Interpretation ID: nht75-5.21

DATE: 06/18/75

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: The General Tire & Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT: Please refer to Mr. Ronald W. Mohler's letter of September 6, 1974, (copy enclosed) and Mr. Snyder's telephone conversation with you on January 23, 1975, regarding the transfer of tread code mark "BFK" from the "Griffin General Tire Service, Inc." retread company operated by Mr. James W. Griffin to the "Griffin General Tire Service" company operated by The General Tire and Rubber Company.

The enclosed copy of the May 17, 1973, letter to Mr. Daniels of the Daniels Tire Service, Inc. company outlines the conditions which must prevail for this company and the "Griffin General Tire Service, Inc." company to use the same code mark BFK. With respect to the "Griffin General Tire Service, Inc." the various limiting conditions prevailing at that time and which we understand will be continued by your acquired company are:

1. Recordkeeping procedures must be internal, i.e., within the specific company.

2. Production is limited. Mr. Griffin advised us that production in 1973 was approximately five truck tires per day.

3. The plant serves only local trade in the vicinity of Hornell, New York.

Please advise us whether our understanding is correct that these conditions will be met by the "Griffin General Tire Service" company operating under the control of The General Tire and Rubber Company. If not, a new code number must be assigned to this plant.

We further wish to advise you that the conditional usage of code mark BFK will not be extended to any future disposition of the "Griffin General Tire Service" company. To perpetuate the abnormal condition where two retread plants use the same code mark is highly undesirable due to the potential confusion, the extra necessary control effort, as well as the personal supervision required at our computer operation.