Interpretation ID: 8529
Quality Control Manager
Horton Emergency Vehicles
500 Industrial Mile Road
Columbus, OH 43228
Dear Mr. Davis:
This is in response to your letter of April 13, 1993, requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 206 as it affects the rear doors of ambulances that your company manufactures. I apologize for the delay in responding.
You state that your ambulances have two rear doors, and that each has locking mechanisms that can be operated both from the outside and inside of the doors. Your specific question is whether you can eliminate the inside locking mechanism on one of the rear doors without violating Standard No. 206. The language in S4.1.3 of Standard No. 206 that you noted in your letter (i.e., "Each door shall be equipped with a locking mechanism with an operating means in the interior of the vehicle.") refers to side doors, but not to rear doors. Thus, your company's ambulances need not be equipped with locking mechanisms on each rear door.
I hope this information has been helpful. If you have any further questions feel free to contact David Elias of my office at the above address or by phone at (202) 366-2992.
Sincerely,
John Womack Acting Chief Counsel
ref:206 d: 7/27/93