Interpretation ID: aiam1821
President
Central Electric Company
P.O. Box 1447
1810 Eleventh Street
Portsmouth
Ohio 45662;
Dear Mr. Hinze: #This is in response to your letter of January 21 1975, to Mr. Howard Dugoff of this agency, requesting a manufacturer's designation number for the brake hose assemblies which you manufacture. #S5.2.4(b) of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, was amended on January 29, 1974 (39 F.R. 3680, Docket No. 1-5, Notice 9), and again on February 26, 1974 (39 F.R. 7425, Docket No. 1-5, Notice 10). #In place of an assemble's code number, assigned by the National Highway Traffic Safety Administration, S5.2.4(b) of the standard now requires:#>>>A designation that identifies the manufacturer of the hose assembly, which shall be filed in writing with: Office of Standards Enforcement, 'Brake Hose Identification,' National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590. The marking may consist of a designation other than block capital letters required by S5.2.4.<<<#The designation need not include your company's address, or even its complete name, as long as it identifies the company and is filed with the NHTSA as described above. Furthermore, you do not need a separate designation for each of your two stores. #You have also described a Dymo label marker and requested approval of its use as a means of complying with the banding requirements of S5.2.4. the NHTSA interprets a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. Furthermore, all of the label information must remain visible after the band has been affixed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of the specific design. #Yours truly, Richard B. Dyson, Assistant Chief Counsel;