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-----........ ~---.....,~ . .-..-.-.... ..............~ _,..._._ :lriction matert'a~ Standar~ 3n3litute, Ync. 370 LEXINGTON AVENUE NEW YORK, N.Y. 10017 Docket Sect ion N~tion~1 Highway S2fety Bureau Room 4223 400 Seventh Street s. \! ..'~shington, D.C. }20591 September 14, 1970 A Af7/1Cf1;11.NI Subjett: Docket No. 70-17. Notice /II Air Brake Systems; Trucks and Buses The Friction ~leterit=~ls Standards Institute, Incorporated submits the follow- ing corrrnents to the subject docket: ": The scope of this Proposed ~.'otor Vehicle Safety Standard is broad and re- c,uires such significant changes from current air brake systems, that time did not permit specific tests to be run to the proposed procedures. It has not been possible to eveluate the pro~osed requirements from existing data, therefore an extension to Januery 1, 1971 is requested for compiling supportingdata. This supporting data will be a prerequisite to meaningful comments on costs and lead time required to comply with this proposal. There are questions regarding interpretation of th~ proposal and comments which can be ~de at this time based on experience and available data. Is it the intent of this proposal to apply only to new vehicles manufactured after the effective dAte1 The propo?al refers to "each brake and drum assembly" being placed on an inertia dynamome'ter. Is the in~ent to dynamometer test all brakes from Hae vehicle or only one of each brake that may differ in size or components? :"/ill this require a double ended dynamometer? S4.2.1 Stopping Dist~nce. The stopping distances specified require unrealistically high average deceleration rates, up to 17.9 fpsps at 60 ~PH. To achieve these stopping distances itwill be necessary to attain deceleration rates as high as 24 fpsps for sustained p~riods. These are not possible with current' brakes systems. Ag<dn Additional time will be required for study and solutions. 54.2.2 Stopping distances specified with partial failure are at substantially "(5% of full brake system. If a split air system is acceptable (54.1.3) we assume a 50-5cr split and.would expect stopping distances to reflect the sAme percentage. A clarification as to what constitutes a split service brake syst~m is requested. S4.2.5 Orake Ret~r~tion Force. To meet the proposed requirements will necessitate a siP.nificant increase in brake torque ::..> over those in current use. This torque increase can he FMSI 00131 Docket 3ection Nation<~! Hir,h:Py S-fety ~ure.:>u \!c:sh i ngton, D. C. .:'20591 -2- Sept ember 14, 1970 ' obtained by br~ke desi~n, higher coefficient of friction lining or both. Ho''tever, development of such friction rraterial will rec,uire more time than permitted by the effective dcte of January 1, 1972. 54. 5.1 ' Should be 34.2.5.1. Also reference to 55.2.5 for burnish should be 55.2.6. Clarification is needed on the torque v~lue to be used in this calculation. Torque output during a given stop may vary <~s much 2s 25% from minimum to maxilr.Um. 54.2.6 Brake Power. ::e are not in full C~greement with this require~ent ns it overlooks~ b~sic function of brcke fade which werns the driver and also protects the braking system from destrqctive temperatures. These r~quirements can not be fully evalu~ted from the standpoint of ultimate l;rake temperature as current I rakes wi 11 not meet these unrealistic fade requirements. 54.2.6.2 '."!e would prefer to h.?.ve specific data before rraking finc-1 ": comment, but it is our opinion t~t a 14 fpsps deceleration requirement is unrealistic within one minute following any test which results in destructive brake temperatures. 54.2.7 S5.1.8 Brake Recovery - we recommend ten stops at two minute _intervals to promote better cooling and a more meaningful recovery check. One minute intervals generally result in .a stabilized drum and lining temperature It is suggested that ~ revised ve~icle burnish procedure be considered for purposes of greater consistancy for correlation and repe~tability of these tests. 200 brake applic~tions from 40 to 20 mph at 10 fpsps maintaining lining temperatures between Jl5F and J85F. ~hke 200 additional applicntions 40 to 20 mph at 10 fpsps ~aintaining lining temperatures between 400F and 500F. This will necessitate insta\lation of plug type therrr.ocouples as specified in S~E J843a. 55.2.1 A tolerance should be established for equivalent wheel load as the inertia weights on dynamometers vary and it is seldcm possible to achieve the exact equivalent in inertia loading. Additional time will be required to determine w~t tolerances would be reasonr-ble. :'te also believe th:~t the dynamometer loading ought to ref.lect various friction losses in a vehicle not encountered on th~ dyMmometer. Time, again, would be required to determine a realistic value. Current passenger car studies indicate this is .86. ~.1e believe the correction factor for trucks should be greater. 55.2.2 0n ambient temperAtUre, we recommend 8 range Of 6o0~ to 95F. S5.2.J ::e would !'-uggest t~t this he chclnged to "air ::\t ambient temper~ture be directed to the drum at the re-te of 2200 feet ror minuto". n..~ +" vnri:dilVl.... in tho !"h...,('P. nf i.ho <"ir FMSI 00132 C:ockct :3cction ~>t ional High\'N"Y S2fety Oureau .iashington, Q,C. '28591 -.3- September 14, 1970 chMmher \'lhich eurrounds the drum it is impossible to comply '.'lith t.he "uniformly and continuously" conditions. 55.2.4 . The lining t.errperature is measured hy"' plug type thermo- couple installed according to SAE J84J~. The drum temperature is me~sured by a thermocouple installed per SAE J667. In summarizing, our supporting data on these cimo~mmeedntiaste tocoJnacneurn~ryi s an 1, exten 1971. sion of It will the be date for filing necessary to run tests in accordance with the proposed procedure before the full significcnce of this safety standard can be evaluated as to cost and particularly lead time. SSC/Clt Respectfully submitted, S. S. Conway, Jr. President .... FMSI 00133 :J.ricfion 177alcria~ S!anJardJ !Jn~llilufe, .Jnc. 370 LEXINGTON AVENUE NEW YORK, N.Y. 10017 Ml!rroy Hdl 3-0572 Cocke t :led ion i''d.ional Hihvny ~fety Bure,qu rlocm 4223 ~CO 3eventh Street, 3. ~. ,,ash i ngton, J. C./120591 september 14, 1970 'fj 'I .:)ubject: Docket No. 70-1 6; Notice ?1 \ir Brake 3ystems On Trailers The Friction ~'.:1terbls :>tandards Institute, lncorpori\ted submits the follow. ing co~ments to the subject docket: The scope of this Proposed r~iotor Vehicle Safety Standard is broad and requires such significant changes from current air brake systems, that time did not permit specific tests to be run to the proposed procedures. It has not been possi- ble to evaluate the proposed requirements from existing data, therefore an exten- sion to January 1, 1971 is requested for compiling supporting data. This support- ing data will be a prerequisite to meaningful co~ents on costs and lead time required to comply with this proposal. . There are questions regarding interpretation of the proposal and comments which can ba made at this time based on experience and available data. Is it the intent of this proposal to apply only to new vehicles manufactured after the effective date? The proposa-l refers to "each brake and drum assembly" being placed on an inertia dynamometer. Is the intent to dynamometer test all br3kes from the ~ehicle or only one of each brake that may differ in size or components? S3 "Curb .. eight" definition is not applicable to trailers as stated. S4.2.1 Stopping capability, "Vehicle at curb weight" is subject to interpretation. Does this refer to trailer only or also include towing motor vehicle. If weight of t~wing motor vehicle is included what provision is made for stopping this additional weight? Brake Retardation Force. To meet the proposed requirements will necessitate a significant increase in brake torque over brakes in current usa. This torque increase can be obtained by brake design. higher coefficient of friction lining, or both. Howeve~ development of such fricti~n material will 'require more time than permitted by the effective date of J~nuary 1, 1972. S4.2.4,1. Clarification is needed on the torque value to be used in this calculation. Tnrque output during a given stop may vary as much as 25~ from minimum to maximum. FMSI 00134 Docket Sect ion n=~tional Highway ;:,afety aureau ...'l sh i ngton, D. C. .~20591 -2- September 14, 19?0 34.2.5. Br~ke Power. We are not in full agreement with this requirement as it overlooks basic functions of brake fade which warns the driver and prote~ts the br~king system from destructivo temperatures. These requirements can not be fully evaluated from the standpoint of ultimate brake temperature as current brakes will not meet these unrealistic fade requirements. S4. 2. 5.2. We would prefer to have specific data before making final comment, but it is our opinion that a 14 fpsps deceleration requirement is unrealistic within one minute foll~wing any test which results in de.struct i ve brake temperatures. S4.2.6. Brake Recovery. We recommend.ten stops at two minute intervals to pror:.otJ better cooling and a more meaningful recovery check. One minute intervals generally result in a stabilized drum and lining temperature. The term Gross Vehicle ~~'eight Rating (GV\'.R) when applied to a trailer is subject to interpretation as written. If the GVWR includes the towing vehicle the Gross Axle .:eight Rating (GA!/R) of the trailer does not comply with GAWR definition in S). If the vehicle is loaded to comply with GAwR definition, what provi~ion is made for stopping additional weight of towing vehicle, to prevent penalizing the trailer brakes? Conditions for burnishing trailer .brak~s Are subject to clari- fications requested in S5.1.1. 1t is suggested the following trailer brake burnish procedure be considered as solution to the clarification needed in 35.1.1.: 200 trailer brake applications 40 iJPH to 20 o;.PH at 10 fpsps maintaining 1 ining temperatures between 3150 F and 385 F. i:ake 200 additional applications 40 t.1PH to 20 fii.PH at 10 fpsps maintaining lining temper- ature between 400 F and 500 F. This will necessitate instal- lation of a plug type thermocouple as specified in SAE J643a. S5.2.2. ~tolerance should be established for eouivalent wheel load as the inertia weights on dynamometers vary and it is seldon possible to achieve the exact equivalent in inertia loading. Additional time will be required to determine what tolerenc~s would be reasonable. ~e also believe that the dynamometer loading ought to reflect various fricti~n losses in a vehicle not encountered on the dynamometer. Time, again, v~uld be required to determine a realistic value. Current passenger c~r studies indicate this factor is .86. ~.e believe the correction factor for trucks should be greater. On amb.ent tomperetore ~ reccumf'!nd a ran~ of &J F to 95 F. FMSI 00135 ------------------------------------------------ Docket Sect ion N."tional Highway ~fety Bureau . ashington, D. C. "20591 -J- 3eptember 14, 1970 55.2.). .:e v1ould suggest that this be changed to 11 3ir at ambient temperature be dirP.cted to the drum at the rate of 2200 feet per minute." Due to _vi'lriaticns in the shape of the air chamber which surrounds the drum, it i~ impossible to comply with the "uniformly and continuously" conditions. Docket 70-16 does not specify thermocouples. As both drum and lining temper- atures per sr.E aJr8e4:r3a~fearnedncderudm, 35.2.5. and 35.2.6. suggest thermocouple per Si\E J667. specifying lining thermocouple In su~martztng, our i~medi~te concern is an extension of the date for filing supporting data on these corrments to Jgnuary 1, 1971. It ~1i 11 be necessary to run tests in accordance with the proposed procedures.before the full significance of thi3 safety standard can be evaluated as to cost and particularly lead time. Respectfully submitted, 3. s. Conway, Jr. President FMSI 00136 CCI:~~NTS TO BE ~u\DE IN WAS!IL:GTON UN HEARING OCTOBER 20, 1970 -- DOCKETS 70-16 &. 70-17. ~!y name is RobL,rt \elson and I ;1m speaking on behalf of the Friction ~L:J.terial Standards Institute, Incorporated. As brake lining manufacturers we are very much concerned with the effects the proposed standards on air brake systems for trucks, buses and trailers will have on our industry. We share and wholeheartedly support the objectives of the Bureau toward improving the stopping ability of vehicles equipped with air brake systems. We are, however, also concerned with the effects these proposals will have on vehicle performance and the role which we can perform toward achieving these objectives. While our concern is directly with the friction materials, these are an integral part of the brake system, and so our comments must, of necessity, also include other components in the foundation brake. Because the principal performance requirements of the.brake are detailed under the dynamometer test sections in~both dockets, we will make only one comment, which is equally appropriate to each docket. We have attempted insofar as it has been possible in the short time available to run dynamometer tests representing a rather broad spectrum of friction materials that are currently available. Our objective was to establish the . performance of currently accepted brake designs and friction m~terials used by vehicle manufacturers under the proposed procedure~ We have.also evaluated other FMSI 00137 rocket Hearing -- - 2- brake linings that are available but not normally used with current brake designs. These, unfortunately, are not in-depth studies but do represent a broad cross section of what is available. Our first concern is the very significant torque increase called for in Brake Chamber Pressure versus Retardation in Fig. 3. Based on various brake designs, ~eight ratings and tire sizes, these requirements are as much as fifty per cent above current new vehicle brake performance. While some increase in torque capability may be desirable on some vehicles, we do not believe that increasing the torque level to that specified in Fig. 3 will ensure reduced stopping distance or safer overall brake performance. Further, tests show that the response of the,brake to increases in pressure are not linear. Therefore, to meet the upper limits of this curve means extremely sensitive brakes at lower application pressures. This variation in retardation force versus brake chamber pressure is not isolated to the specific brake lining characteristics but rather is affected by several factors within the foundation brake. Higher pressures tend to distort the drum and other components such as shoes, anchor pins, etc. Higher pressures also increase the stroke of the air chamber, which results in-reduced push rod force. All of these result in a reduction in torque output versus input pressur~. Our tests to date indicate that no combination of linings on current design FMSI 00138 Docket He.:1ring -- - 3- S-cam or wedge type brakes will meet the full requirements stipulated in Fig. 3. Materials with extremely high coefficients of friction have only been able to meet this requirement at lower pressures. We have had no opportunity to evaluate the effects of these very high coefficients of friction on other factors of brake performance such as drum wear, lining wear and brake noise, which is now being considered a form of pollution. Further, there js a tendency for brake linings with very high coefficients of friction to be less stable at higher temperatures. ; We have had no opportunity to evaluate the effect of less stable friction on the overall brake performance, stopping distance, and the interaction this may have on anti-wheel lock devices. The necessity for compromise in designing any brake system has long been recognized. When any one phase of brake performance is stressed it must be at the . expense or at least. the partial expense pf some other characteristic. As has just been cited, very high coefficients of friction tend to be less stable with temperature. Similarly, extreme fade resistance can be accomplished but generally at the expense of recovery properties. While there are brake linings available that possess exceptional fade resistance, they still have destructive temperature limits. The . very few tests in which we were able to complete the fade schedule and meet the requirements resulted in drum temperatures exceeding l,000F. In some tests the FMSI 00139 Docket Hearings -- - 4- br~kes caught on fire, terminating the test. This is above the destruction temperature fo,r br:ke lining and, as such, they become quite unstable with unpredictable recovery characteristics, We know that brake dTum weight is an important factor in the ultimate temperature reached in a fade test, Some work has been done toward using heavier drums which do indicate improved fade resistance due to the lower brake temperatures. Heavier drums also cool slower so tend to have some adverse effect on recovery. Tests also show that materials with high coefficients of friction and good fade resistance tend to over-recover. Our tests indicate that very few materials are capable of meeting the fade requirements even with heavierdrums and none of these will meet the recovery requirements as they all over-recovered. This combined with what we believe to be an error in the lower limit of 45 psi for 12 fpsps deceleration in the recovery makes it impossible to meet these requirements. We have already questioned the high torque requirements established in Fig 3. At 12 fpsps this indicates a maximum pressure of 37 psi, yet in the recovery we must achieve this with a minimum pressure of 45 psi. These are very adverse conditions and (we) should recognize the fact that the friction level of brake linings tends tC? be less stable following extremely high t~mperatures. We propose this minimum value for recovery be reduced to 30 psi. We do not believe that a brake temporarily at this FM51 00140 Docket !learings -- - 5- torque level is overly sensitive, particularly if used with anti-whee; lock devices. Wbile we recognize a potential problem of controllability with very high friction, we believe that from a pure safety standpoint it is better to have some excess torque capability under these conditions than not enough. Raising the inputs or actuation forces to the brake is another method by which high torques and increased fade resistance can be achieved, As brake lining manufacturers, we have been able to do very little work in this respect and at thia time do not know what effect this may have on the friction material and other components of the foundation brake. In summary, we recognize and wholly support the objectives of the Bureau in increasing the stopping ability of air braked vehicles. We also know there are a number of factors which, individually and collectively, will affect brake performance. We have not had sufficient time to study the effects of these individual changes much less the interaction and relationship involving combinations of these changes. This program is further complicated by the fact that there are very few inertia dynamometers capable of conducting the proposed tests. Screening tests such as those proposed can be run relatively easi!y and quickly, however there is no . substitute for long term vehicle tests of these changes in actual service to .fully evaluate the interrelationship of these various factors and to.prove their FMSI 00141 Docket Hearings -- - 6- reliability. Anything short of this may indeed result in a reduction in overall vehicle safety rather than an improvement. *** Robert E. Nelson October 20, 1970 FMSI 00142 --~----------------------------,----~----------------------------------------------------- I MIJrray Hilt l-0572 I' , ' ,- ~n I V ~~I \- ~rictiol~-- n1ateria~ Stanclarcl YnJtuute, 370 LEXINGTON AVENUE l' NEW YORK, N.Y. 10017 t i --- .._..-_ _ _ _ L _ _ ,.....,. October 20, l.'r. George Nield ~lat ional Highway Safety Bur~u Room .::5234 400 Seventh Street, S. \'/. Washington, D. C. ,;'20591 Surrject: Docket 70-17 Air Brake Systems, Trucks and Buses Dear ~~. Nield: These comments are submitted es supplemental to those filed by the Friction "'aterials Standards Institute, Inc. on September 14, 1970. These comments apply also to Docket 70-16, Air Brake Systems on Trailers. As brake lining rranufacturers we are very much concerned with the effects the proposed standards on air brake systems for trucks, buses and trailers will have on our industry. :te share and wholeheartedly support the objectives of the Bureau toward improving the stopping ability of vehicles equipped with air brake systems. We are, however, also concerned with the effec!s these proposals will have on vehicle performance and the role which we can perform toward achieving these objectives. \'/hile our concern is directly with the friction materials, these are an integral part of the brake system, and so our comments rrust, of necessity, also include other components in the foundation brake. Because the principal performance requirements of the brake are detailed under the dynamometer test sections in both dockets, ,;70-16 and ]70-17, these cornnents wi 11 apply equally to both dockeis. (. We have attempted insofar as possible in the shOd time available to run dynamometer tests representing a rather broad spectrum of friction materials that are currently available. Our objective was to establish the performance of currently ~ccepted brake designs and friction materials used by vehicle manufacturers under the proposed procedure. \'le have also evaluated other brake 1inings that are available but not norll".ally used with current brake designs. These, unfortunately, are not in-depth studies but do represent a broad cross section of what is available. Our first concern is the very significant. torque increase called for in Brake Chamber Pressure versus Retardation in Fip.- ). Based on various brake designs, weight ratings <.~nd tire sizes, these requirements are as nuch as fifty per cant above current new vehicle brake performance. \'ihile some increase in torque capability may be desirable on some vehicles, we do not beli~ve that increasing the torque level to that speciried in Fig. J will ensure reduced stopping distance or safer overall brake performance. Further, te~ts show that the response of the brake to increases in pressure are not generally linear~ Therefore, to meet the upper limits of this curve means extremely sensitive brakes at lower applica- t ic-n rr ...~s!I,.OEl. Thi:5 \1,"\r i.-.t iof) in r.,tartlr\t ion JOf"C.:e versus hrake chamber pressure FMSI 00143 -------------- -- r'r. Georpl! ~J i el d ~!,::d ion-! 'Hirkvi'ly s.~rety Bureau ..ashi ngton,. D. C~ -2- October 20, 1970 is not isolated to t~e ~pecific brake lining cha~acteristics but rather is affected by sever~l factors within the foundation brake. Higher pressures tend to distort the drum and other co~~entssuch as shoes, and anchor pins, and to increase tho stroke of the air chamber. All of these result in a reduction in torque output' versus input pressure. To date we have been able to run ten dynamometer tes~s to evaluate current production brakes and friction ~aterials and also demonstrate the effects of such changes as increcsed coefficient of friction, drum weight, various wheel loads and ~l factors. i:Je have attached plots on each of the dynamometer tests and identified these "A" thru "J'. The test conditions such as b.-ake size, type, Al factor, wheel load, drum weight and friction material have bee~ detailed on each plot. The first discussion wi 11 deal with the retardation force or effectiveness. The second discussion will combine brake power (fade), hot stop and recovery as we consider these closely related. Effect iyeness: It should be noted that all tests failed to meet at least some portions of the proposed requirements. This includes variations in coefficient of friction from medium to very high, loadings, drum weights and AL factors. In all tests the slope of the curves produced by the data does not agree with the slope of the proposed minimum acceptable line. Low pressure points nearly meet or exceed the proposal. Ho1vever as pressure is increased the curve from the data falls far away from the acceptability line. 'ile do not have sufficient data to determine if this relationship should be linear or expreseed in curve form. ~-le feel there may be a variability in dynamometer cal ibratlon which should be further investigated. Some dynamometers have the capability of controlled output while others must be manually operated by controlling input pressure. As long as the current state of the art cannot produce adequate margins for compliance, the dynamometer testing procedures rrust be more definitive. Our tests to date indicate that no com~inat ion of 1 inings on current design "S-cam or wedge type brakes will meet the full requirements stipulated in Fig. 3. Materials with extremely high coefficients of friction have only been able to meet this requirement at lower pressures. We have had no opportunity to evaluate the effects of these very high coefficients of friction on other factors of brake performance such as drum wear, lining wear and brake noise, which is now being considered a form of pollution. Further, there is a tendency for brake linings with very high coefficients of friction to be less stable at higher temperatures. v-Ie have had no opportunity to evaluate the effect of less stable friction on the overall brake performance, stopping distance, and {he interaction this may have on anti-wheel lock devices. The necessity for compromise in designing any brake system has long been recognized. l'lhen any one phase of brake performance is stresse;d it rrust bl:l at the expense or at least the partial expense of some other characteristic. As has just been cited, very high coefficients of friction tend to be less stable with tefll)erature. ~: - It is a recognized fact within the brake lining industry that fade and recovery characteristics are the most difficult to reproduce. Extreme fade resistance can FMSI 00144 \'r. George ~:ield rJat ion<' I '"'Hirb::"'' Safety Gur~;,u .;'ashington, ~o.c: -3- October 20, 1970 be accomplished but generally ~t the expense of recovery properties .~ile there are brake linings available that possess exception?! fade resistance, they still h~ve destructive terrperature limits. The very few tests in which we were able to complete the f3d~ schedule nnd meet the rec,uirements resulted in drum temperatures exceeding l,OCOOF. See curves A, B & G. In another test of a lining that had passed, the brake ~aught on fire when run with a lighter weight drum. See tests A~ D. This is above the destruction temperature for brake lining and, as such, they become quite unst~ble ~tith unpredictable recovery characteristics. l"le know that brake drum weight is an i!T'Portant factor in the ultimate temperature reached in a fade test. Some work has been done toward using heavier drums which do indicate irrproved fade resistance due to the lower brake temperatures. Heavier drums also cool slower so tend to have some adverse effect on recovery. Tests also show that materiels with high coefficients of friction and good fade re- sistance tend to over-recover. See test B. Our tests indicate that very few ma\erials are c~pable of meeting the fade requirements even with heavier drums and none of these will m~et the recovery requirements as they all over-recovered. This combined with what we believe to be an error in the lower limit of 45 psi for 12~ fpsps deceleration in the recovery makes it impossible to meet these requirements. -~e have already questioned the high torque requirements established in Fig. 3. At 12 fpsps this indicates ;: maximum pressure of 37 psi, yet in the recovery we must achieve this with a minimum pressure of 45 psi. These are very adverse con- ditions and we should recognize the fact that the friction level of brake linings tends to be less&able followina extremely hiah temperatures. l.'e ar:-e not in a. position to propose 1ninirrum value until F1g. 3 has bAen properly adjusted. Whlle we recognize a potential problem of controllability vtith very high friction, we believe that from a pure safety standpoint it is better to have some excess torque capability under these conditions than not enough. ' Raising the inputs or actuation forces to the brake is another method by which high torques and increased fade resistance can be achieved. As brake lining manufacturers, we have been able to do very little work in this respect and at this time do not know what effect this may have on the friction material and other components of the foundation brake. In surrroary, we recognize and wholly support the objectives of the Bureau in increasing the stopping ability of air braked vehicles and basing these tests on an inertia dyr.amometer. \:e also know there are a number of factors which, individual- ly and collectively, will affect brake performance. \"/e have not had sufficient time to study the effects of these individual changes much less the interaction and relationship involving combinations of these changes. We recommend the final performance levels be accorr.pl ished in a minimum of two steps allov1ing two years to complete each step. Screening tests such as those proposed can be run relatively easily and quickly. However, there is no substitute for long term vehicle tests of these changes in actual service to fully eveluate the inter- relationship of these various factors and to prove their reliability. Anything short of this may indeed result in a reduction in overall vehicle safety rath~r than an improvement. Respectfully su~i~ted, SSC/clt r,..,,..., ...,,_,,,.. .... ,... S. S. Conway President FMSI 00145 -------------------------------------------------------------------------------------------.--- t.i~. wT II~ ll>~ rso -.... !;_too J \'I t"~ '(o !).. tL <1: 60 u ~"'~-' :: 40 q; v:t. w 20 'lJ. (!. (\.) .. ,, - ,, ' . 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I i ' 'r. .~1 ..!L-j.,_.[t'-rH- ''.1 : ' f r, ~ -1 t;- - r -t----:,-- :1~- 1 1- r r~ >- ' t""- 1 ~ ' 1 . ~ : . . 1\I -; - . t .l- I ,- ' I FMSI 00146 I ~ FFEC'II-JE N E"'!S :::r : -r-~--~---- 1 c r::> - ._ - :- ~ ~: _t _:_:_: -_-. - ,I FAc.Tor<. iBo ..,.-.,. .. :Ul ~ (j L_ ___ ___:. __ : -------- [<) i8t'Aj:: _TV't"-::i CAi-~ ! - I_ ---- 1-- (~ ~ i ' --~-- - ,.. --- 1l'---------------------- --- __ _j FMSI 00147 ,e.:.."'r:-- 1 1'..::->r _ L!__ .. -~,-_ - / FMSI 00148 ---- ---.----~ ---~--;~------,-T -q too ~ '-' r.vrrt. MA Lfi7A ' -tt~' Rc- \!i IL 11~ ~~ I'll urr 7S lbs- ~ (~o <t I WH~fl. ~n AL. FACT=>.;: to~'S.,ol~ 18, r:; '"O:l <1 0 ~ c( :!. u l.lt ~((,l~~ ~,z.:; J":rl- .. 7 ?1. . - . ------- ------- ---~ ~l.:e: !'it'~ .,S.._ ci-'M - t . ' ,' II / I, I / I 7 /. ' I. I I ' ~: --~--~ _] J .- T: L .. --l .I td lo -:\1 !.. .,., q -- ----------. ~ __:__::~~ g --- 1- :.J ..-:::-~~--: __ ,,_ _:~-.: - .. -:-~-- _J. . --t ;. ;>---_- ' -:--------~-----------_-:r-.;-_.--r,1------~--~--------=-,~.,.1._, 0..0 - . I I ....1\1 I '1' - - - ---- - 1-- -1 -- :-~HoT sroP. -11\ Sa ~1..1 ---tJ ~0 '~0 ?sl. --- .. l&l 1---- - ---:- . -~-~--;.-~----_ ~---- ; ____ -~- Ft/sc:-~, i---- -----. I- - - 0<l 4o ~;:.~~---==~: ~L_ =- :_ :-~ 4~ L-:: ~~-~ -:; t5 l1 - ' - - - - - - - - - -- bl ~--- . . -----. -+,-- 1"-- I- t - - ~ .: ,- I ---~~~--~:1 I - >:_.:-:, __I --~-,- .. ,... ' ,-, 1 r_~=--1-i! ., 1 -- ' I I I. FMSI 00149 11.l ('Y~ rq-. n')JTL 'P (0 -13 N: :1') '..L'T r./'\:l cu {\. <Y. 6~ ~- ,,, ' :r-~-~,... ~ ;.c,; 31: ~ r~s 1 ~~ 4~ ::,; "':. rAc..-.,a. B~lcf ~~;:.::_ 2.10 ., 7'"' ;12. >( -~x. \.J ~ <l ',J ,. s- ~------- _(D (/.rn. 2o ,I /. ,' / / ' . Zo 4o Cr 1A li.'t>,-1 ;r:: ~i ~o 90 I oo 'F'02cC /G;Awk (i) .. 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L --I No>; SToP< ,, .("f):~{i~i;~.2~~ --I ., -~ -~ ~------'---__ ~"' -:.l - .- I -. .....' i'I "';::'-. -' L. - i KECO/E"jl:!'f I:~ t I ' : :-:--:- ---~._:. ..~~t-.:i-~-----~_.c _c _,-1 .,-~;.'~---.~~.I_\,. 100 i~"' ~a -~ ~ ..~' ~ - "t-.J ~ --).~~c=~~~:~:t~~::;'l~~~j~ .. :. . -.. - . . .. _-_ .- -- -f ~- -;---~~-f-~-I>! :=~= ~==. rs~~:--~.-t. ~~-I-=.-'-f -- -~;-;:....p-rlt"'.:o-;:~;.e----' --. -1--------- -~G_v.f..e!':I~~.!~.-..:...~~.; ~7:~~=-:.'--:-.~--1 <( 40 ____r ------ --- .,; .. .I . - "X. \J \J ~ 2d -- --- ~------~--~--~~--~--~--~-~~---~-~--=--~--~=~~-~!. -~- '- .. T :--=-=-~=-~~~- Q ClQ . -1 - - -l lt . -, .., . :-.:j_ . i-. --~ ~/--/. ~ . decelctra.llo ' l' n - ~~-~.--~~ t .' STo?1!0S- I r~-;~~>~~~=.~~..-. j- -- ..1 :----. 's}---~--.----~~.~":"_:'..:--i _~;...:.~ --:--~--.:-~:'l.-.=r--::,_=!.-.._;..7~:-~.:_::~~-... : - 1t--~~ ~- :-~~-~- ~' i :,L -" I 0 1 i -~ ~ i ~_J I 17 ; 11 I -;f'i' - ' ' ' :1 --- --- __!_' __ __: ____Tf'ST..:____ _ FMSJ 00150 -- ; ._; . -.~=--;--- :-::i '1 E:S I . . . . - ; ... 1- -. ,- ... ---- .... - t --- j . ~-------------- t---- -- --- ---- . 1 - ~ - .. . -~- i - _________! ... - --- I .I : _j_ .. -.,-- t . -. - r' . - -- r -- --- --I - ----1- ! ! ___ -- ___ .. ~e-CPVf; r:?.'/ J ----- ---. -. ' 1- :'---- --- -----1I ----- I .. I .-~: I f -- -- t FMSI 00151 ..------------------------------------------------------------------------------------------------------ .. "Dwrv1 tJT 7<1 fb t>-t (,.() ~ u.'H(CI.. '-"'''') AI. ttkTOK, N ""'.itll 2. ::)o 1'-~ ~ ~ -vr '"~ !! e,A ICC: $!U r"J'z." 7 ~ . -------- ------- I'(\ "s~.lt:E:. T't PE. (Itt"') .. ~ -- --- --- ------- .. --- ~ --- -I -y ~ tOO,.- '-J ~ Ul 8o ~ .. - - . - ~=j--- j -~:- -_ ~ e.o ~-~-- -~---:J--.--- ~-- . < 4o -~ -I u - - -- - ! --- --- . I ~ L -- _:. -----t .. -- - - - ... - . ~ --+ --- ---C ~ , I - . --- . ~ _ -=--r -- -n-.... ::1. t~~--:- .. 1 I .. - .s No.: .OF -I --- ---------i i .~ HoT StoP.~ 8T. Ps.r .--~-1~ _FT!~"- . - - 1- --- --~- }-. -,I ' _._ _ _ _ _ _ _:___!_ _ _ i -- ,r- I' ,. ' 1- . ' ~ i FMSI 00152 ------- __--- --------,. ...,..~--- -~ j 1M ............. v-4s ~ ~J "'"..'. 'j!l ~-~ "- t..r -~ -:t .,tl, 'l~oi~ ~ ; , I ,I I I ' /. . ./ I I :r -t -I i - ----- -- -~-- :-:_.+)_~ - - - - - - i I-' k) ~ q- 3 }{I :I i' r, ~ I- ~ I I - - - --- - - tQ __ l~s II LO ~ 60 8o, lt.O eETA12'DA11 ON F"oece:jq.tt.w e ~/.) I 1--1 l ' F_!\_.P_~ .:.i ., r ~ bl -<.o {(\ ,--_- ----~ ~-~~--~---~ v'X:-f<l lLi .loA ltl 'l - ruUl ""' Cl i - -~-. . ---;- II ;t I __ t. I f-Jo-r STOP .78 PSI /~!c"~ ~":.:. FT {,0 - -----------~;---------~ :__~ ---:~~~~~:-~3:~-~-~~ -~~ ~ lfi.U> "<' ~ .I -j t , ,. 'I ! - -t- -Ii s riO :. !.- j ... I- or ;- .,i - FMSI 00153 Gn~------------------------------~~--1 ~-~~-~~-------------------=--~--~~ FMSI 00154 FMSI 00155 ri - ~ - - --, -. -,-1 - ~'' J,,;cf~on ' A17 cJ//4 c370 LEXINGTON AVENUE NEW YORK, N.Y. 10017 ,A -~ It{, .. NI ___,__. January 25, 1971 Docket Section, National Highway Safety Bureau Room 4223 400 Seventh st., s. w. Washington, D. C. 20591 Subjecta Docket 70-27, Hydraulic Brake Systems Gentlemen: These Comments are submitted for your consideration, by t~e Friction ~~terials ..... ' Standards Institute, Inc., whose mem~ers :nclude most of the manufacturers of brake linings in the United States. Our comments are supplementary to those made at the October ), 1969 hearing on the up-grading of FMVSs-105, which at that time pertained to passenger cars only (Docket 1-1). . Testing Beguirerents and ~acilities The two-stop fade requirement that is to be made at a speed approximately 5 ~~ under the top speed of the vehicle is a test essentially be~ond the capacity of the brake lining manufacturers when it is applied to vehicles where the top speed eK- ceeds 105 ,~. The brake lining manufacturers are aware of the need for high speed brake testing and capabilities, and have tested at speeds of SO ~.flH, 90 I;PH and 100 MPH. Brake data developed at these high speeds has been extrapolated to insure that linings have extreme high speed capabilities. Beyond extrapolation, the brake lining manufacturers do not have the facilities to specifically warrant compliance where maximum vehi~le speeds in excess of 105 MPH are possible. We question whether such specifications and requirements.ser~e the interests of vehicle safety, nol only for those doing the testing in industry and government,_ but for the general public where brake capabilities at speeds up to 140 MPH may be a license for operating a vehicle at these speeds. Would not the interest of vehicle safety be better served by limiting the speed? Eerformance and Fade Orientation of Test The brake lining manufacturers feel that the high perf~rmance requirements may be met with existing equ\?ment, but that these requirements are the high limit which can only be met with brake 1ining formulation_, aimed at passing this test only. This test is operate'- at conditions in the destructive ran~e for existing 1 inin~s. For example, a sacrifice may be made which will promote rapid lining wear, continuous degradation of friction, poor friction when cold, and brake stability problems aWith linings formulated to pass this performance test ~f only few hundred miles of vehicle operation, it is concei~able that rapid. wear to only 1/16" or 1/8". of the shoe may accelerate problems of brake system d&terioratfon specifically noted In the docket when final inspection is m3de. While guarding the brake performance for the heavy-f~oted driver, the majority of the drivers will most likely pay in shorter brake lininQ life. Further, with existing brake linings geared for performance FMSI 00156 Docket Section, National Hiehway S~fety Bureau Washington, D. C. 20591 -2- January 25, 1971 there usually i9.an increase in imbalance problems such as brake pull at decelerations belcw the lock-up protectlon afforded by anti-ski'd devices. Such sacrifices in wear resistance and stability for the tens of thousands of miles most drivers expect- and should expect- from their linings, will most likely be the price for requiring brake linings formulated for the specific purpose of passing an extreme performance test. Anti-skid and Load-Prooortionino Sy5tems The requirements in Docket 70-27 imply that industry must have "~ntilockine ~vstems" and "Brake Proportionin~ Systems", in no.t just trucks but in all vehicles covered by this docket. These systems present a~ entire new factor as regards the testin~ and capabilities of brake lining. The brake lining manufacturers have minimum background on the possible effects that may result from their use on all vehicles. Concern is expressed by most manufacturers for linings used in multipurpose vehicle~ and h~avy trucks, where design frequently uses linings with different friction ~ characteristics on front and rear brakes. Summary In our earlier response to Docket 1-1 on the initial up-grading of f~VSS-105, we expressed concern about requirements beyond the existing state of the art in braking passenger cars. 1'/e no!ed the lack of testing facilities, and the characteristics of brake fade. These comments apply equally to Docket 70-27. In our response to Dockets 70-16 and 70-17 (\ir.Brake Systems) we enclosed test data to support our position on the difficulties inherent in requirements of those dockets. We wish to emphasize that t~e brake llning industry is just as concerned with the requirements of Docket 70-27 as with these earlier dockets, but we could not perform tests to evaluate these severe requirements, as the brake linin~ in- dustry simply does not have the facilities on which these tests can be run. Respectively submitted, s. s. r-onway President FMSI 00157 --.-e...a,..-.....o-.;::- .-._.._....,r....,... _ _ _ _,..__..;.,~....,- .. ,-_ _... ....,_,_....,.~.:..'-- ~ ~"1 . . . . =""~- ..., kotl2 .- ~..:...;,_'_L_ - f"!--~'f'-=A: -=~ir.-:._---~I,,--~:."''\'"CJ'r1i'~/1 'i"'1~1~~-~~tJ~IJ~.f'lertalAJ .~J/and~rtk J,n;~lilule, J.n~~c. MUrray ~til 3-0572 ~~~r..,~J)~1I;11-=21J/~, J= o~;;.s~~t,-~~-..~ 3 7 o LExlN c'io N A v EN'IJ t .. ,... NEWYOR~,r 100!7~!t 26,,t971 ~, . rfA o/ t+1 c:-v -r ,, r" National Highway Traffic Safety Administration .' Room 4223 400 Seventh Avenue, S. 'N. Washington, D. C. #20591 Subject.: Federal Motor Vehicle Safety Standard #121 Gentlemen: T-hese co!M'Ient.s are submitted for your consider"atton by the Friction Materials Standards Institute, Inc., whose members include most or the manufacturers of brake linings in the United States. These co~ments are to supplement those made earlier ~ in our September 14, 1970 and October 20, 1970 responses to Dockets 70-16 and 70-17. The lnstitut.e 1s members had run various dynamometer and vehicle tests prior to the hearings on Dockets 70-16 and 70-17. While there have been changes incorporated in FMVSS 121, we have not had sufficient time to run additional tests. However, based on past tests, the members of the Institute wish to corrvnent on the .stopping distance requirement. STOPPING DISTANCE REQUlREMEm: FMVSS #121 20 MPH 33 1 ~MPH 245 1 The 20 MPH requirement does not present a problem. However, the 60 MPH mini- mum stopping distance requirement is not attainable with today's good commercial lin- ings on existing braking systems. By "good commercial" linings, we wish to emphasize wear resistance, absence of noise and stability problems, as well as friction and fade characteristics. For example, in one member's tests, using a high friction lining (rated "GG" using SAE recommended practice J866a), the 20 MPH stopping distance requirement was met. However, the 60 MPH requirement could not be met .. The brakes were 16 -1/2 x 7 ,,S Cams", on a single axle. The use of a 11GG" lining for these brakes is not neces- sarily good practice, and in normal service we would expect to use linings below "GG" in friction. We compute the deceleration rate used in Standard 121 using .30 second actu ation time. This is consistent with Standard121, Section 5.3.3, where 0.25 seconds maximum will be allowed to read 60 p.s.i. air. -Pressures in excess of 60 p.s.i.will .be required for stopping distance tests. The tabulation shows that approximately 17.7 ft/sec2 deceieration is ;equired for Standard 121 stopping distances, computed as above. (Note, the 40 MPH - 108 ft stopping distance is not linear with tho other stopping distances). This standard does not allow for speed sensitivity characteristics-of the brake and brake linings. FMSI 00158 Docket Section National Highway Traffic Safety Admin. Washington, D. C. #20591 -2~ March 26, 1971 QEQELERAT[ON AND STQPPING DISTANCE SPEED MEtL 20 25 30 .35 40 ;4o5 55 60 FMVS~ 121 I(XF:CJ/ESLEC2 ) 01 STANCE (FT) 17.7 17.7 17.7 17.7 19.0 17.7 17.7 , 7.7 17.7 ~ 33 49 68 90 106 14) 174 209 245 FM~I R~CO~.M:NDATIQN IECEL DtSTANCE (f!/SErt) (FT) 17.7 17.4 17.2 16.9 16.6 16.4 16.1 15.6 15.6 :n 50 70" 93 120 151 181 228 274 Allowing for current state of the art, a 3% fall-off in deceleration rates should be expectea for each 10 MPH increase in speed. Allowing for this speed slaesntsittwivo itcyol,umwensboeflietvhei~thtaebdleecaerleeraatttioainnar ates ble. and stopping distances shown in Without such an allowance, the the speed sensitivity inherent in brakes and brake linings, is being ignored. $1Jt!1ARY . We wish to emphasize that with existing brake systems~ brake linings cannot be expected to meet the stopping distance requirements of FMVSS #121 at the higher speeds. ment, wAe lrseoc,omamlleonwdinthgaftorthwe hsatt owppeibn~el ieve dista is an error in the 40 MPH- nce requirements be adjusted 108ft requireto allow for speed sensitivity, in line with the v~lues shown by our tabulation. R5speotfully submitted, S. S. Conway President FMSI 00159 - Exhibit "D" Page #1 Nf\YIO~\]AL TFtAFFIC Roucc t:. l\flOTOn \H~H~CLE Sf\r=t:TV 1\C'f OF AUTOMOTIVE SEr~VICE INDUSTRY ASSOCIATION --------------- ------------------- 230 North Michir;5n Av~nue. Chicago, Illinois 60601 (312) 236-8720 THE li>OUS/1/fS !JJ.f!IU/1 SERVICE ASSOCM r!O.\' HANUFACTURER IDENTIFICATION The National Highway Traffic Safety Administration has proposed a new settion, Part 566, to the Code of 1-'cdcral Regulations that would require motor vehicle manufacturers and ~~__y_ehicle equipment manufacturers to submit identifying information and a description of the items they produce for _which a motor vehicle safety standard appUc-s. The purpose of this part is to 11 facil:l.t:_~ the reculation of manufacturers under the National Traffic and Motor Vel1icle Safety Act, and to aid in establishing a code numberine syf;tem for all regulated manufacturers11 Manufacturers would be required to furnish basic iriformation on their corporate and business status and residence, a description of each type of motor vehicle or of equipment they produce, and information on production capacity. The proposed effective date is July 26, 1971 and interested persons are invited to submi.t data, vie\-TS, and arguments concerning the proposed regulations by the close of business on.Jun~ 28, 1971. Comments must refer to th~ docket number, No.71-ll; Notice 1, and should be submitted to: Docket Section, National Hiehway Traffic Safety Administration, Room 5217, 400 Seventh Street, S.W., Washington, D.C. 20591. It is requested, but not required, that 10 copies be submitted, The full text of the proposed regulations as they appeared in the Federal Register of April 28, 1971 is attached. -0- .-..,. (over) .IEJWV OUTY VE::.:..C.. LE and EUU!Prv1EI'JT- PAnTS DISTnlBUTOr.S DIVISION This bulletin is for the e,.clu!.ive usc of n1<1mbcrs e>f Automotive Servir:e lndu~try Ass.oc;at1on. It is not to be reproc!u::.ed. sold, d1stributc::i or othyrwisc released to anyone without tho expre~s written permission of A.S.I.A. FMSI 00160 - .A.nnual ~!eet ing Minutes Exhibit 11 J" National Highway Traffic Safe-ty Admini~lrolion [ 49 CFR Port 566 1 ( Dc-.ckct No. 71-11; Notice 11 MANUFACTURER IDENTIFICATION Notice of Proposed Rule f..1aking 'I11Is notice propo~rs t-o Rc!opt a n~w Part 566 in Title ~9. Code of Federal R>;:1tlatio:1s, t!1at would fC'(!UiH' manufacturers of motor vehicles, and of motor Vl'hicle e-tuip:nent. to which a nwtor vehicle ~:~fcty st:wchrd arplies, to submit ldcntifyinrr Information and a &xription of the items they Pl"OducC'. Sectio!l 112Cc> of the Nati0nal Traffic and l\rotor Vehicle S:tfety Act rC'quires manufacturers of motor vehicles and motor \'chicle equipment to "iH"O\'ide suC'h Information as the Sccreta:y may l"l':~.Sonably TL'<lllirc to enable him to determine v:hrther fUCh mmmfncturcr has acted or Is acting in compliance with this ti\.lc lUlU motor \''hicle ~afct:. sta:1dards pre.--c,ribrd pursuant to this title, ." S'fUon 119 further ~;rnnl.~ the Sc"'Cl"C'Inry &f'nl'rr,J authority to '"issue', amend. and TC'I"t>kC' sucf1 ru!C's and rr;:ulation.<; ns he d'fn1S n!X'C'~~ary to cany out this title." In o:-dcr t.o crn ouf the prol'i~ions of thl' Act., it is often nect>ssary to lune CC'J tain b~.sic information about the manufacture-rs of motor \'chic!'. or l'f'hiclr. equipment subject to ihe Act.. Thir, Is particularlv so in t-he area of enforcrment and in carrying OUt the ~C\'ernl fl!QUircl111"'l"ll.s for communication. ill$pcdlon, and report!.ng. It is necessary to ha1e cc1.: rally organized and collected inform;, lion rr,:arding the manufactuU!r's corporatr l't:-ctus, mallin~ addte:-;:;, it~ms m:.HlU[;.ct tn"C'Cl, and manufncturin!' locntio:l. l\!orroYer, IL Is 11C'C'C'.'"nry to n~,ctil b1e thig information ~o ns to n,:~J:e it Propc-.>rd E'Jf!'ctl\e d1!-'J: 90 days n!lcr lsou8ncc. Tnl't-;str<l P"I".'OilS nrc Invited to ~ubrnit cbt:., 1iecws, nnd ll.l'{'.lilncnts ronccrnln:~ tile propo~.cd rc;;ulations. C0:n:nrnts ~boultl refe-r to the docket numb;:r tmd be ~>ubmitted to: Docket Sc..tlon. Natic.n:~l Hi:::hw::- 'I'lnmc S:~fety Ar!minist!"<ltion, Room 5217, 400 Seventh Stnet SW., Wa>hinr.ton, DC 20591. It is rcqut"'stl'd, but not rcqu.irrd, !.hat 10 copies be suLrnilkd. All comnwnts rct't'ivcd before the close o! business June 28. 1971 will be COil-'idered, and will be amilable in the d0:::l:'t nt the abo1e nddrc-"~~ for c~:nminP.ticm lx>th brfore aud nftN U1e c:lo.,inr. dr1tc. To the: extent J>Oiisibi<>, rommf'llts filed after the above date will nho be cousidrrcd by the Administration. However, the rulemnking Retion ma~ procc.:ocl nt any time aHer thnt date, and c.ommcn(:; reccll'cd after the closing date nnd too !at<, for con:.idt>ration in rr;::nrd to the nclion wrll be trrntcd ns suer:cstions for fuL1uc tulc- mnkinr;. The Administration will con- tinue 'to file tclev:mt material, ns it becomes nvailab!c, in the <h>cl:ct oftcr the closint:: dntc, and it is recDmlntndcoct that int.ercst-ecl persons' contimu: to examine the docket for new materials. This notlce of pmt>Oscd rulcmal:inr~ Is 1ssueclundcr Ute authority of sections 112 and 119 or the National Tramr. and Motor V<hiclc s~rctr Art o 5 u.s.c. 1401 a!HI HO'it, and the delcrrations of authority nt 40 CI-"R 1.51 and 49 Cl'R 501.8. L<>~ucd on A!lril l G, 1971. ROIIOLro A. Duz, Acli11g A ~sociatc Admi11istrator, Motor Vclliclc l'roarallls. PART 56&-MANUF/\CTURJ:R IDEN'flfiCATION 566.1 Stopc-. Page #2 j(j(j,j H.. qnir<'m<"nl~. Each manuf?.cturrr of motor H:hiclr~. and each mar: ttfncturcr or cov~rcd equipment, s!J~.!l furni.':h ihe 1nfonnation specified in para~;raphs <a> throll.!.!h fd) of this sccL!vn to; Administrator, :1\aUo!t:tl Highway Trame S:,fety Adrninistrn tion, 400 Se\'Cilth Strcc~ SW., Wn~h int;ton, DC 20S!)l. Ca) Full individual, partnership, or corporate name of the manufacturer. Cbl Re!>ldence address of the manufa.ctwer a.nd State of incorporation i{ applica blc. (C) Description of each type of motor vcltic.lc or of r.ovcrcd equipment manufactured by the manufactwer, inrludinr, for motor vehicles, the npproximliW ranges of gro.;s \'Chicle wel{;ht ratings for each type, Except liS noted below, the description mny be of general types, !iuch as "P:~.S.S<'nr:cr citrs" or "brake fluid. In the case of multipurpose passenger \"C- hicles, trucks, P..nd trallcrs, the descrip- tion shall be SJ><"<:ific enouGh nlso to llulicatc the types of me for which nhiclcs ato intended, such as "tank trailer," "motor home," or "cargo van." In the cnse o! mo!-er \"chicles produced in two ot more stages, ii the mnnufaeturet is :m Jntermecliate nu.:mfactmel" or :i" final- stage manufacturer, the dec,criptJOn ~hall so stat~ r>.nd include a b:ief de~cnption of the work p~rformcd. Ex.u.rrtr= .. !1'!ulUpurp05~ p.u=.senr,"r \'C: hlcli'o: ll!ot-or hon~<s wlth 0\'V.'R frorn 8,0\JO to 12,(l{)l) pound,>. l'inal-st.,r.e manufncturcr- add boely w bare chu"SL>." <d) Estimnl~d nnrJUal ptoduction of each type \'{h!cle or COI'<'rcd equipment listed in J'csponsc Lo Jtaratraph <c> of this section. 5(i~.r. Ti~tu o( ml.ntillal o( iufonu:t- . rc~,r!ih accE'"sible to tho.~e lul.\'ing 'nforrr:;lent responsibility under the Act, nt:cl pro.ide a means f<'r ic!rntifying nne! c!a.<~ifyin!" nuulUfacturer-" according to the typt:>s of motor \"ehicles or cqui}imcnt which they mnnufncture. A. system is also nN:ded whereby t.lie NIITSA can provide infonnat.ion to manufn.cturers of ,-arious typ..>s o: l"l'hicks or ('(JUipment. For t.i1i'Se !"(>:1.>;')11$, th' Natiotutl Hi~h 'll';ay Trar:lc Safety Admfllistrntio:t proposes to e:>tablish a new Part 566 in Title 49, C'ode c>f PcclP.-al Re~ations, which would require maJJufacturl'rs to re;>Ot"t 'l'ilis p:nt TCfJiliH'-' manufacturers tf motor vehicles, nnd or motor vehlc:le NUipmrnL to. whlch a motor vchidt! ~dC"ty standard applies, to submit 1clrntlfyh1~ infonnation nnd n description of the itc-:ns thry produce. 51i6.2 l'urpo,r. 'I11e purpose of this part !.<; to facilitate the rc~nlatloll of manufacturc1-s unde-r the Nali-:-.nal Traffic nnd Motor Vehlr!!J Snfcty-Act, and to nid in establishing a code numbrrlng snt<'m for all regulated manufRclurcrs. lion. Each manufacturer required to submit Information uudrr 5GG.4 :;hr,Jl submit the information not later than -------~ ---- After that dJte, each person who brg!ns to nw.nufacturc n Ll'llt' oC motor vehicle or covered eqUipment lor whicll he has not s~brnitted the required information shall submit the ln!ormntiol\ I'J>eclf1ed In pan.c-raphs (n.) thl"Ollt:h <dJ of 5GG.4 not later than 30 days'b.ftct he becins manufacture. IFR Doc.71-5371l Piled 4--27-71;8:46 amJ stOtx"r'Cw.:ifti.ehdinir!:lfOondan~:-l~ticom! thtoe the AdministraeiTective date of titc app r>rop::.sed reg11lntion.<. 'I11c lies t.o all manufacturers reorrrumlaotitoonr 5(,(,,3 :\ppliralion. Thh part appJir,s t.o nil IIHlnufacturcrs of motor vrhiC'll~. and to manufacturer:~ vrllicles md of motor vehicle ('(Juipment of motor \ehiclc equipment to which a to ,.-lJich a motot vehicle s."'fety standard motor vehicle Mt{ety standard applies ap;,Jic,, 2nd utilizes the definitions of <h<'rt>nft~r rrfern'd to as "C'OI'<"red equip11 intA-rn~ecUr..f(!'' nnd "fi.n:1l ~t.ngc" n1:-tnu- ment"'), hcll:!er ~t out in 49 CFH Part 5G!l (30 F.R. 70541. The !nform!ltion required inciucles bMic info:mation on the manu- factlf('r's Cv!1:-::.:-ate and busine;:s statu:; and rcsid'~cc, thl' items produc'd, and Information on production cnp::city, 56(,.1 l>t'liniti<>ll. All terms d'!incd In the Act- and the rules nnct standards Issued under its P.uthotity arc usee! ns defined tbcrt>in. Sp!X'ificr.!ly ''intcrmcdintc manufac- turer'' nnd "final-stage m:mufacturcr'' a.re usrd as drfiurd in Part 568, Vehicles ~i~nnfacturcd in '1\;o or More Stages. fEDERAL REGISTU, VOL. 36, NO. 82-WEDNtSDAY, AFRIL 28, 1971 FMSI 00161