January—March 2020

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INDUSTRY ADVISOR

Harry Baergen was previously the Regulation Enforcement Officer for Transport Canada. Currently, he acts as the Compliance Review Program

F/CMVSS 302 “Flammability of Interior Materials (Part 2) By Harry Baergen – Autoregs Consulting NMEDA CRP COORDINATOR

(CRP) Coordinator for NMEDA. If you have any questions about the

flooring and plastics. However, test

Standard 302 has been severely

reports for combustible materials,

criticized for being too lenient,

such as seating material, are still

especially for being a horizontal

not readily available from suppliers.

test. Basically, the standard requires

Although, seat suppliers have been

that certain specified materials that

telling CRP that full test reports are

are within 13 mm (1/2 inch) of the

available if requested, CRP is finding

occupant compartment air space shall

this to be inaccurate.

not burn more than 102 mm (4 inches)

T

First, to revisit the preceding article

per minute when tested horizontally

test reports for F/CMVSS 302,

the adaptive vehicle industry, because

contents of this article, or about the NMEDA CRP, contact Harry Baergen at 778.888.2210.

his is an update to a previous article about difficulties NMEDA manufacturing

members (alterers) have in obtaining “Flammability of Interior Materials.”

for some background, the purpose of F/CMVSS 302 is to reduce death and injuries caused by vehicle fires. F/CMVSS 302 is often overlooked in an adaptive vehicle conversion does

in a burn cabinet according to the test procedure. This is a generous burn rate, but it is only intended to allow time for occupants to exit a burning vehicle. Although, in the adaptive vehicle industry, some moral

consideration might be given to

generally not been forthcoming. In

to the OEM vehicle as some other

the possibility of a disabled person

the meantime, CRP has conceded

industries do. However, F/CMVSS 302

requiring more time to exit a burning

to accept statements from adaptive

does apply to alterers of adaptive

vehicle in a crash.

vehicle manufacturers, in lieu of

vehicles and the standard must

test reports, for non-ignitable and

be considered when certifying an

self-extinguishing materials, such as

adaptive vehicle.

The preceding article was published in the 2014 summer issue of the Circuit Breaker and shortly after that, on September 01, 2014, the Compliance Review Program (CRP) began asking alterers for F/CMVSS 302 test reports. Since then, NMEDA member manufacturers have been making concerted efforts to obtain test reports from material suppliers, but proper test reports have

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NMEDA Circuit Breaker

not add as many flammable materials

...in the case of aftermarket seats, or

other flammable materials, a comprehensive, verifiable, F/CMVSS 302 test report should be demanded from the supplier as a condition of procurement. ”

The test procedure for standard 302 is comparatively simple and inexpensive. A vehicle is not required for the test –


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