Interpretation ID: aiam1796
55 Concord Street
Englewood
New Jersey 07631;
Dear Mr. Utans: This responds to your January 19, 1975 question whether S5.4.3 o Standard No. 105-75, *Hydraulic brake systems*, permits a brake fluid warning statement on a filler cap to be partially obscured by a locking component placed over it, and whether the statement in association with the recommended type of brake fluid.; The answer to both of your questions is no. Section S5.4.3(b) require that the statement be 'located so as to be visible by direct view'. This requirement prohibits an arrangement which would obscure any part of the statement, as would the design described in the drawings which accompany your letter. Section S5.4.3(b) permits a location within 4 inches of the brake fluid reservoir filler plug or cap to accommodate arrangements which do not permit use of the filler cap as a location.; The content of the brake fluid warning statement required by S5.4.3 i specified in every respect other than designation of the recommended type of brake fluid. However, S5.4.3 does limit the permissible designation to 'the recommended type of brake fluid as specified in 49 CFR S571.116' and sets out an example of 'DOT 3'. These criteria do not permit the addition of an automobile manufacturer's name. Such a recommendation could, of course, appear separately in the vehicle's owner's manual.; Yours truly, Richard B. Dyson, Assistant Chief Counsel