Mr. Tom Byrne
Vice President
Goodridge (USA) Inc.
20309 Gramercy
Torrance, CA 90501

Dear Mr. Byrne:

This responds to your April 19, 1996 request for an interpretation of certain hydraulic brake hose labeling requirements in Federal Motor Vehicle Safety Standard No. 106, ABrake Hoses.@

You ask whether a hydraulic brake hose that is sold as part of a brake hose assembly would meet the requirements of S5.2.1 and S5.2.2 if it has the stripes specified in S5.2.1 but does not include the information in S5.2.2(a) through (e). The answer is yes.

Hydraulic brake hoses must be marked with: (1) two stripes meeting the requirements of '5.2.1 of Standard No. 106, unless the hose is of a type excluded under that paragraph; and (2) the information set forth in '5.2.2(a) through (e), until the hose is made into a brake hose assembly. After such assembly, the labeling information of '5.2.2(a) through (e) Aneed not be present on hose . . . .@ (See last sentence of '5.2.2.) However, the hose must continue to have the stripes required by '5.2.1. In addition, the hose assembly would have to be labeled in accordance with the requirements of '5.2.4 or '5.2.4.1 for labeling hydraulic brake hose assemblies.

If you have any further questions, please contact Mr. Marvin Shaw of this office at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:106 d:5/10/96