Interpretation ID: aiam3438
Director of Quality Assurance
The Armstrong Rubber Company
500 Sargent Drive
New Haven
CT 06507;
Dear Mr. Cheetham: This responds to your recent request for an interpretation of th labeling requirements of Safety Standard No. 119 (49 CFR S571.119). Specifically you asked if the requirements of section S6.5(f), requiring the tire label to show the actual number of plies, and the composition of the ply cord material would be satisfied by the Marking:; >>>'Tread - 2 plies Polyester + 2 Aramid Woven Belts Sidewall - 2 plies Polyester.' <<< It has been a longstanding policy of this agency not to issue advanc approval of labeling information. However, we will state that marking appears to satisfy the requirements of section S6.5(f) if it is slightly modified. Specifically, the reference to 'belts' should be deleted, and the word 'plies' should be substituted.; The purpose of the marking requirements in Standard No. 119 is t ensure that the user of the tire is provided with technical information in a straightforward manner. This information is necessary for the safe use of the tire. Section S6.5(f) of the Standard requires that the marking include only the actual number of *plies* and the composition of the *ply* cord material. To satisfy this requirement, the information for the tread should appear as: 'Tread - 2 plies Polyester + 2 plies Woven Aramid.'; Your desire to represent the ply cords as belts probably represents marketing effort by Armstrong to convince purchasers to buy this particular tire. This agency has no reason to believe that these tires are not outstanding performance tires or to reduce your marketing efforts. However, it is inappropriate to extend this marketing effort to the Federally required markings on the sidewall of the tires.; Sincerely, Frank Berndt, Chief Counsel