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Interpretation ID: aiam3843

Paul Escobosa, Esq., Dinkelspiel, Donovan & Reder, One Embarcadero Center - 27th Floor, San Francisco, California 94111; Paul Escobosa
Esq.
Dinkelspiel
Donovan & Reder
One Embarcadero Center - 27th Floor
San Francisco
California 94111;

Dear Mr. Escobosa: In reply to your letter of May 22, 1984, to Mr. Vinson of my office this is to advise you that you will find the truck air brake standard at 49 CFR 571.121, Motor Vehicle Safety Standard No. 121, *Air Brake System*.; As Mr. Vinson informed you, the 'Autostop' braking device about whic you inquired is not directly regulated by a Federal motor vehicle equipment of vehicle standard. However, its installation on a truck conforming to Standard No. 121 must not render the air brake system inoperative in whole or in part, pursuant to 15 U.S.C. 1397(a)(2)(A). If installation occurs before the truck is delivered to its first purchaser for purposes other than resale, the installer is required to attach a label to the truck in accordance with 49 CFR 567.7 that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards.; In any event, as an item of motor vehicle equipment, the 'Autostop' i subject to the notification and remedy provision of 15 U.S.C. 1411 *et seq.* in the event that either its manufacturer or this agency determines that it contains or creates a safety-related defect.; Sincerely, Frank Berndt, Chief Counsel