Interpretation ID: nht94-1.21

TYPE: INTERPRETATION-NHTSA

DATE: January 19, 1994

FROM: Donald F. Lett -- Lett Electronics Co.

TO: Department of Transportation -- NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 5/18/94 From John Womack To Donald Lett (A42; Std. 109; Std. 110; Part 575.104)

TEXT: Dear Sir,

I was directed to your department by Mr. Duane Perrin to resolve any legal responsibility, if any, for the following question;

Is there any pre-necessary authorization needed to modify an existing passenger tire, for instance a 215-70-R15 blackwall radial tire?

Proposed Modification

Grind down the existing sidewall 1/8 to 3/16 inch deep by 2 1/2" wide. Then vulcanizing white rubber into this recess making a 2 1/2" whitewall radial tire out of a previously D.O.T. approved radial blackwall tire.

Thereupon we would merchandise this tire Nation wide to a specific classic car buff of the 1955-1960 era. Your kind attention to this matter would be greatly appreciate.

Thank you,