Interpretation ID: nht80-2.22

DATE: 04/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: McCreary Tire & Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT:

APR 24, 1980 IN REPLY REFER TO: NOA-30

Mr. Robert A. Eddy Manager, Quality Assurance McCreary Tire & Rubber Company Indiana, Pennsylvania 15701

Dear Mr. Eddy:

This is in response to your letter of March 7, 1980, asking whether ASTM E501 and E524 tires must be graded in accordance with the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104). You state that these tires are manufactured in limited quantities as standards for traction testing and are not manufactured for general highway use. It is the National Highway Traffic Safety Administration's understanding that these tires are used only on a test trailer designed for use in skid testing.

The UTQG regulation applies to new pneumatic tires for use on passenger cars (49 CFR 575.104(c)(1)). Thus, ASTM E501 and E524, which are manufactured solely for use on a traction test trailer, would not fall within the application of the UTQG Standards.

Sincerely,

Frank Berndt Chief Counsel

March 7, 1980

Office of Chief Counsel ATTENTION: Mr. Richard J. Hipolit National Highway Traffic Safety Administration 400 Seventh Street, SW Washington, D. C. 02590 Dear Sir:

We are requesting an interpretation of Part 575.104 - Uniform Tire Quality Grading Standards - with reference to the ASTM E501 and E524 tires.

Since these tires are manufactured in limited quantities as standards for skid resistance testing and are not manufactured for general highway use, it is our understanding that they are not covered by the requirements of Part 575.104.

Would you please confirm this interpretation.

Sincerely,

Robert A. Eddy Manager, Quality Assurance

RAE/pel