Interpretation ID: speedrestrictedtires

Stephen M. Padula
Michelin North America
One Parkway South
P.O. Box 19001
Greenville, SC 29602

Dear Mr. Padula:

This responds to your letter asking whether a manufacturer may make certain statements about using 315/80R22.5 LR L truck tires marked with a 55 miles per hour (mph ) speed restriction on the sidewall ("speed-restricted tires") at speeds above 55 mph. You note that a competitor has made these or similar statements in technical information about the tires, and you want to know whether the statements are permitted. Our answer is the statements are not permitted for speed-restricted tires.

You ask about two statements in the manufacturers technical information about the tire. The first concerns information stating that the tire bearing a maximum speed marking of 55 mph, rated at 10,000 pounds/tire at a cold pressure of 130 psi "may not be operated at a sustained speed in excess of 55 mph. Sustained speed is defined as continuous operation at that speed for over one hour. The absolute maximum speed for tires with 55 mph speed restrictions is 65 mph." The second relates to statements that the "tires are speed restricted as listed below [55 mph]. This is due to very high loads associated with these Load Range L tires. When these tires are operated at or below the Load Range "J" (18 PR) loads, they can be operated at 65 mph and the listed speed restriction does not apply."

Standard No. 119, New Pneumatic Tires for Motor Vehicle Other Than Passenger Cars (49 CFR 571.119), permits speed-restricted tires, but only under certain conditions. Under S6.5(e) of the standard, the speed restriction must be marked on the tire sidewall. In describing the information that must be marked, S6.5(e) states: "The speed restriction of the tire, if 55 mi/h or less, shown as follows: Max speed ____ mph."^[1] In other words, the speed restriction must not exceed 55 mph. Speed-restricted tires are generally excluded from the high speed performance requirements of S6.3 of Standard No. 119. In addition, they are subject to a less stringent endurance test schedule (a lower test speed and fewer total revolutions of the test wheel), as shown in Table III of the standard. Since the requirements for speed-restricted tires reflect their anticipated speed-restricted use, it is important that there is an appropriate safeguard ensuring that the tires will not be used at higher speeds. Labeling the tires with a maximum 55 mph speed restriction helps to ensure that the tires will not be used under conditions exceeding the speed restriction marked on the tires.

The first group of statements you describe instruct that the tire may be operated at speeds up to 65 mph for periods not to exceed one hour. We believe that the statements about using the tires at speeds up to 65 mph conflicts with the 55 mph speed restriction labeled on the tire. If the statements are provided, we will not consider the tire to be speed-restricted since it is recommended for use above 55 mph. Thus, the tire would have to meet the requirements that apply to a non-speed-restricted tire.

The second group of statements includes an instruction that, "When these tires are operated at or below the Load Range J (18 PR) loads, they can be operated at 65 mph and the listed speed restriction does not apply." We would not consider the tire to be speed-restricted when the manufacturer has provided that statement. The tire would be tested to the requirements for non-speed-restricted tires under the appropriate load.

I hope this information is helpful. If you have any questions or need additional information, feel free to contact Nancy Bell of my staff at (202) 366-2992.

ref:119

d.8/6/02

^[1] Effective May 27, 2003, this section will read: "The speed restriction of the tire, if 88 km/h (55 mph) or less, shown as follows: Max speed __ km/h (___mph)."