Interpretation ID: aiam0624
Esq.
Nance
Caston
Hefner and Green
Attorneys at Law
421 North Crockett Street
Sherman
TX 75090;
Dear Mr. Hefner: This is in reply to your letter of January 25, 1972, concerning th certification of new trailers which your client manufactures. You state that some of these trailers are shipped (to customers) equipped with used tires that are intended primarily to be used to ship the trailers to their destination, and ask whether these tires should be taken into account in the values for GVWR and GAWR on the certification label.; We do not consider that temporary tires attached to a vehicle fo purposes of shipment should be reflected in the GVWR and GAWR on the certification label, if these tires are not intended to be part of the completed vehicle. consequently, we would expect trailers shipped with such tires to be treated similarly for purposes of certification as vehicles for which no tires have been provided. In such a case, the complete vehicle manufacturer, as indicated in the preamble to the Certification regulations (April 14, 1971, 36 F.R. 2054) must still bear responsibility and certify the vehicle, even though he does not install the tires with which the vehicle will ultimately be equipped. We suggest that one manner in which this could be accomplished by the manufacturer is to list GAWR and GVWR for the optional tire sizes which he recommends in accordance with the amendment to the Certification regulations published December 10, 1971 (35 F.R. 23571). The manufacturer should make it clear to the purchaser of the vehicle that the temporary tires should be replaced when the vehicle is put into use.; We are pleased to be of assistance. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs;