Interpretation ID: nht78-1.21

DATE: 10/02/78

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

TO: Dunlop Tire Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 10, 1978, letter asking whether it is permissible to label motorcycle tires with alternate speeds and load ratings appropriate for those speeds. You suggest that your tires be labeled with maximum speeds of 131, 137, and 143 miles per hour with the corresponding load ratings. The labeling of motor cycle tires is regulated by Standard No. 119, New Pneumatic Tires for Vehicles Other (Illegible word) Passenger Cars.

Standard No. 119 requires that tires be marked with, among other things, the maximum inflation pressure of the tire and the load rating applicable to that inflation pressure. Speed qualifications are permitted on tires when, for example, the tires are speed restricted. Otherwise, tires are not marked with speed criteria although they may be marked with the symbols S, H, or V as part of the tire identification number. These symbols, established by the European Tyre and Rim Technical Organisation (ETRTO), indicate that the tire is an acceptable high-speed tire.

The National Highway Traffic Safety Administration considers it appropriate to permit the symbols S, H, or V to be marked on tires to indicate that such tires are appropriate for high-speed use. This permits, for example, a sophisticated purchaser of tires for emergency vehicles to know that the tires are suitable for the higher operational speeds necessary for those vehicles. The NHTSA, however, considers it inappropriate to mark motorcycle tires with maximum speeds of 131, 137, and 143 miles per hour with the corresponding safe load ratings. Such markings would appear to sanction the use of the tires at these speeds which far exceed the national speed limit.

Since Standard No. 119 regulates the permissible uses of speed designations on nonpassenger car tires, the agency interprets the standard to prohibit the marking of any other speed designations on a tire. The NHTSA considers the only appropriate speed designation on tires to be one that reflects a speed restricted tire or one that uses the symbols established by the ETRTO for tires that have been tested and can be operated at higher speeds.

Sincerely,

ATTACH.

July 10, 1978

J. Levin -- Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Levin:

Dunlop Tire and Rubber Corporation has been asked to manufacture tires for new Honda motorcycles with several load designations appearing on the tire sidewall. The loads vary according to the speed imposed on the vehicle as follows: (These are all V rated tires).

Front Tire Rear Tire Inflation Pressure Max. MPH 3.50V19 4.25V18 Maximum 131 515 Lbs. 655 Lbs. 42 psi 137 490 Lbs. 620 Lbs. 42 psi 143 465 Lbs. 585 Lbs. 42 psi

I have discussed this subject briefly by telephone with Mr. A. (Illegible Word) who urged me to write for your legal interpretation of FMVSS 119 and how to identify these supplementary loads on a tire sidewall.

As I will be out of the office until July 24, please contact Mr. A. M. Mills if additional information is required. His direct phone is (716) 879-8397.

Very truly yours, DUNLOP TIRE & RUBBER CORPORATION; Richard H. Attenhofer -- Manager - Tire Technical Relations

cc: A. M. Mills