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Interpretation ID: tri-mark.rbm





    Mr. Larry Wright
    RV Market Manager
    Tri/Mark
    Industrial Park
    New Hampton, IA 50659


    Dear Mr. Wright:


    This responds to your letter asking whether your side door locking system would meet the requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door retention components (49 CFR 571.206). The answer is yes.

    By way of background, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. The following represents our opinion based on the facts set forth in your letter and presented in subsequent conversations with Rebecca MacPherson of my staff.

    You have requested confidentiality of your incoming request, and we have granted that confidentiality. In order to adequately address your request, however, we must provide a brief, general description of your door retention system.

    You stated that your side door locking system consists of two separate locks. One can be locked and unlocked from either the inside or the outside of the vehicle. This lock, which is not attached to the door handle, is the vehicle's primary locking system. The second can only be locked from the outside of the vehicle, but when so locked, will not prevent an individual inside the vehicle from opening the door. This lock serves as a security feature when the vehicle is parked. The door may be the only door on the vehicle or it may be supplemental to traditional front doors. It typically would not qualify as a front door because it would generally be located behind the driver seat. (1)

    You asked whether your side door locking system would comply with the requirements of S4.1.3, S4.1.3.1, and S4.1.3.2 of FMVSS No. 206.

Paragraph S4.1.3, FMVSS No. 206 provides:

    Door Locks. Each door shall be equipped with a locking mechanism with an operating means in the interior of the vehicle.

We have interpreted S4.1.3 to require the following features: each door must have a locking mechanism, and there must be an interior operating means for engaging the locking mechanism. In your letter you state that your system has an interior means for engaging one of the two door locks. Accordingly, the requirement of S4.1.3 would be met.

Paragraph S4.1.3.1, FMVSS No. 206 provides:

    Side Front Door Locks. When the locking mechanism is engaged, the outside door handle or other outside latch release control shall be inoperative.

Based on your explanation of your design, it is unlikely that the affected door would qualify as a front door. If it does qualify as a front door, the requirements for S4.1.3.1 would also be met since both locks on your system prevent an individual from opening the door when it is locked.

Paragraph S4.1.3.2, FMVSS No. 206 provides:

    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 release controls shall be inoperative.

One of the locks in your system will prevent the door from being opened from either inside or outside the vehicle when the lock is engaged. This lock meets the requirements of S4.1.3.2. The security lock does not meet the requirements of S4.1.3.2. However, this lock is supplemental and is not designed to meet the primary purpose of that section, i.e., preventing individuals from inadvertently opening locked doors while the vehicle is in motion.

Thus, the primary locking mechanism would meet the requirements of either S4.1.3.1 or S4.1.3.2, depending on the placement of the door relative to the driver seat. We note that even though the locking mechanism is not directly linked to the door handle, the door's latch release control, it does render the door handle inoperative since the door remains closed when the locking mechanism is engaged.

I hope this information is helpful to you. Should you have any further questions or desire additional information, please feel free to contact Rebecca MacPherson of my staff at this address or at (202) 366-2992.


Sincerely,


Frank Seales, Jr.
Chief Counsel


ref:206
d.7/26/00



1. FMVSS No. 206 defines a side front door as a door that in a side view has 50% or more of its opening area forward of the rearmost point on the driver's seatback when the driver's seat is adjusted to its most vertical and rearward position. The Standard defines a side rear door as a door that in a side view has 50% or more of its opening area rear of the rearmost point on the driver's seatback when the driver's seat is adjusted to its most vertical and rearward position.