Interpretation ID: nht79-1.2

DATE: 11/20/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Continental Hydraulic Hose Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Allan E. Cameron Continental Hydraulic Hose Corp. State Route 182 East P.O. Box 337 Upper Sandusky, Ohio 43351

Dear Mr. Cameron:

This responds to your recent letter asking questions concerning the labeling requirements of Safety Standard No. 106-74, Brake Hoses, as they would apply to "permanently crimped" hydraulic brake hose assemblies.

Under the standard, a brake hose assembly must be labeled according to the specifications of either S5.2.9 or, at the option of the manufacturer, S5.2.4.1. Under S5.2.4.1, the brake hose end fitting must be permanently labeled with a designation (at least one-sixteenth of an inch high) that identifies the manufacturer and has been registered with the National Highway Traffic Safety Administration. It is not necessary under this option, however, to stamp the symbol "DOT" on the end fitting, to stamp a date on the end fitting or to attach a band or label to the hose assembly. The band or label is only required under the first option, S5.2.4.

Sincerely,

Frank Berndt Chief Counsel

October 2, 1979

Highway Safety Law Division Federal Highway Administration Department of Transportation Washington D.C. 20590

Attention: Mr. Hugh Oates.

Subject: MVSS - 106

Dear Mr. Oates,

Continental Hydraulic Hose Corporation is a manufacturer of hydraulic brake hose assemblies. Our products are permanently crimped. We are not a vehicle manufacturer.

Our interpretation of Paragraph S-5.2.4 and new S-5.2.4.1 as it applies to our labelling requirements is:

1) One end fitting shall be steel stamped with the designation "CH" in letters 1/16" high or more. This designation is on file with your office.

2) It is not necessary that the letters "DOT" be stamped on the hose fitting.

3) It is not necessary that a date be stamped on the hose fitting.

4) It is not necessary that a band or label be attached to the hose assembly, so long as designation in item 1 above is met.

Please advise if you disagree.

Sincerely,

Allan E. Cameron Vice President

AEC/rw