Interpretation ID: aiam1499
Manager
Director
American Retreaders' Assoc.
Inc.
P.O. Box 17203
Louisville
Kentucky 40217;
Dear Mr. Wagner: This is in reply to your letters of April 7 and April 8, 1974 regarding Standard No. 117, 'Retreaded Pneumatic Tires.' Your April 7 letter asks whether Standard No. 117 requires treadwear indicators to be straight across the tread face. Your letter of April 8 encloses two sample rubber labels and asks whether each conforms to the requirements of S6.3 of Standard No. 117.; Paragraph S5.1.1(b) of Standard No. 117 does not specify configuration for treadwear indicators. Rather, it incorporates by reference the requirements for treadwear indicators of S4.2.1(d) of Standard No. 109, which calls only for a treadwear indicator that provides a 'visual indication that the tire has worn to a tread depth of 1/16 inch.' We do not construe this language to require a straight-across treadwear indicator and other configurations are therefore permitted.; With respect to the labeled you enclose in your letter of April 8, eac would conform to all of the requirements of S6.3 (which includes the requirements for both affixed (S6.3.1) and permanent (S6.3.2) labeling) if the tires to which they are affixed are of neither bias-belted or radial construction. If they are of either of these construction types, that information would have to be retention of the original casing labeling.; Yours truly, Richard B. Dyson, Assistant Chief Counsel