Interpretation ID: nht72-1.12

DATE: 04/25/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 5 to Mr. Schneider asking for an interpretation of Standard No. 106.

You ask whether it is permissible to use a rubber protector on a brake nose which masks in part the identification marking required by Standard No. 106. SAE Standard J40b, Automotive brake Hoses, incorporated by reference in Standard No. 106, requires hose working to be permanent in nature. Therefore, use of this protector is permissible, provided that its rubbing effect, if any, does not oblitorate in time the required marking.

You have also asked whether you may conduct the whip test with the rubber protector removed. We have no objection to this method of conducting the whip test. Standard No. 106 is silent as to how the test may be conducted. Paragraph 57.1.4 of our proposal to amend Standard No. 106 (Docket No. 1-5; Notice 7, 36 F.R. 5855, March 30, 1971) represents our view that "protective armor" should be removed for the fatigue test, and you may interpret this as including the rubber protectors also.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

April 5, 1972

Lawrence Schneider National Highway Traffic Safety Administration

SUBJECT: Interpretation of MVSS 106.

We would like to have your interpretation regarding MVSS 106-Hydraulic Brake Hoses, (1) whether or not we may use the rubber protector which would hide the marking on brake hose in part. (Protector itself is not glued, but envelopes the hose tightly so it could be movable when relatively strong force is applied.) (2) whether or not we may conduct the whip test with the rubber protector removed.

Your assistance in this matter would be greatly appreciated.

Satoshi Nishibori Engineering Representative Liaison Office in U. S. A.