Interpretation ID: aiam1940
One Mercedes Drive
Montvale
New Jersey 07645;
Dear Mr. Gerth: #Please forgive the delay in responding to your lette of December 12, 1974, requesting an interpretation of the definition of 'permanently attached end fittings' appearing in Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #You have described a process of heat shrinking plastic vacuum booster hose over short corrugated metal connecting tubes, the ends of which are flared to retain threaded hex fittings. You have submitted sample hose assemblies and requested confirmation of your interpretation that the end fittings are permanently attached. While these fittings may meet the common understanding of the words 'permanently attached,' Standard No. 106-74 defines 'Permanently attached end fitting' as: #>>>an end fitting that is attached by deformation of the fitting about the hose by crimping or swaging, or an end fitting that is attached by use of a sacrificial sleeve or ferrule that requires replacement each time a hose assembly is rebuilt.<<<#Deformation of the hose about the fitting by heat shrinking is not 'deformation of the fitting about the hose by crimping or swaging.' The latter part of the definition is inapplicable because the assemblies are not subject to being rebuilt. Therefore, to classify these end fittings as permanently attached would require an amendment of the standard. Such an amendment is being considered. #Your January 7, 1975, petition for reconsideration, requesting exclusion of the above described vacuum hose from the coverage of Standard No. 106-74, was received more than 30 days after the most recent amendment of the definition of 'brake hose'. Therefore, it has been treated as a petition for rulemaking. The Standard defines 'brake hose' as: #>>>a flexible conduit 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.<<<#The conduit between the vacuum booster and vacuum pump in your brake booster circuit clearly falls within this definition, and hence is subject to the Standard's requirements. The NHTSA has concluded that, because of its flexibility, this hose is exposed to the same hazards as the more traditional types of vacuum brake hose and so should be subject to the same performance requirements. Accordingly, your petition to amend the definition is denied. The conduit between the vacuum pump and the intake manifold, however, falls outside the definition of 'brake hose' because, as described by Mr. Craig Jones in a conversation with Mr. Howard Dugoff of this agency on March 17, 1975, the booster system produces full vacuum even when this conduit fails. Therefore, this conduit need not comply with the requirements of Standard No. 106-74, #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs;