Interpretation ID: aiam2038
Jr.
Flenniken Financial Services
Inc.
515 Market Street
Knoxville
Tennessee 37902;
Dear Mr. Howard: This responds to your letter of July 1, 1975, concerning the lega duties of a tire recapping firm which you insure.; For your convenience, I have enclosed a copy of Federal Motor Vehicl Safety Standard No. 117, *Retreaded Pneumatic Tires*. This standard does not specify the testing which a manufacturer of retreaded tires must do, it does specify the criteria which the tires must meet when tested by the National Highway Traffic Safety Administration (NHTSA) for compliance. While the surest way for the retreader to be confident of compliance would be to follow the procedures in every detail, he is not legally obligated to do so. Section 108 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, requires him to assure himself that, when tested by the NHTSA according to the procedures set out in the standard, his tires will meet the specified criteria. In addition, he is required to repair or replace without charge a non-complying tire.; Sincerely, Frank A. Berndt, Acting Chief Counsel