Interpretation ID: aiam0516
Esq.
Phillips Petroleum Company
Bartlesville
OK 74004;
Dear Mr. Macmanus: This is in reply to a request made on behalf of Phillips Petroleu Company by Veigh J. Nielson for an assigned identification mark for two of Phillips' plants which manufacture tires for research purposes.; As I informed you in my letter of September 20, 1971, if Phillip purchases a new tire, removes the tread material and then applies its own experimental tread containing various rubber compounds, Phillips is considered to be a new tire manufacturer. If Phillips applies its experimental tread to a used tire, it is considered a retreader of tires.; As a new tire manufacturer you are required to certify the tire a conforming to the new passenger car tire standard (No. 109) and comply with Part 574 - Tire Identification and Record Keeping (49 CFR 574). Accordingly, you are assigned the identification mark of 'J1' for tires made in your Bartlesville, Oklahoma plant and 'K1' for tires manufactured in your Stow, Ohio plant.; If you act as a retreader then Part 574 would not be applicable for th tires you retread because they are retreaded for your own use. (Enclosed is a copy of Docket No. 70-12, Notice No. 8 which makes the regulation inapplicable to retreaders who retread for their own use). As explained in my letter of September 20, you are, of course, required to certify that your new tires and your retreaded tires comply with the respective standards for new and retreaded tires if they are to be used on the public highways, by placing the symbol DOT on the tires in the prescribed location.; Sincerely, Lawrence R. Schneider, Chief Counsel