Interpretation ID: 9556
Manager, Testing Services
Standards Testing Laboratories, Inc.
Post Office Box 592
1845 Harsh Avenue, S.E.
Massillon, OH 44648
Dear Mr. Freund:
This responds to your letter addressed to the attention of Walter Myers of my staff in which you asked whether Table II of Federal Motor Vehicle Safety Standard (FMVSS) No. 119, New pneumatic tires for vehicles other than passenger cars, contains certain errors.
You pointed out in your letter that Table I of FMVSS 119 specifies a plunger diameter of 5/16 inch for motorcycles, and 3/4 inch for 12-inch or smaller rims other than motorcycles. Table II, on the other hand, leaves blank the plunger diameter space in the motorcycle column, but lists 5/16 inch plunger diameter in the 12-inch or smaller rim column. You indicated your belief that the inconsistency is due to a typographical error in those columns of Table II and asked us to confirm your interpretation.
Your observation is correct. A November 13, 1973 rule adopting Tables I and II (38 FR 31299) (copy enclosed) specifies the 5/16-inch diameter plunger for motorcycle tires, and the 3/4- inch diameter plunger for 12-inch or smaller tires and 17.5- inch or smaller light truck tubeless tires. Accordingly, the plunger diameter for the motorcycle column in Table II should read 5/16. Similarly, the 12-inch or smaller column in the current Table II is in error in specifying a plunger diameter of 5/16 inch. The correct plunger diameter for that column in Table II should be 3/4 inch to correspond with the plunger diameter specified for 12-inch or smaller rims in Table I.
Thank you for bringing this error to our attention. The agency will issue a correction to avoid any further confusion.
Sincerely,
John Womack Acting Chief Counsel ref:119 d:4/12/94