Interpretation ID: nht75-1.45

DATE: 10/06/75

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

TO: Joseph Lucas North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 29, 1975, asking whether two of your processes for labeling brake hose may be considered "permanent" for purposes of Standard No. 106-74.

As used in our standards and regulations, the requirement for a "permanent" label generally contemplates a label that will remain legible for the expected life of the product under normal conditions. The National Highway Traffic Safety Administration expects a manufacturer to make a reasonable, good-faith determination in this respect. The two labeling samples that you submitted as examples of your processes appear to be permanent.

We are presently re-examining the requirement for permanent labeling of brake hose, and a Federal Register notice in this area may be issued shortly.

Yours truly,

ATTACH.

May 29, 1975

Office of the Chief Counsel -- National Highway Traffic Safety Administration

Dear Sir:

BRAKE HOSE LABELING METHODS

Although we have previously corresponded with you on the subject of brake hose labeling (see attached copy letters: JLNA of September 30, 1974 and NHTSA of October 10, 1974), this present letter seeks your opinion specifically on the method of labeling.

Federal Motor Vehicle Safety Standard 106 requires that brake hoses be permanently labeled, but we know of no standard against which this permanence can be measured.

We wish to continue using hydraulic brake hoses with a "herringbone" surface pattern. Samples are enclosed. Two methods of labeling are available to us and we hope that you approve both.

Method 1. The Hot Foil Process.

Our hoses have always used this process and these hoses have been certified by independent laboratories, the AAMVA and Pennsylvania as complying with regulations.

"Hot Foil" marking is a transfer process in which a heated platten with the legend embossed on it is pressed through a plastic foil on to the rubber hose after the herringbone pattern has been formed and after the rubber hose has been cured (vulcanized). This transfers the legend in plastic foil to the hose.

Sample X attached was labeled in this way.

Method 2. Offset Printing.

In this process, the legend in ink is applied to the hose after extrusion, but before the "herringbone" surface is formed and before the hose is cured.

We understand this process is common for such applications in the USA.

Sample Y attached was labeled in this way.

Since both of these methods are established processes for the purpose of labeling brake hoses, we hope that you will give your approval to them in principle as being acceptable means for "permanent" marking.

Yours truly,

JOSEPH LUCAS NORTH AMERICA INC. -- A. G. Burgess, Vice President (Technical)

Enclosures: Letters (2); Hose X; Hose Y;

cc: F. Redler, with enclosures

September 30, 1974

Office of the Chief Counsel National Highway Traffic Safety Administration

Dear Sir:

GIRLING HYDRAULIC BRAKE HOSE

Girling Limited of Birmingham, England are assemblers of hydraulic brake hoses. These are sold as original equipment primarily to vehicle manufacturers in the United Kingdom. Some of these vehicles are exported to the United States.

Joseph Lucas North America Inc., imports Girling brake hoses for sale as service replacements in the USA.

Two samples of a 1/8" hydraulic brake hose are enclosed for your examination and confirmation that the markings are in accordance with FMVSS 106.

Yours truly,

JOSEPH LUCAS NORTH AMERICA INC. -- A. J. Burgess, Vice President (Technical)

Enclosures: 2 hoses.