Interpretation ID: aiam1714
Chairman
ASTM Subcommittee E17.24
Tire and Slider characteristics
General Motors Proving Ground
Milford
Michigan 48042;
Dear Mr. Anderson: This is in reply to your letters of October 25, and November 5, 1974 requesting our opinion on whether a tire recently approved by ASTM for special purpose highway and airport runway skid resistance tests must conform to Motor Vehicle Safety Standard No. 109 (49 CFR S 571.109), and whether it may be used for skid resistance testing on highways and airport runways. You describe the tire as a G778-15 of bias-belted construction (2-ply polyester sidewall and 2 fiberglass belts), having a tread with no grooves or sipes. You indicate that due to the tread configuration the tire will not meet the high speed performance requirements (S4.2.2.6) of Standard No. 109.; Standard No. 109 applies according to its terms to '...tires for use o passenger cars...' We believe it reasonable to distinguish these ASTM test tires from tires subject to Standard No. 109. While physically similar to passenger car tires, these tires are manufactured purely as test devices, and for test purpose. We conclude, therefore, that they are not 'for use on passenger cars' within the meaning of Standard No. 109. These tires should be distinguished from experimental program for passenger car tires, which we have found to be subject to Standard no. 109.; Because of this conclusion, there are no NHTSA prohibitions on th tires' use as test tires. They may be used for testing purposes on public highways and airport runways if that testing can be conducted in a safe manner. You should, however, check State and local laws in any area in which you which to conduct testing to see that those laws permit testing if this type. Because the tires are not subject to Standard No. 109 we believe it would be preferable if they did not contain the nomenclature required by Standard No. 109 except insofar as that nomenclature relates to their safe use in testing. This would reduce the chance that they may be used on passenger cars for other than test purposes. We also believe a stronger warning against general use would be proper. We have in mind Something like 'CAUTION: NOT FOR GENERAL HIGHWAY USE - DO NOT USE EXCEPT FOR SPECIAL TEST PURPOSES.'; Yours truly, Richard B. Dyson, Acting Chief Counsel