Interpretation ID: 2786y
Mayer, Brown, & Platt
2000 Pennsylvania Avenue, N.W.
Washington, D.C. 20006-1885
Dear Mrs. Jones:
This responds to your letter requesting a confirmation of your telephone conversation with Mr. Stephen Wood of my staff. In that conversation, he informally stated that the attached letter dated January 5, 1990 from Fidelity Tire Manufacturing Company contained the information necessary to comply with the notification requirements in S5.1 of Federal Motor Vehicle Safety Standard 119 (49 CFR 571.119) for tires and rims not listed in the publication of a specified tire and rim association. This letter confirms that Fidelity's letter would satisfy the requirements of section S5.1.
Section S5.1 requires that a listing of the rims which may be used with each tire produced by a manufacturer be provided to the public. The purpose of this requirement is to ensure that the tire will be mounted only on appropriate rims and that the tire will be mounted on vehicles where its load-carrying capacity will be adequate. That section gives manufacturers the option of using the data provided for the tire size and corresponding rims published in certain standardization organization yearbooks or listing the appropriate information "in a document furnished to dealers of the manufacturer's tires, to any person upon request, and in duplicate to [NHTSA]." Fidelity's letter which includes the appropriate dimensional and load-carrying data for the tire and rim appears to satisfy this requirement.
I hope this explanation is helpful. Please contact Mr. Marvin Shaw of my staff at (202) 366-2992 if you have any further questions.
Sincerely,
Paul Jackson Rice Chief Counsel ref:ll9 d:l2/6/90