Interpretation ID: nht75-1.41

DATE: 11/10/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Great Dane Trailers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of March 19, 1975, requesting clarification of the relationship between the masking requirement and the brake hose assembly performance requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses.

On August 1, 1975, the NHTSA issued a notice delaying until March 1, 1976, the effective date of the masking requirement, in order to allow time for public comment on its proposed elimination. Copies of this and a more recent notice are enclosed.

If the standard is amended to eliminate the masking requirement, the issues which you have raised will be mooted. Otherwise, these issues will be dealt with in an upcoming Federal Register notice.

Sincerely,

Enclosures

Great Dane Trailers, Inc.

March 19, 1975

Chief Council's Office -- National Highway Traffic Safety Administration, Department of Transportation

Dear Sir:

If you would, I would like some clarification on FMVSS-106. My question is in regards to effective dates.

First, we understand that all fittings, tubings and hoses in the air brake system must now meet all performance requirements of the 106 regulation. We further understand that all fittings, tubings and hoses must be properly labeled and that the assembler, except the vehicle manufacturer, must band to indicate his certification. The vehicle manufacturer will certify his assembly by the normal certification label installed on the vehicle.

Regarding the labels, we are now receiving fittings properly labeled and the assembler bands are installed as required and are properly labeled. The tubings and hoses, even though they meet the performance requirements, are in most cases not labeled. This, we understand, has been approved.

We understand that painting over the embossed type labels on fitting and banding is completely satisfactory. However, masking must be done at least one place on each tube or hose for identification. It would be useless for us as a manufacturer to mask tubing and hoses that have no label.

It is our understanding that tubing and hose must be properly labeled and that we as a manufacturer must so protect this label as outlined above no later than 31 August, 1975. Is this correct?

We have to problem areas.

1. In our tubing assembly from the front connector to the running gear area. In this area we will install a protective sleeve over the tubing in our assembly process. This can be done without real complications, as we are making the assembly.

2. The major problem area is in the hose assembly purchased with permanent end fittings. In many cases the end fittings are large with relation to the hose size. Therefore, it is desirable for the assembler to install this protective sleeve to fit the hose, rather than us install a large sleeve to clear the fitting that may not do a good job.

I would appreciate your review of this problem area and would like to have a clarification in the labeling requirements.

Sincerely, Dudley E. DeWitt -- Manager, Research & Development

cc: Don W. Wieriman - TTMA