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Interpretation ID: nht73-5.45

DATE: 11/09/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: R. H. Schroeter

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 24, 1973, in which you ask the following questions:

1. Is it true that Standard Nos. 109 and 110 are not applicable to a 1/2-ton pickup truck with camper because such vehicle is not a "passenger car" as defined in Standards 109 and 110?

2. Is it true that in Appendix A of Standard 110 no "alternative rims" are listed for the L70-15 tire simply because no one has requested (in the manner provided in Appendix A to Standard 110) inclusion of such additional or alternative rim widths.

With respect to question 1, a pickup truck is not a passenger car but a "truck" (as defined in 49 CFR S 671.3) for purposes of all the Federal motor vehicle safety standards, including Standard Nos. 109 and 110. Standard No. 109 applies to tires for passenger cars. Standard No. 110 (49 CFR S 571.110) applies only to passenger cars, not to pickup trucks.

In response to your second question, the answer is not an unequivocal "yes", and I regret that you may have drawn that conclusion from your conversations with Michael Peskos of this office. In order for alternative rims to be listed with a tire size designation in the Appendix of Standard No. 110, data showing that the tire and rim combination meets the requirements of both

Standard No. 109 and 110 must first be submitted to the agency. Once that data has been provided, the NHTSA will publish the alternative rim size in Standard No. 110, and if no objections are received within a 30-day period, the tire/rim combination becomes part of the standard. Thus, there are not one but two possible reasons why a rim size is not listed in Standard No. 110:

The tire/rim combination fails to meet either Standard No. 109 or 110; or

It does meet both standards, but no one has requested approval of the combination. This could occur simply if the combination was not intended to be used as original equipment on a passenger car.