Interpretation ID: nht75-1.36

DATE: 11/10/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Amerace Corporation

TITLE: FMVSS INTERPRETATION

TEXT: I am writing to confirm your telephone conversation of July 21, 1975, with Mark Schwimmer of this office, concerning the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses.

Your letter of June 12, 1975, explained that you supply hose in lengths as short as 1 1/2 inches. You found it possible to include a complete legend of the information required by S5.2.2 of the standard only by utilizing two lines of printing, parallel to each other and separated by approximately 1/8 inch. As Mr. Schwimmer explained, such a labeling procedure would satisfy the standard's requirements.

I would like to point out, however, that the standard was amended by Notice 18 (40 FR 38159, August 27, 1975), to facilitate the depletion of inventories of brake hose which complies with all requirements except the labeling requirements of S5.2. One effect of that amendment was to delay until September 1, 1976, the requirement that at least one complete legend appear on any hose used in an assembly, regardless of its length. For your convenience, I have enclosed a copy of the notice.

Sincerely,

Enclosure

June 12, 1975

Office of Chief Counsel N. H. T. S. A.

Attention: Mark Schwimer

Subject: FMVSS-106

Dear Sir:

In reference to our phone conversation of June 3, 1975, Notice 16 of FMVSS-106 is quite explicit in requiring that a complete legend appear on each and every piece of brake hose regardless of length. The Standard itself, and various notices, appear to be less explicit as to whether this legend must appear on only one line. Notice 11 does state "only the required information may appear along one side of the hose". Your clarification is requested on this since we are not able to incorporate a complete legend on each hose length using existing equipment, nor are we able to incorporate it into just a single line.

We currently furnish some OEM parts down to 1-1/2" in length. Current equipment will allow us to repeat a complete legend every 4". On parts shorter than 4" we have found it necessary to hand stamp each piece individually, at a considerable cost penalty I might add, but even using this technique we are not able to include a complete legend on a single line within 1 1/2". However, we can apply a complete legend within 1 1/2" with a hand stamp by utilizing two lines of printing. These two lines are on "one side of the hose", parallel to each other and separated by approximately 1/8".

Since we have a considerable amount of inventory on parts under 4" which have been held up from being shipped since the effective date of Notice 16, which was March 17, 1975, we would appreciate your interpretation of the standard as to whether more than one line is permissible for a complete legend. A reply at your earliest convenience would be appreciated.

Very truly yours,

SWAN HOSE DIVISION -- Amerace Corporation; R. E. Ruda -- Technical Services Manager