Interpretation ID: nht75-1.28

DATE: 09/29/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Continental Hydraulic Hose Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of August 28, 1975, concerning the banding requirement of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses.

Notice 18 (40 FR 38159, August 27, 1975) amended the standard to facilitate the depletion of inventories of brake hose, end fittings, and assemblies which do not meet certain labeling requirements. With regard to the assembly banding requirement, the amendment merely extends the period during which vehicle manufacturers may use unbanded assemblies which were manufactured before March 1, 1975. There is no change in the requirement that assemblies manufactured on and after that date (other than those assembled and installed by a vehicle manufacturer in vehicles manufactured by him) be labeled with a band as specified in S5.2.4 of the standard.

Sincerely,

ATTACH.

August 28, 1975

Office of the Chief Council -- National Highway Traffic Safety Administration

Gentlemen:

Would you please render a legal interpretation on Notice 18 of MVSS 106. The specific question is if assembliers of hydraulic brake hose assemblies are still required to "label by means of a band around (hydraulic) brake hose assembly" as orginally required in S 5.2.4 of MVSS 106. We are currently labeling by such a band.

Thank you,

CONTINENTAL HYDRAULIC HOSE CORP. -- John H. Elgin, Vice President

Attachment Omitted.