Interpretation ID: nht78-2.42

DATE: 01/06/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: National Tire Dealers & Retreaders Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 27, 1977, letter asking whether a tire retreader is permitted to change the designation of a tire from "tubeless" to "tubetype".

Standard No. 117, Retreaded Pneumatic Tires, requires that the information appearing on the tire sidewall be the same as that which appeared on the tire as originally manufactured. This is indicated by the language in paragraph S6.3. If a retreader changed the tire designation from "tubeless" to "tubetype", he would be altering the information that was associated with the original tire. Thus, a retreader is not permitted to change the tire designation in the manner you describe.

SINCERELY,

TIRE RETREADING INSTITUTE

October 27, 1977

John Diehl Department of Transportation Tire Identification and Record Keeping

Dear John:

By this letter we seek a clarification on the subject of using tubes in tubeless tires.

It is our understanding that some new tires manufactured as tubeless are labeled as being tubetype. We understand that the word "tubeless" on the tire sidewall is removed and the word "tubetype" is substituted. Further, we understand that no safety related aspect is involved in making the substitution.

(Accordingly, we seek your concurrence that a tire labeled "tubeless" being processed as a retread, may be labeled "tubetype" at the option of the retreader). We recognize that such an option cannot be exercised if safety considerations dictate otherwise. For example, a tube cannot be used in a retread in lieu of making a needed repair. Yes.

Your early confirmation that retreaders be afforded the same option of re-labeling as is available to new tire manufacturers is sought.

Philip H. Taft Director

November 2, 1977

Philip H. Tafts Director Tire Retreading Institute

Dear Mr. Taft:

Your October 27, 1977 to Mr. John Dill has been referred to this office for reply.

The tire manufacturer is the one who determines whether a tire is a tubeless or tube type tire.

The retreader does not have the option to re-label the tire cord body inorder to retread the tire, and sell it as a tube type tire, because the original tire manufacturer has followed the labeling requirements of (Illegible words) of FMVSS std. 109.

There are no safety related aspects associated with the reclassification of a tubeless tire to tube type, because inner tubes were used in tires that had a special gum insert on the first or band ply before tubeless tire were in successful production.

The above (Illegible Word) a recent article stating that the placement of a tube in a tubeless tire will cause the assembly to run hot and possibly lead to failure.

Also to aid in the understanding of reclassified tires from tubeless to tube type is the fact that the tube type tire is (Illegible Word) completely through the side wall to allow any entrappes air to escape when the tire contains an inner tube in a tubeless tire.

We hope we have clarified your position on tubeless and tube type tires he re-classified by the retrader.

Drill no control

Legal Concurrence!

(Illegible Word)