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 19th 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 19th meeting. The focus of

our July 19th 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 lift
that 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