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Interpretation ID: 23604



    Dietmar K. Haenchen, Process Leader
    Safety Affairs and Vehicle Testing
    Volkswagen of America
    3800 Hamlin Road
    Auburn Hills, MI 48326


    Dear Mr. Haenchen:

    This responds to your letter asking whether a voluntarily-provided interior trunk release on the rear door of a hatchback triggers a requirement in our door lock standard for a locking mechanism. The answer is yes.

    The rear door of a hatchback is excluded from the requirements of Federal Motor Vehicle Safety Standard No. 401, "Interior Trunk Release." Standard No. 401 requires passenger cars with a trunk compartment to have an interior trunk release. In response to petitions for reconsideration of the final rule establishing the standard, we amended the standard to specifically exclude passenger cars with a back door (66 FR 43113,

    August 17, 2001). We defined the term "back door" as: "a door or door system on the back end of a passenger car through which cargo can be loaded or unloaded. The term includes the hinged back door on a hatchback or a station wagon." (Emphasis added.) Thus, the hinged back door on a hatchback is not required to have an interior "trunk release" mechanism.

    You wish to voluntarily provide an interior release mechanism, but ask whether the mechanism would be required to have a locking mechanism under our door lock standard, Standard No. 206. S4.4.2 of Standard No. 206 states:

      Each back door system equipped with interior door handles or that leads directly into a compartment that contains one or more seating accommodations shall be equipped with a locking mechanism with operating means in both the interior and exterior of the vehicle. When the locking mechanism is engaged, both the inside and outside door handles or other latch release controls shall be inoperative.

    The question you present is whether the interior release is an "interior door handle" under Standard No. 206. The standard does not define the term "interior door handle." However, the phrase "door handles or other latch release controls" in the last sentence of the passage quoted above from S4.4.2 shows that "door handles" includes "door latch release controls" generally. See also the preamble of the final rule extending the requirements of Standard No. 206 to back doors (60 FR 50124, 50130, September 28, 1995):

      NHTSA acknowledges that the back doors of some vehicles so equipped [with an interior door handle] are designed for loading and unloading cargo rather than passengers. Nevertheless, sometimes those doors are also used for ingress and egress of back seat occupants. Therefore, if doors designed primarily for loading and unloading cargo lack an interior door handle, no door lock is required. If an interior door handle is present, this rule requires a means for making the door handle (a door release mechanism) inoperative when the locking mechanism is engaged. (Emphasis added.)

    We recognize the opposing purposes of Standard No. 206 and No. 401 regarding containment of vehicle occupants. Standard No. 206's intent is to retain occupants. It requires a door lock on the back door of hatchbacks with interior door handles or that leads directly into a passenger compartment to reduce the likelihood of occupants being ejected through the door in a crash. The agency estimated in the September 1995 final rule that the back door of hatchbacks is about three times as likely to open as one of the front side doors and seven to eight times as likely to open as one of the rear side doors in a crash, resulting in 147 fatalities and 189 serious injuries annually from ejections through the back door of hatchbacks, tailgates, and other back doors. Conversely, Standard No. 401's intent is to facilitate occupant release. Yet, the Expert Panel on Trunk Entrapment, which was formed to study the problem of trunk entrapment, did not address hatchbacks, nor were there any data presented to the panel indicating that persons had died as a result of their being inadvertently or intentionally locked in the rear of hatchbacks. Based on this, we conclude that Standard No. 206's interest in occupant containment should prevail.

    In sum, we appreciate that you want to voluntarily provide a safety device on your hatchbacks. Since, on hatchbacks, the interior release is not required by Standard No. 401, the hatchback does not have to meet that standard's requirements. However, back doors are regulated, and Standard No. 206 requires a back door with an interior door handle (or door release mechanism or latch release control) to have a locking mechanism.

    If you have any further questions, please contact Mr. Dion Casey in my office at (202) 366-2992.

    Sincerely,

    John Womack
    Acting Chief Counsel

    ref:401
    d.3/4/02