Interpretation ID: nht76-1.34
DATE: 06/11/76
FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA
TO: Pirelli Tire Corporation
TITLE: FMVSS INTERPRETATION
TEXT: I am writing in response to your March 12, 1976, letter to Mr. Robert Aubuchon of this agency, concerning the application of Federal Motor Vehicle Safety Standard No. 119, New Pneumatic Tires for Vehicles Other than Passenger Cars, to motor driven cycles whose speed attainable in 1 mile is 30 mph or less.
You have inquired whether such vehicles may be equipped with tires that --
(i) "Carry all the inscriptions required by labeling, plus the marking "MAX SPEED" because speed restricted to less than 55 MPH -- S.6.5."
(ii) "Have passed the endurance test -- S.6.1, S.7.2 in accordance with table III -- speed restricted service: 35 MPH"
(iii) "have not been tested for high speed S.6.3 -- in fact they are speed restricted . . ."
and otherwise comply with the requirements of Standard No. 119.
I assume that, where your letter refers to the marking "MAX SPEED", you intended "MAX SPEED 35 MPH". Although such labeling is not prohibited, the standard does not presently recognize a category of speed-restricted motorcycle tires. Tires for motor driven cycles are subject to the same performance requirements as other motorcycle tires. In particular, the schedule for endurance testing is that found in the "motorcycle entry of Table III, rather than the "35 m.p.h." entry. Similarly, these tires are subject to the high speed performance requirements of S.6.3 without exception. An amendment of Standard No. 119 on this subject is being considered, but no firm decision has been made.
Standard No. 119 prohibits the manufacture of the tires that you have described on and after March 1, 1975. Standard No. 120, Tire Selection and Rims for Motor Vehicles Other than Passenger Cars, prohibits the manufacture of motor-driven cycles equipped with such tires on and after September 1, 1976.
SINCERELY,
PIRELLI TIRE CORPORATION
March 12, 1976
NHTSA
Att: Robert Aubuchon
In reference to the phone conversation of March 9, 1976, we would like to have the following Information:
1) Is it permissible (with respect to the safety requirments stated in Standards 119 and 120) to equip motor driven cycles whose speed attainable in 1 mile is 30 MPH or less (see definitions R571 paragraph 571.3 - B and references in part 571, ST 123 - PRE 5 ST 108 - S.4.1.1 26/27, St 122 - S.5.4/S/5.5) with tires meeting the requirements of Standard 119 inasmuch as they:
a) are indicated in ETRTO data book S.5.1.B
b) carry all the inscriptions required by labeling, plus the marking "MAX SPEED" because speed restricted to less than 55 MPH - S.6.5.
c) have tread wear indicators S.6.4
d) have passed the strength test - S.6.2., S.7.3, in accordance with tables I and II - plunger 5/16
e) have passed the endurance test - S.6.1, S.7.2 in accordance with table III - speed restricted service: 35 MPH
f) have not been tested for high speed S.6.3 - in fact they are speed restricted, moreover they may be included in the requirements of Standard 120 - see paragraphs: S.2, S.5.1.1, S.5.1.2, S.5.3. D"
N.B. There is no indication anywhere in Standard 119 and 120 that the speed restrictions apply only to trucks.
2) As discussed by phone, we have requested that a copy of the letter sent by ETRTO to the DOT be forwarded to you as soon as possible. We would appreciate if you would look into this matter and inform us of the outcome.
Thanking you in advance for a prompt reply, we remain
Francesa Robinsons for Mr. Buzzi
G. Buzzi-Ferraris Technical Manager
Industrie Pirelli spa
MARCH 15, 1976
Robert Aubuchon N.H.T.S.A. Office of Standard Enforcement
We have been informed by Pirelli Tire Corporation N.Y. your request for a copy of the ETRTO Submission to NHTSA concerning an amendment to FMVSS 119 and precisely 'Tyres for low-power motorcycles with restricted speed capability'.
A copy of it is here with enclosed.
Recently, February 26th, Mr. Richard B. Dyson, Assistant Chief Counsel of NHTSA has promised to Mr. Trimble, ETRTO General Secretary, that a Federal Register notice on the subject will be issued in the near future.
(P.G. Malinverni) Tyre Standardization
EUROPEAN TYRE AND RIM TECHNICAL ORGANISATION
The Director National Highway Traffic Safety Administration U.S. Department of Transportation
RD/MS 048/75
SUBMISSION N degree 6/119
FMVSS 110 - TYRES FOR LOW-POWER MOTORCYCLES WITH RESTRICTED SPEED CAPABILITY
In the preamble to Docket 71-18 Notice 6, published in the Federal Register Volume 39, No.29 dated Monday February 11th 1974, page 5192, reference was made to an E.T.R.T.O. proposal for new test values for certain motorcycle tires, which proposal was deemed to be "unclear as to the meaning . . . "
For convenience of reference the paragraph in question is quoted as follows:
"The E.T.R.T.O. proposed new test values for some motorcycle tires, but the request was unclear as to the meaning of the 62 mph criterion and the unsupported request cannot be granted. If in future, the E.T.R.T.O. petitions for rule making to revise the table, an explanation of the criterion and a justification for the test values would permit an informed decision."
In response to the invitation, implicit in this paragraph, to E.T.R.T.O. to petition "for rule making to revise the table" by submitting explanation and justification of its requirements E.T.R.T.O. submits the following petition for consideration on this subject.
FMVSS 119 recognises all data standardised by the various international and national standards organizations (Illegible Words) (Illegible Line) (Illegible Words) in tables II (strength) table III (endurance) and in paragraph S7-1 (high speed).
In accordance with the "invitation" instanced (Illegible Word) ETRTO formally requests reconsideration of the requirements of Standard 119 insofar as two categories of light motorcycle tires are concerned, these being the speed-restricted ranges of such tires listed on pages (Illegible Word) through 119 of the 1974/75 E.T.R.T.O. Data-book.
In requesting certain (Illegible Word) from the terms of Standard 119, E.T.R.T.O. is evoking (Illegible Words) which resulted in amendments to the requirements of (Illegible Words) 122 (Illegible Word) 123, as published in the Federal Register Vol. 39 No. 72 (Illegible Words) 12th 1974, in that the existing Standard 119 is "not reasonable, (Illegible Words) appropriate" to the light motorcycle tires in question.
a) Tires for Small Cubic Capacity Motorcycles With Speed Capability up to 50 mph
These tires are especially designed to be fitted to motor-driven cycles with a (Illegible Words).
They can be recognised from having the word "Moped" (or alternatively "Cyclomoteur", or "Ciclomotore" or "Circlomotor") in the vicinity of the (Illegible Word) designation (e.g. (Illegible Word) - 17 Moped).
E.T.R.T.O. requests that for tires to be mounted on motor-driven cycles with a top speed capability of 30 mph of less, tires known as moped tires in Europe and with a speed restriction of 30 mph, the following specifications be adopted:
1. Strength: the minimum static breaking energy should be the one allowed for rayon cord tires even for other types of cords such as cotton, which is widely used for this tire range and which has breaking energy properties almost identical to rayon.
2. Endurance: the test wheel speed should be 100 rpm
The test leads could be (in percent of maximum lead rating): 100% for 4 hours, 108% for 6 hours and 117% for 24 hours.
3. High Speed Test: no high speed test will apply to these tires since they are "speed restricted".
4. Treadwear Indicators: in view of the low speed usage and the fact that these tires have very shallow tread patterns, (circa 3 mm) similar to cycle tires, E.T.R.T.O. (Illegible Word) that the requirement to add treadwear indicators at 1/32" (0,8 mm) is unrealistic and against the interests of the consumer.
b) Tires for Small Cubic Capacity Motorcycles up to 60 mph (or 100 km/h)
This is the category of tires previously referred to as "up to 62 mph", this being strictly equivalent speed to 100 km/h.
These tires are specially designed to be fitted on lightweight motorcycles with maximum speed not exceeding 60 mph.
(Illegible Line) is considered that a (Illegible Words) rating for these tires (Illegible Words) in a restricted-speed category. In consequence E.T.R.T.O. requested (Illegible Word) (Illegible Lines)
1. Endurance: the test wheel speed should be 200 rpm, the test load in percent of maximum load rating 100 for 4 hours, 108 for 6 hours, 117 for 24 hours
2. High Speed: since the first step of the high speed test is 375 rpm equivalent to a speed on highway largely in excess of 75 mph and that speed is higher than the maximum allowed for the tire we would propose that category to be considered a speed restricted category therefore the high speed test will not be necessary for them.
3. Treadwear Indicators: for the reasons outlined in paragraph (a) (4) above the requirement for treadwear indicators be waived for this range of tires.
c) For case of consideration of these requests it should be noted tha the (Illegible Line) ranges of (Illegible Words) -speed motorcycle tires by their size designation as follows: (i) light motorcycle tires, 30 or 60 mph category - the size designations are in inches and fractions of an inch e.g. 2 1/2 - 17.
(ii) unrestricted speed motorcycle tires - the size designations are in inches and decimals e.g. 2.75 - 17.
E.T.R.T.O. requests that early consideration be given to this petition in order that appropriate steps may be taken for implementation prior to the March 1st 1975 effective date of Standard 119.
Thanking you in advance for your kind consideration of the matter,
R. DERESSON General Secretary