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OOSC, Part II, Item 1. Brake Systems, h. Air brake hose/tubing, (5) - crimped hoses/tubes

Entry DateAugust 27, 2023
Issue Number23-040-VEH
NameTim Cheever
AgencyThe Davey Tree Expert Company
Address4282 West Piute DriveBeverly Hills, FL, 34465United StatesMap It (opens in a new tab)
Phone7708833149
Fax(330) 552-2686
Email[email protected]
CommitteeVehicle Committee
StatusClosed
Summary of Issue

Brand new truck placed out of service under NASOOC *1. h. (5). :Damaged by heat, broken or crimped in such a manner as to restrict air flow. (393.45 (d). 395.45 (d) States: Brake tubing and hose connections. All connections for air, vacuum, or hydraulic braking systems shall be installed so as to ensure an attachment free of leaks, constrictions or other conditions which would adversely affect the performance of the brake system. No adverse effect on performance was measured or discovered during the Level 1 Inspection process.

Justification or Need

This issue was addressed in 2010 with brake experts weighing in however, no action was taken due to lack of a method to measure the restriction or reduction in diameter of the hose / tube and , if any, adequate air flow. Without, there is no justification of the existence of an Imminent Hazard. If no no way to verify the "adverse effect of performance per 393.45 (d), how is there an OOS linked to such. If there is a problem in braking performance, it would show in many other ways such as stroke measurement, lining contact with the drum / rotor or during a PBBT. If there is no adverse effect to the performance of the braking system, why would we use subjective opinion or assumptions to determine an OOS. Especially when such may be used in litigation or criminal accusations. Without addressing in 2010, leaves us once again, with the same questions around imminent hazard when brakes are functioning perfectly fine based on all factual inspection criteria.

Request for Action

Remove NASOOC *1. h. (5) from the criterium based on no measurement guidance and furthermore, this OOS Criteria is subjective in nature as no verification of imminent hazard exist. without a way to measure the existence of an "Adverse effect to the performance, there should not be an OOS. If a problem exist, it would appear in other ways and likely include a 20% OOS in addition to a stand alone brake violation.