Interpretation ID: nht91-7.45

DATE: December 11, 1991

FROM: Frank J. Sonzala-- Senior Vice President, International Transquip Industries, Inc.

TO: Steve Wood -- Chief Council Office, NHTSA

COPYEE: D. Carter; J. Frank Haasbeek

TITLE: Deceptive Labeling of Spring Brakes

ATTACHMT: Attached to letter dated 2/3/92 from Paul Jackson Rice to Frank Sonzala (A39; Std. 121; Std. 106; VSA S 108)

TEXT:

Mr. Richard Carter of NHTSA told me that I should bring this following information to your attention.

It seems that spring brake manufacturers such as Lear Sigler who manufacture the Anchorlok brand spring brake have adopted a practice to add the letters D.O.T. to their chamber housing. Now, this is interpreted by the industry to connote that this type of chamber is D.O.T. approved. We feel that this is misleading and certainly not endorsed by the United States Department of Transportation.

I do not know what can be done about this situation but our customers of the I.T.I. Air Brake Chamber, the Air-Mech are asking us to get D.O.T. on our chambers. Of course, we do not intend to participate in deceptive practices. However, we request that your department send my company a letter explaining how D.0.T. should not be on any chamber and if it is, it should not be interpreted as being approved by D.O.T. or NHTSA.

If you have any questions or comments please give me a call. I have included a rendering of the "Raised D.0.T" inscription on the Anchorlok spring brake chamber casting.