Interpretation ID: aiam1800
B. F. Goodrich Tire Co.
500 South Main Street
Akron
OH 44318;
Dear Mr. Bartlett: This letter reviews for conformity with statutory requirements a draf defect notification letter received by my office regarding Goodrich's impending notification campaign for tires retreaded by B. F. Goodrich using carcasses branded 'General Belted Jumbo 780.'; As you are aware, defect notifications issued on or after December 26 1974, are required to comply with the requirements in section 153 of the 1974 amendments to the National Traffic and Motor Vehicle Safety Act (Public Law 93-492, 88 Stat. 1470). We have the following changes to recommend in your draft notification.; Section 153(a)(5) requires the notification to specify 'the earlies date . . . on which such defect or failure to comply will be remedied without charge, and in the case of tires, the period during which such defect or failure to comply will be remedied without charge . . .' We believe this requirement should be met by specifying the actual earliest date by which dealers will have necessary replacement parts and instructions, and by informing owners that they have 60 days from that date (or 60 days from the day they receive the notification, whichever is later) to obtain replacement free of charge.; You must also include information that is responsive to sectio 153(a)(6). As the procedures referred to in that section have not been published, it is sufficient if you advise owners that they may write to the Administrator, National Highway Traffic Safety Administration, Washington, D.C. 20590, if they find B. F. Goodrich, its distributors, or dealers, to have failed or to have been unable to perform the replacement satisfactorily.; In other respects we find your letter to conform to the statutor requirements.; Yours truly, James C. Schultz, Acting Chief Counsel