Federal Register / Vol. 72, No. 24 / Tuesday, February 6, 2007 / Proposed Rules 5385 

1On September 15, 2004, the agency proposed 

revisions to FMVSS No. 214, Side impact 

protection, which would likely induce vehicle 

manufacturers to use side curtains as a 

countermeasure (69 FR 55550). The Safe, 

Accountable, Flexible, Efficient Transportation 

Equity Act: A Legacy for Users (SAFETEA–LU) 

added a provision to 49 U.S.C. Chapter 301 which 

requires the agency to conduct a rulemaking 

proceeding to establish performance standards to 

reduce complete and partial ejections of vehicle 

occupants. See 49 U.S.C. 30128(c)(1). Containment 

requirements for side curtains may be one of the 

countermeasures to prevent ejections through side 

glazing. 

A preliminary ‘‘Environmental 

Analysis Check List’’ is available in the 

docket where indicated under 

ADDRESSES. Comments on this section 

will be considered before we make the 

final decision on whether the rule 

should be categorically excluded from 

further environmental review. 

List of Subjects in 33 CFR Part 110 

Anchorage grounds. 

For the reasons discussed in the 

preamble, the Coast Guard proposes to 

amend 33 CFR part 110 as follows: 

PART 110—ANCHORAGE 

REGULATIONS 

1. The authority citation for part 110 

continues to read as follows: 

Authority: 33 U.S.C. 471, 1221 through 

1236, 2030, 2035 and 2071; 33 CFR 1.05–1(g); 

and Department of Homeland Security 

Delegation No. 0170.1. 

2. Amend § 110.60, by revising 

paragraph (o–2) to read as follows: 

§ 110.60 Port of New York and vicinity. 

* * * * * 

(o) * * * 

(o–2) Hudson River, at Nyack. That 

portion of the Hudson River bound by 

the following points: 41°06′06.8′′ N, 

073°54′55.5′′ W; thence to 41°06′06.8′′ N, 

073°54′18.0′′ W; thence to 41°05′00.0′′ N, 

073°54′18.0′′ W; thence to 41°05′00.0′′ N, 

073°55′02.2′′ W; thence along the 

shoreline to the point of origin (NAD 

1983), excluding a fairway in the 

charted cable area that is marked with 

buoys. 

Note: The area is principally for use by 

yachts and other recreational craft. A 

mooring buoy is permitted. 

* * * * * 

Dated: January 24, 2007. 

Timothy S. Sullivan, 

Rear Admiral, U.S. Coast Guard Commander, 

First Coast Guard District. 

[FR Doc. E7–1882 Filed 2–5–07; 8:45 am] 

BILLING CODE 4910–15–P 

DEPARTMENT OF TRANSPORTATION 

National Highway Traffic Safety 

Administration 

49 CFR Part 571 

[Docket No. NHTSA–2006–23882] 

RIN 2127–AH34 

Federal Motor Vehicle Safety 

Standards; Door Locks and Door 

Retention Components 

AGENCY: National Highway Traffic 

Safety Administration, Department of 

Transportation (NHTSA). 

ACTION: Final rule. 

SUMMARY: We are amending our safety 

standard on door locks and door 

retention components in order to add 

and update requirements and test 

procedures and to harmonize with the 

world’s first global technical regulation 

for motor vehicles. Today’s final rule 

adds test requirements and test 

procedures for sliding doors, adds 

secondary latched position 

requirements for doors other than 

hinged side doors and back doors, 

provides a new optional test procedure 

for assessing inertial forces, and extends 

the application of the standard to buses 

with a gross vehicle weight rating 

(GVWR) of less than 10,000 pounds, 

including 12–15 passenger vans. 

Today’s final rule also eliminates an 

exclusion from the requirements of the 

standard for doors equipped with 

wheelchair platform lifts. 

DATES: Today’s final rule is effective 

September 1, 2009. Optional early 

compliance is permitted on and after 

February 6, 2007. Petitions for 

reconsideration must be received by 

March 23, 2007. 

ADDRESSES: Petitions for reconsideration 

must be submitted to: Administrator, 

National Highway Traffic Safety 

Administration, 400 Seventh Street, 

SW., Nassif Building, Washington, DC 

20590–0001. 

FOR FURTHER INFORMATION, CONTACT: For 

technical issues: Mr. Maurice Hicks, 

Structures and Special Systems 

Division, Office of Crashworthiness 

Standards, National Highway Traffic 

Safety Administration, 400 Seventh 

Street, SW., Washington, DC 20590; 

telephone (202) 366–6345; telefax (202) 

493–2739; Maurice.hicks@dot.gov. 

For legal issues: Ms. Rebecca Schade, 

Office of the Chief Counsel, National 

Highway Traffic Safety Administration, 

400 Seventh Street, SW., Washington, 

DC 20590; telephone (202) 366–2992; 

telefax (202) 366–3820. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Executive Summary 

II. Background 

A. Safety Problem 

B. Harmonization Efforts and the Proposed 

Upgrade 

1. Global Technical Regulation (GTR) 

2. Notice of Proposed Rulemaking 

3. Public Comments 

III. SAFETEA–LU 

IV. Upgrade to FMVSS No. 206 

A. The GTR Process 

B. Definitions 

C. Hinged Door Requirements 

1. Load Tests 

2. Inertial Test 

3. Door Hinges 

D. Side Sliding Door Requirements 

1. Side Sliding Door Latch Requirements 

2. Side Sliding Door Test Procedure 

a. Compression Versus Tension 

b. Test Device and Set-Up 

c. Application of Force 

d. Performance Requirement 

A. Door Locks 

B. Applicability 

V. Certification Information 

VI. Costs, Benefits, and the Effective Date 

VII. Regulatory Analyses and Notices 

I. Executive Summary 

Between 1995 and 2003, over 54,000 

motor vehicle occupants were ejected 

annually from their vehicles. Ejections 

through glazing (i.e., ejections through a 

vehicle window) comprised 59 percent 

of all ejections. Twenty-six percent of 

all ejections occurred through openings 

other than side glazing and doors, such 

as windshields, open convertible tops, 

and open truck beds. The remaining 15 

percent of ejections occurred through a 

vehicle door. Given the sources and 

magnitude of the overall safety problem 

posed by ejections from vehicles, the 

agency is addressing the problem 

comprehensively, focusing on ejections 

through glazing as well as ejections 

through doors.1 This final rule focuses 

on those ejections that occur through a 

vehicle door. 

Currently, passenger cars, trucks, and 

multipurpose passenger vehicles must 

comply with Federal Motor Vehicle 

Safety Standard (FMVSS) No. 206, Door 

locks and door retention components. 

Most of this standard’s requirements 

were established in the early 1970s, in 


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2The 1998 Global Agreement was concluded 

under the auspices of the United Nations and 

provides for the establishment of globally 

harmonized vehicle regulations. This Agreement, 

whose conclusion was spearheaded by the United 

States, entered into force in 2000 and is 

administered by the UN Economic Commission for 

Europe’s World Forum for the Harmonization of 

Vehicle Regulations (WP.29). 

3While the Agreement obligates such contracting 

parties to begin their processes, it leaves the 

ultimate decision of whether to adopt the GTR into 

their domestic law to the parties themselves. 

order to minimize the likelihood of 

occupant ejections through side door 

openings. In 1995, these requirements 

were expanded to address back doors. 

While these requirements have 

significantly improved door 

performance over the level of prestandard doors, occupants continue to 

be ejected through doors. 

Crashes such as offset frontals, near 

side impacts, and especially rollovers 

lead to complex loading conditions, 

which cause doors to open. 

Additionally, less complex load 

conditions may occur in many nonrollover conditions. While the agency is 

continuing to develop a repeatable and 

practicable test procedure that will 

address complex loading, today’s final 

rule updates the existing requirements 

and test procedures to ensure the 

strength of individual latch components 

for load conditions that are less 

complex, such as those that occur in 

many non-rollover collisions. 

The agency’s efforts to improve the 

requirements and test procedures of 

FMVSS No. 206 to address door 

ejections in a more satisfactory way 

coincided with the adoption of the 

initial Program of Work under the 1998 

Global Agreement.2 The agency sought 

to work collaboratively on door 

ejections with other contracting parties 

to the 1998 Global Agreement, 

particularly Transport Canada, the 

European Union (EU), and Japan. 

Through the exchange of information on 

ongoing research and testing and 

through the leveraging of resources for 

testing and evaluations, the agency led 

successful efforts that culminated in the 

establishment of the first global 

technical regulation (GTR) under the 

1998 Agreement. 

This first GTR demonstrated that 

U.S./EU regulatory cooperation can 

achieve increased safety and 

harmonized standards that are sciencebased and free of unjustified 

requirements. If adopted into domestic 

law by the U.S. and EU, the GTR on 

door locks and door retention systems 

would essentially eliminate the 

differences between the U.S. and EU 

standards for reducing the likelihood 

that a vehicle’s doors will open in a 

crash, thus allowing the ejection of the 

vehicle’s occupants. Adopting 

amendments based on the GTR will not 

only result in improvements to the U.S. 

standard, but also to the EU standard. 

This will also benefit other countries 

since the EU standard is the United 

Nations’ Economic Commission for 

Europe regulation (ECE R.11), which is 

used by the majority of the world 

community. 

The U.S., as a Contracting Party of the 

1998 Global Agreement that voted in 

favor of establishing this GTR at the 

November 18, 2004 Session of the 

Executive Committee, was obligated 

under the Agreement to initiate the 

process for adopting the provisions of 

the GTR.3 On December 15, 2004, we 

issued a notice of proposed rulemaking 

closely based on the GTR, which 

satisfied this obligation (69 FR 75020; 

Docket No. NHTSA–2004–19840; 

NPRM). The provisions of the GTR 

proposed in the NPRM and adopted in 

today’s final rule will improve the 

current requirements and test 

procedures of FMVSS No. 206, and 

reduce deaths and injuries from door 

ejections. 

This final rule improves the current 

FMVSS No. 206 requirements in several 

areas. First and foremost, with respect to 

sliding doors, it replaces the existing 

requirement with new requirements and 

an associated full vehicle test 

procedure. It requires that sliding side 

doors either have a secondary latched 

position, which serves as a backup to 

the fully latched position and increases 

the likelihood that a striker will remain 

engaged with the latch when the door is 

incompletely closed, or a system to 

signal that the door is not fully closed 

and latched. The fully latched and 

secondary latched positions are also 

required to meet load test requirements 

and to meet inertial requirements the 

same way as the latches on hinged 

doors. 

Second, this final rule requires a 

secondary latched position for a latch 

system on double-doors (previously 

referred to as ‘‘cargo-doors’’). Third, it 

adds a dynamic inertial test procedure 

to FMVSS No. 206 as an optional 

alternative to the current inertial 

calculation. Such a test procedure has 

been conducted in Europe for type 

approval purposes. Fourth, this 

document adds new requirements for 

side doors with rear mounted hinges to 

prevent potential inadvertent openings 

while the vehicle is moving. Fifth, this 

document adds minor modifications to 

our door lock requirements. 

This document also extends the 

application of FMVSS No. 206 to buses 

with a gross vehicle weight rating 

(GVWR) of 4,536 kg (10,000 pounds) or 

less, including 12–15 passenger vans. 

Finally, today’s final rule eliminates an 

exclusion from the requirements of 

FMVSS No. 206 previously provided to 

vehicle doors that were equipped with 

wheelchair platform lifts. 

With the improvements adopted in 

this rule to address non-rollover door 

ejections, we estimate that we will 

prevent 7 deaths and 4 serious injuries, 

annually. These benefits come primarily 

from the changes to the sliding door 

requirements and test procedure. The 

total costs of these improvements are 

estimated to be slightly over $8 million. 

Vehicle manufacturers, and 

ultimately, consumers, both here and 

abroad, can expect to achieve cost 

savings through the harmonization of 

differing sets of standards when the 

contracting parties to the 1998 Global 

Agreement implement the new GTR. 

Further, adopting amendments based on 

the GTR not only result in 

improvements to the FMVSS No. 206, 

but also to the door lock and door 

retention component regulation of the 

United Nations’ Economic Commission 

for Europe (ECE R.11), which is used by 

the majority of the world community. In 

addition to the sliding door test 

procedure, the side door with rear 

mounted hinge requirements, and the 

inertial test procedure that are discussed 

above, ECE R.11, when amended per the 

GTR, will benefit from the inclusion of 

back door requirements and rear door 

locking requirements. To date, those 

requirements have been in place only in 

the U.S. and Canada. 

II. Background 

A. Safety Problem 

As originally established, FMVSS No. 

206 was intended to reduce the 

likelihood of occupant deaths and 

injuries resulting from ejections through 

door openings by keeping vehicle doors 

closed in crashes. The opening of these 

doors was primarily due to structural 

failures in the latch, striker, or hinges. 

Sheet metal failures in the door 

structure or the B-pillar were rare. In 

crashes involving the opening of doors, 

the latch, striker, and hinges were 

subjected to tensile and compressive 

forces along the vehicle’s longitudinal 

(forward-to-aft) and lateral (side-to-side) 

axes. Based on these findings, the 

automotive community concluded that 

the most effective means of reducing 

door openings would be through 

increasing the strength of the door 

retention components. In 1964, the 


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4The force was increased to reduce the number 

of door openings resulting from occupant impacts 

on the interior of the door. SAE responded by 

adopting the same lateral force requirement in SAE 

J839. 

5The rate for ejection through a door in rollover 

crashes (0.75 percent) is higher than in non-rollover 

crashes (0.10 percent). However, the actual number 

of ejections in non-rollover crashes is higher. For 

further discussion on rates of rollover and ejection 

see Section IV. Scope of the Safety Problem, in the 

NPRM. 

6 ‘‘Child Restraint use in 2002: Results from the 

2002 NOPUS Controlled Intersection Study.’’

http://www-nrd.nhtsa.dot.gov/pdf/nrd-30/NCSA/ 

Rpts/2003/ChildRestraints.pdf. 

7The GRSP is made up of delegates from many 

countries around the world, and who have voting 

privileges. Representatives from manufacturing and 

consumer groups also attend and participate in the 

GRSP and informal working groups that are 

developing GTRs. Those that chose not to 

participate are kept apprised of the GTR progress 

from progress reports presented at the GRSP 

meetings. 

Society of Automotive Engineers (SAE) 

developed and issued the first test 

procedures designed to address door 

retention components: SAE 

Recommended Practice J839, Passenger 

Car Side Door Latch Systems (SAE 

J839); and SAE Recommended Practice 

J934, Vehicle Passenger Door Hinge 

Systems (SAE J934). 

As initially issued in the early 1970s, 

FMVSS No. 206 was based, in large part, 

on the SAE recommended practices in 

existence at that time, except that 

NHTSA increased the test force 

requirement in the lateral direction.4

Aside from the changes made in 1995 to 

address back door openings, no 

significant changes have been made to 

the current regulation since the early 

1970s. Even with the strengthened door 

retention components required by the 

standard, ejections due to door openings 

still account for 15 percent of all 

ejections. 

In further analyzing the door 

ejections, the agency found that, on an 

annual basis, during the study period, of 

the 15 percent (7,622) of vehicle 

ejections that occurred through a door, 

4,533 ejections occurred in non-rollover 

crashes (i.e., frontal, side, and rear 

impact crashes) versus 3,089 ejections 

in rollover crashes.5

A portion of door ejections due to 

non-rollover door openings occurred 

through sliding door openings and from 

doors in 12–15 passenger vans. Of those 

ejected through a sliding door, 

approximately 20 people are killed and 

30 people are seriously injured each 

year, based on the 1995–2003 data from 

NASS. Based on the 2003 sales data, 

about 85 percent of vans sold in the U.S. 

have sliding doors. Only 15 percent of 

vans sold have double doors. 

We are particularly concerned that the 

individuals with the greatest exposure 

to sliding door failures are children. 

Children sit in the back of vehicles in 

disproportionately high numbers.6 We 

do not believe that this exposure is 

acceptable when measures can be taken 

to minimize the likelihood that a sliding 

door would open in a crash. With the 

increasing popularity of vehicles with 

sliding doors on both the driver and 

passenger side of the vehicle, we expect 

the number of overall sliding door 

failures to increase unless the doors are 

required to be designed in a way that 

reduces the likelihood of a door 

opening. 

B. Harmonization Efforts and the 

Proposed Upgrade 

1. Global Technical Regulation (GTR) 

The agency’s efforts to update the 

requirements and test procedures of 

FMVSS No. 206 in order to address the 

safety issues elucidated above coincided 

with the adoption of the initial Program 

of Work of the 1998 Global Agreement. 

Globally, there are several existing 

regulations, directives, and standards 

that pertain to door lock and door 

retention components. As all share 

similarities, the international motor 

vehicle safety community tentatively 

determined that these components 

might be amenable to the development 

of a GTR under the 1998 Agreement. 

The Executive Committee of the 1998 

Agreement charged the Working Party 

on Passive Safety (GRSP) to form an 

informal working group to discuss and 

evaluate relevant issues concerning 

requirements for door locks and door 

retention components and to make 

recommendations regarding a potential 

GTR.7

The United States of America (U.S.) 

led the efforts to develop the 

recommended requirements for the 

GTR. The U.S., through this agency, 

sought to work collaboratively on door 

ejections with other contracting parties 

to the 1998 Global Agreement, 

particularly Transport Canada, the 

European Union, and Japan. The GRSP 

considered all relevant standards, 

regulations, and directives and 

evaluated alternative requirements and 

test procedures developed and 

presented by the U.S. and Canada, as 

well as refinements suggested by other 

GRSP delegates and representatives. The 

GRSP concluded its work and agreed to 

recommend the establishment of a GTR 

to the Executive Committee. A detailed 

discussion of the development of the 

GTR was provided in the NPRM. 

On November 18, 2004, the Executive 

Committee approved establishment of 

the GTR. The established GTR includes 

improvements over the current FMVSS 

No. 206. With respect to sliding doors, 

the GTR provides a replacement for the 

existing U.S. requirements and a new 

full vehicle test procedure. It also 

specifies that sliding doors either have 

a secondary latched position or a door 

closure warning system that signals if a 

door is not fully closed. For vehicles 

with side doors with rear mounted 

hinge systems, the GTR adds new 

requirements to prevent potential 

inadvertent openings while a vehicle is 

moving. The U.S., as a Contracting Party 

of the 1998 Agreement that voted in 

favor of establishing this global 

technical regulation, was obligated to 

initiate rulemaking to adopt the 

provisions of the GTR. 

2. Notice of Proposed Rulemaking 

On December 15, 2004, the agency 

issued a notice of proposed rulemaking 

proposing to update FMVSS No. 206 

and provide consistency with the GTR 

(69 FR 75020). First and foremost, with 

respect to sliding doors, we proposed to 

replace the existing requirement with 

new requirements and an associated full 

vehicle test procedure. We also 

proposed to require sliding doors to 

have either a secondary latched position 

or a door closure warning system to 

signal that a door is not fully closed. 

Under the proposal, the fully latched 

and secondary latched positions would 

also be required to meet load test 

requirements and inertial requirements 

the same way as the latches on hinged 

doors. 

Second, we proposed to require a 

secondary latched position for doubledoors, currently referred to as ‘‘cargodoors.’’ This requirement already exists 

in the European and Japanese 

regulations. Third, we proposed in the 

NPRM to add a dynamic inertial test 

procedure to FMVSS No. 206 as an 

optional alternative to the current 

inertial calculation. Such a test 

procedure has been conducted in 

Europe for type approval purposes. 

Fourth, we proposed to add new 

requirements for side doors with rear 

mounted hinges. Fifth, we proposed to 

revise the requirements for door locks. 

Finally, we proposed to extend the 

application of FMVSS No. 206 to buses 

with a GVWR of 4,536 kg (10,000 

pounds) or less, including 12–15 

passenger vans, and to remove an 

exclusion for vehicles equipped with 

wheelchair platform lift systems. 

3. Public Comments 

The agency received comments in 

response to the NPRM from motor 

vehicle manufacturers, motor vehicle 

manufacturer trade associations, vehicle 

component manufacturers, an advocacy 


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8See www.unece.org; click on ‘‘Meetings,’’ and 

Committee on Inland Transportation. 

organization, and an individual citizen. 

Comments were submitted by: Nissan 

North America (Nissan); Porsche Cars 

North America (Porsche); America 

Honda Motor Company Limited 

(Honda); Blue Bird Body Company, a 

bus manufacturer (Blue Bird); Alliance 

of Automobile Manufacturers (Alliance); 

Association of International Automobile 

Manufacturers, Inc. (AIAM); Truck 

Manufacturers Association (TMA); 

TriMark Corporation, a door latch 

manufacturer (TriMark); Delphi, a 

vehicle component manufacturer; 

Advocates for Highway Safety, an 

advocacy organization (Advocates); and 

Barb Sachau, a private citizen. 

Vehicle component manufacturers, 

motor vehicle manufacturers, and their 

representative associations generally 

supported the proposed rulemaking as 

well as the GTR process. These 

commenters did raise issues regarding 

some of the proposed test requirements 

and test procedure specifications. Some 

of these commenters also requested 

additional clarification of the proposed 

rule. 

Advocates generally opposed the GTR 

process as lacking an opportunity for 

involvement from public interest 

groups. Advocates also generally 

opposed the proposed rulemaking, 

stating that it was not stringent enough 

and would not provide adequate 

protection against passenger ejection. 

Ms. Sachau generally requested stronger 

standards for vehicle doors. 

III. SAFETEA–LU 

On August 10, 2005, the President 

signed into law the Safe, Accountable, 

Flexible, Efficient Transportation Equity 

Act: A Legacy for Users (SAFETEA–LU; 

Pub. L. 109–59; 119 Stat. 1144). 

SAFETEA–LU contains a variety of 

provisions directing the Secretary of 

Transportation to undertake 

rulemakings for the purpose of 

improving motor vehicle safety. 

Specifically, § 10301(a) requires that the 

rulemaking proceeding initiated to 

upgrade FMVSS No. 206 be completed 

no later than 30 months after the 

enactment of SAFETEA–LU. Today’s 

final rule fulfils that directive. 

IV. Upgrade to FMVSS No. 206 

A.The GTR Process 

As explained above, our proposal to 

revise and update FMVSS No. 206 was 

coincident to the international effort to 

establish a GTR for door latch systems 

and locks. Advocates expressed concern 

that by coordinating efforts to update 

FMVSSs with the GTR process, there 

would be only marginal changes in 

vehicle safety protection and 

performance. Advocates also expressed 

concern with the apparent lack of 

opportunity for safety organizations to 

be involved in the GTR process, and 

that an ‘‘after-the-fact’’ presentation of a 

draft GTR threatens to abridge the 

agency’s authority. 

This comment by Advocates reflects a 

fundamental misunderstanding of the 

GTR process. Contrary to Advocates’

comment, consumer groups have an 

opportunity to be involved in all aspects 

of the GTR process. 

The GTR process was transparent to 

country delegates, industry 

representatives, and public interest 

groups. Information regarding the 

meetings and negotiations was publicly 

available through notices published 

periodically by the agency and the 

UNECE Web site.8 Consumer groups, 

through Consumer International, 

participated in the debates and 

negotiations of GRSP. In the U.S., notice 

of the proposal to develop a door lock 

and door retention GTR was published 

in the Federal Register (68 FR 5333; 

February 3, 2003; Docket No. NHTSA–

03–14395). Comments were received 

and considered from Advocates and the 

Insurance Institute of Highway Safety. 

On October 8, 2004, the agency again 

discussed the GTR proposal (69 FR 

60460; October 8, 2004; Docket No. 

NHTSA–03–14395). No comments were 

received on this notice. 

Further, once the GTR is agreed upon, 

all contracting parties that voted in 

favor of adopting it must then initiate 

their domestic rulemaking process to 

adopt the GTR. NHTSA published a 

proposal to implement the GTR and 

offered its justifications for adopting the 

proposed changes. Those justifications 

were not simply a recitation that the 

changes were in the GTR. Instead, 

NHTSA offered a point-by-point 

explanation of why it believed the 

proposed changes were better policy for 

the American public. The public was 

given the same opportunity to comment 

and be involved in this proposed 

rulemaking as any other NHTSA 

rulemaking. 

NHTSA then evaluates those 

comments and makes appropriate 

changes to the proposal in response to 

the comments and other new 

information that may become available. 

The fact that the proposal was 

developed from a GTR doesn’t free the 

agency of its legal obligations, including 

the obligation to respond to all 

significant comments. Thus, it is not 

apparent why Advocates suggested that 

comments on proposals based on GTRs 

are ‘‘after the fact.’’

Of course, when NHTSA does not 

adopt the proposed version of a GTR, 

the agency will report the changes made 

in the United States back to the 

Executive Committee of the 1998 

Agreement. Based on comments to the 

NPRM in this rulemaking, there are 

some minor differences between the 

Final Rule and the GTR. With the 

acceptance of the GTR, the GRSP 

recognized that further refinements and 

improvements to the language and test 

procedures would be needed and 

planned to identify these through the 

U.S. regulatory process. Over the last 

year, NHTSA has reported to GRSP that, 

as a result of comments to the NPRM, 

we would be making minor 

clarifications to the test procedures and 

the regulatory language in the U.S. 

safety standard. Once the Final Rule is 

published, the GRSP is expecting the 

U.S. proposal to amend the GTR to align 

the text of both requirements. 

We repeat that the GTR process offers 

tangible benefits for the American 

public. By participating in the GTR 

process, we were able to develop a 

better regulation by advancing our 

research efforts and leveraging resources 

through partnering with other countries. 

If we were to have undertaken revisions 

to FMVSS No. 206 independent of the 

GTR process, the agency would have 

incurred higher costs and would have 

required additional time to move 

forward with the rulemaking. The 

international effort helped identify 

concerns and difficulties that were 

present in requirements and test 

procedures that NHTSA was planning 

on proposing in the NPRM and resulted 

in improvements that the agency could 

not have achieved on its own. Through 

this international cooperation the 

sliding door test procedures were 

validated by another country, which 

identified problems in the existing test 

procedures which resulted in the 

improved procedure and regulatory 

language adopted in this document. 

Additionally, from testing already 

conducted in Europe, we were able to 

add a test procedure for the existing 

optional dynamic inertial test for which 

NHTSA had no test procedure 

previously. 

B. Definitions 

The agency is essentially adopting the 

definitions for FMVSS No. 206 as 

proposed, and with additional 

clarification of the definitions for 

‘‘primary door latch’’ and ‘‘auxiliary 

door latch.’’ Today’s rule requires that 

each hinged door system be equipped 

with at least one primary door latch 


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system, which is defined as consisting 

of at a minimum, a primary door latch 

and a striker. A primary latch was 

defined in the NPRM and GTR as a latch 

equipped with both a fully latched and 

a secondary latched position. 

Conversely, an auxiliary latch was 

defined as a latch equipped with a fully 

latched position and fitted to a door or 

door system equipped with a primary 

latch. An auxiliary latch may be 

equipped with a secondary latched 

position, but it is not required to meet 

the secondary latch requirements 

mandated for a primary latch. 

A problem occurs in identifying the 

primary latch on a door or door system 

if the door or door system is also 

equipped with an auxiliary latch that 

has a secondary latch position. If both 

latches have a secondary latched 

position, it is not obvious which latch 

is the primary latch. At the GRSP, the 

International Organizations of Motor 

Vehicle Manufacturers (OICA) requested 

that the definitions of primary and 

auxiliary latches be revised in order to 

differentiate between the two types of 

latches for compliance purposes. 

Today’s rule requires manufacturers to 

designate one of the latches as the 

primary latch in connection with their 

certification of compliance and to 

identify the primary door latch when 

asked to do so by the agency. Such a 

request would be made in connection 

with an agency inquiry regarding 

compliance with the standard. Also the 

definition of ‘‘auxiliary latch’’ adopted 

in today’s document clarifies that an 

auxiliary latch may be equipped with a 

secondary latched position. NHTSA has 

already proposed an amendment to the 

GTR to reflect these clarifications, and 

the amendment was accepted by GRSP. 

C. Hinged Doors Requirements 

1. Load Tests 

FMVSS No. 206 specifies load test 

requirements for latch and hinge 

systems on hinged side doors in the 

longitudinal and transverse directions. 

We did not propose significant changes 

to the existing requirements for latches 

on hinged side doors. Consistent with 

the GTR, we proposed regulatory text 

that removed any implication that the 

latch load is applied relative to the 

vehicle orientation. In the NPRM, we 

proposed to require a secondary latched 

position for ‘‘double doors,’’ which had 

been referred to as cargo-doors in 

FMVSS 206. To the extent a 

requirement for the secondary positions 

may prevent inadvertent door openings, 

we believe it would be beneficial for 

double doors. This requirement already 

exists in the ECE standard. We also 

proposed for the transverse requirement 

to apply to a primary door latch system 

in the fully latched and secondary latch 

position and to an auxiliary door latch 

system in the fully latched position. We 

are adopting the load test requirements 

as proposed, but with corrections and 

clarifications as suggested by 

commenters. 

Comments from manufacturers 

generally supported the side door hinge 

system requirements as proposed. The 

Alliance generally agreed with the 

proposed rule as applied to hinged 

doors but requested additional 

clarification and corrections to the 

requirements as proposed. It requested 

clarification that the vertical hinge load 

requirement at S4.1.2.1(d) applies to 

back doors only. TMA requested 

clarification as to whether the vertical 

load test procedure in S5.1.2.3(c) 

applies only to back doors. The Alliance 

also requested that the sign conventions 

used for the vehicle coordinate 

reference system be changed to 

correspond to SAE J1100 Feb 2001 and 

SAE J211–1 Dec 2003. The Alliance 

requested that the section titles for 

S4.1.1 and S5.1.1 be revised to reflect 

that these sections apply to primary and 

auxiliary latches and latch systems. It 

commented that the test plate 

specification for the secondary latched 

position (S5.1.1.1(b)(4)) should also 

apply to the fully latched position. The 

Alliance also noted that the reference to 

S4.2.3 in S5.1.1.4 appears incorrect. 

The Alliance and TMA are correct in 

that the vertical load requirement of 

S4.1.2.1(d) and the vertical load test 

procedure in S5.1.2.3(c) apply only to 

back doors that open upward. The 

regulatory text has been changed to 

clarify the application of these sections. 

Today’s rule also incorporates sign 

conventions for the vehicle coordinate 

reference system consistent with SAE 

J1100 Feb 2001 and SAE J211–1 Dec 

2003. Consistent use of sign conventions 

between FMVSS No. 206 and the SAE 

standards will minimize any potential 

for confusion. Today’s rule also amends 

the headings for S4.1.1 and S5.1.1 to 

reflect that these sections apply to 

primary and auxiliary latches and latch 

systems. We are also revising S5.1.1.4 to 

correctly reference S4.2.1.3, instead of 

S4.2.3. The above clarifications will also 

be included in the U.S. proposal to 

amend the GTR. 

Advocates commented that the 

requirements for latch systems on 

hinged side doors as proposed were not 

stringent enough and that primary and 

auxiliary latch systems should be 

subject to the same requirements. The 

commenter stated that the load 

requirements do not replicate real world 

crash levels and continue to allow the 

use of the forkbolt striker engagement 

design. Advocates also objected to 

double door auxiliary latches not being 

subject to transverse load requirements. 

Advocates further commented, that 

while it supported the agency’s proposal 

for secondary latching on double doors, 

the proposed load test is incomplete and 

does not replicate real-world crash 

forces that could result in the failure of 

the traditional fork/bolt and pin/striker 

designs used for double door closures. 

NHTSA does not agree with 

Advocates’ assertion that the proposed 

requirements were not sufficiently 

stringent. NHTSA has done numerous 

studies regarding real-world door latch 

loading. See Docket No. 3705. The 

analyses of the data in those studies 

concluded that there is no evidence that 

increased latch strength would reduce 

ejections through the door. First door 

openings in a crash are an infrequent 

event. Using the 1995 to 2003 NASS 

data, door openings occur in less than 

one percent of all vehicle crashes. When 

door openings do occur, they are 

overwhelmingly a result of a failure of 

the supporting structure, not the latch 

mechanism. See Docket No. 3705–11. 

As discussed in the NPRM for this 

rulemaking, NHTSA has devoted its 

efforts to developing a test that will 

assess the potential for structural 

failure. This combination test procedure 

would be capable of testing at higher 

and more complex loading conditions, 

and would better simulate loading in 

rollover crashes. However, as also 

discussed in the NPRM for this 

rulemaking, that test is not yet 

sufficiently developed to allow us to 

propose it in this rulemaking. 

Nevertheless, NHTSA is continuing its 

work on this test. 

The GRSP made the following 

commitments with respect to the 

combination test: 

The adoption of the combination test into 

the GTR is not supported at this time due to 

the technical difficulties in conducting the 

test. Instead, the Working Party delegates and 

representatives will continue to review work 

on the modification of the United States of 

America-based procedure, or the 

development of a new procedure, to capture 

the benefits associated with a test addressing 

door failures due to simultaneous 

compressive longitudinal and tensile lateral 

loading of latch systems in real world 

crashes. Any acceptable procedure developed 

could then be added to the GTR as an 

amendment. ECE/TRANS/180/Add.1; page 

11. 

Thus, there is a consensus within 

GRSP that devoting resources to 

developing a test that assesses the latch 

performance and includes an 


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9As discussed in the NPRM, NHTSA approved a 

GM test procedure in the 1960s. Since that time, no 

other requests have been approved. Such an 

approach is inconsistent with the agency’s usual 

practice over its history, which is to include test 

procedures in the regulatory text of the standard, 

either directly or by incorporation by reference. 

10See presentation from Transport Canada in the 

DOT Docket NHTSA–1999–3705. 

11 Id. 

assessment of structural failure is the 

approach that would reduce ejections 

through the door. Advocates did not 

provide any new information to explain 

why or how it has concluded that 

increasing the stringency of the 

proposed requirements would further 

reduce door ejections. Accordingly, 

NHTSA is not adopting this comment. 

With regard to Advocates’ concern 

with auxiliary latches on double doors, 

we recognize that there may have been 

some confusion with the NPRM. The 

preamble discussion stated that the 

transverse requirement would apply 

only to the primary and not the 

auxiliary door latches. This differs from 

the current requirement in which the 

latches on a single double door must 

jointly resist force loading in the lateral 

direction, i.e., the transverse load 

requirement for each latch is 

determined by dividing a 9,000 N load 

by the number of latches on a single 

door. However, the proposed regulatory 

text would have explicitly required each 

primary and auxiliary latch on a double 

door to separately resist the entire 

transverse load requirement in the fully 

latched position. 

We are adopting the transverse load 

requirement for latches on side hinged 

doors as proposed in the regulatory text 

of the NPRM. This revision establishes 

uniform latching requirements for all 

side hinged door latches. Both primary 

and auxiliary latch systems are required 

to comply with the entire load 

requirement in the fully latched 

position. Also as proposed, this 

document requires primary latch 

systems on hinged side doors to comply 

with a 4,500 N load requirement in the 

secondary latched position. 

2. Inertial Test 

FMVSS No. 206 requires that door 

latch systems on hinged doors and 

sliding doors remain engaged when 

subject to an inertial force of 30 g in the 

longitudinal and transverse directions. 

As FMVSS No. 206 was originally 

established, the agency had specified 

demonstration of compliance with the 

inertial requirement through a 

calculation in accordance with Society 

of Automotive Engineers Recommended 

Practice J839, or a NHTSA approved 

procedure.9

In the NPRM we proposed a dynamic 

inertial test as an option to the existing 

inertial calculation. As proposed, this 

provision would replace the existing 

provision that manufacturers may 

certify to an agency-approved test 

procedure. The proposed inertial test 

procedure was based on the testing 

conducted for United Nations’

Economic Commission for Europe 

Regulation 11 (ECE R.11) type approval. 

It places inertial forces on doors, either 

when installed in the vehicle (full 

vehicle test) or when tested on a test 

fixture (in-frame test), in the 

longitudinal and transverse directions. 

The proposed test procedure was 

validated by the U.S. and Canada during 

the GTR process.10 In proposing the 

procedure, we noted that the proposed 

test is similar to the testing that has 

been relied upon in Europe for typeapproval, but that additional specificity 

may be required in characterizing the 

test fixture. 

In addition to the longitudinal and 

transverse tests, a test in the vertical 

direction was proposed for back doors 

that open in an upward direction. This 

was in response to a finding by 

Transport Canada that the most 

common failure mode in the inertial 

tests conducted by Canada was in the 

direction of door opening.11 We are 

adopting inertial load requirements and 

test procedures generally as proposed, 

but with a clarification regarding the 

force requirements under the dynamic 

compliance options. 

Today’s final rule specifies that under 

the dynamic compliance options, door 

latch systems must not disengage when 

subject to an inertial force as specified 

in the relevant test procedure. Under the 

proposal, the requirements for the 

dynamic options required that the door 

latch system not disengage when subject 

to an inertial load of 30g. Today’s final 

rule clarifies that door latch systems 

must not disengage when subject to a 

30g inertial force when applied as 

specified in the test procedure. Further, 

the test procedure adopted today 

specifies that the force is measured 

based on the acceleration of the sled. 

This is consistent with the sled test 

procedure specified in S13 of FMVSS 

No. 208, Occupant Crash Protection. 

These clarifications and those noted 

above will be included in the U.S. 

proposal to amend the GTR. 

In its comments, Advocates claimed 

that vertical force inertial testing should 

be required for side as well as rear 

doors, particularly side sliding doors 

equipped with only a single latch 

system. Moreover, Advocates contended 

that reliance on foreign test results is 

not acceptable. With respect to the 

Transport Canada test, Advocates stated 

that the testing did not rely on a 

demanding protocol and did not 

reproduce vertical forces, including roof 

crush strength demands that would be 

applied to vehicles in a roll-over. 

Advocates did not provide an 

explanation as to why it believes 

reliance on foreign test results is not 

acceptable. The agency believes that one 

of the benefits of establishing global 

technical regulations is that it leverages 

available data from other countries, 

thereby allowing better allocation of 

agency resources and establishment of 

safety requirements more quickly than if 

the testing and development were 

conducted solely by NHTSA. 

The inertial test requirements and 

procedures adopted today are based 

upon those that have been used 

successfully for many years under typeapproval certification systems. 

However, further specifications for selfcertification systems were necessary. 

Based upon testing performed by 

Transport Canada in association with 

NHTSA, we determined that the results 

and protocol sufficiently validate the 

feasibility of the procedure, and that the 

inertial test requirements adequately 

reflect the crash conditions experienced 

by the U.S. fleet. 

As noted in the NPRM, we believe 

that secondary latches will be necessary 

for sliding doors to pass the new test. 

The primary basis for Advocates’

argument for a vertical inertial test 

appears to be that sliding doors have 

only one latch. However, we believe the 

sliding door test requirement will 

nullify this argument. Furthermore, we 

at this time have no testing or data to 

suggest effectiveness of a vertical 

inertial test requirement, nor did 

Advocates provide any. 

As stated in the NPRM, the focus of 

the GTR and the NPRM were to address 

door system failures in non-rollover 

crashes. As noted above, a combination 

test procedure was developed to 

replicate more complex loading 

experienced in frontal, rear and side 

offset and oblique crashes. However, 

difficulties were encountered with the 

test procedure due to the inability to 

conduct the test on some types of 

latches. This inability precluded our 

adopting the procedure for this 

rulemaking. 

With regard to certification, the 

Alliance noted that manufacturers often 

rely on testing a ‘‘body-in-white’’

vehicle (i.e., a pre-production 

developmental vehicle), whereas the 

FMVSS No. 206 test procedures specify 

testing on post-production vehicles. The 

Alliance requested the agency to 


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confirm its understanding that 

manufacturers are not required to test 

post production vehicles for purposes of 

certification. 

The Alliance is correct in that the test 

procedures in FMVSS No. 206 are not 

requirements. Manufacturers certifying 

compliance with the safety standards 

are not required to follow exactly the 

compliance test procedures set forth in 

the applicable standard. In fact, 

manufacturers are not even required to 

conduct any actual testing before 

certifying that their products comply 

with applicable safety standards. 

However, to avoid liability for civil 

penalties in connection with any 

noncompliance that may be determined 

to exist, manufacturers must exercise 

‘‘reasonable care’’ to assure compliance 

and in making its certification (49 

U.S.C. 30115). It may be simplest for a 

manufacturer to establish that it 

exercised ‘‘reasonable care’’ if the 

manufacturer has conducted testing that 

strictly followed the compliance test 

procedures set forth in the standard. 

However, ‘‘reasonable care’’ might also 

be shown using modified test 

procedures, such as testing on a body in 

white, if the manufacturer could 

demonstrate that the modifications were 

not likely to have had a significant 

impact on the test results. In addition, 

‘‘reasonable care’’ might be shown using 

engineering analyses, computer 

simulations, and the like. 

3. Door Hinges 

The load testing requirements for door 

hinges in the GTR are the same as those 

currently in FMVSS No. 206 and ECE 

R.11. The agency believes that the side 

door requirements for hinges, which are 

based on SAE Recommended Practice 

J934, Vehicle Passenger Door Hinge 

Systems, adequately test the strength 

and design of door hinges. NHTSA has 

fully analyzed its crash data and 

possible failure modes associated with 

the failure of door retention 

components. We have not identified a 

significant safety problem with door 

hinges currently installed in vehicles. 

Accordingly, we are not changing the 

door hinge requirements of FMVSS No. 

206, although we are articulating the 

test procedure for door hinges rather 

than relying on a modified 

incorporation by reference of the 

applicable SAE J839 recommended 

practice. 

D. Side Sliding Door Requirements 

1. Side Sliding Door Latch 

Requirements 

In the NPRM, we proposed to require 

sliding doors to have either: 

1. A primary door latch system that 

meets the same requirements as primary 

door latch systems on hinged side doors 

(i.e., has both a fully and secondary 

latched position), or 

2. A system with a fully latched 

position and a door closure warning 

system to alert the driver when the door 

is not in the fully latched position. 

We stated that this second option 

would ‘‘assure vehicle occupants that a 

sliding door is completely closed.’’ 69 

FR 75026. 

Advocates objected to the option of 

equipping a sliding door with a door 

closure warning system instead of 

requiring all sliding doors to be 

equipped with a secondary latch 

position. Advocates also questioned the 

effectiveness of a door closure warning 

system. That commenter stated that the 

agency should not provide a compliance 

option that relies on occupant behavior, 

as opposed to a mechanical solution, to 

ensure that occupants will not be 

ejected through a door that is not fully 

closed. 

It is appropriate to begin with the 

current requirements in FMVSS No. 206 

to consider this comment. At present, 

FMVSS No. 206 does not require either 

a primary or a secondary latch system 

for sliding doors. The only requirement 

currently applicable to sliding side 

doors in the U.S. is set forth in S4.3, 

which provides that the track and slide 

combination shall not separate when a 

total transverse load of 17,800 Newtons 

is applied. There are currently no 

requirements for the individual latch 

components. 

The proposed GTR upgrades the U.S. 

requirements to require, in addition to 

the existing loading requirement, a latch 

with a fully latched position that meets 

additional loading requirements. We 

believe these new requirements achieve 

Advocates’ suggestion that a mechanical 

solution is more dependable than one 

that requires some human behavior. The 

fully latched position and the associated 

loading requirements are vehicle 

attributes added in this rule. 

As a backup, the proposed rule also 

provided for some supplemental 

protection. The first option is to permit 

a reduced level of protection when the 

latch is not in the fully latched position. 

Under this alternative, the latch must 

have a secondary latched position, 

which is subject to loads 50% or less of 

what the fully latched position must 

meet. The second option is to alert the 

driver that the latch is not in the fully 

latched position, with the expectation 

that the driver will close the sliding 

door so that it is fully latched and 

receive the protection associated with 

the fully latched loading requirements. 

These options for backup protection 

for sliding door latches not in the fully 

latched position have been permitted in 

the ECE regulations for decades now. 

During the discussions of the GTR, the 

European governments said there were 

no data showing better ejection 

prevention with either of the options. 

NHTSA has no data showing a problem, 

since neither has been required in the 

United States, and Advocates did not 

provide any data in its comments. Given 

that the available data in Europe do not 

show a problem with either approach, 

NHTSA has no reason to change its 

proposed upgrade of the sliding door 

requirements in Standard No. 206. 

2. Side Sliding Door Test Procedure 

In addition to the new requirement for 

side sliding door latches, the NPRM also 

proposed a sliding door test procedure 

that evaluates the door as a complete 

system. FMVSS No. 206 currently does 

not include a sliding side door test 

procedure. Since the test produces some 

level of longitudinal force, in addition 

to the direct lateral loading, the door 

components deform and twist. 

Therefore, compliant door latch systems 

will be required to more robust than was 

required in the past. 

We proposed a full vehicle test in 

which a sliding door is tested by 

applying force against the two edges of 

the door. The proposed test setup is 

initiated by placing two loading plates 

against the interior of the door. The 

loading plates are placed on top of the 

latch/striker system located at the door 

edge. If the door edge has two latch/ 

striker systems along one edge, the 

loading plate is placed between the two 

systems. If a door edge does not have a 

latch/striker system, the loading plate is 

placed at a point midway along the 

length of the door edge. An outward 

lateral force of 18,000 N total is then 

applied to the loading plates (i.e., 9,000 

N is applied to each plate). 

The proposed test procedure for the 

sliding door transverse loading test 

specifies that the force application 

device would be mounted on the 

vehicle floor. A test failure would be 

indicated by (1) A separation which 

would permit a sphere with a diameter 

of 100 mm to pass unobstructed 

between the interior of the vehicle to the 

exterior at any point, or (2) the force 

application device reaching a total 

displacement of 300 mm. The proposed 

100 mm of separation requirement, even 

if the latch system does not fail, 

accounts for partial ejections through 

separation of sliding doors from the 

frame without the latch system failing. 

The 100 mm limit is based on a 

commonly used measurement for 


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12See, Docket No. NHTSA–2004–19840–14. 13See Docket No. NHTSA–2004–19840–14. 

maximum allowable open space in the 

U.S. and Canada for school bus opening 

requirements. 

In general, we are adopting the sliding 

door test procedure as proposed. We are 

making several changes to the test 

procedure set-up and the test procedure 

operation in response to concerns raised 

by manufacturers. The changes noted 

below will also be included in the U.S. 

proposal to amend the GTR. 

a. Compression Verses Tension 

Motor vehicle manufacturers raised 

several concerns regarding the sliding 

door test procedure, particularly with 

the test set-up. The Alliance suggested 

applying the force loads in tension as 

opposed to compression. 

The procedure adopted in this rule 

specifies that the force loads are applied 

in compression. In early testing, 

Transport Canada applied force loads in 

tension. However, Transport Canada 

abandoned this force application 

method because of the extent of 

modifications needed to the door being 

tested and the resulting deformation 

that occurred at the attachment points. 

The necessary modifications and the 

deformation resulted in unacceptable 

testing variability. 

b. Test Device and Set-Up 

With regard to the force application 

device as specified in the proposed test 

procedure, Nissan and the Alliance 

favored mounting the device external to 

the vehicle, instead of on the vehicle 

floor. These commenters expressed 

concern that mounting the force 

application device inside the vehicle 

could deform the vehicle floor and 

allow the device to move from its 

original position when applying a load. 

This, they stated, would introduce a 

significant amount of test variability. 

The agency experienced similar 

concerns with the mounting of the test 

device, but resolved the issue through 

use of reinforced plates. The 

reinforcement plates provided a level 

surface for the support of the loading 

device. The plates also distribute 

loading on the floor of the test vehicle 

to reduce the movement of the device 

that could otherwise occur due to 

localized deformation at the attachment 

points. 

During a May 11, 2005 meeting 

between the agency and the Alliance, 

the Ford Motor Company presented the 

results of evaluation testing, which 

demonstrated that use of the 

reinforcement plates on the vehicle floor 

avoids problematic displacement while 

under loading.12

Both the agency and commenters have 

demonstrated the ability to apply the 

requisite load to a vehicle door without 

causing displacement of the force 

application device. In order to minimize 

potential test variability, the final rule 

specifies that a loading device is to be 

rigidly mounted when applying a load. 

As proposed in the NPRM, the load is 

applied to a vehicle door through force 

application plates attached to the ram 

arms of the force application device. 

Nissan asked if the proposed sizes for 

the plates are correlated with a potential 

load area resulting from an occupant 

that impacts the interior of the door. 

NHTSA based the size of the force 

application plates on three 

considerations. First, the width of each 

load plate, 50 mm (2 inches), is 

designed to locate the center of the load 

application over the latch on each door 

edge (a distance of 25 mm (1 inch) from 

the door edge). Second, the length of the 

smaller plate (150 mm (6 inches)) is 

selected to give an area large enough to 

prevent the loading rams from pushing 

through the sheet metal of the door. In 

developmental testing, the 150 mm 

plate did not push through sheet 

metal.13 Third, the length of the larger 

load plate (300 mm (12 inches)) is based 

upon a measurement that is compatible 

to the interior contour of most door 

edges. The door edge contours 

(especially along the top half of the 

door) of many of vehicles tend to be 

highly curved, which dictates where the 

load plates can be positioned. If a plate 

is too long, the contour of a door may 

interfere with the load application. 

We proposed that a force application 

plate 300 mm in length, 50 mm in 

width, and 15 mm in thickness be 

placed equidistant between the multiple 

latches on doors that have more than 

one latch system on a single door edge, 

and this plate would be used to apply 

the load to any tested door edge. The 

Alliance commented that the vertical 

distance between the latches on a single 

door could exceed one meter in length. 

The Alliance stated that applying force 

to such a door with a plate that is 

shorter than the distance between the 

latches could cause the door to bow 

outwards in a manner that does not 

directly apply loading to the latches. 

The Alliance stated that this bowing is 

not representative of a real-world crash 

event and recommended that the load 

plates be extended to a length equal to 

the distance between the latches plus 

150 mm. 

The agency is not adopting the 

Alliance’s suggestion with regard to 

increasing the plate size used for testing 

sliding doors with more than one latch/ 

striker system. We have concluded that 

the force application plate positioning 

proposed in the NPRM and adopted 

today is appropriate for testing vehicle 

doors that have more than one latch 

system, including door designs in which 

the latches are widely spaced. 

A door edge with latches separated by 

a large distance (such as up to or greater 

than 1-meter) could increase the 

likelihood that an occupant impacting 

the interior of the door during a crash 

would force a gap separation. Latches 

with excessive separation may not 

provide as much structural support 

along the length of the entire door edge. 

The proposed procedure, which places 

the force application plate equidistant 

between latches, identifies such 

weaknesses. Further, the agency was 

unable to identify any vehicles that had 

sliding doors equipped with latches 

systems on a door edge that were 

separated by a distance comparable to 

that which concerned the Alliance. 

Therefore, the sliding door test 

procedure is adopted as proposed. 

The Alliance also stated that vehicles 

are currently designed with access holes 

in the door sheet metal, which may not 

provide practicable surface area to place 

the force application plates in the 

location and manner specified in the 

NPRM. The Alliance recommended the 

use of a spreader device, which would 

bridge the access hole and contact the 

door in a manner in an area capable of 

transferring the load to the latch. 

After reviewing the Alliance’s request 

to specify the use of a spreader device, 

we conclude that such a device would 

distribute the load over a large section 

of a vehicle door instead of at the latch/ 

striker component, which is the intent 

of the test. Further, a spreader device 

would act to reinforce a door and alter 

it from its original manufactured 

condition. 

The agency considered other potential 

procedures to accommodate the 

presence of access holes. We evaluated 

moving the force application plate to 

accommodate an access hole, covering 

an access hole with a steel plate, and 

increasing the length of the force 

application plate to accommodate the 

access hole opening. However, each one 

of these alternatives proved to be 

unfeasible. 

Each one of the considered options 

would create compliance testing 

difficulties. Moving the plate to 

accommodate an access hole would 

require us to specify an adequate 

alternative location. This may not be the 

same location for every vehicle. For 

vehicles with an exceptionally long 

access hole or multiple access holes, it 


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14See Docket No. NHTSA–1998–3705–33. 15 Docket No. NHTSA–1998–3705–33. 

could be difficult or impossible to find 

a suitable location for the plate. 

Covering an access hole changes the 

door from its original manufactured 

condition, which is undesirable for 

compliance testing. Increasing the 

length of the load plate to the size of the 

access hole would create test variability 

given that not all access holes are 

uniform in size and location. 

With respect to access holes, we are 

adopting the test procedure as proposed. 

The Alliance did not provide test data 

to support an actual problem existing 

with force application plate size or 

placement and access holes. While the 

Alliance identified a vehicle that had 

access holes located in the area that the 

load plates would be positioned, the 

Alliance never conducted a test to 

demonstrate that the access holes 

actually created a problem. 

Based on our examination of the 

vehicle identified by the Alliance, we 

believe that if the vehicle had been 

tested, the lip of the access hole 

(approximately, 250 mm in length) 

would serve to offer some resistance to 

the plate and eventually, as with all 

sliding door tests, the interior sheet 

metal would quickly deform until the 

plate was in contact with the inside of 

the exterior door shell. Given this 

condition, there should be no difference 

in how the test is conducted, whether 

with or without an access hole present. 

If a latch or retention component exists 

in the boundary of the access hole 

opening, we believe that there should be 

no reason why the plate should not be 

allowed to contact and to apply force 

loading to that component. In such an 

instance the load plate would apply the 

force directly on the retention 

component. 

In its comments, Nissan questioned 

whether the procedure specified in the 

NPRM allows for a rotational joint at the 

connection between the plates and the 

loading arms. The Alliance noted that 

longitudinal displacement of the door 

may occur during testing, causing 

rotational forces and bending moments 

to occur between the load plates and the 

hydraulic rams. The Alliance 

recommended the procedure specify the 

use of socket/swivel joints at the end of 

the loading arms in order for the load 

plate to translate longitudinally and to 

adjust for any contour of the door. The 

Alliance also recommended that the 

procedure specify that the plate edges 

be rounded to a 6 mm radius to avoid 

the edge of the plate acting as a cutting 

edge that would potentially penetrate a 

door’s sheet metal. 

The procedure, as proposed, specified 

that the plates are permitted to rotate in 

the longitudinal direction relative to the 

loading ram. As proposed in the NPRM, 

the loading plates are fixed 

perpendicularly to the hydraulic 

loading arms in a manner that does not 

allow for rotation in a transverse 

direction. Additionally, the loading 

plates are connected directly to the 

hydraulic ram shafts by a threaded stud 

attached to the back of the plate that 

allows for longitudinal rotation. This 

longitudinal rotation allowed for better 

adjustment of the plates to the contour 

of a vehicle door and provided 

acceptable results in testing performed 

by the agency. 

With regard to the permitted rotation 

of the force application plates, we are 

adopting the procedure as proposed. 

The agency is not adopting a procedure 

that would allow for rotation in a 

transverse direction, such as that which 

could be experienced if a swivel joint 

were used. Considerable difference in 

deformation patterns and in the 

direction of the force application 

potentially could result from the use of 

a swivel joint. The potential rotation 

from use of a swivel joint, i.e., rotation 

in both the longitudinal and transverse 

directions, would introduce an 

uncontrollable degree of freedom. Past 

tests have demonstrated that use of a 

swivel joint causes extensive variability 

and repeatability problems.14 Further, 

the test procedure specifies that the 

force application plates are to maintain 

the displacement of the force 

application device in the transverse 

direction. This ensures that as force is 

applied, a door system continues to 

experience a transverse load. 

Although the agency did not 

experience penetration of door sheet 

metal from the loading plates, we 

recognize that without rounded edges 

on the plates, this may be a problem. 

Therefore, we are specifying that the 

loading plates have edges rounded to a 

radius of 6 mm ± 1 mm. 

The proposed test procedure specified 

that the loading plates be placed at the 

‘‘door edge’’ (S5.2.2.3(f)(3), 

S5.2.2.3(g)(3), and S5.2.2.3(h)(3)). The 

proposed test procedure also specified 

that all of the door trim and decorative 

components are to be removed during 

the test set-up. 

In its comments Nissan stated that the 

term ‘‘door edge’’ could be prone to 

misinterpretation and asked that the 

term be further defined. Nissan also 

stated that trim components on a door 

pillar that overlap a sliding door could 

interfere with the test set-up. 

The agency agrees with both of these 

points. Therefore, the procedure 

adopted today further specifies that the 

force application plates are placed 

within 12.5 mm from the interior edge 

of a sliding door. This specification will 

ensure that force is applied directly to 

the portion of the door in which the 

latch mechanism is installed. Typically, 

a latch mechanism is within 12.5 mm of 

the interior edge of a vehicle door. 

Further, we are specifying that pillar 

trim and non-structural components 

that overlap a door be removed to 

permit proper placement of the loading 

plates. 

The Alliance commented that during 

its evaluation of the proposed test 

procedure, the loading plates would 

slide as the door inner panel deflected 

under loading. The Alliance 

recommended the addition of a spreader 

bar with swivels to be used as a 

connection between the load 

application devices. The Alliance 

contends that the spreader bar would: 

(1) Limit the longitudinal motion of the 

loading plates while assuring that the 

lateral load of 9000 N is attained at both 

the fore and aft edges of the door; (2) 

reduce sliding of the loading plates and 

moments into the load cells that lead to 

erroneous load measurements; (3) 

reduce the bending moments 

sufficiently to make the test more 

practicable; (4) reduce the likelihood of 

damage to the test equipment; and (5) 

reduce the risk to laboratory 

technicians. 

Both NHTSA and Transport Canada 

have used a spreader bar, similar to the 

one requested by the Alliance, in 

previous testing when developing the 

sliding door test procedure. Based on 

these tests we concluded that use of a 

spreader bar confines the movement of 

the force application device, thus 

making it inappropriate for testing. 

Because the fore and aft loading plates 

displace unequally, a spreader bar 

causes the load plates to rotate and 

move towards one another. In testing, 

this resulted in abnormal bending forces 

produced at the connection between the 

plates and spreader. 

The force loading device specified in 

NHTSA Vehicle Research and Test 

Center testing used to validate the 

proposed test procedure incorporates 5 

cm box beams for the support of the 

structure.15 The box beams provide 

adequate support and are less prone to 

allow displacement of the hydraulic 

rams. In its initial testing, the Alliance 

did not incorporate supports that 

provide the same level of support as the 

ones specified in today’s test procedure. 

Therefore, we are not amending the 


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procedure to include use of a spreader 

bar. 

However, to control for movement of 

the load application device in order to 

further minimize test variability, the 

procedure adopted today limits 

longitudinal and vertical movements of 

the force application device by 

specifying that a device is to be rigidly 

mounted. 

c. Application of Force 

The sliding test door procedure 

proposed in the NPRM specified that 

each force application device be moved 

at a rate of 20–90 mm per minute until 

a force of 9,000 N is achieved on each 

device, or until either force application 

device reaches a total displacement of 

300 mm. As proposed, if the 9,000 N 

force is achieved, it is held for 10 

seconds. 

The Alliance raised several concerns 

with the specified procedure for 

operating the force application devices. 

First, the Alliance requested that a 500 

N pre-load be applied prior to 

determining the initial position of the 

ram arms for the purpose of measuring 

the transverse displacement of the ram 

arms. The Alliance stated that a pre-load 

of 500 N would ensure that the loading 

plates are correctly positioned and 

would improve repeatability of the test 

by eliminating the effect of free play in 

the system. Specifying a pre-load is 

consistent with the force application 

test procedure specified in S11 of 

FMVSS No. 225, Child restraint 

anchorage systems. 

We agree with the Alliance that a preload for the sliding door test procedure 

would be appropriate. Therefore, we are 

specifying that the test loading device 

achieve a pre-load of 500 N. Once the 

pre-load is achieved the displacement 

measuring devices are then zeroed. 

The Alliance also requested that the 

test procedure define the location and 

procedure for measuring the 300 mm of 

displacement. The commenter 

recommended that the displacement of 

the loading device be measured relative 

to an undisturbed part of the vehicle. 

As explained above, we are specifying 

that a pre-load be applied to a sliding 

door, at which point the displacement 

measuring devices are to be zeroed. 

Given that we establish the point at 

which the displacement of the devices 

are zeroed and limit the movement of 

the force application test device, we do 

not believe it further necessary to 

measure displacement against an 

undisturbed portion of the vehicle. The 

portion of a vehicle that remains 

undisturbed could be different for each 

vehicle model, or even for each 

individual vehicle. By relying on the 

pre-load to establish the initial position 

of ram arm, there is no need to specify 

a portion of the vehicle against which to 

measure displacement. 

Third, the Alliance recommended that 

the test procedure control the load force 

application rather than displacement. 

As stated above, the NPRM proposed to 

control the displacement (20–90 mm per 

minute) until a load of 9000 N is 

reached, and then holding the resulting 

load for 10 seconds. The commenter 

stated that controllers currently in use 

do not allow for simultaneous control of 

both displacement and load, and that 

the procedure as specified would raise 

practicability concerns. 

In response to the Alliance’s concern, 

the procedure adopted today specifies 

that the load be controlled at a rate not 

to exceed 2,000 N per minute. In the 

vehicle testing conducted by NHTSA, a 

load rate of 2,000 N per minute resulted 

in a displacement rate comparable to the 

proposed 20–90 mm displacement rate. 

However, we recognize that given the 

controllers currently in use, controlling 

for the load is a more practical 

procedure. 

Additionally, we are revising the 

procedure to specify holding the 

maximum load for 30 seconds. This 

duration was recommended by the 

Alliance. We also agree that this is 

sufficient time to measure any gap 

separations between the door and 

doorframe as specified by the 

procedure. 

d. Performance Requirement 

The NPRM, consistent with the GTR, 

specified that a test failure is indicated 

by a 100 mm separation of the interior 

of the door from the exterior of the 

vehicle’s doorframe at any point. There 

must not be more than 100 mm of 

separation even if the latch holds, to 

protect against partial ejections. The 100 

mm limit is based on a commonly used 

measurement for maximum allowable 

open space in the U.S. and Canada for 

school bus opening requirements. 

The Alliance recommended that we 

specify the use of a 100 mm sphere to 

on an extension rod to test the gap 

separation requirement. The Alliance 

also requested eliminating S5.2.2.3(j) 

from the test procedure. As proposed, 

this section specified that any 

equipment used for measuring gap 

separations be attached to the vehicle 

prior to the testing. The Alliance stated 

that this is not practical because a 

manufacturer may not be able to predict 

where a separation will occur. 

We recognize that as a practical 

manner the agency and many 

manufacturers likely will use a test 

method similar to that described by the 

Alliance, i.e., through the use of a 

sphere with a 100 mm diameter 

attached to a rod. The agency has used 

a similar procedure in its sliding door 

evaluation testing as well as for 

compliance testing under FMVSS No. 

217, Bus emergency exit and window 

retention and release. The agency has 

been able to perform this procedure 

while maintaining the safety of the 

technicians. However, this is only one 

method that could be used to measure 

a gap and other viable methods may be 

developed, such as laser or telescoping 

measuring devices. While compliance is 

described in terms of passing a sphere, 

we are not adopting the sphere 

procedure as recommended by the 

Alliance. We are eliminating the sphere 

specification in S5.2.2.3(j) to facilitate 

the use of the sphere method or other 

similar techniques. 

Nissan requested clarification as to 

whether a noncompliance would occur 

in a case in which a gap separation 

occurred where the gap measured 

greater than 100 mm at the exterior 

opening, but less than 100 mm at the 

interior of the opening. 

We clarify that the separation 

throughout the gap must exceed 100 

mm for a determination of 

noncompliance. The example provided 

by Nissan would not be a 

noncompliance. This is consistent with 

the intent to limit ejections through a 

separation. 

Both Nissan and the Alliance 

expressed concern that the specified 

period of 10 seconds for maintaining the 

load was not adequate to permit 

measurement of separations between a 

vehicle body and the sliding door. 

Nissan stated that based on its 

experience it could take up to a minute 

to make the necessary measurements. 

The Alliance recommended a period of 

30 seconds. The Alliance stated that this 

would be adequate to limit deformation 

of the door sheet metal and still provide 

enough time for the necessary 

measurements. 

The agency is revising the test 

procedure to specify that the load be 

maintained for 30 seconds. As suggested 

by the Alliance, we believe that it is 

practical to make the specified 

measurements in this time. As stated 

above, we have successfully been able to 

perform this measuring procedure for 

compliance testing under FMVSS No. 

217. 

E. Door Locks 

As proposed, we are adopting two 

minor changes to the door lock 

requirements. First, we are 

distinguishing between exterior and 

interior door locks. All exterior door 


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locks must be capable of being unlocked 

from the interior of the vehicle by 

means of a lock release device which, 

when engaged, shall prevent operation 

of the exterior door handle or other 

exterior latch release control and which 

has an operating means and a lock 

release/engagement device located 

within the interior of the vehicle. 

Interior door locks are subject to the 

same requirements except that for rear 

side doors and back doors, this release 

mechanism must require a separate 

action distinct from the simple 

actuation of the door handle, and the 

release device must be readily 

accessible to the driver of the vehicle or 

an occupant seated adjacent to the door. 

The Alliance commented that the 

proposed door lock provision would 

prohibit a common European rear door 

lock design that permits a vehicle door 

to be unlocked and unlatched with a 

single pull of the handle so long as the 

vehicle has a child safety lock or an 

automatic door locking device. The 

Alliance stated that a requirement for a 

separate action distinct from the simple 

actuation of the door handles to release 

rear side door and back door interior 

locks effectively precludes designs that 

have been in use for many years in 

Europe as well as other markets. The 

Alliance stated that NHTSA did not 

provide data demonstrating a negative 

effect of the GTR provision that permits 

these designs on motor vehicle safety, 

and therefore did not provide 

justification for not proposing the 

provision as contained in the GTR. 

This was a subject that was discussed 

extensively while developing the GTR. 

The standard in the United States and 

Canada has always mandated that the 

interior release mechanism for the door 

locks on side and rear doors must 

require a separate action distinct from 

the simple actuation of the door handle. 

This requirement is in place because of 

our concern that children could 

inadvertently open the back door simply 

by playing with the door handle. A 

system in which a child could open a 

locked door with a single motion would 

almost certainly increase the number of 

inadvertent door openings and place 

child occupants at greater risk of 

ejection. 

The standard for Europe and Japan 

has always permitted rear vehicle doors 

to be unlocked and unlatched with a 

single pull of the door handle, provided 

that the vehicle has a child safety lock 

or an automatic door locking device. 

This regulatory structure reflects a 

concern that rescuers be able to quickly 

open rear doors to assist passengers after 

a crash. These regions believe that the 

requirement for child safety locks 

allows drivers to disable this feature 

when children are riding in the rear 

seat. 

Both of these are plausible safety 

concerns. Neither side to the dispute 

could provide data to resolve the 

problem. Absent a way to resolve this 

difference, the parties agreed to address 

the problem of inadvertent door 

openings by children by either the U.S./ 

Canada approach of requiring a separate 

action to release locked doors in the rear 

or by the European/Japanese approach 

of requiring vehicles to have child safety 

locks or automatic door locking. 

Against this background, the Alliance 

comment is not persuasive. NHTSA 

agrees there are no data to show that 

drivers wouldn’t always engage the 

child safety locks in their vehicles. 

However, if even a few drivers were to 

fail to engage their child safety locks 

and a few children in the rear were to 

open a locked door simply by playing 

with the door handle, those children 

would be at risk for ejection, even 

absent a crash. This risk can be 

ameliorated simply by continuing to 

follow the same requirements that have 

been in place for the interior rear door 

locks of every new car and light truck 

sold in the United States since 1968. 

Moreover, this approach is entirely 

consistent with the GTR. 

F. Applicability 

In the NPRM, the agency proposed 

expanding the applicability of the 

standard to buses with a GVWR of less 

than 10,000 lb and removing an 

exclusion for doors equipped with a 

wheelchair platform lift. Historically, 

FMVSS No. 206 has not applied to 

buses in general because the types of 

doors installed on buses in the 1960s 

were not amenable to testing under the 

standard. The exclusion of wheelchair 

platform lift equipped doors was 

originally adopted in 1985, at which 

time wheelchair lift designs typically 

provided a barrier to occupant 

protection when retracted. When 

retracted, wheelchair lift platforms 

typically covered the doorway opening. 

Changes in the vehicle fleet and in 

technology from the time of original 

adoption of these provisions necessitate 

revisions to the applicability of FMVSS 

No. 206. 

The Alliance commented that the 

final rule should not expand 

applicability of FMVSS No. 206 beyond 

that of the GTR. The Alliance stated that 

expanding the applicability undermines 

the GTR and mitigates the benefits of a 

common global technical requirement. 

The agency believes that all buses 

with a GVWR less than 10,000 lbs 

should be subject to the requirements of 

FMVSS No. 206. These buses are often 

equipped with traditional side-hinged 

doors as opposed to folding doors. With 

the advent of 12- and 15-passenger vans, 

smaller buses are now more frequently 

equipped with traditional side hinged 

doors. For those buses that are equipped 

with folding doors, we are adopting a 

definition of ‘‘folding door’’ that will 

accommodate those types of doors that 

remain unsuitable for testing. Hinged 

doors on buses with a GVWR less than 

10,000 are the same door systems as 

those found on smaller vans, which are 

required to comply with the standard. 

Additionally, we anticipate that the 

impact of the extension will have little 

additional cost to vehicle 

manufacturers. The agency is aware that 

all 12–15 passengers vans, which are 

classified as buses, currently share the 

same door system and latching 

components as other smaller size vans, 

which already meet the requirements of 

our standard. 

Expanding the applicability of the 

standard to include these buses is not 

inconsistent with the GTR process. The 

GTR preamble notes that, ‘‘to address 

concerns about the applicability of door 

retention requirements of heavier 

vehicles, it was proposed that the [GTR] 

only apply to passenger cars, light 

commercial vehicles, and vans, and that 

other vehicles be excluded initially, 

then added in the future after further 

evaluation of various door designs.’’ As 

buses with a GVWR of less than 10,000 

lbs have door designs identical to that 

of vehicles subject to the GTR, there is 

no reason to delay the inclusion of these 

vehicles under FMVSS No. 206. The 

agency intends to recommend that a 

similar provision be adopted by the GTR 

in subsequent revisions. 

Today’s rule also eliminates the 

exclusion of doors equipped with 

platform lifts from the FMVSS No. 206 

requirements. Blue Bird stated that the 

elimination of this exclusion appeared 

only in the NPRM regulatory text, but 

was not discussed in the preamble. Blue 

Bird commented that the platform lift 

exclusion is important to the industry 

and requested that it be retained in the 

final rule. 

As explained in the NPRM, the 

agency adopted the wheelchair platform 

lift exclusion in 1985 in response to a 

petition from Thomas Built Buses (50 

FR 12029; March 27, 1985). At that time, 

wheelchair platform lifts typically 

retracted so as to cover the doorway 

opening and provide an adequate barrier 

to occupant ejections. When we 

established the exclusion the agency 

stated that the barrier created by a 

retracted wheelchair platform lift would 

be sufficient to prevent ejections. 


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A 1998 evaluation revealed that 

wheelchair lift designs have evolved 

such that they no longer provide 

adequate protection for vehicle 

occupants as contemplated when the 

exclusion was adopted. The intent of 

the exclusion was that doors could be 

modified for use with wheelchair lifts 

and could have noncompliant latching 

systems, if the wheelchair lift platform 

could be used to barricade the vehicle 

doorway when in the retracted and 

stored position. This intent is no longer 

met by current wheelchair lift systems, 

which have platforms not covering or 

only partially covering the vehicle 

doorway. For example, some wheelchair 

lift systems connect only to one side of 

a vehicle door frame or have platforms 

that are stored horizontally above the 

vehicle floor and not serving as a 

barricade to the vehicle doorway. Also, 

some power-assisted door openers 

completely disable the OEM door 

latching systems. Disabled door latches 

and a horizontal stored platform would 

not provide an adequate barrier to 

preventing occupant ejection if the door 

were to open during a crash. Further, 

current wheelchair lift designs can be 

installed without modifying the OEM 

door system; installation of a wheelchair 

platform lift does not necessitate 

removal of a vehicle door from 

compliance with FMVSS No. 206. 

Vehicle manufacturers are now 

providing power assisted components 

for the installation of wheelchair 

adaptive equipment. Therefore, the 

exclusion is not necessary for doors 

modified for use with wheelchair lift 

systems. 

V. Certification Information 

Along with its comments, Trimark 

also submitted a series of questions that 

while related to FMVSS No. 206, were 

not directly related to the NPRM. 

Trimark’s questions dealt more with 

compliance testing procedures and selfcertification requirements in general. 

Trimark also asked about the agency’s 

plans to address additional door lock 

and door latch requirements in the 

future. We have addressed Trimark’s 

questions below. 

Trimark notes that S4.1.1.4 requires 

each primary door latch and auxiliary 

door latch system to meet either the 

dynamic requirements specified in 

paragraphs (a) and (b) of that section or 

the calculation requirement. Trimark 

then asked a series of questions 

regarding the calculation. What is the 

definition of the calculation? 

As explained in the NPRM and 

presented in the proposed regulatory 

text, the agency uses the SAE J 839 

definition for the calculation. This is 

consistent with the current FMVSS No. 

206 requirements. 

Trimark further asked if a computer 

simulation could be used, and could a 

pulse be applied in the simulation as it 

is in the dynamic requirement? 

As explained above, FMVSS test 

procedures specify the procedures that 

will be used by the agency to determine 

if a motor vehicle complies with the 

appropriate requirements. We 

understand Trimark’s questions 

regarding the computer simulation to 

refer to a simulation of the dynamic 

requirements. If using reasonable care, 

Trimark relies on modeling to certify to 

the dynamic test, it may do so. 

However, if Trimark were to certify to 

the dynamic test, the agency would 

perform the appropriate dynamic test as 

specified in the standard to determine if 

a vehicle complies. 

Trimark noted that in the NPRM the 

agency referenced a comprehensive plan 

to address vehicle rollover. Trimark 

asked if the plan was subject for public 

review. 

In June 2003 the agency released the 

report, ‘‘Initiatives to Address the 

Mitigation of Vehicle Rollover.’’ This 

report is available at http://wwwnrd.nhtsa.dot.gov/vrtc/ca/capubs/ 

IPTRolloverMitigationReport/. 

Trimark also noted that the agency 

stated that we developed test 

procedures for door closure and 

operability requirements, but that these 

tests need to be validated before issuing 

a separate notice. Trimark asked if these 

test procedures are available for public 

review. 

The agency has not yet proposed door 

closure and operability requirements. 

Therefore, test procedures have not been 

published for review and comment in a 

notice of proposed rulemaking. 

Research results for the test procedures 

can be reviewed in Docket NHTSA–

2004–19840. 

VI. Costs, Benefits, and the Effective 

Date 

This document adds and updates test 

procedures for door latches. We believe 

that only one of these, a new sliding 

door test procedure for FMVSS No. 206, 

will add costs to vehicles and provide 

quantifiable benefits for consumers. The 

agency determined that, aside from 

sliding doors that require the addition of 

a second latch in order to comply with 

the requirements as tested under the 

procedure adopted in the final rule, the 

current fleet complies with the final rule 

adopted today. Further, manufacturers 

failed to provide any data which 

indicates that non-compliant vehicles 

will need significant changes or 

extended timing to come into 

compliance with the proposed 

upgrades. 

The average annual ejections through 

sliding doors from 1995–2003 resulted 

in 20 fatalities and 30 injuries. When an 

occupant is retained in a vehicle and the 

ejection is eliminated, it does not 

necessarily mean that the occupant 

escapes injury. When all vehicles with 

sliding doors meet this proposal, 

annually an estimated 7 fatalities and 4 

occupants with serious to severe 

injuries will be reduced in severity to 

minor injuries (AIS 1) as a result of 

remaining inside the vehicle. 

There were almost 1.4 million vans 

with sliding doors sold in 2003. The 

total number of sliding doors (more than 

2 million) of these vans is higher 

because some of the vans have two 

sliding doors. The sliding door 

requirement, as tested according to the 

new test procedure, essentially requires 

sliding doors to have two latches. An 

estimated 1.2 million sliding doors 

(60%) on 660,000 vans (48%) need a 

second latch to comply. Most of the 

affected vans have two sliding doors. 

The incremental cost of adding a second 

latch is estimated to average $7.00 per 

door. Total costs are estimated at $8.4 

million (in 2003 economics). 

The Alliance requested that 

manufacturers be permitted to comply 

with the final rule according to a phasein schedule consistent with that 

proposed by the agency for the side 

impact upgrade (69 FR 27990; May 17, 

2004; Docket No. NHTSA–2004–17694). 

The Alliance stated that vehicles which 

will require the addition of a second 

latch would require major structural 

modifications to the B-pillars and doors 

to accommodate a two-latch design. 

After considering the comments, the 

agency has decided to establish an 

effective date of September 1, 2009. 

Optional early compliance is permitted 

immediately. This provides 

manufacturers adequate time to make 

the necessary design changes. We do not 

believe it would be appropriate to tie 

the effective date for this rule with that 

of the side impact upgrade, since that 

would result in unnecessary delay in 

obtaining the benefits from this rule. 

The tests for the two rulemakings are 

very different, and the test for this rule 

is not a dynamic crash test. As 

mentioned above, the majority of 

vehicles already comply with the 

proposed upgrades of this rulemaking, 

and those not currently complying 

should not need significant changes to 

come into compliance. 


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VII. Regulatory Analyses and Notices 

A. Vehicle Safety Act 

Under 49 U.S.C. Chapter 301, Motor 

Vehicle Safety (49 U.S.C. 30101 et seq.), 

the Secretary of Transportation is 

responsible for prescribing motor 

vehicle safety standards that are 

practicable, meet the need for motor 

vehicle safety, and are stated in 

objective terms. 49 U.S.C. 30111(a). 

When prescribing such standards, the 

Secretary must consider all relevant, 

available motor vehicle safety 

information. 49 U.S.C. 30111(b). The 

Secretary must also consider whether a 

proposed standard is reasonable, 

practicable, and appropriate for the type 

of motor vehicle or motor vehicle 

equipment for which it is prescribed 

and the extent to which the standard 

will further the statutory purpose of 

reducing traffic accidents and associated 

deaths. Id. Responsibility for 

promulgation of Federal motor vehicle 

safety standards was subsequently 

delegated to NHTSA. 49 U.S.C. 105 and 

322; delegation of authority at 49 CFR 

1.50. 

The agency carefully considered these 

statutory requirements in adopting these 

amendments to FMVSS Nos. 206. 

The amendments to FMVSS No. 206 

will be practicable. This document does 

not adopt significant changes to the 

current requirements of FMVSS No. 

206. With regard to the sliding door 

requirement tested according to the new 

test procedure, 40 percent of current 

sliding doors already would comply. 

Additionally, the amendments 

harmonize the U.S. requirements with 

the global technical regulation. 

These amendments are appropriate 

for the vehicles subject to the 

requirements. Today’s final rule 

continues to exclude vehicle doors for 

which the requirements and test 

procedures are impractical or 

unnecessary (e.g., folding doors, roll-updoors). 

Finally, the agency has determined 

that the amendments provide objective 

procedures for determining compliance. 

The test procedures have been evaluated 

by the agency, and we have determined 

that they produce repeatable and 

reproducible results. The sliding door 

load test procedure and the inertial test 

procedure have also been evaluated by 

the international automotive 

community, which has determined 

them to be practicable. Further, we are 

adopting test procedures to provide 

additional objectivity to existing 

requirements. 

B. Executive Order 12866 and DOT 

Regulatory Policies and Procedures 

Executive Order 12866, ‘‘Regulatory 

Planning and Review’’ (58 FR 51735, 

October 4, 1993), provides for making 

determinations whether a regulatory 

action is ‘‘significant’’ and therefore 

subject to Office of Management and 

Budget (OMB) review and to the 

requirements of the Executive Order. 

The Order defines a ‘‘significant 

regulatory action’’ as one that is likely 

to result in a rule that may: 

(1) Have an annual effect on the 

economy of $100 million or more or 

adversely affect in a material way the 

economy, a sector of the economy, 

productivity, competition, jobs, the 

environment, public health or safety, or 

State, local, or Tribal governments or 

communities; 

(2) Create a serious inconsistency or 

otherwise interfere with an action taken 

or planned by another agency; 

(3) Materially alter the budgetary 

impact of entitlements, grants, user fees, 

or loan programs or the rights and 

obligations of recipients thereof; or 

(4) Raise novel legal or policy issues 

arising out of legal mandates, the 

President’s priorities, or the principles 

set forth in the Executive Order. 

We have considered the impact of this 

rulemaking action under Executive 

Order 12866 and the Department of 

Transportation’s regulatory policies and 

procedures. This rulemaking will not 

have an annual effect on the economy 

of $100 million or more, but is 

significant due to public interest in the 

issues. Therefore, this document was 

reviewed by the Office of Management 

and Budget under E.O. 12866, 

‘‘Regulatory Planning and Review.’’

This document amends 49 CFR Part 

571.206 by adding new performance 

requirements for hinged side doors and 

a new compliance test procedure for 

side sliding doors. These requirements 

must be met by vehicle manufacturers. 

The reason for Federal regulation is that 

consumers do not have any practical 

way of obtaining information relating to 

the strength and safety of sliding doors. 

The cost of modifications for sliding 

doors with one latch is estimated to be 

$7.00 per door, for a total cost to the 

entire fleet of approximately $8.4 

million (2003 dollars). For a further 

explanation of the estimated costs, see 

the Final Regulatory Evaluation 

provided in the docket for this rule. 

C. Executive Order 13132 

NHTSA has examined today’s final 

rule pursuant to Executive Order 13132 

(64 FR 43255, August 10, 1999) and 

concluded that no additional 

consultation with States, local 

governments or their representatives is 

mandated beyond the rulemaking 

process. The agency has concluded that 

the rule does not have federalism 

implications because the rule does not 

have ‘‘substantial direct effects on the 

States, on the relationship between the 

national government and the States, or 

on the distribution of power and 

responsibilities among the various 

levels of government.’’

Further, no consultation is needed to 

discuss the preemptive effect of today’s 

rule. NHTSA rules can have preemptive 

effect in at least two ways. First, the 

National Traffic and Motor Vehicle 

Safety Act contains an express 

preemptive provision: ‘‘When a motor 

vehicle safety standard is in effect under 

this chapter, a State or a political 

subdivision of a State may prescribe or 

continue in effect a standard applicable 

to the same aspect of performance of a 

motor vehicle or motor vehicle 

equipment only if the standard is 

identical to the standard prescribed 

under this chapter.’’ 49 U.S.C. 

30103(b)(1). It is this statutory command 

that preempts State law, not today’s 

rulemaking, so consultation would be 

inappropriate. 

In addition to the express preemption 

noted above, the Supreme Court has 

also recognized that State requirements 

imposed on motor vehicle 

manufacturers, including sanctions 

imposed by State tort law, can stand as 

an obstacle to the accomplishment and 

execution of a NHTSA safety standard. 

When such a conflict is discerned, the 

Supremacy Clause of the Constitution 

makes their State requirements 

unenforceable. See Geier v. American 

Honda Motor Co., 529 U.S. 861 (2000). 

NHTSA has not outlined such potential 

State requirements in today’s 

rulemaking, however, in part because 

such conflicts can arise in varied 

contexts, but it is conceivable that such 

a conflict may become clear through 

subsequent experience with today’s 

standard and test regime. NHTSA may 

opine on such conflicts in the future, if 

warranted. See id. at 883–86. 

D. Executive Order 13045 

Executive Order 13045 (62 FR 19885, 

April 23, 1997) applies to any 

rulemaking that: (1) Is determined to be 

‘‘economically significant’’ as defined 

under E.O. 12866, and (2) concerns an 

environmental, health or safety risk that 

NHTSA has reason to believe may have 

a disproportionate effect on children. If 

the regulatory action meets both criteria, 

we must evaluate the environmental 

health or safety effects of the planned 

rule on children, and explain why the 


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planned regulation is preferable to other 

potentially effective and reasonably 

feasible alternatives considered by us. 

This rulemaking is not subject to the 

Executive Order because it is not 

economically significant as defined in 

E.O. 12866. 

E. Executive Order 12988 

With respect to the review of the 

promulgation of a new regulation, 

section 3(b) of Executive Order 12988, 

‘‘Civil Justice Reform’’ (61 FR 4729, 

February 7, 1996) requires that 

Executive agencies make every 

reasonable effort to ensure that the 

regulation: (1) Clearly specifies the 

preemptive effect; (2) clearly specifies 

the effect on existing Federal law or 

regulation; (3) provides a clear legal 

standard for affected conduct, while 

promoting simplification and burden 

reduction; (4) clearly specifies the 

retroactive effect, if any; (5) adequately 

defines key terms; and (7) addresses 

other important issues affecting clarity 

and general draftsmanship under any 

guidelines issued by the Attorney 

General. This document is consistent 

with that requirement. 

Pursuant to this Order, NHTSA notes 

as follows. The preemptive effect of this 

rule is discussed above. NHTSA notes 

further that there is no requirement that 

individuals submit a petition for 

reconsideration or pursue other 

administrative proceeding before they 

may file suit in court. 

F. Regulatory Flexibility Act 

Pursuant to the Regulatory Flexibility 

Act (5 U.S.C. 601 et seq., as amended by 

the Small Business Regulatory 

Enforcement Fairness Act (SBREFA) of 

1996) whenever an agency is required to 

publish a notice of rulemaking for any 

proposed or final rule, it must prepare 

and make available for public comment 

a regulatory flexibility analysis that 

describes the effect of the rule on small 

entities (i.e., small businesses, small 

organizations, and small governmental 

jurisdictions). However, no regulatory 

flexibility analysis is required if the 

head of an agency certifies the rule 

would not have a significant economic 

impact on a substantial number of small 

entities. SBREFA amended the 

Regulatory Flexibility Act to require 

Federal agencies to provide a statement 

of the factual basis for certifying that a 

rule would not have a significant 

economic impact on a substantial 

number of small entities. 

I certify that this final rule does not 

have a significant economic impact on 

a substantial number of small entities. 

The following is the agency’s statement 

providing the factual basis for the 

certification (5 U.S.C. 605(b)). 

The final rule directly affects motor 

vehicle manufacturers and business that 

design and manufacture door latch 

systems. According to the Small 

Business Administration’s small 

business size standards (see 5 CFR 

121.201), a motor vehicle manufacturer 

(NAICS code 336111, Automobile 

Manufacturing) must have 1000 or fewer 

employees to qualify as a small 

business. A business that designs and 

manufacturers door latch systems 

(NAICS code 336399, All Other Motor 

Vehicle Parts Manufacturing) must have 

750 or fewer employees to qualify as a 

small business. There are four motor 

vehicle manufacturers in the United 

States which would qualify as a small 

business for the purpose of the 

Regulatory Flexibility Act. None of 

these manufacturers make vehicles with 

sliding doors. Vehicle manufacturers 

typically have their door latches 

designed and produced by whollyowned subsidiaries, and would not be 

small businesses for the purpose of the 

Regulatory Flexibility Act. Accordingly, 

there are very few independent vehicle 

door latch manufacturers. 

G. National Environmental Policy Act 

We have analyzed this final rule for 

the purposes of the National 

Environmental Policy Act and 

determined that it does not have any 

significant impact on the quality of the 

human environment. 

H. Paperwork Reduction Act 

Under the Paperwork Reduction Act 

of 1995, a person is not required to 

respond to a collection of information 

by a Federal agency unless the 

collection displays a valid OMB control 

number. The final rule does not contain 

any new information collection 

requirements. 

I. National Technology Transfer and 

Advancement Act 

Section 12(d) of the National 

Technology Transfer and Advancement 

Act of 1995 (NTTAA), Public Law 104–

113, section 12(d) (15 U.S.C. 272) 

directs us to use voluntary consensus 

standards in its regulatory activities 

unless doing so would be inconsistent 

with applicable law or otherwise 

impractical. Voluntary consensus 

standards are technical standards (e.g., 

materials specifications, test methods, 

sampling procedures, and business 

practices) that are developed or adopted 

by voluntary consensus standards 

bodies, such as the Society of 

Automotive Engineers (SAE). The 

NTTAA directs us to provide Congress, 

through OMB, explanations when we 

decide not to use available and 

applicable voluntary consensus 

standards. 

No voluntary consensus standards 

were used in developing the 

requirements because no voluntary 

standards exist that address the subject 

of this rulemaking. However, the SAE 

Recommended Practice J934, September 

1998, Vehicle Passenger Door Hinge 

Systems and SAE Recommended 

Practice J839, September 1998, 

Passenger Car Side Door Latch Systems 

continue to be incorporated by reference 

in the regulatory text. 

J. Unfunded Mandates Reform Act 

Section 202 of the Unfunded 

Mandates Reform Act of 1995 (UMRA) 

requires Federal agencies to prepare a 

written assessment of the costs, benefits 

and other effects of proposed or final 

rules that include a Federal mandate 

likely to result in the expenditure by 

State, local or tribal governments, in the 

aggregate, or by the private sector, of 

more than $100 million in any one year 

(adjusted for inflation with base year of 

1995). Before promulgating a NHTSA 

rule for which a written statement is 

needed, section 205 of the UMRA 

generally requires us to identify and 

consider a reasonable number of 

regulatory alternatives and adopt the 

least costly, most cost-effective or least 

burdensome alternative that achieves 

the objectives of the rule. The 

provisions of section 205 do not apply 

when they are inconsistent with 

applicable law. Moreover, section 205 

allows us to adopt an alternative other 

than the least costly, most cost-effective 

or least burdensome alternative if we 

publish with the final rule an 

explanation why that alternative was 

not adopted. 

The final rule will not impose any 

unfunded mandates under the 

Unfunded Mandates Reform Act of 

1995. This rulemaking does not meet 

the definition of a Federal mandate 

because it would not result in costs of 

$100 million (adjusted annually for 

inflation with a base year of 1995 or 116 

million in 2003 dollars) or more to 

either State, local, or tribal governments, 

in the aggregate, or to the private sector. 

Thus, this rulemaking is not subject to 

the requirements of sections 202 and 

205 of the UMRA. 

K. Regulation Identifier Number (RIN) 

The Department of Transportation 

assigns a regulation identifier number 

(RIN) to each regulatory action listed in 

the Unified Agenda of Federal 

Regulations. The Regulatory Information 

Service Center publishes the Unified 


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Agenda in April and October of each 

year. You may use the RIN contained in 

the heading at the beginning of this 

document to find this action in the 

Unified Agenda. 

L. Privacy Act 

Anyone is able to search the 

electronic form of all comments 

received into any of our dockets by the 

name of the individual submitting the 

comment (or signing the comment, if 

submitted on behalf of an association, 

business, labor union, etc.). You may 

review DOT’s complete Privacy Act 

Statement in the Federal Register 

published on April 11, 2000 (Volume 

65, Number 70; Pages 19477–78) or you 

may visit http://dms.dot.gov. 

List of Subjects in 49 CFR Part 571 

Motor vehicle safety, Reporting and 

Recordkeeping requirements, and Tires. 

In consideration of the foregoing, 

NHTSA amends 49 CFR 571.206 as 

follows: 

PART 571—FEDERAL MOTOR 

VEHICLE SAFETY STANDARDS 

1. The authority citation for Part 571 

continues to read as follows: 

Authority: 49 U.S.C. 322, 30111, 30115, 

30117 and 30166; delegation of authority at 

49 CFR 1.50. 

2. Section 571.206 is amended by: 

(a) Revising S1; S2; the definitions of 

‘‘auxiliary door latch,’’ ‘‘back door,’’

‘‘fork-bolt,’’ ‘‘primary door latch,’’ ‘‘side 

front door,’’ ‘‘side rear door,’’ and 

‘‘trunk lid’’ in S3; S4 through S4.1.1.3; 

S4.1.2; S4.2 through S4.2.1.2; S4.2.2; 

S4.3; S5.1 through S5.1.1.2; S5.1.2; S5.2; 

S5.2.1; S5.2.2; Figure 1; and 

(b) Adding ‘‘auxiliary door latch 

system,’’ ‘‘body member,’’ ‘‘door closure 

warning system,’’ ‘‘door hinge system,’’

‘‘door latch system,’’ ‘‘door member,’’

‘‘door system,’’ ‘‘double door,’’ ‘‘folding 

door,’’ ‘‘fork-bolt opening direction,’’

‘‘fully-latched position,’’ ‘‘hinge,’’

‘‘hinge pin,’’ ‘‘latch,’’ ‘‘primary door 

latch system,’’ ‘‘secondary latched 

position,’’ ‘‘striker,’’ to the definitions in 

S3; S4.1.1.4; S4.1.2.1 through S4.1.2.3; 

S4.2.1.3; S4.2.2.1; S4.2.2.2; S4.3.1; 

S4.3.2; S5; S5.1.1.3; S5.1.1.4; S5.1.2.1 

through S5.1.2.4; S5.2.1.1 through 

S5.2.1.4; S5.2.2.1 through S5.2.2.4; S5.3; 

Figures 2 through 4; Table 1; Figures 5 

through 9; and 

(c) Removing ‘‘cargo-type door’’ and 

‘‘fork-bolt opening’’ from the definitions 

in S3, S4.1.3, S4.1.3.1, S4.4 through 

S4.5, and S5.4 through S5.5, to read as 

follows: 

§ 571.206 Standard 206; Door locks and 

door retention components. 

S1. Scope and Purpose. This standard 

specifies requirements for vehicle door 

locks and door retention components, 

including latches, hinges, and other 

supporting means, to minimize the 

likelihood of occupants being ejected 

from a vehicle as a result of impact. 

S2. Application. This standard 

applies to passenger cars, multipurpose 

passenger vehicles, and trucks, and 

buses with a gross vehicle weight rating 

(GVWR) of 4,536 kg or less. 

S3. Definitions. 

Auxiliary Door Latch is a latch 

equipped with a fully latched position, 

with or without a secondary latched 

position, and fitted to a door or door 

system equipped with a primary door 

latch system. 

Auxiliary Door Latch System consists 

of door latches and strikers other than 

those associated with the primary door 

latch system. 

Back Door is a door or door system on 

the back end of a motor vehicle through 

which passengers can enter or depart 

the vehicle or cargo can be loaded or 

unloaded. It does not include: 

(a) A trunk lid; or 

(b) A door or window composed 

entirely of glazing material and whose 

latches and/or hinge systems are 

attached directly to the glazing material. 

Body Member is that portion of the 

hinge normally affixed to the body 

structure. 

Door Closure Warning System is a 

system that will activate a visual signal 

when a door latch system is not in its 

fully latched position and the vehicle 

ignition is activated. 

Door Hinge System is one or more 

hinges used to support a door. 

Door Latch System consists of latches 

and strikers installed on a door system. 

Door Member is that portion of the 

hinge normally affixed to the door 

structure and constituting the swinging 

member. 

Door System is the door, latch, striker, 

hinges, sliding track combinations and 

other door retention components on a 

door and its surrounding doorframe. 

The door system of a double door 

includes both doors. 

Double Door is a system of two doors 

where the front door or wing door opens 

first and connects to the rear door or 

bolted door, which opens second. 

Folding Door is a movable barrier, 

which will close off an entranceway to 

a bus, multipurpose passenger vehicle 

or truck, consisting of two or more hinge 

panels that swing, slide, or rotate; does 

not have a striker and latch assembly. 

Fork-bolt is the part of the latch that 

engages and retains the striker when in 

a latched position. 

Fork-bolt Opening Direction is the 

direction opposite to that in which the 

striker enters the latch to engage the 

fork-bolt. 

Fully Latched Position is the coupling 

condition of the latch that retains the 

door in a completely closed position. 

Hinge is a device system used to 

position the door relative to the body 

structure and control the path of the 

door swing for passenger ingress and 

egress. 

Hinge Pin is that portion of the hinge 

normally interconnecting the body and 

door members and establishing the 

swing axis. 

Latch is a device employed to 

maintain the door in a closed position 

relative to the vehicle body with 

provisions for deliberate release (or 

operation). 

Primary Door Latch is a latch 

equipped with both a fully latched 

position and a secondary latched 

position and is designated as a ‘‘primary 

door latch’’ by the manufacturer. 

Primary Door Latch System consists of 

a primary door latch(s) and a striker(s). 

Secondary Latched Position refers to 

the coupling condition of the latch that 

retains the door in a partially closed 

position. 

Side Front Door is a door that, in a 

side view, has 50 percent or more of its 

opening area forward of the rearmost 

point on the driver’s seat back, when the 

seat back is adjusted to its most vertical 

and rearward position. 

Side Rear Door is a door that, in a side 

view, has 50 percent or more of its 

opening area to the rear of the rearmost 

point on the driver’s seat back, when the 

driver’s seat is adjusted to its most 

vertical and rearward position. 

Striker is a device with which the 

latch engages to maintain the door in 

the fully latched or secondary latched 

position. 

Trunk Lid is a movable body panel 

that provides access from outside the 

vehicle to a space wholly partitioned 

from the occupant compartment by a 

permanently attached partition or fixed 

or fold-down seat back. 

S4. Requirements. The requirements 

apply to all side and back doors, that 

lead directly into a compartment that 

contains one or more seating 

accommodations and the associated 

door components, except for those on 

folding doors, roll-up doors, detachable 

doors, and on bus doors used only for 

emergency egress purposes and labeled 

accordingly. 

S4.1 Hinged Doors 

S4.1.1 Primary and Auxiliary Door 

Latch Systems. Each hinged door system 

shall be equipped with at least one 


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primary door latch system. By the time 

a vehicle is certified a manufacturer 

shall designate the door latch system(s) 

that is the ‘‘primary door latch 

system(s).’’ Upon certification, a 

manufacturer may not thereafter alter 

the designation of a primary door latch 

system. Each manufacturer shall, upon 

request from the National Highway 

Traffic Safety Administration, provide 

information regarding such designation. 

S4.1.1.1 Load Test One. 

(a) Each primary door latch system 

and auxiliary door latch system, when 

in the fully latched position, shall not 

separate when a load of 11,000 N is 

applied in the direction perpendicular 

to the face of the latch such that the 

latch and the striker anchorage are not 

compressed against each other, when 

tested in accordance with S5.1.1.1. 

(b) When in the secondary latched 

position, the primary door latch system 

shall not separate when a load of 4,500 

N is applied in the same direction 

specified in paragraph (a) of this section 

when tested in accordance with 

S5.1.1.1. 

S4.1.1.2 Load Test Two. 

(a) Each primary door latch system 

and auxiliary door latch system, when 

in the fully latched position, shall not 

separate when a load of 9,000 N is 

applied in the fork-bolt opening 

direction and parallel to the face of the 

latch, when tested in accordance with 

S5.1.1.2. 

(b) When in the secondary latched 

position, the primary door latch system 

shall not separate when a load of 4,500 

N is applied in the same direction 

specified in paragraph (a) of this section 

when tested in accordance with 

S5.1.1.2. 

S4.1.1.3 Load Test Three. 

(Applicable only to back doors that 

open in a vertical direction). Each 

primary door latch system on back 

doors, when in the fully latched 

position, shall not separate when a load 

of 9,000 N is applied in a direction 

orthogonal to the directions specified in 

S4.1.1.1 and S4.1.1.2 when tested in 

accordance with S5.1.1.3. 

S4.1.1.4 Inertial Load. Each primary 

door latch system and auxiliary door 

latch system shall meet either the 

dynamic requirements specified in 

paragraphs (a) and (b) of S4.1.1.4 or the 

calculation of inertial load resistance 

specified in paragraph (c) of S4.1.1.4. 

(a) Each primary door latch and 

auxiliary door latch on each hinged 

door shall not disengage from the fully 

latched position when an inertia load is 

applied to the door latch system, 

including the latch and its activation 

device, in the directions parallel to the 

vehicle’s longitudinal and transverse 

axes with the locking device 

disengaged, when tested as specified in 

S5.1.1.4(b). 

(b) Each primary door latch and 

auxiliary door latch on each hinged 

back door shall also not disengage from 

the fully latched position when an 

inertia load is applied to the door latch 

system, including the latch and its 

activation device, in the direction 

parallel to the vehicle’s vertical axis 

with the locking device disengaged, 

when tested as specified in S5.1.1.4(b). 

(c) Each component or subassembly is 

calculated for its minimum inertial load 

resistance in a particular direction. The 

combined resistance to the unlatching 

operation must assure that the door 

latch system, when properly assembled 

in the vehicle door, will remain latched 

when subjected to an inertial load of 30 

g in the vehicle directions specified in 

paragraph (a) of this section or 

paragraph (b) of this section, as 

applicable, when calculated in 

accordance with S5.1.1.4 (a). 

S4.1.2 Door Hinges. 

S4.1.2.1 When tested in accordance 

with S5.1.2, each door hinge system 

shall: 

(a) Support the door, 

(b) Not separate when a longitudinal 

load of 11,000 N is applied, 

(c) Not separate when a transverse 

load of 9,000 N is applied, and 

(d) For back doors, 

(1) Not separate when a load of 11,000 

N is applied perpendicular to the hinge 

face plate (longitudinal load test) such 

that the hinge plates are not compressed 

against each other (Load Test One). 

(2) Not separate when a load of 9,000 

N is applied perpendicular to the axis 

of the hinge pin and parallel to the 

hinge face plate (transverse load test) 

such that the hinge plates are not 

compressed against each other (Load 

Test Two). 

(3) Not separate when a load of 9,000 

N is applied in the direction of the axis 

of the hinge pin (Load Test Three—only 

for back doors that open in a vertical 

direction). 

S4.1.2.2 If a single hinge within the 

hinge system is tested instead of the 

entire hinge system, the hinge must bear 

a load proportional to the total number 

of hinges in the hinge system. (For 

example, an individual hinge in a twohinge system must be capable of 

withstanding 50% of the load 

requirements of the total system.) 

S4.1.2.3 On side doors with rear 

mounted hinges that can be operated 

independently of other doors, 

(a) The interior door handle shall be 

inoperative when the speed of the 

vehicle is greater than or equal to 4 km/ 

h, and 

(b) A door closure warning system 

shall be provided for those doors. The 

door closure warning system shall be 

located where it can be clearly seen by 

the driver. 

S4.2 Sliding Side Doors. 

S4.2.1 Latch System. Each sliding 

door system shall be equipped with 

either: 

(a) At least one primary door latch 

system, or 

(b) A door latch system with a fully 

latched position and a door closure 

warning system. The door closure 

warning system shall be located where 

it can be clearly seen by the driver. 

Upon certification a manufacturer may 

not thereafter alter the designation of a 

primary latch. Each manufacturer shall, 

upon request from the National 

Highway Traffic Safety Administration, 

provide information regarding such 

designation. 

S4.2.1.1 Load Test One. 

(a) At least one door latch system, 

when in the fully latched position, shall 

not separate when a load of 11,000 N is 

applied in the direction perpendicular 

to the face of the latch such that the 

latch and the striker anchorage are not 

compressed against each other, when 

tested in accordance with S5.2.1.1. 

(b) In the case of a primary door latch 

system, when in the secondary latched 

position, the door latch system shall not 

separate when a load of 4,500 N is 

applied in the same direction specified 

in paragraph (a) of this section when 

tested in accordance with S5.2.1.1. 

S4.2.1.2 Load Test Two. 

(a) At least one door latch system, 

when in the fully latched position, shall 

not separate when a load of 9,000 N is 

applied in the fork-bolt opening 

direction and parallel to the face of the 

latch when tested in accordance with 

S5.2.1.2. 

(b) In the case of a primary door latch 

system, when in the secondary latched 

position, the door latch system shall not 

separate when a load of 4,500 N is 

applied in the same direction specified 

in paragraph (a) of this section when 

tested in accordance with S5.2.1.2. 

S4.2.1.3 Inertial Load. Each door 

latch system certified as meeting the 

requirements of S4.2.1.1 and S4.2.1.2 

shall meet either the dynamic 

requirements specified in paragraph (a) 

of this section or the calculation of 

inertial load resistance specified in 

paragraph (b) of this section. 

(a) The door latch system shall not 

disengage from the fully latched 

position when an inertial load is 

applied to the door latch system, 

including the latch and its activation 

mechanism, in the directions parallel to 

the vehicle’s longitudinal and 


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transversal axes with the locking 

mechanism disengaged, and when 

tested in accordance with S5.1.1.4(b). 

(b) The minimum inertial load 

resistance can be calculated for each 

component or subassembly. Their 

combined resistance to the unlatching 

operation must assure that the door 

latch system, when properly assembled 

in the vehicle door, will remain latched 

when subjected to an inertia load of 30 

g in the vehicle directions specified in 

paragraph (a) of this section, when 

calculated in accordance with 

S5.1.1.4(a). 

S4.2.2 Door System. 

S4.2.2.1 The track and slide 

combination or other supporting means 

for each sliding door, while in the 

closed fully latched position, shall not 

separate from the door frame when a 

total force of 18,000 N along the vehicle 

transverse axis is applied to the door as 

specified in S5.2.2. 

S4.2.2.2 When a sliding door system 

is tested in accordance with S5.2.2, the 

following conditions shall not occur: 

(a) A separation which permits a 

sphere with a diameter of 100 mm to 

pass unobstructed between the exterior 

of the vehicle to the interior of the 

vehicle, while the required force is 

maintained as shown in Figure 1. 

(b) Either force application device 

reaches a total displacement of 300 mm. 

S4.3 Door Locks. Each door shall be 

equipped with at least one locking 

device which, when engaged, shall 

prevent operation of the exterior door 

handle or other exterior latch release 

control and which has an operating 

means and a lock release/engagement 

device located within the interior of the 

vehicle. 

S4.3.1 Rear side doors. Each rear 

side door shall be equipped with at least 

one locking device which has a lock 

release/engagement mechanism located 

within the interior of the vehicle and 

readily accessible to the driver of the 

vehicle or an occupant seated adjacent 

to the door, and which, when engaged, 

prevents operation of the interior door 

handle or other interior latch release 

control and requires separate actions to 

unlock the door and operate the interior 

door handle or other interior latch 

release control. 

S4.3.2 Back doors. Each back door 

equipped with an interior door handle 

or other interior latch release control, 

shall be equipped with at least one 

locking device that meets the 

requirements of S4.3.1. 

S5 Test Procedures. 

S5.1 Hinged Doors. 

S5.1.1 Primary and Auxiliary Door 

Latches. 

S5.1.1.1 Load Test One Force 

Application. The test procedures for 

S4.1.1.1 and S4.2.1.1 are as follows: 

(a) Fully latched position. 

(1) Attach the test fixture shown in 

Figure 2 to the mounting provisions of 

the latch and striker. Align the direction 

of engagement parallel to the linkage of 

the fixture. Mount the fixture with latch 

and striker in the fully latched position 

in the test machine so as to apply a load 

perpendicular to the face of the latch. 

(2) Locate weights so as to apply a 900 

N load tending to separate the latch and 

striker in the direction of the latch 

opening. 

(3) Apply the test load, in the 

direction specified in S4.1.1.1 and 

Figure 5, at a rate not to exceed 5 mm/ 

min until the required load has been 

achieved. Record the maximum load 

achieved. 

(b) Secondary Latched Position. 

(1) Attach the test fixture shown in 

Figure 2 to the mounting provisions of 

the latch and striker. Align the direction 

of engagement parallel to the linkage of 

the fixture. Mount the fixture with latch 

and striker in the secondary position in 

the test machine so as to apply a load 

perpendicular to the face of the latch. 

(2) Locate weights so as to apply a 900 

N load tending to separate the latch and 

striker in the direction of the latch 

opening. 

(3) Apply the test load, in the 

direction specified in S4.1.1.1 and 

Figure 5, at a rate not to exceed 5 mm/ 

min until the required load has been 

achieved. Record maximum load 

achieved. 

(4) The test plate to which the door 

latch is mounted will have a striker cutout configuration similar to the 

environment in which the door latch 

will be mounted on normal vehicle 

doors. 

S5.1.1.2 Load Test Two Force 

Application. The test procedures for 

S4.1.1.2 and S4.2.1.2 are as follows: 

(a) Fully Latched Position. 

(1) Adapt the test fixture shown in 

Figure 3 to the mounting provisions of 

the latch and striker. Mount the fixture 

with latch and striker in the fully 

latched position in the test machine so 

to apply a load in the direction of latch 

opening. 

(2) Apply the test load, in the 

direction specified in S4.1.1.2 and 

Figure 5, at a rate not to exceed 5 mm/ 

min until the required load has been 

achieved. Record the maximum load 

achieved. 

(b) Secondary Latched Position. 

(1) Adapt the test fixture shown in 

Figure 3 to the mounting provisions of 

the latch and striker. Mount the fixture 

with latch and striker in the secondary 

latched position in the test machine so 

as to apply a load in the direction of 

latch opening. 

(2) Apply the test load, in the 

direction specified in S4.1.1.2 and 

Figure 5, at a rate not to exceed 5 mm/ 

min until the required load has been 

achieved. Record the maximum load 

achieved. 

S5.1.1.3 Load Test Three Force 

Application. The test procedures for 

S4.1.1.3 are as follows: 

(a) Adapt the test fixture shown in 

Figure 4 to the mounting provisions of 

the latch and striker. Mount the fixture 

with latch and striker in the fully 

latched position in the test machine so 

as to apply a load in the direction 

specified in S4.1.1.3 and Figure 5. 

(b) Apply the test load, in the 

direction specified in S4.1.1.3 and 

Figure 5, at a rate not to exceed 5 mm/ 

min until the required load has been 

achieved. Record the maximum load 

required. 

S5.1.1.4 Inertial Force Application. 

The test procedures for S4.1.1.4 and 

S4.2.1.3 are as follows: 

(a) Calculation. The calculation is 

performed in accordance with 

paragraph 6 of Society of Automotive 

Engineers Recommended Practice J839, 

Passenger Car Side Door Latch Systems, 

June 1991. 

(b) Dynamic Test. The dynamic 

inertial force application is tested 

according to the setup specified in 

paragraph (1) or (2) of this section. 

(1) Test Setup and Directions for Full 

Vehicle Test. 

(i) Test Setup. 

(A) Rigidly secure the full vehicle to 

an acceleration device that, when 

accelerated together, will assure that all 

points on the crash pulse curve are 

within the corridor defined in Table 1 

and Figure 6. 

(B) Install the equipment used to 

record door opening (doors may be 

tethered to avoid damaging the 

recording equipment). 

(C) Close the door(s) to be tested and 

ensure that the door latch(es) is in the 

fully-latched position, that the door(s) is 

unlocked, and that all windows, if 

provided, on the door(s) are closed. 

(ii) Test Directions. (See Figure 7) 

(A) Longitudinal Setup 1. Orient the 

vehicle so that its longitudinal axis is 

aligned with the axis of the acceleration 

device, simulating a frontal impact. 

(B) Longitudinal Setup 2. Orient the 

vehicle so that its longitudinal axis is 

aligned with the axis of the acceleration 

device, simulating a rear impact. 

(C) Transverse Setup 1. Orient the 

vehicle so that its transverse axis is 

aligned with the axis of the acceleration 

device, simulating a driver-side impact. 


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(D) Transverse Setup 2. (Only for 

vehicles having different door 

arrangements on each side.) Orient the 

vehicle so that its transverse axis is 

aligned with the axis of the acceleration 

device, simulating a side impact in the 

direction opposite to that described in 

b(1)(ii)(C) of this paragraph. 

(2) Test Setup and Directions for Door 

Test. 

(i) Test Setup. 

(A) Mount the door assemblies, 

consisting of at least the door latch(es), 

exterior door handle(s) with mechanical 

latch operation, interior door opening 

lever(s), and locking device(s), either 

separately or combined to a test fixture. 

Each door and striker is mounted to the 

test fixture to correspond to its 

orientation on the vehicle and to the 

directions specified in b(1)(ii) of this 

paragraph. 

(B) Mount the test fixture to the 

acceleration device, and install the 

equipment used to record door opening. 

(C) Ensure that the door latch is in the 

fully-latched position, that the door is 

tethered and unlocked, and that any 

windows are closed. 

(ii) Test Directions. (See Figure 7) 

(A) Longitudinal Setup 1. Orient the 

door subsystem(s) on the acceleration 

device in the direction of a frontal 

impact. 

(B) Longitudinal Setup 2. Orient the 

door subsystem(s) on the acceleration 

device in the direction of a rear impact. 

(C) Transverse Setup 1. Orient the 

door subsystem(s) on the acceleration 

device in the direction of a driver-side 

impact. 

(D) Transverse Setup 2. Orient the 

door subsystem(s) on the acceleration 

device in the direction opposite to that 

described in (b)(2)(ii)(C) of this 

paragraph. 

(E) Vertical Setup 1 (applicable only 

to back doors that open in a vertical 

direction). Orient the door subsystem(s) 

on the acceleration device so that its 

vertical axis (when mounted in the 

vehicle) is aligned with the axis of the 

acceleration device, simulating a 

rollover impact where the force is 

applied in the direction from the top to 

the bottom of the door (when mounted 

in a vehicle). 

(F) Vertical Setup 2 (applicable only 

to back doors that open in a vertical 

direction). Orient the door subsystem(s) 

on the acceleration device so that its 

vertical axis (when mounted in the 

vehicle) is aligned with the axis of the 

acceleration device, simulating a 

rollover impact where the force is 

applied in the direction opposite to that 

described in (b)(2)(ii)(E) of this 

paragraph. 

(3) Test Operation. 

(i) The acceleration device platform 

shall be instrumented with an 

accelerometer and data processing 

system that conforms to the 

requirements specified in Society of 

Automotive Engineers (SAE) 

Recommended Practice J211 December 

2003, ‘‘Instrumentation for Impact 

Test—Part 1—Electronic 

Instrumentation’’, Channel Class 60. 

The accelerometer sensitive axis is 

parallel to the direction of test platform 

travel. 

(ii) Maintaining a minimum 

acceleration level of 30 g for a period of 

at least 30 ms, while keeping the 

recorded acceleration within the pulse 

corridor defined in Table 1 and Figure 

6, accelerate the acceleration device in 

the following directions: 

(A) For Full Vehicle Tests, in the 

directions specified in 

S5.1.1.4(b)(1)(ii)(A) through 

S5.1.1.4(b)(1)(ii)(D). 

(B) For Door Tests, in the directions 

specified in S5.1.1.4(b)(2)(ii)(A) through 

S5.1.1.4(b)(2)(ii)(F). 

(iii) Check recording device for door 

opening and/or closure during the test. 

(iv) If at any point in time, the pulse 

exceeds 36 g and the test specifications 

are met, the test shall be considered 

valid. 

S5.1.2 Door Hinges. The test 

procedures for S4.1.2 are as follows: 

S5.1.2.1 Multiple Hinge Evaluation; 

S5.1.2.1.1 Longitudinal Load Test. 

(a) Attach the test fixture illustrated in 

Figure 8 to the mounting provisions of 

the hinge system. Hinge attitude is 

configured to simulate vehicle position 

(door fully closed) relative to the hinge 

centerline. For test purposes, the 

distance between the extreme end of 

one hinge in the system to the extreme 

end of another hinge in the system is to 

be set at 406 mm ± 4 mm. The load is 

to be applied equidistant between the 

linear center of the engaged portions of 

the hinge pins and through the 

centerline of the hinge pin in the 

longitudinal vehicle direction (see 

Figure 8). 

(b) Apply the test load at a rate not to 

exceed 5 mm/min until the required 

load has been achieved. Record 

maximum load achieved. 

S5.1.2.1.2 Transverse Load Test 

(a) Attach the test fixture shown in 

Figure 8 to the mounting provisions of 

the hinge system. Hinge attitude is 

configured to simulate vehicle position 

(door fully closed) relative to the hinge 

centerline. For test purposes, the 

distance between the extreme end of 

one hinge in the system to the extreme 

opposite end of another hinge in the 

system is to be set at 406 mm ± 4 mm. 

The load is to be applied equidistant 

between the linear center of the engaged 

portions of the hinge pins and through 

the centerline of the hinge pin in the 

transverse vehicle direction (see Figure 

8). 

(b) Apply the test load at a rate not to 

exceed 5 mm/min until the required 

load has been achieved. Record 

maximum load achieved. 

S5.1.2.2 Back Door Hinge Load Test 

(a) Load Test One 

(1) Attach the test fixture illustrated 

in Figure 8 to the mounting provisions 

of the hinge system. Hinge attitude is 

configured to simulate vehicle position 

(door fully closed) relative to the hinge 

centerline. For test purposes, the 

distance between the extreme end of 

one hinge system in the system to the 

extreme opposite end of another hinge 

system is to be set at 406 ± 4 mm. The 

load is to be applied equidistant 

between the linear center of the engaged 

portions of the hinge pins and through 

the centerline of the hinge pin, and as 

specified in S4.1.2.1(d)(1). (See Figure 

9). 

(2) Apply the test load at a rate not to 

exceed 5 mm/min until the required 

load has been achieved. Failure consists 

of a separation of either hinge. Record 

the maximum load achieved. 

(b) Load Test Two 

(1) Attach the test fixture illustrated 

in Figure 8 to the mounting provisions 

of the hinge system. Hinge attitude is 

configured to simulate vehicle position 

(door fully closed) relative to the hinge 

centerline. For test purposes, the 

distance between the extreme end of 

one hinge system in the system to the 

extreme opposite end of another hinge 

system is to be set at 406 ± 4 mm. The 

load is to be applied equidistant 

between the linear center of the engaged 

portions of the hinge pins and through 

the centerline of the hinge pin, and as 

specified in S4.1.2.1(d)(2). (See Figure 

9). 

(2) Apply the test load at a rate not to 

exceed 5 mm/min until the required 

load has been achieved. Failure consists 

of a separation of either hinge. Record 

the maximum load achieved. 

(c) Load Test Three 

(1) Attach the test fixture illustrated 

in Figure 8 to the mounting provisions 

of the hinge system. Hinge attitude is 

configured to simulate vehicle position 

(door fully closed) relative to the hinge 

centerline. For test purposes, the 

distance between the extreme end of 

one hinge system in the system to the 

extreme opposite end of another hinge 

system is to be set at 406 ± 4 mm. The 

load is to be applied through the 

centerline of the hinge pin, and as 

specified in S4.1.2.1(d)(3). (See Figure 

9). 


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(2) Apply the test load at a rate not to 

exceed 5 mm/min until the required 

load has been achieved. Failure consists 

of a separation of either hinge. Record 

the maximum load achieved. 

S5.1.2.3 Single Hinge Evaluation. 

Individual hinges of a hinge system are 

tested in accordance with the 

procedures below: 

(a) Longitudinal Load. Attach the test 

fixture illustrated in Figure 8 to the 

mounting provisions of the hinge. Hinge 

attitude is configured to simulate the 

vehicle position (door fully closed) 

relative to the hinge centerline. For test 

purposes, the load is to be applied 

equidistant between the linear center of 

the engaged portions of the hinge pin 

and through the centerline of the hinge 

pin in the longitudinal vehicle 

direction. Apply the test load at a rate 

not to exceed 5 mm/min until the 

required load has been achieved. Failure 

consists of a separation of either hinge. 

Record maximum load achieved. 

(b) Transverse Load. Attach the test 

fixture illustrated in Figure 8 to the 

mounting provisions of the hinge. Hinge 

attitude is configured to simulate the 

vehicle position (door fully closed) 

relative to the hinge centerline. For test 

purposes, the load is to be applied 

equidistant between the linear center of 

the engaged portions of the hinge pin 

and through the centerline of the hinge 

pin in the transverse vehicle direction. 

Apply the test load at a rate not to 

exceed 5 mm/min until the required 

load has been achieved. Failure consists 

of a separation of either hinge. Record 

maximum load achieved. 

(c) Back Door Hinge Load Tests. 

(1) Load Test One. Attach the test 

fixture illustrated in Figure 8 to the 

mounting provisions of the hinge. Hinge 

attitude is configured to simulate the 

vehicle position (door fully closed) 

relative to the hinge centerline. For test 

purposes, the load is to be applied 

equidistant between the linear center of 

the engaged portions of the hinge pin 

and through the centerline of the hinge 

pin, and as specified in S4.1.2.1(d)(1). 

(See Figure 9). Apply the test load at a 

rate not to exceed 5 mm/min until the 

required load has been achieved. Failure 

consists of a separation of either hinge. 

Record maximum load achieved. 

(2) Load Test Two. Attach the test 

fixture illustrated in Figure 8 to the 

mounting provisions of the hinge. Hinge 

attitude is configured to simulate the 

vehicle position (door fully closed) 

relative to the hinge centerline. For test 

purposes, the load is to be applied 

equidistant between the linear center of 

the engaged portions of the hinge pin 

and through the centerline of the hinge 

pin, and as specified in S4.1.2.1(d)(2). 

(See Figure 9). Apply the test load at a 

rate not to exceed 5 mm/min until the 

required load has been achieved. Failure 

consists of a separation of either hinge. 

Record maximum load achieved. 

(3) Load Test Three. Attach the test 

fixture illustrated in Figure 8 to the 

mounting provisions of the hinge. Hinge 

attitude is configured to simulate the 

vehicle position (door fully closed) 

relative to the hinge centerline. For test 

purposes, the load is to be applied 

through the centerline of the hinge pin, 

and as specified in S4.1.2.1(d)(3). (See 

Figure 9). Apply the test load at a rate 

not to exceed 5 mm/min until the 

required load has been achieved. Failure 

consists of a separation of either hinge. 

Record maximum load achieved. 

S5.1.2.4 For piano-type hinges, the 

hinge spacing requirements are not 

applicable and arrangement of the test 

fixture is altered so that the test forces 

are applied to the complete hinge. 

S5.2 Sliding Side Doors. 

S5.2.1 Door Latches. 

S5.2.1.1 Load Test One Force 

Application. The requirements of 

S4.2.1.1 are tested in accordance with 

the procedures specified in S5.1.1.1. 

S5.2.1.2 Load Test Two Force 

Application. The requirements of 

S4.2.1.2 are tested in accordance with 

the procedures specified in S5.1.1.2. 

S5.2.1.3 [Reserved.] 

S5.2.1.4 [Reserved.] 

S5.2.2 Door System. The test 

procedures for S4.2.2 are as follows: 

S5.2.2.1 Tests are conducted using a 

full vehicle with the sliding door and its 

retention components. 

S5.2.2.2 The test is conducted using 

two force application devices capable of 

applying the outward transverse forces 

specified in S5.2.2.4. The test setup is 

shown in Figure 10. The force 

application system shall include the 

following: 

(a) Two force application plates, (b) 

Two force application devices capable 

of applying the outward transverse load 

requirements for a minimum 

displacement of 300 mm. 

(c) Two load cells of sufficient 

capacity to measure the applied loads 

specified in S5.2.2.4. 

(d) Two linear displacement 

measurement devices required for 

measuring force application device 

displacement during the test. 

(e) Equipment to measure for a 100 

mm separation as specified in 

S4.2.2.2(a), while respecting all relevant 

safety and health requirements. 

S5.2.2.3 Test Setup. 

(a) Remove all interior trim and 

decorative components from the sliding 

door assembly. 

(b) Remove seats and any interior 

components that may interfere with the 

mounting and operation of the test 

equipment and all pillar trim and any 

non-structural components that overlap 

the door and cause improper placement 

of the force application plates. 

(c) Each force application device and 

associated support structure is rigidly 

fixed on a horizontal surface on the 

vehicle floor, while applying the loads. 

(d) Determine the forward and aft 

edge of the sliding door, or its adjoining 

vehicle structure, that contains a latch/ 

striker. 

(e) Close the sliding door, ensuring 

that all door retention components are 

fully engaged. 

(f) For any tested door edge that 

contains one latch/striker, the following 

set-up procedures are used: 

(1)(i) The force application plate is 

150 mm in length, 50 mm in width, and 

at least 15 mm in thickness. The plate 

edges are rounded to a radius of 6 mm 

± 1 mm. 

(ii) The plates are rigidly fixed 

perpendicular to the force application 

devices to maintain the displacement of 

the force application plate in the 

transverse direction. The plates allow 

for longitudinal rotation with respect to 

the vehicle’s centerline axis. The plates 

do not allow for rotation in the vehicle’s 

transverse direction. 

(2) Place the force application device 

and force application plate against the 

door so that the applied force is 

perpendicular to the vertical 

longitudinal plane that passes through 

the vehicle’s longitudinal centerline, 

and vertically centered on the doormounted portion of the latch/striker. 

(3) The force application plate is 

positioned such that the long edge of the 

plate is as close to the edge of the 

interior edge of the door as possible, but 

not such that the forward edge of plate 

is more than 12.5 mm from the interior 

edge. 

(g) For any tested door edge that 

contains more than one latch/striker, the 

following setup procedures are used: 

(1)(i) The force application plate is 

300 mm in length, 50 mm in width, and 

at least 15 mm in thickness. The plate 

edges are rounded to a radius of 6 mm 

± 1 mm. 

(ii) The plates are rigidly fixed 

perpendicular to the force application 

devices to maintain the displacement of 

the force application plate in the 

transverse direction. The plates allow 

for longitudinal rotation with respect to 

the vehicle’s centerline axis. The plates 

do not allow for rotation in the vehicle’s 

transverse direction. 

(2) Place the force application device 

and force application plate against the 

door so that the applied force is 

perpendicular to the vertical 


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longitudinal plane that passes through 

the vehicle’s longitudinal centerline, 

and vertically centered on a point midway between the outermost edges of the 

latch/striker assemblies. 

(3) The force application plate is 

positioned such that the long edge of the 

plate is as close to the edge of the 

interior edge of the door as possible, but 

not such that the forward edge of plate 

is more than 12.5 mm from the interior 

edge. 

(h) For any tested door edge that does 

not contain at least one latch/striker, the 

following set-up procedures are used: 

(1)(i) The force application plate is 

300 mm in length, 50 mm in width, and 

at least 15 mm in thickness. The plate 

edges are rounded to a radius of 6 mm 

± 1 mm. 

(ii) The plates are rigidly fixed 

perpendicular to the force application 

devices to maintain the displacement of 

the force application plate in the 

transverse direction. The plates allow 

for longitudinal rotation with respect to 

the vehicle’s centerline axis. The plates 

do not allow for rotation in the vehicle’s 

transverse direction. 

(2) Place the force application device 

and force application plate against the 

door so that the applied force is 

perpendicular to the vertical 

longitudinal plane that passes through 

the vehicle’s longitudinal centerline, 

and vertically centered on a point midway along the length of the door edge 

ensuring that the loading device avoids 

contact with the window glazing. 

(3) The force application plate is 

positioned such that the long edge of the 

plate is as close to the edge of the 

interior edge of the door as possible, but 

not such that the forward edge of plate 

is more than 12.5 mm from the interior 

edge. 

(i) The door is unlocked. No extra 

fixtures or components may be welded 

or affixed to the sliding door or any of 

its components. 

(j) Place the load application structure 

so that the force application plates are 

in contact with the interior of the 

sliding door. 

(k) Apply a preload of 500 N to each 

actuator and ‘‘zero’’ the displacement 

measuring device. 

S5.2.2.4 Test Procedure. 

(a) Move each force application 

device at any rate up to 2000 N per 

minute until a force of 9,000 N is 

achieved on each force application 

device or until either force application 

device reaches a total displacement of 

300 mm. 

(b) If one of the force application 

devices reaches the target force of 9,000 

N prior to the other, maintain the 9,000 

N force with that force application 

device until the second force 

application device reaches the 9,000 N 

force. 

(c) Once both force application 

devices have achieved 9,000 N each 

hold the resulting load. 

(d) Maintain each force application 

device load as specified in paragraph (c) 

and within 30 seconds measure the 

separation between the exterior edge of 

the doorframe and the interior of the 

door along the perimeter of the door. 

S5.3 [Reserved]. 

BILLING CODE 4910–59–P 


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Issued on: January 30, 2007. 

Nicole R. Nason, 

Administrator. 

[FR Doc. 07–517 Filed 2–5–07; 8:45 am] 

BILLING CODE 4910–59–C 


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