Interpretation ID: aiam2401
6 Frankfurt/Main 2
Postfach 119155
West Germany;
Dear Sirs: #This responds to the Alfred Teves GMBH (Teves) petition o April 9, 1976, for amendment of S5.2.1 of Standard No. 106-74, *Brake Hoses*, to eliminate the striping requirement in the case of hose used in assemblies that have 'keyed' end fittings at both ends. We interpret 'keyed' fittings to mean those that can be installed in only one (or possibly several) orientation(s) to the vehicle. #This is to advise you that the National Highway Traffic Safety Administration has determined to grant Teves' petition with regard to hose that is assembled into an assembly whose fittings permit their installation into the vehicle with only one orientation. Detailed reasons for the limitations expressed in this letter will accompany any notice that proposed this change. #You should understand that our commencement of a rulemaking proceeding does not signify that the rule is made on the basis of all available information in accordance with statutory criteria. #Your letter incorrectly characterized the amendment of S5.2.2 that was proposed in Notice 19 of docket 1-5 (40 Fr 55365, November 28, 1975) and made final in Notice 21 (41 FR 28505, July 12, 1976). The amendment only stated that the labeling required on hose need not be present after the hose has become part of a brake hose assembly or after it has been installed in a motor vehicle. The conclusion in the second paragraph of your letter that '...brake hose does not require labelling according to S5.2.2...' is therefore incorrect. #With regard to your comments on Standard No. 116, *Brake Fluids*, I assume that you were referring to the agency's proposed definition of 'brake fluid' published on December 5, 1975 (40 FR 56928). I also assume that the phrase 'polychloroprene (CR) brake hose inner tube stock' in the proposed definition led you to conclude that only polychloroprene inner tube stock would be allowed for brake hose construction. This is incorrect. All of the materials specified in the definition, including SBR, EPR, CR, and NR, are considered suitable for use in brake hoses. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs;