Interpretation ID: aiam4043
Government Relations Manager
Kawasaki Motors Corporation
U.S.A.
P. O. Box 11447
Santa Ana
CA 92711;
Dear Mr. Hagie: This responds to your April 11, 1986, letter to this office requestin an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 106, *Brake Hoses*. We regret the delay in our response; You asked whether brake hoses that comply with all requirements o Standard No. 106 except the whip resistance test of S5.3.3 may be used in locations not subject to movement during vehicle operation. As explained below, the answer to your question is no.; As you know, Standard No. 106 defines 'brake hose' as 'a flexibl conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.' Manufacturers of brake hoses must certify that their hoses comply with all applicable requirements of the standard. From your letter, it appears that while you agree that the equipment you manufacture are brake hoses, you believe that they should not be subject to whip resistance test because your hoses would not be used between articulating parts.; We do not agree that the whip test does not apply to brake hoses use between non- articulating parts. No provision has been made in the standard or in the whip resistance test of S5.3.3 to exclude hoses manufactured for use between non-moving parts. In contrast, the standard has set separate requirements under certain tests for brake hoses used between articulating parts when it is appropriate to distinguish between articulating and non-articulating applications (see, for example, the tensile strength test of S7.3.10 for air brake hose assemblies).; Further, we believe that there is a safety need to test brake hose intended for non-articulating applications for fatigue resistance, since they are also subject to vibration, bending and articulating stress while the motor vehicle is being operated or repaired.; If you have further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel