Interpretation ID: aiam2589
Engineering Manager
TTMA
2430 Pennsylvania Avenue
N.W.
Washington
D.C. 20037;
Dear Mr. Vierimaa: This responds to your March 16, 1977, letter in which you ask for a interpretation of the certification label requirements of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*, as they apply to trailers.; In your first question, you ask whether a trailer manufacturer ma conform with the certification requirements in any one of three ways: list the GVWR and GAWR with the corresponding tires, rims, and inflation pressure with which the trailer is equipped, list all suitable combinations with the required information as shown in the example appearing in Standard No. 120, or list only the maximum GVWR and maximum GAWR with the proper tires, rims, and inflation pressure, plus the GVWR and GAWR of the trailer with the tires, rims, and inflation pressure with which it is equipped.According to the requirements of Standard No. 120, any of the three methods outlined above would appear to be acceptable. Your second question presents a sample certification plate which lists all of the axles on the trailer. You ask whether it is permissible, where the data for all axles is identical, to list the proper tires, rims, and inflation pressure for the front axle then merely state 'Same as Front' for the remaining axles rather than repeat the same data for all axles. The label requirements of the standard do not permit the approach you suggest. You must list all data for each axle. You should note that there is a proposal to amend Part 567, *Certification*, to permit a simplification of label requirements when the data for all axles is identical. I am enclosing a copy of this proposal for your information.; Sincerely, Joseph J. Levin, Jr., Chief Counsel