Interpretation ID: nht75-1.34

DATE: 09/11/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Bendix Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of July 14, 1975, requesting an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, as applied to brake hose end fittings.

S5.2.3 of the standard requires (with an exception not relevant here) that one component of a multi-piece end fitting be labeled with certain information. You have pointed out that many end fittings designed for use with nylon brake hose include components identical to those found in fittings used with copper tubing, which is not covered by the standard. Labeling of one of these common components would satisfy the standard. You have interpreted Standard No. 106-74 as permitting an end fitting manufacturer to label his full stock of such components, even though some of them would appear in copper tubing assemblies. Your interpretation is correct.

Sincerely,

ATTACH.

Bendix

Heavy Vehicle Systems Group

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

July 14, 1975

Subject: Docket 1-5, Notice 15, FMVSS Number 106 BRAKE HOSE IDENTIFICATION

Reference: Phone conversation of J. P. Koenig, P. M. Johnston and Mark Schwimmer dated July 10, 1975.

Dear Mr. Schwimmer:

As per the above-referenced phone conversation, the Bendix Corporation, Heavy Vehicle Systems Group, desires a clarification on the requirements for the labeling of nylon tubing end fittings.

A nylon tubing end fitting must be labeled on at least one component of the fitting. Although the components of most nylon tubing end fittings are common with the components of copper tubing end fittings, we interpret that current regulations permit the labeling of an end fitting component which is common to both types of fittings. If correctly interpreted, this practice will result in copper tubing assemblies which are not covered by FMVSS Number 106, but which may consist of an end fitting component which is labeled as an FMVSS Number 106 component. On the other hand, if our interpretation is incorrect, fitting manufacturers will be burdened with the additional inventory and distribution control of handling two end fitting components identical in every respect except labeling.

We would appreciate a reply at your earliest convenience.

Very truly yours,

R. W. Hildebrandt -- Group Director of Engineering