Interpretation ID: aiam2035
Director of Engineering
American Trailers
Inc.
1500 Exchange Avenue
Box 26568
Oklahoma City
Oklahoma 73126;
Dear Mr. McNeil: #This responds to your letter of August 12, 1975 concerning the application of Federal Motor Vehicle Safety Standard No 106-74, *Brake Hoses*, to an anchor coupling. #You enclosed a diagram depicting the installation of two of these couplings, and suggested that they are not subject to the labeling requirements of the standard. This interpretation is correct. 'Brake hose end fitting' is defined in Standard No. 106-74 as: #>>>a coupler, other than a clamp, designed for attachment to the end of a brake hose.<<< #The anchor couplings which you have described are attached to the ends of completed brake hose assemblies, rather than to the ends of brake hoses. Therefore, they are not 'brake hose end fittings' subject to the standard's requirements. #It appears from your letter that you might not consider the nylon tubing to be 'brake hose'. If the nylon tubing is flexible, However, such an interpretation would be incorrect. 'Brake hose' is defined in the standard as: #>>>a flexible conduit manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.<<<# Thus flexible chassis plumbing and other flexible conduits, in addition to rubber brake hoses, are subject to the standard's requirements. #Sincerely Frank A. Berndt, Acting Chief Counsel;