Interpretation ID: aiam1949
Moss Motor
Ltd.
P.O. Box 'MG'
5775 Dawson Avenue
Goleta
California;
Dear Mr. Moss: #The President has asked me to reply to your letter o February 9, 1976, concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to replacement brake hoses for MG sports cars built from approximately 1945 to 1955. #All brake hose and brake hose end fittings manufactured on or after September 1, 1974, must meet the performance and labeling requirements of Standard No. 106-74. All brake hose assemblies manufactured on or after March 1, 1975, must meet those performance and labeling requirements in the standard that apply to assemblies and, with an exception noted below, must be constructed of conforming hose and end fittings. #The Federal motor vehicle safety standards are not applicable to classic or antique card in the following sense: a standard applies only to a motor vehicle or item of motor vehicle equipment that is manufactured after its effective date. Thus, for example, there is no requirement that MG's in question be retrofitted with conforming brake hose. However, any person manufacturing brake hose for use in such a vehicle must, on and after September 1, 1974, ensure that the hose conforms. #You may find some relief in S12 of the standard. To facilitate the depletion of inventories of hose manufactured before September 1, 1974, that conforms to all aspects of the standard except the labeling requirements, this provision permits the use of such hose in assemblies manufactured before September 1, 1976. #There are no Federal motor vehicle safety standards that apply to hydraulic brake system components other than Standard No. 106-74, *Brake Hoses*, and Standard No. 116, *Motor Vehicle Brake Fluids*. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs;