Interpretation ID: nht92-1.22

DATE: December 16, 1992

FROM: Bryan D. Patton -- International Automobile Ent. Inc. D.B.A. ERA Replica Automobile

TO: Paul Jackson Rice -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5-12-93 from John Womack to Bryan D. Patton (A41/ Std. 106)

TEXT: I am writing you in regards to a conversation I had with Zack Fraser, an Engineer in the safety compliance division of NHTSA (Phone 202-366-2830).

I asked Mr. Fraser which US DOT regulations had to be met for tubing used for hydraulic brake lines in an automotive application. Mr. Fraser responded that there were no codes of regulations dealing specifically with these lines in this application.

He did say that in the absence of federal regulations that the SAE standard would generally be used to determine suitability of a material to be used in such an application.

If possible, I would like a statement of fact from NHTSA recognizing that:

1) International Automobile Enterprises Inc. has contacted you in this matter.

2) There are no specific federal codes or regulations regarding the use of tubing for use as automotive hydraulic brake lines.

3) The SAE standard would be used to determine such suitability in the absence of a specific federal code or regulation.

Our purpose for requesting this documentation is to be able to substantiate that International Automobile Enterprises Inc. has made an effort in good faith to research all applicable federal motor vehicle safety standards, or any SAE specifications used in place of federal specifications.

Not being an attorney, I suspect the above statements may have to be reworded or altered, but these statements are true to the best of my knowledge based on my conversations with Mr. Fraser.

Thank you for your cooperation in this matter.