Interpretation ID: aiam3190
Ltd.
Hiratsuka Plant
P. O. box 20
Hiratsuka-shi
Kanagawa-ken 254
Japan;
Dear Sirs: Your September 10, 1979, letter to our Tire Division has been referre to me for reply, since you are requesting an interpretation of Federal Motor Vehicle Safety Standard No. 119 (49 CFR S 571.119)/ You asked two questions in your letter. First, you asked whether the definition you offered for 'maximum speed' was correct. If it was correct, you stated that the tire could exceed the speed restriction shown o the tire at a lighter load, ad showed how the information could be set forth on the tire. The listing of varying maximum loads at different maximum speeds is not permitted to appear on the tire. Second, you asked if speed restricted tires could specify a speed restriction other than the 35, 50, and 55 mile per hour (mph) restrictions shown in the endurance test schedule of Standard No. 119. The answer to this question is no.; Regarding you first question, you defined a tire's maximum speed as the highest speed at which a tire can carry the maximum single load that is molded on the tire sidewall.' This definition is an acceptable one for tires with a speed restriction listed for them. However, you went on to note that if this definition was acceptable, the a tire could list varying maximum loads at varying maximum speeds. Such a listing is expressly prohibited by the language of Standard No. 119.; S6.5 of Standard No. 119 specifies that each tire subject to th Standard shall be marked with the information that is set forth in the (sic) following paragraphs. Paragraph (d) of S6.5 requires the maximum load rating and corresponding inflation pressures for single load tires, the type of tire about which you are inquiring, to appear as: Max load * * lbs. at * *psi cold. Paragraph (e) of S6.5 requires that a speed restriction on the tire appear only as: max speed * *mph. Hence, a single load tire can be labeled with only one maximum load and only one maximum speed.; Your second question was whether a manufacturer could restrict th speed of a tire subject to Standard No. 119 to a speed other than the three speed restrictions shown in Table III of the Standard. Paragraph S6.1 requires all ties to pass the endurance test requirements of the Standard, and Table II shows the load and speeds to which the tires will be subjected during the endurance test. If the tire being subjected to the endurance test does not qualify for the special speeds and load as one of the three speed restricted tires shown in the table or as a motorcycle tire, the tire would be tested at the speed and load shown under the heading 'All other'. This would mean that the tire's speed restriction would be ignored for purposes of the endurance test, and it would be tested as if it were a non-sped restricted tire. Such conditions, and no tire which fails to pass the endurance test can be sold in the United States. As a practical matter, therefore, speed restrictions other than the three shown in Table III of the Standard are not recognized by this agency.; The three speed restrictions shown in Table III of the Standard wer adopted from descriptions of three types of speed restricted tires sued by the United States tire industry in 1972, when the agency was initially promulgating Standard No. 119. If your company would like to add another speed restriction to those shown in Table III, you should file a petition for rulemaking with this agency requesting an amendment to Standard No. 119.; Sincerely, Frank Berndt, Chief Counsel