Interpretation ID: aiam0304
Patton
Blow
Verrill
Brand & Boggs
1200 17th Street
N.W.
Washington
DC 20036;
Dear Mr. Verrill: This is in reply to your letter of February 16, 1971, concerning th Tire Identification and Record Keeping Regulations, and your letter of March 12, 1971 submitting additional information.; Section 574.10 requires manufacturers to keep records of tires shippe 'on or in' a vehicle. This would cover the case you describe of tires shipped on a trailer, whether attached to the axle or merely strapped to the frame, providing that the tires were meant for use on that particular trailer.; If the tires are shipped separately, either attached to another traile or shipped in a separate package, they are not considered to be shipped 'on or in' the trailer within the meaning of section 574.10. Therefore, the provisions of section 574.9(b) would apply and the dealer would be required to record the appropriate tire information and communicate it to the tire manufacturer.; If the tires are shipped separately, under Part 574 the traile manufacturer would not be required to keep the records of the tires shipped. However, under section 113(f) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1402), the manufacturer is responsible for maintaining the name and address of the first purchaser. A copy of the Act and the recent amendment to the Act, section 113, which added subsection (f), are enclosed for your information.; Should you so desire, you may submit a petition for rulemaking on thi subject under our rulemaking procedures (49 CFR 553).; Sincerely, Lawrence R. Schneider, Acting Chief Counsel