Interpretation ID: aiam1350
President
B.F. Goodrich Tire Company
500 South Main Street
Akron
Ohio 44318;
Dear Mr. Ross: This is in reply to your petition, dated may 18, 1973, for amendment to Motor Vehicle Safety Standard No. 109 and the Tire Identification and Recordkeeping regulations (49 CFR Part 574). You request that the standard be amended to except tires having an 'unusual configuration and construction,' from the part of S4.3 which requires safety information to be labeled between each tire's maximum section width and bead. You request a similar exception in Part 574 for the tire identification number. Goodrich has experienced difficulties in placing this information in the proper location in tire molds used to manufacture Goodrich's Space Saver Spare tire. You indicate this is caused by the thinness of the mold, which is apparently necessitated by the folding sidewall characteristics of the tire.; In case of the Space Saver Spare, Goodrich wants to be able to plac the labeling information and the identification number in the shoulder area of the tire. Your request is supported with pictures of a Space Saver Spare that has been run to wear-out yet still retains legible labeling in this area. In your view it is unlikely that this tire will be retreaded. You argue that the location you desire to use, while not between the maximum section width and bead, has the advantage of making the information and identification number visible both when the tire is inflated and deflated. the latter condition is important in this case in that this tire is generally carried in a deflated, folded condition when it is not in use.; We do not believe the facts you present justify an amendment to th standard, and have therefore determined that your petition should be denied. The purpose of requiring safety information and the tire identification number to be placed between each tire's maximum section width and the bead is to ensure, to the greatest extent possible, that the information will remain on the tire throughout its useful life, including a retreading process if the tire is retreaded. In our View, it is not all clear that the alternative location you suggest will still meet this objective. The justification which you provide does not show that labeled information cannot be removed in service or that these tires will not, in fact, be retreaded. We certainly would not object if Goodrich were to place identifying information in separate location in addition to that required by the standard.; With respect to the difficulty you have encountered in placing th information in the specified area, we do not find on the basis of the information you have supplied that the alternative possibilities are impracticable. For example, your letter does not mention whether you have attempted to engrave the safety information and that part of the identification number that is constant into the tire molds. While we understand engraving is generally more expensive and somewhat more inconvenient than branding the mold or using metal plates, we do not believe the added expense and inconvenience, particularly as it is amortized over the life of the mold, to be unreasonable in terms of the safety benefit achieved. It also appears that this labeling, in letters 0.078 inches in height, can be placed just above the rim centering rib, which from the sample submitted with your petition, does not appear to have been damaged upon removal. This location would allow removal of the tire from the mold without deformation of the lettering and would place the required information between the tire's maximum section width and bead. With respect to date codes, for which engraving is unsuited, it appears that the code stamp could be recessed so as to be flush with the mold surface, thus eliminating or substantially reducing the destruction of the lettering during removal.; Sincerely, James B. Gregory, Administrator