Interpretation ID: aiam0436
Executive Director
Meiji Rubber & Chemical Company
Ltd.
Kojima Building
10-2
Nishishinjuku
1Chome.Shinjuku-Ku
Tokyo
Japan;
Dear Mr. Shindo:#This is in reply to your letter of September 3 askin questions about compliance of hydraulic brake hose assemblies with Federal Motor Vehicle Safety Standard No. 106.#With respect to your first to questions, The National Highway Traffic Safety Administration does not require that you demonstrate compliance with Standard No. 106 prior to supplying Japanese car manufacturers with brake hose assemblies to be installed on cars intended for export to the united States. If the Japanese vehicle manufacturers request proof of compliance from you (apparently in the form of a certification from the Commonwealth of Pennsylvania based upon test reports from only one or two test laboratories) such a request os solely a business matter between you and the vehicle manufacturer.#Your third question points out that proposed Standard No. 106 (Docket No. 1-5, Notice 7) would eliminate the specification of brake material for hydraulic brake hoses and asks whether you may implement this 'revision' at the present time. Notice 7 is a proposal only, and the current requirements specifying braid material remain in effect until a formal amendment of Standard No. 106 occurs. The brake hose manufacturer's code number, the subject of your fourth question is also a proposal which may or may not be adopted in the final rule.#Sincerely,Lawrence R. Schneider,Acting Chief Counsel;