Interpretation ID: nht81-3.3

DATE: 07/31/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: C. J. B. Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Carol Fitzjohn Quality Control Manager C.J.B. Industries, Inc. P. O. Box 779 Chanute, Kansas 66720

Dear Mr. Fitzjohn:

This responds to your June 2, 1981, letter asking about the requirements for reservoir tanks for air brake systems. In particular, you ask whether section S5.1.2.2 and S5.2.1.3 are the only Federal requirements applicable to the manufacture of the reservoirs.

The two sections that you referenced in your letter are the only sections specifying requirements for the construction of reservoirs for air brake systems. For additional guidance in the construction of reservoirs, you should refer to SAE Standard J10b titled "Automotive and Off Highway Air Brake Reservoir Performance and Identification Requirements." This standard will provide you with the prevailing industry practice in the construction of reservoirs.

You should be aware that you would be responsible under the National Traffic and Motor Vehicle Safety Act if there were any defect relating to motor vehicle safety in your product.

Sincerely,

Frank Berndt Chief Counsel

June 2, 1981

NHTSA Office of Chief Counsel, NOA-30 400 Seventh St. Southwest Washington, D. C. 20590

Gentlemen:

As a manufacturer of pressurized containers, we from time to time are asked to design and or manufacture components for over the road vehicles; and as such have been approached recently by a prospective customer to manufacture a reservoir under the provisions of the "Motor Vehicle Safety Standard No. 121." However, this is where the problem arises. The standard as written does not specify in detail the construction of the reservoir, with respect to materials to be used or the wall thickness of the tank, or list a reference to any other document to which this information is found.

It is imparative for us to manufacture components in the least expensive way and still maintiin a high degree of quality. Therefore, to exceed provisions of a standard only enhances the construction costs.

We would appreciate an opinion on the clarity of sections S5.1.2 through S5.2.1.5 as to whether the construction of said reservoir meet only the provisions of sections S5.1.2.2 and S5.2.1.3; or are there additional requirements not contained therein.

We appreciate any consideration to this matter you can give us in a short amount of time.

Respectfully,

Carol Fitzjohn Quality Control Manager C.J.B. Industries, Inc.

CDF/pac