Interpretation ID: nht72-3.4

DATE: 02/16/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Alabama Tire Dealers and Retreaders Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your three letters, dated December 1, 1971, December 27, 1971, and January 11, 1972, concerning Motor Vehicle Safety Standard No. 117.

In your letter of December 1, 1971, you enclose a booklet that you have recently made available which contains your interpretation of Standard No. 117, and ask us to review it. As your letter was written before the amendment of December 23, 1971 (36 F.R. 24814), and the suit in Chicago, it does not, and our reply will not, deal with the changes made by that amendment or the "stay" ordered by the Court of Appeals. We believe your summary of the standard is correct, but we would recommend that you include in the requirements of paragraph S5.1.1 of Standard No. 117 the treadwear indicator requirements found in S4.2.1(d) of Standard No. 109. This fact is apparently being overlooked by some retreaders, and you may wish to point it out more clearly.

Your letter of December 27 asks whether exposure of cord that has occurred on casings because of "chipping" would prevent the casing from being retreaded under S5.2.1. As presently written, S5.2.1 would preclude the retreading of such a casing if what is exposed is ply cord. However, if it is actually "chafer" fabric, which is a special fabric placed only around the bead, then exposure is permitted.

Finally, with regard to your letter of January 11, I regret that, as you have been told, Mike will not be able to attend the Missalaga Conference. He has told me that your organization has done a very responsible job with regard to not only Standard No. 117 but other areas of tire safety as well, and we appreciate your efforts.