Castrol International - Comment

Federal Motor Vehicle Safety Standards - Motor Vehicle Brake Fluids Docket no NHTSA 00-8633 RIN 2127-AH96 Action : Notice of proposed rulemaking. My comments are as follows: A) Evaporation test Fluid properties and usage conditions have changed significantly since this test was introduced and it is felt the presence of tests such as wet and dry boiling point tests cover requirements, and will ensure that inferior products would not meet the rest of the FMVSS specification. Brake systems now tend to be sealed; thus evaporation is no longer an issue in the same sense as in the past. There are, it is true, in some countries of the world, products on the market that would not meet the evaporation test requirements - these are based on eg water, diacetone alcohol, etc. But these fluids would not meet the rest of FMVSS requirements in any case and the local marketers do not observe or follow FMVSS recommendations regardless of the presence or absence of an evaporation test. If new marketers were to enter the US market they would not be able to claim FMVSS 116 standards with these inferior fluids. Does the FMVSS have any instance (and results) on any fluid which fails the evaporation tests, yet meets all the other FMVSS tests? We do not have any examples. We highly recommend the Evaporation test be deleted in line with the recent SAE action. We consider it does not serve any practical purpose relating to today's fluids. B) Corrosion Test We feel that it would be better to eliminate altogether the step of "finishing" the metals following the preparation and cleaning of surface with 320 paper, ie to follow the procedure currently specified by the SAE J1703 method. If an alternative change to preparation of metals is introduced, it would be necessary to evaluate ALL FMVSS passing fluids currently marketed worldwide to evaluate any adverse results, remembering that fluids which have been around on the market a long time are without corrosion problems noted in the equipment, so are obviously adequate. In general the SAE recommendations for test methods are arrived at after considerable discussion and testing by committees of experts from around the world, and reflect and represent the most up to date (international) thinking. We feel it is in the best interests of the consumer to have compatible National and International specification tests. I will send this comment also by mail to the address specified, as there were some problems in getting your web site to accept. Dr J E van Tilborg Manager, Brake Fluids Castrol International