Interpretation ID: nht93-6.44

DATE: September 23, 1993

FROM: Barry H. Wells -- M.D., Drs. Herzinger, Biles, Zagula & Wells, P.A.

TO: Marvin Shaw -- Atty., NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 11/30/93 from John Womack to Barry H. Wells (A41; Std. 121)

TEXT:

Thank you for the information regarding the upcoming NHTSA publication on the problem of jackknifing in tractor-trailers. I look forward to reading the document. As I mentioned, I would welcome the opportunity to either testify or to go on public record in writing as to the existence of a safety device for tractor-trailers that has been tested and proven to eliminate jackknifing and to stop fully-loaded trucks in distances comparable to those of an automobile.

I have enclosed a promotional videotape featuring the brake. As you can see, it has been tested under a variety of driving conditions and with maneuvers that should precipitate a jackknifing of the test vehicle- maneuvers which also anticipate the agency's goal of establishing performance requirements for a braking-in-a-curve test, as well as a lane- change test. These test were all supervised by Dr. Everett C. Carter of the University of Maryland Transportation Studies Department.

In reading the Advance Notice of Proposed Rulemaking (Federal Register, Vol. 57, No. 110) that you recommended, I was encouraged to discover that NHTSA is "undertaking a comprehensive effort to improve the braking performance of heavy vehicles." It is apparent from my review of the material I requested from the Federal Highway Administration (Accidents Reported by Motor Carriers of Property, 1990, publication no. FHWA/MC-93/011), that the highways are becoming increasingly unsafe as automobiles share the road with more heavy trucks which differ dramatically in their stopping characteristics, especially in inclement conditions. This report cites a 37% increase in the number of accidents in 1990 over the 1986 totals, a 26% increase in the number of fatalities for the same period, and $507 million worth of property damages for 1990. A recent spate of fatal tractor-trailer accidents on the Capitol Beltway has drawn local attention to the problem, and calls have been made for more vigorous safety inspections. However, even doubling the number of inspection teams could not truly make the roads safe, as even under the best road conditions and with properly operating equipment, the fact remains that tractor- trailers require stopping distances that they cannot maintain on the crowded highways, and under inclement weather conditions, they are extremely difficult to stop quickly in a controlled fashion.

Further on in the same ANPRM, it is stated that "...interested persons are requested to provide any relevant factual information on the anticipated safety benefits...of improv(ing) the lateral stability and control performance during braking of heavy trucks," as well as "the type of equipment needed to comply with the new requirements." This relatively simple safety device, which is easy to retrofit on existing equipment or to assemble on original equipment, seems to address directly the problems of lateral stability and increased stopping distances of tractor-

trailers and should save lives if in widespread use.

While I recognize that the agency cannot specifically promote the use of a particular manufacturer's product, it would seem that, from what I have seen of the complexity and cost of the antilock braking systems as well as their performance, the agency would at least be interested in testing the E.B.T. system as extensively as it has the ABS.

Again, I thank you for directing me in obtaining the rulemaking documents, and I look forward to the upcoming NHTSA publication and any opportunity to comment in the Public Docket. If you can offer any further direction, please let me know. I have been told by a friend, who is an aide to Rep. Dan Hamburg of California, that I should inquire as to an opportunity to testify before the House Committee on Public Words and Transportation, or the Subcommittee on Surface Transportation. Any guidance such as this is greatly appreciated.