Interpretation ID: nht79-1.10

DATE: 12/05/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Theodore Bargman Company

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Edward F. Tannery Theodore Bargman Company 129 Industrial Avenue Coldwater, Michigan 49036

Dear Mr. Tannery:

This responds to your recent letter asking whether doors on aftermarket top covers for American Motors Jeeps would have to comply with Safety Standard No. 206, Door Locks and Door Retention Components.

Safety Standard No. 206 applies to passenger cars, trucks and multipurpose passenger vehicles, which would include Jeeps. The standard applies only to completed vehicles, however, and not to aftermarket motor vehicle equipment. Therefore, the doors on aftermarket Jeep top covers would not have to have locks. Further, doors on new Jeep vehicles would also not have to comply with the standard if they are "designed to be easily attached to or removed from" the vehicle, as provided in section S4 of the standard.

Please contact Hugh Oates of my office if you have any further questions.

Sincerely,

Frank Berndt Chief Counsel

October 30, 1979

National Highway Traffic Safety Administration Office of Chief Counsel 400 7th St., S. W. Washington, D. C. 20590

Attention: Mr. Hugh Oates Legal Counsel

Dear Mr. Oates:

On October 29, 1979 I had a phone conversation with Mr. William Smith discussing the legalities of door latches and their requirements for Jeep Motor Vehicles. I know the requirements for automotive, motor homes, etc., all all under the FMVSS No. 206 and test procedures of S.A.E. for transverse, longitudinal, inertia testing but on the American Motor Jeep, it has no top cover or a canvas type cover. There is only a handle latch without a first and second stop strike, and no locking mechanism. My question is, where can we find information covering such a top if they were to be manufactured or fabricated for the aftermarket by an independent company. Would this type of application require a safety lock or come under a different category?

I would appreciate any help you can give on door restraint handles and latches for either canvas tops with side curtains and canvas doors, or fiberglas tops with side doors (entrance doors) for Jeeps.

Sincerely,

THEODORE BARGMAN COMPANY

Edward F. Tannery Vice President of Manufacturing

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