ID: nht74-2.13

DATE: 09/30/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Nabors Trailers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 21, 1974, question whether a "logging pole trailer", which consists of a beam to which an axle-mounted bolster can be clamped at different points to accomodate different log lengths, qualifies as a heavy hauler trailer as that term is defined in Standard No. 121, Air brake systems:

"Heavy hauler trailer" means a trailer with one or more of the following characteristics:

(1) Its brake lines are designed to adapt to separation or extension of the vehicle frame; or

(2) Its body consists only of a platform whose primary cargo-carrying surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent "front-end structure" as that term is used in @ 393.106 of this title.

This also acknowledges receipt of your September 5 and September 17, 1974, letters on the same subject.

The logging pole trailer you describe is a heavy hauler trailer, and as such, Standard No. 121 does not apply to this trailer until September 1, 1976. The beam or "reach", together with the bolster, constitutes the frame of the trailer, and the brake lines are designed to adapt to extension of the bolster element along the beam.

This arrangement differs from the standard highway van which has a one-piece frame with an adjustable tandem axle. The purpose of this sliding arrangement is unrelated to an extension of the frame itself to accomodate the transportation of heavy or oversize loads.

Yours truly,

ATTACH.

NABORS TRAILERS, INC.

Sept. 17, 1974

Sidney Williams -- National Highway Traffic Safety Administration

Dear Mr. Williams:

It should be of interest and concern to the National Highway Traffic Safety Administration that we have not had the sight nor the specifications nor the price of a brake equipped axle assembly that can be certified to meet the requirements of Federal Motor Vehicle Safety Standard 121. We are wholly dependent upon the one source for our brake axle assemblies. From that source we have been told that they have encountered one delay after another in their program to develop and test brakes that will meet the new requirements. Their best hope now is that by the end of October they will be able to give us technical information and sometime in November they will be able to begin shipping certifiable brakes.

The same situation prevails with respect to wheel and drum assemblies. Our supplier of drums have told us that they are conducting tests now and that they should be able to tell us in November what drums will be required for compliance with the new Safety Standard.

You can guess from this information the predicament in which we find ourselves when trailers that we put into production in December scheduled for completion in January will be required by law to be in compliance with SS 121. We are certain that there are many other trailer manufacturers who are dependent upon the same sources of supply that we are who are in the same predicament. There may be other sources of supply for brake axle assemblies and for wheels and drums who are ready to describe and certify their products to meet the new Safety Standard, but we, for one, could not at this time get in schedule with new suppliers.

Sincerely yours, B. H. Smith -- President

NABORS TRAILERS, INC.

Sept. 5, 1974

Sidney Williams -- National Highway Traffic Safety Administration

Dear Mr. Williams:

On November 15, 1973 I sent a collection of our pole trailer catalogs and of photographs of logging pole trailers in service to the Truck Trailers Manufacturers Association in Washington. I thought that these had been sent over to your offices. Perhaps they never did get there. My letter went to Mr. M. L. Higgins who at that time was handling these matters for TTMA, and very shortly after that he resigned and Mr. Burt Weller took his place.

With this letter I am sending you two each of our Catalog 196 and our Form 198 describing our standard types of pole trailers.

The logging pole trailers described in Catalog 196 are those about which we are primarily concerned with respect to MVSS 121. Those trailers are designed and used exclusively in logging operations and move logs from the woods to the saw mills or to storage areas. Logging pole trailers are subjected to unbelievably difficult conditions, or at least unbelievable to those who have never witnessed difficult logging operations. Maintaining brakes and lights on logging pole trailers when the very minimum of equipment is used is difficult and often impossible. When the hardware that is required for compliance with MVSS 121 is added to braking equipment as now being used, the difficulties of maintenance will be multiplied and the likelihood that the brakes will be kept operational is reduced.

On the inside of Catalog 196 you will see good views of the rear assembly of our two popular models, the Logmaster and the SPR. These two trailers are identical in capacity and in usage, and the two models are built simply because some loggers like one type and some like the other. In both models you will see that the rear bolster sits on a frame that sits on the two-spring suspension that sits on the axles. A pole or drawbar connects the front bolster assembly to the rear assembly. The rear assembly can slide along the pole to change the distance between the front and rear bolsters to accommodate various log lengths. If you look closely you will see that the rear assembly is locked into place on the pole by means of clamping collors around the coupling pole ahead of and behind the rear assembly. Also, for safety purposes a pin is dropped through the pole at the rear to avoid the possibility that the trailer might slide off the pole.

You will see in the illustrations that the two hoses for the brakes and the cable for the lighting on the rear assembly are connected to the truck or to the front bolster assembly at the front and are connected to the rear assembly at the rear with quick detachable couplings. You will see that when the distance between the bolsters is relatively short these brake and light lines must be coiled up and supported by the pole. If the trailer should be extended in length, the full length of these lines would be required. It is a characteristic of these trailers that the brake lines are designed to adapt to permitting the distance between the front and rear bolsters to contract and to expand.

Another common practice in the use of logging pole trailers is to load the rear frame assembly on the back end of the truck when the trailer and truck are being carried unloaded back into the woods. This practice is for both economic and safety reasons. When the rear assembly is loaded on the truck the brake lines must be disconnected. Also, no part of the brake system can extend below the bottom of the axles because the axles must rest on the truck frame or on the runners that are put on the truck frame to carry the trailer.

When you look closely at these pictures of these logging pole trailers you will observe that the space between the axles and the load-carrying bolster is limited and is filled with equipment with current types of brakes. The trailers shown have only one air reservoir. In order to comply with MVSS 121 another larger air reservoir will have to be added. There simply is no place to put it on these logging pole trailers without interfering severely with their intended usage. If in addition to this other air reservoir we must add spring-loaded power chambers and the valves and logic boxes and electrical connections required for the anti-skid brake system, it is up to now inconceivable to us how to add that hardware in such a way that it could reasonably be expected to stay on the trailers when they are used in the log woods.

The Models TP and TPC Pole Trailers illustrated in our Form 198 are designed and used primarily for hauling pipe and poles and reinforcing rods and long steel beams and other, long and self-supporting objects. The same difficulties in adding the anti-skid brake equipment and the spring loaded power chambers apply to these trailers as to the logging pole trailers. However, since these two models are used primarily on improved roads the difficulties of maintaining the equipment would not be as great. Trailers of these two models constitute no more than perhaps 50 units a year for us. They do have the same characteristic of logging pole trailers in that the brake lines are designed to be adapted to permitting the distance between the front and rear bolsters to change. There would be the same difficulties on these trailers in getting the speed of brake application and release that there would be on other pole trailers.

I can understand the difficulty of writing an exemption for any one class or category of trailers without letting the exemption be subject to unintended interpretations. However, it has seemed to me since we first became concerned with the problems of MVSS 121 that pole trailers as defined in Part 371.3 of the Federal Motor Vehicle Safety Standards could be exempted without any reasonable misunderstandings. Pole trailers as defined in Part 371.3 were exempted from the requirements of MVSS 108 and have been exempted from certification requirements. I have not understood why they could no also be exempted from MVSS 121, and I think that their categorical exemption would be beneficial rather than detrimental to the highway safety program. I have made all of these statements previously in letters to the National Highway Traffic Safety Administration and to the Truck Trailer Manufacturers Association.

We appreciate very much your consideration of our problems and I thank you again for your telephone call on September 3rd in response to our letter of August 21st.

If it might be helpful to giving you and others concerned a better understanding of our problems, which we think are shared by many others, I would be willing to come to Washington for a conference.

Sincerely yours, B. H. Smith -- President

Enclosures

NABORS TRAILERS, INC.

August 21, 1974

Sidney Williams -- National Highway Traffic Safety Administration

Subject: FMVSS 121 - Air Brake Systems, Docket #74-10, Notice 5

Dear Mr. Williams:

We are unable to determine from the subject Notice 5 and from the discussions and considerations that preceded it whether or not it is the intention of NHTSA that Logging Pole Trailers be considered "Heavy Hauler Trailers" within the definition of that category.

In one way of looking at it nearly all Logging Pole Trailers come within Characteristic (1) of the definition because the brake lines are designed to adapt to permitting the rear frame assembly of the pole trailer to slide on the pole or drawbar and thereby to adapt to extension or contraction of the effective length between the load bearing members. In another way of looking at it, pole trailers would not come within Characteristic (1) because there is no actual separation or extension of the vehicle frame. Actually, in pole trailers there is no frame as such connecting the front and rear load bearing members.

The one consistent and definitive characteristic of pole trailers, as we understand them, is that they consist of a front bolster that rests on the towing tractor and a rear bolster that rests on the trailer suspension and axles with the two connected with a pole on which the rear assembly can slide forward and backward.

In some logging operations the length between the front and rear bolsters is changed frequently, maybe daily. In some operations the length between the bolsters is changed only as the species or types of logs being hauled change. In some operations, on every unloaded trip the rear assembly is moved forward on the pole and is loaded on the truck to be hauled back into the woods. Since logging conditions and practices require different effective lengths between the front and rear bolsters and different problems with respect to the brake lines, practically all of our Logging Pole Trailers are rigged out with quick disconnectors for the brake and light lines at the rear assembly, and to that extent the rigging is similar to that on extendable platform trailers. The difficulties of maintaining good air line connections and unrestricted flow of air are certainly as great on pole trailers as on extendable frame trailers.

There are other inherent problems in applying and maintaining brakes on Logging Pole Trailers that in our opinion should be considered before there is a requirement upon trailer manufacturers to add anti-skid devices, spring loaded power chambers, dual or triple air reservoirs, and the other hardware that goes with the system. For example, up to now we have not been able to devise a way to put spring loaded power chambers on the axles of Logging Pole Trailers without swinging them under the axles. We definitely do not have sufficient clearance for putting the spring loaded power chambers over the axles with the suspensions and construction that we are using now. To put the (Illegible Word) chambers under the axles on pole trailers that are destined for the logging woods is, in our opinion, impracticable. The operators will not be able to keep the power chambers in place. The net result will be that they will knock them off or take them off the trailers and run the trailers without brakes. We run into similar but not insoluble problems with respect to installing additional air reservoirs and all of the other wiring and hardware required in an anti-skid system, but the trailers will have to be redesigned, they will be made substantially more expensive, and they will be less suited to their purpose.

Opinions have been expressed that we should simply assume that the definition of Heavy Hauler Trailers does embrace Logging Pole Trailers and that we should bother ourselves and our customers no more about the problem. We are not willing to leave it there because we cannot afford to be found in violation of the law and to be required to go back and add equipment which we did not furnish when the trailers were built. If we must put the anti-skid equipment on Logging Pole Trailers we must be getting ready for it in our designs and in our production methods, and we must be preparing our customers for the added cost and for the maintenance problems that will be inevitable.

Pole Trailers make up hardly more than 1% of the truck trailers that are manufactured. According to the Bureau of the Census Industrial Report for May, 1974, 189 pole trailers were shipped in May 1974, 214 in April 1974, and 177 in May 1973. For ourselves, the total volume in pole trailers is less than 300 units per year, but that is a substantial portion of our total volume and we are one of the largest suppliers of such trailers to the Southern lumber industry. Could you tell me exactly where we stand with respect to Logging Pole Trailers and MVSS 121?

Sincerely yours, B. H. Smith -- President

ID: nht75-2.2

DATE: 12/16/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Engineering Services

COPYEE: M. I. SCHWIMMER

TITLE: FMVSS INTERPRETATION

TEXT: In response to your November 24, letter concerning the relationship between Federal Motor Vehicle Safety Standards Nos. 109 and 119, I am enclosing a copy of a prior interpretation letter on the same subject, which was sent to Mr. C. D. McCarty of the B. F. Goodrich Company on October 15, 1975.

ID: nht72-3.37

DATE: 03/22/72

FROM: AUTHOR UNAVAILABLE; E.T. Driver; NHTSA

TO: Fiat Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 3, 1972, concerning multiple audible warning requirements.

The audible warning requirements of Federal Motor Vehicle Safety Standards 114 and 208 can be met with the use of one system rather than two separate ones.

ID: nht72-3.5

DATE: 06/08/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Labelmaster

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of May 11, 1972, submitting sample labels for retreaded tires, the samples which you submit, with the appropriate information properly filled in or clearly indicated by an "X" or other mark, will meet the requirements of S6.2 and S6.3 of Standard No. 117.

ID: nht76-2.40

DATE: 10/22/76

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: ACUTEK

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 13, 1976, to Mr. Lewis C. Owen, Safety Standards Engineer, concerning an interpretation of the words "optically combined" as they apply to your Acutek 301 combination rear lamp.

In the Acutek lamp, the data you submitted indicate that when the taillamp bulb is activated independently from the clearance lamp bulb, and vice versa, there is no appreciable amount of incidental light emitted from the lens of the clearance lamp. The amount of light "spill" appears to be so small that it would not be interpreted (by a driver following the vehicle on which it is installed) as illuminating the lens of the taillamp when operated in the clearance lamp mode, and vice versa.

Accordingly, the Acutek 301 combination rear lamp appears to meet the requirements of Federal Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices, and Associated Equipment."

SINCERELY,

Acutek

October 13, 1976

Louis C. Owen

NHTSA

Subject: Acutek 301 light

Since our telephone conversation in which you stated that in the opinion of your office you feel the Acutek 301 tailight and clearance light is optically combined therefore it is not in strict compliance with standards.

I have had time now to consider Acutek's position and feel the design of the lamp does not conflict with S4.4.1 of MVSS 108 which states: "two or more lamp, reflective devices or items of associated equipment may be combined if the requirements for each lamp, reflective device and item of associated equipment are met except that no clearance lamp may be COMBINED OPTICALLY with any tail light or identification lamp.

I think the key words are "COMBINED OPTICALLY". It would seem to me that in order for a lamp to be combined optically you would either have to use the tail light lens or the 2 candlepower filament of the bulb for tail light or both to have a lamp that is optically combined tail and clearance. In reviewing the engineering and the Acutek light I find that we are not using either the tail light filament for the tail light lens to accomplish the clearance function. In fact the clearance function is combined with the side marker lens and uses the side marker bulb to accomplish the clearance function. The lamp will not pass for clearance side marker using only the tail light filament also it will not pass for a tail light using only the side marker bulb. In my opinion the Acutek 301 light does not conflict with S 4.4.1 as the clearance light is not optically combined with the tail light and in fact is completely separated from the tail light by a section of reflex reflector.

It is true there is some very small amount of bleed over light from one section of the lamp to the other. This feature does not in any way decrease the effectiveness of the lamp, but rather is an added safety feature.

For some reason there has been an unusually large amount of controversy concerning this lamp design and feel it is unwarranted. Frankly the controversy has been a deterrent to the sales program and I would like to resolve the question of whether or not the light does in fact comply with MVSS108.

I would like for your office to reexamine the Acutek 301 tail light, keeping in mind that to be optically combined the lamp would use the tail lamp section to accomplish the clearance requirement. Since the lamp does not do this there is not doubt in my mind upon re-evaluation you will agree the lamp does meet requirements and will be in aposition to send me a letter so stating.

At the Chicago Boat Show I had the opportunity to look at the new Truck Lite combination lamp, in my opinion this light does not meet MVSS 108 as they are using the tail light lens to accomplish the clearance function.

Enclosed with this letter is the ETL test reprt which indicates the Acutek 301 rear lamp does comply with all requirements for tail, stop, turn, rear reflex, side marker and reflex, clearance and license illuminator including photometric, lens warpage, color, corrosion, vibration, moisture, dust and bulb socket.

In order to reactivate the sales program, I need a letter form you indicating compliance or what needs to be done to the lamp to bring it into compliance. It is important that this be done as soon as possible for the manufacturers of boat trailers are now placing orders for next years requirements and if there is much more delay on my part then my competitors will have succeded in keeping me out of the market. I do not intend to let this happen.

Upon your re-evaluation of the Acutek 301 lamp I am sure you will agree the clearance lamp is not optically combined with the tail lamp but is combined withthe side marker lens and bulb.

I thank you for your consideration.

Kenneth C. Ploeger President

Report Electrical Testing Laboratories, Inc.

Order No. 97552-L

Date August 30, 1976

REPORT NO. 436523 "*ACUTEK 301 DOT SAE A.I.S.T 76" COMBINATION REAR LAMP (WITH OR WITHOUT LICENSE PLATE ILLUMINATOR) AND COMBINED WITH "ACUTEK 201 DOT SAE APC - 76" LENS - CLEARANCE, SIDE MARKER LAMP AND REFLEX REFLECTOR

RENDERED TO

ACUTEK INC.

INTRODUCTION

This report contains the results of examination and test of the above device to demonstrate compliance with the applicable test requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, effective January 1, 1976 and current indicated SAE Standards as requested by the client. Marks of identification comply with the requirements of CAC, Title 13, California Highway Patrol.

[Report Omitted]

ID: 24724_PruittTray

Ms. Ondiya Pruitt
956 Zion Circle
Roswell, GA 30075

Dear Ms. Pruitt:

This responds to your letter asking about safety regulations for a "car seat tray" that you wish to manufacture. The documents you have provided indicate that the tray is intended to provide an "eating/play surface that can be positioned within the reach on an infant or young child that is sitting in a child restraint seat."From the sketch you provided, it appears that the tray attaches to the child restraint by flexible straps. You state that the tray would be sold to owners of child restraints through stores selling baby products and related items.

The National Highway Traffic Safety Administration (NHTSA) has the authority to issue safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA has used its authority to issue Federal Motor Vehicle Safety Standard (FMVSS) No. 213, "Child Restraint Systems," to reduce the number of children killed or injured in motor vehicles. (This standard is found in volume 49 of the Code of Federal Regulations, 571.213.^[1]) Each new child restraint system, which includes "car seats," must be certified as complying with the requirements of Standard No. 213. This means that, if your car seat tray were sold as part of a new child restraint, the child restraint would be required to comply with all of the requirements of the standard with the tray attached.

As Part of A New Child Restraint

It does not appear that a new child restraint could meet Standard No. 213 with the tray installed. Section S5.2.2.2 of the standard prohibits any fixed or moveable surface in front of the child except for surfaces that adequately restrain a test dummy in a 20 mile per hour test (see also S6.1.1(b)(2) and S6.1.2(a)(2)). The requirement is to prevent items that could injure a child in a crash from being installed where they could be impacted by a child. It appears that your tray would not be able to restrain the test dummy in the test. If so, a child restraint with the tray would not comply with Standard No. 213. In other words, a manufacturer of a child restraint could not sell such a tray as a part of its new child restraint system.

Also, a new child restraint with the tray attached to it might not comply with S5.2.4 of Standard No. 213. S5.2.4 requires any rigid part of the child restraint that can be contacted by the head or torso of the dummy in the dynamic test to have a height of not more than 3/8 inch above any adjacent surface, and have no exposed edge with a radius of less than 1/4 inch. If the head or torso of a restrained dummy could impact the tray, these requirements apply.

Further, child restraint systems recommended for use by children weighing less than 20 pounds must comply with paragraph S5.2.3.2 of FMVSS No. 213. That paragraph requires that each child restraint surface contactable by the child dummys head during a crash test shall be covered with slow recovery energy absorbing materials with specified characteristics. This requirement ensures that children riding in these child restraints will not suffer unnecessary head injuries during crashes.

Aftermarket Item

If your product will be sold to consumers as an aftermarket item, Standard No. 213 does not apply to it, since the standard only applies to new child restraints and not to accessory items. There is no Federal motor vehicle safety standard that applies to a tray.

However, while Standard No. 213 does not apply to the child restraint tray, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements of 49 U.S.C. 30118-30121 concerning the recall and remedy of products with safety-related defects. I have enclosed an information sheet that briefly describes those and other manufacturer responsibilities. In the event you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. If information indicated that a child seat accessory exposed occupants to an unreasonable risk of injury, the agency might conduct a defect investigation which could lead to a safety recall.

In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 49 U.S.C. 30122. This section prohibits them from installing the tray if it "makes inoperative" compliance with any safety standard, such as Standard No. 213. It appears unlikely that your product would be attached to a child restraint by persons in the aforementioned categories. However, if such a person were to attach the tray, he or she could violate 30112 if the child restraints compliance with Standard No. 213 were compromised.

The "make inoperative" prohibition of 30122 does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment.

Thus, child restraint owners could attach the tray without having to meet Standard No. 213. However, we urge consumers not to degrade the safety systems of their vehicles or equipment.

I hope this is helpful. If you have any other questions, please contact Ms. Deirdre Fujita of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref:213
d.11/26/02





---




^[1] The agency recently proposed a number of revisions to the standard, including proposals for incorporating new test dummies and extending the standard to apply to restraints recommended for use by children up to 65 pounds. 67 FR 21806 (May 1, 2002).

ID: nht94-2.6

TYPE: Interpretation-NHTSA

DATE: March 29, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tom Delapp -- Executive Coach Builders, Inc. (Springfield, MO)

TITLE: None

ATTACHMT: Attached to undated letter from Tom Delapp to Chief Council, NHTSA (OCC 8868)

TEXT:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 206, "Door locks and door retention components," as it pertains to the locking mechanism of a so-called "5th" door installed on your limousines . I apologize for the delay in responding. We conclude that the locking mechanism on the 5th door is not prohibited by Standard 206.

Based on your letter and a conversation with David Elias of my office, I understand that you have replaced the extra panel on the right side of a 1993 Lincoln Town Car based limousine with a passenger door (i.e., the 5th door). The door consists complete ly of the original equipment manufacturer's materials and hinges. The 5th door is a supplementary door, and does not replace or effect in any way the two side rear doors with which your vehicles are normally equipped.

When the 5th door is closed, its locking mechanism engages automatically, and the door cannot be opened from the inside or the outside. A solenoid locking mechanism that unlocks the 5th door is located inside the vehicle in a "privacy panel" behind the driver's seat. For the driver to unlock the 5th door, the car must be stopped and the driver must then get out of the car and reach through a window into the area behind the driver's seat. The locking mechanism cannot be reached by the driver while sea ted in the driver's seat, and cannot be reached by the passengers in the rear seats. The 5th door cannot be accidentally opened; unless the locking mechanism has been actively disengaged, the door remains locked. Disengaging the locking mechanism for t he 5th door allows the driver to open the door from the outside, although passengers could push the door open from the inside, as well.

There are two pertinent requirements of FMVSS No. 206 to your situation. First, S4.1.3 (Door Locks) states that:

Each door shall be equipped with a locking mechanism with an operating means in the interior of the vehicle.

In two prior letters, to Mr. Charles Murphy on May 10, 1974, and to Mr. Gary Hackett on April 11, 1988, the agency interpreted S4.1.3 to mean that the locking mechanism must also be OPERABLE from within the vehicle.

The first question to be addressed is whether the 5th door meets the requirement of S4.1.3. We believe the answer is yes, the door is equipped with a locking mechanism with an operating means in the interior of the vehicle that is operable from within the vehicle. The operating means for the locking mechanism is in the interior of the vehicle in that the locking mechanism engages automatically when the 5th door is closed. While the means to

disengage the operating mechanism is not accessible to occupants in the vehicle, Standard 206 does not require the locking mechanism to be capable of being disengaged by an occupant. This is because the purpose of the standard is to minimize the chance that occupants of the vehicle will be ejected in a collision. Thus, the thrust of the standard is to ensure that occupants are retained within the vehicle, such as by requiring doors to have door locks that occupants are capable of locking.

The second pertinent requirement is S4.1.3.2 (Side Rear Door Locks), which states that:

... when the locking mechanism is engaged both the outside and inside door handles or other latch release controls shall be inoperative.

The 5th door appears to comply with S4.1.3.2, in that it cannot be opened from the outside or inside when the locking mechanism is engaged.

In a letter to Ms. C.D. Black, dated April 10, 1987, the agency interpreted a question on child safety locks that is relevant to your situation. The child safety lock operated as a "secondary locking system" that, when activated, rendered the inside rea r door handle incapable of opening the door. (It had no effect on the outside door handle.) As we stated in that letter, our conclusion was that Standard 206 permitted the child safety lock because the standard prohibits only secondary locking systems that interfere with the ENGAGEMENT, but not with the DISENGAGEMENT, of the primary locking system. In that letter, we wrote:

The answer to your question about the child locking systems is dependent on whether the systems interfere with an aspect of performance required by Standard No. 206. We have determined that the answer is no, because the requirements of... S4.1.3.2 are written in terms of what must occur when the primary system is engaged and impose no requirements regarding the effects of disengaging the system. Thus, the aspect of performance required by S4.1.3 for the interior operating means for the door locks is that it be capable only of ENGAGING the required door locking mechanisms. The aspect of performance required by S4.1.3.2 for door locks on the rear doors is that the inside and outside door hand les be inoperative when the locking mechanism is ENGAGED. Since we have determined that... S4.1.3.2 do(es) not address the effects of disengaging the required door locks--i.e., S4.1.3.2 does not require that the inside rear door handles b e operative (capable of releasing the door latch) when the required locking system is disengaged--a child locking system may be provided on a vehicle if it does not negate the capability of the door lock plunger (the operating means) to engage the door locks.

I hope this information has been helpful. If you have any further questions, feel free to contact Mr. Elias at the above address or by phone at (202)366- 2992.

ID: nht94-7.16

DATE: March 29, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tom Delapp -- Executive Coach Builders, Inc. (Springfield, MO)

TITLE: None

ATTACHMT: Attached to undated letter from Tom Delapp to Chief Council, NHTSA (OCC 8868)

TEXT:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 206, "Door locks and door retention components," as it pertains to the locking mechanism of a so-called "5th" door installed on your limousines. I apologize for the delay in responding. We conclude that the locking mechanism on the 5th door is not prohibited by Standard 206.

Based on your letter and a conversation with David Elias of my office, I understand that you have replaced the extra panel on the right side of a 1993 Lincoln Town Car based limousine with a passenger door (i.e., the 5th door). The door consists completely of the original equipment manufacturer's materials and hinges. The 5th door is a supplementary door, and does not replace or effect in any way the two side rear doors with which your vehicles are normally equipped.

When the 5th door is closed, its locking mechanism engages automatically, and the door cannot be opened from the inside or the outside. A solenoid locking mechanism that unlocks the 5th door is located inside the vehicle in a "privacy panel" behind the driver's seat. For the driver to unlock the 5th door, the car must be stopped and the driver must then get out of the car and reach through a window into the area behind the driver's seat. The locking mechanism cannot be reached by the driver while seated in the driver's seat, and cannot be reached by the passengers in the rear seats. The 5th door cannot be accidentally opened; unless the locking mechanism has been actively disengaged, the door remains locked. Disengaging the locking mechanism for the 5th door allows the driver to open the door from the outside, although passengers could push the door open from the inside, as well.

There are two pertinent requirements of FMVSS No. 206 to your situation. First, S4.1.3 (Door Locks) states that:

Each door shall be equipped with a locking mechanism with an operating means in the interior of the vehicle.

In two prior letters, to Mr. Charles Murphy on May 10, 1974, and to Mr. Gary Hackett on April 11, 1988, the agency interpreted S4.1.3 to mean that the locking mechanism must also be OPERABLE from within the vehicle.

The first question to be addressed is whether the 5th door meets the requirement of S4.1.3. We believe the answer is yes, the door is equipped with a locking mechanism with an operating means in the interior of the vehicle that is operable from within the vehicle. The operating means for the locking mechanism is in the interior of the vehicle in that the locking mechanism engages automatically when the 5th door is closed. While the means to

disengage the operating mechanism is not accessible to occupants in the vehicle, Standard 206 does not require the locking mechanism to be capable of being disengaged by an occupant. This is because the purpose of the standard is to minimize the chance that occupants of the vehicle will be ejected in a collision. Thus, the thrust of the standard is to ensure that occupants are retained within the vehicle, such as by requiring doors to have door locks that occupants are capable of locking.

The second pertinent requirement is S4.1.3.2 (Side Rear Door Locks), which states that:

... when the locking mechanism is engaged both the outside and inside door handles or other latch release controls shall be inoperative.

The 5th door appears to comply with S4.1.3.2, in that it cannot be opened from the outside or inside when the locking mechanism is engaged.

In a letter to Ms. C.D. Black, dated April 10, 1987, the agency interpreted a question on child safety locks that is relevant to your situation. The child safety lock operated as a "secondary locking system" that, when activated, rendered the inside rear door handle incapable of opening the door. (It had no effect on the outside door handle.) As we stated in that letter, our conclusion was that Standard 206 permitted the child safety lock because the standard prohibits only secondary locking systems that interfere with the ENGAGEMENT, but not with the DISENGAGEMENT, of the primary locking system. In that letter, we wrote:

The answer to your question about the child locking systems is dependent on whether the systems interfere with an aspect of performance required by Standard No. 206. We have determined that the answer is no, because the requirements of... S4.1.3.2 are written in terms of what must occur when the primary system is engaged and impose no requirements regarding the effects of disengaging the system. Thus, the aspect of performance required by S4.1.3 for the interior operating means for the door locks is that it be capable only of ENGAGING the required door locking mechanisms. The aspect of performance required by S4.1.3.2 for door locks on the rear doors is that the inside and outside door handles be inoperative when the locking mechanism is ENGAGED. Since we have determined that... S4.1.3.2 do(es) not address the effects of disengaging the required door locks--i.e., S4.1.3.2 does not require that the inside rear door handles be operative (capable of releasing the door latch) when the required locking system is disengaged--a child locking system may be provided on a vehicle if it does not negate the capability of the door lock plunger (the operating means) to engage the door locks.

I hope this information has been helpful. If you have any further questions, feel free to contact Mr. Elias at the above address or by phone at (202)366- 2992.

ID: 8868

Mr. Tom Delapp
Executive Coach Builders, Inc.
One Executive Boulevard
Springfield, MO 65802

Dear Mr. Delapp:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 206, "Door locks and door retention components," as it pertains to the locking mechanism of a so-called "5th" door installed on your limousines. I apologize for the delay in responding. We conclude that the locking mechanism on the 5th door is not prohibited by Standard 206.

Based on your letter and a conversation with David Elias of my office, I understand that you have replaced the extra panel on the right side of a 1993 Lincoln Town Car based limousine with a passenger door (i.e., the 5th door). The door consists completely of the original equipment manufacturer's materials and hinges. The 5th door is a supplementary door, and does not replace or effect in any way the two side rear doors with which your vehicles are normally equipped.

When the 5th door is closed, its locking mechanism engages automatically, and the door cannot be opened from the inside or the outside. A solenoid locking mechanism that unlocks the 5th door is located inside the vehicle in a "privacy panel" behind the driver's seat. For the driver to unlock the 5th door, the car must be stopped and the driver must then get out of the car and reach through a window into the area behind the driver's seat. The locking mechanism cannot be reached by the driver while seated in the driver's seat, and cannot be reached by the passengers in the rear seats. The 5th door cannot be accidentally opened; unless the locking mechanism has been actively disengaged, the door remains locked. Disengaging the locking mechanism for the 5th door allows the driver to open the door from the outside, although passengers could push the door open from the inside, as well.

There are two pertinent requirements of FMVSS No. 206 to your situation. First, S4.1.3 (Door Locks) states that:

Each door shall be equipped with a locking mechanism with an operating means in the interior of the vehicle.

In two prior letters, to Mr. Charles Murphy on May 10, 1974, and to Mr. Gary Hackett on April 11, 1988, the agency interpreted S4.1.3 to mean that the locking mechanism must also be operable from within the vehicle.

The first question to be addressed is whether the 5th door meets the requirement of S4.1.3. We believe the answer is yes, the door is equipped with a locking mechanism with an operating means in the interior of the vehicle that is operable from within the vehicle. The operating means for the locking mechanism is in the interior of the vehicle in that the locking mechanism engages automatically when the 5th door is closed. While the means to disengage the operating mechanism is not accessible to occupants in the vehicle, Standard 206 does not require the locking mechanism to be capable of being disengaged by an occupant. This is because the purpose of the standard is to minimize the chance that occupants of the vehicle will be ejected in a collision. Thus, the thrust of the standard is to ensure that occupants are retained within the vehicle, such as by requiring doors to have door locks that occupants are capable of locking.

The second pertinent requirement is S4.1.3.2 (Side Rear Door Locks), which states that:

... when the locking mechanism is engaged both the outside and inside door handles or other latch release controls shall be inoperative.

The 5th door appears to comply with S4.1.3.2, in that it cannot be opened from the outside or inside when the locking mechanism is engaged.

In a letter to Ms. C.D. Black, dated April 10, 1987, the agency interpreted a question on child safety locks that is relevant to your situation. The child safety lock operated as a "secondary locking system" that, when activated, rendered the inside rear door handle incapable of opening the door. (It had no effect on the outside door handle.) As we stated in that letter, our conclusion was that Standard 206 permitted the child safety lock because the standard prohibits only secondary locking systems that interfere with the engagement, but not with the disengagement, of the primary locking system. In that letter, we wrote:

The answer to your question about the child locking systems is dependent on whether the systems interfere with an aspect of performance required by Standard No. 206. We have determined that the answer is no, because the requirements of... S4.1.3.2 are written in terms of what must occur when the primary system is engaged and impose no requirements regarding the effects of disengaging the system. Thus, the aspect of performance required by S4.1.3 for the interior operating means for the door locks is that it be capable only of engaging the required door locking mechanisms. The aspect of performance required by S4.1.3.2 for door locks on the rear doors is that the inside and outside door handles be inoperative when the locking mechanism is engaged. Since we have determined that... S4.1.3.2 do[es] not address the effects of disengaging the required door locks--i.e., S4.1.3.2 does not require that the inside rear door handles be operative (capable of releasing the door latch) when the required locking system is disengaged--a child locking system may be provided on a vehicle if it does not negate the capability of the door lock plunger (the operating means) to engage the door locks.

I hope this information has been helpful. If you have any further questions, feel free to contact Mr. Elias at the above address or by phone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:206 d:3/29/94

ID: nht69-2.33

DATE: 12/03/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Rootes Motors Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 10, 1969, concerning the requirement for turn signal lamps as specified in Federal Motor Vehicle Safety Standard No. 108. With respect to the installation requirements for front turn signal(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)