Interpretation ID: aiam2556
Chairman
Commission on Federal Paperwork
1111 Twentieth Street
N.W.
Washington
DC 20582;
Dear Mr. Chairman: This responds to your March 9, 1977, letter requesting a copy of th report prepared by the National Highway Traffic Safety Administration (NHTSA) in response to the Senate Commerce Committee's inquiries concerning the recordkeeping requirements of the tire registration program. I too am interested in reducing the burden upon the public occasioned by unnecessary paperwork. In accordance with your request, I am enclosing a copy of the NHTSA report.; Regarding your comments concerning the viability of a voluntary tir registration technique to replace the present registration program, you should note that the NHTSA has considered the possibility of a voluntary registration procedure similar to the warranty card procedure utilized by appliance manufacturers. Through informal inquiries of appliance manufacturers, the agency discovered that return of warranty cards averages about 50 percent in the case of expensive appliances and falls as low as 10 percent in the case of 10- to 35-dollar items. An entirely separate problem arises with voluntary registration of tires in that the purchaser cannot be expected to distinguish the serial number from other numbers that appear on each tire. More important, the identification number is placed on the side opposite the whitewall on many tires, and it is probable that the purchaser would fail to locate the correct number in the typical situation where the tires are mounted on his vehicle before he sees them.; If I can be of further assistance, please contact me. Sincerely, Brock Adams