Interpretation ID: nht68-1.4

DATE: 01/25/68

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: The Armstrong Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: In our telephone conversation of January 8, 1968, and your letter of January 9, 1968, you requested:

". . . . an early reply whether labels are required, when the information already appears on one sidewall, except the basic label. (Basic label Information - DOT-153) It is also our feeling that the labeling is not a serious requirement to meet minimum safety standards."

This letter confirms my statement in our telephone conversation that Motor Vehicle Safety Standard 109 may be met if the information required in S4.3 of this standard is molded on one or both sidewalls of the tire in lieu of a label until August 1, 1968, after which this information is required on each sidewall.

Sincerely,

THE ARMSTRONG RUBBER COMPANY

January 9, 1968

Roger H. Compton, Director Office of Standards on Accident Avoidance U.S. Department of Transportation Federal Highway Administration

Dear Mr. Compton:

Re: Replies to 1) Our December 5, 1967, Letter Addressed to Mr. L. K. Bridwell

2) Confirmation of Telephone Call (December 15, 1967) Placing Labeling on One Side of Tire by Stencils Molded into the Tire in Lieu of labels

My letter of December 5, 1967, last paragraph, stated as follows:

"We request an early reply whether labels are required, when the information already appears on one sidewall, except the basic label. (Basic Label Information - DOT-153) It is also our feeling that labeling is not a serious requirement to meet minimum safety standards."

On December 15, 1967, our Mr. John A. Diehl called Mr. Schwentker and received a verbal reply by telephone from you that The Armstrong Rubber, Company could proceed without labels if the required information of S4.3 MVSS Standard 109 was molded on one sidewall of the tire in lieu of labels.

We appreciate your position and understand that your staff is not complete. However, we would like to receive a reply in writing or by means of a notice in the Federal Register that the course which you approved and which we are following can be used by all tire manufacturers.

Sincerely,

R. L. Donnelly Secretary