Interpretation ID: nht79-3.30

DATE: 01/26/79

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NSTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION Jan. 26, 1979 NOA-30

Mr. W. G. Milby Manager, Engineering Services Blue Bird Body Company P. O. Box 937 Fort Valley, Georgia 31030

Dear Mr. Milby:

This responds to your recent letter asking for confirmation that hoses running to air pressure gauges would not be considered "brake hoses" that are subject to Federal Motor Vehicle Safety Standard No. 106-74. Mr. Fred Redler of the agency's Office of Vehicle Safety Standards apparently discussed this matter in a telephone conversation with one of your engineers.

Safety Standard No. 106-74 specifies performance requirements for brake hoses used in motor vehicles. That standard defines a brake hose as,

"a flexible conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes."

If the hose in question is only connected to an air pressure gauge and does not transmit any fluid or pressure used to apply force to a braking system, it would not be considered a brake hose and would not be required to comply with Standard No. 106-74. This letter, therefore, confirms Mr. Redler's statements.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

November 30, 1978 Mr. Joseph J. Levin Chief Counsel National Highway Traffic Safety Administration Washington, D.C. 20590

Dear Mr. Levin:

This is to follow up a conversation between our Staff Engineer, Mr. Robert DuMond, and Mr. Fred Redler at NHTSA.

I am seeking confirmation of an interpretation given to Mr. DuMond by Mr. Redler relative to FMVSS 106-74, Brake Hoses and Fittings.

The question asked was whether FMVSS 106 applied to hoses running to air pressure gauges. Mr. Redler said that it did not because FMVSS 106 applies to brake hoses "...used to apply force to a vehicle's brakes." (Ref. S4). Would you please confirm this at your earliest possible convenience.

Thank you.

Very truly yours,

W. G. Milby Manager, Engineering Services