Interpretation ID: 1983-2.1

TYPE: INTERPRETATION-NHTSA

DATE: 05/04/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mohawk Rubber Company -- T.J. Brown

TITLE: FMVSR INTERPRETATION

TEXT:

Mr. T.J. Brown Mohawk Rubber Company Roanoke, Virginia 241017

Dear Mr. Brown:

This is in response to your March 28, 1983, letter to Roger Fairchild of this office, requesting confirmation of your understanding of the effective dates for the recent suspension of treadwear grading under this agency's Uniform Tire Quality Grading Standards.

Your understanding of the effective dates is correct. Tires produced in molds manufactured on or after August 8, 1983, must have the new grading format which excludes treadwear information. Tires produced in molds manufactured before which includes treadwater information. We encourage manufacturers to use the new format as soon as feasible, to minimize the dissemination of misleading information with regard.

With regard to labels, the requirement that such labels must contain information regarding treadwater grades was suspended effective February 7, 1983. The preamble to the final rule states that manufacturers will be permitted to exhaust inventories of labels which were in existence as of the date of the suspension. Thereafter, manufacturers should begin using labels without treadwear information.

If you have further questions on this matter, please feel free to contact us.

Sincerely,

Frank Berndt Chief Counsel

March 28, 1983 Mr. Roger Fairchild Re: 49 CFR Part 575, Docket No. 25, Notice 52

Dear Mr. Fairchild:

Mr. C.D. Frame of Mohawk contacted you on March 28 pertaining to the ruling included in the Federal Register dated Monday, February 7, 1983.

Our particular concern is in interpretation of the treadwear stamping to be included, or not included, in the tire mold. We understand the ruling to state that tires which are produced after August 8, 1983, are not to have the treadwear information only if the molds themselves were manufactured after this date.

On tires produced in molds which were manufactured prior to August 8, 1983, the treadwear information is permitted on the molded tire. It is further our understanding that tire label are to have the treadwear grade and the explanation as to how it was obtained removed from them as new labels are procurred after the date of February 7, 1983. Existing inventories of labels containing he treadwater information are permitted to be used until such time as thi inventory is depleted.

We would appreciate a letter from you in response to our interpretations as to whether they are indeed correct.

Very truly yours

MOHAWK RUBBER COMPANY

T. J. Brown General Manager, Product Services