Interpretation ID: 10177
Engineering Manager
Avionic Structures, Inc.
1429 North State College Boulevard
Anaheim, CA 92806
Dear Mr. Frink:
This responds to your letter and telephone call asking several questions about Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door Locks and Door Retention Components (49 CFR 571.206).
Your letter stated that your company manufactures a door and frame system designed for installation on a "recreational motor home," which you described as a self-propelled, self-contained recreational vehicle seating six and with a gross vehicle weight rating of under 10,000 pounds. The door system is installed on the right front side of the vehicle and is the primary means of ingress/egress. You stated that the door's latch/striker assembly is purchased from Tri-Mark Corporation, and that Tri-Mark assures you that the latch/striker assembly conforms to the requirements of FMVSS No. 206. You ask what the classification of the vehicle would be and whether FMVSS No. 206 would apply to the door in question.
By way of background information, 49 U.S.C. 30101, et seq. authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. The statute establishes a self-certification system in which manufacturers certify that their products comply with all applicable FMVSSs. This agency ensures compliance by purchasing vehicles and/or equipment in the retail market and testing them as set forth in the applicable standards. If the vehicle or equipment is found to meet the requirements of the standards, no further action is taken. If the vehicle or equipment fails to meet the standards, the manufacturer is responsible for correcting the noncompliance(s) at no cost to the purchaser. NHTSA also investigates defects relating to motor vehicle safety. If a manufacturer or NHTSA determines that a safety-related defect exists, the manufacturer must notify purchasers of its product and remedy the defect free of charge.
For the purposes of the FMVSSs, NHTSA classifies motor vehicles as passenger cars, multipurpose passenger vehicles (MPVs), trucks, buses, motorcycles, and trailers. From your description, the vehicle concerned would be classified as an MPV, which is defined in the definitions section of our FMVSSs (49 CFR 571.3; see enclosed) as a motor vehicle "designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off- road operation."
You first ask about the classification of the vehicle and whether FMVSS No. 206 would apply. FMVSS No. 206 (copy enclosed) applies to passenger cars, MPVs and trucks. Since the vehicle on which your door and frame system will be installed is an MPV, the standard would apply to the vehicle. The standard requires that, with certain exceptions not applicable here, components on any side door leading directly into a compartment containing one or more seating accommodations must comply with the requirements of the standard (see S4 of FMVSS No. 206). The door in question meets this description of S4. According to your letter, there is a step area extending from the door opening into the coach and the passenger seat closest to the door is behind this step area. The presence of the step area does not negate the fact that the door in question leads directly into a compartment that contains passenger seating accommodations. Thus, the components of the door must comply with the requirements of FMVSS 206.
To clarify your understanding of the applicability of FMVSS No. 206, the standard applies to new completed vehicles. Therefore, it would be the vehicle manufacturer who would "certify" compliance with the standard, not the various manufacturers of the components of the door lock system. Sometimes the vehicle manufacturer will rely on the assurances of the suppliers, such as Avionic and Tri-Mark, that the components conform to the requirements of the applicable standards, in making the certification to FMVSS No. 206. However, the vehicle manufacturer is ultimately responsible for ensuring that the vehicle complies with FMVSS No. 206, and therefore must determine whether those assurances are bona fide.
Also enclosed for your information are fact sheets issued by this agency entitled "Information for New Manufacturers of
Motor Vehicles and Motor Vehicle Equipment" and "Where to Obtain NHTSA's Safety Standards and Regulations," respectively. I hope this information is helpful to you. Should you need any additional information or have any further questions, please feel free to contact Mr. Myers of my staff at this address or at (202) 366-2992.
Sincerely,
John Womack Acting Chief Counsel
Enclosures
ref:206 d:9/2/94 Please note that the "National Traffic and Motor Vehicle Safety Act" and the "Motor Vehicle Information and Cost Savings Act" to which the information sheet refers have recently been recodified in Title 49 of the United States Code. This means that the citations used in the information sheet are outdated; however, the substantive requirements described in the sheet have not changed.