Interpretation ID: aiam3225
Lombard
Gardner
Honsowetz & Brewer
915 Oak Street
Suite 200
Eugene
Oregon 97401;
Dear Mr. Irvine: This responds to your letter of February 8, 1980, on behalf of you client, Ideal Welding and Machine Company. That company intends to market a one-piece unit coupling device for the connection of electrical and air-brake lines on tractor- trailers. You ask whether Safety Standard No. 106-74, *Brake Hoses* (49 CFR 571.106-74), would be applicable to this device.; The device described in your letter would not be considered a brak hose assembly or a brake hose end fitting. Rather, according to the drawings enclosed in your letter, a completed brake hose assembly with its own end fitting would be attached to the coupling device, similar to the attachment of a completed assembly to a manifold. Therefore, certification of compliance with Safety Standard No. 106-74 would not be required. This answer dispenses with your remaining questions concerning certification.; Although there are no Federal safety standards applicable to a devic such as you describe, it is a piece of motor vehicle equipment. Under the national traffic and motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, as amended 1974 (15 U.S.C. 1381), a manufacturer of motor vehicles or motor vehicle equipment is responsible for any safety related defects that may exist in its products. The manufacturer would have to notify purchasers of any such safety related defects and remedy the defects at its own expense (15 U.S.C. 1411, *et seq.*). Therefore, your client should ascertain through testing or other means that there are no safety problems with its coupling device. Obviously, this is particularly important with any system involving vehicle braking.; Sincerely, Frank Berndt, Chief Counsel