Interpretation ID: nht94-3.65

TYPE: INTERPRETATION-NHTSA

DATE: July 11, 1994

FROM: Paul Frink -- Engineering Manager, AVIONIC STRUCTURES, INC.

TO: Office of Chief Council, NHTSA

TITLE: Ref: Interpretation of 571.206 Standard No. 206; Door Locks and Door Retention Components. S4. Requirements.

ATTACHMT: Attached to letter dated 09/02/94 from John Womack to Paul Frink (A42; STD. 206)

TEXT: Avionic Structures, Inc. is in the process of manufacturing a door/door frame system that is specifically intended to be installed in a vehicle classified as a Recreational Motor Home.

The door/door frame system is located on the passenger side of the vehicle and directly across from the drivers seat. The location and use of this door is as the primary egress for the vehicle.

The passenger seat is in close proximity to this door, however, as shown on the diagram enclosed the passenger seat is behind the step area extending from the door opening into the coach.

The door/door frame assembly, as manufactured by Avionic Structures is installed into the side wall of the vehicle (motor home) and bolted into place by the vehicle manufacturer. The door/door frame assembly is thus a component part of the sidewall. Se e Dwg. 1.

The door hinging is located between the forward vertical post of the door and the forward vertical member of the frame. The locking and latching components are opposite the hinges on the trailing post of the door and frame. See Dwg. 2.

The double rotor latch and striker bolt are components purchased from Tri-Mark Corporation. These components have been subjected to the test requirements of SAEJ839-JUL92 static load testing. The report submitted by Tri-Mark Corporation to Avionic Stru ctures indicates their units met or exceeded these requirements. See enclosed data sheet from Tri-Mark.

Since the door we have described to you is the only egress for occupants and belongings, as generally used in the living quarters of a Motor Home, Avionic Structures feels it is important for us to understand what category (for testing requirements) this installation falls under.

We would appreciate a clarification as to the need for this door/door frame system to conform to a specific portion of DOT Standard No. 206.

Thank you in advance for your help and prompty reply.

DRAWINGS OMITTED