Interpretation ID: aiam3215
Group Director Engineering
The Bendix Corporation
901 Cleveland Street
Elyria
OH 44035;
Dear Mr. Hildebrandt: This responds to your January 22, 1980, letter asking whether section S6.1.8.1 and S6.2.6 of Standard No. 121, *Air Brake Systems*, permit the adjustment, after burnishing, of brakes that are equipped with automatic brake adjusters. The answer to your question is no.; On April 28, 1977, the agency responded to a similar request that yo made for an interpretation of these sections to permit brake adjustment for brakes equipped with automatic adjusters. At that time, the agency stated that the provisions of Standard No. 121 do not permit the type of a brake adjustment that you request. However, the agency noted that it would accept a petition for rulemaking to modify the standard in the manner you suggest if such a petition were supported with sufficient technical data.; In your current request for an interpretation, you merely restate you 1977 letter without offering the necessary supporting data and without petitioning the agency to amend the standard. Accordingly, we must restate the agency's interpretation that the standard does not permit the type of adjustment that you request.; Sincerely, Frank Berndt, Chief Counsel