Interpretation ID: nht94-5.37

DATE: May 12, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Nicholas S. Copass -- Sales Manager, Titeflex Industrial Americas

TITLE: None

ATTACHMT: Attached to letter dated 9/29/93 from Nicholas S. Copass to David Elias (OCC-9161), letter dated 3/6/91 from Anthony J. Laliko to Vernon G. Bloom, and letter dated 3/18/91 from Arthur H. Neill, Jr. to Anthony J. Lalikos

TEXT:

This responds to your letter to Mr. David Elias, formerly of this office, concerning the manufacture of hydraulic brake hose assemblies by Titeflex and Russell Performance Products. I regret the delay in responding.

We recently responded to a letter from Mr. Jim Davis of Russell about the labeling of the hose assemblies. I have enclosed a copy of that letter for your information. In that letter, we explain that both Titeflex's and Russell's designations need not be marked on the assembly. Instead, since Russell is manufacturing the assemblies and will market the assemblies, Russell's designation must be marked. The designation will identify Russell as the manufacturer of the assembly in the event of a possible noncompliance or defect with the assembly.

I hope this information is helpful. If you have any questions, please do not hesitate to call Ms. Deirdre Fujita of my staff at (202)-366-2992.