Interpretation ID: aiam2889
Director
Quality Assurance
The Armstrong Rubber Company
500 Sargent Drive
New Haven
CT 06507;
Dear Mr. Cheetham: This is in response to your letter of October 19, 1978, requestin approval of the tread labels Armstrong Rubber Company proposes to use in satisfaction of the labeling requirements of the Uniform Tire Quality Grading Standards (UTQGS)(49 CFR 575.104(d)(1)(i)(B)). You propose to include the applicable UTQGS grades for a particular tire on a tread label identifying the tire brand, type and size. A separate label would contain the general grading information from Figure 2 of the rule, including a listing of all possible traction and temperature grades, with the text on the label oriented along the tread circumference instead of across it.; Part 575.104(d)(1)(i)(B) requires that each passenger car replacemen tire, other than a snow tire or temporary use spare tire, have affixed a tread label containing both the specific UTQGS grades for the tire and an explanation of the grades in the form illustrated in Figure 2. Thus, the specific grades for the tire must appear on the same label that contains the explanation of the grading system. The regulation calls for a depiction of all possible traction and temperature grades with the grades applicable to the specific tire indelibly circled.; While the National Highway Traffic Safety Administration (NHTSA) has n objection to the inclusion of the required UTQGS information on the same label with other data such as tire size and brand name, failure to provide the required explanations on the same label with the applicable tire grades is not permitted by the regulation. Your proposed labels also fail to meet the regulation's requirement that applicable traction and temperature grades be denoted by circling the appropriate letter in a display of all possible grades. Finally, the general UTQGS information in your proposal is not in the form illustrated in Figure 2, since the text in your example will appear along the tread rather than at right angles as specified by Figure 2.; While your proposed tread labels do not meet the present requirement of Part 575.104(d)(1)(i)(B), NHTSA will treat your letter as a petition for rulemaking and consider amending the UTQG regulation to permit greater flexibility in tread labeling.; Sincerely, Joseph J. Levin, Jr., Chief Counsel