Interpretation ID: aiam2421
Director of Engineering
Power Controls Division
Midland-Ross Corporation
490 South Chestnut Street
Owosso
MI 48867;
Dear Mr. Denholm: This responds to Midland-Ross' September 30, 1976, question whether th 'method' specified by Compliance Testing, Inc., in its December 8, 1975, Technical Proposal for Solicitation NHTSA-6-A212 is consistent with the laboratory procedure contemplated by the NHTSA for its test contractors in evaluating the compliance of air-braked vehicles with Standard No. 121, *Air Brake Systems*. The NHTSA laboratory procedure for compliance contractors in the case of Standard No. 121 states in relevant part:; >>>*PROCEDURE*: A. Physically locate check valve or equivalent device. B. Following manufacturer's recommendation, check the check valve o equivalent device for proper function without disconnecting any air line or fitting. Describe method and technique used.<<<; The Compliance Testing, Inc. (CTI) solicitation was evaluated alon with other proposals and has been accepted by the NHTSA. The 'method' set forth by CTI as its intended course of action in evaluating the compliance of valves in accordance with the requirements of S5.1.2.3 will not appear in the manual produced for NHTSA compliance testing.; I would like to note in closing that this letter does not constitute a interpretation of the requirements of Standard No. 121. Although the laboratory procedure sets forth the method by which contractors satisfy NHTSA contracts, it does not mean that a vehicle need not meet the requirements of the standard when tested according to its terms by other methods.; Sincerely, Frank A. Berndt, Acting Chief Counsel