Interpretation ID: nht74-5.12
DATE: 03/08/74
FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA
TO: Toyo Kogyo Co., Ltd.
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your February 1, 1974, request for interpretation of Standard No. 106, Brake Hoses, concerning "collapse" in S9.2.8, an incorrect value in Table VI, and proper labeling format.
Your confusion about the meaning of "collapse" in S9.2.8 points out that the requirement was inadvertently changed between notices 7 and 8 and that it should require "no leakage or separation of the inner tube from the fabric reinforcement of the hose". The language will be amended in the near future.
In our response to petitions for reconsideration of Standard 106, we corrected the 5/64 value (question 2) and we accommodated labeling of short hose by permitting labeling separated by any amount up to 6 inches (question 4). You must use one line for labeling required by Standard 106, but you may interrupt the stripe on the opposite side of the required labeling with labeling for other countries, in accordance with S5.2.1 (question 5). In answer to question 3, the fractions should read 3/16, as you indicate you wish to do it.
Your associate, Mr. Hirai, asked our office for an explanation of the certification requirements of S114 of the National Traffic and Motor Vehicle Safety Act of 1966, as they apply to items of motor vehicle equipment to which a standard applies. I have enclosed a notice of clarification.
ENC.
February 1, 1974
Richard B. Dyson
Assistant Chief Counsel
National Highway Traffic Safety Administration
Re: FMVSS 106, Hydraulic Brake Hoses, Docket No. 1-5; Notice 8.
On January 31, 1974, I talked with Miss Grace Robinson, she gave me the information I requested and informed me to send an official letter for confirmation.
Toyo Kogyo has the following question on these regulations:
(Question 1)
Section 9.2.8
"...The vacuum brake hose shall not collapse in a vacuum test of 26 inches of Hg. for 10 minutes." Its' "collapse" may be allowed, if it shall not fully collapse, is this correct?
In section 9.2.6, it shall be allowed with 1/16 inches collapse, with the less severe test condition of 26 inches Hg. and even 5 minutes.
(Question 2)
In table VI dimension of test specimen and feeler gage for deformation tests.
Inside diameter of hose Spec. D (in.) 11/32 inches 3/64 is described, but we think is 11/32 5/64 correct. Is this a misprint?
1) Based on SAE J1403 table 4, 5/64 is correct.
2) Other inside diameter is complete same as the thickness.
(Question 3)
In S9.1 of labeling, may we use the 3/16, (3 and 16 are located in the same line) shape of inside diameter, instead of 3/16?
(Question 4)
In S9.1 of labeling may we describe it with 2 lines?
The length of this labeling shall be assumed with 80mm. We are using 150mm length of hose but in some cases about 55mm length one will be considered in future.
(Question 5)
May we use another labeling on the hose along with the FMVSS 106 labeling?
We are now considering utilizing the hose in another country as well as in the U.S.A.. In that case we want to describe 2-labelings at the same time on the hose. If one more labeling is located on the backside there's no confusion.
Your earliest reply will be appreciated.
Thank you.
Gorou Utsunomiya Branch Manager Toyo Kogyo Co., Ltd. U.SA. Representative Office
cc: Miss Grace Robinson
Dr. Kazushi Sakashita Mr. Eisuke Niguma