Interpretation ID: aiam3282
Tire Division
Rubber Manufacturers Association
1901 Pennsylvania Avenue
N.W.
Washington
DC 20006;
Dear Mr. Cole: This is in response to your letter of April 14, 1980, regarding tw apparent discrepancies in the revised Uniform Tire Quality Grading tread label format, published on November 29, 1979, in Docket 25, Notice 35 (44 FR 58475). As you note, the word 'Vehicle' was omitted from the term 'Federal Motor Vehicle Safety Standard No. 109' under the heading 'Temperature' in Figure 2, Part II, of the regulation as published. This was an inadvertent omission which the National Highway Traffic Safety Administration (NHTSA) plans to correct in a future notice.; You also point out that paragraph (d)(1)(i)(B)(1) of the regulation (4 CFR 575.104(d)(1)(i)(B)(1)), applicable to tires manufactured prior to October 1, 1980, provides for use of the heading 'DOT QUALITY GRADES' in capital letters, while Part I of Figure 2 of the regulation contains the heading 'DOT Quality Grades' using lower case letters. The label format specified in paragraph (d)(1)(i)(B)(1) parallels the label format originally announced in Docket 25, Notice 24 (43 FR 30542, July 17, 1978), the heading of which used all capital letters. Since Part I of Figure 2 is not required on labels printed in accordance with paragraph (d)(1)(i)(B)(1), the use of lower case letters in the heading of Part I does not affect the requirements of paragraph (d)(1)(i)(B)(1). NHTSA will permit, at the manufacturer's option, the use of all capital letters in the heading of Figure 2, Part I, in printing labels to comply with the new two-part label format.; Sincerely, Frank Berndt, Chief Counsel