Interpretation ID: nht70-1.9

DATE: 10/26/70

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Long Mile Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of October 12, 1970, requesting clarification of the required testing for retreaded passenger car tires has been received.

The notice of proposed rule making for Retreaded Pneumatic Tires - Passenger Car was published in the Federal Register (35 FR 4136) on March 5, 1970. Within the proposed standard is states: "S3.2 Retreaded tire requirements: Retreaded tires shall conform to the size, construction, performance and tread wear indicator requirements set forth in paragraphs S4.1 and S4.2 of Federal Motor Vehicle Safety Standard No. 109, no tire may be retreaded by a process which includes the removal of a ply or belt from the casing."

Within S4.2 of Standard No. 109, paragraph S4.2.2.5 specifies the laboratory (dynamometer) test for tire endurance and paragraph S4.2.2.5 specifies the laboratory (dynamometer) test for high speed performance. For your information, I have enclosed a copy of Federal Motor Vehicle Safety Standards No. 109 and No. 110 with amendments.

It was intended that the phrase "through testing" mean testing to Standard No. 109 and it was not intended that the phrase be construed to mean any form of testing.

I hope the above clarifies your question concerning retreaded tires performing to the(Illegible Word) dynamometer tests for tire endurance and high speed performances(Illegible Word)

Sincerely,