Interpretation ID: nht74-4.23
DATE: 08/12/74
FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA
TO: The Weatherland Company
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your July 10, 1974, request to modify the hose labeling provisions of Standard No. 106-74, Brake hoses, to permit DOT labeling of 1/8-inch O.D. nylon tubing.
To the best of our knowledge 1/8-inch O.D. tubing is not used as brake hose as it is defined by the standard:
"Brake hose" means a flexible conduit manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.
The tubing is used for pressure gauge lines and in two-speed differentials, but is apparently not used to transmit or contain the pressure used to apply force to a vehicle's brakes. As it is not considered to be brake hose under the standard, it should not be labeled with the DOT symbol.
Aside from this prohibition on the use of the DOT symbol, you are free to label 1/8-inch O.D. nylon tubing as you choose.
The Weatherhead Company
July 10, 1974
Ref. MUE: 468
Mr. Richard B. Dyson Assistant Chief Counsel U.S. Department of Transportation
SUBJECT: Air Brake Hose Labeling 571.106
The Weatherhead Company manufactures nylon air brake tubing (hose) covered by FMVSS 571.106 (effective September 1, 1974). The DOT labeling requirements for this product specified in the safety standard calls for at least 1/8 inch high letters. One of the common sizes of tubing (hose) (1'8 inch outside diameter) used in truck air brake systems does not have adequate outside surface area to accomodate 1/8 inch high lettering.
A specific exemption of this label requirement is requested to allow The Weatherhead Company to DOT label nylon air brake tubing (hose) of 1/8 inch outside diameter with letters smaller than 1/8 inch high.
Since this standard becomes effective September 1, 1974 for manufacturers of hose and because a lead time is necessary to obtain new DOT labeling equipment, a prompt reply to this request would be greatly appreciated.
JOHN H. MUELLER
Manager - Engineering
Standards & Specifications
ENCL.-SAMPLE