Interpretation ID: aiam2339
Chief Engineer
Parker Hannifin Corporation
Hose Products Division
30240 Lakeland Boulevard
Wickliffe
Oh 44092;
Dear Mr. Currie: #This is in response to your March 24, 1976, lette concerning the application of the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to thermoplastic tubing of 1/8 inch nominal outside diameter that is used in 'auxiliary air equipment rather than the brake system itself. #You have pointed out that it is difficult to label tubing of this diameter with letters that are 1/8 inch high, and requested an amendment of the standard to permit the labeling of such brake hoses with letters that are 1/16 inch high. #Because the tubing that you have described is not manufactured for use in the brake system itself, it is not 'brake hose' as that term is defined in Standard No. 106-74 and is therefore not subject to any of the standard's requirements. In fact, although the standard does not prohibit the manufacture of air brake hose of 1/8-inch outer diameter, we are unaware at this time of the existence of any hose or tubing of that diameter that meets the definition of 'brake hose'. Therefore, the conformity or nonconformity of the tubing in question is a matter of private contract between Parker Hannifin Corporation and those truck manufacturers that are requesting conformity. #In consideration of the possibility that 1/8-inch outer diameter tubing may in the future be used in brake systems, however, there NHTSA has decided to grant your petition to reduce to 1/16 inch the minimum required lettering height on brake hoses of such diameter. Accordingly, a proceeding respecting the issuance of a notice of proposed rulemaking has been commenced. #You should understand that our commencement of a rulemaking proceeding does not signify that the requested amendment will necessarily be issued. A final decision concerning the issuance of a proposal to amend the standard will be made on the basis of all available information developed in the course of the proceeding, in accordance with statutory criteria. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs;