Interpretation ID: aiam2202
5530 Wisconsin Avenue
Suite 1220
Washington
DC 20015;
Dear Mr. Crampton: This is in response to your letter of January 16, 1976, concerning cre cab doors for use on fire trucks, and the interpretation of Federal Motor Vehicle Safety Standard No. 206, *Door Locks and Door Retention Components*.; You asked two questions in your letter: >>>(1) Is it the intent of FMVSS 206 to actually address door hardwar for doors that are adjacent to a walkway and not a seat?<<<; Standard No. 206 is applicable to the type of vehicle that yo described. Paragraph S4 of the standard states that 'component on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard'. The standard does not require the door to be directly adjacent to a seat. The door on your vehicle leads directly 'into a compartment that contains one or more seating accommodations,' so the standard is applicable. The presence of a walkway is irrevelant. (sic); >>>(2) If the standard does apply would not the installation of a untested conventional door structure in place of a folding door result in a safer vehicle?<<<; The NHTSA hopes that manufacturers would install conventional hinge door structures instead of folding doors on fire trucks, if the hinged doors would result in producing safer vehicles. The cost of testing the components of hinged doors for purposes of Standard 206 should not be determinative of whether the manufacturer will install hinged doors or folding doors on the fire trucks. Rather, the safety of the firemen who must use the trucks should be the determinative factor.; You should be aware that the tests in Standard No. 206 are laborator tests of the components, and do not involve the vehicle as a whole. These component systems are generally available from suppliers and are already warranted as being in compliance with Federal standards. Therefore, the cost of using conventional hinged doors might not be as prohibitive as you had supposed.; Please contact us if we can be of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel