Interpretation ID: aiam1674
Sr. Safety Engineer
Oshkosh Truck Corporation
P.O. Box 2566
Oshkosh
Wisconsin 54901;
Dear Mr. Kamath:#This is to confirm your telephone conversation o November 13, 1974, with Mark Schwimmer of this office, concerning the interpretation of Federal Motor Vehicle Safety Standard No 106-74, *Brake hoses*.#You explained that Oshkosh Truck Corporation purchases air brake hose and air brake hose end fittings separately from its suppliers, and does not construct assemblies until the hose and fittings are installed in the vehicles which you manufacture. You asked whether these assemblies must be labeled with a band. S5.2.4 of the standard states:#>>>Each hydraulic brake system assembly, except those assembled and installed by a vehicle manufacturer in vehicles manufactured by him, shall be labeled by means of a band around the brake hose assembly...<<<#Because S5.2.4 is incorporated in S7.2, the air brake hose assemblies you describe are exempt from the banding requirements.#The matters discussed in your letter of November 1, 1974, have been dealt with in the recent amendment to Standard No. 106-74 which was published november 11, 1974 (39 FR 39725) (Notice 14).#Your truly,Richard B. Dyson,Acting Chief Counsel;