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Interpretation ID: aiam2777

Mr. Philip P. Friedlander, Jr., Executive Vice President, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, D.C. 20005; Mr. Philip P. Friedlander
Jr.
Executive Vice President
National Tire Dealers & Retreaders Association
Inc.
1343 L Street
N.W.
Washington
D.C. 20005;

Dear Mr. Friedlander: This responds to your February 23, 1978, letter asking whether a tub can be installed in a tubeless tire without any adverse effects upon safe operation of that tire. In our January 6, 1978, letter to Mr. Philip Taft of your Association, the National Highway Traffic Safety Administration (NHTSA) indicated that a retreader could not change a tire originally labeled 'tubeless' to a tire labeled 'tube type,' because such an alteration would violate the labeling requirements of Standard No. 117, '*Retreaded Pneumatic Tires - Passenger Cars.*' The NHTSA did not state, as you indicate in your letter, that tubes could not be installed in retreaded tubeless tires.; You ask whether the use if tubes in tubeless tires creates any safet problems. The agency is unaware of safety problems resulting from the use of tubes in tubeless tires. The NHTSA has determined, however, that tubes should not be placed in damaged tubeless tires in lieu of permanent repairs to those tires. This determination applies to those instances where tubes were used in tubeless tires after failure of the tire. In such cases, the tire casing could have been fractured or some other damage to the tire could have been sustained that would cause excessive wear of a tube inserted in the tire. Excessive wear of a tube could cause further tire failure. Therefore, tubes should not be inserted as a permanent repair of a damaged tubeless tire. Nothing in this finding, however, is intended to indicate that tubes in undamaged tubeless tires create safety problems. At this time the agency has no data to support your theory that the use of tubes in undamaged tubeless tires poses a safety problem.; Sincerely, Joan Claybrook