Interpretation ID: 16539.wkm

Mr. Donald W. Vierimaa
Vice President - Engineering
Truck Trailer Manufacturers Association
1020 Princess Street
Alexandria, VA 22314-2247

Dear Mr. Vierimaa:

Please pardon the delay in responding to your letter to Dr. Ricardo Martinez, the National Highway Traffic Safety Administration (NHTSA) Administrator, in which you referred to subsection S5.3, Federal Motor Vehicle Safety Standard (Standard) No. 120, Tire selection and rims for motor vehicles other than passenger cars (49 CFR 571.120), and asked whether kilograms and pounds can be abbreviated kg and lb respectively. The answer is yes.

Subsection S5.3, Label information, requires that each vehicle other than passenger cars shall show tire and rim labeling as specified in S5.3.1 and S5.3.2 respectively, "in the format set forth following this section." Examples of the required labeling are set forth following paragraph S5.3.2, entitled "TRUCK EXAMPLE -- SUITABLE TIRE-RIM CHOICE." In those examples the words "kilograms" and "pounds" are spelled out, with no indication that abbreviations may be used.

The labeling is required to be shown "in the format" set forth in the examples. In a denial of a petition for reconsideration and denial of a petition for rulemaking concerning our child seat standard published in the Federal Register on June 4, 1993 (58 FR 31658) (extract enclosed), NHTSA stated:

Format refers to the general appearance of the form and to aspects such as type size, size and placement of margins, size and placement of the spaces for the consumer's name and address, and overall organization of the printed material.

Since no reference is made to the use of abbreviations, it is our opinion that the requirement that the specified labeling be "in the format" shown at the end of the section does not prohibit the use of appropriate abbreviations.

For the sake of brevity, NHTSA has always routinely used abbreviations throughout its standards, especially on prescribed labels. This saves scarce space on such labels and the more commonly used abbreviations, such as "kg" for kilograms and "lb" for pounds, are widely known and recognized by the public. Accordingly, those abbreviations are tantamount to the full spelling of those words and may be used interchangeably with the full spelling of those words in the labeling required by S5.3, Standard No. 120.

I hope this information is helpful to you. Should you have any questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992, fax (202) 366-3820.

Sincerely,
John Womack
Acting Chief Counsel
Enclosure
ref:120
d.3/19/98