Interpretation ID: aiam0145
Vice President
Rubber Manufacturers Association
1346 Connecticut Avenue
N.W.
Washington
D.C. 20036;
Dear Mr. Sears: This letter reaffirms the position of the National Highway Safet Bureau with respect to the handling of petitions for the addition of new tires as stated in recent telephone discussions with members of the Office of Standards on Accident Avoidance.; It was related during these discussions that further action on th petition of November 13, 1968, requesting the addition of the C78-13 tire size designation to Table I-J of the Appendix A of Standard No. 109 cannot be taken until the information indicating compliance with Federal Motor Vehicle Safety Standard No. 110 is received covering the desired test rim width. The Standards are directed at total motor vehicle safety: accordingly, they are just as applicable to replacement tires as to tires intended for new motor vehicles and the guidelines for addition of new tire size designations and new alternative rims to Standards No. 109 and No. 110 as published in the *Federal Register* of October 5, 1968, therefore apply.; The question of a precedence having been established by the addition o the 5 1/2JJ alternative rim to Table I of the appendix to Standard No. 110, without supporting date, in the case of the C70-15 tire size designation has been raised by your organisation. Our records indicate that your request for the addition of this tire size was based on the petition of August 19, 1968. This Action was well in advance of the procedural guidelines established on October 5, 1968. Although this test rim was added to Table I of the appendix A of Standard No. 110, without test date, the National Highway Safety Bureau believes that a safety hazard could exist if this tire and rim combination is not compatible. We Would, therefore, appreciate test information certifying compliance with the requirements of Standard No. 110 by the 5 1/2JJ rim and the C70-15 tire size combination.; Our records indicate that you have submitted petitions dated July 1 and August 29, 1968, requesting the addition of twelve additional alternative rim sizes to Table I of Appendix A of Standard No. 110. To date, data indicating compliance with Standards No. 109 and No. 110 has not been received and we have advised you in several telephone discussions that no action is contemplated until data is submitted.; In conclusion, We would like to reiterate that all future petitions fo additions to Standards No. 109 and No. 110 must be submitted in accordance with the guidelines published in the *Federal Register* on October 5, 1968. The Bureau makes no provisions or exceptions based on the ultimate use of tha(sic) tires. All new tires will be considered within the framework of these guidelines.; Sincerely, H.M. Jacklin, Jr. Acting Director, Motor Vehicle Safet Performance Service;