Here is my updated defence (a few points in red that I might remove):
I received a fine for not adhering to Australian Design Standards for not having doors, but I was not in violation of any Australian Design Rules. 2001 Jeep Wrangler TJs 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 sturdy structural design of its chassis without the doors as well as seats, which were designed to be high enough to avoid impact. Specifically the ADR for side impact protection only apply to vehicles where the torso is within 700mm of the ground.
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 street legal beach buggies and motorbikes do not have doors, nor seatbelts—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 (700mm), 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 chassi 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.
Australian Design Rules
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 (thinking to leave this one out)
Published 12 May 2006
http://www.comlaw.gov.au/Details/F2006L01362
Why not in violation: only applicable after 1 July 2008 with no preceding rules.
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 (might exclude this because all I need to prove is ADR 72)
Published: 3 October 2007
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: the vehicle complies with ADR 72 exempting it from ADR 29/00 as described in section 29.5.
The stock doors are actually not designed to provide protection from impact. They have no side intrusion beams without which they wouldn’t be strong enough to comply as manufactured with the doors on. So how is Daimler Chrystler (Jeep) able to manufacture such vehicles—because the vehicle complies with ADR 72 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
http://www.comlaw.gov.au/Details/F2005L03992
Why not in violation: 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. (The chart is blank, but I’m not actually sure if there isn’t an older version of the rule). And even if the age of the model didn’t exempt it from ADR 72, the height from the ground of a person sitting in the seats (more than 700mm).
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.
3.2. 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 N/A
Passenger car MA M1 1 Jan 1999*
Forward-control passenger vehicle MB M1 1 Jan 2000*
Off-road passenger vehicle MC M1 1 Jan 2000*
Light omnibus MD M2 N/A
Heavy omnibus ME M3 N/A
Light goods vehicle NA N1 1 July 1999*
Medium goods vehicle NB N2 N/A
Heavy goods vehicle NC N3 N/A
Very light trailer TA O1 N/A
Light trailer TB O2 N/A
Medium trailer TC O3 N/A
Heavy trailer TD O4 N/A
* see clauses 3.1.2 and 3.1.3
The TJ model comes with light weight foam filled doors with no side intrusion beams so the doors themselves do not make the Jeep Wrangler TJ complaint with ADR 72—so how do they pass ADR 72? The Jeep TJ is compliant because of the sturdy structural design of the chassis without the doors and the height of the seating reference point being more than 700mm from the ground.
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;
