Interpretation ID: aiam1480
Safety Director
City of Philadelphia
1600 Municipal Services Bldg.
Philadelphia
PA 19107;
Dear Mr. Murphy: This is in reply to your letter of March 5, 1974, inquiring whethe manufacturers of 4-door sedans to be sold to the City of Philadelphia as police vehicles may, consistently with Federal requirements, remove the window and door handles from the rear doors. You state that the vehicle manufacturers claim that Federal requirements prohibit them from modifying the vehicle in this fashion.; Federal Motor Vehicle Safety Standard No. 206 (49 CFR 571.206) require each passenger car rear door to have a locking mechanism that is operable from within the vehicle and that, when engaged, renders the outside and inside door handles inoperative. This requirement applies to the locking mechanism. We do not interpret it to require an inside door handle. There are no Federal standards which require the installation of passenger car window handles.; The fact that in this case the vehicles are intended for government us is immaterial. To clarify the phone conversation which preceded your letter, Section 103(d) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1392(d)) allows a State or its political Subdivision to require that motor vehicles and motor vehicle equipment procured for its own use meet a higher standard of performance than the Federal safety standard, but all vehicles must meet the Federal safety standards.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel