Interpretation ID: 19518.wkm

Mr. Roger C. Anderson
Production Engineering Manager
GT Development Corporation
14601 Interurban Avenue South
Seattle, WA 98168

Dear Mr. Anderson:

This refers to your letter addressed to Walter Myers of my staff and to your telephone conversations with Jim Gilkey of this agency. You asked whether a dash-mounted pneumatic valve attached to the vehicle's air brake circuit to control various non-brake related chassis functions would be subject to Federal Motor Vehicle Safety Standard (Standard) No. 106, Brake hoses. The answer is a qualified yes.

You enclosed schematics of the valve in question with your letter and sent a further drawing to Mr. Gilkey by telefax on May 24, 1999. You stated that the valve is to be used in an unprotected accessory air brake circuit to control various non-brake-related chassis functions. You stated that the plastic-bodied toggle valves incorporate Legris push-to-connect (PTC) 1/4-inch cartridges for connection to the B reservoir in the vehicle's air system. The B reservoir and lines supply air to the vehicle's front brakes. You stated that the PTC cartridges are assembled as an integral element to the dash valve in the manufacturing process, and that original equipment manufacturers insert their accessory lines into these cartridges. You stated that it is your understanding that application of the Legris cartridge integral to your dash valve does not constitute a brake hose end fitting and therefore is not subject to Standard No. 106. You asked us to confirm that understanding.

Brake hose end fitting is defined in S4 of Standard No. 106 as "[A] coupler, other than a clamp, designed for attachment to the end of a brake hose." "Brake hose" is defined, also in S4, as:

[A] flexible conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes (emphasis added).

Although your dash valve does not directly supply air to the vehicle's brake system, if the hoses attached to the dash valve transmit or contain brake air pressure from the vehicle's air system, that is, if failure of any such hose would result in a loss of air pressure in the brake system, then such hoses must comply with Standard No. 106. Moreover, your dash valve to which such hoses were attached would also be required to comply with Standard No. 106. However, if you added a check valve to the non-brake-related circuit so that loss of pressure in the circuit did not affect air brake system pressure, the hose would not be considered brake hose subject to Standard No. 106.

I hope this information is helpful to you. Should you have any questions or need additional information, feel free to contact Mr. Myers or Mr. Gilkey at this address or by telephone at (202) 366-2992 or (202) 366-5295.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:106
d.7/27/99