Interpretation ID: nht88-1.92

TYPE: INTERPRETATION-NHTSA

DATE: 04/11/88

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TO: Gary Hackett -- State of Nevada Taxi Cab Authority

TITLE: FMVSS INTERPRETATION

ATTACHMT: 5/10/74 letter from Lawrence R. Schneider to City of Philadelphia (Std. 206)

TEXT:

Mr. Gary Hackett State of Nevada Taxi Cab Authority Suite 200 1785 E. Square Las Vegas, NV 89155

This is in further response to your March 28, 1988, telephone conversation with Mr. Steve Wood of my staff in which you asked for an Interpretation of Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components. Your specific question asked whether Standard No. 206 requires door handles on rear doors of motor vehicles. The answer to your question is no.

The agency addressed the question you raise in a May 10, 1974, letter to Mr. Charles Murphy who asked whether manufacturers selling vehicles to the City of Philadelphia can remove the door handles from the vehicles' rear doors. In response, the agency in terpreted Standard No. 206 as not requiring an inside rear door handle. The National Highway Traffic Safety Administration stated that the standard's requirements that each passenger car rear door must have a locking mechanism that is operable from withi n the vehicle and that, when engaged, renders the outside and inside door handles inoperative (@4.1.3) specify the performance required of door locking mechanisms only. The agency thus indicated that the standard sets no requirements for inside rear door handles.

I have enclosed a copy of the Murphy letter for your information. Please feel free to contact my office if you have further questions. Sincerely,

Erika Z. Jones Chief Counsel

Enclosure - See 5/10/74 letter