Interpretation ID: nht93-8.20

DATE: November 16, 1993

FROM: Jim Davis -- President, Russell Performance Products

TO: David Elias -- DOT

COPYEE: Bill Collins -- Titeflex

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 David Elias (OCC-9249), and letter dated 10/22/93 from Jim Davis to NHTSA Office of Vehicle Safety Standards, Crash Avoidance Division

TEXT:

After our recent phone conversation I re-read my copy of NHTSA's 49 CFR Ch. V (10-1-88 Edition) covering the marking of brake hose assemblies. Unless I am reading this incorrectly, it seems that we do not need marking on the hose once it has been made into an assembly.

S5.2.2 says that "Each hydraulic brake hose shell be labelled or cut from bulk brake hose that is labelled, etc." But then it goes on to say that "The formation need not be present on hose once it has become part of a brake hose assembly or after it is installed in a motor vehicle." It would seem to me that the phrase "once it has become a part of a brake hose assembly" would relieve us of the necessity to mark the hose.

The copy that I am reading this from is a very indistinct Xerox that I may be misinterpreting.

I can understand the need for interim marking if the hose is placed in commerce in an unassembled state. But that is not the case here where we are the ONLY customer with Titeflex for this particular hose and we make it into assemblies which otherwise meet all the specifications required by NHTSA.

I will call you in a few days to discuss this with you.