Interpretation ID: aiam4288
Manager
Environmental Engineering
BMW of North America
Inc.
Montvale
NJ 07645;
Dear Mr. Ziwica: This letter concerns your request for an interpretation of Federa Motor Vehicle Safety Standard No. 206, *Door Locks and Door Retention Components*, as it applies to the antitheft device BMW intends to install on the Carline 7 passenger car line for model year 1988. We apologize for the delay in responding to your inquiry.; On October 9, 1986, NHTSA published a notice in the Federal Registe granting BMW's petition for an exemption from the marking requirements of the vehicle theft prevention standard, based on its determination that an effective antitheft device will be installed on those lines as standard equipment. (51 FR 3633.) However, because NHTSA wished to further consider the compliance of the double- lock aspect of the central locking system with Standard No. 206, we granted the petition while reserving decision on that issue. We have completed our evaluation of the double-lock system and have determined it is permitted by the standard.; In its petition for exemption from the marking requirements of th Theft Prevention Standard, BMW described an antitheft device which, among other things, prevents entry into the vehicle by affecting the door locks in the following manner:; >>>The inside locking mechanism operating means is a vertical plunge on each door, and the plungers on the front doors override the two rear door plungers. To prevent locking the keys in the car upon exiting, the front doors can only be locked with a key. For Convenience, this also locks all other doors, if they are open at the time of locking, they lock when closed.<<<; >>>The locks in the front doors have three-positions cylinders - off 45 degrees, and 90 degrees. Upon exiting, if the key is turned 45 degrees and removed from the lock, the doors, trunk and gas filler door are locked. If, however, the key is rotated 90 degrees and removed, the car's burglar alarm is armed and the doors are 'double locked', after the plungers move downward, the central locking system is deactivated and the door locks are mechanically inhibited. Thus locked, neither an outside nor inside handle, nor a locking plunger can be used to unlock a door - the doors can only be unlocked and the alarm disarmed using a key in a front door lock... Disconnecting the battery does not unlock the doors or change the 'double locked' mode... In the event of an accident, an inertia switch automatically unlocks all doors.<<<; The requirements of Standard No. 206 for door locks are as follows: >>>S4.1.3 Door locks. Each door shall be equipped with a lockin mechanism with an operating means in the interior of the vehicle.<<<; >>>S4.1.3.1 Side front door locks. When the locking mechanism i engaged, the outside door handle or other outside latch release control shall be inoperative.<<<; >>>S4.1.3.2 Side rear door locks. In passenger cars and multipurpos passenger vehicles, when the locking mechanism is engaged both the outside and inside door handles or other latch release controls shall be inoperative.<<<; The standard was amended on April 27, 1968, to include the door loc requirements described above. An objective of the amendment was to ensure retention of occupants within the vehicle during and subsequent to an impact by reducing inadvertent door openings due to impact upon or movement of inside or outside door handles, and to afford occupants of the rear of a vehicle a method of unlocking the rear door from inside the vehicle (i.e., a reasonable means of escape) in the postcrash phase of an accident.; Your inquiry raises the issue of the permissibility under S4.1. through S4.1.3.2 for negating the capability of the operating means to disengage requisite door locking mechanisms. As explained below, based on our review of the purpose of Standard No. 206 and past NHTSA interpretations of the standard, we conclude that the standard prohibits only additional locking systems which interfere with the capability of the operating means to *engage* the locking system required by the standard. Since, according to your letter of September 24, 1986, BMW's double-lock feature does not interfere with the interior operating means' engagement of the required door locks, the secondary locking system is permitted.; The answer to your question about the double lock system is dependen on whether the system interferes with an aspect of performance required by Standard No. 206. We have determined that the answer is no, because the requirements of S4.1.3.1 and S4.1.3.2 of the standard are written in terms of what must occur when the required locking system is engaged and impose no requirements for the effects of disengaging the system. Thus, the aspect of performance required by S4.1.3 for the interior operating means for the door locks is that it be capable only of *engaging* the required door locking mechanisms. The aspect of performance required by S4.1.3.2 for door locks on the rear doors is that the inside and outside door handles be inoperative when the locking mechanism is *engaged.* Since we have determined that S4.1.3 through S4.1.3.2 do not address the effects of disengaging the required door locks, we conclude that the required aspect of performance in S4.1.3 for door locking mechanisms is that the interior operating means be capable only of engaging the locks. We thus conclude that the standard permits an additional door locking device which might interfere with the disengagement of the required locking system. The additional system, however, must *not* interfere with the capability of the operating means to engage the required door locks.; In determining that the performance requirements of Standard No. 20 address only the effects of engaging the required door locks, we noted that the purpose of the standard is to 'minimize the likelihood of occupants being thrown from the vehicle as a result of impact.' Throughout the rulemaking history of the standard, NHTSA has limited application of the standard's performance requirements only to doors that are provided for the purpose of retaining the driver and passengers in collisions. Because the standard is narrowly focused on occupant retention in a vehicle and specifies no performance requirements for occupant egress, we concluded that there is no requirement in the standard that prohibit a device which negates the capability of the inside operating means for the door locks to disengage the locks, provided that the device does not interfere with the engagement of the required door locking system.; This letter interprets Standard No. 206 in a manner that clarifies pas agency statements on issues raised by secondary locking systems. To the extent that the statements contained herein conflict with interpretations issued in the past, the previous interpretations are overruled.; Sincerely, Erika Z. Jones, Chief Counsel