Interpretation ID: nht87-2.1

TYPE: INTERPRETATION-NHTSA

DATE: 06/05/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Albert Schwarz -- Senior engineer, Imperial Clevite Inc.

TITLE: FMVSS INTERPRETATION

ATTACHMT: 8/3/84 letter from Frank Berndt to Terry E. Teeter (Std. 106)

TEXT:

Mr. Albert Schwarz Senior Engineer, Product Development Imperial Clevite Inc. Imperial Eastman Division 6300 W. Howard Street Chicago, IL 60648-3492

This responds to your January 12, 1987 letter to the National Highway Traffic Safety Administration (NHTSA) concerning Standard No. 106, Brake Hoses. You ask whether the standard applies to flexible conduits (i.e., hoses and plastic tubing) used to trans mit air pressure to accessories such as horns and windshield wipers. The answer to your question is yes, if a failure of such a conduit result; in a loss of air pressure in the brake system.

On August 3, 1984, NHTSA issued an interpretation of Standard No. 106 to Mr. Terry Teeter of the Eaton Corporation, who asked the same question you did about the applicability of the standard to conduits used for accessories. Our letter explains that fle xible hoses (and tubing) connected to accessories are "brake hoses" and subject to the standard if they transmit or contain the air pressure used to apply force to the vehicle's brakes--i.e., a failure of such a hose would result in a loss of air pressur e in the brake system. I have enclosed a copy of our letter to Mr. Teeter for your information.

I understand that Ms. Hom of my staff sent you a copy of a Federal Register notice issued by NHTSA on April 17, 1986, which terminated rulemaking on whether the air brake hose tensile requirement of Standard No. 106 should be reduced for hoses typically used for accessories. NHTSA decided to terminate rulemaking because the agency believed that it would be in the interest of safety for the smaller-diameter hoses to comply with current requirements of the standard. Since you might want to review this not ice in light of the information provided you in this letter, I have enclosed a duplicate copy for your convenience.

You also ask whether there are requirements other than those included in Standard No. 106 that must be met by accessory lines. The answer to your question is no. The air brake hoses you intend to use in accessory lines need comply only with Standard No. 106 to be manufactured and sold in this country.

I hope this information is helpful. Please contact my office if you have further questions.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

(4/17/86 Federal Register notice of termination of rulemaking, 49 CFR Part 571, Docket No. 85-04, Notice 2) omitted.

Januxary 12, 1987

Dear Ms. Jones:

Today, during a conversation with Ms. Dierdra Hom, I raised a question which she has suggested that I pass along to you for comment.

This question involves a vehicle equipped with an air brake system which is within the jurisdiction of DOT 106-74. When such a vehicle also uses the compressed air system to power accessory non-brake equipment, such as horns or windshield wipers, must th e hoses and or plastic tubing, along with their associated couplings, also meet the requirements of DOT 106? Are their other requirements which must also be met by non-safety-related accessories which may also be powered by, and therefore connected to th e compressed air system?

I look forward to receiving your comment.

Yours truly,

Albert Schwarz

Senior Engineer, Product Development