Interpretation ID: 77-3.40
TYPE: INTERPRETATION-NHTSA
DATE: 08/03/77
FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA
TO: Michelin Tire Corporation
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your June 7, 1977, letter asking who must mark a rim in accordance with the requirements of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars, in those cases where the rim is manufactured by one manufacturer and then supplied to a wheel manufacturer who welds the rim to a disc making a completed wheel.
The National Highway Traffic Safety Administration has determined that the rim marking must be undertaken by the rim manufacturer. The rim manufacturer is best able to supply the required rim information and undertake the certification required by S5.2 of the standard. The subsequent addition of the disc to the rim should not alter the information marked on the rim.
SINCERELY,
JUNE 7, 1977
Office of the Chief Counsel National Highway Traffic Safety Administration Department of Transportation
Re: FMVSS 120, Tire Selection and Rims for Motor Vehicles other than Passenger Cars
We are writing to request an interpretation of the rim marking requirement of FMVSS 120 Tire Selection and Rims for Motor Vehicle other than Passenger Cars.
We are interested in the case where a rim manufacturer supplies rims to a wheel manufacturer who then welds these rims to discs thus producing wheels. In such a situation, is the rim manufacturer or the wheel manufacturer responsible for the markings required by FMVSS 120?
Your prompt reply to this inquiry would be appreciated.
MICHELIN TIRE CORPORATION Technical Group
John B. White Engineering Manager Technical Information Dept.
TELEGRAPHIC MESSAGE
NAME OF AGENCY:
Department of Transportation National Highway Traffic Safety Adm. PRECEDENCE Action P (Illegible Word) DATE PREPARED: 8/16/77
SECURITY CLASSIFICATION
TYPE OF (Illegible Word): [x] (Illegible Word) [] BOOK [] MULTIPLE-ADDRESS
NAME: Fred Koch PHONE NUMBER: 202-426-2800
THIS SPACE FOR USE OF COMMUNICATION UNIT: #26417
TO: ROBERT STEVENSON TECHNICAL SALES MANAGER, WHEEL DIVISION GKN SANKEY, LIMITED
PURSUANT TO YOUR TELEPHONE CALL OF AUGUST 15, 1977, TO FRED KOCH REGARDING FEDERAL MOTOR VEHICLE SAFETY STANDARD NO. 120, OUR ANSWERS TO YOUR TWO QUESTIONS FOLLOW.
1. REGARDING THE PRESENCE OF MOLDED LETTERING ON RIM SURFACES IDENTIFYING MILL SOURCE OF MATERIAL NOT SPECIFIED IN THE STANDARD, THERE IS NO OBJECTION TO SUCH MARKING APPEARING ON THE FINISHED RIM PROVIDED IT DOES NOT INTERFERE WITH UNDERSTANDING AND CLARITY OF SEPARATE MARKINGS REQUIRED BY THE STANDARD.
2. REGARDING THE SPACING OF NUMBERS ON THE RIM REPRESENTING DATE OF MANUFACTURER, THE INTENT IS TO MINIMIZE AREA OCCUPIED AND TO AVOID IRREGULAR OR INCONSISTENT SPACING AND OPENINGS IN WHICH INFORMATION MIGHT BE LOST OR UNDETECTED. HOWEVER, THE USE OF VERY SHORT SPACING BETWEEN MONTH, DAY, AND YEAR IS NOT PROHIBITED BY THE STANDARD.
E. T. DRIVER, DIRECTOR OFFICE OF CRASH AVOIDANCE MOTOR VEHICLE PROGRAMS NMV-30 PAGE NO.: 2 NO. OF PGS.: 2