Interpretation ID: aiam4323
Senior Engineer
Product Development
Imperial Clevite Inc.
Imperial Eastman Division
6300 W. Howard Street
Chicago
IL 60648-3492;
Dear Mr. Schwarz: This responds to your January 12, 1987 letter to the National Highwa Traffic Safety Administration (NHTSA) concerning Standard No. 106, *Brake Hoses.* You ask whether the standard applies to flexible conduits (i.e., hoses and plastic tubing) used to transmit air pressure to accessories such as horns and Windshield wipers. The answer to your question is yes, if a failure of such a conduit results in a loss of air pressure in the brake system.; On August 3, 1984, NHTSA issued an interpretation of Standard No. 10 to Mr. Terry Teeter of the Eaton Corporation, who asked the same question you did about the applicability of the standard to conduits used for accessories. Our letter explains that flexible hoses (and tubing) connected to accessories are 'brake hoses' and subject to the standard if they transmit or contain the air pressure used to apply force to the vehicle s brakes--i.e., a failure of such a hose would result in a loss of air pressure in the brake system. I have enclosed a copy of our letter to Mr. Teeter for your information.; I understand that Ms. Hom of my staff sent you a copy of a Federa Register notice issued by NHTSA on April 17, 1986, which terminated rulemaking on whether the air brake hose tensile requirement of Standard No. 106 should be reduced for hoses typically used for accessories. NHTSA decided to terminate rulemaking because the agency believed that it would be in the interest of safety for the smaller-diameter hoses to comply with current requirements of the standard. Since you might want to review this notice in light of the information provided you in this letter, I have enclosed a duplicate for your convenience.; You also ask whether there are requirements other than those include in Standard No. 106 that must be met by accessory lines. The answer to your question is no. The air brake hoses you intend to use in accessory lines need comply only with Standard No. 106 to be manufactured and sold in this country.; I hope this information is helpful. Please contact my office if yo have further questions.; Sincerely, Erika Z. Jones, Chief Counsel