Interpretation ID: aiam2916
Mack Trucks
Inc.
Engineering Division
P.O. Box 1761
Allentown
Pennsylvania 18105;
Dear Mr. Brown: I regret the delay in responding to your August 31, 1978, lette requesting an interpretation of S5.3 of Federal Motor Vehicle Safety Standard No. 120. In that letter, you stated that you had been contacted by an employee of this agency's enforcement office and advised that the certification labels for Mack trucks did not comply with the requirements of that section. The reason given for this conclusion was that the labels used the word 'on' between the tire and rim information instead of the comma shown in the example following S5.3.3.; S5.3 requires that the labeling information specified in S5.3.1 S5.3.3 must appear in the format shown in the truck example following S5.3.3. This requirements does not mean that certification labels must be identical to the example in every respect. Minor variations are permitted. By 'minor variations', I mean such things as a slight difference in punctuation mark that do not change or obscure the meaning of the label. Mack's substitution of 'on' for a comma is such a minor variation and, accordingly, is permissible under the standard.; The label enclosed with your letter shows spaces to provide informatio for the front, rear and tree intermediate axles. When this label is used on vehicles with fewer than five axles, you should stamp 'not applicable', or words of similar import, in the spaces provided for axles which do not exist on the particular vehicle which is being labelled.; Without this indication, the label could be confusing and so would fai to clearly provide the required information for that vehicle. And indication of nonapplicability would alert the reader to that fact.; Sincerely, Joseph J. Levin, Jr., Chief Counsel