ID: nht69-1.27

DATE: 06/06/69

FROM: AUTHOR UNAVAILABLE; H. M. Jacklin, Jr.; NHTSA

TO: Rubber Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of May 14, 1969, to the National Highway Safety Bureau requesting the addition of the 6JJ alternative rim size for the E78-14 tire size designation to Table I of Appendix A of Federal Motor Vehicle Safety Standard No. 110.

On the basis of the data submitted indicating compliance with the requirements of Federal Motor Vehicle Safety Standards No. 109 and No. 110 and other information submitted in accordance with the procedural guidelines set forth in the Federal Register, Volume 33, No. 195, page 14964, dated October 5, 1968, the 6JJ alternative rim size for the E78-14 tire size designation will be listed within Table I of Appendix A of Standard No. 110. This change will be published in the Federal Register in the near future.

The addition of new alternative rim size designations to the table is accomplished through an abbreviated procedure consisting of the publication in the Federal Register of petitioned alternative rim size. If no comments are received, the amendment becomes effective 30 days from the date of publication. If comments objecting to amendments are received, additional rule making pursuant to Part 216 of the Procedural Rules for Motor Vehicle Safety Standards will be considered.

ID: nht69-1.28

DATE: 02/03/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Toyota Motor Company, Ltd

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 4, 1968, to Mr. Eugene Laskin regarding Motor Vehicle Safety Standard No. 111 on rearview mirrors.

Your interpretation and enclosed figure 1 are not entirely correct. The 35 foot distance is measured horizontally, not at an angle. The plane must be tangent to the vehicle -- not tangent to the mirror. The measurement is made at the road surface 35 feet to the rear of the projected eye position and 8 feet outward from this plane.

ID: nht69-1.29

DATE: 03/14/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: The Society of Motor Manufacturers and Traders Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 9, 1969, to the Federal Highway Administrator concerning your 1963 Edition of the S.M.M.T. Tyre and Wheel Engineering Manual.

Federal Motor Vehicle Safety Standard No. 109, within Section S3, lists the "Tyre and Wheel Engineering Data Book dated 1965/1966 of the Society of Motor Manufacturers and Traders Limited (S.M.M.T.)" as one of the references containing acceptable test rims. When Standards No. 109 and No. 110 were developed, the National Highway Safety Bureau accepted the S.M.M.T. 1965/1966 Data Book tire and rim combinations based on established usage. We did not, nor do we at present intend to accept general updating of these referenced publications, either foreign or domestic, as valid reasons for answering Standard No. 109 and No. 110. Consequently, any new tire size designations or alternative rim sizes that you wish to list within Standards No. 109 or No. 110 will have to comply, on an individual basis, with the abbreviated guidelines as outlined in the October 5, 1968 Federal Register.

ID: nht69-1.3

DATE: 06/02/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Hon. Jacob K. Javita -- U.S. Senate

COPYEE: Mr. Delve; Mr. O'Mahoney

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your transmittal memorandum and attached letter from Mr. Robert W. Muller, New York, New York, inquiring about consumer information on passenger car tires.

The Department of Transportation does not presently have a publication which would guide the consumer in selecting tires most suitable to his needs.

To provide the consumer with an indication of the performance characteristics of tires, the Federal Highway Administration is obtaining research data and has established Docket 25, Uniform Tire Quality Grading System - Passenger Cars. A copy of the notice from the Federal Register is enclosed.

As soon as a meaningful system of tire quality grading can be developed to assist the public, it will be made available.

Enclosure

ID: nht69-1.30

DATE: 03/17/69

FROM: AUTHOR UNAVAILABLE; H. M. Jacklin, Jr.; NHTSA

TO: Rubber Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This letter reaffirms the position of the National Highway Safety Bureau with respect to the handling of petitions for the addition of now tires as stated in recent telephone discussions with members of the Office of Standards on Accident Avoidance.

It was related during these discussions that further action on the petition of November 13, 1968, requesting the addition of the C78-13 tire size designation to Table I-J of the Appendix A of Standard No. 109 cannot be taken until the information indicating compliance with Federal Motor Vehicle Safety Standard No. 110 is received covering the desired test rim width. The Standards are directed at total motor vehicle safety; accordingly, they are just as applicable to replacement tires as to tires intended for new motor vehicles and the guidelines for the addition of new tire size designations and new alternative rims to Standards No. 109 and No. 110 as published in the Federal Register of October 5, 1968, therefore apply.

The question of a precedence having been established by the addition of the 5'JJ alternative rim to Table I of the Appendix to Standard No. 110, without supporting date, in the case of the C70-15 tire size designation has been raised by your organization. Our records indicate that your request for the addition of this tire size was based on the petition of August 19, 1968. This action was well in advance of the procedural guidelines established on October 5, 1968. Although this test rim was added to Table I of the Appendix A of Standard No. 110, without text data, the National Highway Safety Bureau believes that a safety hazard could exist if this tire and rim combination is not compatible. We would, therefore, appreciate test information certifying compliance with the requirements of Standard No. 110 by the 5'3JJ rim and the C70-15 tire size combination.

Our records indicate that you have submitted petitions dated July 11 and August 25, 1968, requesting the addition of twelve additional alternative rim sizes to Table I of Appendix A of Standard No. 110. To date, data indicating compliance with Standards No. 109 and No. 110 has not been received and we have advised you in several telephone discussions that no action is contemplated until data is submitted.

In conclusion, we would like to reiterate that all future petitions for additions to Standards No. 109 or No. 110 must be submitted in accordance with the guidelines published in the Federal Register on October 5, 1968. The Bureau makes no provisions or exceptions based on the ultimate use of the tires. All new tires will be considered within the framework of these guidelines.

ID: nht69-1.31

DATE: 01/27/69

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Nottingham & Pinto

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of December 26, 1968, and as a follow-up of our meeting of January 9, both concerning your proposal to hot brand the legend "SECOND NOT ADJ." Over part of the brand name "ATLAS FLYORON" tires.

Provided the branding of the legend does not make the brand name illegible it would be permissible under the motor vehicle safety standards. Examination of the photos you submitted indicates that no part of the brand name is obliterated and only one letter is affected, although still clearly visible. Therefore, as long as one of the methods of branding shown in the photos is followed, the labeling requirements of standard No. 109 with regard to the brand name will have been met.

ID: nht69-1.32

DATE: 04/04/69

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Carlisle Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Your December 27, 1968, request for a code number in accordance with Subsection S4.3 of the Federal Motor Vehicle Safety Standard No. 109 and the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1421 (1)) has been reviewed. Subsection S4.3 of the Federal Motor Vehicle Safety Standard No. 109 applies to passenger car tires; accordingly, the National Highway Safety Bureau has restricted the issuance of code numbers to manufacturers of those tires.

Since Carlisle Tire and Rubber Division does not engage in the manufacture of passanger car tires, and since the code number was requested in anticipation of future tire rule making, the issuance of a code number to the Carlisle Tire and Rubber Division would be premature and not in keeping with the intent of the regulation.

We have enclosed a Mailing List Questionnaire as promised. To assure a flow of specialized mailings which may be of great importance to your particular organization, please complete both sides with the correct information and return it to the Federal Highway Administration, National Highway Safety Bureau, Motor Vehicle Safety Performance Service, Washington, D. C. 20591, Attention: MVSPS List Questionnaire. If you require more than one form or have any inquiries concerning the form, please direct your correspondence to the same address.

ID: nht69-1.33

DATE: 07/14/69

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Interamerican Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 27 in which you request information necessary to obtain a D.O.T. number and import "Pneumant" tires. The information furnished below concerns only those requirements of the Department of Transportation.

Regulations promulgated pursuant to Section 110(e) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. @ 1391 et seq., 1399(e)) require any manufacturer, assembler, or importer of a motor vehicle before offering a motor vehicle or item of motor vehicle equipment for importation into the United States to designate a permanent resident of the United States as his agent upon whom service of all processes, notices, orders, decisions, and requirements, may be made.

The manufacturer of "Pneumant" tires is therefore required to designate an agent is prescribed in the regulations (49 C.F.R. @ 351.45) and I enclose a copy of them, as well as a copy of the National Traffic and Motor Vehicle Safety Act, for your information.

Please note that these regulations require the designation to be made in a specific manner. The designation should contain the following:

(1) a certification by the signer of the designation that it is binding on the manufacturer of "Pneumant" tires under the laws, corporate by-laws, or other requirements governing the making of the designation by the manufacturer of "Pneumant" tires at the place and time where it is made;

(2) the full legal name, principal place of business, and mailing address of the manufacturer of "Pneumant" tires;

(3) trade names, or other designations of origin of the products of the manufacturer of "Pneumant" tires which do not bear its legal name;

(4) a provision that the designation remains in effect until withdrawn or replaced by the manufacturer of "Pneumant" tires;

(5) a declaration of acceptance duly signed by the designated agent; and,

(6) the full legal name and mailing address of the designated agent.

In addition, the designation should be signed by one with authority to appoint the agent for the manufacturer of "Pneumant" tires, and this authority should be so indicated.

In your letter you state that it is your understanding that "all tires used in this Country are subject to approval which will be given in form of a D.O.T. number." This is incorrect. There is no provision in the National Traffic and Motor Vehicle Safety Act which provides that motor vehicles and motor vehicle equipment are to be approved by the United States Government. On the contrary, under this Act the manufacturer of the motor vehicle or item of motor vehicle equipment bears the responsibility for complying with Federal Motor Vehicle Safety Standards promulgated pursuant to the Act; and, pursuant to Section 114 of the Act for certifying that his product so complies. In the case of tires, the applicable standard is Standard No. 109 and I enclose a copy of it with applicable amendments for your reference. Standard No. 109 contains requirements for new pneumatic tires for passenger cars, and in order to meet the requirements of the Act, "Pneumant" tires must comply with Standard No. 109. Furthermore, the manufacturer of these tires must certify in the prescribed manner that such tires so comply.

The "D.O.T. number" to which you refer is required by Section 201 of the Act and the labelling section (S.4.3 and "Figure 1") of Standard No. 109. As specified in the standard, the letters "D.O.T.", when permanently molded into or onto the tire so that the tire is conspicuously labelled on both sidewalls, indicate pursuant to S.4.3(1) and Figure 1 of Standard No. 109, that the tire has been manufactured to conform to applicable Federal Motor Vehicle Safety Standards. This satisfies the certification requirement referred to above.

The code mark number is included as part of the label (as illustrated in Figure 1) pursuant to Section 201 of the Act, when the tire contains a brand name other than the name of the manufacturer, and is included for the purpose of permitting the seller of the tire to identify the manufacturer to the purchaser upon his request.

A code mark number can be obtained from the Department of Transportation by any tire manufacturer on request, but is only necessary when a name other than the manufacturer's is used on the tire. Such a request should be directed to Secretary of Transportation; Attention: Motor Vehicle Safety Performance Service, National Highway Safety Bureau, Federal Highway Administration, U. S. Department of Transportation, Washington, D.C. 20591. Issuance of the code mark number by the government that tires manufactured by the one to whom it is issued meet Federal requirements. As indicated above, the code mark number is to be used purely for labelling purposes.

I am also enclosing a copy of Federal Highway Administration Import Regulations, (19 C.F.R. @ 12.80) which are promulgated jointly with the Treasury Department pursuant to Section 108(b)(3) of the Act for your information.

Should you have further questions, please feel free to contact me.

ID: nht69-1.34

DATE: 03/12/69

FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA

TO: Hector J. Rosso, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 14, 1969, in which you seek information concerning possible overloading of Seiberling 8.25-20 ten ply rating truck tires manufactured in approximately 1963.

The Federal Highway Administration has issued a Federal motor vehicle safety standard for passenger car tires manufactured after January 1, 1968 requiring them to meet certain tests when loaded to prescribed weights. (49 C.F.R. @ 371.21 Standard 109). Performance requirements for truck tires are presently under consideration. Comments have been received in response to an Advance Notice of Proposed Rule Making on this matter but regulations have not as yet been issued.

The Bureau of Motor Carrier Safety regulates the safety and operation of interstate motor carriers. Its regulation regarding tires (49 C.F.R. @ 393.75) is not relevant to your inquiry.

One fruitful source of information may be the Tire and Rim Association Yearbook. This publication provides data on tires and suggests standards for tire load limits. It is published by the Tire and Rim Association, Inc., Comend Building, 34 H. Hawkins Avenue, Akron, Ohio 44313.

I hope this information will be of value to you.

ID: nht69-1.35

DATE: 04/01/69

FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA

TO: European Tire and Rim Technical Organization

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 21, 1969, requesting the "actual state of affairs" concerning States requiring a V-1 marking on tires.

You are correct in your understanding that the Federal tire standard (No. 109 preempts or supersedes any State regulation applicable to the same aspect of performance. The Federal tire standard does not require tires to be marked with the "V-1" symbol. However, it does not prohibit such marking. Our understanding is that American tire manufacturers have continued marking their product with "V-1" symbol although not required to do so by the Federal standard.