Interpretation ID: aiam0421
Recreational Vehicle Institute
Inc.
Suite 406
1140 Connecticut Avenue
N.W.
Washington
DC 20006;
Dear Mr. Humphreys: This is in response to your letter of July 27, 1971, in which yo raised a question concerning the application of Standard 206 to doors on recreational vehicles.; Standard 206, *Door Locks and Door Retention Components*, states tha 'Side door components referred to herein shall conform to this standard if any portion of a 90-percentile two-dimensional manikin as described in SAE Practice J826, when positioned at any seating reference point, projects into the door opening area on the side elevation or profile view.' The term 'seating reference point' corresponds to a 'designated seating position,' which is defined as 'any plan view location intended by the manufacturer to provide seating accommodations while the vehicle is in motion, for a person at least as large as a fifth percentile adult female, except auxiliary seating accommodations such as temporary or folding jump seats.' The question you asked is whether a seating accommodation that the manufacturer labels as 'not for use while the vehicle is in motion' may be disregarded in determining which vehicle doors must comply under the Standard 206 provision quoted above.; The relevant question is whether the seating position in question i 'intended by the manufacturer to provide seating accommodation while the vehicle is in motion.' While Standard 207 will require all seats intended by the manufacturer not to be used while the vehicle is in motion to be so labeled, it does not necessarily follow that the label will be accepted in all cases as conclusive evidence of the manufacturer's intent. The design of the seat and its location in the vehicle must also be considered. As an example, if it were found that a manufacturer had previously intended that a particular seat be used while the vehicle is in motion, and that he now attached the label merely to evade the Standard 206 requirement without changing his design, the application of Standard 206 to the vehicle would not be barred. The ultimate question in such cases is whether the label clearly is in accord with the manufacturer's intent, in light of all the facts.; The above statement is our general position on the application o Standard 206, in answer to your question. It is not intended to change the interim agreements that we made with respect to the current Standrad 206 compliance problems of some of your member manufacturers.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel