Interpretation ID: nht76-3.18

DATE: 04/14/76

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mercedes-Benz of North America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your January 26, 1976, letter concerning your previous suggestion for an amendment to the definition of "permanently attached end fitting" in Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses. Your July 18, 1975, letter suggested that brake hose end fittings attached by means of a dimensional interference fit be considered, along with those attached by heat shrinking, to be permanently attached for purposes of the standard. Please forgive our oversight regarding that letter. We have identified it as a petition for rulemaking and now find it to have merit. Accordingly, the petition is granted and a proceeding respecting the issuance of a notice of proposed rulemaking has been commenced.

You should understand that our commencement of a rulemaking proceeding does not signify that the requested amendment will necessarily 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. We do expect to issue a proposal in the near future.

SINCERELY,

MERCEDES-BENZ OF NORTH AMERICA. INC.

January 26, 1976

Robert L. Carter Associate Administrator Motor Vehicle Programs National Highway Traffic Safety Administration

Subject: Federal Motor Vehicle Safety Standard #106-74

A reply to our letter dated July 18, 1975 concerning the above subject has not yet been received. A copy of this original request for standard amendment is enclosed for your review.

Response at your earliest convenience would be greatly appreciated.

HEINZ W. GERTH