Interpretation ID: nht74-2.29

DATE: 05/01/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Robert E. Langdon III

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 12, 1974, asking whether retreaded tires are required by Motor Vehicle Safety Standard No. 117 to have either a ribbed tread pattern or treadwear indicators.

Standard No. 117 does not have requirements for tread pattern design, and thus retreaded tires need not have a ribbed tread design. Each retreaded tire must, however, in accordance with S5.1.1(b) of Standard No. 117, incorporate a treadwear indicator that will provide a visual indication that the tire has worn to a tread depth of 1/16 inch.

YOURS TRULY,

April 12, 1974

Office of the Chief Counsel -- Attn: Lawrence Schneider, N.H.T.S.A.

Dear Mr. Schneider:

I have talked with Mr. Zemaitas of the San Francisco office of the N.H.T.S.A. several times about the D.O.T. standards for retreaded pneumatic tires. He was able, after calling the enforcement section of N.H.T.S.A. in Washington, to answer the question I had. When I asked if he could send the information to me in writing, he told me that I would have to write to the legal section in Washington in order to receive a written reply, and he was kind enough to give me your address.

I am a member of the Code Committee of the Southern California Council of Sports Car Clubs. Our Council sanctions slaloms, which are non-racing time and maneuverability events for automobiles. These slaloms are normally held on privately owned parking lots. Many of the cars are towed or trailered to the events since, under the provisions of the California Motor Vehicle Code, they may not legally be driven on streets or highways.

My questions stems from the fact that our slalom code has a rule in reference to tires which states, "Tires must be listed . . . in the manufacturer's printed catalog, and/or have a D.O.T. marking." This rule applies to retreaded tires as well as to new tires.

We have dealt with several retreaders that have been retreading D.O.T. marked carcasses with rubber of a low Shore hardness for increased traction. These tires have met the D.O.T. standards and have always had a tread groove pattern. Consequently the retreaders have marked them with their D.O.T. marks in addition to the original manufacturer's D.O.T. mark already on the carcass. The reason our rule is written specifying a D.O.T. mark is that the safety and strength of tires used in our sport is very important to us. We feel that the retreaders will continue to supply us with high quality, safe tires if we require them to meet the D.O.T. standards for retreaded tires.

My question to Mr. Zemaitas which he referred to the enforcement section (Illegible Words) retreaded tire which meets the standards for retreaded pneumatic tires (Code of Federal REgulations, Title 49, Chapter V, Paragraph 571.117) be legally marked with the D.O.T. mark if (1) there is no groove or rib pattern in the tread, and (2) there are wear indicators in the tread.

The enforcement section indicated to Mr. Zemaitas that this can be done, as there is no requirement for a tread groove or rib pattern, but only for tread wear indicators.

What I would like from you is written verification that, as long as a retreaded tire has tread wear indicators, it does not need to have a tread groove or tread rib pattern in order to be legally marked with the D.O.T. mark. This letter will be shown to other members of the Southern California Council of Sports Car Clubs to verify to them that such a retreaded tire complies with D.O.T. standards and therefore can be legally marked with a D.O.T. mark.

I would appreciate a reply from you as soon as possible. If you have any questions, I am normally available from 10 am. to 3 pm. (PST) at the telephone number shown above.

Sincerely,

Robert E. Langdon III