U.S. CONSUMER PRODUCT SAFETY COMMISSION

4330 EAST WEST HIGHWAY

BETHESDA, MD 20814

Caroleene Paul Tel: 301-987-2225

Mechanical Engineer Fax: 301-869-0294

Division of Mechanical Engineering Email: cpaul@cpsc.gov

Directorate for Engineering Sciences

CPSC Hotline: 1-800-638-CPSC (2772) CPSC's Web Site: http://www.cpsc.gov

April 6, 2015

Mr. Erik Pritchard

General Counsel

Recreational Off-Highway Vehicle Association

2 Jenner Street, Suite 150

Irvine, CA 92618-3806

Mr. Greg Knott

Vice President, Regulatory Affairs

Outdoor Power Equipment Institute

341 South Patrick Street

Alexandria, VA 22314

Dear Mr. Pritchard and Mr. Knott:

On October 23, 2014, engineers from member companies of the Recreational OffHighway Vehicle Association (“ROHVA”) and the Outdoor Power Equipment Institute 

(“OPEI”) participated in a public meeting with U.S. Consumer Product Safety Commission 

(“CPSC” or “Commission”) staff to discuss the technical aspects of staff’s recommended 

requirements for ROV safety, as published in a briefing package submitted on September 24, 

2014. 1 On November 19, 2014, the Commission published a notice of proposed rulemaking 

(NPR), with requirements that address ROV stability, vehicle handling, and occupant protection. 

Consistent with the regular participation of agency staff in the voluntary standards process, staff 

has been urged to work with ROHVA and OPEI to address ROV safety through the voluntary 

standards process.

On March 10, 2015, CPSC staff participated in an open meeting with representatives of 

Polaris Industries Inc. Engineers from Polaris presented interesting information highlighting the 

potential use of yaw rate measurements as a possible alternative means to address dynamic 

instability, which many parties present at the October 23, 2014 meeting agreed was an 

undesirable handling characteristic.

 1 The comments in this letter are those of the CPSC staff and have not been reviewed or approved by, and may not 

necessarily reflect the views of, the Commission.
Given the new information provided by Polaris at the March 10, 2015 meeting, staff 

encourages the ANSI/ROHVA and ANSI/OPEI voluntary standards committees to open their 

respective voluntary standards for revision to discuss improvements to the performance 

requirements in the voluntary standards to reduce deaths and injuries associated with ROVs. 

Staff recognizes that the Polaris method of measuring and evaluating dynamic stability is still in 

development and that additional testing and analysis is being conducted by Polaris. Based on the 

information provided by Polaris, staff believes that the approach to addressing the hazard of 

instability in handling through a limit on yaw rate, as discussed at the March 10, 2015 public 

meeting, would greatly benefit from additional input from stakeholders, including industry 

members of ROHVA and OPEI. Staff believes that opening your respective voluntary standards 

would be the best way to bring together all stakeholders in an informative and productive way to 

evaluate the most recent efforts to prevent instability in handling and to improve occupant 

protection and lateral stability.

There appeared to be broad agreement that the October 23, 2014 public meeting that 

involved technical discussions between CPSC staff engineers and ROV manufacturers’ engineers 

was productive. Therefore, staff strongly encourages you to include in-person technical public 

meetings as part of your respective voluntary standards revision process because staff believes 

that would be the most productive way to facilitate discussions on the technical issues associated 

with ROVs. 

CPSC staff remains committed to working with ROHVA and OPEI to develop effective 

revised voluntary standards that will reduce the deaths and injuries associated with ROVs. If you 

have any questions or comments, please feel free to contact me.

Sincerely,

cc: Colin Church, CPSC Voluntary Standards Coordinator