Interpretation ID: nht75-1.22

DATE: 09/11/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: American Trailers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of August 12, 1975, concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, to an anchor coupling.

You enclosed a diagram depicting the installation of two of these couplings, and suggested that they are not subject to the labeling requirements of the standard. This interpretation is correct. "Brake hose end fitting" is defined in Standard No. 106-74 as:

a coupler, other than a clamp, designed for attachment to the end of a brake hose.

The anchor couplings which you have described are attached to the ends of completed brake hose assemblies, rather than to the ends of brake hoses. Therefore, they are not "brake hose end fittings" subject to the standard's requirements.

It appears from your letter that you might not consider the nylon tubing to be "brake hose." If the nylon tubing is flexible, however, such an interpretation would be incorrect. "Brake hose" is defined in the standard as:

a flexible conduit manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.

Thus flexible chassis plumbing and other flexible conduits, in addition to rubber brake hoses, are subject to the standard's requirements.

Sincerely,

ATTACH.

American Trailers, Inc.

August 12, 1975

National Highway Traffic Safety Admin. To - Docket 1 - 5, Brake Hoses

Gentlemen:

SUBJECT: Anchor Couplings

In a sliding suspension condition we use an anchor coupling fitting to join the nylon tubing assembly to the rubber air hose assembly. See the attached sketch. Our question is, whether or not the anchor coupling must meet the labeling requirements of FMVSS-106? Fitting manufacturers to-date have indicated that labeling is not required at this point since the coupling is not part of the air hose assembly.

Your earliest reply would be appreciated.

Sincerely,

Jerry W. McNeil Director Of Engineering

cc: D. Wieriman; TTMA

(Graphics omitted)

AMERICAN TRAILERS, INC. OKLAHOMA CITY, OKLA.

Name ANCHOR COUPLING LOCATION

Drawn By: McBay

Date: 8-11-75

Drawing No. 1-32-0006