Interpretation ID: aiam0258
Director
Automotive Safety Engineering
General Motors Technical Center
Warren
MI 48090;
Dear Mr. Lundstrom: The Director has asked me to reply to your letter of September 29 1970, concerning the compliance of certain motor vehicles, which General Motors intends to import, with Federal Motor Vehicle Safety Standard No. 206 - Door Locks and Door Retention Components.; Each rear door of these vehicles has, in addition to a 'conventional locking mechanism, a special locking mechanism which is described in your letter as:; >>>'an additional lever located on the rear edge of each door which when placed in its 'lock position', will only allow the door to be opened from outside the vehicle even if the conventional locking knob on the upper portion of the door inside the vehicle is in the unlocked position. The additional lever is covered when the door is closed.'<<<; You ask whether the rear doors on these vehicles comply with S4.1.3 o Standard No. 206, which requires that each door 'shall be equipped with a locking mechanism with an operating means in the interior of the vehicle.; A somewhat similar problem was discussed in the preamble to the Apri 27, 1968 amendment (33 F.R. 6465) to the Standard. As stated there, S4.1.3 does not preclude the installation of a special locking mechanism in addition to the required locking mechanism. However, the required locking mechanism must be able to be engaged or disengaged regardless of whether any additional locking mechanism is engaged or disengaged. If the special locking mechanism does not interfere with the operation of the required locking mechanism on the doors in questions, therefore, it will not constitute a failure to comply with the standard.; Please write if I can be of any further assistance. Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs;