Interpretation ID: aiam4384
Q.A. Manager
Lyn-Mont Manufacturing Co.
P. O. Box 11745
4208 Clubview Drive
Fort Wayne
Indiana 46860;
Dear Mr. Crawford: This responds to your letter concerning Safety Standard No.. 106 *Brake Hoses*. You asked whether certain proposed labeling for brake hose assemblies would meet the labeling requirements of sections S7.2.3 and S7.2.3.1. As discussed below, the answer to your question is no.; By way of background information, this agency does not provid approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its products comply with applicable safety standards. The following opinion is based on the facts provided in your letter.; Sections S7.2.3 and S7.2.3.1 provide two options for the labeling o air brake hose assemblies made with end fittings that are attached by crimping or swaging. Section S7.2.3 states that such assemblies, except those assembled and installed by a vehicle manufacturer in vehicles manufactured by him, shall be labeled by means of a band around the brake hose assembly as specified in that paragraph, or, at the option of the manufacturer, by means of labeling as specified in section S7.2.3.1.; If the first option is chosen, using a band as specified in sectio S7.2.3, the band must include (a) the symbol DOT, and (b) the manufacturer designation. If the second option, specified in section S7.2.3.1, is chosen, the manufacturer designation must be placed on at least one end fitting of the assembly. (These sections also specify other requirements concerning labeling, such as size of letters, which are not relevant to this interpretation.); Your proposed labeling, placing the manufacturer designation on th band and the symbol DOT on the end fitting, would not meet the requirements of either of these options. If the first option is chosen, the symbol DOT must be placed on the band along with the manufacturer designation. If the second option is chosen, the manufacturer designation must be placed on the end fitting.; Sincerely, Frank Berndt, Chief Counsel