Interpretation ID: nht70-2.39

DATE: 12/08/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: B. F. Goodrich Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 20, 1970 concerning your telephone conversation with Mr. Schmeltzer of my office, relating to the Tire Identification and Record Keeping Regulations (Docket No. 70-12; Notice No. 2).

You are not completely correct in your understanding that, as a result of the tire identification regulations, the DOT symbol will only be required on the sidewall of the tire where the identification number will appear. As indicated in the(Illegible Word) of the notice of proposed rulemaking on these regulations, it is anticipated that the identification number required by the regulation will replace the manufacturer's identification number required by Standard No. 109. However, no decision has been made as yet whether Standard No. 109 will also be amended to require the "DOT" symbol on only one sidewall of the tire.

You are correct in your understanding that the regulations were not intended to restrict the third grouping of characters, the optional the type code, to three symbols. In addition, you are correct in your understanding that a tire manufacturer will receive individual identification numbers for each of its tire manufacturing and retread plants.

Under the regulations, B.F. Goodrich will not be required to apply for identification marks for Goodrich owned brand name tires if sold and controlled by them.

Concerning your question as to what class of certified mail would be required in the event of a recall, a notification letter sent by certified mail to the addressee, himself, would be preferable but is not, at this time, required by the Act or any regulation issued thereunder.

Thank you for your interest.