Bryce Pfister, P.E.
Director of Engineering
Collins Bus Corporation
PO Box 2946
Hutchinson, KS 67504-2946

Dear Mr. Pfister:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard No. 206, "Door Locks and Door Retention Components." Specifically, you ask whether a door configuration used in your school buses is a "folding door" excluded from the requirements of Standard No. 206. 

As discussed below, we believe the door you describe in your letter is a folding door for purposes of Standard No. 206.

You explain in your letter that the Collins Bus Corporation manufacturers school buses with gross vehicle weight ratings (GVWR) ranging from 9,500 to 19,500 pounds. One of your customers needs a vehicle with a passenger capacity of nine passengers, for the purposes of transporting pre-schoolers. You plan to sell the same basic vehicle you ordinarily would sell as a school bus, but with a reduced passenger capacity.  Because the vehicle will only accommodate nine passengers, you will have to classify these vehicles as multipurpose passenger vehicles (MPVs) rather than as school buses. [1] However, in a telephone conversation with Rebecca MacPherson of this office, you stated that, with the exception of the requirements for flashing lights and stop arms, these vehicles meet all Federal requirements for school buses.

You describe the door used in these vehicles as follows:

The typical passenger entrance door configuration of the Collins school bus includes two door leafs, each pivoting along its outer edge, and each attached to the door jamb at one upper and one lower pivot point. Both

door leaves pivot outward toward a boarding passenger, and the door opening is formed between the two door leaves in their outward position. A hand-operated linkage extending from the driver’s seating position opens and closes the forward door. An overhead linkage connecting to the forward door controls the rear door motion. The doors are latched in the closed position by a device attached to the door operating linkage near the driver’s seat.

Standard No. 206 specifies requirements for door locks and door retention components to minimize the likelihood of occupants being thrown from the vehicle in the event of a crash. The standard applies to passenger cars, trucks, and MPVs, but not to school buses. S4(c) of Standard No. 206 specifically excludes "folding doors" from the standard's requirements. The door described in your letter is a type of door typically used in school buses rather than MPVs.

As to whether the door is a "folding door" for purposes of Standard No. 206, we note that the standard does not include a definition of that term.  Unlike some of the doors typically used for the same purpose in school buses, your door does not consist of two leaves that are hinged together and "fold" in on themselves. Rather, the two leaves in your door are separate. Each pivots outward.  Nonetheless, considering the total design of your door as described above, including (but not limited to) the facts that both door leaves pivot outward toward a boarding passenger to form an opening, and both leaves operate together (through a linkage) by means of the same hand-operated control, we believe your door comes within the meaning of "folding door" for purposes of Standard No. 206.

I hope you find this information helpful. If you have any further questions on this subject, please feel free to contact Rebecca MacPherson in my office at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

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