TJ's without doors are legal says the SDRO

I received the result of my appeal and the sdro has cancelled Pura Vida's fine for driving without doors in NSW.

Pura Vida is a 2001 TJ with mirrors relocated onto the chassis. The same result may or may not apply to newer models.

Ben

My defense...a contribution to the community.

Summary of ADR standards which could apply and why I’m not in violation:
ADR 14/02 – Rear Vision Mirrors – I have three mirrors, one on the windscreen and two on the side of the chassis (not the doors)

ADR 2/00 Side door latches & hinges – not applicable because ADR 2 is only applicable to vehicles manufactured after 2008 and my ’97 TJ model Jeep Wrangler was manufactured in 2001. It’s also not applicable because the ADR does not apply to doors designed to be easily removed—my stock half doors aren’t real doors as per their definition—they’re lightweight, foam filled, and designed to be easily taken off in less than 5 seconds (as described in the owner’s manual).

ADR 29/00 Side door strength – not applicable because my jeep does not violate ADR 72 and ADR 29 only applies to vehicles which are in violation of design standard ADR 72.

ADR 72/00 Dynamic side impact occupant protection – not applicable because my vehicle is a ’97 model manufactured in 2001 and all pre 2000 models are exempt up to 2004. It’s also not in violation because a seat height alone of 700mm is sufficient to meet the requirement and my standard seat height is 950mm. It is also not in violation because the structure of the chassis and the strength of the door frames provide sufficient strength for protection from side impact without the lightweight foam filled doors, which are not designed to provide protection from impact.

My doors don’t provide protection from impact and are designed to be removed - My doors are not real doors and are not designed to provide protection from impact and are designed to be easily removed—all of which is described in the owner’s manual.

Detailed Explanation:
2001 Jeep Wranglers (‘97 TJ model) were designed to remove the doors just like the roof. I can take-off and put-on my doors in less than two seconds without the use of tools—that’s faster than the top.

The factory hard top is fibreglass and the doors are lightweight, filled with foam, and have no side intrusion beams. They were designed this way for quick and easy removal and storage just like the top. The vehicle complies with safety standards because of the height of its seats which were designed to be high enough to comply with the regulations to avoid impact. The sturdy structural design of its chassis and door frames are designed to act as the side intrusion beams without even having the foam filled doors. Specifically the ADR for side impact protection only apply to vehicles where a sitting person’s torso is within 700mm of the ground (1,000mm on a Jeep TJ). 700mm just barely reaches the bottom of the chassis.

In the owner’s manual (as well as on the vehicle) it says that “The top and doors on this vehicle are designed only for protection against the elements. Do not rely on the top and doors to contain occupants within the vehicle or to protect against injury during an accident. Wear seatbelts at all times.” “Although your vehicle may be equipped with a soft top or optional hard top to give the occupants protection from the weather, these tops do not offer structural protection in the event of an accident and do not change the open-body characteristic of the vehicle.”
It’s no legal argument, but from a relative safety perspective, street legal beach buggies and motorbikes do not have doors, nor seatbelts and are more dangerous—as designed. I know Jeep Wranglers (although safer than motorbikes even without doors) are not motorbikes—but nor are they standard cars designed to need doors either.

The lightweight foam-filled doors, which were designed to be optionally removed, do not provide additional protection in a collision because they don’t contain side intrusion beams as are standard with other vehicles. However, the structure of the chassis without the doors was designed to sustain impact on its own without doors and complies with the Dynamic Side Impact Occupant Protection ADR 72 due to the height of the seat (950mm) being more than the minimum 700mm for an exclusion—not due to protection offered by the doors, as the doors offer nothing more than protection from the elements (weather).

I realise that unless the side mirrors are relocated via after market brackets they will not comply with other ADRs. I have, however, relocated the side mirrors to the chassis in order to comply with the requirement to have mirrors.
The owner’s manual also references in several other places that the vehicle was designed to be driven with the doors removed:

· Page 82: “NOTE: If the doors are to be removed, pull the #4 fuse from the fuse block to prevent dome lamp illumination.”
· Page 103: “Outside rear view mirrors are mounted on the doors. If you choose to remove the doors, see your authorized dealer for a replacement cowl-mounted outside mirror....NOTE:If the doors are removed, the courtesy lights will remain on. To turn these lights off, remove fuse #4 in the fuse panel. Refer to ‘Fuse Panel’ in Section 7 of this manual.”
· Page 104: “(Warning) If you remove the doors, store them outside the vehicle. In the event of an accident, a loose door may cause personal injury.”


As described above, unlike other vehicles, which were designed to be driven with doors, the Jeep Wrangler TJ model was intentionally designed to be safely operated with the doors removed...as well as the top—just like motorbikes and other non-standard cars.

ADR 14/02 – Rear Vision Mirrors

Published 14 August 2006

http://www.comlaw.gov.au/Details/F2006L02663

Why not in violation:I have two side mirrors and a rear view mirror. They are attached to the chassis, not the doors.

ADR 2/00 Side door latches & hinges (/00 indicates that this is the first version of this ADR)

Published 12 May 2006

http://www.comlaw.gov.au/Details/F2006L01362

Why not in violation: this rule is only applicable to vehicles manufactured after 1 July 2008 with no preceding rules. It is also not in violation because Jeep TJ Wranglers are excluded from the regulation because the manufactured stock doors are lightweight, foam-filled and not real doors (according to the ADR) and designed to be removed, as explained earlier in the owner’s manual. Since are designed to be easily removed and according to item 2.3 from the ADR below the rule doesn’t apply:

2.3. “’Doors’ means hinged or sliding doors which lead directly into a compartment that contains one or more seating ­positions and which are not folding doors, roll-up doors and doors that are designed to be easily attached to or removed from motor vehicles manufactured for operation without doors.”

From ADR 2 on exclusions for vehicles manufactured prior to 2008:

“Clause 3.2.There is no mandatory application date for all other model vehicles. They may comply with this vehicle standard or continue to comply with earlier versions of this vehicle standard as applicable for particular vehicle categories.”

“Applicability Table
Vehicle Category
ADR Category Code
UNECE Category Code *
Manufactured on or After
Acceptable Prior Rules
Moped 2 wheels
LA
L1
N/A

Moped 3 wheels
LB
L2
N/A

Motor cycle
LC
L3
N/A

Motor cycle and sidecar
LD
L4
N/A

Motor tricycle
LE
L5



LEM

N/A

Enclosed vehicles
LEP & LEG
(see clause 3.4)
1 July 2008
(see clause 3.2)
All vehicles
LEP & LEG
(see clause 3.4)
1 July 2008
(see clause 3.2)
Passenger car
MA
M1
1 July 2008
(see clause 3.2)
Forward-control passenger vehicle
MB
M1
1 July 2008
(see clause 3.2)
Off-road passenger vehicle
MC
M1
1 July 2008
(see clause 3.2)”

ADR 29/00 Side door strength

Published: 3 October 2007 (/00 indicates that this is the first version of this ADR)

http://www.comlaw.gov.au/Details/F2007C00735

“The function of this Design Rule is to specify strength and stiffness requirements for side doors of passenger cars which can be used for occupant access to reduce intrusion into the passenger compartment as a result of side impact.”

Why not in violation: this is not applicable because my jeep does not violate ADR 72 and ADR 29 only applies to vehicles which are in violation of design standard ADR 72.

Further, the stock doors are actually not designed to provide protection from impact (as indicated above in the owner’s manual). The doors are filled with foam and have no side intrusion beams, without which they wouldn’t be strong enough with the doors to comply with ADR 29.. So how is Daimler Chrystler (Jeep) able to manufacture such vehicles legally?—because the vehicle complies with ADR 72 (Dynamic side impact occupant protection) because of its seat height exempting it from ADR 29/00.

Quote from ADR 29 exempting vehicles compliant with ADR 72:
“29.5.EXEMPTION FROM TEST REQUIREMENTS
Vehicles complying with the requirements of ADR 72/… are exempt from the requirements of this rule.”

ADR 72/00 Dynamic side impact occupant protection

Published: 12 December 2005 (/00 indicates that this is the first version of this ADR)

http://www.comlaw.gov.au/Details/F2005L03992

Why not in violation: 3 reasons any of which would independently make my vehicle compliant: (1) the TJ model was produced from 1997-2006 (mine is a 2001) and ADR72/00 is only applicable non new model vehicles as of 2004 with no applicable prior rules. (2)My Jeep is also exempt because all vehicles where the top of the seats is more than 700mm from the ground are compliant—seats in the Jeep TJ wrangler are 950mm. (More specifically the point of measurement is a bit above the seat—point R where a sitting person’s torso connects to their hip/legs). My seats alone are 950mm from the ground—25% higher than needed to meet the safety regulation. (3) It is also not in violation because the structure of the chassis and the strength of the door frames provide sufficient strength for protection from side impact without the lightweight foam filled doors, which are not designed to provide protection from impact. Jeep designed the structure of the doorframe to act as side intrusion beams for the purposes of additional side impact protection.

Quote from ADR 72 the exclusion all vehicles that aren’t new models prior to 2004:
“3.APPLICABILITY AND IMPLEMENTATION
3.1.1.This ADR applies to the design and construction of vehicles as required by clauses 3.1.2 and 3.1.3 and set out in clause 3.2.
3.1.2.This rule is binding:
a)from 1 January 1999 on all new model MA vehicles; and
b)from 1 January 2004 on all MA vehicles.
c)from 1 January 2000 on all new model MB and MC vehicles; and
d)from 1 January 2004 on all MB, MC vehicles.
e)from 1 July 2000 on all new model NA vehicles; and
f)from 1 July 2005 on all NA vehicles.

3.1.3.For the purposes of clause 3.1.2, a “new model” is a vehicle model first produced with a ‘date of Manufacture’ on or after 1 January 1999.”

Quote from ADR 72 on exclusions for vehicles where the seating reference point is 700mm from the ground:
“1. SCOPE
The function of this vehicle standard is to specify crash worthiness requirements in terms of forces and accelerations measured by anthropomorphic dummies so as to minimise the likelihood of injury to the occupants in side impact.

This Regulation applies to the lateral collision behaviour of the structure of the passenger compartment of Ml and Nl categories of vehicles where the R point of the lowest seat is not more than 700 mm from ground level when the vehicle is in the condition corresponding to the reference mass defined in paragraph 2.10. of this Regulation.

2. DEFINITIONS
For the purposes of this Regulation:
2.4. “R point” or “seating reference point” means the reference point specified by the vehicle manufacturer which:
2.4.1. has co-ordinates determined in relation to the vehicle structure;
2.4.2. corresponds to the theoretical position of the point of torso/thighs rotation (H point) for the lowest and most rearward normal driving position or position of use given by the vehicle manufacturer for each seating position specified by him;”

congrats mate

Goodons you mate. Great result for all TJ owners. Have fun without doors andhi without fear ofroad the fines

cheers
Mani

GOOD STUFF BEN !!!!

Hate the SDRO, I tend to park where ever I want so pretty much funded last years Christmas party for them, hahahaha...

Good win though mate, I take it from all that JK owners are screwed, but bring on Marcus' bar doors

Hi Ben,

First of all thank you for all the detail on the legislation. I know its been years since you posted this thread, but I would be keen to find out more specific detail of the SDRO file so I can quote it if there is an issue, as I am keen to take my doors of my 2001 TJ. I have already purchased the mirrors to mount in the hinges.

Possibly even the date or if there is a reference number on your paperwork so that I can get a copy of it through SDRO, and have it in the car to site if needed.

I have previously challenged fines through the court system (and won), but it takes time and money, and it is be cheaper and easier to avoid it if possible.

Gavin

Many thanks for this great detailed post.