Interpretation ID: nht89-1.49

TYPE: Interpretation-NHTSA

DATE: March 22, 1989

FROM: Heracilio R. Prieto -- President, Easton, Inc.

TO: Erika Jones -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-27-90 from P.J. Rice to H.R. Prieto (A36; Std. 116)

TEXT:

Our company has blended and packaged brake fluids in Puerto Rico for over 10 years. We have always interpreted that the lot number/packaging date must be printed directly on the brake fluid container for us to be in strict compliance under FMVSS 116.

Given the aggressiveness of brake fluids on any ink, we have always wished we were allowed to use a label notch coding system which we have used successfully for years in our detergent packaging operation. The relative simplicity of the mechanical devic e, vis-a-vis the jet-ink coder, also makes thc notch system operationally more reliable.

The recent revisions in S5.2.2.2 of standard 116 seem oriented to demand indelibility and permanence in the information required on the brake fluid label or container. No ink system could possibly match the notched label on either count. In the spirit of this new approach, I urge you to consider the notch system as an acceptable method of batch/date coding brake fluid bottles.

I am attaching copies of the literature from the exclusive supplier of this system for your perusal.

I hope you concur with our assessment and look forward to your comments. Please let me know if you need any additional informational from us.

Attached is literature entitled Codedge Label Dating Machine (text omitted).