Interpretation ID: aiam1904
Director/General Manager
Factory Representative Office
Toyota Motor Sales
U.S.A.
Inc.
1099 Wall Street West
Lyndhurst
NJ 07071;
Dear Mr. Nakajima: This is in response to your letter of March 17, 1975, requestin clarification of the requirement and demonstration procedure for sliding doors specified in Federal motor vehicle safety standard No. 206, *Door Locks and Door Retention Components*.; You have indicated that it is your understanding that derailment of th guide roller or track and slide combination is permissible under Standard No. 206 as long as door stoppers and door locks withstand the specified transverse load. This interpretation is correct. Standard No. 206 requires in S4.3 that the track and slide combination *or other supporting means* for each sliding door not separate when a transverse load of 4,000 pounds is applied, with the door in the closed position. Since the track and slide combination is not designed to bear loads at the closed position, derailment of the combination is of no consequence. Other supporting means must support the test load.; You have also outlined three demonstration procedures and asked whethe they 'fall within the intent' of S5.3 of Standard No. 206. While all three procedures might satisfy the literal requirements of S5.3, procedure 'C' most thoroughly implements the intent of Standard No. 206.; The bench test fixture described in 'A' is particularly troublesome. O the Toyota vehicle in question, resistance against a transverse load applied at the leading edge appears to depend heavily on the lock at the trailing edge. Since the resistance of this lock must be transmitted to the leading edge stoppers through the door itself, the door plays an important role in the performance of the entire system. Yet the rigid door described in 'A' would almost certainly behave differently than an actual door, in which case the test results would not demonstrate compliance with S4.3.; A similar problem exists with regard to procedure 'B', in that th rigid pillar employed might provide much more resistance to bending than the actual vehicle pillar. Bending of the pillar at the door's leading edge would substantially lessen the resistance to opening provided by the stoppers (B & C in your Fig. 1).; Standard No. 206 does not set out separate requirements for every doo design. Indeed, this standard was adopted in anticipation that most sliding doors would incorporate a track- and-slide combination as a supporting means. Where a different design is employed, as in this instance, procedure 'C' best fulfills the intent of the standard by providing the most authentic demonstration.; Please do not hesitate to write if we can be of further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel