Interpretation ID: nht76-1.49
DATE: 12/08/76
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Kelsey-Hayes Company
TITLE: FMVSS INTERPRETATION
TEXT: This responds to Kelsey-Hayes' April 21, 1976, question whether motor vehicle rims that are labeled in conformity with the requirements of Standard No. 120, Tire Selection and Rims for Vehicles Other Than Passenger Cars, may be installed on passenger cars.
The requirements of S5.2 of Standard No. 120 for labeling of rims for use on multipurpose passenger vehicles, trucks, buses, trailers, and motorcycles do not affect the use of those rims on passenger cars. This situation would change if Standard No. 110, Tire Selection and Rims, is modified in the future to prohibit one or more of the items required by S5.2, but such an eventuality is considered to be unlikely.
Sincerely,
ATTACH.
KELSEY-HAYES COMPANY
November 9, 1976
Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration
RE: Request for Interpretation: FMVSS-120
Dear Mr. Berndt:
We requested an interpretation on this safety standard in April, 1976 and have not yet received a reply. A copy of my April 21 letter is enclosed for reference.
May we hear from you soon on this matter? We have some pressing business decisions to make.
Very truly yours,
John F. McCuen
enclosure
KELSEY-HAYES COMPANY
April 21, 1976
Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration RE: Request for Interpretation - FMVSS-120 Non-Passenger Car Rims
Dear Mr. Berndt:
Kelsey-Hayes Company is a domestic manufacturer of motor vehicle equipment including rims for passenger car, truck, and other vehicle applications.
We make some rims that are used for both original equipment passenger cars and original equipment recreational trailers. As we understand the provisions of FMVSS-120, such a rim, when manufactured and sold for use on a trailer, must conform to FMVSS-120. It is not clear, however, whether rims conforming to FMVSS-120 may also be used on new passenger cars.
We envision circumstances under which a rim marked in conformance with FMVSS-120 is inadvertently shipped to a passenger car assembly plant for use on a new passenger car. We seek your interpretation of whether or not a manufacturer of passenger cars may use rims conforming to FMVSS-120. Assuming there is a safety benefit to the marking of rims for use on vehicles other than passenger cars, we assume those benefits are comparable when the same rim is used on a passenger car. This apparent benefit would seem to outweigh the costs associated with segregating identical wheels as a factor of the customers to whom we ship them to.
Accordingly, (Illegible Words) which would enable us to sell (Illegible Words) to FMVSS-120 for original equipment passenger car applications.
Very truly yours,
John F. McCuen