Interpretation ID: nht70-2.51

DATE: 01/02/70

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of November 25, 1969, to the National Highway Safety Bureau requesting the addition of the 4-J and 4 1/2-J rims for use with the 5.60x15 tire size designation and the 4 1/2-J rim for use with the 6.00x15L tire size designation to Table I, Appendix A of Federal Motor Vehicle Safety Standard No. 110.

The addition of these rims to Standard No. 110 is not necessary, as these combinations are listed within the references cited in S.J of Standard No. 109. The fact that you have changed the hump configuration on these rims requires no action on our part as we do not list variations from the basic Tire and Rim Association's contours. We consider only the rim width and flange coutour designation at this time when listing rims in the standard.

Manufacturers who modify rims are, of course, responsible to see that their product will perform satisfactorily to the requirements of Standard No. 109 and No. 110.

ALBA TIRE COMPANY

NOV. 24, 1969

NATIONAL HIGHWAY SAFETY BUREAU

We unfortunatley were unable to attend the Convention in Atlanta, and to hear your address, delivered to those interested, at the convention. However I have reviewed your address carefully, as reported in the November issue of Modern Tire Dealer, and have some questions.

Will Off the Read New Tires, and Retreads(say Racing Tires) come under the Regulations which are proposed for New Tires- and Retreads? If they are going to be included we wonder why-sincethis Deal is a different Ball game from the other phases of the Tire Business. The reason I say this is because of the difference in the original construction of the Tires (new at the factory). There is also a vast difference in the performance of the Tires-as regards heat buildup-and heat dissipation factors,. For ourselves we have been retreading Racing Tires for some 6 years now, and I have my First complaint-with one of my Retreads coming loose. My 45 years experience in Retreading may not make me an expert- but(Illegible Word) have learned a few things about the performance of Retreaded Tires on the Tracks-as opposed to New Tires. I cannot find any difference in the performance-or the satisfaction of the Users of a new Tire-as opposed to Retreads.

I ship my retreaded Race Tires all over Texas, Oklahoma, Kansas, and Nebrasks, as well as New Mexico. These Tires are run on both Paved, and Dirt Tracks, and by(Illegible Word) slow cars to sprint cars which turn up to 145 mph on the Straightway- NO PROBLEMS.

I buy my Retrenching Rubber Tax Free-since it is not going to be used on Hiway Type Tires- and of course should be Tax free.

I am 100% for a Fine quality Retread-and have for many years been critical of the Marginal Retreader-who had nothing but price- and POOR Quality to recommend his product-but as I say-I am wondering WHY The Race Tire deal should be included in any Guidelines that apply to Highway type Tires?

We will appreciate greatly your consideration of our concern-and thank you for an early response.