Interpretation ID: aiam1278
Robertson Tank Lines Inc.
P. O. Box 1505
Houston
TX 77001;
Dear Mr. Hayes: This is in reply to your letter of August 30, 1973, requesting a DO code number for retreaded tires you manufacture. It appears from your letter that the tires you retread are truck tires intended solely for your company's own use.; Any tires retreaded by and solely for use by Robertson Tank Lines ar exempt from NHTSA recordkeeping requirements and a code number is not required. As truck retreads are not subject to any Federal motor vehicle safety standard, you are also not required to place a 'DOT' symbol on them. If you retread passenger car tires, however, you are required to place a 'DOT' symbol on the tire sidewall (indicating conformity to Federal Motor Vehicle Safety Standard No. 117).; Yours truly, Richard B. Dyson, Assistant Chief Counsel