Interpretation ID: 1983-3.5

TYPE: INTERPRETATION-NHTSA

DATE: 09/15/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Lyn-Mont Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Jeffrey A. Crawford Q.A. Manager Lyn-Mont Manufacturing Co. P.O. Box 11745 4208 Clubview Drive Fort Wayne, Indiana 46860

Dear Mr. Crawford:

This responds to your letter concerning Safety Standard No. 106, Brake Hoses. You asked whether certain proposed labeling for brake hose assemblies would meet the labeling requirements of sections S7.2.3 and S7.2.3.1. As discussed below, the answer to your question is no.

By way of background information, this agency does not provide approvals of motor vehicles or motor vehicle equip- ment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its products comply with applicable safety standards. The following opinion is based on the facts provided in your letter.

Sections S7.2.3 and S7.2.3.1 provide two options for the labeling of air brake hose assemblies made with end fittings that are attached by crimping or swaging. Section S7.2.3 states that such assemblies, except those assembled and installed by a vehicle manufacturer in vehicles manufactured by him, shall be labeled by means of a band around the brake hose assembly as specified in that paragraph, or, at the option of the manufacturer, by means of labeling as specified in section S7.2.3.1.

If the first option is chosen, using a band as specified in section S7.2.3, the band must include (a) the symbol DOT, and (b) the manufacturer designation.. If the second option, specified in section S7.2.3.1, is chosen, the manufacturer designation must be placed on at least one end fitting of the assembly. (These sections also specify other require- ments concerning labeling, such as size of letters, which are not relevant to this interpretation.)

Your proposed labeling, placing the manufacturer designation on the band and the symbol DOT on the end fitting, would not meet the requirements of either of these options. If the first option is chosen, the symbol DOT must be placed on the band along with the manufacturer designation. If the second option is chosen, the manufacturer designation must be placed on the end fitting.

Sincerely,

Frank Berndt Chief Counsel

July 5, 1983

Office of Vehicle Safety Standards Crash Avoidance Division National Highway Traffic Safety Adm. 400 Seventh St. S.W. Washington, D.C. 20590

ATTN: Mr. Bloom

Subject: FMVSS -106 Paragraph S7.2.3 and S7.2.3.1

Dear Mr. Bloom,

There is some confusion on interpreting these two paragraphs between ourselves and a customer.

We've interpreted paragraph S7.2.3 to read that the assembly can be labeled with a band listing the information in sub-paragraph A&B, with it being our option to put on our designation as the manufacturer either on this tag or marked on the fitting as described in paragraph S7.2.3.1.

Our customer interprets this to read that this designation must be stamped on the fitting no matter what. What we would like to do is stamp the symbol DOT on the hex of the fitting.

Enclosed please find a sketch of our assembly showing where they would be marked in accordance with the 106 spec.

We would like a legal interpretation on weather we would be in compliance labeling our assemblies in this manner.

Sincerely,

Lyn-Mont Manufacturing Co.

Jeffrey A. Crawford Q.A. Manager

NO SHARP EDGE UNLESS OTHERWISE NOTED.

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