Interpretation ID: nht87-1.84

TYPE: INTERPRETATION-NHTSA

DATE: 06/03/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Leon Steenbock -- Administrative Manager, Engineering, FWD Corporation

TITLE: FMVSS INTERPRETATION

ATTACHMT: 8/13/80 letter from F. Berndt to FWD Corporation (Std. 206)

TEXT: Mr. Leon Steenbock Administrative Manager, Engineering FWD Corporation Clintonville, WI 54929-1590

This responds to you; April 10, 1981, letter to my office asking about the applicability of Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components, to door locks on fire trucks. You enclosed a copy of an August 13, 1980, letter to you from former Chief Counsel Frank Berndt and asked whether Mr. Berndt's opinion concerning fire truck door locks is current. The answer is yes.

In 1985, the National Highway Traffic Safety Administration amended Standard No. 206 to exempt doors equipped with wheelchair lifts from the requirements of the standard. However, since that amendment has no bearing on door locks for fire trucks and beca use we have made no changes to the standard that would affect fire trucks, we confirm that the agency's 1980 interpretation his not been superseded or revised by subsequent interpretations of or amendments to the standard.

For your information, I have enclosed a current copy of Standard No. 206 and information on how you can obtain copies of our motor vehicle safety Standards and other regulations.

Sincerely, Erika Z. Jones Chief Counsel Enclosures

April 10, 1987

U. S. Department of Transportation National Highway Traffic Safety Administration 400 Seventy Street, S.W. Washington, D.C. 20590

Attn: Erika Jones - Chief Counsel

Subject: FMVSS 206 Door Lock; and Door Retention Components

Reference my phone conversation with Deirdie Hom on April 9, 1987 regarding door locks on fire trucks. Find attached a copy of the letter from NHTSA of August 13,1980 which addressed this subject. I asked if opinion given in this letter would still be cu rrent or had there been modifications to the standard that would change this opinion exempting fire trucks from this standards requirements.

As, we plan to discuss this subject at a Dealers Sales meeting the week of April 27, 1987 I would appreciate your earliest consideration of this request.

Sincerely, FWD CORPORATION Leon Steenbock Administrative Manager, Engineering enc: LS/llm PxHONE: 715-823-2141 TELEX:26-3424

(See 8/13/80 letter from F. Berndt to FWD Corporation