Interpretation ID: nht75-2.12

DATE: 09/11/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Armstrong Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of May 30, 1975, concerning the standards applicable to a tire which you manufacture and sell with the designation L78-15LT, Load Range C.

You are mistaken in your assumption that a station wagon is classified as a multi-purpose passenger vehicle. Because it is constructed neither on a truck chassis nor with special features for occasional off-road operation, a station wagon is a passenger car rather than a multi-purpose passenger vehicle.

If, despite this misunderstanding, the L78-15LT tire in question is designated by you as primarily intended for use on lightweight trucks or multi-purpose passenger vehicles, then it is a light truck tire subject to Federal Motor Vehicle Safety Standard No. 119, New Pneumatic Tires for Vehicles Other than Passenger Cars.

Because a station wagon is a passenger car, Standard No. 110 requires that its original equipment tires comply with Standard No. 109. Standard No. 110 is not applicable to used cars, so there is no prohibition on the use of the L78-15LT tire as replacement equipment on a station wagon. However, because the informational placard on a station wagon would suggest to its owner the use of inflation pressures which are dangerously inadequate for light truck tires, we do not wish to encourage the sale of such tires as replacement equipment for use on station wagons.

Sincerely,

ATTACH.

ARMSTRONG RUBBER COMPANY

May 30, 1975

National Highway Traffic Safety Administration U. S. Department of Transportation

Attention: Chief Counsel

Dear Sir:

We are manufacturing and selling in the replacement market only a truck tire described as a

L78-15 Light Truck 6-ply rated tire. This will be designated as a L78-15LT, C load range.

We have been informed by one of our large distributors that they intend to sell this tire as a replacement tire for use on station wagons. The rims used on station wagons are listed by The Tire and Rim Association as a rim size for this tire.

As we interpret the definition of a "Light Truck Tire" under Standard 119, this tire may be used on station wagons if qualified and labeled under MVSS 119 and need not be qualified or carry the labeling required under MVSS 109. We assume a station wagon to be a multi-purpose passenger vehicle.

We understand that our interpretation would not apply if the tire were supplied as original equipment.

We would appreciate your opinion in this matter.

Sincerely,

R. L. Donnelly -- SECRETARY