Interpretation ID: powerliftgate

Mr. Paolo Ivaldi
Fiat Auto R&D U.S.A.
39300 Country Club Drive
Farmington Hills, MI 48331-3473

Dear Mr. Ivaldi:

This responds to your letter of March 20, 2001, and to your telephone conversations with Katherine McDonough of my staff. I am pleased to have this opportunity to answer your question about Federal Motor Vehicle Safety Standard No. 118, "Power-Operated Window, Partition, and Roof-Panel Systems" (49 CFR section 571.118).

You explain that you are designing a power-operated liftgate. By liftgate, you mean the type of vertically-opening back door that is typically found on a sport utility vehicle or van. Your system would allow the user to open and close the liftgate either remotely or by pushing a button on the vehicle console.

With regard to the power-operated liftgate you are designing, you ask three questions. First, you ask whether Standard No. 118 applies to the operation of such power-operated liftgates. Next, assuming that FMVSS No. 118 applies, you ask whether a liftgate, which will operate only when the vehicle's ignition key is in the on position, will satisfy the requirements of FMVSS No.118. Finally, again assuming that FMVSS No. 118 applies, you ask whether the standard requires that you put "pinch sensors along the liftgate openings."

The answer to all of your questions is that FMVSS No. 118 does not apply to power-operated liftgates. Paragraph S2 of FMVSS No. 118 reads, in pertinent part, "this standard specifies requirements for power-operated window, partition, and roof-panel systems." The term partition refers to the type of interior retractable window that might be found in a limousine, and the term roof-panel refers to the type of retractable panels that are commonly known as sunroofs. Accordingly, since a liftgate is not a window, partition, or roof-panel, FMVSS No. 118 does not apply to its operation.

During your conversation with Ms. McDonough, you mentioned that you are voluntarily equipping the liftgate with obstacle sensors. These sensors are capable of detecting the presence of an obstacle in both directions, e.g., both opening and closing, and will stop the motion of the liftgate until the obstacle is removed. We appreciate your effort to reduce the likelihood of injuries caused by the inadvertent closing of a liftgate on an occupant.

Please note that your liftgate must comply with FMVSS No. 206 "Door Locks and Door Retention Components." There are no special exemptions for power doors. Accordingly, your liftgate must meet all of FMVSS No. 206's requirements for back doors. In addition, all other applicable safety standards must be met.

I hope this letter answers your questions. Should you have any further questions, please feel free to call Katherine McDonough at 202-366-2992.

Sincerely,

John Womack
Acting Chief Counsel

ref:118#206
d.5/23/01