Interpretation ID: nht74-4.9

DATE: 07/03/74

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

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 26, 1974, question whether labeling information on hose installed in vehicles must remain legible after the vehicle is painted, and what "permanently labeled" means in S5.2.2.

The answer to the question of painting over label information will be answered in our upcoming notice in response to petitions for reconsideration of the amendments we have made to the standard.

"Permantly labeled" means affixed in such a manner that it is not easily removable, and is reasonably designed to remain affixed and legible for the normal life of the component.

Yours Truly,

Volvo of America Corporation

April 26, 1974

Lawrence Schneider, Chief Counsel National Highway Traffic Safety Administration

Volvo of America Corporation hereby requests an interpretation on amended FMVSS 106 published February 26, 1974 [Docket No. 1-5; Notice 10].

Volvo requests an interpretation on the extent which the markings on the brake hose, end fitting and band around the brake hose assembly must remain legible after the assembly is installed on the vehicle. Volvo has determined these markings may become illegible after the chassis is painted. Would the NHTSA find it acceptable to have one or more markings on the hose remain legible, and the markings on the fitting and the band, if not legible after painting, be legible when the paint is removed?

Volvo also requests a definition of "permanently labeled" as stated in Section S5.2.2

Volvo thanks you for your consideration on this matter and requests a reply as soon as practical.

Rick Shue Product Safety Engineer

cc: S. Larsson