ID: nht76-1.27

DATE: 03/08/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Michelin Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 27, 1976, concerning the rim listing requirements of Federal Motor Vehicle Safety Standards No. 109 and 110.

You wish to designate the 15x5.5JJ rim as permissible for use with tire sizes 225-15 and 230-15. You have requested confirmation of your interpretation that you need merely list the rim in a document that is furnished to your dealers, to any person on request, and in duplicate to the Tire Division of the NHTSA. Your interpretation is correct. Please note, however, that this listing must include dimensional specifications and a diagram of the rim, unless each of the association publications referred to in S4.4.1(b) of Standard No. 109 in which the rim is listed already contains such specifications and diagram.

We hope that you will also ensure that this tire-rim combination is listed in one of those publications as soon as is possible.

MICHELIN TIRE CORPORATION Technical Group

JANUARY 27, 1976

Office of the Chief Counsel National Highway Traffic Administration Department of Transportation

Re: FMVSS 109 - New Pneumatic Tires for Passenger Cars FMVSS 110 - Tire Selection and Rims

We are writing to confirm our interpretation of paragraph S.4.4.1 of FMVSS 110 and paragraph S.3 and S.4.4.1 of FMVSS 109.

It is our understanding that in order to add an additional permissible rim width for a tire which is already listed in the tables of FMVSS 109, we need merely include it in a document (such as our Data Book or Technical Bulletin) which is furnished to our dealers and to any person upon request, and in duplicate to the Tire Division of NHTSA.

It is our immediate need to add the 15x5.5JJ rim as a permissible fitment for tire sizes 225-15 and 230-15.

Your prompt reply would be appreciated. Thank you.

John B. White Engineering Manager Technical Information Dept.

ID: nht76-1.28

DATE: 08/06/76

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Hon. John J. LaFalce - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your correspondence on behalf of Mr. George J. Ciancio, concerning the tires on his 1975 Dodge Van B-100. Prior to responding, this office contacted Mr. Ciancio for additional information.

From the correspondence you submitted to this Administration, Mr. Ciancio did not appear to receive satisfactory responses to the questions he submitted to the Chrysler Corporation concerning the tire problems he was experiencing. We offer the following responses for his consideration:

Question 1 - Stamped on the sidewalls of the original tire the rating is 1400 pounds. Is this maximum load?

Response - Yes. The maximum load rating for an E7815 B passenger car type tire is 1400 pounds. This rating is only applicable when this tire is used for passenger car service. For a van of the type used by Mr. Ciancio, a service factor is applied for "truck service" and the maximum load becomes 1270 pounds.

Question 2 - My registration shows the van weight at 4434 pounds. What is the laden weight of the B-100 van?

Response - Mr. Ciancio was contacted on this point. Our data indicates that the Dodge B-100 van should weigh approximately 3600 pounds depending on the installed equipment. As the Gross Vehicle Weight Rating (GVWR) is 4600 pounds, the approximate laden weight would be about 1000 pounds as indicated by Chrysler. If in fact, the van does weigh 4434 pounds empty, then the laden weight cannot be over 166 pounds, which of course, cannot be correct.

Question 3 - Do I read correctly that my total tire weight allows 5400 pounds, which includes van and load?

Response - No. From page 3 of your Owners Manual, you will note, "The GVW rating of your truck as manufactured is shown on the Safety Certification Label. The GVW rating is the total permissible weight of your truck including driver, passengers, body, and payload." As the GVWR of the B-100 van is 4600 pounds, 4600 pounds is the maximum load.

Question 4 - The axle capacity in the manual front and rear is shown as 2700 pounds. Does this mean with loaded weight?

Response - No. The axle capacity of 2700 pounds is the rating determined by the vehicle manufacturer as the maximum load that should be applied to that individual axle - it does not mean that both axles can take the design capacity for a total of 5400 pounds. Again, the B-100 van is limited to 4600 pounds GVW. Vehicle load on each axle is further limited by the suspension's spring and wheel ratings which reduce actual load carrying capacity to GAWR valves of 2480 front and 2340 rear. These figures indicate the importance of proper load distribution in the vehicle.

Question 5 - Is it true if I increase my tire size from E78-15B to G78-15B, would it make any difference in the load I could carry without jeopardizing the axle weight capacity?

Response - No. By changing the tires on the van from E ratings to G ratings would not change the GVWR of 4600 pounds. The van is still limited to a GVWR of 4600 pounds.

We hope that the responses to these questions will answer some of the concerns of Mr. Ciancio.

ID: nht76-1.29

DATE: 12/01/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Pirelli Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your November 1, 1976, letter to Mark Schwimmer of my staff, concerning the marking "V1" on passenger car tires.

The marking "V1" is not required by any Federal statute, motor vehicle safety standard, or other regulation to appear on the sidewall of passenger car tires. Furthermore, Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 as amended, 15 U.S.C. 1392(d), provides in pertinent part:

Whenever a Federal motor vehicle safety standard establshed under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.

This provision, considered with Federal Motor Vehicle Safety Standard No. 109, prohibits any State from imposing any safety labeling requirements for passenger car tires other than those contained in that standard. Any differing safety labeling requirements, including the "V1" that you have mentioned, are thus preempted and void.

SINCERELY,

NOVEMBER 1, 1976

Mark Schwimmer N.H.T.S.A. Office of Chief Counsel

The marking V1 on passenger car tires, as you know, signifies compliance to the "minimum performance requirements and uniform test procedures for new tires for passenger cars and station wagons" issued by the Vehicle Equipment Safety Commission on May 14, 1965 and later revised on October 11, 1965 and September 17, 1966.

To my knowledge no further revisions have been made, because the FMVSS 109 went into effect as of January 1, 1968. I assume, therefore, that the marking V1 should be applied only on the tires listed in the tables 1 - 6 of the regulation as follows: Table 1 - Domestic bias tires of the following series: Low Section (ex. 6.50-14) 4 & 8 P.R.

Super Balloon (ex. 6.70-15) 4 & 8 P.R.

Super Low Section (ex. 6.95-14) 4 & 8 P.R.

Table 2 - 70 Series, alpha numeric bias construction (ex. E 70-14) Table 3 - Domestic radial millimetric series from cross section Table 4 - European bias tires of the following series: Table 5 - European bias tires of the millimetric series (ex.

Table 6 - European radial tires of the millimetric series up to the cross section 155 (ex. 145 R 13) version A (32 psi)

I would like to know if the above is correct and therefore the marking V1 is no longer requested on the tires not included in this list.

If the requirements do not apply to every state in the United States, please notify me.

Thank you in advance for your reply on this matter.

PIRELLI TIRE CORPORATION

Galileo Buzzi-Ferraris Technical Manager

ID: nht76-1.3

DATE: 12/03/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: American Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to American Motors Corporation's (AMC's) September 9, 1976, request for confirmation that Standard No. 101, Control Location, Identification, and Illumination, permits the addition of a "fan" symbol to a control that is identified by the word "fan" in accordance with the requirements of S4.2.1.

The AMC interpretation is incorrect. Section S4.2.1 states in part:

S4.2.1 . . . . A control may, in addition, be identified by a symbol, but only a symbol shown in column 3 or 4 shall be used. However, if the word "None" appears in column 3, no symbol shall be provided. . . .

Table I, whose columns are referred to in S4.2.1, contains an entry for "Heating and Air Conditioning System," and column 3 for that entry contains the word "None". This means that no symbol can be used in addition to the word "fan" on the control for the fan control switch.

The language in the preambles to three proposals to amend Standard No. 101 that you list in your letter does not have the effect of amending the requirements of the standard itself. As you are no doubt aware, a recent proposal would amend Table I to include a symbol for the heating and air conditioning system, but this proposal has not yet been made final. A copy of the proposal is enclosed for your information.

SINCERELY,

American Motors Corporation

September 7, 1976

Robert L. Carter Associate Administrator Motor Vehicle Programs National Highway Traffic Safety Administration U. S. Department Of Transportation

American Motors Corporation (AM) submits this request for an interpretation of the control identification requirements contained in FMVSS 101 as they relate to the fan control switch of the heater and/or air conditioning system.

AM requests this interpretation because of the language contained in Docket 1-18; Notice 7, 10 and 11. Therein, the NHTSA has stated their tentative determination that a fan symbol should be allowed, at the manufacturer's option, to supplement the word "Fan" or "Blower" for purposes of identifying the fan control switch, and has announced its intention to incorporate the internationally accepted ISO fan symbol into Standard 101.

AM is about to release a future heater and air conditioner control assembly which will incorporate the word "Fan" along with the appropriate symbol described in ISO Standard 2575/1 (4.8). AM requests NHTSA's interpretation in order to assure that our incorporation of the ISO fan symbol will not be judged in conflict with the requirements of Standard 101.

A prompt reply to this request would be appreciated in order to facilitate this design decision.

K. W. Schang Director - Vehicle Safety Programs

ID: nht76-1.30

DATE: 03/01/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Leisure Time Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 29, 1976, requesting an interpretation of the requirements of S.6 of Federal Motor Vehicle Safety Standard No. 111, Rearview Mirrors, as they apply to the manufacture of mobile homes with a GVWR of greater than 10,000 pounds.

The standard requires that these vehicles be equipped with outside mirrors of unit magnification, each with not less than 50 in<2> of reflective surface, on both sides of the vehicle. While you are free to provide additional mirrors, the standard clearly requires two mirrors each of which has at least 50 in<2> of reflective surface. Substitution of a number of small mirrors for one or both of the 50 in<2> mirrors is impermissible, even if a total reflective area of 50 in<2> is provided.

If you require any further assistance, do not hesitate to write.

SINCERELY,

Leisure time PRODUCTS, INC.

January 29, 1976

Chief Council N.H.T.S.A. Department of Transportation

SUBJECT: Motor Vehicle Safety Standard No. 111

As a manufacturer of motor homes of over 10,000 pounds GVWR, I am not certain on how to interpret Section S6 of Standard No. 111. I understand the minimum requirements for mirror size, capability, and location which would be applicable. The item which I question is the 50 in<2> of reflective surface. Are the mirrors required to be of one piece instead of possibly two piece? For example, two mirrors one with 40in.<2> reflective surface and additional mirror of adequate size to meet the 50in.<2> requirement for each side of vehicle.

Your immediate attention to this matter would be appreciated. Thank you.

Tommy Watson Engineer of Codes and Standards

ID: nht76-1.31

DATE: 04/28/76

FROM: AUTHOR UNAVAILABLE; James B. Gregroy; NHTSA

TO: Hon. Vance Hartke - U.S. Senate

COPYEE: BUREAU OF MOTOR CARRIER SAFETY; FEDERAL HIGHWAY ADMINISTRATION

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 30, 1976, enclosing a letter from Mr. Dennis Oser concerning the effective date of Federal Motor Vehicle Safety Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars.

Standard No. 119 became effective March 1, 1975, and applies to non-passenger-car tires manufactured on and after that date. From his reference to "April 1, 1976", Mr. Oser appears to be concerned with the effective dates of 49 CFR 393.75, a regulation issued by the Federal Highway Administration's Bureau of Motor Carrier Safety (BMCS). That regulation addresses the type of tires with which motor vehicles in use in interstate commerce must be equipped. Accordingly, I have forwarded your letter to the BMCS for further reply.

Sincerely,

ATTACH.

United States Senate

COMMITTEE ON COMMERCE

March 30, 1976

James Gregory, Administrator -- National Highway Traffic Safety Administration

Dear Dr. Gregory:

I am enclosing for your review a letter that I have received from Mr. M. Dennis Oser. Mr. Oser inquired as to whether it would be feasible to amend MVSS 119 so that it will apply to new tires only as they are purchased rather than as a it now applies to all tires being used on April 1, 1976. Would you please review Mr. Oser's letter and provide me with your response.

I look forward to your response.

Sincerely yours,

VANCE HARTKE, Chairman -- Surface Transportation Subcommittee

Enclosure

February 19, 1976

The Honorable Vance Hartke United States Senate

My dear Senator Hartke:

Enclosed, please find copies of letters concerning subjects of importance to this company and the trucking industry.

Any help you can give by lending your support will be greatly appreciated.

Very truly yours,

OSER LEASING COMPANY, INC.;

M. Dennis Oser -- Vice President General Manager

Enclosures

February 19, 1976

Bureau of Motor Carriers Safety -- Department of Transportation

Gentlemen:

RE: MVSS119

Please consider changing the subject standard so that it will apply to new tires only as they are purchased rather than as it now applies to all tires being used on April 1, 1976, regardless of date of purchase. The following two reasons appear to be the only applicable facts in this situation:

1. Safety will not be compromised by making the requested change.

2. There will be no adverse economic impact on the industry or this company if the requested change is made.

Sincerely,

OSER LEASING COMPANY, INC.;

M. Dennis Oser -- Vice President General Manager

February 19, 1976

The Honorable Lionel Van Doerlin -- Chairman, Subcommittee on Consumer Protection and Finance, House of Representatives

Dear Representative Van Doerlin:

Within your jurisdiction as an oversight committee for the National Highway Traffic Safety Administration, please accept the enclosed copy of a letter to the Bureau of Motor Carriers Safety with regard to MVSS119.

Further, with regard to MVSS121, any priority your committee could assign in its oversight role to putting this standard high on its agenda could be of significant impact economically to the trucking industry. The confusion and frustration being felt throughout the operating segment of this industry is disastrous.

Yours very truly,

OSER LEASING COMPANY, INC.;

M. Dennis Oser -- Vice President General Manager

Enclosure

ID: nht76-1.32

DATE: 05/11/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA

TO: Intercraft Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your March 29, 1976, letter concerning regulations applicable to farm tractor tires whose importation is contemplated by one of your clients.

Farm tractors are not "motor vehicles" as that term is defined in the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391 et Seq.). Accordingly, tires designed exclusively for use on farm tractors are not "motor vehicle equipment." Therefore, the importation of such tires and tubes is not subject to Federal motor vehicle safety standards or other regulations issued by the National Highway Traffic Safety Administration. We are unaware of any other regulations of the Department of Transportation concerning such tires.

Yours truly,

ATTACH.

Intercraft Corporation

March 29, 1976

Frank Berndt -- Acting Chief Counsel, National Highway Traffic Safety Administration,

Dear Mr. Berndt:

A foreign tire manufacturer has indicated to us that he is interested in exporting certain agricultural tires and matching tubes to one of our clients in the United States. If a transaction can be concluded, these tires and tubes would be imported to the U.S. by our client and would be sold by him in this country.

Two sizes of farm tires and tubes would be involved: 15.5-38 (6 and 8 PR) and 18.4-38 (8 PR). We understand that both of these sizes of tires and tubes are made for the rear wheels of farm tractors for field use only and are considered "Off The Road" in the tire industry.

We would like to ask if there are any U.S. Department of Transportation regulations concerning motor vehicle safety standards, tire identification and recordkeeping, or manufacturer identification that apply to the importation to the United States of tires and tubes of those two size designations? Do any DOT regulations apply to any other facet of the importation of such tires and tubes to the U.S.?

Sincerely, Robert M. Brodkey -- President

ID: nht76-1.33

DATE: 04/07/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Trans-Continental Tire Sales, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: I am writing to confirm your March 19, 1976, telephone conversation with Mark Schwimmer of this office concerning Federal Motor Vehicle Safety Standard No. 119, New Pneumatic Tires for Vehicles Other than Passenger Cars.

Standard No. 119 requires that the symbol "DOT" appear on the sidewall of a non-passenger car tire, as a certification that the tire meets all of the standard's performance and labeling requirements. Assuming that the tire in question does meet those requirements and is so certified, there is no prohibition in the standard against additional labeling such as "Blem" or "A.B.O." I hope this clarifies the status of your tires.

Sincerely,

ATTACH.

March 9, 1976

Frank Berndt -- Acting Chief Counsel, N.H.T.S.A. Dept. of Transportation

Re: Federal Motor Vehicle Safety Standards Sec. 119.

Dear Mr. Berndt,

Can you clarify that truck tires marked "A.B.O." or "Blem" are safe for highway use on the front end of commercial over the road vehicles?

The tires in question do meet D.O.T. highway specifications for manufacturers safety, in so for as they are free from defects in workmanship and materials.

Please rush clarification as soon as possible.

Thank You.

Respectfully Yours,

Raymond Oleisky, Operations Manager

ID: nht76-1.34

DATE: 06/11/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA

TO: Pirelli Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: I am writing in response to your March 12, 1976, letter to Mr. Robert Aubuchon of this agency, concerning the application of Federal Motor Vehicle Safety Standard No. 119, New Pneumatic Tires for Vehicles Other than Passenger Cars, to motor driven cycles whose speed attainable in 1 mile is 30 mph or less.

You have inquired whether such vehicles may be equipped with tires that --

(i) "Carry all the inscriptions required by labeling, plus the marking "MAX SPEED" because speed restricted to less than 55 MPH -- S.6.5."

(ii) "Have passed the endurance test -- S.6.1, S.7.2 in accordance with table III -- speed restricted service: 35 MPH"

(iii) "have not been tested for high speed S.6.3 -- in fact they are speed restricted . . ."

and otherwise comply with the requirements of Standard No. 119.

I assume that, where your letter refers to the marking "MAX SPEED", you intended "MAX SPEED 35 MPH". Although such labeling is not prohibited, the standard does not presently recognize a category of speed-restricted motorcycle tires. Tires for motor driven cycles are subject to the same performance requirements as other motorcycle tires. In particular, the schedule for endurance testing is that found in the "motorcycle entry of Table III, rather than the "35 m.p.h." entry. Similarly, these tires are subject to the high speed performance requirements of S.6.3 without exception. An amendment of Standard No. 119 on this subject is being considered, but no firm decision has been made.

Standard No. 119 prohibits the manufacture of the tires that you have described on and after March 1, 1975. Standard No. 120, Tire Selection and Rims for Motor Vehicles Other than Passenger Cars, prohibits the manufacture of motor-driven cycles equipped with such tires on and after September 1, 1976.

SINCERELY,

PIRELLI TIRE CORPORATION

March 12, 1976

NHTSA

Att: Robert Aubuchon

In reference to the phone conversation of March 9, 1976, we would like to have the following Information:

1) Is it permissible (with respect to the safety requirments stated in Standards 119 and 120) to equip motor driven cycles whose speed attainable in 1 mile is 30 MPH or less (see definitions R571 paragraph 571.3 - B and references in part 571, ST 123 - PRE 5 ST 108 - S.4.1.1 26/27, St 122 - S.5.4/S/5.5) with tires meeting the requirements of Standard 119 inasmuch as they:

a) are indicated in ETRTO data book S.5.1.B

b) carry all the inscriptions required by labeling, plus the marking "MAX SPEED" because speed restricted to less than 55 MPH - S.6.5.

c) have tread wear indicators S.6.4

d) have passed the strength test - S.6.2., S.7.3, in accordance with tables I and II - plunger 5/16

e) have passed the endurance test - S.6.1, S.7.2 in accordance with table III - speed restricted service: 35 MPH

f) have not been tested for high speed S.6.3 - in fact they are speed restricted, moreover they may be included in the requirements of Standard 120 - see paragraphs: S.2, S.5.1.1, S.5.1.2, S.5.3. D"

N.B. There is no indication anywhere in Standard 119 and 120 that the speed restrictions apply only to trucks.

2) As discussed by phone, we have requested that a copy of the letter sent by ETRTO to the DOT be forwarded to you as soon as possible. We would appreciate if you would look into this matter and inform us of the outcome.

Thanking you in advance for a prompt reply, we remain

Francesa Robinsons for Mr. Buzzi

G. Buzzi-Ferraris Technical Manager

Industrie Pirelli spa

MARCH 15, 1976

Robert Aubuchon N.H.T.S.A. Office of Standard Enforcement

We have been informed by Pirelli Tire Corporation N.Y. your request for a copy of the ETRTO Submission to NHTSA concerning an amendment to FMVSS 119 and precisely 'Tyres for low-power motorcycles with restricted speed capability'.

A copy of it is here with enclosed.

Recently, February 26th, Mr. Richard B. Dyson, Assistant Chief Counsel of NHTSA has promised to Mr. Trimble, ETRTO General Secretary, that a Federal Register notice on the subject will be issued in the near future.

(P.G. Malinverni) Tyre Standardization

EUROPEAN TYRE AND RIM TECHNICAL ORGANISATION

The Director National Highway Traffic Safety Administration U.S. Department of Transportation

RD/MS 048/75

SUBMISSION N degree 6/119

FMVSS 110 - TYRES FOR LOW-POWER MOTORCYCLES WITH RESTRICTED SPEED CAPABILITY

In the preamble to Docket 71-18 Notice 6, published in the Federal Register Volume 39, No.29 dated Monday February 11th 1974, page 5192, reference was made to an E.T.R.T.O. proposal for new test values for certain motorcycle tires, which proposal was deemed to be "unclear as to the meaning . . . "

For convenience of reference the paragraph in question is quoted as follows:

"The E.T.R.T.O. proposed new test values for some motorcycle tires, but the request was unclear as to the meaning of the 62 mph criterion and the unsupported request cannot be granted. If in future, the E.T.R.T.O. petitions for rule making to revise the table, an explanation of the criterion and a justification for the test values would permit an informed decision."

In response to the invitation, implicit in this paragraph, to E.T.R.T.O. to petition "for rule making to revise the table" by submitting explanation and justification of its requirements E.T.R.T.O. submits the following petition for consideration on this subject.

FMVSS 119 recognises all data standardised by the various international and national standards organizations (Illegible Words) (Illegible Line) (Illegible Words) in tables II (strength) table III (endurance) and in paragraph S7-1 (high speed).

In accordance with the "invitation" instanced (Illegible Word) ETRTO formally requests reconsideration of the requirements of Standard 119 insofar as two categories of light motorcycle tires are concerned, these being the speed-restricted ranges of such tires listed on pages (Illegible Word) through 119 of the 1974/75 E.T.R.T.O. Data-book.

In requesting certain (Illegible Word) from the terms of Standard 119, E.T.R.T.O. is evoking (Illegible Words) which resulted in amendments to the requirements of (Illegible Words) 122 (Illegible Word) 123, as published in the Federal Register Vol. 39 No. 72 (Illegible Words) 12th 1974, in that the existing Standard 119 is "not reasonable, (Illegible Words) appropriate" to the light motorcycle tires in question.

a) Tires for Small Cubic Capacity Motorcycles With Speed Capability up to 50 mph

These tires are especially designed to be fitted to motor-driven cycles with a (Illegible Words).

They can be recognised from having the word "Moped" (or alternatively "Cyclomoteur", or "Ciclomotore" or "Circlomotor") in the vicinity of the (Illegible Word) designation (e.g. (Illegible Word) - 17 Moped).

E.T.R.T.O. requests that for tires to be mounted on motor-driven cycles with a top speed capability of 30 mph of less, tires known as moped tires in Europe and with a speed restriction of 30 mph, the following specifications be adopted:

1. Strength: the minimum static breaking energy should be the one allowed for rayon cord tires even for other types of cords such as cotton, which is widely used for this tire range and which has breaking energy properties almost identical to rayon.

2. Endurance: the test wheel speed should be 100 rpm

The test leads could be (in percent of maximum lead rating): 100% for 4 hours, 108% for 6 hours and 117% for 24 hours.

3. High Speed Test: no high speed test will apply to these tires since they are "speed restricted".

4. Treadwear Indicators: in view of the low speed usage and the fact that these tires have very shallow tread patterns, (circa 3 mm) similar to cycle tires, E.T.R.T.O. (Illegible Word) that the requirement to add treadwear indicators at 1/32" (0,8 mm) is unrealistic and against the interests of the consumer.

b) Tires for Small Cubic Capacity Motorcycles up to 60 mph (or 100 km/h)

This is the category of tires previously referred to as "up to 62 mph", this being strictly equivalent speed to 100 km/h.

These tires are specially designed to be fitted on lightweight motorcycles with maximum speed not exceeding 60 mph.

(Illegible Line) is considered that a (Illegible Words) rating for these tires (Illegible Words) in a restricted-speed category. In consequence E.T.R.T.O. requested (Illegible Word) (Illegible Lines)

1. Endurance: the test wheel speed should be 200 rpm, the test load in percent of maximum load rating 100 for 4 hours, 108 for 6 hours, 117 for 24 hours

2. High Speed: since the first step of the high speed test is 375 rpm equivalent to a speed on highway largely in excess of 75 mph and that speed is higher than the maximum allowed for the tire we would propose that category to be considered a speed restricted category therefore the high speed test will not be necessary for them.

3. Treadwear Indicators: for the reasons outlined in paragraph (a) (4) above the requirement for treadwear indicators be waived for this range of tires.

c) For case of consideration of these requests it should be noted tha the (Illegible Line) ranges of (Illegible Words) -speed motorcycle tires by their size designation as follows: (i) light motorcycle tires, 30 or 60 mph category - the size designations are in inches and fractions of an inch e.g. 2 1/2 - 17.

(ii) unrestricted speed motorcycle tires - the size designations are in inches and decimals e.g. 2.75 - 17.

E.T.R.T.O. requests that early consideration be given to this petition in order that appropriate steps may be taken for implementation prior to the March 1st 1975 effective date of Standard 119.

Thanking you in advance for your kind consideration of the matter,

R. DERESSON General Secretary

ID: nht76-1.35

DATE: 04/14/76

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Bemperit of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This confirms a telephone conversation between yourself and Mr. George Chifflett, a member of my staff, on March 12, 1976. In that conversation a telex from Semperit, Austria, was discussed and the following points were made:

1. Motor-driven cycles (mopeds) need not be equipped with tires conforming to Federal Motor Vehicle Safety Standard (FMVSS) No. 119, until September 1, 1976. Of course, if the tires were manufactured after March 1, 1975, they would have to conform (see paragraph S5.1.1 of FMVSS No. 120 and paragraph S3 of FMVSS No. 119, highlighted copies enclosed).

2. All tires manufactured after May 22, 1971, must be marked in accordance with Title 49, Code of Federal Regulations, Part 574 (49 CFR 574), Figure I (copy enclosed). Tires on mopeds being offered for sale must be marked accordingly. If branding would weaken the tire sidewall, replacement might be the only solution to the problem.

3. FMVSS No. 119, applies to all covered tires manufactured on or after March 1, 1975. It does not apply to tires in aftermarket inventory that were manufactured before that date.

4. "Federal Register Car [CFR] 393 Docket Number MC-56 Notice Number 75-19," pertains to a Bureau of Motor Carrier Safety regulation that applies to vehicles being used as interstate carriers. It does not apply to vehicles being manufactured or offered for sale. As stated before, vehicles manufactured on or after September 1, 1976, must be fitted with tires that meet FMVSS No. 109 or 119.

5. The post March 1975 labeling described in your telex does not meet the requirements of FMVSS No. 119.

(a) The symbol "DOT" must appear before the manufacturer's identification code number, as a certification that the tire complies with the standard. "TIRE" may appear elsewhere on the tire, but it is not required.

(b) The composition of the ply cord material must also appear.

(c) While the labeling "Maximum Speed 30 MPH" is not prohibited, the standard does not presently recognize a category of speed-restricted motorcycle tires. Moped tires are subject to the same performance requirements as other motorcycle tires, most notably, the high speed and endurance test requirements. An amendment on the subject is being considered, but no firm decision has been made.