Interpretation ID: nht80-3.36

DATE: 08/13/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 9, 1980, letter requesting clarification of the Federal requirements for door locks on fire trucks. Specifically, you ask whether Safety Standard No. 206, Door Locks and Door Retention Components (49 CFR 571.206), is applicable to fire trucks.

As Mr. Oates of my office stated in his telephone conversation with you, Safety Standard No. 206 applies to all passenger cars, multipurpose passenger vehicles and trucks. Since fire trucks are not specifically exempted in the standard, they would be considered "trucks" and would have to comply with the standard. There are certain types of doors on vehicles, however, that do not have to comply with the requirements of the standard. Section S4 of the standard provides:

Components on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard. However, components on folding doors, roll-up doors and doors that are designed to be easily attached to or removed from motor vehicles manufactured for operation without doors need not conform to this standard.

Therefore, certain doors on fire trucks may not be required to have locks. For example, a door leading to a cat-walk or standing area on the fire truck that contains no seating position would not have to comply with the standard. Likewise, a passenger compartment door that is readily removable would also not have to comply. I believe that many fire trucks have these type doors. You should check with your sales people to see if the vehicles they saw at the Fire

Equipment Show would qualify under the exceptions mentioned above. If you are aware of specific models that should comply with the standard but which do not, we would appreciate being apprised of that information. I hope this has clarified the requirements of the standard.