First of all let me say that I applaud your effort to make our highways safer by working to get a nationwide standard for trailer brakes. Then let me point out it seems like at this point trailer (RV) manufacturers are following the currently applicable standards and laws. You might find it easier looking into the RVIA rules concerning towable RVs braking standards. Remember all RV that carry the RVIA seal (and Heartland is one of them) abide by the RVIA rules. Do you know if NTHSA has standards for braking for trucks and autos? My opinion is we are all responsible for our own safety and we rely on the government to do too much for us. If we do things ourselves without government involvement then maybe government cost just might be able to be reduced. MHO.
NHTSA does have braking standards for trucks and autos, and they do have standards for trailers if they are equipped with air brakes.
Here are ths standards specified by RVIA:
RVIA Adopted Standards
12-Volt Electrical Requirements as specified by ANSI/RVIA 12V Low Voltage System Standard.
- Addresses the interfacing of the original chassis manufacturer and the RV manufacturer designs so as to be compatible.
- Overcurrent protection tables and conductor (wire) sizing and protection criteria.
- Requires listed lighting fixtures and other devices and appliances to be installed in accordance with manufacturer’s written instructions.
120-Volt Electrical Requirements as specified in Article 551 and other applicable sections of NFPA 70, of the National Electrical Code.
- Ground fault protected receptacles are specified where they are appropriate.
- Only listed electrical fixtures, appliances, equipment and materials that have been labeled by nationally recognized testing agencies are allowed.
- Dielectric tests are performed on the completed Recreation Vehicle to determine that the electrical system is installed correctly.
Fuel Systems and Equipment as specified in ANSI/NFPA 1192 Standard on RV’s.
- Venting requirements for propane appliances are specified where necessary.
- Propane piping sizes are required to ensure a propane supply that provides for proper appliance performance.
- Over fill protection devices (OPD) are required on all installed propane containers.
- Propane line routing and accessibility - all joints in propane lines must be accessible for periodic leak testing and repair. Lines may not be installed in spaces where a nail or screw could pierce the line.
- Fuel burning appliances must be listed for RV use and labeled by a nationally recognized testing agency that has found the product to be suitable for its intended use.
- Sealed combustion and direct venting to the outside is required for all propane appliances, except for gas ranges, to provide for a complete separation of the combustion chamber from the interior atmosphere.
- Each propane system must be tested upon final assembly to determine proper leak-free performance.
Fire & Life Safety Requirements as specified in NFPA 1192 Standard for RVs.
- Interior finish flame spread limitations are required.
- Minimum exit facilities providing unobstructed travel to the outside of the vehicle must be available.
- Smoke alarms, fire extinguishers, CO detectors and LP-Gas detectors are mandate based on applicable criteria.
Plumbing Systems as specified in ANSI/NFPA 1192 Standard for RVs.
- Only listed plumbing devices, fixtures and appliances that have been labeled by nationally recognized testing agencies are allowed.
- Water distribution systems are sized to provide adequate flow rate and designed to prevent backflow contamination.
- Fixtures with traps and vents must be provided to protect against siphonage and back pressure.
- Vents to release gases from any waste holding tank must be provided.
Federal Motor Vehicle Safety Standards as specified in Code of Federal Regulations, Title 49 Part 571.
Title 49 Part 571.105 applies to hydraulic and electric brake systems, but it does not include towable RVs.
§ 571.105 Standard No. 105; Hydraulic and electric brake systems.
S1.
Scope. This standard specifies requirements for hydraulic and electric service brake systems, and associated parking brake systems.
S2.
Purpose. The purpose of this standard is to insure safe braking performance under normal and emergency conditions.
S3.
Application. This standard applies to multi-purpose passenger vehicles, trucks, and buses with a GVWR greater than 3,500 kilograms (7,716 pounds) that are equipped with hydraulic or electric brake systems.
Establishing a standard for towable RVs would be as simple as expanding the application of this standard to all trailers with a GVWR of 3,500 pounds or greater.
I note that you have disk brakes on your rig. When you assert that we are all responsible for our own safety, are you saying that if we want brakes on our trailers that will actually stop the trailer rather than just slow it gradually, we need to retrofit the electric brakes with electric/hydraulic disk brakes? Or, did your trailer come from the factory with disk brakes?
If the brakes on my Sundance cannot be made to provide maximum braking effort (ie. be capable of sliding the tires at any speed -- pretty much like every other vehicle I own), I will retrofit disk brakes with an electric/hydraulic actuator, which will cost me around $2,000, but should I have to do that to obtain satisfactory braking on a brand new unit?
Even though I live in the People's Republic of Minnesota, I am no fan of large or expanded government (I am actually a fan of Ron Paul and am glad to see that he has entered the race but don't think he has much of a chance), but extending the existing 571.105 braking standard to towable RVs shouldn't increase our deficit by more than a few $billion.