Interpretation ID: nht78-1.22

DATE: 09/22/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Dunlop Tire Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 2, 1978, letter noting two standards of the National Highway Traffic Safety Administration that you consider to be in conflict. You suggest that Part 569, Regrooved Tires, conflicts with Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, in their requirements for the size of the molding of the word "regroovable".

Standard No. 119 specifies all of the labeling of tires for motor vehicles other than passenger cars. The size of that required labeling is set at not less than .078 inches. This size provision applies generally to all of the various information required to be labeled on a tire. The information labeled on the tire includes the tire identification number and word "regroovable" if appropriate. Both of these requirements, however, are subjects of their own regulations. The tire identification number is specifically regulated by Part 574 and regroovable tires are regulated by Part 569. Each of these Parts further specifies the size designation of the information that it requires. For example, Part 569 specifically requires the word "regroovable" to be in letters .38 to .50 inches in height.

The two standards do not conflict. The size requirement in Part 569 falls within the acceptable size levels of Standard No. 119. Part 569 merely further restricts the size of the word "regroovable" beyond that specified in Standard No. 119. Accordingly, the two are consistent. To understand both requirements, apply the general size requirements of Standard No. 119 to all information that is not otherwise regulated elsewhere. For information specifically regulated elsewhere, apply the size criteria specified in the applicable regulation.