Interpretation ID: nht79-3.29
DATE: 04/05/79
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: U. S. Suzuki Motor Corporation
TITLE: FMVSS INTERPRETATION
TEXT:
April 5, 1979
Mr. Michael Petler Assistant Manager Safety and Legislation Department U.S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs, California 90670
Dear Mr. Petler:
This is in response to your request of March 22, 1979, for an interpretation of Federal Motor Vehicle Safety Standard No. 109. First, I would like to apologize for the delay in responding to your request of September 14, 1978. As was explained to you in a telephone conversation on March 22, your letter and the response thereto was apparently lost when the Chief Counsel's offices were moved. Although we took great care to ensure that something like this would not happen, it seemingly did in this case. I regret this and hope that it has not caused any undue inconvenience for your company.
You asked whether it was permissible under Standard 109 for a manufacturer to stamp the maximum permissible inflation pressure of a tire and its maximum load rating on the tire in both English units (pounds and psi) and metric units (kilograms and kPa). S4.3(b) and (c) of the standard specify that each tire shall have permanently molded onto the sidewalls the maximum permissible inflation pressure and the maximum load rating for the tire. This agency has interpreted this requirement to mean that the information must appear on the sidewalls in the English units, since this is the system of measurement which will be used and understood by most consumers. However, so long as the information appears in English units, there is no reason that it could not also be expressed in equivalent metric units, if the presentation of the additional information does not cause confusion about the required information. By stating not only the pressure and rating values, but also the units of value, your company would avoid causing any such confusion. Therefore, the expression of inflation pressure and load rating in English and metric units as shown in your illustration is permissible under Standard 109.
Sincerely,
Frank Berndt Acting Chief Counsel
March 22, 1979
Steven Kratzke Office of Chief Counsel National Highway Traffic Safety Administration Room 5213 400 Seventh Street, S.W. Washington, D.C., 20590
Dear Mr. Kratzke:
As per our telephone conversation of this date, as requested I have enclosed a copy of my letter of September 14, 1978, to Mr. Levin regarding our request for interpretation of FMVSS No. 109.
If you are in need of any additional information please feel free to contact us.
Thank you for your interest and assistance in this matter.
Sincerely,
F. Michael Petler Assistant Manager Safety and Legislation Department
FMP/ks Enc.
September 14, 1978
Joseph J. Levin, Esquire Chief Counsel National Highway Traffic Safety Adminisiration Room 5219 400 Seventh Street, S.W. Washington, D.C. 20590
RE: Request for interpretation, FMVSS #109, New Pneumatic Tires- Passenger Cars
Dear Mr. Levin:
We have been requested by our parent company, Suzuki Motor Co., Ltd. to request from your agency, an interpretation of Section S4.3 of this standard, as to the permissibility of molding specific information on the sidewall of a 6.00-16 passenger car tire in both U.S. and Metric (SI) units. We note that in Section S.4.3.4. (a) and (b) that dual markings have been allowed for tires if the maximum inflation pressure of a tire is 240, 280 or 300 KPa.
Our company would like to know whether FMVSS #109 would permit the information required in S4.3 (b) and (c) to be molded onto the 6.00-16 tire sidewall in the following manner by our tire supplier.
That information is:
MAX LOAD 1400 LBS (635 KG) AT 32PSI (221KPA) MAX PRESS
For your convenience we have attached a copy of a drawing that shows the various required markings that would appear on this tire as required in S4.3 of the standard. The letter height would be 4mm, and the letters would be raised 0.4mm for items (b) and (c) of S4.3.
If you are in need of any additional information please feel free to contact us.
Thank you for your assistance in this matter.
Sincerely,
F. Michael Petler Assistant Manager Safety & Legislation Department
attachments (1)
FMP/vw