Interpretation ID: aiam2037
Secretary
Armstrong Rubber Company
New Haven
Connecticut 06507;
Dear Mr. Donnelly: This responds to your letter of may 30, 1975, concerning the standard applicable to a tire which you manufacture and sell with the designation L78-15LT, Load Range C.; You are mistaken in your assumption that a station wagon is classifie as a multi-purpose passenger vehicle. Because it is constructed neither on a truck chassis nor with special features for occasional off-road operation, a station wagon is a passenger car rather than a multi-purpose passenger vehicle.; If, despite this misunderstanding, the L78-15t tire is question i designated by you as primarily intended for use on lightweight trucks or multi-purpose passenger vehicles, the it is a light truck tire subject to Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other than Passenger Cars*.; Because a station wagon is a passenger car, Standard No. 110 require that its original equipment tires comply with standard No. 109. Standard No. 110 is not applicable to used cars, so there is no prohibition on the use of the L78-15LT tire as replacement equipment on a station wagon. However, because the informational placard on a station wagon would suggest its owner the use of inflation pressures which are dangerously inadequate for light truck tires, we do not wish to encourage the sale of such tires as replacement equipment for use on station wagons.; Sincerely, Frank A. Berndt, Acting Chief Counsel