Interpretation ID: nht92-8.41

DATE: February 28, 1992

FROM: Bill Gaines -- Engineer, Transfer Flow, Incorporated

TO: Wally Herger -- Congressman

TITLE: None

ATTACHMT: Attached to letter dated 4/27/92 from Frederick H. Grubbe to Wally Herger (A39; Std. 301); Also attached to letter dated 3/13/92 from Wally Herger to Nancy Bruce

TEXT:

The reason I am asking to speak with you on Saturday, February 29, 1992, involves my company's inability to meet Federal Motor Vehicle Safety Standard No. 301-75 as the manufacturer. This standard has to do with required testing involving the vehicle's fuel system integrity. It is required testing if the vehicle in question has not been sold to the end user.

While we have no problem with the intent of this standard, we are very concerned with the inflexibility of testing and the high cost of performing these test.

We have been quoted $30,000.00 to perform one FMVSS 301 test. Of course, if it doesn't pass then we are required to redesign the fuel system, crash another vehicle and spend another $30,000.00.

If we were selling hundreds of thousands of the same tank, $30,000.00 would be inconsequential. However, if we only sell 50 of these tanks a year then the cost is ridiculous. If we make 600 different kinds of tanks a year, 30 of one style and 100 of another, like we do, then the cost for testing is unthinkable.

A completely different and less stringent structural test is required for vehicles over 10000 GVW and for vehicles under 10000 GVW that have been sold to the end user. We at Transfer Flow, perform these test as required. While they are not as expensive as the crash test, they do effectively demonstrate the structural integrity of the fuel tank and the components attached to it.

We have been in the fuel systems business for over nine years. In that time frame, we have designed over 600 different fuel systems for pick-ups, vans, motor homes, travel trailers and industrial equipment. We have written emissions certifications for companies such as Fleetwood, Oshkosh Truck, Gillig, Bluebird and many others. The California Air Resources Board refers other tank manufacturers to us, to help them submit emissions applications.

We want to provide our customers with safe fuel systems, but we must be given some flexibility in the testing requirements. As a small volume manufacture, we can't afford to perform the FMVSS 301-75 test. We need an alternative.

Again, we are not opposed to testing our product. There are many ways to demonstrate that a product meets the required specifications. Drop testing, vibration testing and finite analysis are just a few methods that can accomplish this task. The engineering analysis that we are capable of doing today was not even taught in the early seventies.

Since we have been unable on our own to alter this requirement for companies such as ourselves, we are asking for your assistance. Please give us a hand.