Interpretation ID: 24393.rbm

Donald S. Litman, Esq.
The Mayerson Law Offices, P.C.
3540 Schuylkill Road
Spring City, PA 19475

Dear Mr. Litman:

This responds to your question as to whether plastic exterior door handles are prohibited by any Federal motor vehicle safety standards (FMVSSs). The short answer to your question is no, exterior plastic door handles are not prohibited under any of the safety standards.

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 FMVSSs. These standards specify safety performance requirements for motor vehicles and/or items of motor vehicle equipment. FMVSS No. 206, Door locks and door retention components, most closely addresses your question regarding exterior door handles. FMVSS No. 206 does not directly regulate either interior or exterior door handles. It does, however, impliedly require both interior and exterior door handles or other release mechanisms in its regulation of door locks (see generally, 49 CFR 571.206, S4.1.3 and S4.4.2). FMVSS No. 206 does not prohibit or require that the door handles or release mechanisms be composed of any particular material. Rather, it specifies performance requirements.

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
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d.6/24/02