Interpretation ID: nht78-2.40

DATE: 10/27/78

FROM: AUTHOR UNAVAILABLE; S. P. Wood For J. J. Levin, Jr.; NHTSA

TO: Bridgestone Research Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Oct 17, 1978

Mr. Ken Yoneyama Chief Engineer Bridgestone Research Inc. 350 Fifth Ave., Suite 4202 New York, New York 10001

Dear Mr. Yoneyama:

This is in response to your letter of September 22, 1978, asking whether tires listed in Table 1-A of Appendix A, Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires - Passenger Cars, must comply with Part 575.104, Uniform Tire Quality Grading Standars, (UTQGS), if the tires are installed as original equipment on multi-purpose passenger vehicles. You also inquire as to the effective dates for the provision of UTQGS information to first purchasers of new motor vehicles under Part 575.104 (d) (1) (iii).

UTQGS applies to a tire type whose predominant contemplated use is on passenger cars, even if the manufacturer knows the tire type is also used as original equipment on multi-purpose passenger vehicles. A manufacturer's determination to certify a tire as conforming to Standard No. 109, will also determine the tire's classification for purposes of UTQGS. Thus, UTQGS would apply to any tire labeled with a size designation listed in Aappendix A of Standard No. 109, other than a deep tread, winter-type snow tire or space-saver or temporary use spare tire, regardless of the tire's actual use.

On October 23, 1978 NHTSA issued a Federal Register notice (copy enclosed) granting the petition of American Motors Corporation to revise the effective dates for Part 575.104 (d) (1) (iii) to September 1, 1979 for bias-ply tires and March 1, 1980 for bias-belted tires. On the basis of this change, your statement regarding effective dates is correct.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

September 22, 1978 Ref. No. KY/107

Mr. Richard Hipolit Office of Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 7th Street, S. W. Washington, D. C. 20590

Dear Mr. Hipolit:

This letter is with reference to rule S575.104, Uniform Tire quality Grading Standards (Docket No. 25; Notice 24), as published in the Federal Register, Vol. 43, 90. 137, July 17, 1978.

We would like to know whether the rule on the "Application" and the "Effective date of the requirements for original equipment tires" can be read as follows:

1. Application

Paragraph (c) on the "Application" states that, "This section applies to new pneumatic tires for use on passenger cars... ."

On the basis of this statement, we understand that the rule is not applied to new pneumatic tires for use on vehicles other than passenger cars, even if the tires are listed on the Table of Standards No. 109.

For instance, a 6.00-16 tire is listed on the Table 1-A of Appendix A in the Standard No. 109, as a tire that is used for passenger cars. However, when the 6.00-16 tires are originally equipped on multipurpose passenger cars, we understand that it is not necessary for the tires to comply with the rule.

Is this correct, or not?

2. Effective Date

For the information requirements to be furnished to the first purchaser of a new motor vehicle, the paragraph (d) (1) (iii) states that, "The information ..... it must contain a statement referring the reader to the tire sidewall for the specific tire grades for the tires... ."

We understand that the information requirements to the first purchaser of a new moter vehicle will become effective on September 1, 1979 for bias ply tires and on March 1, 1980 for bias belted tires on the basis of the molding requirements.

Is this correct, or not?

We would appreciate it if you would inform us as to your opinion and judgement on the above interpretations, as soon as possible.

Thank you for your time and consideration.

Yours truly,

KEN YONEYAMA Chief Engineer

KY/sff