Interpretation ID: aiam2419
Factory Manager
Nichirin Rubber Industrial Co.
Ltd.
1118
Sazuchi
Bessho
Himeji
Japan;
Dear Mr. Yamazoe: #This is in belated response to your May 14, 1976 letter concerning Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #The National Highway Traffic Safety Administration (NHTSA) recognizes the designation 'NCRN' as identifying Nichirin Rubber Industrial Co. on all brake hoses and brake hose assemblies manufactured by Nichirin, regardless of whether these components are intended for use in hydraulics, air, or vacuum brake systems. #The NHTSA does not issue approvals of motor vehicle equipment prior to sale. Under the National Traffic and Motor Vehicle Safety Act of 1966, as amended, certification of compliance with applicable safety standards is performed by the manufacturer. Standard No. 106-74 does not specify the testing which a manufacturer must do before certifying that his brake hose and assemblies comply, it does specify the performance levels which these products must meet when tested by the NHTSA for compliance. The manufacturer is required to exercise due care in assuring himself that his certification is neither false nor misleading. #Sincerely, Frank A. Berndt, Acting Chief Counsel;