Interpretation ID: aiam2055
The Weatherhead Company
300 East 131st Street
Cleveland
Ohio 44108;
Dear Mr. Mueller: #This is in response to your letter of July 9, 1975 concerning the banding requirements of Standard No. 106-74. You asked whether the requirements for a band may be avoided in the situation where a hose manufacturer makes a hose assembly to a vehicle manufacturer's 'specified requirements,' under the exception for hoses 'assembled and installed by a vehicle manufacturer.' #The exception in the standard for assemblies made by a vehicle manufacturer cannot be interpreted to apply to those made by a hose manufacturer, as you suggested, so the answer to your question must be no. It is the intent of the standard to distinguish between the two situations you described. #We are presently reviewing the labeling requirements of the brake hose standard in light of your letter and other information. If you wish to present further data and other arguments toward the revocation of the banding requirement, the appropriate form in which to do so would be a petition for rulemaking under Pard 552. #Your truly, Richard B. Dyson, Assistant Chief Counsel;