Interpretation ID: 24365-2.rbm

Ms. Kimberly Boucher
Spartan Motor Chassis, Inc.
1165 Reynolds Road
Charlotte, MI 48813

Dear Ms. Boucher:

This responds to your letter asking whether fire trucks are required to have side door locks that meet the requirements of Federal motor vehicle safety standard No. 206, Door locks and door retention components (FMVSS No. 206). Your question is addressed below.

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 agencys functions under the Vehicle Safety Act is to issue and enforce Federal motor vehicle safety standards. These standards specify safety performance requirements for motor vehicles and/or items of motor vehicle equipment. FMVSS No. 206, which generally regulates door latches, hinges and locks, applies to passenger cars, multipurpose passenger vehicles, and trucks.

In your letter, you requested NHTSA to make a determination that a fire truck is an incomplete truck rather than a multi-passenger vehicle. You also asked whether it is permissible to have the Society of Automotive Engineers (SAE) assign a unique vehicle identifier for an incomplete truck,^[1] and whether such an identifier would exempt the vehicle from the side door lock requirements of FMVSS No. 206. In a follow-up conversation with a member of my staff, you clarified that your concern was whether the incomplete vehicles manufactured by your company are trucks or multipurpose passenger vehicles, not whether the vehicle was incomplete or finally manufactured.

NHTSA defines vehicle types according to their particular attributes in 49 CFR 571.3. A multipurpose passenger vehicle is defined as a "motor vehicle with motive power, except a low-speed vehicle or trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation." A truck is defined as a "motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special purpose equipment."

The Vehicle Safety Act places the responsibility for classifying a particular vehicle in the first instance on the vehicle's manufacturer. NHTSA does not approve or endorse any vehicle classifications before the manufacturer itself has classified a particular vehicle. NHTSA may examine the appropriateness of the manufacturer's classification in the context of an enforcement action.

While we can provide opinions about vehicle classification, you do not provide sufficient information in your letter to offer a specific opinion. I note, however, that we would generally expect vehicles commonly referred to as fire trucks to be considered trucks under our regulations, since they are designed primarily for the transportation of firefighting equipment. It is possible that a vehicle operated by a fire department that is designed primarily to transport passengers rather than specialized equipment could be characterized as a multi-purpose vehicle.

As to your question regarding the requirements for side door locks on trucks, I note that the response depends on what type of door the truck is equipped with. FMVSS No. 206 applies to all doors other than folding doors, roll-up doors, doors designed to be easily attached to or detached from the vehicle, and doors equipped with a wheelchair lift that is attached to an alarm system. These doors are excluded from the standard pursuant to S4(c). Additionally, FMVSS No. 206 only regulates the components on side doors that do not fit into one of these excluded categories if the doors lead directly into a compartment that contains one or more seating accommodations (see S4(a)). The standard also specifies requirements for back doors (S4.4). However, these requirements only apply to passenger cars and multipurpose passenger vehicles.

FMVSS No. 206 requires categories of side doors to meet differing requirements depending on where the door is located and how it is attached to the vehicle. The requirements for hinged side doors other than cargo doors are found in S4.1, while the requirements for cargo doors are found in S4.2. Sliding side doors are addressed by S4.3. Of these categories of side doors, only hinged side doors are required to have door locks.

Under S4.1.3, door locks, all hinged side doors covered by the standard must be equipped with a locking mechanism that can be operated from the interior of the vehicle. Additionally, S4.1.3.1, side front door locks, requires all side front doors to have a lock that prevents the door from being opened from the outside of the vehicle when the door lock is engaged.

S4.1.3.2, side rear door locks, requires side rear doors that when the locking mechanism is engaged both the outside and inside door handles or other latch release mechanisms be inoperative. However, S4.1.3.2 does not apply to trucks; it only applies to passenger cars and multipurpose passenger vehicles. Thus, if the vehicle in question is a truck, it does not need to meet this particular requirement.

I note that under S4.4.2, door locks, each back door system covered by the standard that is equipped with interior door handles, or that leads directly into a compartment with one or more seating accommodations must have a locking mechanism that can be operated from both the inside and the outside of the vehicle. Additionally, when the locking mechanism is engaged, both the inside and outside door handles must be inoperative. However, as noted earlier, FMVSS No. 206's requirements for back doors apply only to passenger cars and multipurpose passenger vehicles and not to trucks.

As a final note, our records indicate that your company already has a vehicle identifier for trucks. Accordingly, there is no need to request the SAE to come up with a unique identifier for any fire trucks that you manufacture.

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

ref:206

d.8/2/02

^[1] The first 3-6 characters (depending on the size of the vehicle manufacturer) of a vehicle's vehicle identification number (VIN) are assigned by the SAE and identify the vehicle manufacturer and type. For more detailed information on VINs, please refer to 49 CFR 565.