ID: nht68-1.1

DATE: 05/29/68

FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA

TO: Royal Brass, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 26, 1968, concerning certification of brake hoses. Hydraulic brake hose for use in passenger cars and multipurpose passenger vehicles manufactured after January 1 1968 must comply with Federal Motor Vehicle Safety Standard No. 106. Hydraulic Brake Hoses - Passenger Cars and Mutipurpose Passenger Vehicles.

At the time of delivery of the completed brake hose assembly to a distributor or dealer the manufacturer of the completed brake hose assembly must certify that it complies with the applicable standard. In the case of equipment such as the brake hose assembly the certification may be in the form of a label or tag on the completed brake hose assembly or on the outside of the container in which the brake hose assembly is delivered.

For your information I have enclosed a copy of the Federal Motor Vehicle Safety Standards, the notice published in the Federal Register concerning certification and a copy of the National Traffic and Motor Vehicle Safety Act of 1966. Particular attention should be paid to sections 108 and 114 of the Act.

I hope this letter and the enclosures are adequately responsive to your questions.

Sincerely,

April 26, 1968

U.S. Department of Transportation Federal Highway Administration

Attn: Robert M. O'Mahoney

Gentlemen:

We are manufacturer and distributor of automotive brass fittings, steel hydraulic fittings, hydraulic brake fittings, hydraulic brake hose assemblies, and make equipment for the assembly of hydraulic hoses and hydraulic brake hoses. The bulk brake hose is purchased from Inland Rubber Division of General Motors. All of our fittings are made to SAE specifications as shown in the SAE Handbook. What type of certification must we give to our customers? We sell to original equipment manufacturers, trucking companies, jobbers, and garages.

An early reply will be appreciated.

Very truly yours,

ROYAL BRASS, INC. -- R. R. McLain

Sales Manager

ID: nht92-7.38

DATE: April 17, 1992

FROM: Bill Willett

TO: NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/8/92 from Paul J. Rice to Bill Willett (A39; Std. 108)

TEXT:

I am proud to have the oportunity to have talked with Mr. VanIderstine.

I feel that the flickering brake light is an improvement to the existing dim-bright red light now used.

The back windshield light used since 1986 is also an improvement. The cars before 1986 are the main concern to me. I believe if this were used on older cars that accidents would be prevented.

A survey of Alabama citizens interested in this safety device and how it has affected them over a period of time is one of the first projects of the new unit.

I am interested in knowing what I can do and what I can't do.

Example: Can a 10.00 fee be charged with a survay group member installing it free of charge. Is there any Federal law preventing me from doing research by adding another device to the vehicle lights.

At the present time I'm testing and looking for the proper flickering device to use.

This flickering brake light flashes on and off at a faster rate than that of the turn signal and the emergency flashers.

It is intended to alert the driver that the brakes are applied as long as the brakes are used -- unlike that used in California which I'm told only flashed for a second or two.

Very soon I plan to go to California and get information that might help me in Ala.

At this point it would mean a great deal to me if you responded with a letter supporting my effort in looking for a safer product and hopefully getting a good positive survey.

Sir, if you have any advice on the project I'd sure like the help. Thank you.

ID: nht93-7.43

DATE: October 28, 1993

FROM: Jelly, Rachel -- Executive Engineer, Legislation and Certification., Lotus Cars Ltd.

TO: Womak, John -- Acting Chief Council, NHTSA

TITLE: NONE

ATTACHMT: Attached To A Letter Dated 5/9/94 From John Womack To John Bloomfield (A42; PART 525)

TEXT: Lotus / Bugatti, request for clarification regarding CAFE petition(s) for alternative CAFE standards.

Since January 1986 General Motors has owned 100% of Group Lotus. Under GM ownership the fuel economy data from the Lotus vehicles has been included with the GM import fleet for the purposes of CAFE fines and reporting. As GM had enough fuel efficient vehicles in its import fleet to offset the shortfall of the Lotus vehicles fuel economy-performance, no fines were required and thus no waiver petition for an alternative CAFE value was necessary.

On the 27th August 1993 General Motors sold 100% of Group Lotus Ltd to Bugatti International. Bugatti is also a vehicle manufacturer and plans to market passenger cars in the USA commencing with the 1994 model year. Both companies actual/projected sales volumes when taken individually, and combined, will make the companies eligible for classification as a small volume manufacturer. Please see the supporting data on page 3 of this letter for sales projections and fuel economy information.

Lotus now finds itself in the position where it needs to apply for an alternative CAFE standard for the 1994 thru 1997 (and possibly subsequent) model years. Also Bugatti is planning to submit a petition for alternative standards in the near future.

Please could you officially advise me if Lotus will be permitted to petition for its own CAFE value for its vehicles and Bugatti will be able to petition for another value for its fleet, or will Lotus and Bugatti have to combine sales projections and fuel economy data and petition for a joint value? The two manufacturing companies are run as separate entities within the group to maintain the individual identity of the products.

If you require any further information please do not hesitate to contact me, my direct line telephone and fax numbers are 44 953 608131 (tel) and 44 953 608132 (fax).

CONFIDENTIAL.

Lotus and Bugatti US manufacturing and fuel economy data:-

ID: nht69-2.42

DATE: 12/22/69

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Ford Motor Company

TITLE: FMVSR INTERPRETATION

TEXT: RE: CONSUMER INFORMATION

This is in response to your telegram of December 15 concerning the submission of consumer information on passenger cars produced by your associated company in England. You stated, "This data will be submitted to the Bureau thirty (30) or more days in advance of any of these cars being offered for sale in the United States as required by section 375.6 as published on October 22, 1969."

The regulation (49 CFR @ 375.6(b)) requires information to be made available to prospective purchasers, on or afer January 1, 1970, on "each of the vehicles offered for sale" at the dealer showroom. The general applicability of the information is to vehicles manufactured on or after January 1, 1970. The intent of the regulation is to provide prospective vehicle buyers with information on all the various types of vehicles currently being manufactured and available for purchase after that date.

You apparently are assuming that, within the meaning of the regulation, no vehicles are "offered for sale" to prospective purchasers except those that are physically present in the dealer showroom. This certainly does not reflect the practice of most manufacturers, whose dealers, while keeping representative stock of vehicles on hand, offer for sale (and enter into contracts for sale of) the manufacturer's complete line of vehicles. This interpretation would, furthermore, tend to defeat the main reaon for providing information to prospective purchasers, since a dealer would never be obligated to provide information on vehicles other than those that happened to be in his possession at a given moment.

We advise you, therefore, that the term "vehicles offered for sale" in the prospective purchaser requirement, 49 CFR @ 375.6(b), refers to all the types of vehicles that a manufacturer represents, or the dealer represents with the permission of the manufacturer, as being available for purchase by the general public at a particular dealer location. The regulation requires that consumer information be provided to prospective purchasers on each of there vehicles on or after January 1, 1970, and to the Administrator 30 days in advance of its availability to prospective purchasers.

ID: nht90-2.15

TYPE: INTERPRETATION-NHTSA

DATE: 04/12/90

FROM: BARRY FELRICE ASSOCIATE ADMINISTRATOR FOR RULEMAKING

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL NHTSA

TITLE: ACTION: PORSCHE'S MODIFIED ANTITHEFT EXEMPTION

ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM BARRY FELRICE -- NHTSA TO MIKE LOVE -- PORSCHE, A 35 PART 543; LETTER DATED 03/30/90 FROM MIKE LOVE -- PORSCHE TO JERRY CURRY -- NHTSA ADMINISTRATOR ON 49 CFR PART 543 EXEMPTION

TEXT: On April 4, 1990, Porsche Cars North America, Inc. (Porsche) submitted a request for approval of a modification to the existing antitheft device for the exempted MY 1990 Porsche 911 and 928 carlines.

Rulemaking has reviewed the changes submitted by Porsche, and finds that the system activation process as described by Porsche would not undermine the device and that it would qualify for de minimis treatment. Porsche has changed the antitheft system by allowing it to additionally monitor the glove box for opening. This means that if the glove box is opened while the system is armed, the alarm will be activated. Previously, the antitheft system would only monitor the vehicle's doors, hood, hatc, igni tion switch, and removal of its radio.

The system's alarm control unit will now be integrated with the central locking and interior light control units to save space and to simplify the vehicle's electrical system. Porsche's antitheft system will also now have the capability to accept other inputs such as motion sensors, and improved diagnostic capability to enhance serviceability.

The new system will continue to be armed by locking either the driver or passenger door with the ignition key. The same points of entry will continue to be monitored by the system and the disabling and alarm features will remain the same. The new syste m will also continue to be as protected and tamper resistant as the current system.

As stated above, Rulemaking does not believe that these changes are significant enough to warrant submission of a full modification petition by Porsche and, therefore, would qualify for de minimis treatment. Accordingly, Rulemaking requests a letter gra nting the change to the antitheft system be forwarded to Porsche, pursuant to Part 543.9(j).

Attachment Letter from Porsche Cars North America, Inc.

ID: 10-001612_Hansen_motorcycle_crs

ID: 1985-02.15

TYPE: INTERPRETATION-NHTSA

DATE: 04/16/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. Alexander E. Nagy

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Alexander E. Nagy 19015 132nd Avenue Sun City West, AZ 85375

Dear Mr. Nagy:

This responds to your letter to this agency, as supplemented by a March 11, 1985 telephone conversation between yourself and Steve Kratzke of my staff. You indicated that you plan to produce golf carts, which would be designed primarily for use on golf courses, but would also be used to transport golfers on the public roads from their homes to the golf course and back. You asked what Federal safety requirements the golf carts would have to meet. As explained below, if your golf carts are used on public highways, have a top speed of 20 mph or less, and have a configuration which readily distinguishes them from other vehicles, they would not be motor vehicles, and therefore would not be subject to this agency's safety standards.

Section 102(3) of the National Traffic and Motor Vehicle Safety Act, as amended (15 U.S.C. 1391 (3)) defines a "motor vehicle" as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.

This agency's safety standards apply only to vehicles which are "motor vehicles" within the meaning of this definition. Vehicles such as forklifts and mobile construction equipment which are sold primarily for off-road use, but which incidentally use the public roads to travel from one job site to another are not considered motor vehicles. On the other hand, vehicles which regularly use the public roads and stay off-road for only limited periods of time are motor vehicles and are subject to our safety standards. NHTSA has generally said that golf carts are not motor vehicles because their use on public roads is intermittent and incidental to their use on golf courses.

However, you stated in your letter and emphasized in the telephone conversation that you intend your golf carts to be regularly used on the public roads to transport golfers and their equipment to and from their homes. Accordingly, the agency's past reasoning as to whether golf carts are motor vehicles (intermittent use on the public roads, which use is purely incidental to use on golf courses) would not apply to these golf carts.

This agency has stated in many prior interpretations that even vehicles which will be used regularly on the public roads will not be considered motor vehicles if such vehicles have a maximum attainable speed of 20 miles per hour (mph) or less and have an abnormal configuration which readily distinguishes them from other vehicles. Golf carts generally have a vehicle configuration which readily distinguishes them from other vehicles, since they do not have doors, a windshield, windshield wipers, and the like. Hence, even if your golf carts are intended to be used on the public roads, they would not be considered motor vehicles if they have a configuration similar to most other golf carts and if their maximum attainable speed is 20 mph or less.

If you decide to build your golf carts so that they would not be classified as motor vehicles, you may wish to contract the Consumer Product Safety Commission to learn if they have any Federal safety regulations applicable to golf carts. Their address is: Office of the General Counsel, U.S. Consumer Product Safety Commission, Washington, D.C. 20207. If you decide to build your golf carts so that they would be;classified as motor vehicles, I have enclosed an information sheet which explains how to obtain copies of this agency's regulations.

Finally, you noted that you may build these golf carts in versions powered by a gasoline engine, an electric motor and batteries, and a hybrid version powered by a gasoline engine and electric motor. You asked if the electric and hybrid versions would have to meet any additional safety requirements. If your golf carts are motor vehicles, and therefore subject to this agency's safety standards, the same safety standards apply regardless of whether the vehicle is driven by a gasoline, electric, or hybrid engine, and there are no additional safety requirements applicable to electric and hybrid vehicles . If your golf carts are not motor vehicles, I must again refer you to the Consumer Product Safety Commission for a response.

If you have any further questions or need further information on this subject, please contact Mr. Kratzke at this address or by telephone at (202) 426-2992.

Sincerely,

Original Signed By

Jeffrey R. Miller Chief Counsel

Enclosure

Alexander E. Nagy 19015 132nd. Ave. Sun City West, AZ 85375

Dept. of Transportation NHTSA Office of Rule Making 400 7th St., SW Washington, D.C. 20590

Dear Sir:

I an planning on designing, developing and manufacturing golf cars. What federal safety requirements will the cars have to meet? Some will be driven by a gasoline engine, others by and electric motor and batteries. In addition, I may also develop a golf car employing a hybrid type power plant, a combination gasoline engine and electric motor. What additional federal safety requirements, if any, would they have to meet?

The golf cars will be designed primarily to traverse golf courses, however, they will also be utilized to transport the golfer from his residence to the golf course and base home.

May I hear from you soon? Thank you.

Yours sincerely,

Alexander E. Nagy Phone #: 602 975-2050

ID: 3259o

Mr. Donald N. Stahl
District Attorney
Office of District Attorney
Bureau of Investigation
Court House
P.O. Box 442
Modesto, CA 95353

Dear Mr. Stahl:

Re: McCoy Tire Service Center D.A. No. CF696

This responds to your letter asking about requirements concerning the importation of tire casings. According to your letter, a routine inspection by the California Highway Patrol (CHP) of a local school district's buses disclosed recapped tires on a bus which did not have DOT markings on the tires. The CHP learned that the tire casings were originally designed for use by a rubber tire train in Japan and were new tires that had been imported for recapping purposes. The tire casings were imported as slicks (no tread design), and the slick was removed. The tires were then recapped using the "bondag" process and sold to the school district. You asked whether it is permissible to import this type of tire casing and, if so, whether the particular type of tire casing meets Department of Transportation standards. Your questions are responded to below. Our opinions are based on the facts provided in your letter.

Before addressing your specific questions, I will provide background information about requirements for tires. All tires which are subject to a Federal motor vehicle safety standard must have the symbol "DOT" molded into the sidewall by the manufacturer or retreader, if those tires are to be imported into the United States. This symbol represents a certification by the manufacturer or retreader that the tire complies with all requirements of the applicable safety standards.

New tires for use on school buses are subject to Federal Motor Vehicle Safety Standard No. ll9 (49 CFR 571.119). Section S6.5(a) of the standard requires that all new tires for use on motor vehicles other than passenger cars have the DOT symbol molded into the sidewall by the manufacturer. Tires without this symbol may not be legally imported. This is also true for used tires manufactured on or after the effective date of Standard No. ll9, March l, l975, with one narrow exception.

Used tires for use on motor vehicles other than passenger cars which have less than 2/32 inch of tread remaining and which are imported solely for the purpose of being retreaded in this country prior to resale may be imported without a DOT symbol on the sidewall. I have enclosed a copy of a June l8, l98l letter to Mr. Roy Littlefield, which explains in detail the requirements of this narrow exception to the requirements that used tires have a DOT symbol on the sidewall to be legally imported.

No Federal safety standard is applicable to retreaded tires for use on motor vehicles other than passenger cars. They may be imported without certification of compliance by the retreader. However, these tires must have a tire identification number marked on the sidewall, per the requirements of 49 CFR Part 574.

Your first question is whether it is permissible to import the type of tire casing at issue. As indicated above, new tires for use on school buses may not be imported without the DOT symbol. However, it is our opinion that the casings at issue are materials needing further manufacturing operations to become completed items of motor vehicle equipment, rather than finished items of motor vehicle equipment (tires which could lawfully be used or sold as they are). This opinion is based on the fact that the casings are being imported as slicks, which generally cannot be used on the public highways under state laws since they have no tread, and since the casings are being imported for purposes of recapping.

Your second question is whether the casings at issue meet Department of Transportation standards. A key issue in answering this question is whether the tires are considered to be retreaded tires or new tires subject to Standard No. ll9. It is our opinion that any tires manufactured by applying new tread to new casings are considered new tires rather than retreaded tires, and are subject to the same requirements as any other new tires.

The National Highway Traffic Safety Administration defines "retreaded" as "manufactured by a process in which a tread is attached to a casing." The term "casing" is defined as "a used tire to which additional tread may be attached for the purpose of retreading." See 49 CFR Part 57l.ll7 and 49 CFR Part 574.3(b).

In the situation you described in your letter, the casings were not used tires at the time the "recapping" took place. Instead, they were simply new tires (originally designed for use on a rubber tire train) which were imported for recapping purposes. These casings would not be considered used tires until they have actually been used (presumably on a train prior to importation, or on the highway, with the new tread attached, in the United States.)

Since the tires at issue were not used tires at the time they were recapped, they are not retreaded tires but are instead new tires, subject to Standard No. ll9. The tires would appear not to comply with Standard No. ll9, given the absence of the DOT symbol. Your letter states that the original manufacturer of the tires has stated that the tires are not suitable by any means for highway use. If the tires are not suitable for highway use after they have been recapped, they may contain a safety-related defect. See l5 U.S.C. l4ll et seq. We note that the defect provisions of the National Traffic and Motor Vehicle Safety Act apply to items of motor vehicle equipment regardless of whether there is an applicable safety standard.

We hope this information is helpful, and we are referring your letter to our Office of Enforcement.

Sincerely,

Erika Z. Jones Chief Counsel

ref:VSA#574#119 d:l2/9/88

ID: 3312o

Mr. Donald N. Stahl
District Attorney
Office of District Attorney
Bureau of Investigation
Court House
P.O. Box 442
Modesto, CA 95353

Dear Mr. Stahl:

Re: McCoy Tire Service Center D.A. No. CF696

This responds to your letter asking about requirements concerning the importation of tire casings. According to your letter, a routine inspection by the California Highway Patrol (CHP) of a local school district's buses disclosed recapped tires on a bus which did not have DOT markings on the tires. The CHP learned that the tire casings were originally designed for use by a rubber tire train in Japan and were new tires that had been imported for recapping purposes. The tire casings were imported as slicks (no tread design), and the slick was removed. The tires were then recapped using the "bondag" process and sold to the school district. You asked whether it is permissible to import this type of tire casing and, if so, whether the particular type of tire casing meets Department of Transportation standards. Your questions are responded to below. Our opinions are based on the facts provided in your letter.

Before addressing your specific questions, I will provide background information about requirements for tires. All tires which are subject to a Federal motor vehicle safety standard must have the symbol "DOT" molded into the sidewall by the manufacturer or retreader, if those tires are to be imported into the United States. This symbol represents a certification by the manufacturer or retreader that the tire complies with all requirements of the applicable safety standards.

New tires for use on school buses are subject to Federal Motor Vehicle Safety Standard No. ll9 (49 CFR 571.119). Section S6.5(a) of the standard requires that all new tires for use on motor vehicles other than passenger cars have the DOT symbol molded into the sidewall by the manufacturer. Tires without this symbol may not be legally imported. This is also true for used tires manufactured on or after the effective date of Standard No. ll9, March l, l975, with one narrow exception.

Used tires for use on motor vehicles other than passenger cars which have less than 2/32 inch of tread remaining and which are imported solely for the purpose of being retreaded in this country prior to resale may be imported without a DOT symbol on the sidewall. I have enclosed a copy of a June l8, l98l letter to Mr. Roy Littlefield, which explains in detail the requirements of this narrow exception to the requirements that used tires have a DOT symbol on the sidewall to be legally imported.

No Federal safety standard is applicable to retreaded tires for use on motor vehicles other than passenger cars. They may be imported without certification of compliance by the retreader. However, these tires must have a tire identification number marked on the sidewall, per the requirements of 49 CFR Part 574.

Your first question is whether it is permissible to import the type of tire casing at issue. As indicated above, new tires for use on school buses may not be imported without the DOT symbol. However, it is our opinion that the casings at issue are materials needing further manufacturing operations to become completed items of motor vehicle equipment, rather than finished items of motor vehicle equipment (tires which could lawfully be used or sold as they are). This opinion is based on the fact that the casings are being imported as slicks, which generally cannot be used on the public highways under state laws since they have no tread, and since the casings are being imported for purposes of recapping.

Your second question is whether the casings at issue meet Department of Transportation standards. A key issue in answering this question is whether the tires are considered to be retreaded tires or new tires subject to Standard No. ll9. It is our opinion that any tires manufactured by applying new tread to new casings are considered new tires rather than retreaded tires, and are subject to the same requirements as any other new tires.

The National Highway Traffic Safety Administration defines "retreaded" as "manufactured by a process in which a tread is attached to a casing." The term "casing" is defined as "a used tire to which additional tread may be attached for the purpose of retreading." See 49 CFR Part 57l.ll7 and 49 CFR Part 574.3(b).

In the situation you described in your letter, the casings were not used tires at the time the "recapping" took place. Instead, they were simply new tires (originally designed for use on a rubber tire train) which were imported for recapping purposes. These casings would not be considered used tires until they have actually been used (presumably on a train prior to importation, or on the highway, with the new tread attached, in the United States.)

Since the tires at issue were not used tires at the time they were recapped, they are not retreaded tires but are instead new tires, subject to Standard No. ll9. The tires would appear not to comply with Standard No. ll9, given the absence of the DOT symbol. Your letter states that the original manufacturer of the tires has stated that the tires are not suitable by any means for highway use. If the tires are not suitable for highway use after they have been recapped, they may contain a safety-related defect. See l5 U.S.C. l4ll et seq. We note that the defect provisions of the National Traffic and Motor Vehicle Safety Act apply to items of motor vehicle equipment regardless of whether there is an applicable safety standard.

We hope this information is helpful, and we are referring your letter to our Office of Enforcement.

Sincerely,

Erika Z. Jones Chief Counsel

/ref:VSA#574#119 d:12/9/88

ID: aiam4290

Dear Ms. Black: This responds to your December 11, 1986 to me concerning Federal Moto Vehicle Safety Standard No. 206, *Door Locks and Door Retention Components*. I apologize for the delay in responding. You ask whether we interpret Standard No. 206 to permit installation of a particular type of door locking system which you referred to as a 'child safety lock.' The answer to your question is yes.; You explain that a 'child safety lock' is a special locking syste installed in addition to the locking system mandated by Standard No. 206. You state that the required locking system (hereinafter referred to as 'the primary locking system') is operated by a vertical plunger located in the door top trim roll (window sill). The child safety lock (which I will refer to as a 'secondary locking system') consists of a lever that is located in the shut face of the rear door which can only be reached when the door is open. When the lever is set in the 'active' position, it renders the inside rear door handle incapable of opening the door. The outside door handle is operative and can be used to open the door.; The requirements of Standard No. 206 for door locks are as follows: >>>S4.1.3 Door locks. Each door shall be equipped with a lockin mechanism with an operating means in the interior of the vehicle.<<<; >>>S4.1.3.1 Side front door locks. When the locking mechanism i engaged, the outside door handle or other outside latch release control shall be inoperative.<<<; >>>S4.1.3.2 Side rear door locks. In passenger cars and multipurpos passenger vehicles, when the locking mechanism is engaged both the outside and inside door handles or other latch release controls shall be inoperative.<<<; As you know, the standard was amended on April 27, 1968, to include th door lock requirements described above. An objective of the amendment was to ensure retention of occupants within the vehicle during and subsequent to an impact by reducing inadvertent door openings due to impact upon movement of inside or outside door handles. Other objectives were to protect against children opening rear door handles, and to afford occupants of the rear of a vehicle a method of unlocking the rear door from inside the vehicle (i.e., a reasonable means of escape) in the postcrash phase of an accident.; Your inquiry raises the issue of the permissibility under S4.1. through S4.1.3.2 for negating the capability of the interior latch release controls (door handles) to operate the door latches when the door locking mechanism is disengaged. As explained below, based on our review of the purpose of Standard No. 206 and past agency interpretations of the standard, we conclude that the standard prohibits only secondary locking systems which interfere with the *engagement* of the primary locking system. Since your child locking systems do not interfere with the manner in which the primary locking system engages, their installation on the vehicles you manufacturer is permitted.; The answer to your question about the child locking systems i 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 S4.1.3.1 and 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 S4.1.3.1 and S4.1.3.2 do 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.; While the agency stated in its April 1968 notice amending Standard No 206 that one purpose of requiring an interior means of operating door locks was to allow a reasonable means of escape for vehicle occupants, the agency did not go further in facilitating escape by also including a provision to require in all circumstances that door handles be operative when the primary locking system are disengaged. Since the agency could easily have included such a provision to address this reverse situation, but did not do so, the implication is that the agency did not intend to impose requirements regarding that situation. In fact, the notice included a contemporaneous interpretation that the standard permits a secondary locking device which rendered the inside rear door handle inoperative even when the primary locking mechanism was disengaged. This affirms that NHTSA did not even intend to impose a requirement that the handles always be operative when the primary locking mechanism is disengaged.; In determining that the performance requirements of Standard No. 20 address only the effects of engaging the required door locks, we noted that the purpose of the standard is to 'minimize the likelihood of occupants being thrown from the vehicle as a result of impact.' Throughout the rulemaking history of the standard, NHTSA has limited application of the standard's performance requirements only to doors that are provided for the purpose of retaining the driver and passengers in collisions. Because the standard is narrowly focused on occupant retention in a vehicle and specifies no performance requirements of occupant egress, we concluded that there is no requirement in the standard that prohibits a device which negates the capability of the inside operating means for the door locks to disengage the locks, provided that the device does not interferer with the engagement of the required door locking system.; Another issue related to your inquiry is whether the location of th operating means for the child locks is regulated by Standard No. 206. We have determined that the answer is no. Secondary locking mechanisms discussed in the final rule adopting the door lock requirements and in past agency letters all were designed so that the operating means for the secondary mechanism was inaccessible when the door was closed. In none of those documents did the agency take exception to that location of the operating means, much less suggest that those means, like the means for the primary locking mechanism, must be located in the vehicle's interior.; This letter interprets Standard No. 206 in a manner that clarifies pas agency statements concerning issues raised by secondary locking systems such as 'child safety locks.' To the extent that the statements contained herein conflict with interpretations made by NHTSA in the past, the previous interpretations are overruled.; Please contact my office if you have further questions. Sincerely, Erika Z. Jones, Chief Counsel