Interpretation ID: nht68-3.8

DATE: 01/14/68

FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA

TO: The Armstrong Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Bridwell has asked that I reply to your letter of December 5, 1967, which asks if the labeling requirements of S4.3 of Standard No. 109, can be complied with by placing some of the information on one sidewall of a tire and other information on the other sidewall.

The Standard requires that all of the labeling information be on both sidewalls and placing some of the necessary information on one sidewall of the tire and some on the other would not satisfy this requirement.

The standard provides that until August 1, 1968, the labeling requirements of S4.3 may be met by affixing to each tire a label or tag that incorporate all specified information not molded into or onto the tire."

THE ARMSTRONG RUBBER COMPANY

December 5, 1967

Mr. L.K. Bridwell Federal Highway Administrator National Highway Safety Bureau

Ref: Labeling of Tires where S.4.3 Requirements Appear on One Side of the Tire Only.

The mechanics of complying with the labeling requirements of S.4.3 MVSS No. 109 can become very cumbersome and expensive.

Here was our thinking over a year ago - we placed all the required information on what would be the white sidewall part of the mold, leaving the black side free to add that which would be required by the U.S. Department of Transportation, in the standards which we now have.

The attached sheet with this explanation will reveal the problem. Label No. 1 is basic. Labels 2 to 11 inclusive would have to be added to the tire. The workmen would first affix the basic label than a label to supply this missing information. As can be seen there are 56 sizes involved and ten other labels which shows a basic of conbinations to be 560.

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

R.L. Donnelly Corporate Secretary