Interpretation ID: aiam3469
Johnson
Campbell & Moesta
912 Buhl Building
Detroit
MI 48226;
Dear Mr. Jaworski: This responds to your recent letter requesting confirmation that th National Highway Traffic Safety Administration (NHTSA) has not issued any safety standards or regulations concerning the use of brake hose as a fuel line in commercial vehicles. Mr. Vernon Bloom of the NHTSA apparently told you that the agency has no standards regarding vehicle fuel lines.; Mr. Bloom is correct in his statement that no Federal safety standard or regulations preclude the use of brake hose as a vehicle fuel line, and that there are no standards directly relating to fuel lines. However, the agency does have a safety standard which indirectly involves fuel lines. Safety Standard No. 301, *Fuel System Integrity* (49 CFR 571.301), specifies performance requirements governing fuel systems on new motor vehicles. The standard specifies the maximum amount of fuel leakage that may occur following a barrier crash test of a new vehicle. Although the individual components of the fuel system, such as the fuel tank, do not have to meet specific requirements, each component obviously must be durable in order for the entire system to meet the general performance requirement of Standard No. 301. Therefore, you should ascertain whether the brake hose you intend to use as a fuel line would compromise a vehicle's ability to comply with that standard.; I would also point out that, although there are no safety standard directly relating to fuel lines, manufacturers are responsible for any safety-related defects which may occur in their vehicles or equipment. Section 151, *et seq*., of the National Traffic and Motor Vehicle Safety Act provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge. Under these provisions, you would be responsible if it were determined that your fuel lines constituted safety-related defects.; Sincerely, Frank Berndt, Chief Counsel