Interpretation ID: 1984-2.41

TYPE: INTERPRETATION-NHTSA

DATE: 07/31/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Continental Products Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Jack DiMaio Technical Service Dept. Continental Products Corporation 1200 Wall Street West Lyndhurst, New Jersey 07071

Dear Mr. DiMaio:

This responds to your recent letter seeking an interpretation of the requirements of Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars (49 CFR S571.119). Specifically, you asked whether it is necessary to mold the DOT symbol on the sidewall of a motorcycle tire used for racing on a production motorcycle, if the production motorcycle is to be used only on the race track. Standard No. 119 requires the DOT certification to appear on new motorcycle tires designed for highway use. If these tires are designed for use only on a race track, they need not have a DOT symbol on the sidewall.

Section S6.5( a) of Standard No. 119 specifies that each tire subject to the standard shall be marked with the symbol DOT, which shall constitute a certification that the tire conforms to applicable Federal motor vehicle safety standards. However, section S3 specifies: "This standard applies to new pneumatic tires designed for highway use on...motorcycles manufactured after 1948" emphasis added. Thus, the relevant question in determining whether the DOT certification must appear on the sidewall of a tire is whether the tire is designed for highway use.

It is not clear from your letter whether these tires are designed for highway use. You noted that the motorcycles on which the tire is mounted are intended for use only on race tracks. If these tires are not designed for use on other motorcycles, the DOT symbol need not be molded on the sidewall of the tires. If, on the other hand, the tires are also designed for use on other motorcycles which wil1 be used on the highways, the DOT symbol must be molded on the sidewall of the tires. This is a determination which must be made in the first instance by Continental, but may be reexamined by this agency.

Please feel free to contact me if you need any further information on this matter.

Sincerely,

Frank Berndt Chief Counsel

June 20, 1984 NHTSA 400 7th Street S.W. Washington, D.C. 20590

Attn: Frank Berndt Dear Mr. Berndt,

In a recent visit to Continental A. G., in Hanover, Germany, the question of high speed motor cycle racing tires camp up. The question is as follows.

Is it necessary to mold the DOT approval on the sidewall of a motor cycle tire used for racing on a production racing motor cycle to be used on the race track only?

Your early response to the above questions would be greatly appreciated along with any comments relating to this subject.

Sincerely, Jack DiMaio Technical Service Dept.