Interpretation ID: aiam2882
Manager - Tire Technical Relations
Dunlop Tire Company
P. O. Box 1109
Buffalo
New York 14240;
Dear Mr. Attenhofer: This responds to your July 10, 1978, letter asking whether it i permissible to label motorcycle tires with alternate speeds and load ratings appropriate for those speeds. You suggest that your tires be labeled with maximum speeds of 131, 137, and 143 miles per hour with the corresponding load ratings. The labeling of motor cycle (sic) tires is regulated by Standard No. 119, *New Pneumatic Tires for Vehicle Other Than Passenger Cars.*; Standard No. 119 requires that tires be marked with, among othe things, the maximum inflation pressure of the tire and the load rating applicable to that inflation pressure. Speed qualifications are permitted on tires when, for example, the tires are speed restricted. Otherwise, tires are not marked with speed criteria although they may be marked with the symbols S, H, or V as part of the tire identification number. These symbols, established by the European Tyre and Rim Technical Organization (ETRTO), indicate that the tire is an acceptable high-speed tire.; The National Highway Traffic Safety Administration considers i appropriate to permit the symbols S, H, or V to be marked on tires to indicate that such tires are appropriate for high-speed use. This permits, for example, a sophisticated purchaser of tires for emergency vehicles to know that the tires are suitable for the higher operational speeds necessary for those vehicles. The NHTSA, however, considers it inappropriate to mark motorcycle tires with maximum speeds of 131, 137, and 143 miles per hour with the corresponding safe load ratings. Such markings would appear to sanction the use of he tires at these speeds which far exceed the national speed limit.; Since Standard No. 119 regulates the permissible uses of spee designations on nonpassenger car tires, the agency interprets the standard to prohibit the marking of any other speed designations on a tire. The NHTSA considers the only appropriate speed designation on tires to be one that reflects a speed restricted tire or one that uses the symbols established by the ETRTO for tires that have been tested and can be operated at higher speeds.; Sincerely, Joseph J. Levin, Jr., Chief Counsel