Interpretation ID: 1983-1.14

TYPE: INTERPRETATION-NHTSA

DATE: 02/07/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Empire Construction Co. Inc. -- H.J. Lindekugel, Consultant

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. J. Lindekugel Consultant Empire Construction Co., Inc. East 10310 Montgomery Box 11012 Spokane, Washington 99211

Dear Mr. Lindekugel:

This responds to your recent letter asking if the rim marking requirements of Safety Standard No. 120, Tire Selection and Rims for Motor Vehicle Other Than Passenger Cars, apply to "remanufactured truck wheels." They do not.

Section S5.2 of Standard No. 120 sets forth rim marking requirements applicable to all new rims manufactured on and after September 1, 1977, and designed for use on motor vehicles other than passenger cars. Remanufactured wheels are considered used wheels instead of new wheels for purpose of Standard No. 120, and so are not subject to the rim marking requirements.

Should you need any further information or have any further questions in this area, please contact Mr. Steve Kratzke of my staff at (202)426-2992.

Sincerely, Original Signed by Frank Berndt

Attention: Attorney for Rulemaking

Re: DOT number for remanufacturing process

Greetings: This writer was referred to you by Lauretta Carlson, Highway Safety Program Area Director, National Highway Traffic Safety Administration, Seattle, WA.

The point of inquiry is whether or not a DOT identification number is necessary for a re-manufactured truck wheel, not a repaired wheel. The review made with Lauretta Carlson showed no such standards as a pre-requisite. She sent me a copy of the Code of Federal Regulations, 57-119 and 57-120 which confirmed her judgement she suggested this letter.

Please advise the writer if the position she has taken is correct.

Very Truly Yours,

H. J. Lindekugel, Consultant