Interpretation ID: nht93-1.39

DATE: February 18, 1993

FROM: Marty D. Pope -- President, Wheels "R" Rollin, Inc.

TO: Walter Meyers -- Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3-30-93 from John Womack to Marty D. Pope (A40; Std. 120)

TEXT: Per our conversation on Motor Vehicle Safety Standards #120, S5.2, let me take a few minutes of your time to explain how this law is and will be affecting our business. Our company, Wheels "R" Rollin, Inc., refurbishes vast amounts of wheels that we obtain from numerous salvage yards. Most of the vehicles these wheels were removed from range from 1970 to 1993 vehicles. We blast the wheels down so we can put on a new finish on them. To give you an example of the business I have built, in 1992 we refurbished and sold over 100,000 wheels, 1993 promises to be even a better year. The wheels that my company refurbishes are sold to utility trailer manufacturers for use on their utility trailers. We have been in the trailer business for 15 years, in the wheel business for four years, all at the same location. We have over $100,000 in equipment to use to refurbish wheels. I employ eight people in the wheel shop. Our goal is to purchase $200,000 more in equipment. This equipment will employ at least five more people. This law went into effect in 1977, and up to this point I have not had a problem concerning this. This has put a hold on my business.

I am willing to comply to government regulations, but we need to know how to comply and what we can do to bring the wheels manufactured before 1977 up to standards. At the present time we have 10,000 wheels in stock, with 10% of the wheels in stock having the D.O.T. stamping on them. Is it a possibility to stamp the wheels previous to 1977 with a regulation code to approve their usability? In the past week orders have been placed for 24,000 wheels. As you can see my stock of D.O.T. stamped wheels and my orders do not come close. Please, I am needing your input on which avenues to take, and any help you can give us to save what it has taken hard work to build.

Mr. Myers, your immediate attention to this matter is needed and will be greatly appreciated, so I can keep the eight individuals employed and keep my production on line.

If I can offer any further information concerning this, please do not hesitate to call me.