Interpretation ID: nht74-5.38
DATE: 04/22/74
FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA
TO: Meiji Rubber & Chemical Co., Ltd.
TITLE: FMVSS INTERPRETATION
TEXT: This is in response to your February 27, 1974, request concerning brake hose identification codes and labeling, conflicts of Federal and State standards, and procedures for certifying hose, end fittings, and hose assemblies in compliance with Standard No. 106, Brake hoses. This also responds to your March 25, 1974, (ref T-76) request for approval of your proposed hydraulic and vacuum brake hose labeling.
Notice 10 was published on February 26, 1974. It modified the labeling requirements, and a copy is enclosed. It is certain that another notice will be published shortly which may modify the marking requirements further. Therefore I advise that you not undertake modifications of your labeling in the near future.
In answer to your February 21 letter, if we require a code at a later date, the code will not relate to the MRA code. Concerning the marking of multi-piece fittings, the designation must appear on each part of a reusable end fitting, although this requirement is presently under reconsideration.
With regard to conflicting State regulations such as Pennsylvania's, our regulation as of September 1, 1974, preempts any State brake hose regulations which are not identical with respect to the some aspects of performance. The National Traffic and Motor Vehicle Safety Act of 1966 provides at @ 103(d):
Whenever a federal motor vehicle safety standard established under this subchapter is in effect, no state or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard. . . .
2
However, it is permissible, if a manufacturer wishes, for him to place Pennsylvania labeling on the reverse side of the hose.
It is the responsibility of the manufacturer to certify that his products comply with Standard No. 106. You may conduct a test program, or you may hire an independent test laboratory to conduct the test program for you. One test laboratory in the United States which tests brake hose is VPI of Blacksburg, Virginia. The National Highway Traffic Safety Administration does not conduct certification tests, but it does conduct tests on manufacturer products to enforce compliance.
In answer to your March 25 letter, the hydraulic brake hose marking on "Face A" appears to conform to the requirements of S5.2.2, assuming that letter "size" refers to letter height. Notice 10 permits the manufacturer designation to be other than block capital letters. "Face B" is not regulated by our standard.
With regard to the brake hose end fitting and brake hose assembly examples, they appear to conform to S5.2.3 and S5.2.4 if the letter "size" refers to letter height. It should be noted that Notice 10 excludes labeling of two-piece fittings and certain assemblies and that the next notice may make further modifications.
With regard to vacuum brake hose, your "Face A" example appears to conform to S5.2.2 if letter "size" refers to letter height. S5.2.1 is not applicable and therefore the stripe is not required. "Face B" is not regulated by our standard.
ENC.
MEIJI RUBBER & CHEMICAL CO., LTD.
February 21, 1974
National Highway Traffic Safety Administration
Dear Sirs:
Subject: Brake Hoses for FMVSS
As to the Part 571-Federal Motor Vehicle Safety Standards (FMVSS), Brake Hoses of Docket No. 1-5: Notice 8 published in the Federal Register Vol. 38, No. 218 issued on Tuesday Nov. 13, 1973, we shall be pleased if you will kindly show us about the procedure for getting the code nos.
1. We manufacture brake hoses and metal fittings, assemble them into oil brake hoses, and sell them to automobile manufacturers. We have got the Code No. 57-1 from MRA. Please show us the relation between the code no. of MRA and that of newly published FMVSS.
2. Please show us the relation between FMVSS and the specifications regulated by a state such as the State of Pennsylvania.
3. In order to get the code no. FMVSS, what procedure should be followed by company as ours, who manufactures hoses and several types of metal fittings, and assembles them into oil brake hoses?
4. There are several types of forms in our metal fittings. Is it necessary to get the code no. on the respective types of our metal fittings?
5. Please introduce us to the public institutions who can test and qualify oil brake hoses to get the code no. FMVSS.
Your generous cooperation would be highly appreciated.
Yours Sincerely
H. Tsukano, Sub-manager Technical Division
MEIJI RUBBER & CHEMICAL CO., LTD.
March 25, 1974
Docket Section National Highway Traffic Safety Administration
Subject: Submission of Comments on Federal Motor Vehicle Safety Standards Docket No. 1-5: Notice 9
We would like to ask for the approval of our attached application about the Brake Hose Identification provided in the Docket No. 1-5; Notice 9 on the Federal Register, Vol. 39, No. 20, Tuesday, January 29, 1974.
H. Tsukano, Sub-Manager Technical Division
enc.
P.S. As for the expenses, we will pay on your request.
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LABELING
I. HYDRAULIC BRAKE HOSE
1. Hydraulic brake hose (ID 1/8")
1-1. Printed parts
1-2. Face A (printed mark) (every 6 inches)
-- DOT MRCC 10/74 1/8 HR -- DOT MRCC
Notes: The color of printed letters is white.
The size of a letter is 1/8".
The width of line is 1/16".
MRCC stands for Meiji Rubber & Chemical Co.
1-3. Face B (printed mark)
M MEIJI RUBBER JAPAN 1/8 NO57-1 1974 SAE J1401
(which is indication of the approval for the export to a northern state (Pennsylvania).)
Notes: The white letters are printed continuously
The size of letter is 1/8".
M: The trade mark of Meiji Rubber & Chemical Co.
1/8: The inside diameter of hose 1974: year of production
N057-1: The approval number of RMA (Rubber Manufacturers Association) (444 Madison Avenue, New York 10022, U.S.A.) Line number 57
Yarn color code yellow yellow-black
RMA assignment Meiji Rubber Company, Ltd. attained on March 1st, 1967
SAE J1401 Society of Automotive Hydraulic Brake Hose
2. Hydraulic brake hose end fitting
DOT MRCC 1/8 H XY
Notes: Letters stamped
The size of a letter 1/16"
MRCC stands for Meiji Rubber and Chemical Co.
1/8: The inside diameter of hose X is the figure of production that comes after 197 Y means the month of production
3. Hydraulic brake hose assembly
DOT MRCC 10/74
Notes: Letters stamped
The size of a letter 1/8"
Rubber band width 8 mm red colored hypalon rubber
MRCC stands for Meiji Rubber & Chemical Co.
II. Vacuum Brake Hose (ID 3/8")
1. Printed parts
(A) Face A (printed mark) (every 6 inches)
-- DOT MRCC 10/74 3/8 VL -- DOT MRCC
Notes: The white letters printed
The size of a letter 5 mm
The width of line 3 mm
MRCC stands for Meiji Rubber & Chemical Co. 3/8 means the inside diameter of hose.
(B) Face B (printed mark) (every 6 inches) M MRCC JAPAN -- M ---
Notes: The white letters printed
The size of a letter 5 mm
The width of line 3 mm
M is the trade mark of Meiji Rubber & Chemical Co. MRCC stands for Meiji Rubber & Chemical Co.