Interpretation ID: nht93-7.32

DATE: October 21, 1993

FROM: James "Bubba" Schaub -- Midas Muffler and Brake

TO: John Womack -- Acting Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/8/94 from John Womack to James Schaub (A42; Std. 105; Part 570)

TEXT:

First allow me to introduce myself. My name is James "Bubba" Schaub. I manage a Midas Muffler and Brake Shop in Slidell, Louisiana, located at 180 Gause Blvd., and have for 9 years now. My concern is in the area of ethical and sound business practice. I'm taught by Midas to replace brake rotors and/or brake drums when they exceed the minimum thickness (on disc rotors) or maximum diameter (on drums), published by Original Equipment Manufacturers. My questions are as follows:

1. Please interpret F.M.V.S.S. 105 HYDRAULIC BRAKE SYSTEMS.

2. Is there any basis for fraud in following this policy? (Of disc rotor and/or drum replacement when out of manf. safety tolerances).

Please understand that my concern lies only with doing the right thing - the safe way, for our costumers. Let it be known that the local auto dealership service dept.'s are not following their own recommendations, for safety in this matter, which causes my costumers to believe that we (Midas) are fraudulently selling and installing parts on their vehicles when they're not needed. But, if I can present an established standard to our (Midas) costumers, I can prevent them from feeling they've been taken advantage of.