ROV Standards 

Presented to 

U.S. CPSC Chairman Elliot Kaye 

U.S. CPSC Commissioner Joe Mohorovic 

September 30, 2014 
2 

Agenda 

1. ANSI ROHVA 1-2014 – Approved on September 24, 2014 

2. History, Evolution and Status of ROV Standards Development in 

Collaboration with CPSC staff 

3. Preliminary Issues 

4. Next Steps 
3 

ANSI/ROHVA 1-2014 

(Approved by ANSI on 9/24/14) 

New Dynamic Stability and Handling Test/Requirement 

• 30 MPH dropped throttle J-Turn with 110 degree steering input 

• Pass = no TWL 

– 4 of 10 vehicles in CPSC/SEA legacy test fleet do not pass new test 

• More demanding for oversteer vehicles 

New Alternative Seat Belt Reminder Requirements 

• FMVSS 208-style audible + lighted alerts 

– Proposed by CPSC staff in Feb 2011 

• Driver speed-limiting (15 MPH) seat belt interlock 

– Over 60% of projected MY15 volume will include interlock 

Updates in Response to 8/29/13 CPSC Staff Letter – 

Not Evaluated in Briefing Package 
4 

Timeline: 2008-2011 

ROHVA Developed Two Iterations of Standards in Consultation with CPSC 

2009 2010 2011 

ANPR 

Issued 

Initial 

ROHVA 

Meeting 

With 

CPSC 

ANSI/ROHVA 

Draft 

Issued 

ANPR 

Comment 

Period 

Ended 

ANSI/ROHVA 

1-2010 

Approved 

ANSI/ROHVA 

Re-Opened 

ANSI/ROHVA 

1-2011 

Approved 

SEA 

Report 

Issued 
5 

Timeline: 2012-2014 

CPSC Staff Provided Specific Proposals; ROHVA Made Significant Changes in Third Iteration of Standards 

2012 2013 2014 

SEA 

Meeting 

SEA 

Repeatability 

Testing 

ROHVA Response to 

CPSC Staff Letter / 

ANSI/ROHVA Re-Opened / 

ROHVA Request for Meeting 

ROHVA 

Response 

ANSI/ROHVA 

1-2014 

Approved 

CPSC 

Staff 

Comments 

CPSC 

Staff 

Letter 

Briefing 

Package 

Issued 
6 

Evolution of ROV Standards 

Issue 

ANPR / CPSC 

Staff 

Comments 

ANSI/ROHVA 

1-2010 

ANSI/ROHVA 

1-2011 

8/13 CPSC 

Staff Letter 

ANSI/ROHVA 

1-2014 NPR 

Stability & 

Handling 

Static Stability Loaded SSF 

1.03-1.44 

Unloaded Kst 

1.00 

Unloaded Kst 

1.00 

N/A Unloaded Kst 

1.00 

N/A 

Dynamic 

Stability 

Unspecified JTurn - Ay at 

TWL (Feb 

2011) 

N/A RRR 30 mph J-Turn 

– push to limit; 

pass if TWL at 

0.70+g 

30 mph J-Turn 

– fixed input of 

110 deg.; pass 

if no TWL 

30 mph J-Turn 

– push to limit; 

pass if TWL at 

0.70+g 

Vehicle 

Handling 

Understeer 

Mandate 

N/A N/A Understeer 

Mandate 

Oversteer

subsumed in 

ROHVA J-Turn 

Understeer 

Mandate 

✔

✔
7 

Evolution of ROV Standards 

Issue 

ANPR / CPSC 

Staff 

Comments 

ANSI/ROHVA 

1-2010 

ANSI/ROHVA 

1-2011 

8/13 CPSC 

Staff Letter 

ANSI/ROHVA 

1-2014 NPR 

Side Retention 

Unspecified 

Performance 

Reqs. and 

Other Features 

N/A Zone 1 

(Constr.) 

N/A Zone 1 

(Construction) 

N/A 

Zone 2 (Perf. & 

Constr.) 

Zone 2 – 

modify Constr.; 

delete Perf. 

Zone 2 – modify 

Constr.; delete 

Perf. 

Zone 2 – 

modify 

Constr.; 

delete Perf. 

Zone 3 (Perf. & 

Constr.) 

Zone 3 – 

modify Constr.; 

delete Perf. 

Zone 3 – modify 

Constr.; maintain 

Perf.

N/A 

Zone 4 (Helmet 

+ ROPS) 

N/A Zone 4 (Helmet + 

ROPS) 

N/A 

✔

✔

✔

✔
8 

Evolution of ROV Standards 

Issue ANPR / CPSC 

Staff Comments 

ANSI/ROHVA 

1-2010 

ANSI/ROHVA 

1-2011 

8/13 CPSC 

Staff Letter 

ANSI/ROHVA 

1-2014 NPR 

Seat Belt 

Reminder 

Mandatory 

Lighted Restraint 

Warning (Dec 

2009) 

Optional 

Lighted 

Restraint 

Warning 

Mandatory 

Lighted 

Restraint 

Warning 

N/A Alt. FMVSS 208-

style Audible + 

Lighted Alerts 

N/A 

FMVSS 208-style 

Audible Alert (Mar 

2011) 

N/A N/A N/A Alt. FMVSS 208-

style Audible + 

Lighted Alerts 

N/A. 

Seat Belt 

Technology 

N/A N/A N/A Driver/Front 

Passenger 

Speed-Limiting 

Interlock 

Alt. Driver SpeedLimiting Interlock Driver/Front 

Passenger 

Speed-Limiting 

Interlock 

✔

✔

✔
NPR Briefing Package

• Addresses ANSI/ROHVA 1-2011 standard 

• Does not address ANSI/ROHVA 1-2014 voluntary standard, 

approved on September 24, 2014 

• 15 USC § 2058(b)(2) and (c)(3) (“For purposes of this section, a 

voluntary standard shall be considered to be in existence when 

it is finally approved by the organization or other person which 

developed such standard, irrespective of the effective date of 

the standard [(b)(2)].”) 

9 
Preliminary Issues 

DYNAMIC STABILITY AND HANDLING 

• “Although the Commission believes that the dynamic lateral 

stability and vehicle handling requirements will reduce the 

number of deaths and injuries involving ROVs, it is not possible 

to quantify this benefit because we do not have sufficient data to 

estimate the injury rates of models that already meet the 

requirements and models that do not meet the requirements.” 

• “Thus, we cannot estimate the potential effectiveness of the 

dynamic lateral stability and vehicle handling requirements in 

preventing injuries.” NPR at 131 (emphasis added).* 

*Rhino comparison based on only two incidents which CPSC staff concedes are not representative. 

Briefing Package n.16. 10 
Preliminary Issues (cont.) 

• Does not account for J-turn Test in ANSI ROHVA 1-2014 

– NPR J Turn Test*: Vehicles A, B**, D, F, I , J do not pass 

– ANSI ROHVA 1-2014 J Turn Test: Vehicles A, D, F, J do not 

pass (based on SEA data) 

*The NPR and briefing materials contain numerous references to NHTSA and NHTSArelated test methods and testing that are taken out of context, incomplete, and also 

disregard NHTSA’s traditional practice of providing several years of lead time for 

vehicle redesigns. 

**Kst 1.0 static stability requirement in ANSI ROHVA 1-2014 not met (see App. A, Table 3) 

 11 
Preliminary Issues (cont.) 

• Even aside from our concerns about the (a) lack of repeatability/

reproducibility* and (b) use of limit condition as pass/fail criteria 

in NPR J Turn test, there is no data demonstrating that .70g is 

threshold for “unreasonable risk” – only theoretical benefits.** 

*Among other things, CPSC’s contractor disregarded multiple test runs in which two 

wheel lift did not occur at the specified steering input; only tested one vehicle per 

model on a single day at a single location on a single surface; did not account for 

variations in ambient temperatures; etc. 

**This includes the difference between the .70 threshold and the .68 measurement for 

Vehicle I, which is the only vehicle that passes ANSI ROHVA 1-2014 but fails the NPR 

threshold. 

12 
Preliminary Issues (cont.) 

• Proposed Hang Tag 

– NHTSA NCAP – correlated extensive accident rate data to 

rollover risk for SSF rating purposes only (not pass/fail) 

– No ROV specific accident data/correlation for CPSC 

proposed rule 

• No data for .70g being a “minimally acceptable” criterion 

for “rollover resistance” – staff lacks “sufficient data to 

estimate the injury rates” of models that do/do not meet 

this criterion (NPR at 131) 

• No data demonstrating .80 is “comparatively safer” than .

70 for “consumer information” purposes – especially for 

off-highway vehicles (15 USC 2051(b)(2)) 

13 
Preliminary Issues (cont.) 

• Occupant Protection (seatbelt) 

– ANSI ROHVA 1-2014 mandates seat belt reminder system to 

include either an FMVSS 208-style audible alert or a speedlimiting interlock for the driver 

• FMVSS 208-style alert was suggested by CPSC in 

development of ANSI ROHVA 1-2011 (CPSC Staff Letter, 

Mar. 10, 2011) 

– Federal law prohibits NHTSA from mandating interlocks, but 

ROHVA has included it as an option in response to CPSC’s 

suggestion 

14 
Preliminary Issues (cont.) 

• Majority of new unit sales (2015 MY) includes driver-side 

interlocks – industry generated benefit without regulatory 

mandate (but disregarded in NPR). 

• ROV manufacturers deploying driver-side interlocks have made 

reasonable determinations not to include passenger-side 

interlocks based on current technologies, vehicle uses, offhighway environment, and other factors – including “Captain of 

Ship” principle reflected in CPSC’s own data: 

“[T]here is some evidence that the use of seat belts by passengers is 

correlated with the seat belt use of the driver. In the incidents examined by 

the Commission, of the 121 right front passengers with known seat belt 

usage, the driver and right passenger had the same seat belt use status most 

of the time (about 82 percent).” NPR at 152 (emphasis added). 15 
Preliminary Issues (cont.) 

• Appropriate to permit industry to continue to innovate in this 

area. It is unnecessary and premature for regulatory mandate. 

• NPR indicates that CPSC itself is conducting additional 

“necessary” testing on consumer acceptance on interlock that 

will not be completed until December 2015. (Briefing Package at 

301) 

• No data indicating consumer acceptance of passenger side 

interlocks. 

16 
Preliminary Issues (cont.) 

• Occupant Protection (shoulder probe test/Zone 2) 

– CPSC Staff (Aug. 29, 2013) – recommended passive 

barrier/structure or single-hand, single-operation 

barrier/structure – no deflection > than 1 inch 

– ROHVA TAP – adopted CPSC Staff recommendation 

on single-hand, single-operation barrier/structure; 

reduced deflection from no > than 3” to no > than 2” 

– CPSC Staff (May 23, 2014) – no further staff 

comment on proposed revisions to ANSI ROHVA 

Zone 2 requirements 17 
Preliminary Issues (cont.) 

– ANSI ROHVA 1-2014 – includes passive barrier/

structure or single-hand, single-operation barrier/

structure no > 2 inches deflection outside vehicle 

– NPR – passive barrier/structure only – 1 inch 

deflection 

18 
Next Steps 

• ROHVA remains open to collaboration on robust 

voluntary standards, as our history demonstrates 

• CPSC should not issue NPR because the briefing 

package does not evaluate new ANSI ROHVA 1-2014 

standard 

• CPSC should focus on initiatives that will have a 

demonstrable, direct safety impact based on objective 

data 

• CPSC and ROHVA should work collaboratively within 

the context of the voluntary standards and avoid 

protracted and costly disputes 19