Interpretation ID: nht74-1.14

DATE: 07/03/74

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

TO: Imperial-Eastman Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 2, 1974, questions concerning the labeling of multi-piece end fittings, the use of hose marked with the DOT symbol in non-brake applications, and the acceptability of an end fitting design under the requirements of Standard No. 106, Brake hoses.

The answers to your first two questions will appear in the upcoming notice responding to petitions for reconsideration of amendments to Standard No. 106.

As to the acceptability of a certain end fitting design, the standard specifies performance requirements for end fittings. Any design which meets the specifications of the standard may be manufactured after the effective date of the standard.

Yours truly,

May 2, 1974

Docket Room National Highway Traffic Safety Administration

Ref: FMVSS106, Docket 1-5, Note 10

Gentlemen:

Imperial-Eastman Corporation, a manufacturer of brake hose, couplings, and hose assemblies have a direct interest in FMVSS106, and hereby submit the following comments or requests for interpretations; they are not items for petition.

1. S7.2 Labeling

"Except for two-piece end fittings that are attached by deformation of the fitting about a hose by crimping or swaging, each air brake hose end fitting shall be permanently etched, embossed or stamped, in block capital letters and numerals at least one-sixteenth of an inch high with the DOT labeling information."

We assume that on three-piece air brake hose end fittings which utilize sacrificial sleeves or ferrules, and are considered permanently attached end fittings, that it would be permissible to mark only the coupling nut, with the DOT labeling information.

2. Thermoplastic air brake hose in accordance with SAE J844, Type 3 is currently being used by practically most major truck manufacturers in the United States on original equipment. This hose is normally used to replace copper tubing and/or rubber hose in air brake systems.

This type of thermoplastic hose with air brake hose end fittings is also used for auxiliary lines to windshield wipers, air horns, pressure gages, etc., and for fuel lines.

Fittings and/or fitting components used in these applications may be identical with those used in and marked for air brake applications. Is it permissible for these items to retain the DOT labeling information when used in these other applications?

3. The SAE has a committee which has proposed a fitting performance specification for SAE J844, Type 3, Nylon air brake tubing. One of the types of fittings that meet this performance specification and is currently being used by most major truck manufacturers on air brake systems, consist of a nut, sleeve, tube support and body. The tube support is a brass eyelet, pressed into the body by the coupling manufacturer, which prevents collapse of the tubing. The body is a standard air brake body which meets SAE J246 Standard. For service replacement a loose eyelet and sleeve are provided.

Such fittings are neither described within the DOT Standard, nor specifically excluded from it. Assuming that such fittings are qualified to the DOT test requirements of the standard, and are marked in accordance with the standard, may we then assume they are acceptable?

Sincerely,

IMPERIAL-EASTMAN CORPORATION Imperial Division

Robert C. Gibson Standards and Specifications Engineer