Interpretation ID: aiam2013

Mr. John H. Mueller, The Weatherhead Company, 300 East 131st Street, Cleveland, Ohio 44108; Mr. John H. Mueller
The Weatherhead Company
300 East 131st Street
Cleveland
Ohio 44108;

Dear Mr. Mueller: #Please forgive the delay in responding to you letter of March 25,1975, which suggested an inconsistency in the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #S5.1 of the standard requires each hydraulic brake hose assembly to be equipped with end fittings which are attached by means of crimping or swaging. You have correctly pointed out that S5.2.3 specifies labeling requirements for 'hydraulic' end fittings which are neither crimped nor swaged, even though at present there are no hydraulic fittings, that fit that description. This language appears as part of S5.2 because S5.2 is incorporated by reference in S7.2 and S9.1, the labeling requirements for hose, fittings, and assemblies used in air and vacuum brake systems, respectively. Although there is thus no inconsistency, the National Highway Traffic Safety Administration is considering a clarifying amendment along the lines you have suggested, which would eliminate S5.2.3 and specify the labeling requirements directly in S7.2 and S9.1. #Thank you for pointing out this potential source of confusion. #Sincerely, Frank A. Berndt, Acting Chief Counsel;