Interpretation ID: 77-3.34

TYPE: INTERPRETATION-NHTSA

DATE: 07/25/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Daido Kohyo Co. Ltd.

TITLE: FMVSR INTERPRETATION

TEXT: 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) examined 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 the 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 in accordance with requirements of 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,

DAIDO KOGYO CO. LTD.

April 30, 1977

ATT: THE DOCKET ROOM, NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

SUBJECT: Written Comment as for Rim Size Designation defined in (Docket No. 71-19: Notice 06: Docket No. 75-32: Notice 02) Part 572.

Reference is made to the above mentioned FMVSS as to Tire Selection and Rims for Motor Vehicle other than Passenger Cars.

The rim size designation is defined to mean the rim diameter and width, and this designation order, a diameter designation followed by a width designation, is to distinguish rim designation from tire designation. However, this order of designation is hardly agreeable for us to follow. And we have also a couple of questions to which we would like to obtain your prompt reply.

(1). ISO/TC31/SC10 has been holding meetings four times during the period from June, 1974 to February, 1977, and we, DAIDO, has been taking part in these meetings as representative from Japan and making every endeavor to ISO-rize motorcycle rims.

But it has been never down for discussion that a width designation followed by a diameter designation had better be changed to a diameter designation followed by a width designation. whereas the former designation has been conventionally used in Japan and European countries.

We write here in addition that Mr. Hollis, the representative from U.S.A., has never brought this matter forward at ISO meeting in the past.

(2). There is a danger that the one effort change of conventional rim size designation will create many troubles and confusion, which must be, we feel, more serious as compared with the confusion with tire designation.

For instance, a rim designated as 1.6 x 13 by conventional designation should be changed to 18 x 1.6 in accordance with FMVSS. At this, most of people who have been familiar with conventional designation may regard this rim as 18" width and 16" diameter unintentionally.

We would like to point out the fact that catalogues or brochures of most motorcycle distributors and dealers in U.S.A. list rim size designation as (width) x (diameter). This means that most people concerned in motorcycle trade are already familiar with the said rim designation.

(3). We understand that tire designation is (width) - (diameter) and conventional rim designation is (width) x (diameter). Here is, we can see, distinctive difference of designation, which is "-" and "x" located between width designation and diameter designation.

Even though the order of width designation and diameter designation is same between tire and rim, we feel confident that if you appeal further to a large public such rim designation will not create any troubles and confusion as ever.

(4). S5.2 "Rim marking" requires that each rim or wheel disc in case of singlepiece wheel be marked with informations listed in paragraph (a) through (e). Our question is whether these informations should be marked correspondingly to the order of (a) through (e), or random arrangement of each paragraph is acceptable.

(5). We understand that there is no restriction in marking any other informations than the requirements of FMVSS specified in S5.2. We, Japanese manufacturer, must put JIS marking in accordance with the requirement of Japanese Industrial Standard if the product is approved and authorized by JIS Authority, while it is requested to put "J" mark by order of FMVSS. This means that we are under an obligation to mark both "J" and "JIS".

We have been preparing for the enforcement date of FMVSS based on our own understanding to rim marking requirement, until the receipt of revised NHTSA notice which was issued on January 23, 1977.

We are now facing serious troubles and worrying about if our motorcycle rims can meet with the requirements of FMVSS and with the effective date, August 1st, 1977.

We would appreciate receiving your prompt comments and reply in the above mentioned regards.

Thank you very much and we remain.

(p.s.: We will write to Mr. Malinverni, chairman of ISO/TC31/SC10, to ask his opinions and the future course of ISO. After this we will possibly submit our comments again to you.)

Takeo Shimoguchi General Manager