Interpretation ID: nht76-1.18

DATE: 11/10/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nichirin Rubber Industrial Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: 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 hose and brake hose assemblies manufactured by Nichirin, regardless of whether these components are intended for use in hydraulic, 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,

NICHIRIN RUBBER INDUSTRIAL CO., LTD.

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

May 14, 1976

ATTENTION: Richard B. Dyson Acting Chief Counsel

According to your letter on the 7th of Feb. in 1975, I understood that our designation "NCRN" had been entered in Office of Standards Enforcement.

I want to ask your advice for following point. May I interpreted it that designation "NCRN" is able to apply to all head that is written in Federal Motor Vehicle Safety Standard No. 106-74?

Namely these are S5 Hydraulic Brake Hose, S7 Air Brake Hose, S9 Vacuum Brake Hose. Now, we apply to the Hydraulic Brake Hose. In the future We Want to apply to the Air Brake Hose and Vacuum Brake Hose.

Of course we think it is necessary that we complete regular process (AAMVA etc.) after test of TEST Laboratory in U.S.A. Will you please give me your advice that is necessary for me?

Etsuo Yamazoe Factory Manager