Interpretation ID: nht74-4.26

DATE: DATE:05/07/74

FROM: FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: TO: Perkasie Vulcanizing Co., Inc.

TITLE: TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 25, 1974, asking whether, consitently with Federal Motor Vehicle Safety Standard No. 117, maximum permissible load may be labeled in two lines, viz.:

MAXIMUM PERMISSIBLE LOAD XXXXXXXX LBS.

You ask further whether there is a maximum height requirement for the lettering used in the label.

Standard No. 117 does not specify labeling format, and the two-line format you submit conforms to the standard. Paragraphs S6.3.1 and S6.3.2 of Standard No. 117 require all safety labeling, both permanent and affixed, to be at least 0.078 inches in height. No other requirements regarding labeling size are specified.

PERKASIE VULCANIZING CO., INC.

[Illegible Words]

SUBJECT: Federal Motor Vehicle Safety Standards FMVSS-117 - Auto Tire Retreads

In our letter to you dated January 4, 1974 on the subject we gave you information regarding the requirement that on February 1, 1974 certain information must be permanently molded into or onto the sidewall of an auto tire retread.

As you may have noticed in news releases, the U.S. Court of Appeals on January 8, 1974 modified the requirements as to what information must appear on the sidewall.

The result is -- on Auto Tire Retreads all that is required as of February 1, 1974 is --

"Maximum permissible load"

This information must be permanently molded into or onto the sidewall of Auto Tire Retreads.

All the other information such as tire size, inflation pressure, ply rating, tubeless or tube type, bias ply, bias/belted or radial must be on the tire, or may be labeled onto the tire, either permanently or by the addition of a label that is not easily removable, during the retreading process as we mentioned in a previous letter to you dated May 9, 1973, may still be used.

We will keep you advised of future rulings or changes.

TITLE: FMVSS INTERPRETATION DATE:05/07/74 FROM: AUTHOR UNAVAILABLE; Lawr

JAS. H. MATTHEWS & CO.

February 18, 1974

Perkesie Vulcanizing Company

ATTENTION: Ralph Perkesie

SUBJECT: Retread Law FMVSS-117

In response to our phone conversation recently in which you had requested us to investigate the retread law FMVSS-117 concerning the character size and length as specified in this law for the labeling of the maximum permissible load designation.

It is our position that we can not presume to interpret or have access to this particular law. This specification should be interpreted by the department of transportation with Perkesie Vulcanizing Company. Any questions concerning this particular law or its' requirements stated in this law should be passed upon the department of transportation. We hope that you can understand that the Jas. H. Matthews & Company is simply the supplier of the tags as specified by a customer. If these tags must meet a specific regulation or a variance of this regulation, this must be interpreted by the customer.

We have our facilities at your disposal in supplying and fulfilling your particular requirements for tags once these specifications have been determined.

We hope this information is of value to you and if we can be of any further service to you in any way please do not hesitate to contact us.

C. R. Parfitt Industry Specialist