Interpretation ID: nht74-4.8

DATE: 07/03/74

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

TO: Continental Hydraulic Hose Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 16, 1974, request for approval of Continental's banding technique to meet the requirements of Standard No. 106 Brake hoses, for labeling brake hose assemblies, and for use of the letter "C" to identify Continental as an assembly manufacturer.

The NHTSA interpretes a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of specific design.

The letter "C" has already been recorded with the Office of Standards Enforcement as the manufacturer designation for Continental Gummi-Werke A. G. of Germany. Please submit another choice to: Office of Standards Enforcement, "Brake Hose Identification", National Highway Traffic Safety Administration, 400 Seventh St. S.W., Washington, D.C. 20590.

Continental Hydraulic Hose Corp.

National Highway Traffic Safety Administration

Attention: Mr. Herlehy

Subject: MVSS-106 Docket 10

Dear Sir:

Continental Hydraulic Hose manufacture hydraulic brake hose assemblies. We also make the end fittings but purchase the hose. The fittings are permanently crimped in place.

Reference is made to paragraph S5.2.4 of Docket 10 which relates to labeling by the hose assembler. We propose:

1) That our designation be the letter "C".

2) That the band be a strip of adhesive backed vinyl tape wrapped securely around the skirt of one end fitting. The tape would be preprinted in 1/8" letters with:

DOT

C (our code) Month and year.

Please advise if the above is acceptable.

Sincerely,

James W. Long