Interpretation ID: aiam1934
Alfred Teves GMBH
6 Frankfurt/Main 2
Postfach 119155
Germany;
Dear Mr. Beller: This responds to your April 29, 1975, question whether S5.4.3 o Standard No. 105-75, *Hydraulic brake systems*, permits a brake fluid warning statement on a filler cap to be partially obscured by two 'contact blades' on the cap which apparently are inserted into a receptacle attached to the vehicle. The description you enclose is similar to one submitted with an earlier request which we evaluated in a March 3, 1975, letter to your representative, Mr. Paul Utans.; Sections S5.4.3(b) requires that the statement be 'located so as to b visible by direct view.' As we noted in our March 3 letter, this requirement prohibits an arrangement which would obscure any parts of the statement. We also noted that S5.4.3(b) permits a location within 4 inches of the brake fluid reservoir filler plug or cap to accommodate arrangements which do not permit use of the filler cap as a location.; From the drawing you enclose, we conclude that the contact blade obscure part of the warning and it therefore would not comply with the requirement of S5.4.3(b). As an enforcement matter, we would find it impossible to allow a 'minor noncompliance' and still be able to enforce a standard objectively. We do not consider the ability to turn the cap to expose the warning to constitute 'visible by direct view.'; Yours truly, Richard B. Dyson, Assistant Chief Counsel