Interpretation ID: aiam2328
President
Little Dude Trailer Company
Inc.
P.O. Box 4513
Fort Worth
Texas 76106;
Dear Mr. Rogers: This is in response to your March 26, 1976, letter concerning th certification label requirements in S5.3 of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; You have pointed out that the example shown in S5.3 presents rim inflation, and maximum speed information after the Gross Vehicle Weight Ratings (GVWRs) as well as after the Gross Axle Weight Ratings (GAWRs). You have suggested that the text of S5.3 merely requires such information to appear after the GAWRs and urged such an interpretation. It appears that you have misunderstood the text.; In its present form, S5.3 requires each listed GVWR and GAWR to b followed by the information specified in paragraphs S5.3(a) through (d). Paragraph (a) is divided into subparagraphs (a)(1) and (a)(2) in order to specify different items to follow GVWR and GAWR, respectively. Paragraphs (b) through (d) (which specify rim, inflation, and maximum speed information) are not subdivided because the same items are intended to follow GVWR and GAWR.; Several petitions for reconsideration of the standard have requeste and amendment of S5.3 to eliminate the requirements that tire and rim information appear after the GVWR. Your suggestions on this matter, as well as the other suggestions in your letter, are being considered by the National Highway Traffic Safety Administration in the preparation of its response to those petitions.; Please note that the effective dates of several of the standard' requirements, including that of S5.3, were delayed in a Federal Register notice published on May 6, 1976 (41 FR 18659, Docket No. 71-19, Notice 4). A copy of that notice is enclosed for your convenience.; Yours truly, Stephen P. Wood, Assistant Chief Counsel