Interpretation ID: aiam1117
Jr.
Director of Communication
National Tire Dealers & Retreaders Association
Inc.
1343 L Street
N.W.
Washington
D.C. 20005;
Dear Mr. Friedlander: This is in reply to your letter of March 21, 1973, in which you ask ho retreaded tires are to be tested to the strength requirements (plunger-energy) of Standard No. 117 (S5.1.1, incorporating by reference S4.2.2.4 of Standard No. 109). You appear to believe testing to the requirement is precluded because Standard No. 117 contains no requirement that the cord material be labeled onto the tire, and the plunger-energy requirements specify different performance levels for differing cord materials.; While Standard No. 117 does not require the generic name of the cor material to be labeled onto the retreaded tire, we expect that it will be found on most tire casings and will be available to the retreader on all post 'DOT' casings, and on many pre-DOT casings as well. If a retreader tire is not labeled with its cord material, the strength test can still be conducted. It is not necessary to know the cord material before the plunger-energy values are obtained. Once they are obtained, a sample can be removed from the tire, from which the material can be determined.; Yours truly, Richard B. Dyson, Assistant Chief Counsel