Mr. Lance Tunick
Vehicle Services Consulting, Inc.
P.O. Box 23078
Santa Fe, NM 87502-3078
Dear Mr. Tunick:
This responds to your letter concerning a February 6, 2007, final rule amending Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door Locks and Door Retention Components. You ask whether the amendments continue to permit a double pull door handle found on some rear side door locking systems. The first actuation of the interior rear door handle unlocks the door and the second pull releases the latch to open the door. As discussed below, our answer is yes, FMVSS No. 206 will continue to permit the double pull door handle you described in your letter.
The February 6, 2007, final rule added to and updated requirements and test procedures of FMVSS No. 206, and harmonized with the worlds first global technical regulation for motor vehicles (72 FR 5385). (The effective date of the final rule is September 1, 2009; there are pending petitions for reconsideration of the final rule. Docket No. NHTSA-2006-23882.) To prevent inadvertent rear door openings, the standard specifies in S4.3.1:
S4.3.1 Rear side doors. Each rear side door shall be equipped with at least one locking device which has a lock release/engagement mechanism located within the interior of the vehicle and readily accessible to the driver of the vehicle or an occupant seated adjacent to the door, and which, when engaged, prevents operation of the interior door handle or other interior latch release control and requires separate actions to unlock the door and operate the interior door handle or other interior latch release control.
As noted in your letter, NHTSA stated in the final rule that the requirement in S4.3.1 for separate actions to unlock the door and operate the interior door handle or other interior latch release control have been in place for the interior rear door locks of every new car and light truck sold in the United States since 1968. (72 FR at 5395) A review of past agency interpretations on the double pull design is thus instructive.
Past interpretations have been issued by NHTSA permitting the double pull door locking design (see March 28, 1996 letter to you and an October 7, 1993 letter to Karl-Heinz Ziwica) under current FMVSS No. 206 requirements. The current FMVSS No. 206 requirement (S126.96.36.199) states:
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.
In those letters, NHTSA interpreted the word inoperative to refer to the operation of opening the door, rather than that of disengaging the lock. For the double pull rear side door lock systems, when the locking mechanism is engaged, actuation of the door handle cannot open the door, which NHTSA stated met the requirement of current S188.8.131.52.
The new S4.3.1 reflects current S184.108.40.206 in the second clause of the amended standard (and which, when engaged, prevents operation of the interior door handle or other interior latch release control). Thus, for the double pull rear side door lock systems described in the March 28, 1996 and October 7, 1993 letters, this second clause of S220.127.116.11 is met, since actuation of the door handle cannot open the door.
The new S4.3.1 has a further provision in its last clause (and requires separate actions to unlock the door and operate the interior door handle or other interior latch release control). We believe that the double pull door locking design described in the March 28, 1996 and October 7, 1993 letters meets the last clause of the new S4.3.1. For the double pull rear side door lock system you described, two separate actions are needed to open the door: the first pull unlocking the door and the second pull which activates the latch release control and opens the door. This design is distinguished from a system in which a door can be unlocked and unlatched with a single pull of the door handle, which is not permitted under the new S4.3.1. 72 FR at 5395.
In conclusion, the new FMVSS No. 206 door locks requirements continue to permit the double pull rear side door lock system described in the letters you referenced. If you have any further questions, please do not hesitate to contact Sarah Alves of my staff at (202) 366-2992.
Anthony M. Cooke
 The double pull door lock system in those letters were like the one you currently describe: the first pull of the inside rear door handle unlocks the door but does not release the latch to open the door, and the second pull releases the latch to open the door.