Interpretation ID: nht69-2.18

DATE: 12/01/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Executive Motors, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 28, 1969, to the National Highway Safety Bureau, concerning our Federal Motor Vehicle safety standards.

The Initial Federal Motor Vehicle Safety Standard No. 109, "New(Illegible Word) Tires - Passenger Cars" was published in the Federal Register on November 13, 1967. This standard specifies tire(Illegible Word) and laboratory test requirements for head unseating resistance, strength, endurance, and high speed performance; defines tire load ratings; and specifies labelling requirements. The standard also requested "Persons desiring an amendment to Standard No. 109 adding tires not presently listed, should submit sufficient pertinent information relative to these tires in 10 copies to the Secretary of Transportation---."

The(Illegible Word) S.p.A. of Milan, Italy requested the addition of the 165-400 tire size designation to Standard No. 109 as well as the adoption of the letter symbols(Illegible Words) for tires. The(Illegible Words) petition was approved and published in the Federal Register on April 18, 1969. The(Illegible Word) tire size designation has been listed within Table I-D of Standard No. 109 since that time.

The labelling requirements of Standard No. 109 apply to all new(Illegible Word) tires - both domestic and foreign - manufactured after January 1,(Illegible Word). There are no "special markings" required on the tires coming into this country other than those detailed in Standard No. 109. For your information, I have enclosed Federal Motor Vehicle Safety Standard No. 109 and No. 110 with amendments.

The 165-400 tire size designation is currently listed within our Standard No. 109 and the labelling requirements are considered to be reasonable and in the interest of safety. The National Highway Safety Bureau does not prohibit any tire manufacturer from fabricating motor vehicle tires. The availability of tires from a specific tire manufacturer is a matter of that company's policy for marketing and has no direct relation to Federal Motor Vehicle Safety Standard No. 109.

As required by the National Traffic and Motor Vehicle Safety Act of 1966, initial Federal Motor Vehicle Safety Standard No. 108, which deals with lighting requirements, was based on existing standards. Accordingly, the initial standard reflected existing requirements contained in Federal and State regulations and the Society of Automotive Engineers Standards on lighting equipment. Since publication of the initial standard on February 3, 1967, this Bureau has sponsored a continuing research program leading to the development of more effective and extensive requirements for vehicular lighting. In fact, during the past two years, eight research contracts have been awarded in the areas of improved forward and rear lighting systems. Under these contracts, in-depth studies, tests and evaluations will be conducted to determine the most effective color, size, intensity, location, and method of controlling the operation of the lamps which are required on the front and rear of motor vehicles. Further follow-on studies and evaluations are envisioned to determine the most-effectiveness and practicability of the proposed improved lighting systems. Results of this research will assist us in evaluating your suggestion and other similar suggestions relating to improved rear lighting systems.