U.S. CONSUMER PRODUC T SAFETY COMMISSION
4330 EAST WEST HIGHW AY 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

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- 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, 201 4, engineers from member companies of the Recreational Off

Highway 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” ) staf f 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 a n 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 pre sent 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 measuri ng and evaluating dynamic stability is still in development and that additional testing and analysis i s being conducted by Polaris. B ased 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 p revent instability in handling and to improv e occupant protection and lateral s tability

.

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

- pe rson 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 co mmitted to working with ROHVA and OPEI to develop effective revised voluntary standard s 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