Interpretation ID: aiam3379
Chief Car Safety and Regulation Engineer
Rolls-Royce Motors Ltd.
Car Division
Crew
Cheshire CW1 3PL
England;
Dear Mr. Ridgway: This responds to your letter concerning the labeling requirements o Standard No. 105 applicable to a separate indicator lamp concerning reservoir level. Your letter asked whether it is permissible to use words other than 'Brake Fluid' for vehicles which use hydraulic system mineral oil rather than conventional brake fluid. As explained below, the answer is yes.; Section S5.3.5 of Standard No. 105 states in relevant part: >>>...If separate indicator lamps are used for one or more of th various functions described in S5.3.1(a) to S5.3.1(d), the lens shall include the word 'Brake' and appropriate additional labeling (use 'Brake Pressure,' 'Brake Fluid' for S5.3.1(a) and S5.3.1(b) except that if a separate parking indicator lamp is provided, the single word 'Park' may be used....<<<; As your letter pointed out, conventional brake fluid and hydrauli system mineral oil are not compatible. Safety Standard No. 116, *Motor Vehicle Brake Fluids*, differentiates between 'brake fluid' and hydraulic system mineral oil.'; We interpret section S5.3.5 to require the use of the words 'Brak Fluid' only for vehicles which use conventional brake fluid. The section's use of the word 'appropriate, ' prior to its statement that 'Brake Fluid' be used for S5.3.1(b), indicates that the labeling set forth in the parentheses need only be used where it adequately describes the fluid being used. For vehicles which use hydraulic system mineral oil, or other types of non-conventional brake fluid which might be developed in the future, the general requirement for the word 'Brake' and appropriate additional labeling is applicable.; We are concerned, however, about your proposed use of the words BRAK HSMO/LHM, since we doubt that many persons would understand that HSMO/LHM is an abbreviation for hydraulic system mineral oil/liquide hydraulique minerale. We suggest that you consider using the words 'BRAKE MINERAL OIL' or similar language that more persons would understand.; Sincerely, Frank Berndt, Chief Counsel