Search Interpretations

Interpretation ID: GF006496

    Mr. Merrill Sutton
    Tie Down Engineering, Inc.
    5901 Wheaton Drive
    Atlanta, GA 30336


    Dear Mr. Sutton:

    This responds to your facsimile and subsequent phone conversation with George Feygin of my staff regarding the possibility of placing your companys name on "side two" of brake hoses manufactured by Meiji Rubber and Chemical, Ltd. (Meiji). You indicated that Meiji is duly registered with the U.S. Department of Transportation (DOT) as a brake hose manufacturer. Further, Meiji is prepared to place your name, as a distributor, on "side two" of the brake hose.

    By way of background, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements. The issues raised by your letter are addressed below.

    Federal Motor Vehicle Safety Standard No. 106 (FMVSS No. 106) has certain labeling requirements. S5.2.1 of the standard states:

    S5.2.1 Each hydraulic brake hose shall have at least two clearly identifiable stripes of at least one-sixteenth of an inch in width, placed on opposite sides of the brake hose parallel to its longitudinal axis. One stripe may be interrupted by the information required by S5.2.2, and the other stripe may be interrupted by additional information at the manufacturer's option." (Emphasis added.)

    Based on the language of the standard, Meiji, as a manufacturer of brake hoses, is permitted to enter "additional information" on the other side of the brake hose at its option. Such "additional information" can include, among other things, the name of your company.

    We note that one side (or "side one") of the brake hose must contain information as required by S5.2.2. Specifically, the one side of the brake hose must include: (a) the symbol DOT; (b) a designation that identifies the manufacturer of the hose; (c) the nominal inside diameter of the hose; (d) the month, day and year of manufacture; [1] and (e) either "HR" to indicate regular-expansion hydraulic hose or "HL" to indicate low-expansion hydraulic hose.

    I hope this information is helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    Enclosure
    ref:106
    d.10/9/03


    [1] Your facsimile contained drawings of the brake hose in question. We note that the drawing of "side one" of the brake hose contains only the month and year of the manufacture but not the date.