nht76-4.9 | NHTSA

DATE: 09/02/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Paul Atkinson

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your June 18, 1976, letter concerning the application of Federal Motor Vehicle Safety Standard No. 117, Retreaded Pneumatic Tires, to passenger car tires that are retreaded from bead to bead.

I understand that in this process, the labeling information molded on the sidewalls of the tire to be retreaded is buffed off prior to the application of new rubber. You have requested our assurance that "it is permissible to do bead to bead retreading, removing the present labeling and remolding all the pertinent information on the tire."

The requirements for casings to be used in retreading are set out in S5.2.3 of Standard No. 117:

Each retreaded tire shall be manufactured with a casing that bears, permanently molded at the time of its original manufacture into or onto the tire sidewall, each of the following:

(a) The symbol DOT;

(b) The size of the tire; and

This section requires the above information to be present on the casin at the beginning of the retreading process, to ensure both that the carcass was originally manufactured to comply with Standard No. 109, New Pneumatic Tires -- Passenger Cars, and that the retreader has reliable information on which to base the labeling of the completed tire. The section does not, however, require that this originally molded information be retained on the completed tire.

Certification and labeling requirements for completed retreaded tires are set out in S6 of the standard. The DOT symbol required by S6.1, however, is not a "remolding" of the original DOT symbol (certifying compliance with Standard No. 109) that may have been buffed off. It is a new certification by the retreading party that his product complies with Standard No. 117. Further, this new DOT symbol must be followed by the letter "R", as indicated in 49 CFR @ 574.5, Tire Identification and Recordkeeping. "Remolding" of the original DOT symbol is neither required nor permitted. Finally, the information required by S6.3 to appear on the completed tire is permitted, but not required, to so appear through retention of the original labeling.

In conclusion, bead-to-bead retreading is not prohibited by Standard No. 117, provided that the casings satisfy S5.2.3 at the beginning of the retreading process, and all other requirements of the standard are met.

YOURS TRULY,

PAUL ATKINSON TIRE RETREADING CONSULTANT

June 18, 1976

Frank Berndt, acting chief council National Highway Traffic Safety Administration

I visited with Mr. Arturo Casanova and Mr. David Snyder on Tuesday, June 15. I brought some questions to them that they felt should be directed to you for a decision, and if necessary, a ruling.

I have a firm that I represent in Pennsylvania, that is planning to enter the passenger tire retreading field. They will be different in their operation in that they plan to retread tires from bead to bead. Both sidewalls will be buffed, and a thin venier of rubber applied. The sidewall mold plates will be engraved to contain all of the information required by your department.

I raised the question to Mssrs. Casanova and Snyder about any objections that your department might have to these plans. It was their feeling that their was no objection, other than the possible objection to the removal of the DOT certification, proving that the casing used was in fact a DOT casing.

As this process involves a very advanced cost in federal excise taxes, and advanced cost in processing, materials, and equipment, it will not be competitive with customary retreading. It will have to be sold at a very premium price.

Also, it has been eight years since the incorporation of the DOT symbol. Tires without this symbol have been for all practical purposes, have been used up, and are no longer on the casing market. I do not feel that any reputable dealer would accept a casing of this age, regardless of DOT rulings.

I am requesting a ruling from you that it is permissible to do bead to bead retreading, removing the present labeling and remolding all the pertiment information on the tire. This is with the understanding that all tires used for passenger use will be DOT casings. The DOT would be returned by molded labeling.

I would add for your consideration that this system is widely used throughout Europe. There is also a dealer in Minnesota who is advertising this type work in magazines. I am also informed that it is being done by at least one company in California.

I would appreciate your favorable ruling on this matter at your earliest convenience.

Paul Atkinson

Interpretation ID: nht76-4.9