Interpretation ID: nht81-3.2

DATE: 07/28/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Armstrong Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent request for an interpretation of the labeling requirements of Safety Standard No. 119 (49 CFR @ 571.119). Specifically you asked if the requirements of section S6.5(f), requiring the tire label to show the actual number of plies, and the composition of the ply cord material would be satisfied by the Marking: "Tread - 2 plies Polyester + 2 Aramid Woven Belts Sidewall - 2 plies Polyester."

It has been a longstanding policy of this agency not to issue advance approval of labeling information. However, we will state that marking appears to satisfy the requirements of section S6.5(f) if it is slightly modified. Specifically, the reference to "belts" should be deleted, and the word "plies" should be substituted.

The purpose of the marking requirements in Standard No. 119 is to ensure that the user of the tire is provided with technical information in a straightforward manner. This information is necessary for the safe use of the tire. Section S6.5(f) of the Standard requires that the marking include only the actual number of plies and the composition of the ply cord material. To satisfy this requirement, the information for the tread should appear as: "Tread - 2 plies Polyester + 2 plies Woven Aramid."

Your desire to represent the ply cords as belts probably represents a marketing effort by Armstrong to convince purchasers to buy this particular tire. This agency has no reason to believe that these tires are not outstanding performance tires or to reduce your marketing efforts. However, it is inappropriate to extend this marketing effort to the Federally required markings on the sidewall of the tires.

Sincerely,

ATTACH.

May 8, 1981

Frank Berndt, Chief Counsel of National Highway Traffic Safety

Administration -- U.S. Department of Transportation

Dear Mr. Berndt:

This letter is a request for an interpretation of identification for material placed in a tire as specified in Part 571.119, S5.6(f).

The Armstrong Rubber Company is planning to produce radial ply tires with an Aramid Woven Belt. Our preference would be to mark the sidewall of the tire as follows:

Tread - 2 plies Polyester + 2 Aramid Woven Belts

Sidewall - 2 plies Polyester

This woven belt is a new design for tread reinforcing material that has been tested by The Armstrong Rubber Company and found to be very satisfactory for use in radial ply tires.

I trust this information will permit you to respond.

Sincerely, THE ARMSTRONG RUBBER COMPANY; R. W. Cheetham -- Director of Quality Assurance

cc: Francis Armstrong