Interpretation ID: 86-2.2

TYPE: INTERPRETATION-NHTSA

DATE: 03/01/86 EST

FROM: Erika Z. Jones; NHTSA

TO: Dipl.-Ing. F. Vapenicek -- Chief of Machinery Plant, Nova Hut Klementa Gottwalda

TITLE: NONE

ATTACHMT: 2/17/86 letter from Erika Z. Jones to Ralph Trimarchi (Std. 110; Std. 119; Std. 120; Std. 109)

TEXT:

AIR MAIL Dipl.-Ing. F. Vapenicek Chief of Machinery Plant Nova Hut Klementa Gottwalda n.p., 707 02 Ostrava 7 CZECHOSLOVAKIA

Dear Mr. Vapenicek:

This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other than Passenger Cars. You stated that the dimensions of your rims comply with dimensional specifications of the European Tyre and Rim Technical Organization. You asked whether disc wheels provided with certain information can be regarded as complying with the requirements of U.S. standards. Your question is responded to below.

By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.

You provided the following example of your disc wheel marking on the attachment face of the disc:

(b) 8,0-20 (c) DOT-E (d) symbol of the manufacturer (e) 6 87

You stated that the information listed in (b) and (d) also appears on every part of your multipiece rim and that height and depth of the marking meets the requirements of S5.2 of Standard No. 120.

Section S5.2 states: . . . each rim or, at the option of the manufacturer in the case of a singlepiece wheel, wheel disc shall be marked with the information listed in paragraphs (a) through (e) of this paragraph . . . . The information listed in paragraphs (a) through (e) of this paragraph shall appear on the weather side. In the case of rims of multipiece construction, the information listed in paragraphs (a) through (e) of this paragraph shall appear on the rim base and the information listed in paragraphs (b) and (d) of this paragraph shall also appear on each other part of the rim.

Your letter indicates that you plan to place your disc wheel marking "on the attachment face of disc." While it is not clear what you mean by the term attachment face of disc, I would like to note several requirements specified by section S5.2 for marking location. First, the marking must be placed on the rim, except that for singlepiece wheels manufacturers have the option of placing the marking on the wheel disc. Thus, assuming that your rim is a multipiece rim, the marking must be placed on the rim rather than the disc. Second, the information listed in paragraphs (a) through (c) must be placed on the weather side. Section S4 provides a definition for the "weather side" of a rim. Third, for multipiece rims, the information listed in paragraphs (a) through (e) must appear on the rim base, and the information listed in paragraphs (b) and (d) must also appear on each other part of the rim. Section 54 provides a definition for "rim base."

Your sample disc wheel marking links by a hyphen the symbol "DOT" required by S5.2 (c) and the designation "E" required by S5.2(a). The symbol DOT constitutes a certification by the manufacturer of the rim that the rim complies with all applicable motor vehicle safety standards, while the designation E indicates the source of the rim's published nominal dimensions, i.e., in your case, the European Tyre and Rim Technical Organization. While NHTSA expects the information provided in paragraphs (a), (b) , and (c) to be grouped together, we do not recommend linking "DOT" and "E" by a hyphen. These symbols provide two different types of information, and the inclusion of a hyphen could cause confusion.

The information required by S5.2(b) is "(t)he rim size designation, and in the case of multipiece rims, the rim type designation. For example: 20 x 5.50, or 20 x 5.5. " Your sample disc wheel marking is 8,O-20. I note first that the rim size designation (defined in S4 as "rim diameter and width") should use the symbol "x" between the width and diameter, as indicated by S5.2(b)'s example. Moreover, for multipiece rims, S5.2(b) requires both the rim size designation and the rim type designation. S4 defines the term "rim type designation" as "the industry or manufacturer's designation for a rim by style or code." If your disc wheel is a multipiece rim, the disc wheel marking should include the rim type designation.

S5.2(c) requires a designation that identifies the manufacturer of the rim by name, trademark, or symbol. Your letter indicates that you plan to use a symbol. I note that, as discussed in an interpretation letter dated February 17, 1986 (copy enclosed), 49 CFR Part 551 requires rim manufacturers to designate a permanent resident of the United States as the manufacturer's agent for service of process in this country. Among other things, the designation of agent must contain information concerning marks, trade names, or other designations of origin of any of the manufacturer's wheels and rims that do not bear its name.

The information in your sample disc wheel marking under (e) is consistent with one of the examples provided in S5.2 (e) to indicate the month and year of manufacturer.

Sincerely,

Erika Z Jones Chief Counsel

Enclosure (see 2/17/86 letter from Erika Z. Jones to Ralph Trimarchi)

Dear Sirs,

We take the liberty of asking you for your advice concerning the disc wheels. As the requirements of S571,120 differ from those on windshields or tires when symbol DOT is concerned we are not quite sure whether our disc wheels marking meets the requirements. We would like to mention that dimensions of our rims comply with dimensional specifications required by the EUROPEAN TYRE AND RIM TECHNICAL ORGANIZATION.

An example of our disc wheel marking on the attachment face of disc (according to S 571.120):

(b) 8,0-20 (c) DOT-E (d) symbol of the manufacturer (e) 6 87

The information listed in (b) and (d) also appears on every part of our multipiece rim as specified in S 571.120 S5.2. Height and depth of the marking meet the requirements of S 571.120 S5.2.

Be so kind, please, and let us know whether a disc wheel provided with the information (b), (c), (d) and (e) above can be regarded as complying with the requirements of U.S. standards.

We are looking forward to hearing from you soon.

Yours sincerely,

Dipl.-Ing. F. Vapenicek Chief of Machinery Plant