Interpretation ID: nht71-4.37

DATE: 11/02/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: REBCO

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 24, 1971, concerning the retention of records of the names and addresses of first purchasers of retread tires that you manufactured prior to October 13, 1971, the date you went out of the retread business.

Under the Tire Identification and Record Keeping Regulation you are required to maintain the names of first purchasers three years from the time the sale is reported to you or your designee. Therefore, as to those tires manufactured between May 22, 1971 and the date you went out of business, October 24, 1971, you are required to maintain, or have maintained for you the names and addresses of the first purchasers for three years after this information is recorded by you or your designee.