Interpretation ID: nht91-5.11

DATE: July 31, 1991

FROM: Wayne Trueman -- Plant Manager, BX-100

TO: Barry Felrice -- Associate Administrator of Rulemaking, U.S. D.O.T.

TITLE: None

ATTACHMT: Attached to letter from Paul Jackson Rice to Wayne Trueman (A38; Std. 121); Attached to letter dated 9-24-91 from Wayne Trueman to Marvin Shaw

TEXT:

Once again please allow me to take this opportunity to thank you and your staff for the prompt response you gave to my previous inquiries to your office.

Currently, our BX-100 Brake Equalizers are being specified by numerous customers for installation on their new equipment (tractor and trailer) orders at the factory. There have been several inquiries by school districts from several states in reference to having these units retrofitted onto their current stock of school buses or included into the specification for their new bus orders. However, current California law requires that written approval be obtained from the chassis manufacturer prior to making any "Brake System Modifications ". (ref. California Highway Patrol Title 13, Section #1246c. - copy attached).

What we are trying to determine now is: 1. Whether or not a similar written authorization requirement exists for some or all other states in reference to school buses.

2. Are there any special regulations pertaining to school buses that need to be considered prior to installing or retrofitting product into their air brake systems.

Or are the remaining states simply subject to compliance with current FMVSS 121 regulations?

The effectiveness of the BX-100 Brake Equalizer has been documented by independent test labs, customer conducted tests and testing done with a "Minnetonka Warehouse" VC200 de-accelerotometer. I am enclosing a copy of the tests done at Nevada Automotive Test Center, and two "G" Force graphs done from the information obtained with the deaccelerometer. These and other tests have been done on a variety of air brake equipped vehicles both before and after installation of the BX-100 Brake Equalizers. The results consistently indicate shorter stopping distance with less application pressure, and increased driver control which allows the vehicle to stop in a straight line.

Once again, I would like to thank you in advance for your assistance on this matter. If we are successful in penetrating this market, the test and actual end user results, indicate that we will be instrumental in avoiding accidents and saving many lives.

Attachment A

California Highway Patrol Title 13 Section 1246C School Bus Brakes (text omitted)

Attachment B

Nevada Automotive Test Center Final Report for BX-100 International, Inc.

Brake Test Evaluations for the BX-100 Brake Equalizer Authorization: Purchase Order No: Verbal NATC Project No: 20-17-404 October 1989 Prepared by: Gene Smith Test Engineer

Nevada Automotive Test Center P.O. Box 234, Carson City, Nevada 89702 Telephone No. (702) 882-3261

(Text and graphics omitted)