Interpretation ID: nht74-1.13

DATE: 03/06/74

FROM: AUTHOR UNAVAILABLE; L. R. Schneider for R. B. Dyson; NHTSA

TO: Lufkin Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your January 30, 1974, request for inclusion in Standard 106, Brake hoses, of J1402 type A and B hose and J844 (nylon type 3) hose.

Standard 106 has already been amended by the addition of 3/8-in and 1/2-in special sizes to the list of hose sizes which may be used with reusable fittings, and this addition permits continued use of commonly utilized types of A and B hose.

The nylon 3 hose to which you refer is not excluded from use under the standard. Several of its manufacturers have indicated that it does conform to the requirements of the standard, which have been modified to reflect the lower tensile strength valves needed when used at non-articulating points in the system.

Yours truly,

ATTACH.

January 30, 1974

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION -- Docket Section

Re: Docket No. 1-5 Notice 8 49 CFR 571.106; 38 FR 31302 (November 13, 1973)

PETITION FOR NEW RULEMAKING - FMVSS

Gentlemen:

LUFKIN INDUSTRIES, Trailer Division, is a manufacturer of a variety of on and off-highway trailer equipment. We operate a number of branch offices that sell, service, repair and distribute parts for LUFKIN and other trailers.

We are concerned that FMVSS 106, in its present form, is design restrictive. The law will severely effect our timetable of preparation for FMVSS 121, for the following reasons:

1. Failure to list SAE J1402 type A and B hose as acceptable air brake hose.

2. Failure to list SAE J844 (Nylon Type 3) as acceptable "Chassis plumbing".

According to test data provided by our vendors, J1402 type A and B hose meets FMVSS 106, Paragraph S7. We strongly recommend that you recognize this product as acceptable due to its apparent safety and economy.

We have used J1402 type B for years as plumbing from air valve to brake chamber, and from belly of trailer down to sliding bogey. Repair manager interviews and review of documentation and warranty reports show no failures due to excessive pressure. Only two hose failures have occurred during the past two years. Both resulted from mechanical damage so severe that SAE 100RS, SAE J1402 type D, wire braid hose could not have prevented failure.

The same statements are true concerning SAE J844 (Nylon Type 3) tubing. The tubing's adaptability and workability have simplified complex varieties of air brake "chassis plumbing" on a variety of trailer configurations without sacrificing safety or dependability. We petition that SAE J844 (Nylon Type 3) tubing be accepted as "chassis plumbing" except for delivery lines from air relay valve to brake chambers, trailer-tractor connections, trailer-dolly-trailer connections, and trailer belly to sliding bogey connections.

If SAE J1402 type A and B hose and SAE J844 (Nylon Type 3) tubing are not accepted as brake hose under this law, we, as well as numerous trailer manufacturers, will be faced with unusable hose, tubing and fittings. Because of quantity order requirements necessitated by scarcity, long trailer construction lead times and planning uncertainties generated by FMVSS's 106 and 121, we may be unable to phase-out obsolete material in the time remaining. Additionally, all LUFKIN brake actuation and release timing tests have been conducted on equipment using the type B hose and nylon tubing. Duplication and waste will result if new components are to be introduced now.

We respectfully submit that the final disposition of FMVSS 106 needs immediate resolution. We must finalize drawings, purchase required parts, establish pricing, prepare a firm schedule for phase-out of any unusable parts and complete our shop training program. We need, from you, a finalized FMVSS 106 regulation that will allow us to plan effectively to meet mutual safety and reliability goals.

Yours very truly,

LUFKIN INDUSTRIES, INC.

W. T. Little -- Vice-President General Manager, Lufkin Trailer Division

cc: A. G. Colburn; Joe Bills