Interpretation ID: nht91-6.43

DATE: October 30, 1991

FROM: Edward M. Klisz -- Chief, Light Tactical Vehicle Branch, Department of the Army, U.S. Army Tank Automotive Command

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 1/17/92 from Paul Jackson Rice to Edward M. Klisz (A39; Std. 119; Part 574)

TEXT:

Reference is made to a telephone conversation between Mr. Marvin Shaw of your office and Mr. Edward Klisz of the U.S. Army Tank-Automotive Command (TACOM) on 25 Oct 91, regarding foreign made tires procured in Southwest Asia (SWA) during Operation Desert Storm/Desert Shield.

As indicated during the telephone conversation TACOM (as the Department of Defense's (DOD) designated tire manager) is trying to ascertain the suitability for Army use of foreign made tires procured while units were in SWA. Some of these tires had DOT markings on them and some did not. Enclosed is a listing of tires currently stored at Fort Stewart, GA. Request your office review this list and determine if the DOT codes are accurate according to your records.

We are also interested in understanding the process better. It is our understanding that foreign manufacturer's must register with your office to obtain a certification number which would signify that the tire will meet the Federal Motor Vehicle Safety Standards (FMVSS). When the tires enter the U.S., the importer, in-essence, becomes the manufacturer and is responsible for the certification of the tires. Further, we understand that the process is a self-certification process and there may be some random testing done. Request you correct any misunderstanding we may have or enlighten us further on how the process works and any pitfalls we should be aware of.

We would appreciate a reply by 15 Nov 91 so that we can act as expeditiously as possible to dispose of any unsafe tires.