Interpretation ID: aiam2351
Suplicy Cacique Trading Co.
Inc.
120 Wall St.
New York
New York 10005;
Dear Mr. Downey: #This is in response to your telephone conversation o June 3 and June 21, 1976, with Mark Schwimmer of this office concerning the application of the Federal motor vehicle safety standards to components of hydraulic brake systems for passenger cars. #The performance of hydraulic brake systems for passenger cars is the subject of Standard No. 105-75. The only standards that apply directly to components of a hydraulic drake system are Standard No. 106-74, *Brake Hoses*, and standard No. 116, *Motor Vehicle Brake Fluids*. Standard No. 106-74 applies to brake hoses, brake hose end fittings, and brake hose assemblies. These terms are defined in the standard as follows: #>>>'Brake hose means a flexible conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes. #'Brake hose end fitting' means a coupler, other than a clamp, designed for attachment to the end of a brake hose. #'Brake hose assembly' means a brake hose, with or without armor, equipped with end fittings for use in a brake system, but does not include an air or vacuum assembly prepared by the owner or operator of a used vehicle, by his employee, or by a repair facility, for installation in that used vehicle. #'Vacuum tubing connector' means a flexible conduit of vacuum that (i) connects metal tubing to metal tubing in a brake system, (ii) is attached without end fittings, and (iii) when installed, has an unsupported length less than the total length of those portions that cover the metal tubing.<<< #Please note that vacuum tubing connectors are not presently subject to any safety standards. #Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, specifies that #>>>Every manufacturer or distributer of a motor vehicle or motor vehicle equipment shall furnish to the distributer or dealer at the time of delivery of such vehicle or equipment by such manufacturer or distributer the certification that each such vehicle or item of motor vehicle equipment conform to all applicable Federal motor vehicle safety standards. In the case of an item of motor vehicle equipment such certification may be in the form of a container in which such item is delivered... .<<< #With respect to an item of motor vehicle equipment for which there exists no applicable Federal motor vehicle safety standard, the National Highway Traffic Safety Administration interprets this section as not requiring any certification. Sincerely, Frank A. Berndt, Acting Chief Counsel;