Interpretation ID: nht74-5.43

DATE: 08/01/74

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

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 1, 1974, letter concerning Volkswagen's petition to exempt its pre-bent vacuum hose from some requirements of Standard No. 106-74, Brake hoses. You requested that we confirm that an in-line vacuum check valve is not regulated under the standard, and that the standard's use of "light duty" and "heavy duty" vacuum hose terminology corresponds to the use of those terms in the SAE Standard J1403a. We responded to the Volkswagen petition in a letter of July 2, 1974, to Mr. J. W. Kennebeck of Volkswagen.

You are correct in your conclusion that an in-line check valve like the valve in Volkswagen's pre-bent vacuum line is not a brake hose fitting subject to the requirements of Standard No. 106-74.

The National Highway Traffic Safety Administration tends to make the same distinction between light and heavy duty vacuum hose types as is made by the SAE Standard J1403a, which is based on the thickness of the hose wall. In addition to those sizes listed by the SAE we have added 9/32-inch hose.

YOURS TRULY,

VOLKSWAGEN OF AMERICA, INC.

July 1, 1974

Tad Herlihy, Esq. Office of Chief Counsel NHTSA

This will confirm our recent telephone conversation concerning FMVSS 106 applicable to brake hoses.

I understood you to say that Notice 11 of Docket 1-5 was not intended to serve as a response to our letter of April 26, 1974, which raised several questions concerning the applicability of S 9.2, 9.2.2, 9.2.3, 9.2.7 and 9.2.10 to certain pre-bent non-metallic vacuum hoses used by Volkswagen. You indicated that a separate response would be forthcoming in the near future.

You also confirmed that vacuum line check valves, regardless of where they are located in relation to the engine, whether in line, such as Volkswagen's, or directly connected to the engines, are exempt from Section 106.

In a separate telephone conversation, Mr. Ziwica raised the question as to whether the substance of the definition of "light and heavy duty vacuum brake(Illegible Word)" was identical to that used in SAE J 1403. I understand that it was the NHTSA's intent to incorporate the SAE definitional elements although somewhat different language was chosen. If my understanding is incorrect, please let me know as soon as possible.

Gerhard P. Riechel Attorney

cc: Mr. K.-H. Ziwica