Latest Articles

April 2024
New UN ECE Regulation on Real Driving Emissions Published

On March 19, 2024, a new United Nations Economic Commission for Europe (UN ECE) Regulation on the real driving emissions (RDE) of light duty passenger and commercial ...

March 2024
The Consumer Product Safety Commission (CPSC) Issued a Final Rule (FR) to Amend Consumer Product Safety Standard for Four-Wheel All-Terrain Vehicles (ATVs)

The CPSC issued a Final Rule (FR) in the Federal Register: Volume 89, Number 15 dealing with16 CFR Part 1420 for ATV safety. The CPSC addressed the comments that were ...

February 2024
NHTSA Issue ANPRM Regarding Advanced Drunk and Impaired Driving Prevention Technology

On January 5, 2024 the NHTSA published an Advanced Notice of Proposed Rulemaking (ANPRM) in the Federal Register. This notice deals with Advanced Impaired Driving ...

2024

January 2024
EU Regulations on the In-Service Verification Testing of CO2 Emissions Published

(EU) 2019/631, which is the EU Regulation on the CO2 emissions performance standards for new passenger cars and for new light commercial vehicles, includes a requirement ...

2023

December 2023
EU Regulation on Advanced Driver Distraction Warning Systems Published

On November 22, 2023, a new European Commission Delegated Regulation (EU) 2023/2590 on Advanced Driver Distraction Warning (ADDW) systems was published. The fitment of ...

November 2023
Updates to Australian Design Rule on Side Impact Proposed

On September 22, 2023, the Australian Government published a proposed update to the Australian Design Rule (ADR) on dynamic side impact occupant protection; ADR 72/00. ...

October 2023
The NHTSA Issue a Proposal to Amend Anthropomorphic Test Devices

The NHTSA has published in the Federal Register a Notice of Proposed Rulemaking (NPRM) for an optional dummy to be part of 49 CFR Part 572, Anthropomorphic Test Devices. ...

September 2023
The Consumer Product Safety Commission (CPSC) Issues a Proposal to Amend Consumer Product Safety Standard for Four-Wheel All-Terrain Vehicles (ATVs)

The CPSC has published in the Federal Register an NPRM updating 16 CFR Part 1420 to reflect the latest version of ANSI/SVIA 1-2007. The major updates reflected in the ...

August 2023
Draft EU Regulation on Recyclability and End of Life Vehicles Published

Following a review of the current EC Directives on End of Life Vehicles (ELVs) and on the reusability, recyclability and recoverability of motor vehicles, the European ...

July 2023
The National Highway Traffic Safety Administration (NHTSA) Issued a Proposal to Add a New Federal Motor Vehicle Safety Standard (FMVSS) to Require Automatic Emergency Braking (AEB) for Light Vehicles

The new rulemaking requires Automatic Emergency Braking (AEB), including Pedestrian AEB (PAEB), systems on light vehicles. The new requirements (FMVSS 127 - Automatic ...

June 2023
The Environmental Protection Agency (EPA) Issued a Proposal to Amend Specific Provisions in the Greenhouse Gas Reporting Rule (40 CFR Part 98)

The Environmental Protection Agency (EPA) is updating the Greenhouse Gas Reporting Rule (GHGR). EPA indicates that this is being done to improve the quality and ...

May 2023
Draft EU Regulation on Advanced Driver Distraction Warning Systems Published

On March 24, 2023, the European Commission published a draft Delegated Regulation on Advanced Driver Distraction Warning (ADDW) systems, which are defined as systems that ...

April 2023
Updated UN ECE Regulation on Automated Lane Keeping Systems Published

Updated UN ECE Regulation on Automated Lane Keeping Systems Published On March 3, 2023, the 01 Series of Amendments to UN ECE Regulation No. 157 on Automated Lane ...

March 2023
Updates to UN ECE Regulation on Advanced Emergency Braking Systems for Heavy Vehicles Published

On February 21, 2023, an 02 Series of Amendments to UN ECE Regulation No. 131 on Advanced Emergency Braking Systems (AEBS) for heavy vehicles were formally published. The ...

February 2023
The EPA Proposes New Rule to Revise 2023 through 2025 Calendar Year Renewable Fuel Standard Program (40 CFR Part 80 and Part 1090)

The Environmental Protection Agency (EPA) issued proposed rulemaking in the December 30, 2022 Federal Register (F.R. Vol. 87 No. 250) - EPA 40 CFR Part 80 and Part 1090 ( ...

January 2023
Two New ECE Regulations to Protect Vulnerable Road Users Adopted

At the 188th session of the United Nations Economic Commission for Europe (UN ECE) World Forum for Harmonisation of Vehicle Regulations (WP.29) in November, two new UN ...

2022

December 2022
Draft EU Regulation on Euro 7 Emissions Requirements Published

A draft version of the new EU Regulation specifying the Euro 7 emissions requirements that will apply to all M and N category vehicles was published on the European ...

November 2022
Updates to UN ECE Regulation on Hydrogen Fuel Systems Published

United Nations Economic Commission for Europe (UN ECE) Regulation No. 134 on hydrogen fuel systems was originally published in June 2015 and, although its scope covered ...

October 2022
The Department of Transportation (DOT) Issued a Request for Information (RFI) Enhancing the Safety of Vulnerable Road Users at Intersections

The DoT is searching for data, information and ideas to make intersections safe for Vulnerable Road Users (VRUs) and vehicles. The request focuses on adapting existing ...

September 2022
Scope of EU Regulations on Heavy Duty Vehicle CO2 Emissions Expanded

To allow for the full implementation and monitoring of the European Union’s policies on the reduction of CO2 emissions from heavy duty vehicles, it will be necessary to ...

August 2022
NHTSA Issue a Notice of Proposed Rulemaking (NPRM) Regarding Event Data Recorders (EDRs)

The National Highway Traffic Safety Administration (NHTSA) is proposing to amend the regulation for Event Data Recorders (EDRs) to extend the recording period for timed ...

July 2022
Updates to the EU Regulation on Heavy Duty Vehicle Emissions Proposed to Cover Vehicles using Pure Biodiesel

With the increased commercial availability of diesel fuels containing a higher proportion of biodiesel, e.g. (B20) ad (B30), and even pure biodiesel (B100), the European ...

June 2022
Draft Updates to the EU Regulation on Light Duty Vehicle Emissions Published

On May 23, 2022, the European Commission published a draft Regulation containing proposed amendments to (EU) 2017/1151 on light duty vehicle emissions. The package of ...

May 2022
Draft EU Regulations on the Type Approval of Fully Automated Vehicles Published

The European Commission have recently published two draft EU Regulations which pave the way for the more widespread deployment of fully automated vehicles in Europe. One ...

April 2022
The National Highway Traffic Safety Administration (NHTSA) Issued a Request for Comments (RFC) Regarding Adding Additional Advanced Driver Assistance Systems (ADAS) to the New Car Assessment Program (NCAP) Plus Other Updates

NHTSA published in the Federal Register a Request for Comments (RFC) on proposed actions to the NCAP (New Car Assessment Program). These actions include adding four new ...

March 2022
Draft EU Regulation on Administrative Fines for Type Approval Non-Compliance Published

EU Regulation No. 2018/858 introduced provisions which require the European Commission to carry out compliance verification activities on vehicles and components that are ...

February 2022
The National Highway Traffic Safety Administration (NHTSA) Issued a Final Rule Creating FMVSS 227 – Bus Rollover Structural Integrity

On December 29, 2021 NHTSA published in the Federal Register a Final Rule (FR) establishing FMVSS 227 - Bus Rollover Structural Integrity. This FR ensures that bus roofs ...

January 2022
Scope of UN ECE Regulation on Tyre Pressure Monitoring Systems Extended

On December 17, 2021, the 01 Series of Amendments to UN ECE Regulation No. 141 on Tyre Pressure Monitoring Systems (TPMS) were formally published. The mandatory fitment ...

2021

December 2021
EU Regulation on Intelligent Speed Assistance Systems Published

On November 17, 2021, new European Commission Delegated Regulation (EU) 2021/1958 on Intelligent Speed Assistance (ISA) systems was published. The fitment of ISA systems ...

November 2021
EU and UN ECE Develop New Regulations on Event Data Recorders

In recent weeks, there have been some important developments in both the European Union (EU) and the United Nations Economic Commission for Europe (UN ECE) regarding new ...

October 2021
The Environmental Protection Agency (EPA) Proposed New Rule to Revise 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas (GHG) Emissions Standards

The EPA issued a proposal in the August 10, 2021 Federal Register to increase the stringency of GHG Emission and Fuel Economy on Light Vehicles. Near term actions are for ...

September 2021
EU Regulation on Driver Drowsiness and Attention Warning Systems Published

On August 16, 2021, new European Commission Delegated Regulation (EU) 2021/1341 on Driver Drowsiness and Attention Warning (DDAW) systems was published. The fitment of ...

August 2021
Two New ECE Regulations to Protect Vulnerable Road Users Published

The United Nations Economic Commission for Europe (UN ECE) have recently published two new UN ECE Regulations covering systems which are intended to assist drivers in ...

July 2021
Draft EU Regulation on Type Approval Market Surveillance Requirements Published

On June 8, 2021, the European Commission published a new draft EU Implementing Regulation for EU Regulation No. 2018/858 on the approval and market surveillance of motor ...

June 2021
NHTSA Seeks To Repeal The Safer Affordable Fuel-Efficient Vehicles Part One: One National Program

Published in the May 12, 2021 Federal Register, a Notice of Proposed Rulemaking (NPRM) proposes to fully repeal the regulatory text and appendices promulgated in the "The ...

May 2021
EU Regulation on Emergency Lane Keeping Systems Published

The mandatory fitment of Emergency Lane Keeping Systems (ELKS) is one of the new safety features required by EU Regulation 2019/2144, and to support the introduction of ...

April 2021
New UN ECE Regulation on Automated Lane Keeping Systems Published

On March 4, 2021, new United Nations Economic Commission for Europe (UN ECE) Regulation No. 157-00 on automated lane keeping systems was officially published. This new ...

March 2021
Draft EU Regulation on Driver Drowsiness and Attention Warning Systems Published

The mandatory fitment of Driver Drowsiness and Attention Warning (DDAW) systems is one of the new safety features mandated by EU Regulation 2019/2144, and to support the ...

February 2021
New Chinese Standards on Advanced Driver Assistance Systems Published

The Chinese Government have published three new standards which specifically cover advanced driver assistance systems. Chinese standard GB/T 39263-2020 specifies terms ...

January 2021
NHTSA Seeks Additional Input for Development of a Framework for Automated Driving System (ADS) Safety

As noted in the InterRegs December Bulletin, NHTSA had authored an ANPRM on Automated Driving Systems that was to be released in the Federal Register soon. In the ...

2020

December 2020
Updates to UN ECE Regulation on Advanced Emergency Braking Systems Published

Since the publication of the original version of UN ECE Regulation No. 152 on advanced emergency braking systems (AEBS) for M1 and N1 category vehicles, the Informal ...

November 2020
New Australian Road Vehicle Standards Legislation Published

In preparation for the mandatory implementation of the Australian Road Vehicle Standards Act 2018, on September 30, 2020, the Australian Government published a new 03 ...

October 2020
The NHTSA/DOT issue Interim Final Rule and Request for Comments Regarding Delay of FMVSS 141 Minimum Sound Requirements for Hybrid and Electric Vehicles

NHTSA has published an Interim Final Rule along with a Request for Comments in response to a petition asking for relief in meeting phase-in and full compliance dates for ...

September 2020
EU Proposes Revisions to the Post 2020 Average CO2 Monitoring Requirements for Light Duty Vehicles

As specified in Regulation (EU) 2019/631, the average CO2 emissions targets applicable to passenger car and light commercial vehicle manufacturers will switch from being ...

August 2020
New UN ECE Regulations on Cyber Security and Software Updates Adopted

At the 181st session of the United Nations Economic Commission for Europe (UN ECE) World Forum for Harmonisation of Vehicle Regulations (WP.29) in June 2020, two new ...

July 2020
New Chinese Standards on Electric Vehicles and Batteries Published

As part of an exercise to update the safety requirements applicable to electrically powered vehicles, China has recently published three new Chinese standards. GB 38031- ...

June 2020
Updates to ECE Regulation on Lighting Installation Adopted

At the 180th session of the United Nations Economic Commission for Europe (UN ECE) World Forum for Harmonisation of Vehicle Regulations (WP.29) in March 2020, an 07 ...

May 2020
National Highway Traffic Safety Administration Proposes Revisions to Federal Motor Vehicle Safety Standards (FMVSSs) to Accommodate Automated Driving Systems (ADS)

In the March 30th Federal Register (Vol. 85; No.61) the National Highway Traffic Safety Administration (NHTSA) published a proposal to modify many of the 200 Series ...

April 2020
Taiwan Delays the Introduction Dates for Certain New Safety Requirements

In January 2020, the Taiwanese Ministry of Transportation and Communications (MOTC) issued an updated version of their Motor Vehicle Safety Testing Regulations which ...

March 2020
USDOT Expands Autonomous Vehicle Support and Requests Comments

The Office of the Secretary for the United States Department of Transportation (USDOT) issued Automated Vehicles 4.0: Ensuring American Leadership in Automated Vehicle ...

February 2020
New ECE Regulation on Blind Spot Information Systems Published

On January 13, 2020, a new United Nations Economic Commission for Europe (UN ECE) Regulation on Blind Spot Information Systems for the detection of bicycles, ECE ...

January 2020
New EU General Safety Regulation Published

The long awaited new EU General Safety Regulation was finally published in the Official Journal of the European Union on 16th December 2019 as EU Regulation No. 2019/2144 ...

2019

December 2019
EU Regulation on Aerodynamic Devices for Trucks and Trailers Published

On November 12, 2019, a new EU Regulation was published which introduced amendments to EU Regulation No. 1230/2012 on the type approval requirements for masses and ...

November 2019
NHTSA Issues an Advanced Proposal for the Addition of a Seat Belt Use Warning System for Rear Seats

On September 27, 2019 (FR Vol. 84 No. 188) the National Highway Traffic Safety Administration (NHTSA) published an Advance Notice of Proposed Rulemaking (ANPRM) (Docket ...

October 2019
NHTSA Issues an NPRM to allow more Flexibility in the Pedestrian Alert Sounds of Hybrid and Electric Vehicles (HEVs)

On September 17, 2019 the National Highway Traffic Safety Administration (NHTSA) issued a Notice of Proposed Rulemaking (NPRM) to amend Federal Motor Vehicle Safety ...

September 2019
New EU Regulation on CO2 Emissions Targets for Heavy Duty Vehicles Published

On July 25, 2019, a new European Union Regulation specifying CO2 emissions reduction targets for heavy duty vehicles, EU Regulation No. 2019/1242, was published in the ...

August 2019
New UN ECE Regulation on Advanced Emergency Braking Systems Adopted

At the 178th session of the World Forum for Harmonisation of Vehicle Regulations (WP.29) in June 2019, a new UN ECE Regulation on Advanced Emergency Braking Systems (AEBS ...

July 2019
US Federal Agencies are Continuing to Pursue Rulemaking related to Autonomous Vehicles

On May 28, 2019 the National Highway Traffic Safety Administration (NHTSA) proposed an Advanced Notice of Proposed Rulemaking (ANPRM) and is seeking public comment on ...

June 2019
Draft Amendments to EU Regulation on Heavy Duty Vehicle Emissions Published

On 17th May 2019, the European Commission published a draft Regulation introducing "Step E" of the Euro VI heavy duty emissions requirements. The two main amendments ...

May 2019
Major Revisions to UN ECE Regulations on Lamps and Reflectors Adopted

At its recent 177th session, the World Forum for Harmonisation of Vehicle Regulations (WP.29) adopted three new United Nations Economic Commission for Europe (UN ECE) ...

April 2019
New Australian Road Vehicle Standards Legislation Published

A number of significant changes to the Australian legislative requirements regarding the importation and first provision of road vehicles and their components have been ...

March 2019
Draft EU Regulation on Aerodynamic Devices for Trucks and Trailers Published

On 30th January 2019, the European Commission published a draft Regulation proposing amendments to EU Regulation No. 1230/2012 on the type approval requirements for ...

February 2019
Updates to EU and UK Type Approval Requirements Published to Cover Brexit

The UK's impending departure from the European Union will have implications on the application and acceptability of European Union type approvals issued to passenger cars ...

January 2019
Updated ECE Requirements on Airbag Warning Labels Proposed

At the November session of the World Forum for Harmonisation of Vehicle Regulations (WP.29), an 08 series of amendments to United Nations Economic Commission for Europe ( ...

October 2023

The NHTSA Issue a Proposal to Amend Anthropomorphic Test Devices

The National Highway Traffic Administration (NHTSA) published a Notice of Proposed Rulemaking (NPRM) in the September 7, 2023 Federal Register (F.R. Vol. 88 No. 172; 49 CFR PART 572 Docket No. NHTSA-2023-0031). This NPRM would amend NHTSA's regulations to include an advanced crash test dummy, the Test Device for Human Occupant Restraint (THOR) 50th percentile adult male (THOR-50M). This dummy represents an adult male of roughly average height and weight and is designed for use in frontal crash tests. NHTSA plans to issue a separate NPRM to amend Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection, to specify the THOR–50M as an alternative (at the vehicle manufacturer's option) to the 50th percentile adult male dummy currently specified for use in frontal crash compliance tests.

The NHTSA and the broader vehicle safety community uses crash test dummies in a variety of ways. NHTSA uses crash test dummies to test vehicles for compliance with Federal Motor Vehicle Safety Standards (FMVSSs), to determine vehicle crashworthiness ratings for the New Car Assessment Program's (NCAP) 5-Star Safety Ratings, and to conduct vehicle safety research. Regulatory authorities in other countries and regions, third-party vehicle rating programs, motor vehicle and equipment manufacturers, and others use crash dummies to evaluate vehicle safety and design safer vehicles and equipment.

Now, the NHTSA uses the devices specified in 49 CFR Part 572, Anthropomorphic Test Devices to test for FMVSS compliance and NCAP performance. Part 572 provides detailed design information, engineering drawings and procedures for assembly and inspection. NHTSA has codified numerous dummies that range in sex, size, age, and measurement capability. The 50th percentile male dummy currently defined in Part 572 for frontal impacts is the Hybrid III-50M. NHTSA added the HIII-50M to Part 572 in 1986. An initial THOR-50M design was published in 2001. There are currently two different THOR dummies, the THOR-50M, and one under development that represents a small-statured adult female, the THOR 5th percentile adult female (THOR-05F). Although this proposal is limited to the THOR-50M, it is anticipated that a rulemaking proposal will be published in the near future to add the THOR-05F to Part 572.

Improvements for the THOR-50M include more human-like occupant response in a crash and advanced instrumentation. These attributes enable it to better predict the risk of injury to human occupants which should help vehicle designers develop and test improved occupant restraint systems as well as types of novel vehicle seating configurations likely to be used in highly automated vehicles. The NHTSA has tentatively concluded that the THOR-50M is sufficiently biofidelic, exhibits repeatable and reproducible performance, and is sufficiently durable. The European New Car Assessment Program (Euro NCAP) has officially adopted the THOR-50M and is currently rating vehicles using this dummy. The Economic Commission for Europe is considering adopting the THOR-50M for use in frontal crash testing under its vehicle safety regulations. The NHTSA believes that the THOR-50M's enhancements will lead to more effective restraint system designs and allow more informative comparisons of the safety of different vehicles. Additionally, the fact that manufacturers are already using this dummy, leads the NHTSA to believe vehicle manufacturers will choose to certify vehicles to FMVSS No. 208 using the THOR-50M. The NHTSA anticipates issuing a proposal in the near future to amend FMVSS No. 208 to specify the THOR-50M as an alternative (at the vehicle manufacturer's option) to the HIII-50M test dummy for use in frontal crash compliance tests.

The THOR-50M is designed to better evaluate the effectiveness of modern vehicle restraint systems and address the types of injuries that continue to occur. These improvements include the following:

  • Improved biofidelity - The THOR-50M has been assessed in a wide array of both component and full-body test conditions for which human response is known and was found to be both qualitatively and quantitatively congruent with human response corridors.
     
  • Improved instrumentation - The THOR-50M has both improved and additional instrumentation compared to the HIII-50M.
     
  • Improved injury prediction - The biofidelity of the THOR-50M, combined with its extensive instrumentation, provides an enhanced capability to measure expected human response and predict injury.
     
  • Improved evaluation of vehicle performance -The above enhancements allow the THOR-50M to better differentiate the performance of different vehicles and restraint systems. The more sophisticated measurement capabilities of the advanced system are better suited to develop and test more sophisticated and highly tunable contemporary restraint systems. Motor vehicle manufacturers and restraint suppliers have already used the THOR-50M to evaluate vehicle crashworthiness and develop occupant protection countermeasures.

Other possible benefits of using the THOR-50M include that it is well-suited for possible new seating configurations brought on by vehicles with Automated Driving Systems (ADS). NHTSA is developing an adaptation of the THOR-50M that is better suited for reclined postures which may be prevalent among ADS occupants. NHTSA's test dummies are used in a range of applications beyond FMVSS compliance testing (e.g., NCAP testing, standards and regulations in other transportation modes, and research). While the purpose of Part 572 is to describe the anthropomorphic test devices that are to be used for compliance testing of motor vehicles and motor vehicle equipment with motor vehicle safety standards, it also serves as a definition of the ATD for other purposes. Examples include consumer information crash testing, standards and regulations in other transportation modes, and research; therefore, it would be to the benefit of government, academia, and the multi-modal transportation industry to include a definition of the THOR-50M ATD in Part 572.

The NHTSA believes that the technical data package adequately describes and would ensure the uniformity of the dummy. Upon finalization of this proposal, a new subpart for the THOR-50M would be added to Part 572, and the technical data package documents would be incorporated by reference. The NHTSA seeks comment on whether the THOR-50M is sufficiently specified to ensure that dummies are uniform and will provide repeatable and reproducible measurements. The NHTSA also seeks comment on whether it would be useful to end-users of the dummy if NHTSA created a list of suppliers used by the NHTSA to obtain various parts and instrumentation, and/or general specifications or operating characteristics of a part (as provided by a manufacturer's specification sheet). This information would not be incorporated into Part 572, but would be provided as a reference for users and could be periodically updated by the NHTSA.

Testing with THOR-50M requires a Data Acquisition System (DAS). The DAS performs signal conditioning, triggering, and data collection to store measurements from instrumentation installed in the dummy during a test into nonvolatile memory. As it relates to ATDs, there are effectively two types of DAS: external and internal (or in-dummy). The 2018 drawing package does not specify a DAS because it assumed the use of an external DAS. Based on their testing, the NHTSA has tentatively concluded that the THOR-50M with the in-dummy DAS is equivalent to one with the external DAS, and is therefore proposing an internal DAS as permitted optional instrumentation. NHTSA seeks comment from users who have experience with both umbilical and in-dummy DAS configurations of the THOR-50M, as to whether they have seen any quantifiable differences between the two systems. The NHTSA also seeks comment on if any additional changes should be made to the proposed drawings specifying the in-dummy DAS to make it more amenable to additional DAS systems that are already in the field.

NHTSA's investigation of the sources of variability provided additional confidence that the proposed acceptance intervals are both achievable and sufficient to ensure that the dummy is providing uniform responses. The NHTSA seeks comment on this methodology. Although the qualification docketed report "THOR-50M Repeatability and Reproducibility of Qualification Tests'' (R&R Report) utilizes only NHTSA's test data, the NHTSA is open to considering qualification data provided by commenters in the finalization of the qualification specifications, provided that the data are from THOR-50M ATDs conforming to the 2023 drawing package and the data was collected following the proposed Qualification Procedure.

Other items that the NHTSA request comments on include:

  • THOR-50M users who have evaluated alternative rib guide designs and have data to support equivalence of durability, repeatability and reproducibility, and equivalence of response in qualification, biofidelity, injury criteria, and vehicle crash test conditions.
     
  • The NHTSA might consider changing the qualification targets to reflect the larger population of THOR-50M units in the field, depending on any change that it could have on the biofidelity of the dummy and the applicability of injury risk functions.
     
  • Qualification testing - should the qualification procedures be incorporated by reference, or whether it would be preferable to locate a much-simplified set of qualification procedures directly in Part 572 and put additional detail and documentation in the Office of Vehicle Safety Compliance (OVSC) laboratory test manual or similar document that would not be incorporated by reference but instead provided as guidance to DOT contractors and other ATD end users?

Comments for this proposal need to be submitted not later than November 6, 2023. The NHTSA are proposing that the Final Rule would be effective on publication in the Federal Register.

The NHTSA NPRM is available on InterRegs.NET for our US Federal subscribers and is also available at www.selectregs.com.

Bob Pheiffer