circumstances--primarily 1) because of the quantity of the new products being introduced within a short time frame, 2) because of the need for greater education with respect to the use of Standard 121-equipped vehicles, and 3) because of the understandable concern on the part of the trucking industry about the cost of safety equipment which is immediately apparent weighed against the benefits which will take some time to become apparent.

Having shared in this hearing the problems Eaton has experienced and is presently experiencing with respect to anti-lock systems, it may be asked whether Eaton is optimistic with respect to the future of such systems. The answer to that question is a simple "yes".

Eaton is prepared to stand behind its anti-lock system. We are doing everthing we can to provide service and backup support to our customers. We have technical service personnel in the field; they are trained and ready to help. And, we have emergency parts distribution available.

We question seriously whether this is the time to make fundamental judgments about the future of Standard 121. Some believe it has been wrong to bring the anti-lock system to the market without a gradual introduction. But, in our opinion, that isn't justification for condemning Standard 121 prior to the availability of a statistically significant data base. We believe it is imperative that the industry advance further along the learning curve before

any conclusions are drawn with respect to the future of Standard 121.

Senator EAGLETON. Mr. Glover, how about the Goodrich Co.?

TESTIMONY OF THOMAS L. GLOVER, DIRECTOR, PRODUCT ADMINISTRATION, ENGINEERED SYSTEMS DIVISION, B. F. GOODRICH

Mr. GLOVER. I will be very brief, Senator.

I will cover five points.

As you have requested, I will summarize my statement.

Senator EAGLETON. Without objection, your entire statement will appear in the record at the conclusion of your testimony.

Mr. GLOVER. We have experienced problems in our program. We believe that these problems were caused by production start-up and not in the fundamental design characteristics of the system.

We have tried to correct these problem areas and have taken the necessary steps to prevent these problem areas from occurring again. As the other gentlemen have stated, our warranty claims, apart from the formal recall campaigns that we have established, have been running at a low rate.

We, too, have conducted extensive and effective orginal equipment manufacturer and fleet training programs. We will continue to support this effort. We have trained over 9,000 people, as our records indicate.

No reported accidents have been attributed to the use of our system. There is a growing evidence that skid control in a number of instances have prevented potential serious accidents.

Finally, we believe that our design concept and current production performance answers the requirements of the FMVSS 121.

Senator EAGLETON. Has NHTSA or BMCS or NTSB ever been out to Goodrich to look at its complaint file or whatever you call the records that pertain to customer complaints?

Mr. GLOVER. Yes. In fact, several months ago NHTSA requested, I believe, of all the manufacturers to submit their files, complaint files, and warranty data files which they are now compiling.

Senator EAGLETON. You have already turned them over?

Mr. GLOVER. Yes.

Senator EAGLETON. Do you have an opinion on behalf of Goodrich about the bus and schoolbus regulations?

Mr. GLOVER. No, sir; we do not. We do not have a model for that. [The prepared statement of Mr. Glover follows:]

STATEMENT OF THOMAS L. GLOVER, DIRECTOR OF PRODUCT ADMINISTRATION, BRAKING SYSTEMS, B. F. GOODRICH COMPANY, ENGINEERED SYSTEMS DIVISION Mr. Chairman and members of the sub-committee:

My name is Thomas Glover, director of product administration, braking systems. I am here representing the B F Goodrich Company.

Our engineering and production facilities are located in Troy and St. Paris, Ohio, and we are currently producing and delivering anti-skid systems to over 80 original equipment manufacturers of trucks, tractors and highway trailers. In 1971, we initiated our activity to design, test and manufacture a product to meet the proposed requirements of MVSS-121. Our background runs from the Aerospace industry and we considered the requirements for this new standard within our technical and manufacturing capabilities.

Subsequent laboratory, track and field testing postured our company for timely delivery of our product, prior to the implementation dates of January and March of 1975.

This testimony will outline the B F Goodrich Company's experience on skid control for trailers, tractors and trucks. We do not have a model that is employed on buses.

I am going to discuss both the negatives-which are represented by the problems we have experienced to date and the positives-which are represented. First, by the action programs implemented to solve the above problems. Second, by the extensive training programs implemented to effectively handle skid control in the field.

First, to our problem areas

As is normally the case when a company, any company, enters a market with a new product, start-up problems are likely to occur. Our experience to date with skid control systems for the heavy duty truck market is certainly no exception.

We had four notification/recall campaigns; three through our own company and one in cooperation with a vendor to B F Goodrich, only one of which is still active and underway. A short review of the nature of the latest notification/ recall campaign is as follows:

In June of 1977, we became aware of a potential problem with our system used on trailers, and trailers only, which resulted in a potential computer malfunction.

Specifically, the component is identified as BFG part number 1800-2 controller, which is the controller that controls brake pressure under potential skid conditions. The units were produced and delivered, prior to February 1976, almost two years ago.

The defect referred to may exist in the 1800-2 controllers by serial number range as follows:

G 034000 through G 059999; J 000001 through J 024000; and K 000001 through K 009600.

It is estimated that the safety related defect will be found in approximately nine percent of the controllers above recited, or three percent of the trailers involved.

The defect, if existing, in the controller is identified as an electrical disconnect of one of several capacitors. This defect is caused by excessive vibration and is time-in-service related. This electrical disconnect causes a loss of brakes above 35 MPH on the axle on which the controller is installed or a loss of skid control at any speed. The failure could occur without the driver having warning that his trailer brakes are inoperative above 35 MPH on the axle involved or that his skid control unit has reverted to fail-safe.

In summarizing our notification/recall situation, it is: first, pertinent to point out that the four recall campaigns-were derivatives not of design deficiencies, but of manufacturing start-up problems.

Second, it can be reported that three of the recall programs moved forward on schedule and, although aggravating to our customers and expensive to our company, we nevertheless feel they have improved the overall product integrity of our system:

That the fourth program is underway and progressing satisfactorily.

And finally, current data from our warranty claims department reveals a total of 2446 warrantable controllers have been returned on warranty claims. This represents less than 2 percent of the total controllers shipped since the beginning of our program.

And finally, no skid control vehicles involved in accidents have, subsequent to investigation, determined skid control to be responsible for the accident.

Thus far, we have discussed problem situations. Now, I am going to redirect our testimony to a more positive vain.

Our sales, service, marketing and engineering personnel have been working closely with our OEM and fleet customers, both in the correction of our field problems and to carry forward our important training programs. Notwithstanding our early product problems, we believe the situation is improving drastically.

At the outset of our entry into the skid control market, we recognized that even though many maintenance personnel were well acquainted with the electrical complexities of a truck, tractor or trailer, we knew skid control systems would be new to them.

In anticipation of the need for education and familiarization of this new product, we developed a complete series of audio-visual programs.

These programs include supporting maintenance manuals, trouble-shooting booklets, and diagnostic service aids to insure that all those associated with the BFG system are trained in its installation and servicing.

Specifically, there are seven programs available.

First, FMVSS 121: This program defines the technical implications of FMVSS 121 for air-braked vehicles. The purpose and implementation dates for trucks, tractors, trailers and buses are stated. Also included is a detailed explanation of the brake performance and equipment requirements for trailer and converter dollies as they relate to service, parking, and emergency brake systems. The truck and tractor requirements are deailed, along with the principles of operation of the BFG skid control system.

This program also explains performance characteristics when vehicles with skid control are mixed with a tractor or trailer that is not skid control equipped.

Second, the truck OEM installation program: This program follows the assembly line installation procedures of a two and three-axle skid control system, with particular emphasis on wheel speed hardware installation for both front steerable and rear drive axles.

Third, the trailer OEM installation program: This program outlines the step-by-step installation procedures used to install a two-tank skid control system. It includes the basic steps for installing in-axle and in-wheel sensors, the plumbing of the primary and emergency air systems, and the electrical wiring of the fuse box and modulator assemblies.

Fourth, the truck retrofit program: This one details the installation of the BFG skid control system on a pre-1975 tractor.

Fifth, the trailer retrofit program: Similar to the truck OEM installation program, this one also includes the procedures for an operational check of the total system upon completion.

Sixth, the truck skid control diagnostic program: This program explains the function and operation of the fail-safe monitor, modulator valve, controller, sensors, and solenoids, and outlines diagnostic procedures to follow in case of malfunction, and finally,

Seventh, the trailer skid control diagnosis program: This final program explains the function and operation of the fuse box, controller, sensors, modulators and solenoids.

It also describes the operation of the primary and emergency air systems. Along with the above mentioned programs, BF Goodrich has also prepared additional training aids to help explain the operation and servicing of its skid control system.

These includes: Truck and trailer functional display boards of a single axle skid control system. These training boards are powered by a 12-volt battery to permit a visual demonstration of the operation of the components required to equip a truck or trailer with skid control.

Also, truck and trailer diagnostic wall charts explain the trouble-shooting of a malfunctioning skid control system based on the operation of the failsafe indicator light for trucks, and the operation of the fuse box indicator lights for trailers.

A diagnostic procedure is outlined to locate the problem and shows specific volt-ohmmeter checks and specifications.

Regarding the application and use of the programs, different manufacturers and fleets make different training requests. Therefore, we have tailored our methods of training to adapt to these differences. For example, certain manufacturers have an extensive training department of their own. In this case, we have supplied the basic programs and materials, leaving the specific training to the manufacturer. An example of this approach is the very fine training organization of Kenworth.

Other manufacturers have established regional centers to train their dealer personnel. Here, B F Goodrich personnel have partcipiated in the training session, making the actual presentations. Mack Truck is a good exampe of this approach.

Some manufacturers favor field training at their branch or dealer location. To meet this requirement, B F Goodrich field service personnel regularly conduct training sessions during or after working hours. Budd factory branches, for example, have received many such training seminars from BFG. and many fleets have received training seminars at their maintenance facilities. In summarizing our training effort, it can be stated that through the use of our field salesmen, field servicemen, product sales engineers, and service engineers, we have been meeting the training requirements of the vehicle manufacturers and fleets.

Through August of 1977, we have conducted in excess of 1,000 training meetings with OEM's and fleets. Approximatey 9.000 industry representatives have attended one or more of these training programs.

As indicated earlier, no accidents attributed to our skid control system have been confirmed and we have received reports of instances where 121 systems have actually prevented accidents. At present, a number of actual reports and testimonials are on file at our Troy, Ohio, facility which speak positively about our skid control system.

In summary the B F Goodrich Company has reached the following conclusions about skid control and MVSS 121 :

(1) We experienced start-up problems in our program. We believe these problems were caused by production start-up problems, rather than fundamental design characteristics.

(2) We have moved as rapidly as possible to correct these problem areas and have taken necessary steps to prevent similar occurrences in this area.

(3) Warranty claims, apart from the formal programs, have been running at a low rate.

(4) We have conducted extensive and effective OEM and fleet training programs and will continue to support our customers in this important activity. (5) No reported accidents have been attributed to the use of our system and there is growing evidence that skid control has, in a number of instances, prevented potentially serious accidents.

(6) Finally, we believe that our design concept and current product performance answers the requirements of motor vehicle safety standard 121.

We appreciate the opportunity to present this report outlining B F Goodrich experience relative to skid control systems.

Senator EAGLETON. We will turn now to Mr. Campanini of the Berg Manufacturing Co.

TESTIMONY OF SERGIO CAMPANINI, PRESIDENT, BERG

MANUFACTURING CORP.

Mr. CAMPANINI. I will try to reduce this written presentation so I will read portions of it.

My name is Sergio Campanini and I am president and general manager of the Berg Manufacturing Co., division of the Echlin Manufacturing Co. You will recognize that my comments must, of necessity, be concerned with Berg's experience in the antilock area.

Berg, for many years, has been a manufacturer of air brake and electrical components for the heavy-duty transportation industry. Prior to 1970, when the first version of FMVSS-121 was published, Berg's research and development efforts had been directed toward the solution of two problems: the balancing of brake controls between the tractor and trailer, and the proportioning of braking effectiveness to the load of the vehicle.

These developments were not adequate to meet the stability standards as proposed by FMVSS-121. In order to continue to maintain. our position as a viable supplier to the heavy duty industry, we determined that it was necessary that Berg offer an antilock system. The Berg antilock was developed in cooperation with Fiat of Turin, Italy. I would like to briefly discuss the inherent aspects of motor vehicle braking and the problems encountered in designing better braking systems. The very nature of the standard addresses itself to two conflicting aspects of the braking of heavy duty vehicles: Braking power and controllability.

The braking of the vehicle is reciprocal of the engine design objective; brakes must dissipate the energy stored in an 80.000 pound