Interpretation ID: 19753.wkm

Mr. Anthony DeFilippo
Goodyear Tire & Rubber Company
Attn: DOT LAB
#1 Goodyear Boulevard
Lawton, OK 73505

Dear Mr. DeFilippo:

This responds to your inquiry, telefaxed to this office on March 18, 1999, seeking our approval for your proposed modification of the bead unseating fixture currently depicted in Figure 1, Bead Unseating Fixture, of Federal Motor Vehicle Safety Standard (Standard) No. 109, New pneumatic tires.

You would like to modify the test fixture so that you would have more flexibility to test tires of very different sizes. You state that you produce very large tires for vehicles such as the Plymouth Prowler and the Chevrolet Corvette, among others, and that you also produce small tires. You want to modify the fixture shown in Standard No. 109 to attach the shoe and mounting plate directly to the hydraulic cylinder, as depicted in your enclosed drawing, to allow easier loading and unloading of tires, as well as to make the process more ergonomically correct, by permitting use of a motorized hoist.

You do not need our approval to modify the test fixture. The test procedures specified in the Federal motor vehicle safety standards (FMVSS) are the procedures on which the performance requirements of the FMVSSs are based and which this agency uses in its testing of motor vehicles and equipment for compliance with the FMVSSs. The FMVSSs, including Standard No. 109, do not specify the testing that manufacturers must do. The standards specify the performance levels that motor vehicles and equipment must meet when tested in accordance with the procedures set forth in the standard.

NHTSA does not specify test procedures applicable to manufacturers, and does not give approvals to manufacturers' test procedures. As stated above, manufacturers are required to certify that their products comply with all applicable FMVSSs. While the surest way to assure compliance would be to test tires in accordance with the test procedures specified in Standard No. 109, you are not legally obligated to do so.

Please note that we are not in a position to comment on ISO requirements. You should contact ISO representatives for information about that organization's test requirements.

I hope this information is helpful to you. If you have any questions or need additional information, feel free to call Walter Myers of my staff at this address or by telephone at (202) 366-2992, or by fax at (202) 366-3820.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:109
d.6/10/99