Interpretation ID: aiam2088
Assistant Vice President
Mercedes-Benz of North America
Inc.
P.O. Box 350
Montvale
NJ 07645;
Dear Mr. Gerth: This is in response to your letter dated May 7, 1975, regarding a apparent conflict between the inertia load requirement of Standard 206, *Door Locks and Door Retention Components*, (49 CFR 571.206, S4.1.1.3) and the test procedure incorporated by S5.1.1.2, Paragraph 5 of SAE Recommended Practice J839b. I regret the delay in responding, your letter was mistakenly routed to our Docket Section and only recently came to our attention.; The answer to your question is that the requirement of S4.1.1. controls. It is sufficient that the door latch system withstand a 30g load only in the transverse and longitudinal directions. The system is not required to withstand this load in 'any direction.'; You asked further about the acceptability of centrifuge testing t demonstrate compliance with the inertia load requirement of Standard 206. Although S5.1.1.2 mentions 'approved tests,' NHTSA has consistently refused to approve or supervise the methods manufacturers use to test to the standard. Any government inertia load compliance testing will be done in accordance with paragraph 5 of SAE Recommended Practice J839b. Mercedes-Benz, of course, may employ any method it chooses to ensure compliance with this and other safety standards, as long as the product complies. We recognize that centrifuge testing may be highly useful in a variety of applications, and I do not by any means want to discourage innovations in developmental or compliance testing.; Yours truly, Richard B. Dyson, Assistant Chief Counsel