Interpretation ID: nht74-3.50

DATE: 06/03/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: American Retreaders' Assoc., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of April 7 and April 8, 1974, regarding Standard No. 117, "Retreaded Pneumatic Tires." Your April 7 letter asks whether Standard No. 117 requires treadwear indicators to be straight across the tread face. Your letter of April 8 encloses two sample rubber labels and asks whether each conforms to the requirements of S6.3 of Standard No. 117.

Paragraph S5.1.1(b) of Standard No. 117 does not specify a configuration for treadwear indicators. Rather, it incorporates by reference the requirements for treadwear indicators of S4.2.1(d) of Standard No. 109, which calls only for a treadwear indicator that provides a "visual indication that the tire has worn to a tread depth of 1/16 inch." We do not construe this language to require a straight-across treadwear indicator and other configurations are therefore permitted.

With respect to the labels you enclose in your letter of April 8, each would conform to all of the requirements of S6.3 (which includes the requirements for both affixed (S6.3.1) and permanent (S6.3.2) labeling) if the tires to which they are affixed are of neither bias-belted or radial construction. If they are of either of these construction types, that information would have to be included either through affixed or permanent labeling, including retention of the original casing labeling.

AMERICAN RETREADERS' ASSOCIATION, INC.

April 7, 1974

Lawrence R. Schneider Chief Counsel Department of Transportation National Highway Traffic Safety Administration

In the manufacture of retreaded tires we have a need for clarification as to what constitutes a "tread wear indicator."

We are aware of a specific height requirement of 1/16" but are not clear as to whether it must be straight across the tread face or if some other type of configuration is acceptable.

Thank you for your assistance.

E. J. Wagner

Managing Director

AMERICAN RETREADERS' ASSOCIATION, INC.

April 8, 1974

Lawrence R. Schneider Chief Counsel Department of Transportation National Highway Traffic Safety Administration

I have enclosed two sample rubber labels that we have been recommending to retreaders to affix to the sidewall of their product in order to comply with Section S6.3 as it now stands.

There has been some question as to whether this label complies with the requirements of S6.3.

May we have your views on this?

Thank you for your assistance.

E. J. Wagner

Managing Director