Tech Service Rep
Dana Drivetrain Services Division
P.O. Box 321
Toledo, Ohio 43697-0321
Dear Ms. Morrow:
This responds to your letter to the National Highway Traffic Safety Administration (NHTSA), Office of Safety Performance Standards, asking several questions about labeling requirements in Standard No. 106, Brake hoses, for Atube and hose assemblies@ used in air brake applications. Your letter was referred to my office for reply. I apologize for the delay in the agency=s response.
Some background information about Standard 106's labeling requirements would be helpful in answering your questions. Standard 106 applies to new motor vehicles and to new brake hoses, brake hose end fittings, and brake hose assemblies manufactured for use in motor vehicles. Section S4 of the standard defines various terms that are relevant to your inquiry. Section S7.2 sets forth requirements related to the labeling of air brake hoses (S7.2.1), air brake hose end fittings (S7.2.2), and air brake hose assemblies (S7.2.3). New brake hoses, end fittings, and assemblies must meet these requirements to be sold in or imported into this country. If the items do not comply, the manufacturer is subject to civil penalties and recall responsibilities.
Section S4 of Standard 106 defines Abrake hose@ as a Aflexible conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid or vacuum used to apply force to a vehicle=s brakes.@ (Emphasis added.) Please note that NHTSA=s longstanding position is that the term Aflexible@ in the definition of Abrake hose@ excludes steel tubing. (See NHTSA=s response to petitions for reconsideration, 39 FR 7425, February 26, 1974, copy enclosed.) Flexible plastic tubing is considered to be brake hose.
Section S7.2.1 specifies that AEach air brake hose shall be labeled, or cut from bulk hose that is labeled, at intervals of not more than 6 inches, measured from the end of one legend to the beginning of the next@ with certain information, including a designation that identifies the manufacturer and the symbol DOT. The symbol DOT constitutes a certification by the brake
hose manufacturer that the hose conforms to all applicable motor vehicle safety standards. The requirement further states that AThe information need not be present on hose that is sold as part of a brake hose assembly or a motor vehicle.@
Section S4 defines Abrake hose end fittings@ as Aa coupler, other than a clamp, designed for attachment to the end of a brake hose.@ Section S7.2.2 specifies that AExcept for an end fitting that is attached by deformation of the fitting about a hose by crimping or swaging, at least one component of each air brake hose fitting shall be etched, embossed, or stamped@ with information that includes the symbol DOT.
Section S4 defines Abrake hose assembly@ as Aa brake hose, with or without armor, equipped with end fittings for use in a brake system, but does not include an air or vacuum assembly prepared by the owner or operator of a used vehicle, by his employee, or by a repair facility, for installation in that used vehicle.@ Section S7.2.3 specifies that AEach air brake hose assembly made with end fittings that are attached by crimping or swaging, except those sold as part of a motor vehicle, shall be labeled@ by either a band around the brake hose assembly marked with certain information, or at the manufacturer=s option, by etching, stamping or embossing at least one end fitting with the manufacturer=s designation.
With this background in mind, I will now respond to your specific questions.
(1) Do tube fittings need to be stamped ADOT@?
The answer depends in part on whether the tubing to which the end fitting attaches is flexible. As noted above, NHTSA=s longstanding position is that the term Aflexible@ in the definition of Abrake hose@ excludes steel tubing or fittings for such tubing. Because there are no Federal requirements that regulate fittings for steel tubing, such fittings should not be certified with the DOT mark.
Plastic tubing is brake hose, so fittings for such hose are subject to the labeling requirements set forth in S7.2.2. Under that section, end fittings (other than those that are attached by deformation of the fitting about the hose by crimping or swaging), have to be marked with specified information, including ADOT.@ There are no labeling requirements for end fittings that are attached by crimping or swaging.
(2) Does tubing need to be marked ADOT@?
Assuming the tubing is flexible, the answer is yes, brake hose is required to be labeled with the symbol ADOT@ or cut from bulk hose that is labeled at intervals of not more than 6 inches with the symbol ADOT,@ under the requirements set forth in S7.2.1. (Note that under that section, the information need not be present on hose that is sold as part of an assembly or motor vehicle.)
(3) Do reusable (field attachable) hose ends need to be stamped ADOT@?
At least one component of a reusable (field attachable) hose end fitting is required to be stamped with the symbol DOT, and other information, under the provisions set forth in S7.2.2.
(4) Do permanently attached (crimped) ends need to be stamped ADOT@?
A crimped end fitting would not be required to be stamped with the symbol ADOT,@ under the exception set forth in S7.2.2.
(5) Does hose need to be marked ADOT?@
Our answer to Question Two should answer this question.
(6) Does an assembly of tubing with tube fittings for air brake systems need to be labeled if it is assembled by one party for resale/use by a second party?
Assuming you are referring to a brake hose assembly made up of end fittings that are attached by crimping or swaging, the assembly would have to be labeled under section S7.2.3. It can be labeled by either a band around the brake hose assembly or by etching, stamping or embossing at least one end fitting. An exception to this requirement is that a brake hose assembly sold as part of a new motor vehicle need not be so labeled.
As explained in our answer to your next question, an assembly made with reusable end fittings is not required to be labeled.
(7) Does a brake hose assembly with reusable (field attachable) ends need to be labeled if it is assembled by one party for resale/use by a second party?
Under section S7.2.3, an air brake hose assembly with reusable ends is not required to be labeled, because only those brake hose assemblies made with end fittings that are attached by crimping or swaging must be labeled. In an earlier interpretation letter to Stratoflex, Inc. dated January 15, 1987 (copy enclosed), the agency explained that
Standard No. 106 requires only that the end fittings be labeled and does not set a labeling requirement for the assemblies. These provisions were made in the standard because NHTSA believed labeling requirements for assemblies having renewable or reusable end fittings were impractical. NHTSA concluded that with reusable end fittings, the assembler=s identity could be lost or misapplied by a person reassembling the set at a later date, and the chances for confusion concerning the identity of the assembler would be great.
Even though the brake hose assembly is not required to be labeled, at least one component of each air brake hose fitting must be etched, embossed, or stamped with specified information, including the symbol DOT, under S7.2.2.
(8) Does a brake hose assembly with permanently attached (crimped) ends need to be labeled if it is assembled by one party for resale/use by a second party?
Our answer to Question Six should answer this question.
I hope this information is helpful. If you have further questions, please contact Mr. Marvin Shaw of this office at (202) 366-2992.
Samuel J. Dubbin Chief Counsel