Interpretation ID: nht75-1.33

DATE: 08/25/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: John H. Mueller -- Manager, Engineering Standards

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of March 25, 1975, which suggested an inconsistency in the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses.

S5.1 of the standard requires each hydraulic brake hose assembly to be equipped with end fittings which are attached by means of crimping or swaging. You have correctly pointed out that S5.2.3 specifies labeling requirements for "hydraulic" end fittings which are neither crimped nor swaged, even though at present there are no hydraulic fittings that fit that description. This language appears as part of S5.2 because S5.2 is incorporated by reference in and assemblies used in air and vacuum brake systems, respectively. Although there is thus no inconsistency, the National Highway Traffic Safety Administration is considering a clarifying amendment along the lines you have suggested, which would eliminate S5.2.3 and specify the labeling requirements directly in S7.2 and S9.1.

Thank you for pointing out this potential source of confusion.

Sincerely,

March 25, 1975

Reference: MUE-534

Richard B. Dyson -- Assistant Chief Counsel, National Highway Traffic Safety Administration

Subject: FMVSS 571.106 Para. S5.2.3 Labeling Hydraulic Brake Hose End Fittings

Dear Mr. Dyson:

The standard erroneously specifies labeling for certain end fittings that are not allowed by the standard's construction requirements. Please consider the following explanation and recommendation.

Notice 16 reiterates that hydraulic brake hose assemblies must be made with the end fittings crimped or swaged onto the hose. Consistent with the Notice, Paragraph S5.1 requires all assemblies to be crimped or swaged. Unfortunately, Paragraph S5.2.3 then explains how to label end fittings that are not crimped or swaged.

Since the standard does not allow end fittings for hydraulic brake hose that require labels, no label should be described. An appropriate correction would be to drop Paragraph S5.2.3 from the standard. Air brake hose end fittings that do require labels could then be regulated under Paragraph S7.

Yours very truly,

THE WEATHERHEAD COMPANY --

John H. Mueller,

Manager, Engineering Standards