Interpretation ID: nht74-3.17

DATE: 07/30/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 3, 1974, question whether the Standard No. 106-74, Brake hoses, labeling requirements for brake hose fittings (S5.2.3) permit labeling in addition to that required in the section.

Optional labeling is not prohibited by the standard as long as the additional marking does not confuse the required marking. We have already interpreted S5.2.2 to permit optional labeling on the opposite side of the hose from the required labeling. The required labeling must appear without additions to make it clearly legible.

Your illustration appears satisfactory as long as the "1/8" and the "lot number" are sufficiently separate for clarity.

NISSAN MOTOR CO., LTD.

July 3, 1974

Lawrence R. Schneider Chief Council National Highway Traffic Safety Administration

This is to confirm our telephone conversation of June 27th with Mr. Herlihy of your office regarding the brake hose end fitting labeling requirement of FMVSS 106, S.5.2.3.

We would like to employ additional labeling in block capital letters or numerals, as shown in the attached Figure 1, which is not requested in the Standard and which will constitute "Lot Numbers" by the fitting manufacturer.

We believe that it would be acceptable to have this additional labeling when considering the fact that the FMVSS 106 does not prohibit additional labeling and that we feel the need for additional labeling in order to identify problems more easily if something should happen. We do not think that this kind of additional labeling would cause any confusion with the labeling requested by the FMVSS.

Please advise us as to whether or not our understanding in the above matter is correct.

Thank you for your attention to our request.

Tatsuo Kato

Staff, Safety

Attachment

Example:

DOT OSK H 1/8 XXXXX

Manufacturer's Designation

NHTSA Requested Labeling

"LOT NUMBERS" by fitting manufacturer in block capital letters or numerals at same height as requested in the FMVSS labeling.

(Graphics omitted)