Interpretation ID: aiam2890
Burke & Burke
30 Rockefeller Plaza
New York
NY 10020;
Dear Mr. Pinto: This is in response to your letter of October 25, 1978, requestin approval of the tread labels Atlas Supply 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. All possible traction and temperature grades would be depicted with the grades applicable to the specific tire indelibly circled. A separate label would contain the general grading information from Figure 2 of the rule.; 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. While the National Highway Traffic Safety Administration (NHTSA) has no 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.; While Atlas' proposed tread labels do not meet the present requirement of Part 575.104(d)(1)(i)(B), NHTSA now has under consideration a petition for rulemaking requesting amendment of the UTQG regulation to permit greater flexibility in tread labeling.; Sincerely, Joseph J. Levin, Jr., Chief Counsel