Interpretation ID: 1985-01.36

TYPE: INTERPRETATION-NHTSA

DATE: 02/26/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Bernt Svensson -- Marketing Director, Viskafors Gummifabrik AB

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Bernt Svensson Marketing Director Viskafors Gummifabrik AB Box 2059 S-515 02 Viskafors SWEDEN

This responds to your letter to Ms. Kathleen DeMeter of my staff, asking for information on how to get a new temporary spare tire size included in the tire tables following Standard No. 109 New Pneumatic Tires --Passenger Cars (49 CFR S571.109). The agency rescinded tire tables in Standard No. 109 in a final rule published at 46 FR 61473; December 17, 1981. I have enclosed a copy of that rule together with a current copy of Standard No. 109 for your records.

Section S4.4.1 requires tire manufacturers to provide a listing of the rims that may be used with each tire size it produces. Section S4.2.1(c) requires a tire's load rating to be the load rating for that size specified in a submission under S4.4.1. This may be provided by the manufacturer in a document furnished to each of the manufacturer' s dealers, to this agency, and to the public upon request. Alternatively, the manufacturer may use the data for that tire size shown in a current publication of one of the standardization organizations listed in S4.4.1(b). Your company will have to use one of these two means of complying with this requirement, instead of relying on the tire tables, as was formerly done.

The current publication of the American standardization organization (the Tire & Rim Association) shows no listing for the tire size about which you inquired. It is possible that the size is listed by one of the other standardization organizations. If not, you should either get the size listed by the standardization organization of your choosing or submit the data directly to this agency, all your dealers and the public, upon request.

Should you have any further questions on this matter, please contact Mr. Stephen Kratzke of my staff at this address.

Sincerely,

Frank Berndt Chief Counsel

Enclosures

1985-02-01 U.S. Department of Transportation M/MA2 National Highway Traffic Safety Administration 400 Seventh St. S.S. WASHINGTON, D.C. 20590 U S A

Att.: Mrs. Kathleen DeMeter

Dear Mrs. DeMeter,

From your files you may record that we are a producer of tires having the plant code VV.

We are in the process of manufacturing a spare tire for one of our clients in Sweden and would kindly ask for your advice and information as to the following points:

In the MVSS 109 regulation there are several sizes listed under the heading "T-series" 60 psi tires.

Due to various technical reasons we are considering one particular size which as far as we know is not listed namely T 125/90 R 15. (We understand that "D"-bias and "R"-radial are equal alternatives.

In connection with this we have the following questions:

Is T 125/90 "D" alt. "R" 15 now recorded in the latest edition of MVSS 109. If so could you please send us this edition showing all required data or alternatively the specific data for this tire as a complement to the MVSS 109 needed to consider and meet the USA legal requirements.

If you are not familiar with this particular size in the "T-series" range could you please advise us how we should proceed to have this tire recorded and recognized.

We would appreciate your consideration of this matter and look forward to your early response.

Very truly yours, VISKAFORS AB

Bernt Svensson Marketing Director