Interpretation ID: nht71-4.43

DATE: 11/08/71

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

TO: Commercial Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 14, 1971, in which you ask whether matrices (or molds) must be relettered to a new identification code mark when the ownership of a company is transferred from father to son. The son may continue to use the existing number if he will write a letter to us stating that he is the new owner, the date on which he became the new owner, that he wishes to continue to use the same identification code mark, and that he assume all responsibility under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C 1381 et. seq) for tires manufactured with the identification mark on or after the date he assumes ownership of the company. This letter should also refer to the name of the old company and should include any changes being made in company name, address and types of tires being retreaded.

With the above procedure the matrices would not have to be relettered. We will change our records to conform to the information contained in the letter.