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Interpretation ID: nht91-2.8

DATE: March 4, 1991

FROM: John E. Calow -- Sr. Safety Engineer, Oshkosh Chassis Division

TO: Chief Council, NHTSA

COPYEE: Gary Schmiedel

TITLE: None

ATTACHMT: Attached to letter dated 5-8-91 from Paul Jackson Rice to John E. Calow (A37; Std. 105; Std. 108)

TEXT:

Oshkosh Chassis Division (OCD) is submitting this letter for a written interpretation of FMVSS 105 with regard to Parking Brake actuation times.

It is OCD's understanding that there is no requirement for Parking Brake actuation times of hydraulic brake systems. This is based upon information attained from reference material 49 CFR 571.105.

OCD would appreciate a written affirmation or denial of our understanding of Parking Brake actuation times.

Thank you for your time.