Interpretation ID: nht75-1.46
DATE: 09/24/75
FROM: ROBERT L. CARTER -- NHTSA
TO: Imperial-Eastman Corporation
TITLE: FMVSS INTERPRETATION
TEXT: This is in response to your letter of May 28, 1975, in which you petitioned for the replacement of the "permanent" labeling requirement for brake hose in Standard No. 106-74 with a "weather resistant" test requirement. You also asked whether a series of dots may be included after the required date information on the hose, to indicate in coded form the day or manufacture.
With respect to your petition, this agency is reconsidering the permanency requirement for the labeling, and a notice is planned for issuance shortly on the subject. We do not find an additional test requirement for the labeling to be justified, on the basis of data presently before the agency, since the usefulness of the labeling is limited primarily to the pre-assembly period. Therefore, in the strict sense your petition is hereby denied. You may find, however, that the changes now being developed in our rulemaking proceedings will resolve your problem in this area.
The standard does not permit the use of coded dots indicating production date in the location specified for the required information. S5.2.2(c) specifies the following information as part of the required label:
The month, day, and year, or the month and year, of manufacture, expressed in numerals. For example, 10/1/74 means October 1, 1974.
Our interpretation of S5.2 (as incorporated in S7.2) is that the required information may not be interrupted by optional information. Therefore, the day of manufacture, if indicated as part of the S5.2.2 legend, must be expressed in numerals. You may, of course, use the coded dots if they appear on the opposite side of the hose.
Sincerely,
ATTACH.
Imperial-Eastman Corporation
May 28, 1975
Office of Chief Counsel -- National Highway Traffic Safety Administration
Ref: Motor Vehicle Safety Standard No. 106-74
Gentlemen:
Please consider the following two areas of concern regarding the reference Standard:
1. The labeling requirements for air brake hose per S7.2, which refers to S5.2 on hydraulic brake hose, include the term ". . . shall be permanently labeled . . ."
Interpretation of the word "permanently" is creating a problem between suppliers and users because there is no test procedure to evaluate permanency.
To clarify the requirement, we hereby petition that the first paragraph of S5.2.2 be revised to the following:
"Each hydraulic brake hose shall be marked with a weather resistant label at intervals of not more than 6 inches, measured from the end of one legend to the beginning of the next, in block capital letters and numerals at least one-eight of an inch high, with the information listed in paragraphs (a) through (e). The label shall remain legible after 24 hours of exposure to salt spray. (S6.9)".
The title of S6.9 should correspondingly be changed to:
S6.9 End fitting corrosion resistance and label weather resistance test.
2. Please furnish an opinion on the legality of including a series of dots in the labeling of air brake hose. The dots would appear after the date (month and year) to indicate the working day of manufacture.
This system would allow us to satisfy internal needs for a lot coding system and avoid the extremely high cost of discarding the higher quality engraved marking wheels on a daily basis.
The dots would not interfere with or preclude the other required information.
Please give these two matters your prompt attention to allow us to confidently assure our customers of conformance to MVSS 106 with our C6 nylon air brake tubing.
Thank you for your cooperation. We look forward to an expeditious reply.
Sincerely,
William J. Kronschnable -- Assistant Chief Engineer, Synthetic Products
cc: Fred Redler - National Highway Traffic Safety Adminstration