absorb energy on contact by occupants in the event of a crash." The modifying clause shou ld have been included, since Standard No. 302 applies only to the vehicle components identified in S4.1 of the standard.

Sincerely,