Interpretation ID: nht81-2.27

DATE: 05/19/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bridgestone Tire Co., Ltd.

TITLE: FMVSR INTERPRETATION

TEXT:

May 19, 1981

Mr. H. Hayashi Manager for Safety Standards Tire Quality Assurance Dept. Bridgestone Tire Co., Ltd. 2800-1, Ogawa, Higashi-Cho Kodaira-Shi, Tokyo, JAPAN

Dear Mr. Hayashi:

This is in response to your letter of March 26, 1981, requesting, an interpretation of the Uniform Tire Quality Grading (UTQG) Standards (49 CFR S575.104). You ask whether a tire designed for service as a temporary use spare tire, and labeled on its sidewall with the inscription: TEMPORARY USE ONLY FOR SPARE TIRE, INFLATE TO 40 PSI, MAX. SPEED 50 MPH, is exempt from the requirements of the UTQG Standards.

As you note, the "Application" section of the UTQG regulation does not apply to space-saver or temporary use spare tires. Thus, the UTQG Standards would not apply to the tire you describe, which is designed as a temporary use spare tire and is so labeled.

Sincerely,

Frank Berndt Chief Counsel

March 26, 1981

Office of the Chief Counsel, National Highway Traffic Safety Administration, 400 Seventh Street s.w., Washington,D.C.20590 U.S.A. Subject: Request for official advice in respect to the interpretation of Uniform Tire Quality Grading Standards (49CFR 575.104)

Dear Sirs:

Recently we have a plan to manufacture a temporary use type spare tire with 185/70 R14 size designation for U.S.A. market at the request of some automobile manufacturer. This type temporary use spare tire is designed to comply all the requirements of FMVSS No. 109, including labelling requirements.

In addition, this spare tire is to have the following labelling letters molded on both sidewalls:

Letters to be labelled

1) TEMPORARY USE ONLY FOR SPARE TIRE

2) INFLATE TO 40 PSI

3) MAX. SPEED 50 MPH

Note:- Refer to the attached sheet.

In the section 49CFR 575.104(C), it is provided that "However, this section does not apply to deep tread, winter-type snowtires or to space-saver or temporary use spare tires."

We, therefore, understand that Uniform Tire Quality Grading requirements would not apply to our temporary use type spare tire.

We hope to have your official comments and/or advice on our interpretation of the application of UTQG Standards.

Your kind and early reply would be highly appreciated.

Sincerely yours,

H. HAYASHI MANAGER FOR SAFETY STANDARDS TIRE QUALITY ASSURANCE DEPT.