Interpretation ID: nht88-2.44

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 7, 1988

FROM: WILLIAM SHAPIRO -- MANAGER -- REGULATIONS AND COMPLIANCE, VOLVO

TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: FEDERAL MOTOR VEHICLE SAFETY STANDARD NUMBER 106; BRAKE HOSES-REQUEST FOR INTERPRETATION

ATTACHMT: ATTACHED TO MEMO DATED 12-9-88, TO WILLIAM SHAPIRO, FROM ERIKA Z. JONES -- NHTSA, STD 106

TEXT: Section 5.3 sets forth the test requirements for hydraulic brake hoses. This section states that:

"A hydraulic brake hose assembly or appropriate part thereof shall be capable of meeting any of the requirements set forth under this heading, . . . However, a particular hose assembly or appropriate part thereof need not meet further requirements aft er having been subjected to and having met the constriction requirement (S5.3.1) and any one of the requirements specified in S5.3.2 through S5.3.11."

Sections S5.3.3 and S6.3 speak to the Whip Resistance Test. Table 11 in Section S6.3.1 specifies slack for different hose configurations. In Table 11 for a hose "over 19 to 24 inches inclusive", and "more than 1/8 inch or 3mm." there is no slack specif ied and therefore no requirement in the standard.

Volvo believes that the correct interpretation of this standard, for a hose that falls into the category of over 19 to 24 inches, inclusive, and more than 1/8 inch or 3mm. in diameter is that, while it must meet or exceed the constriction requirement, an d any one other of the requirements in Section S5.3, it need not be tested to meet or exceed the whip resistance requirement to be in compliance with FMVSS 106. Please confirm this for us.

Thank you for your attention to this matter. If you require any additional information, please feel free to contact me.