Interpretation ID: 86-5.26

TYPE: INTERPRETATION-NHTSA

DATE: 09/29/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. William C. Fisher

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. William C. Fisher Product Engineer Parker Hannifin Corporation Parflex Division 1300 North Freedom Street Ravenna, OH 44266

Dear Mr. Fisher:

Thank you for your letter and enclosure regarding the labeling requirements for air brake hose assemblies set forth in Standard No. 106, Brake Hoses. I regret the delay in our response. We have referred the matter to our enforcement division to obtain more information about the assemblies you enclosed. We will return the samples of brake hose assemblies you sent, as you requested, when our examination is completed.

Sincerely,

Erika Z. Jones Chief Counsel

National Highway Traffic Safety Admin. Department of Transportation Office of Chief Council, NOA32 Room 5219 400 Seventh Street, S.W. Washington,D.C. 20590

Attention : Ms. Deirdre Hom, Attorney Advisor

Subject: D.O.T. Safety Standard 106 Section 7.2.3, Parts a and b - Identification of brake tubing assemblies by banding; Section 7.2.3.1 - End fitting marking to D.O.T. regulations.

Dear Deirdre:

Per our recent conversation, I have enclosed samples of the air brake end fittings which we contend are not in compliance with DOT 106 regulations. These assemblies were permanently ". . attached by crimping or swaging. ." a brass collar to the nylon tubing. This would, in our opinion, constitute a permanently attached fitting which is not reusable. In addition, no identification band was found on the coil assembly, and all end fittings lack D.O.T. identification markings.

I request that you review these samples and render a decision on the following questions:

1) Do these samples constitute permanently attached fittings under Section 7.2.3?

2) Is the attachment of a D.O.T. identification band required on brake hose assemblies made with this type of end fitting?

3) Is the end fitting identification marking in compliance with DOT 106 regulations?

I have enclosed for review, a current production sample of a Parker brake coil assembly that complies with DOT 106 regulations.

I request that these samples be returned to me at the Parker Parflex Division upon completion of your study.

Ms. Deirdre Hom Page 2

Your swift attention to this matter will be appreciated. If you have any additional questions, please contact me at (216) 296-2871, ext. 259.

Very truly yours,

William C. Fisher Product Engineer

WCF:dm

Enclosures

1) Unidentified brake hose end fitting (Section Out) 2) Unidentified brake hose end fitting 3) Parker brake coil assembly

cc: William Hertel, Corporate Staff Engineer, Parker Hannifin Corp. Mark Kugelman, General Marketing Mgr., Parker Hannifin Corp. Robert Wiseman, Plant Mgr., Parker Hannifin Corp.