Interpretation ID: aiam1015
Semperit of America
Inc.
156 Ludlow Avenue
Northvale
New Jersey 07647;
Dear Mr. Kutschera: This is in reply to your letter of January 25, 1973, inquiring whethe size designations '225/70SR14 replaces G70SR14', and '215/70SR15 replaces F70SR15' etc., may be used under Federal Motor Vehicle Safety Standard No. 109.; Paragraph S4.3(a) of Standard No. 109 provides for the labeling of 'on size designation, except that equivalent inch and metric size designation may be used.' The NHTSA has taken the position that this requirement does not prohibit the labeling of replacement sizes when the replaced size is in fact being superseded by the replacement size.; Because your proposed label contains both a metric and an inch siz designation, however, it is not clear whether these size designations are intended as 'equivalent' or 'replacement' sizes. If you intend the former size to supersede the later, your use of 'replaces' between the two size designation is consistent with Standard No. 109, If your intention is to label equivalent size designation, however, the use of 'replaces' is inappropriate. One way in which equivalency may be appropriately shown is to place the inch size designation if a parenthesis () immediately following the metric size designation.; One last point is that the size designation listed in the Appendix o Standard No. 109 for 70 Series radial ply tires differ from those specified in your letter. Table I-G, which lists this tire type, specifies size designations in which the second letter is and 'R'. Thus, the size designations which you submit should have read GR70SR14 and FR70SR15. Other size designations of this tire type should be identified accordingly.; Yours truly, Richard B. Dyson, Assistant Chief Counsel