Interpretation ID: nht68-3.9

DATE: 01/18/68

FROM: AUTHOR UNAVAILABLE; G. F. Lambert for Robert M. O'Mahoney; NHTSA

TO: The Armstrong Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: MR. BRIDWELL HAS ASKED me to reply to your letter of December 1, 1967.

In your letter you raise three questions. The first is:

"(1) We find that in smaller rim diameter models that it is impossible to place all the branding in the white sidewell side between the buffing rib and the top of the rim flange area as shown in Figure 1, Page 14 - MVSS No. 109.

In complying with a state requirement, namely V-1, it was necessary to place the stamping above the buffing rib. Permission is requested to place the stamping above the rib in a protected area where it will not be scuffed and destroyed."

The labeling requirements of Standard No. 109 make it mandatory that the approved symbol (DOT) and the code mark be between the maximum section width and the bead, other information need only be conspicuously labeled. Additionally, there is no requirement that the information be in one section of the area specified, but rather the entire circumferential area can be used for the labeling.

Your second question is:

"(2) Reprocessed Tires

In tire manufacturing sometimes a mold fold will occur in the area of the branding. The area is buffed. If such stamping is removed, will it be necessary to rebrand the tire, or will the use of a label be sufficient? This usually occurs on one side of the tire only."

Your question concerns new tires that have had the labeling information removed by some subsequent manufacturing process. In order to comply with S4.3 of Standard No. 109, the tire will have to be labeled on both sidewalls. Please note however, that S4.3.1 states that "until August 1, 1968, the labeling requirements of S4.3 may be met by affixing to each tire a label or tag that incorporates all specified information not molded into or onto the tire."

Your third question is:

"(3) Removal of 'V-1' born Models

It is our understanding that MVSS Standards No. 109 and 110 prcempt the 'VESC' regulation 'V-1' revised. We are also aware that states can impose safety regulations for tires and motor vehicles provided they are higher than the Federal Standards and are for use on the state owned equipment.

We request a statement from the Department of Transportation stating the position the Department will take regarding the 'V-1' requirements."

Federal motor vehicle safety standards do not require that tires be manufactured without the "V-1" symbol. Presently, a manufacturer may, at his option, continue the practice of molding tires with the "V-1" symbol.