Interpretation ID: 18110.wkm

Mr. Joseph Hogan
HYCOP AB
Box 970
S591 29 Motala
Sweden

Dear Mr. Hogan:

This responds to questions you asked in a letter that was faxed to Jeannette Greenfield of the National Highway Traffic Safety Administration (NHTSA) on May 19, 1998, and in telephone conversations with Walter Myers of my staff on June 3 and 11, 1998. Your questions concern several different requirements in Federal Motor Vehicle Safety Standard No. 106, Brake hoses (copy enclosed).

Registering a Designation

You explain that you manufacture vacuum brake hose assemblies for Saab Automobile AB (Saab). You state that you would like to "register the DOT label" and ask us to indicate acceptance of the labeling. Standard 106 does not require labeling to be registered, but instead requires manufacturers to file a designation with NHTSA that identifies the manufacturer as the assembler (S9.1.3). The manufacturer, in turn, labels the designation on the vacuum brake hose assembly. We have established a procedure by which our Office of Vehicle Safety Compliance will check to ensure that the designation you wish to use is not already in use, and will inform you under separate cover of the results of its review. I have enclosed a copy of the form you should complete and submit for this purpose.

Labeling the Assembly

The labeling requirements for vacuum brake hose assemblies are set forth in S9.1.3 of Standard 106. That section provides, among other things, that vacuum brake hose assemblies made with end fittings attached by crimping or swaging and plastic tube assemblies made with fittings attached by heat shrinking or dimensional interference fit, except those sold as part of a motor vehicle, shall be labeled either (a) with a band around the assembly, or (b) by marking an end fitting. If option (a) is used, the band must be etched, embossed, or stamped in block capital letters, at least 1/8 inch high, with the symbol "DOT" and the manufacturer's designation that has been filed with NHTSA. If option (b) is used, the assembly manufacturer may etch, stamp, or emboss at least one end fitting of the assembly with the manufacturer's designation, at least 1/16 inch high. You must mark your assemblies using one of these options.

Labeling the Hose With Supplemental Information

You ask whether you may add supplemental labeling to your product, in addition to the marking required by S9.1.3. You told Mr. Myers in your June 11 telephone conversation that Saab wants you to label your hoses as follows:

You explained to Mr. Myers that the "DOT" would indicate compliance with Standard 106; "HYCOP" would be your manufacturer's identification code; XXX would represent the day of manufacture, from 001 to 365, while XX would represent the year; 12.5 would indicate the outside diameter of the hose in millimeters; 1.25 would represent the thickness of the hose wall, also in millimeters; and that OD and VL would represent outside diameter and light duty vacuum brake hose, respectively.

It is permissible for you to label your hose with additional labeling, subject to the following. By marking the hose with the "DOT" symbol, you are indicating that the component complies with Standard 106. Standard 106 has hose marking requirements that you did not have to meet because your hose is sold as part of a hose assembly (see the exception in S9.1.1 that excludes such hose from the labeling requirement). While your hose is excluded from marking requirements, there are performance requirements in the standard that apply to it. We do not prohibit you from providing a repetitious certification (the "DOT" symbol) if you wish to mark the hose that way. However, if you undertake to mark your hose with the DOT symbol, you must mark your hose with the other markings required of vacuum hoses as well, as specified in S9.1.1 of the standard.

Subsection S9.1.1 of the standard sets forth the labeling requirements for bulk vacuum hoses. Those requirements are:

(a) The symbol "DOT", which constitutes the manufacturer's certification that the hose complies with applicable standards;

(b) The manufacturer's designation which, as noted above, is required to be filed with NHTSA;

(c) The month, day, and year or month and year of manufacture;

(d) The nominal inside diameter of the hose, expressed in inches or millimeters; or the nominal outside diameter of plastic tubing, again expressed in inches or millimeters (the abbreviation "mm" must follow hose sizes that are expressed in millimeters), followed by the letters "OD"; and

(e) The letters "VL" or "VH" indicating light or heavy duty brake hose, respectively.

Assuming that we accept "HYCOP" as your designation, your proposed labeling would comply with (a), (b), (c), and (e). However, as noted above, (d) calls for marking either the inside diameter of the hose or, in the case of plastic tubing, you can mark the outside diameter. In neither case is the thickness of the hose wall marked. Thus, the 1.25 figure representing the thickness of the hose wall must be removed. Further, the 12.5 for the outside diameter of the hose must be followed by "mm," indicating a measurement in millimeters, then followed by the letters "OD."

I hope this information is helpful to you. Should you have any questions or need further information, feel free to contact us at this address or by telephone at 001 801 10 (202) 366-2992, fax (202) 366-3820.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
d.7/10/98
ref: #106