Interpretation ID: aiam2733
Nichirin Rubber Industrial Co.
Ltd.
1118
Sazuchi
Bessho
Himeji
Japan;
Dear Mr. Shimoda: This responds to your letter dated November 29, 1977, asking about th procedures for obtaining approval of hydraulic brake hoses. Your company is altering the labeling on some of its hose and asks whether the hose must be retested and whether notice of the changes must be given.; The National Highway Traffic Safety Administration (NHTSA) does no approve in advance motor vehicles or motor vehicle equipment. It is up to manufacturers to certify that their products comply with all applicable safety standards and regulations. The NHTSA conducts compliance testing for purposes of enforcement.; It is, therefore, up to your company to decide whether to test its hos according to the procedures specified in Safety Standard No. 106, *Brake Hoses*. The NHTSA only requires that you determine in the exercise of due care that the hose meets all requirements specified in the standard. Further, you do not have to give the NHTSA notice when you change the labeling information on your hose, unless you change the designation identifying your company. In that case, the new designation would have to be filed with the NHTSA according to the specifications of paragraph S5.2.2(b) of Standard 106.; You will have to contact the American Association of Motor Vehicl Administrators directly to determine their requirements for approval and notification following your labeling changes.; Please contact me if our office can be of any further assistance. Sincerely, Joseph J. Levin, Jr., Chief Counsel