Interpretation ID: nht81-3.42

DATE: 11/20/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Fruehauf Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter to Mr. Kratzke of my staff concerning the requirements of Federal Motor Vehicle Safety Standard No. 120 (49 CFR @ 571.120). Specifically, you asked if retreaded tires could be mounted on new trucks and trailers, and what requirements those tires would have to meet.

Retreaded tires can be mounted on new trucks and trailers without violating Standard 120. For your information, I have enclosed a copy of a 1978 interpretation concerning Standard 120 which explains that retreaded tires can be mounted on new trucks and trailers in compliance with the standard. The only requirements those tires would have to meet is that the sum of the maximum load ratings for the tires would have to be at least equal to the gross axle weight rating of the axle to which they were fitted, as specified in section @ 5.1.2 of the Standard 120. As explained in the attached letter, there is no requirement that the retread meet the requirements of Standard 119 because those requirements are inapplicable to retreads. Further, there is no requirement that the retreads have the DOT symbol.

If you have any further questions, please contact Mr. Kratzke at (202) 426-2992.