Interpretation ID: nht92-5.46

DATE: June 24, 1992

FROM: Kenneth Lenz -- HME Incorporated

TO: Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated July 1, 1992 (est.) from Paul J. Rice to Kenneth Lenz (A39; Std. 206)

TEXT:

I have been reviewing Federal Motor Vehicle Safety Standards (FMVSS) for applicability to fire trucks, specifically certain provisions of FMVSS 206.

There have been requests from fire departments to eliminate the interior and exterior door locks required by FMVSS 206, S4.1.3. The fire company's reasons for eliminating all door locks is that "the vehicle is used in emergency situations and a door that has been locked accidently may hinder the ability of the apparatus to respond".

I would appreciate and interpretation of FMVSS 206 on whether or not fire trucks are required to comply with this regulation or if an exemption from compliance with S4.1.3 can be obtained for fire trucks.

Thank you.