Interpretation ID: nht92-3.47

DATE: 09/21/92

FROM: KEVIN MITCHELL -- DEVELOPMENT ENGINEER, THE GOODYEAR TIRE AND RUBBER CO.

TO: PAUL JACKSON RICE -- CHIEF COUNCIL, NHTSA

COPYEE: J. GRAGG -- QUALITY ASSURANCE MANAGER; B. HENRY -- DEVELOPMENT MANAGER; R. ANDERSON -- PRODUCTION MANAGER; H. HILSON -- MARKETING MANAGER

TITLE: SUBJECT: CHANGE IN DOT PRINT LINE ON GOODYEAR HYDRAULIC BRAKE HOSE.

ATTACHMT: ATTACHED TO LETTER DATED 11-25-92 FROM PAUL J. RICE TO KEVIN MITCHELL (A40; STD. 106)

TEXT: Goodyear is currently in the process of improving the quality of our printing on hydraulic brake hose. The hose in question is used on passenger car brake systems and falls under the FMVSS 106 specification. The purpose is to improve the quality of the print by removing excess information which will improve the mechanical printing process.

Under section 5.2 labeling, Goodyear has in the past and is meeting all requirements of section 5.2.1 and 5.2.2. The question that has arisen involves section 5.2.2.c. Goodyear currently adds two additional letters to the date code for further traceability. The two additional letters spell out the "batch" and "shift" the hose was manufactured under, see below for current and new printing.

DOT print line old.

(1/16" Stripe) DOT - GY - 01/92 - 1/8 - HL

DOT print line new.

(3/32" Stripe) DOT GY 01/01/92 AA - 1/8 HL

SAE print line old.

(1/16" Stripe) GY - 1/8 - 5030 - 01/01/92 AA - SAE J1401

SAE print line new.

(3/32" Stripe) - 5030 SAE J1401

The batch and shift letters have always been added on the SAE line. To keep the information in a format which our customers are used to, we have moved them to the DOT and expanded the date to include month/day/year from month/year. Since section 5.2.2.c does not specifically say these letters can or cannot be added to the DOT print line, Goodyear is being proactive and asking for a written letter from the DOT committee to authorize these improvements before production starts.

We wish to begin the improved printing as soon as possible. If you could please expedite this request as quickly as possible it would be appreciated.