Interpretation ID: nht70-2.33

DATE: 10/29/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Juno Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of August 26, 1970, concerning the compliance of your cut-van motor home with Federal Motor Vehicle Safety Standard No. 206 - Door Locks and Door Retention Components, has been forwarded to this office for reply.

You state that the door in the camper body is located so that no portion of a manikin in any designated seating position would project into the door opening in the side view. If, as it appears, you are correct, the door locks and door retention components on that door are not required to comply with Standard No. 206.

You also state that you believe that the doors on the cab comply with Standard No. 206. As a manufacturer of multipurpose passenger vehicles, you are responsible under the National Traffic and Motor Vehicle Safety Act of 1966 for the compliance of the cab doors with Standard No. 206. Although the van may have been manufactured as a truck, it must, when subsequently converted to a multipurpose passenger vehicle, comply with all multipurpose passenger vehicle standards in effect on the date of manufacturer of your motor home. Therefore, you should(Illegible Word) either from the van manufacturer or by your own tests, that the cab doors comply with Standard No. 206.

Please let us know if we can be of further assistance.