American Motorcycle Dealer AMD 227 June 2018 | Page 56

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 …

Asupplier 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 ? 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

TECH EXTRA

Motorcycle Brake Lines

PART 1 - What is the Importance of DOT Compliance for Motorcycle Rider Safety to manufacturers and dealers ?

“ How does noncompliance affect the dealer or customizer ?”

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 . So , let ’ s start with the governing agencies that are running the show . The NHTSA is an arm of the Department of

“ Vigorous process controls and quality standards ”

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
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 ”
The name of the manufacturer must be clearly identified
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

“ Manufacturers and importers are required to register with NHSTA ”

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 “ offroad ” 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
56 AMERICAN MOTORCYCLE DEALER - JUNE 2018 www . AMDchampionship . com