Interpretation ID: aiam0296

Mr. David J. Humphreys, Washington Counsel, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC 20006; Mr. David J. Humphreys
Washington Counsel
Recreational Vehicle Institute
Inc.
Suite 406
1140 Connecticut Avenue
Washington
DC 20006;

Dear Mr. Humphreys: This is to confirm your interpretation of the Tire Identification an Record Keeping Regulations as expressed in your letter of February 18, 1971.; The vehicle manufacturer is responsible for the retention of records o tires shipped 'in or on' a new vehicle. However, if the vehicle is used to transport extra tires, the manufacturer is not obliged to retain records of those tires, but rather, the vehicle dealer will be responsible for communicating the appropriate information to the tire manufacturer in accordance with either section 574.8 or section 574.9 of Part 574.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel