Interpretation ID: nht76-4.42

DATE: 02/25/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Byron A. Crampton

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 16, 1976, concerning crew cab doors for use on fire trucks, and the interpretation of Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components.

You asked two questions in your letter:

(1) Is it the intent of FMVSS 206 to actually address door hardware for doors that are adjacent to a walkway and not a seat?

Standard No. 206 is applicable to the type of vehicle that you described. Paragraph S4 of the standard states that "component on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard". The standard does not require the door to be directly adjacent to a seat. The door on your vehicle leads directly "into a compartment that contains one or more seating accommodations," so the standard is applicable. The presence of a walkway is irrevelant.

(2) If the standard does apply would not the installation of an untested conventional door structure in place of a folding door result in a safer vehicle?

The NHTSA hopes that manufacturers would install conventional hinged door structures instead of folding doors on fire trucks, if the hinged doors would result in producing safer vehicles. The cost of testing the components of hinged doors for purposes of Standard 206 should not be determinative of whether the manufacturer will install hinged doors or folding doors on the fire trucks. Rather, the safety of the firemen who must use the trucks should be the determinative factor.

You should be aware that the tests in Standard No. 206 are laboratory tests of the components, and do not involve the vehicle as a whole. These component systems are generally available from suppliers and are already warranted as being in compliance with Federal standards. Therefore, the cost of using conventional hinged doors might not be as prohibitive as you had supposed.

Please contact us if we can be of any further assistance.

YOURS TRULY,

TRUCK BODY AND EQUIPMENT ASSOCIATION, INC.

January 16, 1976

Richard B. Dyson, Asst. Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

The Fire Apparatus Manufacturers Division (FAMD) of the Truck Body and Equipment Association (TBEA) represents more than fifty manufacturers of fire apparatus, who in turn account for approximately 85% of the pieces of equipment sold within the United States.

Recently several FAMD members have questioned this office as to specific requirements of FMVSS 206 as applicable to fire apparatus equipped with crew cabs. The vehicles in question (see sketch) are generally produced on a commercial truck chassis by adding fire fighting equipment, a fire apparatus body, and finally - a crew cab which allows the vehicle to carry additional personnel.

From the sketch, it can be seen, that the crew cab doors open up to a walkway to the passenger compartment and not onto a designated seating position. The three designated seating positions furnished with the crew cab are set back into the compartment to allow personnel clothed (Illegible Words) and breathing apparatus to walk to their seat.

Section S4 of FMVSS 206 states that the standard does not apply to folding doors or doors that are designed to be easily attached and removed, and therefore when faced with the high costs of testing a few completed vehicles to FMVSS 206 or installing either folding doors or quick release hinges, the decision is simple - but inconsistent with our aim toward developing the best piece of fire apparatus possible.

With this dilema in mind, our questions are as follows:

1. Is it the intent of FMVSS 206 to actually address door hardware for doors that are adjacent to a walkway and not a seat?

2. If the standard does apply, would not the installation of an untested conventional door structure in place of a folding door result in a safer vehicle?

We would appreciate any additional comments that you may have concerning this situation.

Byron A. Crampton Manager of Engineering Services

* Notes

1. Crew cab doors are presently the folding type or equipped with quick disconnect hinges.

FIRE APPARATUS with CREW CAB

(Graphics omitted)