Interpretation ID: nht75-2.20
DATE: 08/25/75
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Firestone Tire & Rubber Company
TITLE: FMVSS INTERPRETATION
TEXT: I am writing to confirm the interpretation of Federal Motor Vehicle Safety Standard No. 119, New pneumatic tires for vehicles other than passenger cars, which was given to you by Mark Schwimmer on April 16, 1975.
Your letter of February 26, 1975, explained that:
(i) Firestone would produce 100 tires in size D50C-16.5 for use on one of the prototype vehicles in the Urban Mass Transit Administration's Trans-Bus program;
(ii) these tires would be certified as being in compliance with Standard No. 119; and
(iii) D50C-16.5 is a new size, not appearing in any existing tire and rim organization publications.
In such cases, S5.1(a) of the standard requires tire and rim matching information to be furnished to dealers of the manufacturer's tires. Your letter suggested that, because Firestone does not expect the tire to be sold through any dealers, this requirement would be inapplicable. As Mr. Schwimmer explained, that interpretation is incorrect. S5.1 of Standard No. 119 applies to all new bus tires, including prototypes manufactured for prototype vehicles. Therefore, you must furnish the matching information to all dealers of Firestone non-passenger-car tires.
Sincerely,
ATTACH.
February 26, 1975
Mark Schwimmer, Attorney -- Office of Chief Counsel, National Highway Traffic Safety Adm.
RE: TIRES FOR UMTA TRANS BUS PROGRAM
Dear Mr. Schwimmer:
As I advised you in our telephone conversation, Firestone has the contract to produce tires for the prototype vehicles being tested by UMTA currently. We have received an order for an additional 100 tires in size D50C-16.5 for use on the prototype manufactured by The Rohr Industries. Since these tires will be produced after March 3rd, they will be certified by Firestone as being in compliance with FMVSS 119.
Size D50C-16.5 is a new size and is not included in any list showing tire and rim matching information. FMVSS 119 specifies in Section S5.1(a) that where such information is not published in the documents listed it is to be supplied to dealers and to NHTSA.
By copy of the attached letter to the Tire Division, NHTSA, we are supplying the necessary information to NHTSA. However, since we have orders for only 100 tires to be used only on the prototype vehicle and since it is our understanding from the prime contractor that the test will be terminated at the end of this year, thereby precluding any possibility of this size being sold for this purpose through any dealers, we are not planning to send copies of the tire and rim matching information to our dealers.
May I have your confirmation that we will be acting within your interpretation of FMVSS 119 in this matter?
As you know, the testing of the three prototype buses is under the control of UMTA. It is not anticipated that any additional tires will be needed for the other two prototypes, however, if the prime contractors should order additional tires it would most likely be under the same conditions as the order received from Rohr Industrial and we would follow the same procedure as it is agreed will be acceptable with the D5OC-16.5 tires.
In view of the fact that an order has been placed with us, it would appear that the prime contractor anticipates a need in the near future. Therefore, we would appreciate your prompt attention to this matter.
Sincerely, A. J. DiMaggio -- QUALITY ASSURANCE, FIRESTONE
February 26, 1975
The Tire Division National Highway Traffic Safety Adm.
Gentlemen:
Pursuant to Section S5.1(a) Motor Vehicle Safety Standard 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, this is to advise that tire size D50C-16.5 is to be used with a 6.0 x 16.5 rim.
This size tire is not listed in any of the publications of the organizations listed in FMVSS 119.
Very truly yours, A. J. DiMaggio -- QUALITY ASSURANCE, FIRESTONE