Interpretation ID: aiam1867
Specialty Sales Assistant
William Penn Laboratories
1882 Guildhall Building
Cleveland
Ohio 44115;
Dear Mrs. Stein: This is in reply to your letter of March 26, 1975, to Mr. Schultz enclosing a sample brake fluid can, and asking whether it meets paragraph S5.2.1 of Motor Vehicle Safety Standard No. 116.; Since the inner metal pressed-in closure must be punctured or otherwis damaged, or removed, in order to use the fluid, the can meets our container sealing requirement.; The can also meets other requirements of Standard No. 116 with t exceptions, The phrase 'Conforms to Federal Standard No. 116' should be phrased 'Conforms to Federal Motor Vehicle Safety Standard No. 116' in order to meet S5.2.2.2(a). In addition, the designation of the contents as 'DOT 3 MOTOR VEHICLE BRAKE FLUID' must appear on the can in accordance with S5.2.2.2(e). This designation in such form presently does not appear on the container.; Yours truly, Richard B. Dyson, Assistant Chief Counsel