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Interpretation ID: nht75-1.47

DATE: 05/21/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: Hon. Alan Cranston, U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT: I am writing in response to your letter of April 14, 1975, in which you requested information on Federal Motor Vehicle Safety Standard No. 106-74 (49 CFR Part 571.106-74) and its relation to the enclosed letter you had received from Mr. Thomas Z. Marshall of San Francisco.

Standard No. 106-74 specifies performance and labeling requirements for motor vehicle brake hose, brake hose end fittings, and brake hose assemblies. Because labeling applied to hose and end fittings cannot satisfactorily identify the manufacturer of an assembly made up of those components, S7.2 of the standard (by incorporating S5.2.4) requires certain assemblies to be labeled by means of a band. By identifying the manufacturer and the date of production, this band permits both the enforcement of the standard's performance requirements and the tracing of defective assemblies.

Mr. Marshall appears to have misunderstood some aspects of the standard. While each manufacturer of brake hose assemblies must initially inform the NHTSA of the identifying designation he intends to use on his bands, there is no requirement that he keep records of assemblies made or send such records to this agency. In addition, the bands need not be metallic, but may be of other materials which are less expensive to produce. Mr. Marshall has correctly pointed out, however, that the standard in its present form specifies the same requirements for large manufacturers, repair shops, and individual truck owners. In recognition of the burdens thus imposed on a person who manufacturers only a small number of assemblies, the NHTSA proposed an amendment of the definition of brake hose assembly, to exclude certain assemblies from the requirements of the standard (40 FR 8962, March 4, 1975, copy enclosed). We expect to act on that proposal in the near future.

Sincerely,

2 Enclosures Constituent's letter

United States Senate WASHINGTON, D.C. 20518

April 14, 1975

To: Office of Congressional Liaison -- Department of Transportation

Enclosure from: Thomas Z. MArshall -- Waits Motor Supply Co., 234 - 7th Street, San Francisco, California 94103

Re: Please explain and give current information on the new truck regulation, 106 Air Brake Standard.

I forward the attached for your consideration.

Your report, in duplicate, along with the return of the enclosure will be appreciated.

Sincerely

Alan Cranston

Please address envelope to: Senator Alan Cranston Senate Office Building Washington, D.C. 20510

Att: M. Bleeke

Feb. 18, 1975

Senator Alan Cranston Senate Office Bldg., Washington, D.C.

re: FMVSS(DOT) 106 Air Brake Standard

Dear Senator Cranston:

Please have some of your staff look into what the National Hwy. Traffic Safety Commission is up to.

I am enclosing a reprint of only a portion of the subject regulation.

Please understand that these people are requiring that over 400,000 truck fleets, shops, and purveyors of hose register and receive a registration number; (2) Each fabricator (except Original Equipment Manufacturer) will have to fabricate a metal tag and affix same to assembly (3) he will also have to keep records of assemblies made and send these reports to Wash.

Can you see the number of bumbling bureaucrats the administration of this law will require. I heard today that one enterprising manufacturer is out selling a tag marking machine at $ 80 each. Multiply that out and see what a windfall profit someone is going to make; to say nothing of the profit in the repeat sale of the blank tags themselves.

Someone has sold this agency a bill of goods. They don't want to listen to reason. They are hell bent to see that their stupidity doesn't come to light.

Someone must rise up and say, "let's wait a minute."

Do you realize that the owner of one truck, if he does his own repair, will have to register if he wants to save money by making his own hose assembly? This is where this regulation is viscious and inflationary.

If you are just going to send me the usual "kiss off" letter and file this in the file 13, don't bother to reply. If you are really interested in looking into this rather than the headline grabbing CIA, FBI and Watergate matters, I would appreciate hearing from you.

Very truly yours, Thomas Z. Marshall, Pres. -- WAIT MOTOR SUPPLY CO.

Labeling

A. Hose and Tubing

1. Must have a layline consisting of the following:

a. The symbol DOT, constituting a certification by the manufacturer that the hose and tubing conforms to all applicable motor vehicle safety standards.

b. Manufacturers identification can presently be any symbol, trademark, letters, etc., which have been files by letter with NHTSA. Our (Illegible Symbol) has been registered and will be used on hose, tubing and couplings manufactured by I-E.

c. The month, day or year, or the month and year of manufacture, expressed in numerals.

d. The nominal inside diameter of the hose expressed in inches or fractions of inches, or the nominal outside diameter of the tube expressed in inches or fractions of inches followed by the letters OD.

e. The letter "A" to indicate the hose or tube is for use in "Air Brake" assemblies.

2. No additional information is allowed on the DOT layline; however, a second layline (180 degrees away) is permissible with any information desired. I-E hose and tubing will have an additional layline to identify our style, size, etc.

3. Examples of DOT hose and tube marking:

(Graphics Omitted)

B. Couplings

1. All reusable and renewable couplings must be labeled.

Permanently attached crimped or swaged couplings do not require any marking.

All fittings which are labeled need the DOT marking on only one piece of the coupling.

2. Coupling marking shall be as follows:

a. The symbol DOT, constituting a certification by the fitting manufacturer that the end fitting conforms to all applicable motor vehicle safety standards.

b. Manufacturer identification. Our (Illegible Symbol) has been registered and will be used on couplings manufactured by I-E.

c. The letter "A" to indicate the fitting is for use in "Air Brake" hose assemblies.

d. The nominal inside diameter of the hose to which the fitting is properly attached expressed in inches or fractions of inches, or the outside diameter of the tube to which the fitting is properly attached expressed in inches or fractions of inches followed by the letters OD.

3. Example of DOT coupling marking:

(Graphics Omitted)

C. Assemblies

1. As of March 1, 1975 each brake hose assembly, except those assembled and installed by a vehicle manufacturer in vehicles manufactured by him, shall be labeled by means of a band around the brake hose assembly. The band may be attached so as to move freely along the length of the assembly, as long as it is retained by the end fittings.

2. The band shall be permanently etched, embossed, or stamped with the following:

a. The symbol DOT, constituting certification by the hose assembler that the hose assembly conforms to all applicable motor vehicle safety standards.

b. A designation that identifies the manufacturer of the hose assembly. Our (Illegible Symbol) with a letter indicating assembler has been registered and will be used on hose assemblies manufactured by I-E.

c. The month, day and year, or the month and year of assembly.

2. Example of DOT hose assembly band marking:

(Graphics Omitted)

Summary

1. The new regulations are law and everyone concerned with vehicle brake hoses, brake hose end fittings and brake hose assemblies used on vehicles manufactured for use on the public streets, roads and highways must comply.

2. State of Pennsylvania Approval of Air Brake Hose. Until recently it was apparent that the labeling of air brake hose would still be required. However, Pennsylvania has bowed to federal jurisdiction and will now accept FMVSS 106 as the governing authority for brake hose assemblies.

It is still necessary for hose manufacturers to obtain Pennsylvania State approval on all brake hoses. Only now the approval testing will be done to the FMVSS 106 requirements and not SAE requirements.

3. Please remember that FMVSS 106 pertains only to products intended for use in brake systems. Any I-E hose or fittings manufactured for use in auxiliary air or hydraulic applications can be used without falling under the jurisdiction of FMVSS 106.

4. Registration.

A designation that identifies the manufacturer of the hose, hose fittings and hose assembly shall be filed in writing with:

Office of Standards Enforcement Brake Hose Identification National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Reference: FMVSS 106

5. Questions on FMVSS 106.

Anyone may contact the National Highway Traffic Safety Administration for interpretations of the standard. If calling, they may answer your question on the telephone, but will probably ask that you put the questions in writing and send you a letter in reply.