Interpretation ID: 77-3.37

TYPE: INTERPRETATION-NHTSA

DATE: 07/29/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Utility Trailer Manufacturing Co.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your May 20, 1977, letter asking whether your proposed certification labels comply with the requirements of Part 567, Certification.

The National Highway Traffic Safety Administration (NHTSA) does not issue advance approval of compliance with Federal safety standards or regulations. We will, however, issue an opinion of whether your labels appear to comply with the regulations. The labels you submitted appear to comply with all but one of the requirements of Part 567 and Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. On your certification labels, you list the symbol "W/" before the rim information. This symbol should be dropped from the label. Further the rim size designation should use the symbol "x" between the diameter and width. Information supplied on a certification label must be provided in the form detailed in Part 567.

SINCERELY,

UTILITY TRAILER MANUFACTURING CO.

May 20, 1977

N.H.T.S.A. Attn: George Shifflett

Re: Code NMV-22

Please give me an interpretation as to whether our proposed certification labels per attached drawings AB-2381A and AB-2383A meet the requirement of 49CFR571.120-5.3 and 49CFR567.

The peculiar aspects of these labels and reasons for them are as follows:

1. Since the GAWR, tire size, rim size, and tire cold inflation pressure are the same for all axles on a trailer, this information is listed once. Note that a trailer typically will have 1, 2, or 3 axles.

2. The actual tire sized delivered on a trailer and its inflation pressure will be stated to avoid misinforming the customer as to the proper inflation pressure required and the possible associated product liability. For example if our label called out GAWR = 20,000. With 11-24.5 (F) tires with 24.5 x 3.25 rims, at 75 PSI cold dual, but the trailer was delivered with Michelin 11 R 24.5 x (G) tires, and our customer followed the 75 PSI inflation pressure per our label instead of the inflation pressure stated on the tire sidewall, the tire capacity per axle would only be 1d, 185. Note that the 11-24.5 (F) is a popular tire used to achieve the 20,000 maximum per axle load bridge law and that its 75 PSI inflation pressure is a maximum.

3. The label per AB-2387A lists (8) different popular sizes. Since tires sizes are change frequently on stock trailers at the (Illegible Word) level this should reduce the required frequency of exchanging certification labels and thus reduce the number of circarded or called labels that get into the hands of thieves for use on stolen trailers to misrepresent the actual V.I.N. California State Highway Petrol has stated, that handling of replacement certification labels is a real problem today.

Please answer within two (2) weeks, as we must order new labels by mid June, in order to be ready for September 1, 1977 effective date. Call me at (213) 965-1541 if I can be of any help in answering questions.

Paul F. Bennett Chief Engineer

NOTES:

TABLE FOR STAMPING INFORMATION TO BE BRIGHT BRASS. NO PRINTED MATTER LESS THAN 3/32 HIGH. ALL PRINTED MATT TO BE CAPITALS. BACKGROUND GLOSSY BLACK MATL. NOT LESS THAN .032 BRASS.

(Graphics omitted)

MASTER DWG. RETURN TO FILE. IN DRAWER #17 INDEX PG. #1

REVISION DATE REFERENCE DRW NO. THIS DRAWING IS A CONFIDENTIAL DISCLOSURE THE SUBJECT MATTER OF WHICH IS THE PROPERTY OF THE UTILITY TRAILER MFG. CO. AND IS NOT TO BE REPRODUCED OR MANUFACTURED FOR ANY PURPOSE WITHOUT WRITTEN PERMISSION OF UTILITY TRAILER MFG CO. UTILITY TRAILER MFG CO. CITY OF INDUSTRY, CALIFORNIA D.O.T. CERTIFICATION LABEL SPECIAL VEHICLES DRN PAT.C SERIAL AND SHOP ORDER CHD. SALES OFFICE PT. NO. 03-5600-0-027 DATE: (Illegible Words)

OWG NO.: AB-2383-A

NOTES: (Illegible Data)

C. ALL DIM. FOR INDIVIDUAL BLOCK LETTERING PER DWG AB-2383A EXCEPT AS NOTED.

(Graphics omitted)

REVISION DATE: REFERENCE DWG NO. THIS DRAWING IS A CONFIDENTIAL DISCLOSURE THE SUBJECT MATTER OF WHICH IS THE PROPERTY OF THE UTILITY TRAILER MFG. CO. AND IS NOT TO BE REPRODUCED OR MANUFACTURED FOR ANY PURPOSE WITHOUT WRITTEN PERMISSION OF UTILITY TRAILER MFG. CO. UTILITY TRAILER MFG. CO. CITY OF INDUSTRY, CALIFORNIA D.O.T. CERTIFICATION LABEL STD DUAL AXLE VEHICLES DRN.: (Illegible Word) SERIAL AND SHOP ORDER CHD. SALES OFFICE DATE: MAY 30, 1977 DWG NO.: AB2383A