[Federal Register Volume 91, Number 141 (Friday, July 24, 2026)]
[Notices]
[Pages 46827-46828]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2026-15010]
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
[Docket No. NHTSA-2026-1553]
Denial of Motor Vehicle Defect Petition
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation.
ACTION: Denial of a petition to open a defect investigation.
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SUMMARY: This notice sets forth the reasons for the denial of a
petition, DP25-002, submitted by Mr. Kevin Clouse to the Administrator
of NHTSA (the ``Agency'') by a letter dated November 7, 2025, under 49
U.S.C. 30162 and 49 CFR part 552. The Petition requests that the Agency
initiate a safety defect investigation into allegations that ``the
emergency egress controls for the mechanical door release are not
readily accessible and clearly identifiable'' and ``as a result fail to
comply with Federal Motor Vehicle Standard (FMVSS) 206 in the Model
Year (MY) 2022 Tesla Model 3 (the ``subject vehicles''). After
conducting a technical review of (1) consumer complaints submitted by
the petitioner; (2) consumer complaint information in NHTSA's
databases; and (3) other relevant information in possession of the
agency, NHTSA's Office of Defect Investigations (ODI) concluded that it
is unlikely that additional investigation would result in finding that
a defect related to motor vehicle safety exists, and the issue is best
addressed through the rulemaking process. As a result, no further
investigation of the issue raised by the Petition is warranted, and the
agency has accordingly denied the Petition.
FOR FURTHER INFORMATION CONTACT: Mrs. Ayesha Huertas Torres, Vehicle
Defect Division A, Office of Defects Investigation, NHTSA, 1200 New
Jersey Avenue SE, Washington, DC 20590. Telephone: 771-201-1918. Email:
[email protected].
SUPPLEMENTARY INFORMATION:
1. Introduction
Any interested person may petition NHTSA to request that the agency
initiate an investigation to determine whether a motor vehicle or item
of replacement equipment complies with an applicable motor vehicle
safety standard or contains a defect that relates to motor vehicle
safety. 49 U.S.C. 30162(a)(2); 49 CFR 552.3. Upon receipt of a properly
filed petition, the agency conducts a technical review of the petition,
material submitted with the petition, and any additional information.
49 CFR 552.6. The technical review may consist solely of a review of
information already in the possession of the agency or it may include
the collection of information from the motor vehicle manufacturer and/
or other sources. Id. After conducting the technical review and
considering appropriate factors, which may include, but are not limited
to, the nature of the complaint, allocation of agency resources, agency
priorities, the likelihood of uncovering sufficient evidence to
establish the existence of a defect and the likelihood of success in
any necessary enforcement litigation, the agency will grant or deny the
petition. See 49 U.S.C. 30162(a)(2); 49 CFR 552.8.
2. Defect Petition Summary
In a letter dated November 7, 2025, Mr. Kevin Clouse (the
Petitioner) requested that NHTSA ``open a safety defect investigation
into the emergency mechanical door release design'' in the MY 2022
Tesla Model 3 vehicles as the design ``fails to comply with FMVSS 206
requiring emergency egress controls to be readily accessible and
clearly identifiable.'' Mr. Clouse supported his request with details
regarding his own experience during an emergency event.
The Petitioner stated that following a head-on collision, the MY
2022 Tesla Model 3 suffered a total loss of electrical power and caught
fire. Due to the loss of power, the electric door handles became
inoperative. The Petitioner stated he was unable to locate the
mechanical door handle, forcing him to climb into the back seat and
exit the vehicle through a rear passenger window. The Petitioner
further stated that the mechanical emergency door release in his 2022
MY Tesla Model 3 is not accessible and clearly identifiable and thus
fails to comply with FMVSS 206. NHTSA has based its decision on a
review of the material cited by the Petitioner, pertinent information
in NHTSA's databases, and other relevant information in possession of
the agency.
3. Office of Defects Investigation Analysis
A vehicle equipped with electric door handles without an accessible
mechanical door release creates a risk to safety when the electric door
handle becomes inoperative due to loss of power and occupants are
unable to locate the mechanical door release to exit the vehicle in
case of an emergency. A concealed or hard to locate door release could
prevent an operator or occupant from exiting the vehicle in the event
of an emergency, such as a crash or fire. The potential risk for
entrapment
[[Page 46828]]
can result in a severe injury or death of the operator and other
occupants of the vehicle.
As of March 13, 2026, out of the population of 179,031 subject
vehicles, NHTSA has identified one (1) consumer complaint, in NHTSA's
databases alleging that the mechanical door release is concealed and
unlabeled, resulting in a risk of entrapment in the event of an
emergency, as cited in the Petition. The complaint is for the same
Vehicle Identification Number (VIN) as the subject vehicle of the
Petition. The allegation describes a front impact collision, where the
vehicle lost electrical power, and the electric door mechanism stopped
working.
The 2022 MY Model 3 has a mechanical release for the front doors,
located in front of the window switch on the door's interior and
consists of a lever that can be pulled up to open the door. The subject
vehicle does not have a mechanical release for the back doors.
The owner's manual for the 2022 MY Tesla Model 3 includes a section
labeled ``In Case of Emergency'' that details how to open doors from
the interior when the vehicle has no electrical power. The owner's
manual refers to the mechanical release as a ``manual door release.''
The owner's manual instructs the operator to ``pull up the manual door
release located in front of the window switches.'' The owner's manual
includes an illustration showing the mechanical door release lever and
its location on the door. The illustration depicts an image of the door
with the window switch and lever, including a blue arrow pointing to
the location of the lever to demonstrate the upward movement required
to operate the lever. The lever shown in the illustration does not
contain a label to identify it. Although they vary in design and
location, mechanical releases for the front doors are available on all
Tesla models. The location and operation of the mechanical release is
described in the owner's manual for each Tesla model. Further, the
owner's manual cautions the operator that the mechanical door release
should only be used when the subject vehicle has no power or if
otherwise necessary. If the subject vehicle has power, the button
located at the top of the interior door handle should be used to open
the doors.
The Petition stated the lack of an accessible mechanical door
release is a violation of the requirements of Federal Motor Vehicle
Safety Standard (FMVSS) 206 (49 CFR 571.206). FMVSS 206 specifies
performance requirements for vehicle door locks, latches, hinges, and
attachment components to prevent passenger ejection during crashes. It
applies to passenger cars, trucks, and buses with a GVWR of 4,536 kg
(10,000 lbs.) or less, focusing on maintaining latch engagement under
inertial loads and structural integrity. No requirements exist in the
standard that address the Petitioner's concern regarding the labeling
and location of a mechanical door release in passenger vehicles.
On November 4, 2025, NHTSA's Office of Rulemaking received a
petition to initiate the issuance of a new Federal Motor Vehicle Safety
Standard (FMVSS) to mandate a robust and obvious door egress system in
all motor vehicles. The request has been granted, and the Agency will
accordingly commence a rulemaking proceeding. See 49 CFR 552.9. A
decision as to the issuance of a rule will be made on the basis of all
available information developed in the course of the rulemaking
proceeding, in accordance with statutory criteria. Id.
The Agency has thoroughly assessed the material submitted by the
Petitioner, consumer complaint information in NHTSA's databases, and
other relevant information already in possession of the Agency. NHTSA
does not believe that the issues presented by the Petitioner indicate
the likelihood of a safety related defect that would warrant a defect
investigation, and the issue is best addressed through the rulemaking
process. After full consideration of the available information and the
commencement of the related rulemaking proceeding, the Petition is
denied.
(Authority: 49 U.S.C. 30162(d) and 49 CFR part 522; delegation of
authority at 49 CFR 1.95(a).\1\)
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\1\ The authority to determine whether to approve or deny defect
petitions under 49 U.S.C. 30162(d) and 49 CFR part 552 has been
further delegated to the Associate Administrator for Enforcement.
Eileen Sullivan,
Associate Administrator for Enforcement.
[FR Doc. 2026-15010 Filed 7-23-26; 8:45 am]
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