Interpretation ID: nht75-1.30

DATE: 06/03/75

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

TO: Floyd, Kramer & Lambrecht

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of April 25, 1975, concerning the applicability of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, to the Wabco Westinghouse Duo-Matic Coupler.

You have described the Coupler as a device which replaces the glad hand coupler now used by most manufacturers to connect truck tractor and trailer brake lines. Because the brake hose which attaches to the Coupler is equipped with its own end fittings, the Coupler itself is not an end fitting. Therefore, Standard No. 106-74 is inapplicable.

The Coupler is, however, subject to the requirements of 49 CFR Part 393.45 and 393.46, of which I have enclosed a copy. Please direct any questions you may have concerning interpretation of these requirements to the Office of the Chief Counsel, Federal Highway Administration, at 400 Seventh St., S.W., Washington, D.C. 20590.

Yours truly,

Enclosure

April 25, 1975

Office of Chief Counsel -- National Highway Traffic Safety Administration, Attention: Mark Schwimmer

Re: Wabco Westinghouse Duo-Matic Coupler

Dear Mr. Schwimmer:

Reference is made to our telephone conversation on April 11, 1975, concerning the applicability of M.V.S.S. No. 106-74 and Part 566-Manufacturer Identification, to our above referenced product. As indicated, we represent the importer of this equipment in the United States and wish to comply fully with your agency before distribution is begun in this country. Enclosed please find:

1. Three copies of a product description for Wabco Westinghouse Duo-Matic Coupler, Model No. 452 803,

2. Three copies of product description for Wabco Westinghouse Duo-Matic Coupler, Model No. 452 802,

3. Assorted photographs of the coupler showing the unit with and without brake hose end fittings. The black and white picture shows the unit installed on a Norwegian vehicle.

As indicated above, we are interested as to whether the above cited regulations apply to these units. It should be noted that we don't feel this is a "brake hose end fitting", as defined in your regulations, as a fitting is placed on the brake hose prior to the brake hose being attached to our unit. The end fittings are not part of our unit. Our unit simply replaces the "glad hand coupler" now used by most manufacturers to couple the hose end fittings of the tractor and trailer truck units.

We also feel that our units do not constitute a "brake hose assembly" as defined in your regulations, as, again, our unit does not include brake hoses or the end fittings of brake hoses, but merely couples end fittings together between tractor and trailer or between two trailers.

We would also advise you that the above referenced units are used in Sweden, Norway, Denmark, Finland, and New Zealand and have been so used in said countries since 1971.

We would request from you the following:

1. Whether the above cited regulations apply to our products.

2. Whether any other regulations of your agency apply to these products.

If any further additional information is required for you to make the above determination, please notify us. Thank you for your cooperation in this matter, and I remain

Sincerely,

FLOYD, KRAMER & LAMBRECHT -- Kenneth B. Kramer

Encls.