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Interpretation ID: nht87-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 01/15/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Norm Alexander

TITLE: FMVSS INTERPRETATION

TEXT:

Norm Alexander, Manager Engineering Customer Service Stratoflex, Inc. P.O. Box 10398 Fort Worth, TX 76114

Dear Mr. Alexander:

This responds to your two letters to me concerning the labeling requirements of Federal Motor Vehicle Safety Standard No. 106, Brake Hoses, for air brake hoses, end fittings, and assemblies. I regret the delay in responding to your inquiry.

Before I begin to answer your specific questions, it might be helpful to explain that Standard No. 106 has separate sections setting requirements for hoses, end fittings, and assemblies used in hydraulic, air and vacuum brake systems. The section of the standard that you are concerned with is S7, the requirements for air brake hoses, brake hose assemblies, and brake hose end fittings. Section S7.2 sets forth the labeling requirements for those items of equipment, and is further subdivided into three par ts: paragraph S7.2.1 regarding hose; S7.2.2 regarding end fittings; and S7.2.3 regarding assemblies.

Your first question asks for confirmation of your understanding that air brake hose is labeled according to paragraphs S7.2.1(a) through (e). Your understanding is correct. Air brake hoses (that are not part of a brake hose assembly) must be labeled acco rding to the specifications of paragraph S7.2.1. Paragraphs S7.2.1(a) through (e) list the required information.

You asked whether end fittings that are to be attached by means other than crimping or swaging are labeled pursuant to S7.2.2(a) through (d). You are correct that paragraphs S7.2.2(a) through (d) list the information required to be labeled on the end fit tings you described. They are labeled in the manner specified in the lead-in sentence of S7.2.2.

Your next question concerned labeling requirements for end fittings that are to be attached by crimping or swaging. You asked whether you would label those end fittings pursuant to S7.2.3.1. As explained below, the answer to your question is yes, provide d that you also manufacture the brake hose assembly.

Paragraph S7.2.3.1 is part of the subparagraph which sets labeling requirements for assemblies. Thus, S7.2.3.1 describes an option for labeling air brake hose assemblies made with end fittings attached by crimping or swaging. A manufacturer of end fittin gs which are to be attached by crimping or swaging is not required to label the fittings if that manufacturer does not also assemble them. Such a manufacturer may voluntarily label its fittings. However, as explained below, if it voluntarily marks its fi ttings, the fitting manufacturer should keep records of its production lots showing whether the marking on a particular lot of end fittings is a voluntary label or whether it was made to identify itself as the assembler.

Because Standard No. 106 requires an assembler using crimped or swaged end fittings to identify itself as the manufacturer of the assembly, there is a chance for confusion if the assembler chooses to label by marking the end fittings pursuant to S7.2.3.1 and the fitting manufacturer had previously voluntarily marked the fittings with its own designation. In order to reduce the chances of confusion and facilitate enforcement efforts in determining who is responsible for the manufacture of the assembly, w e encourage manufacturers who voluntarily label their fittings to keep adequate records indicating whether they have sold the fittings separately to an assembler or whether they have used the fittings in assemblies they have produced themselves.

Your fourth question asked about labeling requirements for air brake hose assemblies that use end fittings that are not attached by crimping or swaging. You are correct 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 persons reassembling the Bet at a later date, and the chances for confusion concerning the identity of the assembler would be great.

Your fifth question asked whether air brake hose assemblies made with end fittings attached by crimping or swaging, except those made and installed by a vehicle manufacturer in its own vehicles, may be labeled by means of a band pursuant to S7.2.3 or by marking the end fitting as specified in S7.2.3.1. The answer is yes. Standard No. 106 provides manufacturers of those types of assemblies the option of labeling their assemblies according to either S7.2.3 or S7.2.3.1.

The second part of your fifth question also concerned Standard No. 106's labeling requirements for air brake hose assemblies made with crimped or swaged end fittings. You asked whether your understanding is correct that a "component manufacturer's identi fication on a fitting is sufficient for hose assemblies fabricated by the component manufacturer: but bulk products procured and assembled by a second party (not vehicle manufacturer) must be marked by that assembler - tag or fitting."

Your understanding is correct. A manufacturer of crimped or swaged end fittings who also manufactures brake hose assemblies may satisfy the standard's labeling requirements by marking its identification on its fitting. A manufacturer of brake hose assemb lies who purchased its end fittings must label the assembly by a tag (pursuant to S7.2.3) or by labeling the end fitting (pursuant to S7.2.3.1).

Your next question asked whether standard No. 106 requires manufacturers to mark the date of assembly on their brake hose assemblies. The answer is no.

Your final question asked whether additional information may be entered on the hose assembly tag. The answer to your question is yes. NHTSA has interpreted Standard No. 106 as permitting the labeling of brake hose with optional information in addition to that required by the standard if, in order to avoid confusion with the required information, the optional information appears on the opposite side of the hose. Based on those interpretations, we conclude that you are permitted to label your assemblies w ith optional information if the labeling is done in a manner that avoids confusion with the required information.

I hope this information is helpful. Please contact my office if you have any further questions.

Sincerely,

Erika Z. Jones Chief Counsel

August 25, 1986

Department of Transportation 400 7th Street SW Washington, D.C. 20590

Attention: Ms. Erika Jones Chief Counsel Room 5219

Subject: FMVSS 106-74, as amended

Dear Ms. Jones:

Pursuant to my conversation with Ms. Deidre Hom on August 22, 1986; we respectfully submit our understanding of the marking/labeling requirements of Section S7, subject standard. We request written confirmation of this understanding or correction(s) as r equired. Stratoflex is a manufacturer of crimp and non crimp (screw together) fittings and hose to provisions of FMVSS 106.

1. Hose - per S7.2.1 (a) thru (e).

2. End Fittings (not crimped or swaged) - per 57.2.2 (a) thru (d).

3. End fittings (crimped or swaged) - per S7.2.3.1 (at least one fitting per assembly, assembler identification)

4. Hose assembly with non crimped/swaged fittings - No marking other than components (1 and 2 above).

5. Hose assembly with crimped/swaged fittings - Band per S7.2.3 (a) and (b) or fitting only per 3 above. (See note below)

NOTE: No marking required for hose assemblies assembled and installed by a vehicle manufacturer.

Item 3 above (and the alternate of item 5) indicates that component manufacturer's identification on a fitting is sufficient for hose assemblies fabricated by the component manufacturer; but, bulk products procured and assembled by a second party (not ve hicle manufacturer) must be marked by that assembler - tag or fitting.

Is the date of assembly (fittings to hose) required?

May additional data be entered on the hose assembly tag?

Thank you for your consideration and assistance. Please feel free to contact us if any additional clarification is required.

Very truly yours,

S T R A T O F L E X , I N C .

Norm Alexander, Manager Engineering Customer Service