Interpretation ID: nht70-1.44

DATE: 03/10/70

FROM: D. W. TOMS -- DIR., NHTSA; SIGNATURE BY ROBERT BRENNER

TO: Recreational Vehicle Institute, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 13, 1970 to the Administrator, in which you requested an interpretation of Standard 206, Door Locks and Door Retention Components, as applied to motor homes and chassis-mount campers. Specifically, you asked whether door components must conform to the requirements of the standard when the door is located across the width of the vehicle from a seating position.

The relevant language is in paragraph S4. of the standard:

"Side door components referred to herein shall conform to this standard if any portion of a 90-percentile two-dimensional manikin as described in SAE Practice J826, when positioned at any seating reference point, projects into the door opening area on the side elevation or profile view."

This language clearly covers, and was intended to cover, the situation that you describe. The phrase "projects into the door opening area on the side elevation or profile view" eliminates, in respect to the standard's application, any consideration of the lateral distance of the seating position from the door opening. The door components of vehicles you described in your letter must therefore conform to the standard.

We are pleased to be of assistance.