Interpretation ID: nht72-3.23

DATE: 07/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Resources Applications, Designs & Control, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 21, 1972 requesting a determination as to the applicability of Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components, to (Illegible Words) equipment manufactured for installation on truck tractors.

An amendment to Standard No. 206 was issued in January 1972 (37 F.R. 284), which stated that the requirements of the Standard are applicable to any side door leading directly into a passenger compartment containing one or more seating accommodations.

From the information and photographs you provided, it appears that although the (Illegible Words) equipment is a passenger compartment, it is designed as a completely separate unit not containing any seating accommodations, and would therefore be exempt from the requirements of Standard No. 206.

It should be noted, however, that is not sleeper berth equipment is installed in such a way that it is (Illegible Word) to the truck cab and can be (Illegible Word) by the driver from within the cab, than any side doors on the sleeper berth equipment would be side door leading into a passenger compartment (the cab) containing seating accommodation and they would have to meet the requirements of the Standard.

For your information, I am enclosing a copy of this (Illegible Words) to Standard No. 206.