Interpretation ID: nht92-9.24

DATE: February 5, 1992

FROM: Robert Salton -- Engineer, Performance Friction Corp.

TO: Office of Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/14/92 from Paul J. Rice to Robert Salton (A39; Std. 105)

TEXT:

On the recommendation of your staff, I am requesting an interpretation of a regulation contained in the FMVSS-105 Safety Standard.

The sections in question are:

1. S.5.1.4.1 (Regulations) 2. S.7.11.1.1 (Procedures)

We are unclear about the pedal force requirements during the first fade/recovery test - baseline check stops.

The interpretation will make clear to us exactly what calculation of pedal effort is used to verify compliance during the Fade and Recovery Check Stops. Also, what values of pedal effort would be considered non-compliance (i.e., peak, average, sustained) greater than 10 lbs or less than 0 lbs.

I have spoken with Zack Frazier of your staff and he is familiar with our questions. I regret that no data or vehicle instrumentation traces are available to me at this time.

Please call me if you have any questions. My need is urgent so as to continue brake system development and testing.