Interpretation ID: aiam2062
Imperial-Eastman Corporation
1440 North 24th Street
Manitowoc
Wisconsin 54220;
Dear Mr. Kronschnabel: #This is in response to your letter of May 28 1975, in which you petitioned for the replacement of the 'permanent' labeling requirement for brake hose in Standard No. 106-74 with a 'weather resistant' test requirement. You also asked whether a series of dots may be included after the required date information on the hose, to indicate in coded form the day of manufacture. #With respect to your petition, this agency is reconsidering the permanency requirement for the labeling, and a notice is planned for issuance shortly on that subject. We do not find an additional test requirement for the labeling to be justified, on the basis of data presently before the agency, since the usefulness of the labeling is limited primarily to the preassembly period. Therefore, in the strict sense, your petition is hereby denied. You may find, however, that the changes now being developed in our rulemaking proceedings will resolve your problems in this area. #The standard does not permit the use of coded dots indicating production date in the location specified for the required information. S5.2.2(c) specified the following information as part of the required label: #>>>The month, day and year, or the month an year of manufacture, expressed in numerals. For example, 10/1/74 means October 1, 1974.<<<# Our interpretation of S5.2 (as incorporated in S7.2) is that the required information may not be interrupted by optional information. Therefore, the day of manufacture, if indicated as part of the S5.2.2 legend, must be expressed in numerals. You may, of course, use the coded dots if they appear on the opposite side of the hose. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs;