Interpretation ID: nht94-5.35

DATE: May 16, 1994

FROM: Doris Hull -- Owner, Sikeston Trailer Sales, Inc.

TO: Robert Hellmuth -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attachment dated 8/12/94 Letter from John Womack to Doris Hull (Std. 109, 119 & 12)

TEXT:

This letter is in regards to a phone conversation with Mr. Walter Meyers on May 13, 1994 that David McCormick and I had. The conversation was concerning trailers with new and used tires. The understanding that we got that we are allowed to do is included in this letter. I would appreciate a quick response from you.

We understood that we, as manufactures, can sell to a dealer, who picks up a load of trailers, the trailers being stacked on top of each other; we can install new tires on the bottom trailer that would meet the requirements of standard 120 and for the other trailers that are stacked we can sell the used tires and rims mounted but not installed on trailers. That if a tractor trailer loaded with trailers was sold we could sell the used tires and rims but not installed on the trailers. All used tires and rims would meet the D.O.T. Standard 120 qualifications. We understood that an individual can request used tires and rims, we can sell them to them and install them if requested by the individual.

Your prompt attention to this matter is greatly appreciated. We have also talked with George Shifflett concerning what Mr. Meyers informed us.

Please do not hestitate calling me at the number listed above if there are any questions I may be able to help with.