Interpretation ID: nht76-4.14

DATE: 07/23/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to White Motor Corporation's April 26, 1976, question whether S5.3.3 and S5.3.4 of Standard No. 121, Air Brake Systems, require minimum brake chamber air pressures of 60 psi and 95 psi, respectively, or whether these air pressures are included in the sections only as "bench marks" on which to base specifications for minimum actuation and release timing in brake systems. Section S5.3.3 specifies in part:

. . . With an initial service reservoir system air pressure of 100 psi, the air pressure in each brake chamber shall, when measured from the first movement of the service brake control, reach 60 psi in not more than 0.45 seconds. . . .

Your understanding that S5.3.3 and S5.3.4 only specify the air pressures of 60 psi and 95 psi as the basis for timing requirements is correct. Neither value is intended as a requirement that the vehicle be designed to provide a certain level of brake chamber air pressure. The values were based on an understanding of the typical configuration of existing air brake systems at the time the final rule was issued.

In response to your request for interpretation of these sections in view of White's intent to use a lower air pressure than was commonly used in the past, the agency will utilize the stated 60-psi value or a value that is 70 percent of the maximum air pressure (measured by the NHTSA at the brake chamber), whichever is lower. In the case of release, the stated 95-psi value or the value that represents maximum air pressure (measured by the NHTSA at the brake chamber), whichever is lower, will be used. For purposes of this determination, the maximum air pressure in the brake chamber is that obtainable with full brake application when the pressure in the service reservoir is at 100 psi. Use of the maximum air pressure application timing would be unreasonable because of the decreased rate of air pressure build-up that occurs as the brake chambers reach maximum pressure.

The agency will issue an interpretive amendment to S5.3.3 and S5.3.4 to reflect this interpretation.