Interpretation ID: nht93-4.2

DATE: May 18, 1993

FROM: Richard Muraski -- President/CEO, Equa-Brake

TO: John Womack -- Acting Chief General Counsel, NHTSA

COPYEE: Armando Mena

TITLE: None

ATTACHMT: Attached to letter dated 8/5/93 from John Womack (signature by Kenneth N. Weinstein) to Richard Muraski (A41; Std. 121)

TEXT:

On July 2, 1992, the National Highway Traffic Safety Administration (NHTSA) denied a Petition of Rulemaking on an Air Brake System product presented by the Washington Corporation. The petition would have amended FMVSS Standard No. 121 to require a device that regulates air pressure differential between the two wheels on each axle. This ruling could impact our product, the Equa-Brake System which operates on a similar principal yet different design.

Equa-Brake is enclosing a packet on our product and would like an interpretation of this NHTSA action on it.

This interpretation is vital to our efforts. Equa-Brake understands that this denial of rulemaking does not prohibit Equa-Brake from installing its product on vehicles through manufacturers dealer or repair businesses provided it does not render the brake system to fall out of compliance with Standard 121. If you have any questions, please contact me at 702-329-7072 or Armando Mena at 703-938-5117. Thank you.

Attachment

EQUA-BRAKE is a MECHANICAL "auxiliary brake system" that increases brake force and improves brake performance on all vehicles that are equipped with air brakes.

Direct benefits of the Equa-Brake "auxiliary brake system" include safer, straighter, shorter (up to 30% shorter) stopping under panic braking situations.

Reduced one wheel lock-up coupled with significantly reduced brake drum temperatures (reduced brake fade) allows drivers to maintain control under emergency stopping conditions, virtually eliminating potential jack-knife problems.

Under normal braking - the increased brake force permits drivers to maintain their habitual braking patterns with substantially less application pressure. This reduces brake wear and also reduces the tendency for trailer wheels to lock-up - loaded or unloaded.

Tire life is extended from 10% to 20% or more by reducing flat spots caused by one wheel lock-up.

Additional direct benefits result in lower operating costs by extending brake component life up to 40% or more (some users claim extended brake life significantly exceeding 40%).

Indirect benefits derive from increased driver confidence in the vehicle being driven, along with potential insurance savings that result from a safer vehicle that could avoid costly accidents.

Unlike drive line retarders that have proven to be dangerous when activated on wet road surfaces - especially in turns or cornering the driver is always in control of any vehicle equipped with the Equa-Brake "auxiliary brake system".

The Equa-Brake "auxiliary brake system" is totally mechanical, does not use any type of electronics, does not require maintenance and is warranteed for five (5) years.

It is absolutely fail safe. In the unlikely event any component of the Equa-Brake "auxiliary brake system" should fail, the vehicle brake system will return to factory specifications.

Current users include fleets, concrete mixer trucks, fleets of trailers only and fire departments.

Users report improved brake performance, extended brake component life and increased driver confidence in the ability to control their vehicle during the braking sequence.