PART 1 - What is the Importance of DOT Compliance for Motorcycle Rider Safety to manufacturers and dealers?
This month AMD Magazine is restarting an industry informational and advisory content concept that we pioneered in the 1990s. The idea was simple enough – to leverage the knowledge and experience of leading vendors, industry experts and respected insiders in dealing with some of the market’s important technical issues. To get us started, we invited Scott Hurwitz, founder and CEO of Pittsford, New York based specialist Magnum Shielding, to discuss the complex matrix of issues that affect the design, manufacturing and engineering of brake lines – one of motorcycling’s critical components - and the importance of meeting DOT regulations …
A supplier to Harley-Davidson’s P&A program, Magnum Shielding Corporation also sells Magnum label brake hoses to the international aftermarket - to selected independent custom businesses and through our distribution partner Drag Specialties to its dealers.
No surprise then that rider safety is taken very seriously. Through vigorous process controls and quality standards, Magnum ensures compliance (for all their brake line categories) with DOT specifications and requirements as set forth by the National Highway Traffic Safety Administration (NHTSA). But what does that actually mean? Why is it so important, and how do the answers to these questions affect your business and perhaps your reputation?
|The name of the manufacturer must be clearly identified|
|As is the case with many product groups, DOT regulations make labeling as important to achieving full compliance as the quality of the product itself|
Common questions often asked are: who determines the DOT criteria, how is it enforced, what are the requirements of DOT compliance (Part 2 of this series), and most importantly, how does this affect the dealer?
You may also wonder how to determine if the motorcycle brake lines being sold for highway use are compliant and legal, especially considering dealer liability if an accident occurs where brake line failure is claimed to be a cause or is argued to be a contributing factor. Unfortunately, the reality of our times is that the popularity of auto accident law firms and their “aggressive case capture advertising” make this an even bigger issue than ever.
|Magnum Shielding CEO Scott Hurwitz: “For brake lines, the standard is FMVSS-106 and this standard specifies and defines labeling and performance requirements for vehicle brake hose and brake hose end fittings”|
So, let’s start with the governing agencies that are running the show.
The NHTSA is an arm of the Department of Transportation (DOT). NHTSA’s mission is to “Save lives, prevent injuries, and reduce vehicle-related crashes.” As part of its activities, they write and enforce the Federal Motor Vehicle Safety Standards (FMVSS) covering basic safety equipment (e.g. tires, headlamps/tail lamps, and brake hoses and brake hose assemblies.) For brake lines, the standard is FMVSS-106, and this standard specifies and defines labeling and performance requirements for motor vehicle brake hose and brake hose end fittings.
The purpose of this standard is to reduce deaths and injuries occurring as a result of brake system failures from pressure loss due to leaks or ruptures. It is assumed that if a manufacturer’s brake hose assemblies meet this standard, by virtue of passing all the numerous testing criteria defined in the standard, then they will have done their due diligence and the brake lines will be safe to use.
Interestingly enough, the FMVSS-106 standard establishes performance requirements, without dictating design specifications. This is left entirely to the manufacturer of the brakes lines. However, it is illegal to market a product that does not conform to the safety standard or would take a vehicle out of compliance with it. If a product is covered by an industry FMVSS standard, NHTSA anticipates the product complies, otherwise, the company may risk product liability exposure, and NHTSA could deem the product to be unsafe.
Brake line manufacturers and importers selling assemblies intended for street driven motorcycles are required to register with NHTSA, given that such products are “covered by an FMVSS.” NHTSA then assumes “self-certification” and assigns manufacturers identification numbers associated with their chosen “Symbol” and places the company in their Manufacturer Database.
At this point, NHSTA or DOT does not “approve” the brake lines for use on licensed vehicles, neither does it require submission or proof of any documentation regarding the safety of these aftermarket parts, unless triggered by an incident or event.
Then, NHTSA has the authority to conduct an investigation and order a product removal from the marketplace should the product be found not to comply with the Safety Standard. This includes the removal of previously installed brake lines. Given this, it would be prudent to determine if the brake lines you are currently selling are indeed compliant.
Sometimes the words “For Off-Road Use Only” are seen on packaging. Is this a legal term? Surprisingly, “off-road” and “off-road vehicles” are not terms defined in NHTSA regulations and therefore have no legal meaning. All it really means is that the manufacturer cannot control or enforce how the product will be used.
Simply put, brake lines are subject to the FMVSS, and if they are manufactured to replace equipment covered by the FMVSS, especially if they have published fitments for specific year/model on-road motorcycle (motor vehicle) applications, then the brake lines are legally required to be compliant.
With so many choices available for motorcycle brake lines, it’s not surprising to find that many are not compliant with FMVSS-106 motor vehicle safety requirements. Dealers must be aware that in the event of a braking related accident, they may be deemed negligent for selling and/or installing an “off-road” product for a licensed motor vehicle.
So, how would one know if the brake lines, formally referred to as brake hose assemblies, are FMVSS-106 compliant? The easiest way is to look on the product packaging for mention of DOT FMVSS-106 compliance. Another means of checking is to look in manufacturer and/or distributor catalogs for product descriptions. Because DOT compliance is such a huge deal, not to mention a well-earned accomplishment, for marketing purposes, one would think that any savvy manufacturer’s or marketer’s catalog ad copy will surely make mention of compliance.
However, the best way to know for sure is to look for the proper identification, or “labeling”, on the brake hose assembly itself. There are three options manufacturers have to accomplish this:
A band may be attached so as to move freely along the length of the assembly. It shall be etched, embossed, or stamped with both the symbol DOT and the manufacturer’s designation or symbol.
The brake hose may be labeled directly in block capital letters and numerals with the symbol DOT, the manufacturer’s designation or registered symbol, the date of manufacture, the outside diameter (OD) of the hose, and HR to designate its volumetric expansion rating.
At least one end fitting of the hydraulic brake hose assembly is etched, stamped or embossed with a designation that identifies the manufacturer and is filed with NHTSA.
Stripes are also included in DOT labeling requirements and must be placed on the brake hose parallel to its longitudinal axis to prevent twisting during assembly and installation. If you do not see this printed stripe on an aftermarket assembly, the brake line is not FMVSS-106 compliant. Per the Standard, aftermarket assemblies are NON-OEM hose assemblies, and torque stripes are required.
The only exception to this labeling rule is if the brake hose is OEM and manufactured for use only in a brake line assembly whose end fittings prevent its installation in a twisted orientation.
Some manufacturers’ brake lines are TÜV approved. Basically, this means that a TÜV station or department (Technical Inspection Association) provides European accreditation by overseeing compliance with domestic and international guidelines, standards and directives. In this case, they oversee the process of testing and documentation associated with DOT FMVSS-106 criteria.
The takeaway from this article is that DOT FMVSS-106 compliance matters and is the primary way to ensure the safety of the rider, given that brake lines are integral to the safe operation of the motorcycle.
We at Magnum Shielding Corporation feel that it’s important for you to know the details of what to be aware of and what to look for when ensuring the protection of both your customers’ safety and your hard-earned business.
Stay tuned for Part 2 - the tests and testing procedures that must be passed to make the finished line and achieve compliance.