Mr. Dennis J. Tualej

Nu-Way Intermodal Services, Inc.

220 Roger Avenue

Westfield, NJ 07090

Dear Mr. Tualej:

This responds to your letter seeking clarification as to the appropriate maximum load markings and inflation pressures on the sidewall of truck tires. You asked if differing markings on similar tires provided to you by different suppliers are acceptable. As discussed below, our review of the sample markings set forth in your letter leads us to conclude that the first marking you cited conforms to the requirements of our tire safety standards, while the second marking does not conform.

By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal Motor Vehicle Safety Standards (FMVSSs) for new motor vehicles and items of motor vehicle equipment (see 49 U.S.C. Chapter 301). NHTSA, however, does not approve motor vehicles or motor vehicle equipment. Instead, each manufacturer must self-certify that its products meet all applicable safety standards prior to sale.

FMVSS No. 119, New Pneumatic Tires for Vehicles Other than Passenger Cars sets forth, among other things, labeling requirements for tires for use on trucks. Of relevance here, the maximum load rating and corresponding cold tire inflation pressure marking requirements are provided in FMVSS No. 119 paragraphs S6.5(d) and S6.6, as described below.

Paragraph S6.5(d) of the standard requires that the truck tires be marked on each sidewall with, among other things, the maximum load rating and corresponding cold inflation pressure for the particular tire. This information must be shown as follows:

(Mark on tires rated for single and dual load): Max load single __kg (__lb) at __kPa (__psi) cold. Max load dual __kg (__lb) at __kPa (__psi) cold.


(Mark on tires rated only for single load): Max load __kg (__lb) at __kPa (__psi) cold.

Paragraph S6.6 of the standard sets forth requirements concerning how to determine the numerical values for the maximum load rating and corresponding inflation pressure. That provision directs the manufacturer to use a maximum load not lower than the lowest maximum load and corresponding inflation pressure for the particular tire size contained in a current publication from one of the following entities:

(a) The Tire and Rim Association;

(b) The European Tyre and Rim Technical Organisation;

(c) Japan Automobile Tire Manufacturers Association, Inc.;

(d) Deutsche Industrie Norm;

(e) British Standards Institution;

(f) Scandinavian Tire and Rim Organization, and

(g) The Tyre and Rim Association of Australia

Turning to the specific examples cited in your letter, you asked which of two maximum load ratings and corresponding inflation pressures for 10.00-20 14 Bias Ply Tires is accurate. These markings, supplied by two tire manufacturers, differed in two ways: (1) they employed different syntaxes, and (2) the maximum load rating values were different. We have restated the content of these two tire markings below:

(1)   Max load single 2800 kg (6175 lb) at 690 kPa (100 psi) cold. Max load dual 2430 kg (5355 lb) at 620 kPa (90 psi) cold;

(2)   Max load single 6040 lb at 105 psi cold. Max load dual 5300 lb at 95 psi cold.

In terms of format, because the tires you ask about are dual load tires, they must be marked so as to be consistent with the format specified in S6.5(d) of FMVSS No. 119 (i.e., Max load single __kg (__lb) at __kPa (__psi) cold. Max load dual __kg (__lb) at __kPa (__psi) cold.). Thus, in terms of syntax, marking #1 is consistent with the applicable requirement, whereas marking #2 is not.

In terms of content, the values recited in marking #1 correspond to the maximum load ratings for a 10.00-20 14 Bias Ply Tire assigned by the Tire and Rim Association, one of the tire industry organizations whose tire-load tables is incorporated by reference in our standard. Therefore, the values provided in marking #1 would be appropriate for inclusion in the required marking on the tire sidewall.

As to marking #2, in order to conform to paragraph S6.6, the maximum load rating values must not be lower than the lowest maximum load and corresponding inflation pressure for the particular tire size in one of the specified publications. The lowest such maximum load rating for 10.00-20 14 Bias Ply Tires for single tire application is 5842 lbs, as listed in the Scandinavian Tire and Rim Organization 2006 Year Book, and the lowest such maximum load rating for dual tire application is 5346 lbs, as listed by the Japan Automobile Tire Manufacturers Association (JATMA). While the single tire application rating in marking #2 (6040 lbs) is not lower than the lowest allowable single tire load rating, the dual tire application rating (5300 lbs) is lower than the lowest allowed rating. As both the single and the dual maximum load rating values must comply with paragraph S6.6, marking #2 is not in conformity with that paragraph.

We hope that the above information will assist you in advising your customers. If you have any additional questions about this matter, please contact Ari Scott of my staff at (202) 366-2992.

Sincerely,

Anthony M. Cooke

Chief Counsel

d.3/8/07

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