Interpretation ID: 77-2.17

TYPE: INTERPRETATION-NHTSA

DATE: 04/21/77

FROM: AUTHOR UNAVAILABLE; Brock Adams; NHTSA

TO: Commission on Federal Paperwork, Frank Horton - Chairman

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your March 9, 1977, letter requesting a copy of the report prepared by the National Highway Traffic Safety Administration (NHTSA) in response to the Senate Commerce Committee's inquiries concerning the recordkeeping requirements of the tire registration program. I too am interested in reducing the burden upon the public occasioned by unnecessary paperwork. In accordance with your request, I am enclosing a copy of the NHTSA report.

Regarding your comments concerning the viability of a voluntary tire registration technique to replace the present registration program, you should note that the NHTSA has considered the possibility of a voluntary registration procedure similar to the warranty card procedure utilized by appliance manufacturers. Through informal inquiries of appliance manufacturers, the agency discovered that return of warranty cards averages about 50 percent in the case of expensive appliances and falls as low as 10 percent in the case of 10- to 35-dollar items. An entirely separate problem arises with voluntary registration of tires in that the purchaser cannot be expected to distinguish the serial number from other numbers that appear on each tire. More important, the identification number is placed on the side opposite the whitewall on many tires, and it is probable that the purchaser would fail to locate the correct number in the typical situation where the tires are mounted on his vehicle before he sees them.

If I can be of further assistance, please contact me.

SINCERELY,

COMMISSION ON FEDERAL PAPERWORK

Honorable Brock Adams Secretary Department of Transportation

We greatly appreciate the Department of Transportation's past cooperation with the Commission on Federal Paperwork. It is our hope that in continuing to work together on specific paperwork problems we will be able to reduce significantly the burden borne by the public.

The Commission has received comments concerning the burdensome reporting and recordkeeping requirements of the mandatory new and retread tire registration program of the National Highway Traffic Safety Administration. It has been brought to our attention that voluntary registration may be a viable alternative to the current reporting program which could reduce the burden on tire dealers and manufacturers.

We have learned that the Senate Commerce Committee has sent you a letter requesting data on the tire registration program including the number of new and retread tires recalled and the percentage of registrants who comply with the program. In order for the Commission to adequately review the reporting requirements we would like to receive a copy of the report you are preparing for the Committee.

We appreciate your continuing cooperation and look forward to hearing from you in the near future.

With kindest personal regards,

Frank Horton Chairman