Interpretation ID: aiam2137
Brainerd & Bridges
1 North LaSalle Street
Chicago
Illinois 60602;
Dear Mr. Brainerd: #This is in response to your October 30, 1975 letter requesting clarification of the status of the banding requirement of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #The National Highway Traffic Safety Administration (NHTSA) has granted petitions, filed by General Motors Corporation and Ford Motor Company, which requested deletion of the banding requirement. This deletion is the 'change now being developed in our rulemaking proceedings' to which you have referred. The complete elimination of the banding requirement is inconsistent with any substitute labeling requirement. The petition of your client, Kugelfischer Georg Schaefer & Co., was denied for this reason. #You should understand that our commencement of a rulemaking proceeding does not signify that the requested amendment will necessarily be issued. It does indicate, however, a determination that there is a reasonable possibility that the requested amendment will be issued. A final decision concerning the issuance of a proposal to amend the standard will be made on the basis of all available information developed in the course of the proceeding, in accordance with statutory criteria. If the NHTSA determines that such an amendment would not be appropriate, the amendment which you have requested will be considered as an alternative. We do expect to issue a proposal in the near future. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs;