Manager Engineering Quality
Western Star Trucks
2076 Enterprise Way
Kelowna, British Columbia
Dear Mr. Gornick:
This responds to your telephone conversation with Walter Myers of my staff on October 10, 1996, and your letter of October 11, 1996, addressed to Mr. Myers. You asked whether emergency doors on sleepers manufactured by your company for installation on the back of truck cabs must comply with Federal motor vehicle safety standard (FMVSS) No. 206, Door locks and door retention components. The answer is no.
You stated in your letter that your company offers a sleeper that can be mounted on the back of a truck cab. Access to the sleeper is provided through an opening in the back wall of the cab and the front wall of the sleeper. An emergency door 20.25 inches wide and 28 inches high may be installed as an option on the passenger side of the sleeper. Although the interior opening is the primary access, the emergency door provides a means of both ingress and egress to the sleeper from outside the cab. There are no seating accommodations in the sleeper, only a bed. The bed is equipped with 2 restraint straps to hold an occupant in place if the vehicle were to suddenly stop or to roll over. Nothing is provided, however, for anyone sitting on the edge of or at the back of the bed.
As you correctly pointed out in your letter, paragraph S4 of FMVSS No. 206 provides that "[c]omponents on any side door leading directly into a compartment that contains one or more seating accommodations" must comply with the
requirements of the standard. The key words here are "directly" and "one or more seating accommodations."
On July 28, 1972 this office issued a letter to Mr. J. Donald Waldman of Resources Applications, Designs & Control, Inc. (copy attached), in which we stated in response to a question similar to yours that even though the sleeper is a passenger compartment, it is a separate unit with no seating accommodations. Thus, FMVSS No. 206 would not apply. However, we went on to say that:
[I]f the sleeper berth equipment is installed in such a way that it is contiguous to the truck cab and can be entered by the driver from within the cab, then any side doors on the sleeper berth equipment would be side doors leading into a passenger compartment (the cab) containing seating accommodations and they would have to meet the requirements of the Standard.
This language could be interpreted to say that if there is any means at all of ingress or egress through the sleeper door into the cab, even if one must crawl through the sleeper compartment and over the bed to get into the cab, then the door must comply with FMVSS No. 206. We think that such an interpretation would be inconsistent with the plain language of the standard. Accordingly, in a letter to Mr. Jiro Doi of Mitsubishi Motors America, Inc., dated April 26, 1996 (copy enclosed), we stated that a back door "that leads directly into a compartment that contains one or more seating accommodations" means:
[A] door through which vehicle occupants enter from outside the vehicle directly into a vehicle compartment in which occupant seats are located, or exit the vehicle directly from a compartment in which they have been seated to the outside of the vehicle.
Thus, doors "leading directly into a compartment that contains one or more seating accommodations" means just that, and does not include a compartment through which or over which a person must crawl or climb to reach a compartment containing seating accommodations. Accordingly, the small emergency door leading into or out of your sleeper compartment does not lead directly into a compartment containing seating accommodations, and is therefore not
required to comply with the requirements of FMVSS No. 206. Any interpretation to the contrary that is stated or may be inferred in the Waldman letter is hereby rescinded.
I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992.
Acting Chief Counsel