Interpretation ID: aiam2627
Engineering Manager
Technical Information Dept.
Michelin Tire Corporation
New Hyde Park P.O.
P.O. Box 3467
New York
New York 11040;
Dear Mr. White: This responds to Michelin's March 23, 1977, letter concerning it February 20, 1976 petition for reconsideration of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*. Your petition for reconsideration was responded to on February 7, 1977 (42 Fr 7140). By this letter, you attempt to resubmit your petition for reconsideration.; Petitions for reconsideration must be received by the agency within 3 days of the publication of a notice. Since the resubmission of your petition is untimely, it has been considered a petition for rulemaking as required by Part 553,35 of our regulations (Code of Federal Regulations, Volume 49). The National Highway Traffic Safety Administration (NHTSA) denies your requested rulemaking.; Your petition suggests that consumers will be confused by the tir label information if the vehicle is not equipped with the tires identified on the label. The agency has determined that confusion will be minimized by the use if the optional heading 'Suitable Tire-Rim Choice.'; Your petition raises a second problem concerning tires of identica size designations manufactured by different companies. These tires may have different inflation pressures even though their sizes are identical. The agency understands that this difference in inflation pressure could result in confusion. Manufacturers, however, con avoid this problem through the use of the manufacturers's name on the tire information label as part of the tire information. Use of the manufacturer's name on the label should distinguish between two otherwise similar tires.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;