Document mq4LkNX84qQx0N5DpyMOy6j7k

fto fll '1? ^driclion nurials Standards ddnstitutc, d)nc. 370 LEXINGTON AVENUE NEW YORK, N. Y. 10017 MJrray Hid 3-0572 September 14, 1970 Docket Section National Highway Safety Bureau Room 4223 400 Seventh Street S.W. ..'ashington, D.C. ,20591 Subjefet: Docket No. 70-17. Notice #1 _ Air Brake Systems; Trucks and Buses The Friction Materials Standards Institute, Incorporated submits the follow ing comments to the subject docket: 'r The scope of this Proposed Motor Vehicle Safety Standard is broad and re quires 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 evaluate the proposed requirements from existing data, therefore an extension to Januacy 1, 1971 is requested for compiling supporting`data. 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 the proposal and comments which can be 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 proposal refers to "each brake and drum assembly" being placed on an inertia dynamometer. Is the intent to dynamometer test all brakes from tbe vehicle or only one of each brake that may differ in size or components? Will this require a double ended dynamometer? 54.2.1 Stopping Distance. The stopping distances specified require unrealistically high average deceleration rates, up to 17.9 fpsps at 60 fl/PH. To achieve these stopping distances it will be necessary to attain deceleration rates as high as 24 fpsps for sustained periods. These are not possible with current' brakes systems. Again additional time will be required for study and solutions. 54.2.2 Stopping distances specified with partial failure are at substantially 75% of full brake system. If a split air system is acceptable (S4.1.3} we assume a 50-5CT split and would expect stopping distances to reflect the same percentage. A clarification as to what constitutes a split service broke system is requested. S4.2.5 Brake Retardation Force. To meet the proposed require ments will necessitate a significant increase in brake torque over those in current use. This torque increase can he FMSI 00131 Docket Section National Highway S-fety Bureau l/sshington, D.C. ,''20591 2- - September 14, 1970 ' obtained by brake design, higher coefficient of friction lining or both. However, development of such friction material wi11 require more time than permitted by the effective date of January 1, 1972. S4.5.1 ' Should be 34.2.5.1. Also reference to S5.2.5 for burnish should be S5.2.6. Clarification is needed on the torque value to be used in this calculation. Torque output during a given stop may vary as much as 25/2 from minimum to maximum. S4.2.6 Brake Power, :.'e are not in full agreement with this re quirement as it overlooks a basic function of brake fade which warns the driver and also protects the broking system from destructive temperatures. These requirements can not be fully evaluated from the standpoint of ultimate brake temperature as current Drakes will not meet these unrealistic fade requirements. * S4.2.6.2 '/e would prefer to have specific data before making final t comment, but it is our opinion that a 14 fpsps deceleration requirement is unrealistic within one minute following any test which results in destructive brake temperatures. S4.2.7 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. ' S5.1.8 S5.2.1 It is suggested that a revised vehicle burnish procedure be considered for purposes of greater consistancy for correlation and repeatability of these tests. 200 brake applications from 40 to 20 mph at 10 fpsps maintaining lining temperatures between 315F and 385F. hteke 200 additional applications 40 to 20 mph at 10 fpsps maintaining lining temperatures between 400F and 500F. This will necessitate installation of plug type thermocouples as' specified in SAE J843a. A tolerance should be established for equivalent wheel load as the inertia weights on dynamometers vary and it is seldom possible to achieve the exact equivalent in inertia loading. Additional time will be required to determine what tolerances would be reasonable. .Ve also believe that the dynamometer loading ought to reflect various friction losses in a vehicle not encountered on the dynamometer. Time, again, would be required to determine a realistic value. Current passenger car studies indicate this is .86. Je believe the correction factor for trucks should be greater. . S5.2.2 On ambient temperature, we recommend a range of 60F to 95F. . ' S5.2.3 V.'e would suggest that this be changed to "air at ambient temperature he directed to the drum at the rate of 2200 feet por mirwito". Hno to variations in tbo sKipn of tlio air FMSI 00132 Docket Section Motional Hiphway Srfety Bureau Washington,JD.C. .'20591 -3- f September 14, 1970 chamber which ourrounds the drum it is impossible to comply with the "uniformly and continuously" conditions. S5.2.4 ' The lining temperature is measured ^y a plug type thermo couple installed according to SAE J843a. The drum temperature is measured by a thermocouple installed per SAE J667. In summarizing, our immediate concern is an extension of the date for filing supporting data on these comments to January 1, 1971. It will be necessary to run tests in accordance with the proposed procedure before the full significance of this safety standard can be evaluated as to cost and particularly lead time. Respectfully submitted. SSC/Clt S. S. Conway, Jr. President FMSI 00133 "* 11 WaleriaL Siandards Sndtitute> Sue. 3/0 LEXINGTON AVENUE NEW YORK, N. Y. 10017 M'Jrray Hill 3-0572 Docket section I'ltional Highway Safety Bureau Room 4223 4C0 Seventh Street, S. u ./ashington, D. C. 20591 September 14, 1970 /\TTAcH/V]^T '& Subject: Docket No. 70-16; Notice /I \ir Brake Systems On Trailers The Friction f'aterials Standards Institute, Incorporated submits the follovw- ing comments to the subject docket: : The scope of this Proposed Motor 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 comments 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 proposal refers to "each brake and drum assembly" being placed on an ^ inertia dynamometer. Is the intent to dynamometer test all brakes from the vehicle or only one of each brake that may differ in size or components? 33 "Curb eight" definition is not applicable to trailers as stated. 34.2.1 Stopping capability, "Vehicle at curb v/eight" is subject to interpretation. Does this refer to trailer only or also include towing motor vehicle. If weight of tnwing motor vehicle is included what provision is made for stopping this additional weight? S4.2.4 Brake Retardation Force. To meet the proposed requirements will necessitate a significant increase in brake torque over brakes in current use. This torque increase can ije obtained by brake design, higher coefficient of friction lining, or both. However, development of such friction material will "require more time than permitted by the effective date of January 1, 1972, 34.2,4.1. Clarification is needed on the torque value to be used in this calculation. Torque output during a given stop may vary as much as 25`/ from minimum to maximum. FMSI 00134 Docket Section National Highway Safety Bureau n.ashington, D C. ./20591 -2- September 14, 1970 34.2.5. , Brake Power, We are not in full agreement with this requirement as it overlooks basic functions of brake fade which warns the driver and protects the braking system from destructive 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 following any test which results in destructive brake temperatures. S4.2.6. 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. . 55.1-n. The term Gross Vehicle ..eight Rating (GVl'.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 33. If the vehicle is loaded to comply with GAWR definition, what pro vision is made for stopping additional weight of towing vehicle, to prevent penalizing the trailer brakes? S5.1.6. Conditions for burnishing trailer brakes are subject to clari fications requested in 35.1.1. It is suggested the following trailer brake burnish procedure be considered as solution to. the clarification needed in 35.1.1.J 200 trailer brake appli cations 40 UPH to 20 ,;PH at 10 fpsps maintaining lining temper atures between 315 F and 385 F. Take 200 additional appli cations 40 f.PH to 20 IVPH 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 JS43a. 35.2.1. A tolerance should be established for eauivalent wheel load as. the inertia weights on dynamometers vary and it is seldon possi ble to achieve the exact equivalent in inertia loading. Addi tional time will be required to determine what tolerencas would be reasonable. S5.2.2, t'.e also believe that the dynamometer loading ought to reflect various friction losses in a vehicle not encountered on the dynamometer. Time, again, would be required to determine a. realistic value. Current passenger car studies indicate this factor is .86. '.Ve believe the correction factor for trucks should be greater. 4. On ambient temperature, we recwoieiui a range of 60 F to 95 F FMSI 00135 Docket Section Motional Highway Safety Bureau l.ashington, D. C. w20591 -3" September 14, 1970 55.2.3. , ,.'e would suggest that this be changed to "air at ambient temper ature be directed to the drum at the rate of 2200 feet per minute." Due to variations in the shape of the air chamber which surrounds the drum, it is impossible to comply with the "uniformly and continuously" conditions. Docket 70-16 does not specify thermocouples. As both drum and lining temper atures are referenced, 35.2.5. and 55.2.6. suggest specifying lining thermocouple per 5AE J843a and drum thermocouple per 5AE J6o7. In summarizing, our immediate concern is an extension of the date for filing supporting data on these comments to January 1, 1971. It will be necessary to run tests in accordance with the proposed procedures .before the full significance of this safety standard can be evaluated as to cost and particularly lead time. Respectfully submitted, 3. S. Conway, Jr. President FMSI 00136 /) jfA c rtrf u > c' t COMMENTS TO BE MADE IN WASHINGTON ON HEARING OCTOBER 20, 1970 -- DOCSvETS 70-16 b. 70-17. My name is Robert Nelson and I am speaking on behalf of the Friction Material 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 materials used by * vehicle manufacturers under the proposed procedure. We have.also evaluated other FMSI 00137 Pocket 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. weight 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 pressure. " Our tests to date indicate that no combination of linings on current design FMSI 00138 Docket Hearing -- 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 .is 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 (of 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 1,000F. In some tests the FMSI 00139 Docket Hearings -- - 4- brakes caught on fire, terminating the test. This is above the destruction temperature for brake lining and, as such, they become quite unstable with unpredictable recovery characteristics. We know that brake drum 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 heavier-drums 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 to be less stable following extremely high temperatures. ' We propose this minimum value for recovery be reduced to 30 psi. We do not believe that a brake temporarily at this FMS1 00140 Docket Hearings 5 torque level is overly sensitive, particularly if used with anti-wheej. lock devices. While 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 this 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 t 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 easily and quickly, however there is no ' 4r 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 1 floor' 512 I- oc; "1 :n .3riction Wat*rials Standards institute, d)nc. 370 LEXINGTON AVENUE NEW YORK, N. Y. 10017 MUrray HiM 3-0572 October 20, 1970 firr/!c^^r b f.V. George Nield National Highway Safety Bureau Room ,"5234 400 Seventh Street, S. 17. Washington, D. C. ,,"20591 Subject: Docket 70-17 Air Brake Systems, Trucks and Buses Dear Mr. Nield: These comments are submitted as supplemental to those filed by the Friction feterials Standards Institute, Inc. on September 14, 1970. These comments apply also to Docket 70-16, Air Brake Systems on Trailers. 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. .Ve share and wholeheartedly support the objectives of the Bureau toward improving the stopping ability of vehicles equipped with air brake systems, '.'.'e 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 re quirements of the brake are detailed under the dynamometer test sections in both dockets, ,I70-l6 and ;v70-17, these comments will apply equally to both dockets. ' t- We have attempted insofar as possible in the short time available to run dynamo meter 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 materials used by vehicle manufacturers under the proposed procedure. We have also evaluated other 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, weight 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 generally linear. Therefore, to meet the upper limits of this curve means extremely sensitive brakes at lower applica tion pr^scMfoe. TJiia variation in retardation force versus brake chamber pressure FMSI 00143 fV. Georpe Nisid National Hirhway Safety Bureau ..ashington, D. C. 2- - October 20, 1970 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, and anchor pins, and to increase the 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 tests to evaluate current production brakes and friction materials and also demonstrate the effects of such changes as increased coefficient of friction, drum weight, various wheal loads and AL factors. We have attached plots on each of the dynamometer tests and identified these "A" thru "J". The test conditions such as brake size^type, AL factor, wheel load, drum weight and friction material have been detailed on each plot. The first discussion will deal with the retardation force or effectiveness. The second discussion will combine brake power (fade), hot stop and recovery as we consider these closely re lated. Effectiveness: -s ' It should be noted that all test3 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. However as pressure is increased the curve from the data falls far away from the acceptability line. We do not have sufficient data to determine if this relationship should be 1 inear or expressed in curve form. We feel there may be a variability in dynamometer calibration which should be fur ther 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 must be more definitive. Our tests to date indicate that no combination of linings 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. We 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 re cognized. Whan any one phase of brake performance is stressed it must be 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 temperature. . Fade: 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 Yr. George Yield National Highway Safety Bureau Washington, D. C. -3-- October 20, 1970 be accomplished but generally at the expense of recovery properties. ./hile 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 1,0C0F. See curves A, B & G. In another test of a lining that had passed, the brake .caught on fire when run with a lighter weight drum. See tests A L D. This is above the destruction temperature for brake lining and, as such, they become quite unstable with unpredictable recovery characteristics. vVe know that brake drum 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 re sistance tend to over-recover. See test B. Our tests indicate that very few materials are capable of meeting the fade requirements even with heavier drums 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 12y 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 v/e 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 liable following extremely high temperatures, i/e are not in a position to propose'minimum value until Fig. 3 has been properly adjusted. While v/e recognize a potential problem of controllability v/ith 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 summary, 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 dynamometer, t.'e also know there are a number of factors which, individual ly and collectively, will affect brake performance, l/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 accomplished in a minimum of two steps allowing 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 evaluate 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 rather than an improvement. Respectfully submitted, SSC/clt S. S. Conway President FMSI 00145 KCUFFCL ft C 9 *f * CO. TeSTT A FMSI 00146 C <E r 4 _l w$ FMSI 00147 10 X 10 TO THE INCH 3 S 9 -5 *4* FMSI 00148 r m u\O X lO KCUFf '. TO THE INCH 3 5 0 -5 co. ha&i . IO X io t o T H i; i j :l.h 3 i> 0 - FMSl 00149 rrrccT'v-rfVrss T(rM i f u tu f ri:L x J FMSI 00150 `i o * io t o i n r ;n h 3 5 0 - pMSI 00151 'O X 10 TO T rlL i'.- M 3 rjO - 4 e^T- '' FMSI 00152 FMSI 00153 5 C $ M ''N l O LO X m FMSI 00154 FMSI 00155 Rccn 51? i m friction V'Jrray H.'l 3-0572 ^alerials Standards institute, *3nc. 370 LEXINGTON AVENUE NEW YORK, N. Y. 10017 if/vfCtfl' -6` /jTT^C January 25, 1971 Docket Section, National Highway Safety Bureau Room 4223 400 Seventh St,, S, W. Washington, D, C, 20591 ' Subject* Docket 70-27, Hydraulic Brake Systems Gentlemen* s These "comments are submitted for your consideration, by the Friction Materials Standards Institute, Inc., whose members -Include most of the manufacturers of brake linings in the United States, Our comments are supplementary to those made at the October 3, 1969 hearing on the up-grading of FMVSS-105, which at that time pertained to passenger cars only (Docket 1-1), Testing Requirements and Facilities The two-stop fade requirement that is to be made at a speed approximately 5 A^PH under the top speed of the vehicle is a test essentially beyond the capacity of the^ brake lining manufacturers when it is applied to vehicles where the top speed ex ceeds 105 fPH, The brake lining manufacturers are aware of the need for high speed brake testing and capabilities, and have tested at speeds of 80 MPH, 90 MPH 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 vehicle speeds in excess of 105 MPH are possible. We question whether such specifications and requirements serv,e the interests of vehicle safety, no\ only for those doing the testing in industry and government, but for the general public where brake capabilities at speeds up to 140 A,PH 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? . Performance and Fade Orientation of Test The brake lining manufacturers feel that the high performance requirements may be met with existing equipment, but that these requirements are the high limit which can only be met with brake lining formulations aimed at passing this test only. This test is operate., at conditions in the destructive range for existing linings. For example, a sacrifice may be made which will promote rapid lining wear, contin uous degradation of friction, poor friction when cold, and brake stability problems. '* a' With linings formulated to pass this performance test of only a ,few hundred miles of vehicle operation, it is concei-vable that rapid wear to only 'l/l6" or 1/8" of the shoe may accelerate problems of brake system deterioration specifically noted in the docket when final inspection is made. While guarding the brake performance for the heavy-footed driver, the majority of the drivers will most likely pay in shorter brake lining life. Further, with existing brake linings geared for performance FMSI 00156 Docket Section, National Hiphway Safety Bureau Washington,~D. C. 20591 -2- January 25, 1971 there usually is. an increase in imbalance problems such as brake pull at deceler ations below the lock-up protection 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 Systems The requirements in Docket 70-27 imply that industry must have "Antilocking Systems" and "Brake Proportioning Systems", in not just trucks but in all vehicles covered by this docket. These systems present an entire new factor as regards the testing 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 vehicles, and heavy trucks, where design frequently use9 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*^/SS-105, we expressed concern about requirements beyond the existing state of the art in braking passenger cars. We noted 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 (Air, Brake Systecns) we enclosed test data to support our position on the difficulties inherent in requirements of those dockets. We wish to emphasize that the brake lining industry is just as concerned with the requirements of Docket 70-27 as with these earlier dockets, but we coujd not perform tests to evaluate these severe requirements, as the brake lining in dustry simply does not have the facilities on which these tests can be run. Respectively submitted. S S. Conway President FMSI 00157 kooafc,-512 ~1 : ' friction rll]ptcrias -_S4indnr^li ^9nilitute, S)nc. 370 LEX fNGtON AVEN't)$ NEW YORK, N. Y. 10017 W, ' - MUrray Hill 3-0572 -- u- Docket Section < National Highway Traffic Safety Administration Room 4223 . 400 Seventh Avenue, S, W. Washington, D. C. #20591 ' Ifcrch 26, 1971 ' ''.k/Sir'rAo-lMe^r " fK Subject: Federal Motor Vehicle Safety Standard #121 Gentlemen: : These comments are submitted for your consideration by the Friction Materials Standards Institute, Inc., whose members include most of the manufacturers of brake linings in the United States. These comments are to supplement those made earlier in our September 14, 1970 and October 20, 1970 responses to Dockets 70-16 and 70-17. ` The Institute's members had run various dynamometer and vehicle tests prior to the hearings on Dockets 70-16 and 70-17. While there have been changes incorpo rated 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 comment on the stopping distance requirement. - STOPPING DISTANCE REQUIREMENT FMVSS #121 , ` 20 MPH 33' '0 60 MPH 245' . 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 -l/2 x 7 "S Gams", on a single axle. The use of a "GG" 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 Standard 121, 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/sec^ deceleration is required for Standard 121 stopping distances, computed as above. (Note, the 40 MPH - 103 ft stopping distance is not linear with the 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 DECELERATION AND STOPPING DISTANCE SPEED MPH 20 25 30 35 40 45 50 55 60 FMVSS 121________ DGCEl , DISTANCE (FT/SEC2). (FT) 17.7 17.7 17.7 17.7 19.0 17.7 17.7 17.7 17.7 ' 33 49 68 90 108 143 174 208 245 . ' FMS1 RECOMMENDATION DECEL ,, DISTANCE (FT/SEC2) (FT) 17.7 17.4 17.2 16.9 16.6 16.4 16.1 15.8 15.6 33 50 70 93 120 151 187 228 274 Allowing for current state of the art, a yf> fall-off in deceleration rates should be expectea for each 10 MPH increase in speed. Allowing for this speed sensitivity, we believe the deceleration rate9 and stopping distances shown in the last two columns of this table are attainable. Without such an allowance, the speed sensitivity inherent in brakes and brake linings, is being ignored. , Summary . 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. Also, allowing for what we believe is an error in the 40 MPH - 108 ft require ment, we recommend that the stopping distance requirements be adjusted to allow for speed sensitivity, in line with the values shown by our tabulation. t Respectfully submitted. S. S. Conway President FMSI 00159 rS TT KO \nrrun T1TJ / fi'Yinn um^vriiin/nVvT t/O-i Exhibit "D" Page #1 NATIONAL TRAFFIC L IViOTOFt VEHICLE SAFETY ACT OF 1G5 Route AUTOMOTIVE SERVICE INDUSTRY ASSOCIATION 230 North Michigan Avenue. Chicago. Illinois G0601 (312) 236-8720 m iMusi/trs sail fun smci usocuhoh r n,'' H MANUFACTURER IDENTIFICATION `The National Highway Traffic Safety Administration has proposed a new sec tion, Part 566, to the Code of Federal. Regulations that would require motor vehicle manufacturers and motor vehicle equipment manufacturers to submit identifying information and a description of the items they produce for which a motor vehicle safety standard applies. The purpose of this part is to "facilitate the, regulation of manufacturers under the National Traffic and Motor Vehicle Safety Act, and to aid in estab lishing a code numbering system for all regulated manufacturers". Manufacturers would be. required to furnish basic information 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 submit data, views, and arguments concerning the proposed regulations by the close of business on.June, 28, 1971. Comments must refer to the docket number, No.71-11; Notice 1, and should be submitted to: Docket Section, National Highway 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- - j ^ * ^ - (over) HEAVY DUTY VEHICLE and EQUIPMENT-PARTS DISTRIBUTOR DIVISION This bulletin is for the exclusive use of members of Automotive Service Industry Association. It is not to be reproduced, sold, distributed or otherwise released to anyone without tho express written permission of A.S.I.A. FMSI 00160  Annual Meeting Minutes National Highway Traffic Safety Administration [ 49 CFR Port 566 1 l Docket No. 71-11; Notice 1] MANUFACTURER IDENTIFICATION Notice of Proposed Rule Making Tills notice projjoscs to adopt a new Part 566 in Title 49, Code of Federal Regulations, that would rc-qlitre manu facturers of motor vehicles, and of motor vehicle equipment- to which a motor ve hicle safety standard applies, to submit idcntifyiWT information and a descrip tion of the items they produce. Section 112(c) of the National Traffic and Motor Vehicle Safety Act requires manufacturers of motor vehicles and motor vehicle equipment to "provide such information as the Secretary may reasonably require to enable him to de termine whether such manufacturer has acted or Is acting in compliance with this title and motor vehicle safety standards prescribed pursuant to this title, Section 119 further grants the Secretary general authority to "issue, amend, and revoke sucii rules and regulations ns he deems necessary to cany out this title." In oixlor to carry out the provisions of the Act, it^is often necessary to have certain basic information about the man ufacturers of motor vehicles or vehicle equipment subject to the Act. T his is par ticularly so in the area of enforcement and in carrying out the several require ments for communication, inspection, and reporting. It is necessary to have ccni rally organized and collected infor mation regarding the manufacturer's corporate status, mailing address, items manufactured, and manufacturing loca tion. Moreover, it is necessary to assem ble this information so as to make It readily accessible to those having en forcement responsibility under the Act, and provide c. means for identifying nncl classifying manufacturers according to the types of motor vehicles or equipment which they manufacture. A system is also needed whereby the NIITSA can provide information to manufacturers of various types of vehicles or equipment. For these reasons, the National High way Trade Safety Administration pro poses to establish a new Part 5C6 in Tide 49, Code of Federal Regulations, which would require manufacturers to report specified information to the Administra tor within 90 days of the effective date of the proposed regulations. The regulation applies to all nianuiacturers of motor vehicles and of motor vehicle equipment to which a motor veliicle safety standard applies, and utilizes the definitions of "intermediate" and "final stage" manu facturer set out in 49 CFR Part 508 (3G F.R. 7054'. Ttie information required includes basic information on the manu facturer's corporate and business status and residence, the items produced, and Information on production capacity. Proixvsed effective date: 90 days after issuance. Interested persons arc Invited to submit data, views, and arguments concerning the proposed regulations. Comments should refer to the docket number and be submitted to: Docket Section. National Highway Tiaffic Safety Administration, Room 5217, 400 Seventh Street SW., Washington, DC 20591. It is requested, but not required, tiiat 10 copies be submitted. All comments re ceived before the close of business June 28, 1971 will be considered, and will be available in the docket at the above address for examination both before and after the closing date. To the extent pos sible, comments filed after the above date will also bo considered by the Ad ministration. However, the rulemaking action may proceed at any time after that date, and comments received after the closing date and too late for consid eration in regard to the action will be treated as suggestions for future rule making. Tire Administration will con tinue to file relevant material, as it becomes available, in the docket after the closing date, and it is recommended ttiat interested pcrsons continue to ex amine the docket lor new materials. This notice of proposed rulemaking is issued under the authority of sections 112 and 119 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1401 and 1407', and the delegations of authority at 49 CFR 1.51 and 49 CFR 501.8. Issued on April 10, 1971. noaox.ro A. Diaz. Acting Associate Administrator, Motor Vehicle Programs. PART 566--MANUFACTURER IDENTIFICATION 566.1 Scope. Tliis part requires manufacturers of motor vehicles, and of motor vehicle equipment to. which a motor vehicle safety standard applies, to submit Iden tifying information and a description of the items they produce. 566.2 Purpose. The purpose of this part Is to facili tate the regulation of manufacturers under the National Traffic and Motor Vehicle Safety-Act, and to aid in cstabllsliing a code numbering system for all regulated manufacturers. 566.3 Application. Tliis part applies to all manufacturers of motor vehicles, and to manufacturers of motor vehicle equipment to which a motor veliicle safety standard applies (hereafter referred to as "covered equip ment"). 566.1 Definition*. AH terms defined in the Act and the rules and standards issued under its authority are used as defined therein. Specifically "intermediate manufac turer" and "final-stage manufacturer" arc used as defined in Part 568, Vehicles Manufactured in Two or More Stages. Exhibit "D" Page =?2 566.5 lie qnirrnicnls. Each manufacturer of motor vehicles, and eacli manufacturer of covered equipment, shell furnish the information specified in paragraphs (a) through (d> of this section to: Administrator, Na tional Highway Traffic Safety Adminis tration, 400 Seventh Street SW., Wash ington, DC 20591. (a) Full individual, partnership, or corporate name of the manufacturer. (b) Residence address of the manu facturer and State of incorporation if applicable. (c) Description of each tyi>e of motor veliicle or of covered equipment manu factured by tlie manufacturer, including, for motor vehicles, the approximate ranges of gross veliicle weight ratings for each type. Except as noted below, the description may be of general types, such as "passenger cars" or "brake fluid." In the case of multipurpose passenger ve hicles, trucks, and trailers, the descrip tion shall be sixxific enough also to indi cate the types of use for which vehicles aro intended, such as "tank trailer," "motor home," or "cargo van." In the case of motor vehicles produced in two or more stages, if the manufacturer is an intermediate manufacturer or-a finalstage manufacturer, the description shall so state and include a brief description of the work performed. Example: "Multipurpose passenger ve hicles: Motor homes wit.li OVWH from 8.000 to 12,000 pounds. Final-stage manufacturer^ odd body to bare chassis." (d) Estimated annual production of each type vehicle or covered equipment listed in rcsixmsc to paragraph (c) of this section. 56$.6 Time of suliniiltal of iufurni.x- , lion* Each manufacturer required to submit information under 5 5GC.4 shall submit the information not later than_______ _ ------- After that date, each person who begins to manufacture a type of motor vehicle or covered equipment for v/liich he has riot submitted the required in formation shall submit the information specified in paragraphs (a) through (d) of { 5GG.4 not later than 30 daysTifter he begins manufacture. |Fit Doc.71-5378 Filed 4-27-71:8:48 ami fEDERAL REGISTER, VOl. 36, NO. 82--WEDNESDAY, AFKIl 28, 1971 FMSI 00161