Dr. Jos Morsink - Comment

LS, Please find below my comments to the proposed changes of the DOT FMVSS 116 Change to the corrosion method: Compared to J 1703 and 1704, FMVSS 116 requires currently an extra steel whool polishing step which now is being proposed to be replaced by silicon carbide paper grit # 1200. The proposers say they believe that less variability would results in the corrosion results. Maybe I have missed the details, but is there any evidence made available supporting this assumption? Evaporation test method: This method has been the subject of debate in the SAE Brake Fluids Standards Committee for a considerable period of time. Many brake fluids experts had a chance to provide their input and it has not been just an ad hoc decision to skip this method from SAE J 1703 and 1704. Using data from many supporting laboratories, the final conclusion was that the method is not reliable enough (yes the repeatability improves by a rotating oven, but the reproducibility stays below an acceptable performance level), can be considered as outdated (it originates from a time that volatile alcohols used to be part of a brake fluid formulation), and is ample compensated by other methods of the specs. Particularly, the expressed worry about a vapour lock is covered by ERBP requirements, we believe. We could not find arguments in the DOT proposal opposing the opinion of the SAE members that boiling point tests actually make the evaporation test redundant. Actually, correct me if I'm wrong, it is quite remarkable to notice that input of a historic study, on basis of which the method has been rejected from J 1703 and 1704, is now applied to maintain the evaporation method in FMVSS 116. Furthermore, I believe that the considerations on cost effects are quite simplified since e.g. costs of calibration and turn around time are not being considered.    Many regards, Jos Morsink Member of the SAE Motor Vehicle Brake Fluids Standards Committee    Dr. J.B.W. Morsink PD&MS Manager Brake Fluids Shell Chemicals SIC-CTEOD/2, SRTCA, Badhuisweg 3, 1031 CM Amsterdam / P.O.B. 38000, 1030 BN Amsterdam Tel:+31 20 630 3481; Fax:+31 20 630 3034; email:Jos.B.W.Morsink@opc.shell.com