Interpretation ID: aiam3812
Office Manager
Mazda (North America)
Inc.
Detroit Office
23777 Grenfield (sic) Road
Suite 462
Southfield
MI 48075;
Dear Mr. Nakaya: This responds to your letter requesting an interpretation of Standar No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars* (49 CFR S571.120). Specifically, you noted that section S5.2 of that standard required that certain information be labeled on the 'weather side' of each rim or wheel disc. You then offered your interpretation of the term 'weather side', and asked for my comments on that interpretation. My comment is that Standard No. 120 explicitly defines 'weather side', and that the definition of the term in Standard No. 120 is somewhat broader than your interpretation of the term.; Section S4 of Standard No. 120 contains the following definition 'Weather side' means the surface area of the rim not covered by the inflated tire. The interpretation you offered in your letter was consistent with this definition, because it would require that the information not be labeled in an area where it would be obscured by the inflated tire. However, your interpretation would also require that the information not be labeled in an area where it would be obscured by any axle mounting components, and this requirement is not contained in the definition set forth in Standard No. 120. You are free to use your narrower interpretation for your own purposes since it is consistent with the definition in the Standard, but the definition set forth in the Standard would be used to determine whether a rim complies with the requirements of the Standard.; Please feel free to contact me should you have any further questions o need more information on the requirements of Standard No. 120.; Sincerely, Frank Berndt, Chief Counsel