Interpretation ID: nht74-4.10

DATE: 07/03/74

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

TO: Toyota Motor Sales, U.S.A., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your June 11, 1974, request for approval of Toyota's banding design to meet the requirements of Standard No. 106, Brake hoses, for labeling brake hose assemblies.

The NHTSA interpretes a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. You should be able to determine the compliance of your labeling method with the standard. It does appear that the Toyota label does not encircle the assembly and attach to itself. The NHTSA does not approve specific designs in advance, in any case, because the material, installation method, and underlying material can significantly affect the quality of a specific design.

TOYOTA MOTOR SALES, U.S.A., INC.

June 11, 1974

James B. Gregory Administrator National Highway Traffic Safety Administration

Re: Interpretation of FMVSS No. 106

We would like to request clarification of S5.2 of Standard No. 106, "Labeling," as published in theFederal Register on November 13, 1973 and amended on February 26, 1974.

S5.2.4 reads as follows:

"Each hydraulic brake hose assembly, . . . , shall be labeled by means of a band around the brake hose assembly. The band may at the manufacturer's option be attached so as to move freely along the length of the assembly, as long as it is retained by the end fittings. The band shall be permanently etched, embossed or stamped, in block capital letters and numerals at least one-eighth of an inch high, with the following information: . . ."

On the basis of our understanding of this section, we constructed a prototype plastic band to be attached to the neck of the end fitting. The band was made of plastic because of the rust problem that occurs in metal bands during corrosion testing. On the band the figures "DOT TG A/B," where A represents the numeral for the month and B the last two digits of the year of production, are permanently etched. While the band can be removed manually if desired, it will definitely not fall off during vehicle usage.

With the original of this letter, we have attached a sample of this band. Please let us know whether or not you think that it will meet the requirement.

As this is a very urgent matter, your expeditious reply will be greatly appreciated.

Thank you.

Y. Veda

for K. Nakajima

Director/General Manager

Factory Representative Office