Interpretation ID: 6952
Design Engineer
Eberhard Manufacturing Co.
21944 Drake Road
Cleveland, Ohio 44136-6697
Dear Mr. Kuminski:
This responds to your letter of February 3, 1992 concerning Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components. You asked about the standard's test requirements for sliding doors on cargo vans (sections S4.3 and S5.3). Your three questions and the response to each follow.
1. I will need specifications on how to perform this test on a test fixture using the striker assembly and the door latch only.
Standard No. 206 "specifies requirements for side door locks and side door retention components including latches, hinges, and other supporting means, to minimize the likelihood of occupants being thrown from the vehicle as a result of impact." The standard's requirements for sliding doors are set forth in sections S4.3 and S5.3.
Section S4.3 specifies that the track and slide combination or other supporting means for each sliding door shall not separate when a total transverse load of 4,000 pounds is applied, with the door in the closed position. Section S5.3 states, "(c)ompliance with S4.3 shall be demonstrated by applying an outward transverse load of 2,000 pounds to the load bearing members at the opposite edges of the door (4,000 pounds total). The demonstration may be performed either in the vehicle or with the door retention components in a bench test fixture."
Under section S5.3, the same basic procedure is conducted whether the test is conducted in a vehicle or with the door retention components in a bench test fixture, i.e., an outward transverse load of 2,000 pounds is applied to the load bearing members at the opposite edges of the door (4,000 pounds total). The details of the procedure using a bench test fixture will necessarily vary for different designs of sliding doors, since the door retention components themselves vary. The test should be conducted in such a manner that the same loads are applied to the door retention components as would occur in a vehicle test.
You specifically asked about how to perform the test on a test fixture using the striker assembly and door latch only. I note that since the requirement in section S4.3 applies to the "track and slide combination or other supporting means" for a sliding door, the striker assembly and door latch of a sliding door are tested only if they are part of the supporting means for the door. I also note that the entire supporting means for a sliding door is tested under section S5.3 and not merely one part.
I have enclosed for your information a copy of a May 13, 1975 interpretation letter to Toyota (including the incoming letter) which discusses various demonstration test fixtures which might be used to test sliding doors under Standard No. 206.
2. What load must the system withstand in the primary locked position to pass the test?
3. Is there a load requirement that the system must withstand in the secondary locked position to pass the test?
Section S4.1.1 of Standard No. 206 requires hinged doors, other than cargo-type doors to have both a fully latched position and a secondary latched position. There is not a similar requirement for sliding doors. Section S4.3 requires only one test, with a total load of 4,000 pounds, for sliding doors. This test would be performed with the door latched.
I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel
Enclosures ref:206 d:3/30/92