Interpretation ID: 1983-2.47

TYPE: INTERPRETATION-NHTSA

DATE: 08/18/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Continental Products Corp. -- Arnold Van Ruitenbeck, Vice President

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Arnold van Ruitenbeek Vice President Continental Products Corporation 1200 Wall Street West Lyndhurst, New Jersey 07071

Dear Mr. van Ruitenbeek:

This responds to your recent letter asking for an interpre-tation concerning Safety Standard No. 119, New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars. Specifically, you asked whether your company could label two maximum load ratings on the sidewall of certain motorcycle tires it manufactures. One maximum load rating would be applicable at the tire's top-rated speed, while the other would be applicable at a speed of 60 miles per hour. Such labeling would violate Standard No. 119.

Section S6.5 of Standard No. 119 requires that certain information be labeled on the sidewall of all tires to which the standard applies. Section S6.5 requires the maximum load rating and corresponding inflation pressure to appear on all motorcycle tires, shown as follows:

Max load lbs at psi cold.

The maximum load rating on the tire's sidewall, as the name implies, is intended to alert the consumer to the tire's maximum capabilities. Allowing tire manufacturers to specify more than one maximum load, based on various vehicle speeds, would dilute the value of the maximum load information to the consumer, by introducing the possibility of confusion and uncertainty about the actual maximum load the tire could carry while in use on a particular trip. To avoid this, the agency has stated on each occasion when questions have arisen in this area that only one maximum load rating may appear on the sidewall of tires.

Please understand that the agency does not doubt that these tires can carry higher loads at lower speeds. Further, it does not have any objection to your publicizing those loads in your advertising literature, which you enclosed with your letter. However, the purpose of the labeling requirements on the sidewall of tires is not to give the consumer information for all possible operating conditions for the tire. Indeed, there is not enough space on the sidewall of the tire to do this. The purpose of the labeling requirements is to provide the consumer, in a straightforward manner, with technical information necessary for the safe use of the tires. In the case of the maximum load information, this necessitates providing only one maximum load rating on the sidewall of the tires.

Sincerely,

Frank Berndt Chief Counsel

April 21, 1983

Mr. Frank A. Berndt Chief Counsel NATIONAL HIGHWAY TRAFFIC ADMINISTRATION 200 7th Street S.W. Washington, D.C. 20590

Dear Mr. Berndt:

We are requesting an advisory opinion on motorcycle tire sidewall markings as required by FMVSS 119.

Continental motorcycle tires are made in Germany where there are no speed limits on the Autobahn.

Motocycle tire load ratings are governed by the speed rating of the tire: the higer the speed rating, the lower the load and, visa versa, the lower the speed the higher the load.

Our SuperTwin tire (see attached brochure) have a V-rating for 150 MPH and the load rating molded into the tire is for this speed. At 60 MPH the load rating is aproximately 52% higher - as is shown in the last column of the enclosed brochure.

In our program are two sizes that are mainly used on touring bikes, usually ridden with one extra passenger and extra luggage.

We are now asking for your permission to engrave, in addition to all required DOT markings, the higer 60 MPH load capacity on the sidewall of the tire, underneath where the DOT load rating for 150 MPH now appears.

The proposed sentence is: For size 30/90 V 16 TK44 : At 60 MPH the load capacity is 880 lbs at 40 PSI. For size 130/90 V 17 TK44 : At 60 Mph the load capacity is 900 lbs at 40 PSI.

This information is very helpful for the rider and contributes to the safe operation of the motorcycle. We look forward to hearing from you.

Very truly yours,

Arnold van Ruitenbeek Vice President