Interpretation ID: 1984-3.44

TYPE: INTERPRETATION-NHTSA

DATE: 11/29/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Continental Products Corporation -- Jack DiMaio

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Jack DiMaio Continental Products Corporation 1200 Wall Street West Lyndhurst, NJ 07071

This responds to your recent letter to Mr. Steve Kratzke of my staff, seeking an interpretation of Standard No. 119 New Pneumatic Tires for Vehicles Other Than Passenger Cars (49 CFR S571.119). Specifically, you asked three questions about the size markings required for truck tires. As a general matter, Standard No. 119 leaves the question of the appropriate size marking to the discretion of the individual manufacturer or to the manufacturers collectively, through the several standardization organizations. To be certain that I fully address your concerns, however, I will answer each of your questions in the order you presented them in your letter.

1 . Please clarify whether it is allowed to market a low profile tire with a size marking of 280/80 R22.5.

At the outset, I wish to clarify one point. In this and your other questions, your size designations do not include a letter designating the tire load range. In prior interpretations of Standard No. 120, which relates to tire selection and rims for vehicles other than passenger cars, I have indicated that the load range is considered a part of the size designation. This conclusion was based on the fact that many truck tires have identical dimensions, but widely varying load carrying capacities, depending on the load range. Hence, this answer and the two following assume that the size markings on the sidewall of these tires would include a letter indicating the load range assigned to the tires, as required by paragraph S6.5(j) of Standard No. 119.

Paragraph S6.5(c) of Standard No. 119 specifies that each tire subject to that standard shall be marked with the tire size designation shown "in the documents and publications designated in S5.1." Paragraph S5.1 of Standard No. 119 requires that tire manufacturers provide the public with a listing of the rims that may be used with each tire size the manufacturer produces. The manufacturer is given the option of itself individually furnishing such a listing to each of its dealers, to this agency, and to the public upon request or relying on the listings shown in the publications of the standardization organizations. A standardization organization is a voluntary association composed of representatives of each of its member tire companies. The purpose of standardization organizations is to establish and promulgate sound engineering standards for tires, rims, and their allied parts.

In the case of the 280/80 R22.5 size marking, you may rely on the listings published for that size by any of the standardization organizations shown in S5.1(b) or submit the listings directly to this agency and to each of your dealers. A check of the 1984 publications of the Tire & Rim Association and the Japan Automobile Tire Manufacturers Association by this agency did not show any listing for this size designation. It is possible that this size marking is listed by one of the other standardization organizations shown in S5.1(b). If not and if you wish to sell tires with this size designation, you will have to submit a listing of the size rims which may be used with this tire to this agency and to each of your dealers, as specified in S5.1(a).

2. Can the marking 280 R22.5 be used eventually?

If you wish to submit the rim matching information directly to your dealers and to this agency, pursuant to S5.1(a) of Standard No. 119, that marking may be used at the present time. However, it would be preferable if the tire manufacturers, through the standardization organizations, could agree on one size marking for tires with the same physical dimensions and load carrying capacity. This would lessen confusion on the part of consumers and tire service shops. The confusion on the part of those persons was one of the reasons the National Highway Traffic Safety Administration published the tire tables for passenger car tires subject to Standard No. 109. Notwithstanding the agency desire that tire manufacturers use the standardization organizations to resolve tire sizing questions, there is no requirement that they do so, provided that they satisfy the requirements of S5.1(a) for disseminating the sizing information.

3. Do standardization instructions exist which say that only marking 275/80 R22.5 is possible?

No such instructions exist in Standard No. 119. It is possible that this is the only size marking which has been approved by a standardization organization and thus the only marking which can be used if the manufacturer wants to meet the sizing dissemination requirements under S5.1(b) of Standard No. 119. However, as stated above, the individual manufacturer is free to follow the dissemination requirements of S5.1(a) for tire sizes not listed in standardization organization publications.

Should you have any further questions, or need further information on this subject, please do not hesitate to contact Mr. Kratzke at this address or by a telephone at (202) 426-2992.

Sincerely,

Frank Berndt Chief Counsel

September 28, 1984 NHTSA Rm. 5219 Office of Chief Counsel 400 7th St. S.W. Washington, D.C. 20590 Attn: Steve Kratzke Dear Mr. Kratzke, We at Continental are in preparation of our own version of the new Low Profile truck tire. Some questions have arisen that you may be able to answer regarding size markings. 1. Please clarify whether it is allowed to market a low profile with marking 280/80 R22.5. 2. Can the marking 280 R22.5 be used eventually? 3. Do standardization instructions exist which say that only marking 275/80 R22.5 is possible? Should you have any questions or need more information, please contact the undersigned. Sincerely, Jack Di Maio Continental Products Corporation Main Office 1200 Wall Street West Lyndhurst, NJ 07071 (201) 460-0200; Telex: 133 391