Interpretation ID: aiam3346
Vice President
Engineering Department
Bridgestone Tire Company of America
Inc.
2160 West 190th Street
P. O. Box 2964
Torrance
California 90509;
Dear Mr. Hamaya: This responds to your July 17, 1980 letter to this office in which yo posed six questions concerning Safety Standard 119 (49 CFR s571.119). The answers are set forth below following the number you assigned to each question in your letter.; (1) No, T&RA design information is not considered apart of the T&R yearbook for purposes of Standard 119, Design information refers to future tire sizes which will soon be produced, but which are not currently on the market. Since the specifications in the design information have not been formally approved by T&RA, as the yearbook entries have, the design information has not been subjected to the same type of examination by T&RA, and is not accepted by this agency.; (2) The Plunger Energy Table (Table II in Standard 119) Publishe November 13, 1973 is the most current table we have published.; (3)The ETRTO petition to which you refer has not been granted by thi agency. Shortly after receipt of the petition, we made a telephone contact with ETRTO requesting further information which would justify setting the plunger energy specifications at the requested levels. ETRTO was informed that the petition would not be considered until we had received this additional information, and no further information has been received. Similarly, you company has requested the inclusion of additional values for Table II i a letter dated August 9, 1979. Mr. Finkelstein, our Associate Administrator for Rulemaking, sent a letter to Mr. P. L. Lab of Bridgestone on September 12, 1979 requesting further information and justification for including these values. To date, no further information has been received.; (4) Since there is no plunger energy value specified for tubeless tire with a load range greater than 'J' in Table II, there are currently no requirements for plunger energy strength that these tires must meet. It is acceptable if you choose to test these tires at the strength level specified for load rang 'J' ties, but that level is significantly below what would be expected for higher load range tires.; (5) When you company submits matching information to this agenc pursuant to the requirements of S5.1(a) of Standard 119, it is perfectly acceptable to send duplicate copies of the information you have furnished to the dealers, and no separate letter is necessary.; (6) I am aware of only three requests for plunger energy tests fo tubeless tires with load ranges greater than 'J'. The first came from Michelin in 1973, when the Standard wa being development. NHTSA asked Michelin to provide information o the proposed values, and Michelin never raised the issue again. ETRTO submitted the petition your referred to in question 3, and never provided the further information requested. Bridgestone submitted a petition in August 1979 and never provided the further information requested. There have been no other requests for additional plunger energy values.; If you have any further questions concerning this matter please fee free to contact Mr. Steve Kratzke of my staff at (202)426- 2992.; Sincerely, Frank Berndt, Chief Counsel