Interpretation ID: aiam2109

Mr. J. W. Lawrence, P.O. Box 91500, Cleveland, Oh 44101; Mr. J. W. Lawrence
P.O. Box 91500
Cleveland
Oh 44101;

Dear Mr. Lawrence: This is in response to your July 19, 1976, letter requesting a interpretation of S567.4(g) of 49 CFR Part 567, *Certification*, with respect to the listing of pound and kilogram weight ratings.; You have cited my June 30, 1976, letter to Toyota Motor Sales, whic stated that weight ratings may be expressed in both pounds and kilograms, provided that each kilogram rating appears 'after' the corresponding pound rating. You have also cited 49 CFR Part 567.4(g), which specifies that 'Gross Axle Weight Rating' or 'GVWR' be 'followed by' the pound ratings for each axle, identified in order from front to rear.; If A and B are two items of information on a label, the NHTS interprets 'A is followed by 'B' to mean 'B appears to the right of A or below A or both.' We consider 'B appears after A' to have the identical meaning.; The pairing of pound and kilogram ratings that is permitted by th interpretation in the Toyota letter must appear hierarchically within the sequence of axle ratings specified in S567.4(g). For example, the following listing is permitted:; GAWR FRONT 2000 lbs/907 kgs REAR 2200 lbs/998 kgs, while the following listing is not permitted: GAWR FRONT 2000 lbs REAR 2200 lbs (907 kgs/998 kgs). Sincerely, Frank A. Berndt, Acting Chief Counsel