Interpretation ID: nht72-1.19

DATE: 02/11/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Salt Lake Auto Auction

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 5, 1972, inquiring whether you may inlay whitewall rings on black tires. You state that in the process a narrow strip of black rubber around the tire is buffed or ground off and replaced with a strip of whitewall which is bonded or vulcanized to the tire in its place.

Assuming that you are discussing applying this process to new passenger car tires, whether the process is permissible depends upon whether or not it adversely affects the tire's compliance with Motor Vehicle Safety Standard No. 109, "New Pneumatic Tires," which prescribes performance requirements for all passenger car tires sold in the United States. A copy of the standard is enclosed.

If after using the process the tire will not comply with Standard No. 109, the use of the process is prohibited, and its use can result in the imposition of civil penalties of up to $ 1,000 per tire and of other sanctions as well (15 U.S.C. 1397(a)(1), 1398, 1399). In addition, it is the responsibility of the one who wishes to use the process to determine whether it will cause the tires to fail the standard.