Interpretation ID: nht91-3.24

DATE: April 16, 1991

FROM: Paul R. Kirchgraber -- Souvenirs of the Future

TO: Paul Jackson Rice -- Chief Consul, NHTSA

TITLE: Re Request For Interpretation of Federal Standards Compliance

ATTACHMT: Attached to letter dated 5-6-91 from Paul Jackson Rice to Paul R. Kirchgraber (A37; Std. 108)

TEXT:

I am writing to request a legal interpretation from your office on exactly which standards, if any, my firm needs to comply with in order to sell an exterior tire/wheel cover for on-road vehicular use. This tire cover is to be made from a new fabric that our company has developed which is both solar heat reflective and highly reflective of light (see enclosed).

We believe that when this cover is placed on the exterior mounted tire of a motor home, trailer, passenger van or four wheel drive, it will provide a significant safety enhancement by making the vehicle more visible to the surrounding traffic.

The THERMAL reflective characteristic of this tire cover currently has important use in the off-road motor car racing industry in that it helps keep the temperature of high performance racing tires at a constant level prior to race time. Because of the LIGHT reflective characteristics, we are also interested in adapting this product for on-road use as an external tire cover.

In order to offer this product for commercial sale, we want to be certain that the reflective nature of the fabric used in this cover does not present a safety hazard. I would be grateful if you would please cite any appropriate federal test standards from the code of federal regulations for similar automotive accessories.