Interpretation ID: 77-1.47

TYPE: INTERPRETATION-NHTSA

DATE: 03/17/77

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Lucas Industries North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 4, 1977, question whether Safety Standard No. 116, Motor Vehicle Brake Fluids, permits DOT 3 and DOT 4 brake fluids to be colored "fluorescent yellow."

The answer to your question is yes. Paragraph S5.1.14 of Standard No. 116 specifies that DOT 3 and DOT 4 fluids manufactured on or after September 1, 1978, shall be "colorless to amber." The agency interprets this color range to include any "yellow," whether or not fluorescent. Although not required, we consider fluorescence to be an added safety factor since it would facilitate the detection of leaks in the braking system.

Sincerely,

ATTACH.

Office of the Chief Counsel -- National Highway Traffic Safety Administration

Dear Sir

Federal Motor Vehicle Safety Standard No. 116 - Brake Fluids

Girling Limited manufactures motor vehicle brakes in the United Kingdom and also markets brake fluid. Girling Limited, like ourselves, is a subsidiary of Lucas Industries Limited of England. Girling products enter this country as original equipment on imported vehicles and, also, we import and market their products.

We wish to know whether "fluorescent yellow" is an acceptable color for DOT 3 and DOT 4 motor vehicle brake fluids. The definition of clear-to-amber does not make this apparent.

Yours truly

LUCAS INDUSTRIES NORTH AMERICA INC;

A J Burgess -- Vice President (Technical)

cc: F Redler, NHTSA