Interpretation ID: aiam4290
Jaguar Cars
Inc.
600 Willow Tree Road
Leonia
New Jersey 07605;
Dear Ms. Black: This responds to your December 11, 1986 to me concerning Federal Moto Vehicle Safety Standard No. 206, *Door Locks and Door Retention Components*. I apologize for the delay in responding. You ask whether we interpret Standard No. 206 to permit installation of a particular type of door locking system which you referred to as a 'child safety lock.' The answer to your question is yes.; You explain that a 'child safety lock' is a special locking syste installed in addition to the locking system mandated by Standard No. 206. You state that the required locking system (hereinafter referred to as 'the primary locking system') is operated by a vertical plunger located in the door top trim roll (window sill). The child safety lock (which I will refer to as a 'secondary locking system') consists of a lever that is located in the shut face of the rear door which can only be reached when the door is open. When the lever is set in the 'active' position, it renders the inside rear door handle incapable of opening the door. The outside door handle is operative and can be used to open the door.; The requirements of Standard No. 206 for door locks are as follows: >>>S4.1.3 Door locks. Each door shall be equipped with a lockin mechanism with an operating means in the interior of the vehicle.<<<; >>>S4.1.3.1 Side front door locks. When the locking mechanism i engaged, the outside door handle or other outside latch release control shall be inoperative.<<<; >>>S4.1.3.2 Side rear door locks. In passenger cars and multipurpos passenger vehicles, when the locking mechanism is engaged both the outside and inside door handles or other latch release controls shall be inoperative.<<<; As you know, the standard was amended on April 27, 1968, to include th door lock requirements described above. An objective of the amendment was to ensure retention of occupants within the vehicle during and subsequent to an impact by reducing inadvertent door openings due to impact upon movement of inside or outside door handles. Other objectives were to protect against children opening rear door handles, and to afford occupants of the rear of a vehicle a method of unlocking the rear door from inside the vehicle (i.e., a reasonable means of escape) in the postcrash phase of an accident.; Your inquiry raises the issue of the permissibility under S4.1. through S4.1.3.2 for negating the capability of the interior latch release controls (door handles) to operate the door latches when the door locking mechanism is disengaged. As explained below, based on our review of the purpose of Standard No. 206 and past agency interpretations of the standard, we conclude that the standard prohibits only secondary locking systems which interfere with the *engagement* of the primary locking system. Since your child locking systems do not interfere with the manner in which the primary locking system engages, their installation on the vehicles you manufacturer is permitted.; The answer to your question about the child locking systems i dependent on whether the systems interfere with an aspect of performance required by Standard No. 206. We have determined that the answer is no, because the requirements of S4.1.3.1 and S4.1.3.2 are written in terms of what must occur when the primary system is engaged and impose no requirements regarding the effects of disengaging the system. Thus, the aspect of performance required by S4.1.3 for the interior operating means for the door locks is that it be capable only of *Engaging* the required door locking mechanisms. The aspect of performance required by S4.1.3.2 for door locks on the rear doors is that the inside and outside door handles be inoperative when the locking mechanism is *engaged*. Since we have determined that S4.1.3.1 and S4.1.3.2 do not address the effects of disengaging the required door locks--i.e., S4.1.3.2 does not require that the inside rear door handles be operative (capable of releasing the door latch) when the required locking system is disengaged--a child locking system may be provided on a vehicle if it does not negate the capability of the door lock plunger (the operating means) to engage the door locks.; While the agency stated in its April 1968 notice amending Standard No 206 that one purpose of requiring an interior means of operating door locks was to allow a reasonable means of escape for vehicle occupants, the agency did not go further in facilitating escape by also including a provision to require in all circumstances that door handles be operative when the primary locking system are disengaged. Since the agency could easily have included such a provision to address this reverse situation, but did not do so, the implication is that the agency did not intend to impose requirements regarding that situation. In fact, the notice included a contemporaneous interpretation that the standard permits a secondary locking device which rendered the inside rear door handle inoperative even when the primary locking mechanism was disengaged. This affirms that NHTSA did not even intend to impose a requirement that the handles always be operative when the primary locking mechanism is disengaged.; In determining that the performance requirements of Standard No. 20 address only the effects of engaging the required door locks, we noted that the purpose of the standard is to 'minimize the likelihood of occupants being thrown from the vehicle as a result of impact.' Throughout the rulemaking history of the standard, NHTSA has limited application of the standard's performance requirements only to doors that are provided for the purpose of retaining the driver and passengers in collisions. Because the standard is narrowly focused on occupant retention in a vehicle and specifies no performance requirements of occupant egress, we concluded that there is no requirement in the standard that prohibits a device which negates the capability of the inside operating means for the door locks to disengage the locks, provided that the device does not interferer with the engagement of the required door locking system.; Another issue related to your inquiry is whether the location of th operating means for the child locks is regulated by Standard No. 206. We have determined that the answer is no. Secondary locking mechanisms discussed in the final rule adopting the door lock requirements and in past agency letters all were designed so that the operating means for the secondary mechanism was inaccessible when the door was closed. In none of those documents did the agency take exception to that location of the operating means, much less suggest that those means, like the means for the primary locking mechanism, must be located in the vehicle's interior.; This letter interprets Standard No. 206 in a manner that clarifies pas agency statements concerning issues raised by secondary locking systems such as 'child safety locks.' To the extent that the statements contained herein conflict with interpretations made by NHTSA in the past, the previous interpretations are overruled.; Please contact my office if you have further questions. Sincerely, Erika Z. Jones, Chief Counsel