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Interpretation ID: GF008677

    Mr. Bryce Pfister
    Director of Operations
    Collins Bus Corporation
    P.O. Box 2946
    Hutchinson, KS 67504-2946


    Dear Mr. Pfister:

    This is in response to your letter and subsequent e-mail regarding the placement of a tire safety information placard required by Federal motor vehicle safety standard (FMVSS) No. 110 "Tire selection and rims for motor vehicles with a GVWR of 4,536 kilograms (10,000 pounds) or less."Specifically, you ask if FMVSS No. 110 permits attaching the placard to the panel located above the drivers door in a raised roof vehicle, when the placard does not fit in the other locations specified in S4.3.

    By way of background, the National Highway Traffic Safety Administration (NHTSA) issues FMVSSs applicable to new motor vehicles and certain items of motor vehicle equipment. However, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements.

      S4.3  of FMVSS No. 110 reads, in relevant part, as follows:

      "S4.3  Placard. Each vehicle, shall show the information specified in on a placard permanently affixed to the driver's side B-pillar. In each vehicle without a driver's side B-pillar and with two doors on the driver's side of the vehicle opening in opposite directions, the placard shall be affixed on the forward edge of the rear side door. If the above locations do not permit the affixing of a placard that is legible, visible and prominent, the placard shall be permanently affixed to the rear edge of the driver's side door. If this location does not permit the affixing of a placard that is legible, visible and prominent, the placard shall be affixed to the inward facing surface of the vehicle next to the driver's seating position" (emphasis added)

    The photographs attached to your e-mail show a tire safety information placard that is considerably larger than the one contemplated by the agency, and used as an example in Figure 1 of the regulatory text.We note however, that a larger placard is not prohibited by FMVSS No. 110 because the Standard does not specify a particular size or a dimension for the placard. We also note that your placard would not be legible if affixed to the B-pillar, or to the rear edge of the drivers side door because it would have to bend along the edges of the door or the B-pillar.We conclude that locating the tire safety information placard on the panel above the drivers side door satisfies the requirement that the placard be affixed to the inward facing surface of the vehicle next to the drivers sitting position.In this location, the placard is clearly legible, visible and prominent.

    I hope you find this information helpful. If you have further questions, you may contact Mr. George Feygin of my staff at (202) 366-2992.

    Sincerely,

    Stephen P. Wood
    Acting Chief Counsel

    ref:110
    d.4/7/06