Mr. Dave Brass
Dana Weatherhead Publications Supervisor
P.O. Box 455
Toledo, OH 43697-0455

Dear Mr. Brass:

This responds to your letter asking about labeling requirements in Standard No. 106, Brake Hoses, for air brake hose assemblies. You state that you supply brake hose and brake hose end fittings that are marked pursuant to Standard No. 106. You then ask whether under '7.2.3, a distributor such as NAPA Auto Parts Stores, has to attach a band to an air brake hose assembly that it crimps within its stores.

Section 7.2 of Standard No. 106 sets forth requirements related to the labeling of air brake hoses ('7.2.1), air brake hose end fittings ('7.2.2), and air brake hose assemblies ('7.2.3). Section 7.2.3 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 (1) a band around the brake hose assembly marked with certain information, or (2) at the manufacturer=s option, by etching, stamping or embossing at least one end fitting with the manufacturer=s designation. An exception to this requirement is that a brake hose assembly sold as part of a new motor vehicle need not be so labeled.

Under your example, NAPA would be the manufacturer of the assembly. As an assembler, NAPA is required to either label the brake hose assembly with either a band around it or by etching, stamping or embossing at least one end fitting. In other words, your customers would need to label air brake hose assemblies that they crimp or swage.

In response to your question about paragraph S4, our response is that the purpose of this paragraph is to define relevant terms in the Standard, such as Abrake hose,@ Abrake hose assembly,@ Abrake hose end fittings,@ and Apermanently attached end fitting.@ These definitions would not eliminate or otherwise affect the need for a distributor to comply with the labeling requirements set forth in S7.2.3.

I hope this information is helpful. If you have further questions, please contact Mr. Marvin Shaw of this office at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

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