Federal Motor Vehicle Safety Standard 206; Door Locks and Door Retention Components

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DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

49 CFR Part 571

[Docket No. 94-70, Notice 2]

Federal Motor Vehicle Safety Standard 206; Door Locks and Door

Retention Components

AGENCY: National Highway Traffic Safety Administration, DOT.

ACTION: Notice of public meeting and request for comments.

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SUMMARY: This document announces a public meeting to seek comments on

potential upgrading of Federal Motor Vehicle Safety Standard No. 206,

Door Locks and Door Retention Components, to further reduce the

likelihood of occupants being ejected through side door openings as a

result of vehicle crashes.

The purpose of this public meeting is to inform all interested

parties about the current status of NHTSA's research on side door

ejections and potential countermeasures for ejection reduction, and to

solicit comments on the agency's findings. In addition, the agency

wishes to obtain information related to reduction of side door

ejections through development of improved latches and other

countermeasures that are being undertaken by domestic and foreign

vehicle manufacturers, and other organizations. The information

gathered at this meeting will assist the agency in deciding its future

course of action to solve the side door ejection problem. In addition,

the agency is also seeking information from safety groups or other

interested parties who may have conducted their own investigation on

the magnitude of the safety problem in this area and potential

solutions.

DATES: The meeting will be held on August 7, 1995 at the address given

below, starting at 9:00 a.m. Persons or organizations desiring to make

presentations at the public meeting are asked to advise NHTSA of their

intent by July 24, 1995. Copies of presentations, or an outline

thereof, should be submitted to the contact person shown below not

later than July 31, 1995. All written comments and statements on the

subjects discussed at the meeting must be received by the agency no

later than August 21, 1995 so that such comments and statements could

be included in the final transcripts of the public meeting.

ADDRESSES: The public meeting will be held at the following address:

Holiday Inn-Fair Oaks Mall, 11787 Lee Jackson Memorial Highway,

Fairfax, VA 22033. Tel: (703)-352-2525 and Fax: (703)-352-4471.

Requests to make a presentation and a copy of the presentation, or

an outline thereof, should be sent to: Dr. Joseph Kanianthra, Chief,

Side and Rollover Crash Protection Division, Office of Vehicle Safety

Standards, National Highway Traffic Safety Administration, 400 Seventh

Street SW., Washington, DC 20590.

Written comments should refer to the docket and notice number shown

above and ten copies should be submitted to Docket Section, National

Highway Traffic Safety Administration, Room 5109, 400 Seventh Street

SW., Washington, DC 20590. However, submissions containing information

for which confidential treatment is requested should be submitted with

three copies to Chief Counsel, National Highway Traffic Safety

Administration, Room 5219, 400 Seventh Street SW., Washington, DC

20590. Seven additional copies from which the purportedly confidential

information has been deleted should be submitted to the Docket Section.

FOR FURTHER INFORMATION CONTACT:

Dr. Joseph Kanianthra, Chief, Side and Rollover Crash Protection

Division, Office of Vehicle Safety Standards, National Highway Traffic

Safety Administration, 400 Seventh street SW., Washington, DC 20590.

Tel: (202)-366-4924, and Fax: (202)-366-4329.

SUPPLEMENTARY INFORMATION: Federal Motor Vehicle Safety Standard

(FMVSS) No. 206, Door Locks and Door Retention Components (49 CFR

571.206), specifies performance requirements for side door locks,

latches, hinges and other support means used in vehicles to minimize

the likelihood of occupants being ejected through the side door

openings. The standard requires, among other items, each latch and

striker system and each hinge system not to disengage when a

longitudinal force of 2,500 lbs or a transverse force of 2,000 lbs is

applied. In addition, the standard requires each latch and striker

system not to disengage when a 30-g inertial loading is applied in the

longitudinal or transverse direction. To assess the effectiveness of

the standard, the agency conducted a rulemaking evaluation study ``An

Evaluation of Door Locks and Roof Crush Resistance of Passenger Cars--

Federal Motor Vehicles Safety Standards Number 206 and 216'' (DOT HS

807-489, November 1989). In the study, the fatal ejection risk in

rollovers was calculated for passenger cars manufactured during the

1963-1982 period. The study concluded that latch improvements

implemented in 1963-1968 reduced the fatal ejection risk by 15 percent

in rollover accidents.

It is well known that promoting seat belt usage is the most cost/

effective means to reduce the risk of ejection. The agency and vehicle

manufacturers have been promoting seat belt usage for many years and,

consequently, the average seat belt usage rate has increased

dramatically in recent years. However, the NASS accident data show that

the total fatal ejections per year remain relatively constant since

1978 in spite of significant increases in seat belt usage in recent

years. The agency believes that there are two counter balancing effects

which contribute to maintaining the number of ejection fatalities and

injuries relatively constant. The reduced ejection rates due to an

increase in seat belt usage is probably off-set by the exceptional high

ejection rates in small cars, light trucks and multipurpose passenger

vehicles. The increasing number of small cars on the highway since the

late 1970's and the current consumer preference of using pickups, mini-

vans and utility vehicles for personal transportation are likely to

increase the total number of fatal ejections in those vehicles. Thus,

any benefits derived from increased seat belt usage appear to have been

off-set by the increase in ejections experienced in small cars, light

trucks, and multipurpose passenger vehicles. It is estimated that in

1995 and beyond side door ejections will result in approximately 1,475

fatalities and 1,925 AIS 3+ injured survivors. Therefore, side door

ejections are and will remain a significant safety problem.

Since the issuance of FMVSS No. 206 in 1967, the agency has

investigated many crashes associated with side door openings and

ejections. In 1986, the agency initiated a pilot study ``Side Door

Latch/Hinge Assembly Evaluation'' (DOT HS 807-234, October 1986) to

investigate side door latch strength and occupant ejection problems.

Since then, the agency has continued its research efforts in this area.

To date, the agency has identified many real world latch failure

mechanisms and has developed a set of test procedures that may be

suitable for evaluating the performance of the latch and striker

systems used in most production vehicles. These test procedures

potentially address only a small portion of possible failure modes that

are occurring in real world crashes. The agency has concluded that the

side door ejection problem involves a variety of different latch

failure mechanisms, and that there is not a single representative latch

failure mode that

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causes the door to open in real world crashes. Each latch failure mode

must be dealt with individually as a unique event. Therefore, the

agency's options are:

(1) To Upgrade FMVSS No. 206's Test Procedures: FMVSS No. 206 could

be upgraded by including additional tests under FMVSS NO. 206. Those

additional tests may include by-pass tests, full door longitudinal and

transverse load tests, GM rotation tests, inertial loading tests and

other tests. The performance levels have to be determined from the test

results of latches of those vehicles selected from the accident data

files with low and high door opening rates and latch failure rates.

However, this option has the disadvantage of multiple tests for

manufacturers' certification and the agency's enforcement efforts.

(2) To Require a Secondary Latch for All Doors: In 1994, NHTSA

contracted EASi Engineering to develop and manufacture a secondary door

latch system which is able to:

1. resist forces in different directions.

2. meet FMVSS No. 206's fully latched test requirements.

3. mitigate by-pass and linkage activation failures.

EASi Engineering, based on the above criteria, developed a

secondary latch system for a 1991 Ford Taurus. Therefore, an

alternative option is to amend FMVSS No. 206 requiring a secondary

latch mechanism for all doors. This option has the definite advantage

of limited test requirements for the latch itself. However, the

effectiveness of a secondary latch system in real world crashes is not

known at this time.

(3) To Use a modified FMVSS No. 214 test: FMVSS No. 214 specifies a

static door crush test and requires side doors of a vehicle to remain

attached in a dynamic side impact test. The static door crush test of

FMVSS No. 214 includes longitudinal, transverse, and rotational forces

experienced by the latch and striker system in a real world crash.

FMVSS No. 214 requires that the peak crush resistance of a side door

shall not be less than two times the curb weight of its vehicle or

7,000 pounds, whichever is less. In general, this peak transverse load

would induce a longitudinal load in excess of 2,500 pounds to the latch

and striker system of the door. It appears that the static door crush

test requirements possibly surpass those of FMVSS No. 206's

longitudinal tests. Therefore, the longitudinal load test of FMVSS No.

206 may be redundant. The transverse load tests of FMVSS No. 206 could

be replaced by a modified FMVSS No. 214 test. In a static door crush

test, both the latch and the hinges of a door are tested simultaneously

and the latch and striker system of the door is subjected to pulling,

shearing and twisting forces which simulate some of the real world

loading conditions. In a dynamic side impact test, some of the dynamic

effects on the side structure in crashes are also simulated. In

addition, potential structural effects of the door and pillar component

responses upon the latch strength could be duplicated in a test

procedure developed for the purpose. It appears that FMVSS No. 214

types of tests are a potential option for rulemaking actions associated

with side door ejection reduction.

A disadvantage of this option is that the door latch and striker

system is not subjected to a significant longitudinal compression which

was found in the agency's research to be a critical load component

associated with by-pass failures.

PUBLIC MEETING: All interested persons and organizations are invited to

attend the meeting. To assist interested parties to prepare for the

meeting, the agency has developed a preliminary outline, shown below,

or major topics to be discussed at the meeting. Any additional agenda

items of interest could be included by making a request to the agency

at the address given in the notice.

Preliminary Outline of Topics for Public Meeting

1. Accident Data

(A) Estimated Target Population

(B) Door Opening Rate Analysis

(C) Hard Copy Accident Data Analysis

2. Status of Door Latch research: Test Procedures Evaluated

(A) Bench Component Tests

(B) In Vehicle Component Tests

(C) Other Test Methods

3. Future Research: Potential Countermeasures

(A) Upgrade of FMVSS No. 206

(B) Secondary Latch System Development

(C) FMVSS No. 214 Types of Tests Development

(D) Other Methods

The agency intends to conduct the meeting informally, along the

lines of the public meeting on head impact protection held on November

15, 1993. The agency will summarize its activities in the three major

topic areas at the beginning of the discussion for each topic, followed

by presentations by other interested parties. Before moving to the next

major topic area, there will be an informal discussion period.

Interested persons may ask questions or provide comments during this

period. The public may submit written questions to the presiding

official to consider asking of particular participants or presenters.

The agency will provide an overhead projector, a slide projector

and a TV-VCR system. The agency requests that persons planning to use

other visual aids in their presentations must indicate to the agency

their requirements. A copy of the charts and other materials used in

the presentation must be provided to the agency for the docket at the

end of the meeting.

COMMENTS: The agency invites all interests parties to submit written

comments concerning the agenda items planned to be discussed in the

meeting. The agency notes that participation in the public meeting is

not a prerequisite for submission of written comments. Anyone desiring

submission of comments should send them to the same address as above

and must follow the same requirements outlined in section ADDRESSES.

No comment may exceed 15 pages in length (49 CFR 553.21). This

limitation is intended to encourage commenters to detail their primary

arguments in a concise fashion. Necessary attachments may be appended

to a comment without regard to the 15-page limit. All comments that are

submitted within two weeks after the date of the public meeting will be

available for public review in the docket. Those persons who desire to

be notified upon receipt of their written comments in the Docket

Section should enclose, in the envelope with their comments, a self-

addressed stamped postcard. Upon receipt, the docket supervisor will

return the postcard by mail.

Persons making oral presentations at the meeting are requested, but

not required, to submit 25 written copies of the full text of their

representation to Dr. Joseph Kanianthra no later than the day before

the meeting. Presentations are limited to 15 to 20 minutes. If time

permits, persons who have not requested presentation time, but want to

make a statement will be afforded an opportunity to do so at the end of

the meeting. Copies of all written statements, if provided by the

commenters within two weeks after the meeting, will be placed in the

docket. However, a verbatim transcript of the meeting will be prepared

by NHTSA and placed in the basket as soon as possible after the

meeting.

Authority: 49 U.S. Secs. 322, 30111; delegation of authority at

49 CFR 1.50.

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Issued on: July 7, 1995.

Patricia Breslin,

Acting Associate Administrator for Safety Performance Standards.

[FR Doc. 95-17088 Filed 7-11-95; 8:45 am]

BILLING CODE 4910-58-M