Interpretation ID: 1984-1.26

TYPE: INTERPRETATION-NHTSA

DATE: 03/21/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mazda (North America) Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Nakaya Office Manager Mazda (North America), Inc. Detroit Office 23777 Greenfield Road Suite 462 Southfie1d, MI 48075

Dear Mr. Nakaya:

This responds to your letter requesting an interpretation of Standard No. 120, Tire selection and rims for motor vehicles other than passenger cars (49 CFRS571.120). 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 or need more information on the requirements of Standard No. 120.

Sincerely,

Frank Berndt Chief Counsel

January 13, 1984

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C. 20590

RE: Interpretation of FMVSS 120; Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars

Dear Mr. Berndt:

The above Standard provides guidelines regarding the nature and display of tire and rim specifications. Within these guidelines, reference is made in Section 5.2 that the specifications, placed on the rim or wheel disc, " . . . shall appear on the weather side".

Mazda believes that this terminology refers to the surface of the rim or wheel disc that is not obscured by the mounted tire or any axle mounting components. This would result in ready accessibility of all specifications to personnel as the tire is mounted to the rim and avoid the obliterating effects that often occur between mating surfaces.

Please clarify the above terminology and comment on Mazda's interpretation of this requirement.

Thank you.

Sincerely,

H. Nakaya Office Manager

HN/ab