Interpretation ID: nht92-5.34

DATE: 07/01/92 EST

FROM: Bob Bullard

TO: Walter Myers

TITLE: None

ATTACHMT: Attached to letter dated 9/4/92 from Paul Jackson Rice to Bob Bullard (A39; Std. 120)

TEXT:

In regards to our telephone conversation on Monday, July 20 concerning used tires being installed as standard equipment on new utility trailers.

There are over 200,000 utility trailers manufactured annually. Of this number, approximately 185,000 are mounted with used tires and shipped to the dealers. The dealers sell these trailers to the general public. This situation presents a problem in that every trailer has a rated load weight allowable. With used tires being used-the rated load weight is totally inaccurate, because no one knows what kind of weight a used tires can carry. Because of this problem, it is not uncommon to see a new trailer have a blow-out on our highways. In many instances, these accidents cause major fatalities.

The NHTSA has had the foresight to asses the situation and now has a regulation pertaining to used tires on trailers,--reference #49CFR Ch.V,571.120,S5.1.3. The drawback to this regulation is that no trailer manufacturer or dealer knows about this law. If they are aware of it's existence- they do not full understand it. Although this regulation speaks for itself, some of those dealing with the requirements may not have an extensive educational background. For this reason, I desperately need an interpretation from your office that spells out exactly what a manufacturer and dealer can and cannot do in regards to this law.

Please include in this interpretation, a simplified version of the regulation, penalty for violations, and who to contact for enforcement. This version will be sent to dealers around the country.

If only one life can be saved on our highways by bringing utility trailers to your already existing standards, the time on this issue will have been well spent.

Please forward the requested information to: Bob Bullard 12400 West I-20 E Odessa, Texas 79766 (915) 563-0300