Interpretation ID: aiam1682
Vice President (Technical)
Joseph Lucas North America Inc.
Two Northfield Plaza
Troy
Michigan 48084;
Dear Mr. Burgess:#This is to confirm your telephone conversation o November 13, 1974, with Mark Schwimmer of this office, concerning your request of October 4 for an interpretation of Federal Motor Vehicle Safety Standard No. 106-74 and its relation to SAE Standard J1403.#You are correct in assuming that all inside diameters listed in Tabled V and VI of Standard No. 106-74 are permitted for both light-wall and heavy-wall vacuum brake hose.#Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 prohibits any State from establishing or continuing in effect a safety standard applicable to an item of motor vehicle equipment performance, where there is an applicable Federal standard covering the same aspect of performance, unless the standards are identical. The NHTSA has determined that FMVSS 106-74 and SAE Standard J1403 are applicable to the same aspect of performance, and that they are not identical. Therefore, the States are prohibited from disapproving the use of brake hose which meets the requirements of Standard no. 106-74 but does not meet SAE Standard J1403.#Yours truly,Richard B. Dyson,Acting Chief Counsel;