Interpretation ID: RMAmetric22869

Mr. Steven Butcher
VP Technical and Standards
Rubber Manufacturers Association
1400 K Street, NW
Washington, DC 20005

Dear Mr. Butcher:

This responds to your March 12, 2001 letter asking whether four labeling sample proposals, subject to Federal Motor Vehicle Safety Standard (FMVSS) No. 119, New pneumatic tires for vehicles other than passenger cars (571.119), are acceptable in terms of placement of the metric units under the Final Rule for the Metric Conversion of Tire Standards, Docket No. NHTSA-98-3837, Notice 1 ("Final Rule") (May 27, 1998, 63 FR 28912).

The National Highway Traffic Safety Administration (NHTSA) does not issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample markings appear to comply with the requirements of FMVSS No. 119, as amended by the Final Rule.

A review of the labeling illustrations you supplied indicates that you have used a different format than illustrated in our Final Rule of May 27, 1998. For example, the amended FMVSS No. 119 does not dictate repetition of the existing English measurement label after the metric measurement label, e.g. "MAX LOAD 1020 KG AT 350 KPA COLD (MAX LOAD 2250 LBS AT 50 PSI)" but, rather, the placement of the existing English measurement in parenthesis after the metric measurement, e.g. "MAX LOAD 1020 KG (2250 LBS) at 350 KPA (50 PSI) COLD". This specification resulted from comments by manufacturers that unnecessary words needlessly increase the amount of labeling required on the tires.

The example of marking information shown in S5.6 of FMVSS No. 119 in the Final Rule is intended only as a guide to manufacturers. A manufacturer can vary the illustrated format somewhat as long as the requirements of S5.6, as amended, are satisfied. Since the additional words in your proposed labels do not obfuscate the required markings, the labels appear to comply with the requirements of FMVSS No. 119, as amended by the Final Rule.

I hope this information is helpful. If you have any questions or need additional information, feel free to contact Nancy Bell of my staff at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

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