Interpretation ID: nht74-5.28

DATE: 03/19/74

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Girling Limited

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Girling's February 22, 1974, petition for abbreviated labeling on short(Illegible Word) hose in cases where the 6-inch interval required by S5.2.2 of Standard 106, Brake hoses, makes complete labeling impossible.

The National Highway Traffic Safety Administration has modified the labeling requirement of February 26, 1974 (39 FR 7425) by specifying an interval of "not more than 6 inches" to permit the manufacture and labeling of short hose length without waste. Lettering may be any width so long as it is at least one-eighth of an inch high. Your petition, therefore, is denied as unnecessary.

Sincerely,

Chief Counsel, National Highway Traffic Safety Administration,

February 22, 1974

Part 571 - Federal Motor Vehicle Safety Standards Standard No. 106 - BRAKE HOSES (Docket No. 1-5; Notice 8)

Standard No. 106, Brake Hoses (Docket No. 1-5; Notice 8) published in the Federal Register Vol.38, No.218 of November 13, 1974, requires Vacuum Brake Hoses to be labelled at 6 inch intervals with the following information, using letters at least 1/8 inch high -:

1) Symbol DOT

2) Manufacturers identification (for example, GY)

3) Month & year of manufacture (for example, 10/74)

4) Inside diameter of the hose (for example, 13/32)

5) VL or VH

It has become apparent that some brake system installations use vacuum hoses which are less than 6 inches long, sometimes only 1 1/2 inches long - and it appears physically impossible to print all of the above labelling requirements on some of these short vacuum brake hoses.

The various US State legislatures (for example, Pennsylvania) have always accepted this situation in relation to their brake hose labelling requirements and permitted vacuum brake hoses with only items 1) and 3) labelled, adding item 2) if possible.

We would therefore propose that very short vacuum brake hose lengths may be labelled: DOT - 10/74 and if possible: DOT - GY - 10/74.

We would very much appreciate your early, favourable ruling on this proposal.

P. Oppenheimer, Technical Legislation Manager