'Part II - 12.b.(5) - 75% or more of the tread width loose or missing in excess of 12 inches (30.4 cm) in circumference does not specify if the "in excess of 12 inches" needs to be in one continuous section or if multiple sections, 12 inches or less, can be added together to get to the "in excess of 12 inches".

In addition, Part II - 12.b.(5) places a vehicle OOS when "75% or more of the tread width is loose or missing in excess of 12 inches (30.4 cm) in circumference" on all tires other than those found on the front steering axle(s) of a power unit.

There is no prohibition in Title 49 against having a recapped/retreaded tire on the front steering axle(s) of a truck or truck tractor. When loose or missing tread is encountered on the front steering axle(s) of a truck or truck tractor, an inspector can only cite a violation and then must allow the vehicle to proceed, as opposed to being able to place a motorcoach OOS with the same condition.

Both Title 49 and the OOSC hold the tires found on the front steering axle(s) of a power unit to at least the same standard, if not higher, as the tires found on axle(s) other than the front steering axle(s) of a power unit, except in this instance.

Clarification for Item 12.b.(5) and uniformity by adding it to the front steering axle section in 12.a.

Specify whether the "in excess of 12 inches" must be in one continuous section and/or multiple sections that, when added, exceeds 12 inches. Also, add the same or similar condition and clarification to Item 12.a. that is appropriate for a steering axle.