Interpretation ID: aiam3494
Esq.
Assistant General Counsel
Fruehauf Corporation
10900 Harper Avenue
P.O. Box 238
Detroit
MI 48232;
Dear Mr. Starkey: This responds to your recent letter to Mr. Kratzke of my staf concerning the requirements of Federal Motor Vehicle Safety Standard No. 120 (49 CFR S571.120). Specifically, you asked if retreaded tires could be mounted on new trucks and trailers, and what requirements those tires would have to meet.; Retreaded tires can be mounted on new trucks and trailers withou violating Standard 120. For your information, I have enclosed a copy of a 1978 interpretation concerning Standard 120 which explains that retreaded tires can be mounted on new trucks and trailers in compliance with the standard. The only requirements those tires would have to meet is that the sum of maximum load ratings for the tires would have to be at least equal to the gross axle weight rating of the axle to which they were fitted, as specified in section S5.1.2 of the Standard 120. As explained in the attached letter, there is no requirement that the retread meet the requirements of Standard 119 because those requirements are inapplicable to retreads. Further, there is no requirement that the retreads have the DOT symbol.; If you have any further questions, please contact Mr. Kratzke at (202 426- 2992.; Sincerely, Frank Berndt, Chief Counsel