From: Paul, Caroleene
To: Stevenson, Todd ; OS - Office of the Secretary Subject: Please add information to public documents for ROVs
Date: Monday, July 16, 2012 11:41:00 AM

Hi Todd,

Because we are in the rulemaking process for ROVs, please add the CPSC response to questions to ROHVA on an upcoming public meeting in regulations.gov under Supporting Materials (CPSC-2009- 0087) so we can review the reponses in the context of late submissions to the ANPR.

Thanks very much,

Caroleene Paul Mechanical Engineer US Consumer Product Safety Commission 5 Research Place Rockville, MD 20850 301-987-2225

From: Paul, Caroleene Sent: Tuesday, July 03, 2012 3:01 PM To: 'Paul Vitrano' Cc: Teems, Anthony; Kumagai, Mark; Little, Barbara Subject: July 19th public meeting and CPSC staff response to ROHVA's questions

Dear Paul,

Thank you for the questions you submitted on May 11, 2012 concerning CPSC staff’s

evaluation of ROVs and the NPR. The focus of our July 19 th meeting is to share CPSC staff data and provide your members an opportunity to discuss the test methods and results performed by our contractor, SEA. The scope of this meeting is to understand the testing performed by CPSC’s contractor and to understand the subsequent duplicate testing performed by ROHVA. We hope to resolve any inconsistencies between CPSC staff’s and
ROHVA’s data.

Many of the questions you have asked go beyond the scope of asking for clarification of or questions regarding the SEA report and will not be discussed in this meeting. We cannot respond to those questions (Questions #1, 2, 3, 7, and 8) that go beyond the scope of the upcoming meeting, but we will submit the questions as part of the ROV rulemaking record and they will be addressed in the context of the rulemaking as CPSC staff continues to develop its NPR briefing package.

The CPSC staff can answer the following questions about the SEA data:Question #4

. A review of the dropped throttle J-turn testing for which results are presented in Appendix E of both the April and August 2011 SEA Reports indicates that data from several tests may not have been included in the original Reports. In addition to the runs numbered 116 and 117, 1128 and 1129, and 1326 and 1328, were there any other tests performed where a vehicle (or vehicles) in the operator and passenger loading configuration showed an Ay variability of 0.03 g or greater between runs when
tested in the same direction? If so, please list the machine(s) by identifying letter and provide the test results for all such runs.

CPSC staff response : In Section 4.5 of the April 2011 report SEA states: "...the blue lines are the tests with the minimum steering that resulted in tip-up and the red lines are the tests with the maximum steering that did not result in tip-up." There are no tests with intermediate steering or severity between these two. These blue and red lines are shown for all vehicles in both the right and left steer directions.

Question #5

. ROHVA understands that all materials/data received from CPSC thus far have been generated on a dry pavement and/or concrete surface. Has the CPSC or any other contractors performed any testing of ROVs on surfaces other than pavement or
concrete? Specifically, have any tests been performed instrumented or otherwise, in the types of environments in which ROVs are intended to be utilized? If so, please provide data/graphs/findings from this testing.

CPSC staff response : CPSC staff have performed tests on a groomed dirt track but the data and findings will not be made public in time for the July 19 th meeting. The focus of our July 19 th meeting is to share CPSC staff data with ROV and examine why there may be, as ROHVA suggests, inconsistencies with ROHVA’s data. We will submit your questions as part of the ROV rulemaking record, and they will be addressed in the context of the rulemaking as CPSC staff continues to develop its NPR briefing package.

Question #6

. From page 12 of the SEA report, ROHVA understands that “...tip-up events are considered those that produced significant two-wheel lift and in almost all cases outrigger contact.” Please identify the number of drop throttle J-Turn tests performed by SEA where 2-wheel lift was observed without outrigger contact. Please provide this data, by machine, for both loading conditions tested. If the precise number of runs cannot be provided, please provide an approximate anecdotal answer rounding to the
nearest 10%.

CPSC staff response : The statement “For this testing, tip-up events are considered those that produced significant two-wheel lift and in almost all cases outrigger contact,” is describing that the lateral threshold testing of these vehicles resulted in two-wheel liftthat would have continued into a 90 degree rollover if the outrigger did not prevent the rollover event from occurring. Therefore, to determine the minimum lateral acceleration required to induce rollover, the tests were repeated at smaller and smaller steer angles until the vehicle exhibited just enough two-wheel lift to measure that minimum lateral acceleration but not enough to make outrigger contact (and thereby incorrectly measure the lateral acceleration caused by outrigger impact with the ground). 100% of the J-Turn
tests that measured the minimum lateral acceleration of the vehicle at rollover threshold
exhibited 2-wheel lift without outrigger contact since by definition that was how the
value was measured.

Please contact me if you have any questions or would like to further discuss the scope of this meeting. We look forward to a productive meeting.

Sincerely,

Caroleene Paul Mechanical Engineer US Consumer Product Safety Commission 5 Research Place Rockville, MD 20850 301-987-2225