Interpretation ID: nht93-7.13

DATE: October 7, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Karl-Heinz Ziwica -- General Manager, Environmental Engineering, BMW of North America, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 5/20/93 from Karl-Heinz Ziwica to Stephen P. Wood (OCC 8679)

TEXT:

This responds to your request for an interpretation regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 206, with respect to a new design for a door lock and latch mechanism that BMW is planning to introduce in the United States. It appears that your proposed door lock and latch mechanism would comply with FMVSS No. 206.

Based on information provided in your letter, the new locking mechanism will be placed on side rear doors, and will consist of a door handle that serves the dual function of acting as a door locking mechanism and door latch release. When the side door is locked, a rear seat passenger would pull the door handle once to disengage the locking mechanism. The passenger would have to pull the door handle a second time to open the side rear door.

Based on additional information received from a demonstration given to David Elias of my office, I understand that the side rear doors, themselves, cannot be individually locked by the rear passengers. The doors can be locked only when the driver or front seat passenger lock all the car doors via the vehicle's electronic locking mechanism. The internal mechanisms are located at the rear part of the driver's and front seat passenger's armrests located on the front doors, which are reached fairly easily by belted rear seat passengers. The door handle on the side rear door, as noted above, is the mechanism by which the locking mechanism is disengaged.

S4.1.3 requires that each door be equipped with a locking mechanism with an operating means in the interior of the vehicle. Your proposed operating means for engaging the locking mechanism in each door is inside the vehicle, even though the four individual door locking mechanisms are controlled by the two operating means located on the armrest on the side front doors. S4.1.3 requires only that the operating means for the locking mechanisms be located inside the vehicle, and does not require that each door have its own, independent operating means for engaging the locking mechanism. Thus, it would seem that your proposed locking mechanism complies with S4.1.3.

S4.1.3.2 requires that inside and outside door handles be inoperative when the locking mechanism is engaged. An issue concerning your system is whether the inside door handle is "inoperative" even though it can operate to disengage the door locking mechanism when the locking mechanism is engaged. We conclude the answer is yes. S4.1.3.2 is intended, in part, to reduce inadvertent door openings in a crash due to impact on or movement of inside door handles. Thus, "inoperative," as used in S4.1.3.2, refers to the operation of opening the door. When the locking mechanism is engaged, the door handle cannot open the door, which meets the requirement of S4.1.3.2.

I hope this information has been helpful. If you have any further questions, please feel free to contact Mr. Elias at the above address or by phone at (202) 366-2992.