Interpretation ID: nht75-4.14

DATE: 05/14/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Gurley Refining Company

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of April 10, 1975, you ask whether a label you enclosed meets the requirements of Motor Vehicles Safety Standard No. 116.

The color coding requirements published on August 22, 1974, have been suspended for the present. The phrase "conforms or exceeds FMVSS 116" meets the requirements "certification that the brake fluid conforms to Federal Motor Vehicle Safety Standard No. 116," although it is ungrammatical and the reference to "exceeding" is redundant.

Your label therefore meets our requirements.

YOURS TRULY,

April 10, 1975

(Illegible Word) Legal Council National Highway Traffic Safety Administration

Dear Sir:

Enclosed you will find a black and white laycut of the label we use to package brake fluid. We wish an official ruling from your department as to whether or not our label does conform to all the requirements of FMVSS 116 as amended in Federal Register, Volumn 39, Number 164 - Thursday, August 22, 1974. Your prompt attention to this matter will be appreciated.

Very truly yours, JIM BENNETT -- GURLEY REFINING CO.

Enclosure

CRG

SUPER HEAVY DUTY

BRAKE FLUID DOT 3 MOTOR VEHICLE BRAKE FLUID 284 degrees F Min. Wet Boiling Point

NET 12 FLUID OZS. CONFORMS OR EXCEEDS FMVSS 116

GRC HYDRAULIC BRAKE FLUID

(Illegible Text)

GURLEY REFINING CO. MEMPHIS, TENN. 30102

CUST. GURLEY REFINING DESIGN (Illegible Words)

ENG. 2700-1

S.O. 244-3191

SIZE 211X467.5

C.E. 459X8364

B.P.

DATE 10-19-71

NO. PROOFS PROOF DATE CHANGE A 1-11-72 CHANGE B CHANGE C