Interpretation ID: aiam2653
House of Representatives
Washington
D.C. 20515;
Dear Mr. Gudger: Please excuse the delay in my response to your letter of June 15, 1977 addressed to Mr. Norman Sultan, with a copy to the National Highway Traffic Safety Administration (NHTSA) regarding the Federal requirement for registration of tires.; Mr. Sultan has reported a tire registration of 10 percent in his are of operation which is considerable less than the national figures of 30 percent for retreads and 70 percent for new tire replacements developed in our studies. Mr. Sultan is urging a change in the law to permit voluntary registration of all tires.; Mr. John Snow, my predecessor, reported to the Honorable Warren G Magnuson, Chairman of the Committee on Commerce, U.S. Senate, that consideration would be given to changing Regulation Part 574 allowing voluntary registration of retreaded tires in lieu of mandatory registration. Since taking office, I have devoted considerable attention to reviewing and analyzing the pertinent factors related to tire registration. I am convinced of the safety benefits of registering new tires and I consider the mandatory recordkeeping provision essential to the purpose of the Vehicle Safety Act. However, because retreaded tires are individually manufactured and therefore could not be recalled as are mass produced items, I am considering proposing revocation of the mandatory recordkeeping requirements for retreaded tires.; For your information I am enclosing a copy of my recent letter t Senator Magnuson in response to his questions on this subject.; You may be interested to know that a recent meeting wit representatives of the National Tire Dealers and Retreaders Association (NTDRA) provided an opportunity to discuss basic clerical problems associated with registration. As a result, an interpretation of the regulation was reached which would permit the tire purchaser personally to complete the registration form. Although dealer responsibility remains, the interpretation is considered by NTDRA to provide considerable relief to dealers in time and cost. Hopefully this action will offset much of the objections to the current tire registration process.; Sincerely, Joan Claybrook