Interpretation ID: aiam4024
Papy
Poole
Weissenborn & Papy
201 Alhambra Circle
Suite 502
Coral Gables
FL 33134;
Dear Mr. Blunt: This responds to your two letters to former Chief Counsel Jeffre Miller in which you sought information concerning our Uniform Tire Quality Grading Standards (UTQGS).; In your first letter, you enclosed a copy of a newspaper article tha appeared in the Miami Herald. That article stated that a 'Federal study' rated projected mileage for 134 different radial tires, and ranked the 'best' and 'worst' tires. You asked for a copy of this study, along with the standards used by the agency to grade treadwear, traction, and temperature-resistance for tires. Your second letter indicates you subsequently received a copy of our UTQGS (49 CFR S575.104), which sets forth the procedures the tire manufacturers use to grade their tires. As discussed below, the 'Federal study' referenced in the newspaper article is merely information taken from tire manufacturers' UTQGS submissions to the agency.; As set forth in the UTQGS, this agency requires the tire manufacturer to assign grades to each of their tire designs. NHTSA then makes available to the public the grade assignments reported to it by the tire manufacturers. Hence, the tests to which the article referred were conducted entirely by the individual tire manufacturers, not by the Federal government.; Neither the tire manufacturers nor the agency made, or could make, an total tire mileage projections from the reported treadwear grades. If one were to project total mileage from the treadwear grade, one could say only that a certain tire might get x miles if driven over the same roads at the same speeds on the same vehicles with the same careful maintenance performed daily on those vehicles. A projection of a tire's treadlife which did not include all of these caveats would be misleading.; Finally, the agency does not categorize particular tires as the best o the worst based solely on the treadwear grades assigned by the manufacturers. Such an approach ignores the importance of the traction and temperature resistance grades, both of which have far greater significance from a safety standpoint than does the treadwear grade. Because of the many variables involved in selecting the most appropriate tire, this agency cannot state that any particular tire is the best for most drivers.; In your second letter, you stated that you had received a 198 publication entitled 'Tire Grading System Information,' and requested a copy of the 1983 and 1984 updates of that publication. The agency did not update that publication during those years. Instead, all interested consumers have been provided with a complete listing of all grades which have been reported to the agency, together with an explanatory sheet telling how to use those grades. I have enclosed a copy of those grades for your information.; For your information, NHTSA suspended treadwear grading requirement under the UTQGS, effective February 8, 1983. This action was announced after the agency found high levels of variability in treadwear test results and in the grade assignment practices of the various tire manufacturers. This variability resulted in a substantial likelihood that treadwear information being provided to the public under this program would be misleading, i.e., that the assigned treadwear grades could, in many instances, incorrectly rank the actual treadwear performance of different tires.; On April 24, 1984, the United States Court of Appeals for the Distric of Columbia Circuit vacated the agency's suspension of the treadwear grading requirements in *Public Citizen v. Steed*, 733 F.2d 93. Accordingly, the agency published a final rule reimplementing the treadwear grading requirements on December 19, 1984 (49 FR 49293, copy enclosed). Hence, if you were seeking treadwear grades for 1983 and 1984, none were assigned during those years.; If you have any further questions or need more information on thi subject, please contact Steve Kratzke of my staff at this address or by telephone at (202) 426-2992.; Sincerely, Erika Z. Jones, Chief Counsel