Interpretation ID: aiam2408
Toyoda Gosei Co.
Ltd.
9
I-chome
Nishiyabushitacho
Nishiku
Nagoya
Japan;
Dear Mr. Yokoi: #This is in belated response to your April 9, 1976 letter concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to certain combination hydraulic brake hose assemblies. #Figure 3 of your letter depicts two typical brake hose assemblies that are connected end-to-end. Figure 4 depicts the intended installation of such a pair of assemblies, with the joined fittings meeting at a bracket that is attached to a shock absorber. Figure 1 and 2 show two designs to simplify the structure at this juncture. #Treating these figures in reverse order, the 'B type' design shown in Figure 2 is similar to the pair of assemblies shown in Figure 3, except that the pair of joined end fittings is replaced with a single center fitting. The National Highway Traffic Safety Administration (NHTSA) considers such a construction to be two distinct brake hose assemblies, which would be tested separately for compliance with Standard No. 106-74. The center fitting would simply be considered an end fitting for each of these assemblies. #the 'A type' design shown on figure 1 would be treated differently, however. In this design, the two separate pieces of hose are replaced by a single piece that runs the full length between the outermost end fittings. in place of joined fittings as in Figure 3 or a center fitting as in Figure 2, this hose would be surrounded by molded rubber and a metal ring. The ring would be mounted in the bracket that is attached to the shock absorber. The NHTSA considers this construction to be a single brake hose assembly, and testing for compliance with Standard No. 106-74 would be conducted accordingly. For example, the tensile strength test would be performed by pulling at the outermost fittings, on the full length of the hose. However, this interpretation would not require the assembly to be capable of meeting the whip resistance requirements of S5.3.3 with the full length subject to flex. The NHTSA considers such a brake hose assembly to have two distinct 'free lengths'--one on either side of the center metal ring. Therefore, the whip resistance test would be performed separately on each of these portions. In other words, the metal ring would be treated as an 'end fitting,' for the purposes of the whip resistance test described in S6.3. #Sincerely, Frank A. Berndt, Acting Chief Counsel;