Interpretation ID: aiam2077
Joseph Lucas North America Inc.
Two Northfield Plaza
Troy
Michigan 48084;
Dear Mr. Burgess: #This is in reply to your letter of May 29, 1975 asking whether two of your processes for labeling brake hose may be considered 'permanent' for purposes of Standard No. 106-74. #As used in our standards and regulations, the requirements for a 'permanent' label generally contemplates a label that will remain legible for the expected life of the product under normal conditions. The National Highway Traffic Safety Administration expects a manufacturer to make a reasonable, good- faith determination in this respect. The two labeling samples that you submitted as examples of your processes appear to be permanent. #We are presently re-examining the requirement for permanent labeling of brake hose, and a Federal Register notice in this area may be issued shortly. #Yours truly, Richard B. Dyson, Assistant Chief Counsel;