Interpretation ID: nht79-3.28
DATE: 04/27/79
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: B. F. Goodrich Company
TITLE: FMVSS INTERPRETATION
TEXT: This responds to a January 15, 1979, request from Mr. A. J. Burt to permit adjustment of foundation brakes during the burnish procedures in S6.1.8 and S6.2.6 of Standard No. 121, Air Brake Systems, for any reason. At present, such adjustments can only be made to control brake temperature, as stated in our January 24, 1979, letter to Mr. Burt.
The National Highway Traffic Safety Administration is unaware of a reason other than control of brake temperature which would justify adjustments during burnish. Accordingly, we decline to grant your request. The NHTSA would, of course, be willing to consider any data or other information you have which would indicate that the present interpretation of burnish procedures may be too narrow in this respect.
SINCERELY,
BFGoodrich Engineered Systems Division
January 15, 1979
Department of Transportation 400 7th Street S.W.
Attention: Tad Herlihy
Dear Mr. Herlihy:
This letter is to confirm our telephone conversation of January 10th regarding our November 8, 1978 letter from Mr. D. L. Haines to the Chief Cousel, requesting clarification of certain sections of Paragraphs S5.3, S5.4, S6.1.8, and S6.2.6 of FMVSS-121 as pertain to brake adjustment during brake burnish.
On November 28, 1978, in answer to my telephone request for a quick response, Mr. Haines was sent a copy of FR Doc. 74-26461 filed 11/7/74. That document states that "brake adjustment can be made during the burnish to control brake temperature".
As discussed in our January 10th conversation, BFGoodrich is asking that an additional written response be made to our letter which requests, for the reasons stated in that letter, concurrence with the more general conclusion "that adjustment during burnish prior to road or dynamometer testing is acceptable".
Please address the response to Mr. D. L. Haines.
A. J. Burt Manager Highway Products Support Engineering
CC: D. L. HAINES