Interpretation ID: 24204.rbm

Mr. Chad Compton
Monaco Coach Corporation
2700 S Nappanee Street
Elkhart, IN 46517

Dear Mr. Compton:

This responds to your letter requesting clarification of Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door retention components. Specifically, you have asked whether the load requirements for latch systems on the front entry door of a motor home can be reduced if the overall door latch system is composed of two, independently operating latch and striker assemblies. The answer is no.

By way of background, the National Highway Traffic Safety Administration (NHTSA) administers a statute requiring that motor vehicles manufactured for sale in the United States or imported into the United States be manufactured so as to reduce the likelihood of motor vehicle crashes and of deaths and injuries when crashes do occur. We refer to that statute as the Vehicle Safety Act. It is codified at 49 U.S.C. 30101, et seq.

One of the agency's functions under the Vehicle Safety Act is to issue and enforce FMVSSs. These standards specify safety performance requirements for motor vehicles and/or items of motor vehicle equipment. Manufacturers of motor vehicles must certify compliance with all applicable safety standards and permanently apply a label to each vehicle stating that the vehicle complies with all applicable FMVSSs.

FMVSS No. 206 specifies certain performance requirements for door retention components. Paragraph S4.1.1 applies to all hinged side doors, other than cargo-type doors. The paragraph specifies that each door latch and striker assembly shall be provided with two positions consisting of a fully latched position and a secondary latched position. S4.1.1 then specifies that each assembly meet minimum level of force requirements for longitudinal loads (S4.1.1.1), transverse loads (S4.1.1.2), and inertial loads (S4.1.1.3). Compliance with the first two of these requirements is demonstrated using the test procedure detailed in paragraph 5 of the Society of Automotive Engineers Recommended Practice J839, Passenger Car Side Door Latch Systems, June 1991 (SAE-J839). Compliance with the third requirement is demonstrated either by agency-approved tests or in accordance with paragraph 6 of SAE-J839.

Nothing in the standard prohibits a door latch system that consists of more than one latch and striker assembly. However, because S4.1.1 applies to each latch and striker assembly rather than to each door latch system, the force requirements for longitudinal, transverse, and inertial loading must be met for each latch and striker assembly provided when the latch is engaged in both its primary and secondary position.

Should you require any additional information or assistance, please contact Rebecca MacPherson, of my staff, (202) 366-2992 or at the address given above.

Sincerely,
Jacqueline Glassman
Chief Counsel
ref:206
d.5/13/02