Interpretation ID: nht90-2.90

TYPE: INTERPRETATION-NHTSA

DATE: 06/18/90

FROM: PAUL JACKSON RICE -- NHTSA CHIEF COUNSEL

TO: DOUGLAS MAYES -- PRESIDENT CREATIVE PRODUCTS, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 10/17/89 FROM DOUGLAS MAYES -- CREATIVE PRODUCTS TO NHTSA; RE BRAKING DISTANCE TEST AND LABORATORIES USED BY DOT; OCC 4087

TEXT: This responds to your letter asking questions in relation to your product called "gyroscopic wheel covers." We apologize for the delay in our response.

According to your letter and accompanying information, you claim that use of "gyroscopic wheel covers" can reduce stopping distance. You stated that Dr. Carl Clark of this agency suggested that you request this office to provide a letter specifically ou tlining the requirements of the agency's braking test, and a list of the various testing facilities used by the agency when testing a product for this purpose. You then asked for a letter stating the "stopping distance test guidelines" of Safety Standar d No. 105, Hydraulic Brake Systems," and a list of laboratories acceptable to DOT that could be used to test your product. You also asked whether an SAE standard is a proper example of a stopping distance test. You stated that it is your intention to us e these testing standards and one of the acceptable laboratories so as to properly document your product's test results in compliance with the DOT testing standards.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of th e manufacturer to ensure that its products meet applicable standards.

Safety Standard No. 105, Hydraulic Brake Systems, applies to passenger cars and other motor vehicles. The standard specifies, among other things, a number of stopping distance tests that each motor vehicle must meet. I have enclosed a copy of the stand ard for your information.

I note that Standard No. 105 was not designed for the purpose of evaluating whether a product such as yours can improve stopping distance. We are unable to offer an opinion as to the appropriateness of using Standard No. 105's stopping distance tests fo r that purpose, or how such a test program would best be carried out.

This agency does not provide recommendations or endorsements for particular testing laboratories. I have, however, enclosed a list of the independent laboratories conducting compliance tests for NHTSA's Office of Vehicle Safety Compliance during the cur rent fiscal year.

I have also enclosed a copy of an information sheet we have prepared which provides information for new manufacturers of motor vehicles and motor vehicle equipment.

I hope this information is helpful.

[NHTSA STANDARD NO 105 HYDRAULIC BRAKE SYSTEMS; 49 CFR CHAPTER V; DATED 10/01/89 OMITTED]