Interpretation ID: nht95-2.8

TYPE: INTERPRETATION-NHTSA

DATE: March 21, 1995

FROM: Stephen M. Padula -- Industry Standards & Government Regulations, Uniroyal Goodrich

TO: Walter K. Myers -- NHTSA, Office of the Chief Counsel

TITLE: NONE

ATTACHMT: ATTACHED TO 5/17/95 LETTER FROM JOHN WOMACK TO STEPHEN M. PADULA (A43; PART 575; REDBOOK 2)

TEXT: Dear Mr. Myers:

As discussed in our conversation of March 20, I would like to know if a UTQGS Treadwear grade of 00 or 000 is permissible. My contention is that it would be because of the following argument.

According to 49 CFR @ 575.104(d)(2)(i), "Each tire shall be graded for treadwear performance with the word "TREADWEAR" followed by a number of two or three digits representing the tire's grade for treadwear, expressed as a percentage of the NHTSA nominal treadwear value . . .". Further, @ 575.104(e)(2)(ix)(F) requires the computation of "the percentage (P) of the NHTSA nominal treadwear value . . . using the following formula":

P = Projected mileage / 30,000 X 100

The computed value of P is then rounded to the nearest lower 20-point increment (after September 1, 1993).

Using a hypothetical example of a tire with projected mileage of 5,000 miles would result in the following value for P:

P = 5,000 / 30,000 X 100 = 16.67

Rounding the above number to the nearest lower 20 point increment would result in a grade of 0. Since 2 or 3 digits are required the grade would become 00 or 000.

I would appreciate your response as soon as possible.