Interpretation ID: aiam0784
President
Resources Applications
Designs & Control
Incorporated
7045 Marcello Street
Paramount
CA 90723;
Dear Mr. Waldman: This is in response to your letter of July 21, 1972 requesting determination as to the applicability of Federal Motor Vehicle Safety Standard No. 206, *Door Locks and Door Retention Components*, to sleeper berth equipment manufactured for installation on truck tractors.; An amendment to Standard No. 206 was issued in January 1972 (37 F.R 284), which stated that the requirements of the Standard are applicable to any side door leading directly into a passenger compartment containing one or more seating accommodations.; From the information and photographs you provided, it appears tha although the sleeper berth equipment is a passenger compartment, it is designed as a completely separate unit not containing any seating accommodations, and would therefore be exempt from the requirements of Standard No. 206.; It should be noted, however, that if the sleeper berth equipment i installed in such a way that it is contiguous to the truck cab and can be entered by the driver from within the cab, then any side doors on the sleeper berth equipment would be side doors leading into a passenger compartment (the cab) containing seating accommodations and they would have to meet the requirements of the Standard.; For your information, I am enclosing a copy of this recent amendment t Standard No. 206.; Yours truly, Richard B. Dyson, Assistant Chief Counsel