Interpretation ID: nht93-4.5
DATE: May 20, 1993
FROM: Karl-Heinz Ziwica -- General Manager, Environmental Engineering, BMW of North America, Inc.
TO: Stephen P. Wood -- Assistant Chief Counsel, Rulemaking, NHTSA
COPYEE: David Elias; William Fan
TITLE: Re: 49 CFR 571.206, FMVSS No. 206; Door Locks and Door Retention Components; Request for Interpretation
ATTACHMT: Attached to letter dated 10/7/93 from John Womack to Karl-Heinz Ziwica (A41; Std. 206)
TEXT:
Recently, William Scully of my staff and our counsel, Donald M. Schwentker, met with David Elias of your staff and William Fan of Rulemaking to discuss our interpretation of 49 CFR 571.206, Federal Motor Vehicle Safety Standard ("FMVSS") No. 206, Door locks and door retention components, with respect to a new design door latch and lock system that BMW is planning to introduce on a new car line in the United States in the near future. At that time, Mr. Scully also demonstrated the new system on a modified production BMW passenger car.
We hereby request the agency's confirmation of our interpretation that the operation of BMW's new system conforms to the applicable provisions of FMVSS 206.
FMVSS 206 REQUIREMENTS
S4.1.3 DOOR LOCKS. Each door shall be equipped with a locking mechanism with an operating means inside the vehicle.
S4.1.3.1 SIDE FRONT DOOR LOCKS. When the locking mechanism is engaged, the outside door handle or other outside latch release control shall be inoperative. S4-1.3.2 SIDE REAR DOOR LOCKS. In passenger cars and multipurpose passenger vehicles, when the locking mechanism is engaged, both the outside and inside door handles or other latch releases controls shall be inoperative.
DESCRIPTION OF THE OPERATION OF THE BMW SYSTEM
The inside door handle operates as a door lock release AND SUBSEQUENTLY as a door latch release. The first complete activation of the recessed handle (a pulling motion) releases the door locking mechanism. The second activation (another pulling motion) operates the door latch release control.
WHY THE BMW DOOR LOCK SYSTEM COMPLIES WITH FMVSS 206
-- When the rear door locking mechanism is engaged, the door handles ARE INOPERATIVE.
-- After the door locking mechanism is disengaged (by activating the common door lock/door latch release handle), the door handle BECOMES OPERATIVE.
OCCUPANT PROTECTION INTENDED BY FMVSS 206, AND HOW BMW'S DOOR LOCK SYSTEM PROVIDES SUCH PROTECTION
-- Ejection
* BMW's system affords even more protection against inadvertent opening of doors than that required by FMVSS 206 for front doors.
-- Inadvertent Opening by Children
* All BMW products are fitted with rear door child locks (which deactivate operation of the inside door handles) as standard equipment, and when such child locks are engaged, the rear doors CANNOT BE OPENED FROM THE INSIDE.
* Restrained children cannot reach the rear door handle.
* Two separate actions are required to open the rear doors (when the child locks are not engaged), just as in a conventional door lock and door latch release system.
* The door lock release of most current conventional systems is placed immediately adjacent to the door latch release.
OTHER ADVANTAGES OF BMW'S DOOR LOCK SYSTEM
In addition to the convenience provided to the vehicle occupants, BMW's door lock system affords easier exit after a crash, and is less vulnerable to damage during side impact.
For these reasons, BMW believes its new system fully complies with the applicable provisions of FMVSS 206, while providing distinct advantages to its customers.
If you have any questions about this request or the operation of the new BMW door locking system, please contact Mr. William Scully at (201) 573-2069.