Interpretation ID: nht75-4.17

DATE: 09/11/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Flenniken Financial Services, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of July 1, 1975, concerning the legal duties of a tire recapping firm which you insure.

For your convenience, I have enclosed a copy of Federal Motor Vehicle Safety Standard No. 117, Retreaded Pneumatic Tires. This standard does not specify the testing which a manufacturer of retreaded tires must do; it does specify the criteria which the tires must meet when tested by the National Highway Traffic Safety Administration (NHTSA) for compliance. While the surest way for the retreader to be confident of compliance would be to follow the procedures in every detail, he is not legally obligated to do so. Section 108 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, requires him to assure himself that, when tested by the NHTSA according to the procedures set out in the standard, his tires will meet the specified criteria. In addition, he is required to repair or replace without charge a non-complying tire.

SINCERELY,

July 1, 1975

National Highway Traffic Safety Administration James B. Gregory Administrator

Re: Title 40 CFR 571-171A and Current Amendments

We insure a tire recapping firm here in Knoxville, Tennessee. We are providing products coverage, and the company writing this coverage has set out some essential recommendations to be complied with in order to continue same. I an enclosing the recommendations and request that you advise me as soon as possible just what these people need to do to be in compliance with these.

Thank you for your cooperation and prompt reply.

FLENNIKEN FINANCIAL SERVICES, INC.

Frank C. Howard, Jr.

8-5-75

I would appreciate a reply on this I can't do any think until I hear from you

Thank you Frank C. Howard, Jr