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The check, before the first fill

Updated

On this page8
Five questions. One of them is a fifteen-minute bench test written into a federal standard.

One: which rule are you under?

Brake fluid or hydraulic system mineral oil puts you under 49 CFR 571.116, with its own packaging, labeling and test clauses. Anything else goes to the thresholds in 16 CFR 1700.14 and the labeling triggers in 16 CFR 1500.14.

Two: what are the percentages by weight?

Methanol against 4 percent, ethylene glycol against 10, hydrocarbons summed against 10 with a viscosity under 100 SUS. Write down each computed figure, not the conclusion you drew from it.

Three: does the closure do what the rule asks?

For brake fluid, resealable with an impervious inner seal and a tamper-proof feature destroyed on first opening. For a crossed threshold, special packaging tested to the effectiveness specifications. Get the supplier’s test position in writing.

Four: are the required words present, exactly?

Seven items and four verbatim warnings for brake fluid, never on a removable part. A specified signal word and statement for glycol. Signal word plus two statements for petroleum distillates. Reproduce, do not rewrite.

Five: does the label survive its own fluid?

Slit it vertically, immerse the filled container for 15 minutes at room temperature, wipe it, and read the required information from 305 mm. Then try to peel it: it must not come off without being destroyed or defaced.

And keep a safety data sheet behind all of it

Hazard communication is a separate obligation that applies to the shipped container regardless of which consumer rule you cleared. It is the item most often assumed to be somebody else’s.

File the five answers with the batch record

Rule, percentages, closure and its test position, label text, and the immersion result with the dated sample. A reformulation or a new supplier then takes an hour to recheck rather than being taken on trust.

References

49 CFR 571.116, Federal Motor Vehicle Safety Standard No. 116, Motor vehicle brake fluids. S5.2.1 requires every container of 177 mL or more to have a resealable closure with an inner seal impervious to the fluid and a tamper-proof feature destroyed or substantially altered on first opening. law.cornell.edu
49 CFR 571.116 S5.2.2, on certification, marking and labeling: seven required items on the container or a permanently affixed label, never on a removable part such as a lid, including the DOT grade, the minimum wet boiling point in Fahrenheit, a packaged-lot serial number and four verbatim safety warnings. S5.2.2.4 moves the labeling to an outer carton where the container is not normally visible. law.cornell.edu
49 CFR 571.116 S6.14, Container information: cut the label vertically all the way through, immerse the container in the fluid it holds for 15 minutes at 23 plus or minus 5 C, wipe it dry, and the required information must remain legible to an observer with 20/40 vision at 305 mm. law.cornell.edu
16 CFR 1700.14, Substances requiring special packaging. Paragraph (a)(8) covers methanol at 4 percent or more by weight; (a)(11) ethylene glycol at 10 percent or more; (a)(31) nonemulsion liquid household chemical products at 10 percent or more hydrocarbons by weight under 100 SUS at 100 F. law.cornell.edu
16 CFR 1500.14, Products requiring special labeling. Paragraph (b)(2) requires "warning" and "Harmful or fatal if swallowed" for 10 percent or more ethylene glycol; (b)(3)(ii) requires "danger", "Harmful or fatal if swallowed" and "Call physician immediately" for 10 percent or more petroleum distillates, because they may be aspirated into the lungs. law.cornell.edu
29 CFR 1910.1200, Hazard Communication, which sets what a shipped container of a hazardous chemical carries and requires a safety data sheet. law.cornell.edu
Written from federal regulation and from measured catalog data, not from a blending bench. We sell containers and closures; whether a particular closure satisfies a particular clause is a question about that closure and its supplier’s testing, and nothing here certifies a package as compliant. Anything on these pages is a starting point.