Interpretation ID: aiam0269
Esq.
Assistant Counsel
B.F. Goodrich Company
500 South Main Street
Akron
OH 44318;
Dear Mr. Morgan: This is in reply to your letter of November 20, 1970 concerning you telephone conversation with Mr. Schmeltzer of my office, relating to the Tire Identification and Record Keeping Regulations (Docket No. 70-12, Notice No. 2).; You are not completely correct in your understanding that, as a resul of the tire identification regulations, the DOT symbol will only be required on the sidewall of the tire where the identification number will appear. As indicated in the preamble of the notice of proposed rulemaking on these regulations, it is anticipated that the identification number required by the regulation will replace the manufacturer's identification number required by Standard No. 109. However, no decision has been made as yet whether Standard No. 109 will also be amended to require the 'DOT' symbol on only one sidewall of the tire.; You are correct in your understanding that the regulations were no intended to restrict the third grouping of characters, the optional tire type code, to three symbols (sic) In addition, you are correct in your understanding that a tire manufacturer will receive individual identification numbers for each of its tire manufacturing and retread plants.; Under the regulations, B.F. Goodrich will not be required to apply fo identification marks for Goodrich owned brand name tires if sold and controlled by them.; Concerning your question as to what class of certified mail would b required in the event of a recall, a notification letter sent by certified mail to the addressee, himself, would be preferable but is not, at this time, required by the Act or any regulation issued thereunder.; Thank you for your interest. Sincerely, Lawrence R. Schneider, Acting Chief Counsel