Interpretation ID: 18170.wkm

Mr. M. Kikkawa
Mazda North American Operations (ESE)
1203 Woodridge Avenue
Ann Arbor, MI 48105

Dear Mr. Kikkawa:

This responds to Mazda's letter asking for an interpretation of Federal Motor Vehicle Safety Standard (Standard) No. 206, Door locks and door retention components, as it applies to sliding side doors. You ask what loads would be applied to such a door, and where on the door the loads would be applied.

Paragraph S4.3 of the standard provides: "The track and slide combination or other supporting means for each sliding door shall not separate when a total transverse load of 17,800 Newtons (4,000 pounds) is applied, with the door in the closed position."

The doors are tested to that requirement in accordance with S5.3, which specifies that: "Compliance with S4.3 shall be demonstrated by applying an outward transverse load of 8,900 Newtons (2,000 pounds) to the load-bearing members at the opposite edges of the door (17,800 Newtons (4,000 pounds) total). . . ."

You suggest that test loads should be applied at three positions on the door. Your letter enclosed drawings, Figures 1 and 2, depicting a sliding door on a van-like vehicle. Marked on figure 1 are: (a) the location on the door where the roller in the upper front edge of the door is located; (b) the location where the roller in the lower front edge of the door is located; and (c) the location of the center roller and door lock in the rear center edge of the door. You suggest on figure 2 that a test load of 1,000 pounds (lb.) should be applied at both the (a) and (b) locations and a load of 2,000 lb. applied at the (c) location.

The requirement in S4.3 applies to "the track and slide combination or other supporting means for each sliding door." Applying this to figure 1, we agree with you that S4.3 provides that the track and slide combination at locations (a) and (b) and the supporting means for the door at location (c) are required to withstand the 4,000 lb. applied load.

With regard how the load is applied to these positions, S5.3 requires that a load of 2,000 pound lb. be applied "to the load-bearing members at the opposite edges of the door." Locations (a) and (b) are at the opposite edge of the door from (c). NHTSA would test your door by applying a 2,000 lb. load to the front edge of the door at locations (a) and (b), and a 2,000 lb. load to the rear edge of the door at location (c). Instead of applying a 1,000 lb. load at (a) and (b) as you suggest, we would attach a bar between (a) and (b) and would apply the 2,000 lb. load to the center of the bar so as to ensure that the loads at attachment points (a) and (b) are nominally equal.

I hope this information is helpful to you. Should you have any questions or need additional information, feel free to contact Walter Myers of my staff at this address or at (202) 366-2992, or by fax at (202) 366-3820.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:#206
d.9/21/98