Interpretation ID: nht75-1.39
DATE: 03/18/75
FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA
TO: Bendix Heavy Vehicle Systems Gp.
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your letter of February 14, 1975, requesting an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses.
You have asked whether Bendix may use the same manufacturer identification designation on brake hose, brake hose end fittings, and brake hose assemblies manufactured at three plants which are geographically separated. While S5.2 of Standard No. 106-74 requires designations identifying the manufacturer of these components, nothing in the standard prohibits a single manufacturer from applying the same designation to components manufactured at different plant locations.
Yours truly,
ATTACH.
Bendix
Heavy Vehicle Systems Group
Mark Schwimmer, Attorney -- Office of Chief Counsel, National Highway Traffic Safety Administration
February 14, 1975
Subject: Docket 1-5; Notice 9, FMVSS No. 106 -- Brake Hose Identification
Ref.: Letter from F. Armstrong to R. W. Hildebrandt dated July 1, 1974.
Phone conversation of R. G. Brewer and M. Schwimmer dated February 6, 1975.
Dear Mr. Schwimmer:
As per the above referenced phone conversation of February 6, 1975, The Bendix Corporation, Heavy Vehicle Systems Group, desire a clarification on the Manufacturer Identification Regulation.
A hose assembly identification designation has previously been assigned to our organization. Hose assemblies are manufactured at three plants which are geographically separated. The same management is responsible for operation of the three plants. All engineering is done at one location and hose assembly designs at the three plants are identical. In addition, identical quality control standards are maintained at all plants.
Does the Regulation permit our Corporation to manufacture hose, hose fittings, and hose assemblies under FMVSS No. 106 in more than one plant location with the same identification designation? Can the identification designation be used at all plant locations.
We would appreciate a reply at your earliest convenience.
Very truly yours, R. W. Hildebrandt -- Group Director of Engineering cc: R. Daley
POWER CONTROLS DIVISION -- Midland-Ross Corporation
January 16, 1975
Mark Schwimmer -- Office of the Chief Counsel, National Highway Traffic Safety Administration
Dear Mr. Schwimmer:
As relayed in our telephone conversation of January 14, 1975, we are interested in the relationship between the requirements of Federal Motor Vehicle Safety Standard 106 and Military Specification MIL-H-3992C. Both of these refer to automotive air and vacuum brake hoses.
Several questions have been raised regarding the applicability of these two documents with respect to hose purchased to the MIL-H-3992C specification (either for military or commercial use). We would appreciate rulings by you or your office to the following specific questions:
1. Both MIL-H-3992C and FMVSS 106 require specific labeling on the hose and on a tag on the assembly. Is it necessary for sale to the military to run two lines of identification (one per MIL-H-3992C and the other per FMVSS 106) on this hose? Likewise for commercial sale? Is it necessary for sale to the military, to include both the FMVSS 106 and the MIL-H-3992-C requirements on the assembly tag? Likewise for commercial sale?
2. Would hose manufactured and sold to the MIL-H-3992C specification also be required to meet the physical requirements of FMVSS 106 for military applications? Likewise for commercial applications?
Very truly yours, Leon C. Huneke -- Chemical Engineer