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Interpretation ID: 8-29-02Johnsonltr


    Mr. Frank Johnson
    Executive Vice President
    Nichirin Inc.
    139 Copernicus Boulevard
    Brantford, Ontario
    CANADA N3P 1N4


    Dear Mr. Johnson:

    This responds to your letter, which we received on June 3, 2002, regarding Federal Motor Vehicle Safety Standard ("FMVSS") No. 106, Brake Hoses. Specifically, you ask whether stainless steel braided brake hoses must meet the striping requirements of S5.2.1, Labeling. The answer is yes, unless the hoses are either sold as part of a motor vehicle or manufactured for use only in an assembly whose end fittings prevent the hoses from being installed in a twisted orientation.

    S5.2.1 requires that "[e]ach hydraulic brake hose, except hose sold as part of a motor vehicle, shall have at least two clearly identifiable stripes of at least one-sixteenth of an inch in width, placed on opposite sides of the brake hose parallel to its longitudinal axis." 49 CFR 571.106. In addition, S5.2.1 provides that "hydraulic brake hose manufactured only for use in an assembly whose end fittings prevent its installation in a twisted orientation in either side of the vehicle, need not" meet the striping requirement. 49 CFR 571.106.

    You indicate in your letter that Honda is proposing to use stainless steel braided hoses in a "new vehicle program" and you ask whether the outer mesh of these hoses needs to be striped. As indicated above, the requirements of S5.2.1 apply to all hydraulic brake hoses, not only those made of rubber. S5.2.1 does not exclude stainless steel braided brake hoses from the striping requirement. (See also May 12, 1994 letter to Mr. Jim Davis, Russell Performance Products, copy enclosed.) Accordingly, the stainless steel braided hose about which you inquire must be striped unless they meet either of S5.2.1's two exceptions.

    If you supply brake hoses to Honda and the hoses are only installed on newly-manufacured vehicles, then the hoses would not need to be striped under S5.2.1. However, if Honda were to sell any of the brake hoses as replacement parts, and therefore they are not installed on a new motor vehicle, then they would need to be striped unless they are constructed in such a way or have unique features that would prevent their being installed in a twisted manner when they are put on the vehicle as replacement brake hoses.

    Finally, we note that the agency has been petitioned by Parker Hannifin to update FMVSS No. 106. NHTSA granted the petition and is now evaluating the issues raised therein. If you are interested in reviewing a copy of this petition, you may access it at the following web address:
    http://dms.dot.gov/search/document.cfm?documentid=46189&docketid=4367

    I hope this information is helpful. If you have any questions, you may contact Robert Knop of this office at (202) 366-2992.

    Sincerely,

    Jaqueline Glassman
    Chief Counsel

    Enclosure
    ref:106
    d.9/6/02