Interpretation ID: Hopkins.1

Mr. Bruce A. Hopkins
Vice President, Standards and Education
Recreation Vehicle Industry Association (RVIA)
1896 Preston White Drive
P.O. Box 2999
Reston, VA 20195-0999

Dear Mr. Hopkins:

This is in response to your letter of October 21, 2003, in which you requested clarification of several issues under Federal Motor Vehicle Safety Standard (FMVSS) No. 110, Tire Selection and Rims, as amended by a final rule published on November 18, 2002, (67 FR 69600). Your questions involved actions that your final stage manufacturer members must take to meet the requirements of the regulation, once the revisions become effective on September 1, 2004. [1] Specifically, you asked about the content and placement of vehicle placards, listing of information related to spare tires, and reporting of seating capacity.

As you are aware, the National Highway Traffic Safety Administration (NHTSA) is in the process of responding to petitions for reconsideration of the November 18, 2002, final rule, and we expect to issue our response shortly. We note that RVIA itself submitted a petition to the agency on this rulemaking. Our review suggests that the issues raised in your most recent letter are already before the agency in the context of the petitions for reconsideration, and we believe that the response will clarify these matters and will allow manufacturers sufficient time to assure compliance with applicable requirements.

Should you have any remaining or additional questions once the response to the petitions for reconsideration is published, please feel free to submit them to the agency. If you have further questions in the interim, you may contact Mr. George Feygin of my staff at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:110
d.1/21/04