Interpretation ID: aiam2012
Power Controls Division
Midland-Ross Corporation
490 S. Chestnut Street
Owosso
Michigan 48867;
Dear Mr. Huneke: #Please forgive the delay in responding to your lette of March 24, 1975, to Mr. Schwimmer of this office concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to new brake hose assemblies whose end fittings are partially disassembled by vehicle manufacturers. #You have described brake hose assemblies equipped with permanent end fittings containing sacrificial sleeves. Although the assemblies are complete when delivered by you to a vehicle manufacturer, they must be partially disassembled by him (because they lack swivel fittings) to facilitate installation in vehicles. At this point the vehicle manufacturer does not, as you have suggested, become the hose assembler, assuming responsibility for the assemblies' compliance with the standard and relieving you of responsibility for their continued compliance. He is not, however, required to remove the assembler's band which you have installed pursuant to S5.2..4 (as incorporated by reference in S7.2 and S9.1), although he is free to do so, nor is he required to install his own band, because of the exception in S5.2.2 for assemblies which are assembled and installed by a vehicle manufacturer in his own vehicles. Furthermore, he is not required to replace the sacrificial sleeve in the end fittings, because that sleeve has not been used. #An aftermarket purchaser who disassembles and then reassembles one of your assemblies also relieves you of responsibility for its continued compliance with the standard. He is not required to remove your assembler's band, nor is he required to replace the sacrificial sleeve. #Sincerely, Frank Berndt, Acting Chief Counsel;