Interpretation ID: nht75-2.30

DATE: 11/25/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Dayton Wheel Prod., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of August 27, 1975 (117-1), requesting an interpretation of paragraph S3 of Federal Motor Vehicle Safety Standard No. 211, Wheel Discs, Wheel Nuts, and Hub Caps.

Our interpretation of Standard No. 211 is that S3 prohibits winged projections that do not extend beyond the outer edge of the tire or rim, as well as those that do.

We hope that this information will be of assistance. If you have any further questions, please contact us.

Sincerely,

ATTACH.

DAYTON WHEEL PRODUCTS, INC.

August 27, 1975

U.S. Department of Transportation -- National Highway Traffic Safety Administration

Dear Sirs:

This letter is to request an interpretation of Motor Vehicle Safety Standard No 211, section S3. We need to know what determines a "projection".

We maintain that a "projection" must extend outside the plane drawn through the outermost side of the tire or rim. Any portion of the wheel that does not project beyond that plane would not constitute a hazard to pedestrians.

Please send your comments on the above and a clarification on how the projection should be determined. Thank you for your assistance.

Sincerely, James J. Schardt -- President

c.c. Robt. E. Weltzer -- Highway Safety Management Specialist, DOT-NHTSA; Reference 117-1