Interpretation ID: nht81-1.16

DATE: 02/19/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Titeflex, Industrial Products Groups

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether air compressor discharge hose lines would be considered "brake hose" subject to the requirements of Safety Standard No. 106.

Safety Standard No. 106, Brake Hoses (49 CFR 571.106), defines "brake hose" as:

A flexible conduit 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.

This definition excludes the line from the air compressor to the supply tank, if that hose does not supply force to the vehicle's brakes in your system. Therefore, your hose would not be required to comply with Safety Standard No. 106.

In response to your question 1(b), any hose that supplies force, either directly or indirectly, to the vehicle's brakes is considered "brake hose", whether or not the hose is "right at the wheel brakes themselves" (as stated in your letter). For example, hose in brake booster systems is generally considered "brake hose."

In answer to your last two questions, there are no other Federal Motor Vehicle Safety Standards which would be applicable to air compressor discharge hoses. You will have to contact the individual States to see if there are applicable regulations at that level. We are not aware of any such State regulations, however.

Sincerely,

ATTACH.

Titeflex INDUSTRIAL PRODUCTS GROUP

October 24, 1980

Office of Chief Counsel -- National Highway Traffic Safety Administration

Gentlemen:

The purpose of this letter is to obtain clarifying information concerning your Motor Vehicle Safety Standard #106-74 ("Brake Hoses"), revised 7/7/76, and as amended by Notice #24 effective 5/25/78, copies of which I have.

Our company is a manufacturer of flexible Teflon hose and swaged fittings. We have been asked by numerous motor vehicle end-users (buses, motorcycles, race cars, etc.) throughout the U.S. as to whether or not our hose, fittings, and hose assemblies meet DOT specifications. Accordingly, we would appreciate your response to the questions below:

1. Among other things, paragraph S-4 of #106-74 defines "brake hose" (and "a brake hose assembly") as being" a flexible conduit manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a motor vehicle's brakes" (this pertains to hydraulic, air, and vacuum brakes).

(a) In public transit buses (e.g., those governed by UMTA's Transit Coach Specifications), must air compressor discharge flexible hose lines (air compressor-to-ping tank) be governed by Standard #106-74? Or are these compressor discharge lines considered only accessory lines and thus do not have to meet these specifications? Are these lines "in the brake system" or not?

(b) It is my understanding that only the actual brake hoses right at the wheel brakes themselves are the hoses which must comply with this standard. Is this correct?

2. This Safety Standard pertains only to "brake hoses". Are there any other Motor Vehicle Safety Standards, on a National basis, with which our hoses/assemblies must comply for any other motor vehicle application?

3. Finally, are there any individual state or local standards which apply for these or other flexible hose applications on any motor vehicle, assuming we comply with your national standards?

Your assistance in helping to clarify this matter will be most appreciated. Thank you in advance for your help.

Sincerely,

Robert J. McGurk -- Manager, Market Development