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Interpretation ID: aiam2505

Lt. C.R. Townsend, Director Motor Vehicle Inspection Division, Oklahoma Department of Public Safety, 3600 north Eastern, P.O. Box 11415, Oklahoma City, Oklahoma 73111; Lt. C.R. Townsend
Director Motor Vehicle Inspection Division
Oklahoma Department of Public Safety
3600 north Eastern
P.O. Box 11415
Oklahoma City
Oklahoma 73111;

Dear Lt. Townsend: This is in response to your December 16, 1976, letter concerning tire marked 'Reno Farm Tire--Farm Use Only' that are appearing on some passenger cars in Oklahoma. I understand that the DOT symbol is also marked on the sidewalls of these tires, as a certification of conformity to Federal Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires--Passenger Cars*.; Paragraph S6 of the standard precludes the manufacture of farm tires i passenger car tire sizes unless those tires conform to and are certified as conforming to all aspects of the standard. There is not, however, any provision in Standard No. 109 that prohibits the additional marking that you have described on a tire that is manufactured and sold for passenger car use. No safety issue appears to be presented by this situation.; You have also asked who is responsible for compliance with the Tir Identification and Recordkeeping regulation (49 CFR Part 574, copy enclosed). That regulation creates various obligations for tire manufacturers, motor vehicle manufacturers, motor vehicle dealers, and others. Where(sic) a tire manufacturer sells tires to a trailer manufacturer, the presence of the 'Farm Use Only' marking has no effect on those obligations.; Sincerely, Frank A. Berndt, Acting Chief Counsel