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U . S . CONSUMER PRODUCT SAFETY COMMISSION

WASHINGTON . . C . 20207

June 5 , 1985

Honorable Doug Barnard Chairman Subcommittee on Commerce , Consumer and Monetary Affairs Committee on Government Operations Room B - 377 Rayburn House Office Building Washington , D . C . 20515

Dear Chairman Barnard :

During the May 21 , 1985 , hearing on All - Terrain Vehicles ( ATVs ) which you convened on behalf of your Subcommittee , a few matters were raised which call for additional comment .

During my own testimony , you inquired as to why the Commission had not acted earlier in detecting the ATV risk and proceeding much sooner to conduct the comprehensive hazard and engineering analysis needed before it could undertake any appropriate regulatory action . After reviewing with you the budgetary constraints under which this Commission has been operating since 1981 , you asked what other matters occupying our attention rose to a comparable order of magnitude . I cited and discussed one such example , the hazard associated with chain saw kickback . But in order that your own understanding and that the record of the proceeding be complete , I would appreciate that my response be supplemented to include reference to the several priority projects which this Commission has been addressing in FY ' 84 and ' 85 . A list of those projects is attached .

Secondly , in the course of my remarks , I explained that " . . . in attempting to turn a 3 - wheeled ATV , one of the rear wheels must be raised from contact with the ground or pad . " When Congressman Larry Craig was questioning the last panel of manufacturers , he asked them about the validity of my above - stated description of a typical turning maneuver . They plainly disagreed with it , and so did he . The fact of the matter , however , is that in the literature produced by those very companies , there are numerous references to the need for one of the two rear wheels to " break traction " during a turn manenuver ( or comparable language ) . This is due to the absence of any kind of differential on the rear axle . In other words , in order to turn the vehicle properly , you must get weight off the rear wheel on the side toward which you are turning or , in effect , balance the vehicle on two wheels . That is precisely what I was referring to and which appears

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