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Interpretation ID: nht75-1.40

DATE: 03/18/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Central Electric Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of January 21, 1975 to Mr. Howard Dugoff of this agency, requesting a manufacturer's designation number for the brake hose assemblies which you manufacture.

S5.2.4(b) of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, was amended on January 29, 1974 (39 F.R. 3680; Docket No. 1-5; Notice 9), and again on February 26, 1974 (39 F.R. 7425; Docket No. 1-5; Notice 10).

In place of an assembler's code number, assigned by the National Highway Traffic Safety Administration, S5.2.4(b) of the standard now requires:

A designation that identifies the manufacturer of the hose assembly, which shall be filed in writing with: Office of Standards Enforcement, "Brake Hose Identification," National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590. The marking may consist of a designation other than block capital letters required by S5.2.4.

The designation need not include your company's address, or even its complete name, as long as it identifies the company and is filed with the NHTSA as described above. Furthermore, you do not need a separate designation for each of your two stores.

You have also described a Dymo label maker and requested approval of its use as a means of complying with the banding requirement of S5.2.4. The NHTSA interprets a band

as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. Furthermore, all of the label information must remain visible after the band has been affixed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of the specific design.

Yours truly,

ATTACH.

CENTRAL ELECTRIC COMPANY

January 21, 1975

National Highway Traffic Administration -- Department of Transportation

Attention: Howard Dungoff

Dear Sir:

We are an Aeroquip Distributor and we are contemplating making replacement hose on a very small scale for a few of the trucking companies in our area, and we want to comply with the Federal Motor Vehicle Standards, which go into effect March 1, 1975, requiring that all hose be banded when all new material is used.

We have 2 stores, one is Central Electric Company, Portsmouth, Ohio and Central Electric Company, Chillicothe, Ohio.

Will we be assigned one number for both stores or will we have a number for each outlet? If we have to have a number for each store, please assign us one for each store. Also is it necessary to emboss a company name and complete address, plus the number assigned to us by DOT?

We would like to know if it is permissable to use a Dymo tape label maker, which uses 1/2" wide aluminum metal tape, which has a self adhesive material on one side and can be wrapped around the hose, which will adhere itself to the hose?

Your quick reply to this will be greatly appreciated.

Very truly yours,

K. L. Hinze, President