Interpretation ID: 1982-1.26

TYPE: INTERPRETATION-NHTSA

DATE: 03/23/82

FROM: MIKE SMITH -- PRESIDENT, FLEET TIRE SERVICE

TO: NHTSA

TITLE: NONE

ATTACHMT: MEMO DATED 6-30-82, NOA-30, TO MIKE SMITH, FROM FRANK BERNDT - NHTSA

TEXT: We are a tire retreader located in southwest Arkancas and are in the process of importing 220 tires from Brussels for the explicite purpose of retreading. Our paper work on the acquisition of these casings lists them as rubber tires in error.

We will list all the serial numbers on the tires at time of receipt and keep a permanent shop record of such, which is our normal procedure. At this point the tires will be buffed and we will have a local police authority examine each tire and ascertain each tire has been buffed for retreading.

We have visited with Mr. Buckley of the Department of Transportation and he was unable to give us a definite ruling on this procedure for meeting proof of conformity.

Will you please advise if this method will be acceptable to you. If not, please furnish us with an alternative method for proof of conformity.

These tires have already arrived in New Orleans and we are proceeding with our plans for receiving and retreading.