Interpretation ID: nht95-3.83

TYPE: INTERPRETATION-NHTSA

DATE: August 9, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA; Signature by Stephen P. Wood

TO: D. L. O'Connor -- Manager, Government & Customer Compliance, The Goodyear Tire & Rubber Company

TITLE: NONE

ATTACHMT: ATTACHED TO 7/13/95 LETTER FROM D. L. O'CONNOR TO WALTER K. MYERS (OCC 11043)

TEXT: Dear Mr. O'Connor:

This responds to your telephone conversation with Walter Myers of my staff on July 12, 1995, followed up by your letter of July 13, 1995.

You stated that Goodyear is encountering difficulties in exporting tires to Colombia, South America, in that Colombia wants verification that Goodyear complies with all Federal motor vehicle safety standards (FMVSS) when placing the DOT symbol on tires. You believe that Colombia will permit importation of Goodyear tires if NHTSA recognizes that Goodyear is a U.S. tire manufacturer in good standing and that Goodyear's placing the DOT symbol on its tires is accepted as valid certification of compliance b y the U.S. government.

As Mr. Myers stated in your telephone conversation, other U.S. tire manufacturers and exporters have had similar difficulties with Central and South American countries. All those countries regard the FMVSSs as acceptable assurances of tire safety, but t hey do not seem to understand or are skeptical of our system of manufacturer self-certification. They want assurances from a responsible U.S. government agency that manufacturer self-certifications are accepted as valid by the U.S. government.

Enclosed is a statement similar to those that we have provided other manufacturers and exporters. Since the Federal government cannot and does not approve, certify or endorse vehicles and equipment, this statement is as far as we can go in getting the F ederal government involved in what by law is essentially a manufacturer responsibility.

I hope the enclosed statement will be helpful to you. Should you have further questions or need additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992.

Enclosure

8/9/95

To Whom It May Concern:

Subject: Tires Manufactured by Goodyear Tire & Rubber Company

United States law requires tire manufacturers themselves to certify that the tires they manufacture for sale in the United States comply with all applicable Federal motor vehicle safety standards. There is no provision in U.S. law for approval or certif ication by this agency, the National Highway Traffic Safety Administration (NHTSA), the agency responsible for implementing the Federal law. NHTSA enforces the standards by randomly selecting and testing approximately 100 passenger car tires and 70 other than passenger car tires per year to ensure the validity of the tire companies' self-certification programs.

NHTSA states that all motor vehicle tires of any type or size manufactured by Goodyear Tire and Rubber Company and bearing the symbol "DOT" are recognized by the United States as having been produced and certified in conformity with all applicable Federa l motor vehicle safety standards of the United States.

Any questions or requests for additional information regarding this matter may be directed to Walter Myers at this address or at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel, NHTSA (Signed by S. Wood)