Interpretation ID: nht74-5.21

DATE: 04/11/74

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

TO: BMW of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 19, 1974, request for confirmation that the clamps and check valve that attach a vacuum hose assembly to a brake booster are not subject to Standard No. 106, Brake hoses.

A brake hose end fitting is defined as "a coupler, other than a clamp, designed for attachment to the end of a brake hose." As described by you, the couplers are the clamps and the check valve is an engine component to which the hose has been attached by the clamp couplers. Therefore your interpretation is correct that the clamps and check valve are not subject to Standard No. 106.

Yours Truly,

BMW of North America, Inc.

March 19, 1974

National Highway Traffic Safety Administration

Attn: Mr. L. Schneider, Chief Counsel

Re: Marking of Brake Hoses

This is subject to FMVS's No. 106 Brake Hose Markings. In our brake system, BMW uses a vacuum hose assembly which leads from the intake manifold to the brake booster and which includes also a check valve. The components are assembled by BMW, the manufacturer, who, of course, also certifies the finished vehicle.

It is BMW's understanding that the vacuum hose, which is used for this assembly, has to be marked with the manufacturer's code, or with the manufacturer's marking as long as no code is available. The clamps which are used for this assembly as well as the check valve which meets the free flow requirements, don't need to be marked.

If our assumption is incorrect, we kindly ask that you inform us accordingly.

Office of O. Weinreich Director of Engineering Signed by M. Rein Staff Engineer