Interpretation ID: aiam2631
General Manager
Daido Kogyo Co.
Ltd.
1-197 Kumasaka-cho
Kaga
Ishikawa-pref.
Japan;
Dear Mr. Shimoguchi: This responds to your April 30, 1977, comments concerning Standard No 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*. Your comments question the advisability of requiring the rim size designation to be stated in the order of diameter by width. This designation would be the reverse of existing Japanese and European practices.; The National Highway Traffic Safety Administration (NHTSA) examine this issue in its response to petitions for reconsideration of Standard No. 120 (42 FR 7140). The agency determined that the rim size designation should be expressed on the label in the manner proposed in the standard (diameter by width) to avoid confusion with the tire size designation which is measured in terms of width by diameter. Since publication of our response to petitions for reconsideration (which included your petition), we have received no information presenting new reasons to alter the chosen format. Therefore, the NHTSA will continue to implement the standard as published in the February 7 Notice.; In a second question, you ask whether the NHTSA requires that th information specified in S5.2 of the standard be listed in any particular order. Although the agency has not specified the order in which the information required in S5.2 should be listed, the NHTSA expects that for purposes of clarity the information in paragraphs (a), (b), and (c) would be grouped together as would the information in paragraphs (d) and (e).; Finally, you note that the symbol 'JIS' must be marked on the rim i accordance with requirements od the Japanese Industrial Standard while NHTSA requires only the letter 'J.' For purposes of uniformity the agency will continue to require the letter 'J' even though this may result in the double marking situation to which you refer.; I trust that this responds fully to your comments. Sincerely, Joseph J. Levin, Jr., Chief Counsel