Interpretation ID: nht73-3.16

DATE: 01/24/73

FROM: AUTHOR UNAVAILABLE; David Schmeltzer; NHTSA

TO: The Cooper Tire Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 10, 1973, which requests an advisory opinion as to whether, under the Tire Identification and Record Keeping regulation (49 CFR Part 574) it is permissible for a tire manufacturer to use a serial tin which would mold onto the tire mold surface four numbers indicating the day of the week, the numerical week and the last digit of the year. The tin would be placed immediately after the third grouping of the tire identification number which is used as a descriptive code to identify significant characteristics of the tire and to identify the brand name owner if the tire is manufactured for a brand name owner.

The regulation was written with the possibility in mind that some manufacturers might want to identify their production by day as well as by week and year. Therefore, the regulation provided that the third grouping, which is optional, could contain as many as four spaces so that one of the spaces could identify the day of the week.

The method you propose using appears to include the day of the week in the fourth grouping of the tire identification, not the third grouping as was contemplated. However, the practicability of your suggestion is recognized and while the regulation speaks in terms of groupings, as you point out there are no overall dimensional limits and no specified spacing requirements between the third and fourth groupings. Therefore, there would be no prohibition

against your using an insertable serial tin system which would make up the last four symbols of the tire identification number and which would identify the day of the week, the week of the year and the year.