Interpretation ID: aiam0361
Jr.
Group Supervisor
Engineering Services
Blue Bird Body Company
Fort Valley
GA 31030;
Dear Mr. Phelps: This letter is to further clarify an interpretation contained in ou letter of May 6, 1971, concerning the Tire Identification and Record Keeping Regulation.; We wish to make it clear that although the final-stage manufacturer ma designate someone to maintain the records required under section 574.10 of the Tire Identification and Record Keeping Regulation, the legal responsibility for maintaining the records remains with the final-stage manufacturer.; However, the incomplete vehicle manufacturer, or any intermediat manufacturer, may assume 'legal responsibility for all duties and liabilities imposed on manufacturers by (the Act) with respect to the vehicle as finally manufactured . . .' (49 C.F.R. 568.7). In such a case, the responsibilities for maintaining the records required by the Act and by the Tire Identification and Record Keeping Regulation will be assumed by the incomplete vehicle manufacturer, or any intermediate manufacturer, and the final-stage manufacturer will be relieved of all liability for maintaining the records.; We would also point out that the Tire Identification and Record Keepin Regulation was not meant to preclude the use of multiple designees for the maintenance of the required records. See the enclosed interpretation issued on May 28, 1971 (36 F.C. 9780).; Sincerely, Lawrence R. Schneider, Acting Chief Counsel