Interpretation ID: nht93-7.38

DATE: October 22, 1993

FROM: Jim Davis -- President, Russell Performance Products

TO: David Elias -- Chief Counsel, DOT

COPYEE: Bill Collins -- Titeflex; Rick Rohauer -- Russell

TITLE: None

ATTACHMT: Attached to letter dated 5/12/94 from John Womack to Jim Davis (A42; Std. 106), letter dated 10/22/93 from Jim Davis to NHTSA Office of Vehicle Safety Standards, Crash Avoidance Division, and letter dated 11/16/93 from Jim Davis to David Elias

TEXT:

I am writing to you to formally describe our involvement with Titeflex Industrial Americas with respect to the submission Titeflex has made to the D.O.T. with regard to brake hoses and brake hose assemblies that meet D.O.T. Specification MVSS 106.

Titeflex developed a hose, hose end, and assembly procedure to produce a brake hose assembly utilizing a Teflon inner liner hose with a stainless braided outer covering that meets D.O.T. Specification MVSS 106. These hose assemblies have passed all the pertinent tests and these test results are on file with the D.O.T. from Titeflex Industrial Americas.

Titeflex has in turn given Russell Performance Products the exclusive license to manufacture, assemble, and market these hose assemblies to the marketplace. Titeflex supplies Russell with the Teflon stainless braided hose used in these assemblies. Russell manufactures the hose ends utilizing Titeflex engineering drawings. Russell permanently assembles the Titeflex hose to the Titeflex designed and Russell manufactures hose ends using special crimping machines. Russell personnel have been trained in these assembly procedures by Titeflex personnel.

Russell has also filed a copy of our identifying logo, a stylized symbol "R", with the Office of Vehicle Safety Standards. Russell is selecting the option provided in S5.2.4.1 of MVSS 106 to identify each hose assembly produced by Russell Performance Products that will be marketed as a hose assembly that meets D.O.T. Specification MVSS 106.

We are awaiting directions from your office as to whether both the Russell "R" and the Titeflex "T" need to be stamped, etched or engraved on one hose end of the hose end assembly or whether just the Russell "R" will suffice.

The other issue which needs to be addressed is if the raw hose that we purchase from Titeflex has to be identified per S5.2.2. Due to the construction of the hose which has a stainless braided outer covering it is impossible to print any data directly on the hose as is commonly performed on rubber hose. To apply identifying labels every six inches is also impractical.

Russell and Titeflex's position is that this is not necessary for the following reasons:

1. Russell is the only marketer of this hose making the claim that it meets D.O.T. Specification MVSS 106. As a result of this exclusive arrangement the source of the hose, once it is made into an assembly by Russell and placed into use by a consumer, is directly traceable only to Titeflex in the event of any problem in the field. Titeflex will be the ONLY supplier of such hose to Russell. 2. Assuming the date of manufacture requirement has to do with determining shelf life on normal rubber hose, our position is that stainless braided covered Teflon hose has relatively unlimited shelf life and the actual date of manufacture is not an issue.

We submit that by identifying the hose assemblies with the Russell symbol "R" and additionally with the Titeflex symbol "T" provides all the traceability required to meet the intent of the D.O.T. specifications.

I believe this covers everything we discussed on the phone. If I have missed anything or you need further clarification on any points, please let me know.