Interpretation ID: nht94-1.1

TYPE: Interpretation-NHTSA

DATE: 01/01/94 EST

FROM: Tom Delapp -- Executive Coach Builders, Inc.

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/29/94 from John Womack to Tom Delapp (A42; Std. 206)

TEXT:

As a quality manufacturer of limousines we strive to meet or exceed any safety regulation which would affect our customers or their clients. To this end we request an interpretation to Federal Motor Vehicle Safety Standard #206, specifically the section which addresses the use of an inside locking mechanism.

Our need for this interpretation is based on the design of a "5th" door conversion that we plan to offer for sale based on the 1993 Lincoln Town Car base vehicle. The door assembly has been evaluated by a professional engineer and has exceeded the requi rement of section #214. It is designed to be opened safely through the use of an electrically controlled solenoid that is accessible by the driver from a parked position. The door panel contains no provisions for occupant control due to the exclusion o f interior and exterior release controls, making the use of a rear door locking mechanism unnecessary.

In a telephone conversation with George Shifflett, Safety Compliance Specialist, he concurred that the provision for an interior lock in this case was redundant, but cautioned that a final interpretation and approval must be issued by your office.

Please address this matter at your earliest convenience. Should you require further information to process this request, please feel free to contact me by phone or writing.