Interpretation ID: nht74-4.37

DATE: 01/08/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: American Retreader's Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 20, 1973, asking under what conditions retreaded tires, which you describe as, "not first class mainly from the standpoint of appearance, may be sold. You state that the tires are not defective, and are being sold for non-highway use, such as for farm wagons and hay bailers.

Standard No. 117 (Retreaded pneumatic tires) applies to all retreaded tires manufactured for use on passenger cars. The sale of such tires for off-highway vehicular purposes does not remove them from the coverage of the standard. Consequently, the tires must comply fully with Standard No. 117, bear the manufacturer's identification number (49 CFR Part 574), and not be restricted to off-road operation.

November 20, 1973

Mike Peskoe Assistant Chief Counsel National Highway Traffic Safety Administration

A number of our members have written, asking us questions concerning the sale or disposition of retreads that are not first class, mainly from the standpoint of appearance. They are not defective.

(Illegible Word) retreads are being sold to implement dealers for non-highway(Illegible Word) such as on farmwagons, hay balers, etc.

1.) Should the retreader remove his assigned identification mark before selling it?

2.) Should he leave his assigned identification mark on the retread and brand or otherwise permanently identify it as being for farm or non-highway use?

3.) Should he remove his assigned identification mark and permanently identify it as being for farm or non-highway use?

Your help in clarifying these questions will be appreciated.

Arden H. Faris Assistant Director