Federal Motor Vehicle Safety Standards; Door Locks and Door Retention Components, 5385-5413 [07-517]

Agencies

• National Highway Traffic Safety Administration
• DEPARTMENT OF TRANSPORTATION

[Federal Register Volume 72, Number 24 (Tuesday, February 6, 2007)]
[Proposed Rules]
[Pages 5385-5413]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 07-517]


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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.

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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.
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    \1\ On 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.
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    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

[[Page 5386]]

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 pre-standard 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 non-
rollover 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.
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    \2\ The 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).
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    This first GTR demonstrated that U.S./EU regulatory cooperation can 
achieve increased safety and harmonized standards that are science-
based 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.
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    \3\ While 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.
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    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

[[Page 5387]]

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.
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    \4\ The 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.
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    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\
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    \5\ The 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.
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    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.
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    \6\ ``Child Restraint use in 2002: Results from the 2002 NOPUS 
Controlled Intersection Study.'' https://www-nrd.nhtsa.dot.gov/pdf/
nrd-30/NCSA/Rpts/2003/ChildRestraints.pdf.
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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\
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    \7\ The 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.
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    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 
double-doors, currently referred to as ``cargo-doors.'' 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

[[Page 5388]]

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, Sec.  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.
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    \8\ See www.unece.org; click on ``Meetings,'' and Committee on 
Inland Transportation.
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    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

[[Page 5389]]

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

[[Page 5390]]

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\
---------------------------------------------------------------------------

    \9\ As 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.
---------------------------------------------------------------------------

    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 type-approval, but 
that additional specificity may be required in characterizing the test 
fixture.
---------------------------------------------------------------------------

    \10\ See presentation from Transport Canada in the DOT Docket 
NHTSA-1999-3705.
---------------------------------------------------------------------------

    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.
---------------------------------------------------------------------------

    \11\ Id.
---------------------------------------------------------------------------

    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 
type-approval certification systems. However, further specifications 
for self-certification 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

[[Page 5391]]

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

[[Page 5392]]

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.
---------------------------------------------------------------------------

    \12\ See, Docket No. NHTSA-2004-19840-14.
---------------------------------------------------------------------------

    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.
---------------------------------------------------------------------------

    \13\ See Docket No. NHTSA-2004-19840-14.
---------------------------------------------------------------------------

    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

[[Page 5393]]

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.
---------------------------------------------------------------------------

    \14\ See Docket No. NHTSA-1998-3705-33.
---------------------------------------------------------------------------

    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