Interpretation ID: nht68-3.32

DATE: 05/02/68

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

TO: Weslock Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of April 22, 1968, to Mr. Bridwell has been referred to me for reply.

You state that it is your understanding that the proposed rule making in Docket 2-16 will require door locks on trailers and mobile homes to be so constructed "as to be recessed flush on exterior doors." Federal motor vehicle safety standard No. 206, Door Latches, Hinges, and Locks - Passenger Cars, was originally issued on January 31, 1967 and became effective on January 1, 1968. An amendment to this standard was issued on April 24, 1968 with an effective date of January 1, 1969.

Neither the standard as presently written or the proposed amendment in Docket 2-16 is applicable to trailers and mobile homes. Moreover, there is no provision either in the standard or in the proposed amendment which requires that door locks must be so constructed "as to be recessed flush on exterior doors," even as to those motor vehicles to which the standard applies presently or to which it is proposed to apply in Docket 2-16. For your information, we are enclosing a copy of the recent amendment to Standard No. 206 as attachment No. 1, and a copy of the proposed amendment for Docket 2-16 as attachment No. 2.

In view of the foregoing, you may wish to reconsider your request that we forward to you the comments contained in Docket 2-16. The cost to you for forwarding those comments would be fifty cents a page and the number of pages contained in Docket 2-16 is considerable. Since your understanding of the thrust of Docket 2-16 is not correct, your request for an extension of time to May 25, 1968 is denied.

WESLOCK COMPANY

April 22, 1968

Federal Highway Administration Room 316, Donohoe Building 6th & D Street, S. W. Washington, D. C. 20591

Attention: Lowell K. Bridwell Federal Highway Administrator

Although we have not received Docket 2-16, an amendment to Standard 206, we are told that all interested persons have until April 25, 1968 to file comments.

As manufacturers of locks for trailers and mobile homes, we have reason to believe we are affected by Docket 2-16. By hearsay, we understand that this Docket will require that locks be so constructed as to be recessed flush on exterior doors.

If our understanding is correct, we fear that we, and many other lock manufacturers, may be seriously damaged by this requirement. We respectfully request an extension of time until May 25, 1968 to file comments and shall appreciate your sending us Docket 2-16 for study.

May we also suggest that serious consideration be given to the danger of entrapment in trailers arising from the use of locks which do not open automatically upon turning of the inside knob. To prevent loss of life, it may be wise to require panic-proof locks; that is, those which unlock and open merely by turning the inside knob and which do not depend upon the performance of some precedent operation.

Sincerely,

Ernest Cipriano President