Interpretation ID: 1983-1.39

TYPE: INTERPRETATION-NHTSA

DATE: 04/07/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Dunlop Tire Company

TITLE: FMVSR INTERPRETATION

TEXT:

APR 7 1983 NOA-30

Mr. Richard H. Attenhofer Technical Manager, O.E Dunlop Tire Company Box 1109 Buffalo, New York 14240

Dear Mr. Attenhofer:

This responds to your recent letter to Mr. Kratzke of my staff, requesting an interpretation of 49 CFR Part 574, Tire Identification and Recordkeeping. Specifically, you asked if Dunlop could use a print type called OCR-A for the DOT symbol and the tire identification number.

Note 1 to Figure 1 of Part 574 specifies only four different print types which may be used for the DOT symbol and identification number, none of which are OCR-A. However, Note 4 to Figure 1 states that other print type will be permitted if approved by this agency. We have examined the print type shown in the diagram attached to your letter and have no objections to your company printing the required information in OCR-A type.

In the final rule establishing Part 574 (35 FR 17257, November 10, 1970), the agency explained that the reason for specifying only four print types which would be acceptable without advance agency approval was to ensure that the information would be easily readable by all persons. The OCR-A print type shown in the diagram attached to your letter is easily readable and thus satisfies our concerns in that regard. Accordingly, that print type is hereby approved.

Sincerely,

Frank Berndt Chief Counsel

February 10, 1983

Mr. Steven Kratzke Office of the Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, SW Washington, D. C. 20590

Dear Mr. Kratzke:

Dunlop Tire and Rubber Corporation wishes to utilize the latest electronic techniques for sorting and inventory control of automobile, motorcycle and truck tires which are subject to Tire Identification and Recordkeeping as defined in CFR 49, Chapter V, Part 574.

We request an interpretation of your office if the style of characters shown on the attached sketch 9522-DS do meet the requirements of Notes 1 or 4 shown in Figure 1 of Part 574.

Dunlop is grateful for your prompt consideration of this matter. Should you have any questions please call me direct at 716/879-8327.

Very truly yours,

DUNLOP TIRE & RUBBER CORPORATION

Richard H. Attenhofer, Technical Manager, O.E.