Rulemaking

Tire Testing Standards

Description

NHTSA's proposal to upgrade tire testing standards, updating FMVSS 109 (passenger/light truck tires)

The testing standards that a tire must pass in order to be eligible for a DOT code in the United States have not been updated since 1967. Bias ply tires, not radials were the prevalent tire back then, so it is necessary for the standards to be upgraded. NHTSA published a proposal on December 19, 2001. TIA asked for an exemption for retreaded tires from this proposal. The retread process does not affect the casing so these tests would be redundant. TIA supported the RMA's alternative proposals for high speed, endurance, and low-pressure tests. TIA also opposed aging tests and asked NHTSA to hold off on publishing a test on road hazard impact and bead unseating tests. (These tests were not required by the TREAD Act.)

Docket Number

2000-8011

History/Status

NPRM published March 5, 2002, deadline May 6

Extension of time granted - deadline moved to June 5

Comments on NPRM submitted June 5, 2002 (download below)

Final Rule due June 1, 2002 - realistically fall 2002

Next year FMVSS 119 (commercial) will be updated

TIA Position

Asked for exemption from tests for retreads

Asked for exemption from tests for specialty tires

Voiced concern over costs to manufacturers

Opposed aging tests, although oven aging least burdensome

Supported RMA's alternative proposals

Rulemaking

Tire Labeling Requirements

Description

NHTSA simplifying tire labeling requirements

After the Ford/Firestone crisis and a public outcry on what information is found on the sidewall of a tire, Congress asked the NHTSA to examine and update tire labeling requirements. NHTSA put out a request for information on tire labeling. At the time, TANA conducted a survey of our members to see what tire industry felt the general public knew about their tires. [See TANA's comments submitted about the survey results.]

After initial information was gathered, NHTSA proposed a new tire labeling regulation. They proposed to put the Tire Identification Number (TIN) on both sides of the tire so that consumers and tire technicians could easily find it. NHTSA also proposed that the TIN be reordered so that the plant and date code portion of the TIN moves to the front of the string of characters. TIA opposed both of these proposals. The expense to the manufacturers and the danger to the technicians having to change both sides of a tire mold are not worth the benefits to the consumer. TIA strongly opposed the Rubber Manufacturers Association's (RMA) proposal to remove the maximum inflation pressure and the cord and ply information from the sidewall of a tire. Tire technicians need this information to service and/or recycle tires.

Docket Number

2000-8296 and 2000-11157

History/Status

ANPRM published December 1, 2000

January 30, 2001 TANA submitted comments to docket

February 14, 2001 ITRA submitted comments to docket

NPRM published December 19, 2001

TIA submitted joint comments February 12, 2002

Final Rule due out late summer 2002

TIA Position

TANA conducted survey of consumer education level for NHTSA

comments on ANPRM

Do not place TIN on both sides of tire

Do not reorder TIN

Leave max pressure on sidewall of tire

Leave cord material and ply information on sidewall of tire

Consumer education commitment

Rulemaking

Tire Pressure Monitoring Systems

Description

TREAD Act mandates TPMSs in all vehicles within 2 years of a final rule.

The TREAD Act mandated that every new car be equipped with a TPMS. NHTSA published their regulation July 24, 2001 and ITRA and TANA submitted comments on September 6, 2001. [See ITRA's comments. See TANA's comments.] The organizations were very concerned that the independent tire dealers are not being given the information they need to install, service and maintain these TPMSs from the OEMs. The organizations were also concerned with NHTSA's proposed definition for underinflation.
The final rule was published June 5, 2002. Unfortunately NHTSA proposed that if a vehicle is using a direct system (with sensors in each tire sending a signal to the dashboard) the TPMS does not have to trigger until the tire is 25 percent below the recommended cold psi. An indirect TPMS (that runs off the anti-lock braking system) does not have to trigger until the tire is 30 percent below the recommended cold psi for that tire. TIA is strongly opposed to NHTSA's supposed "safety" regulation which in effect allows the motoring public to drive on severely underinflated tires. TIA has supported a petition that NHTSA mandate reserve inflation pressure in tires to offset the TPMS rule. [See letter to NHTSA supporting petition.]

Docket Number

2000-8572

History/Status

July 24, 2001 NPRM published

TANA submitted comments September 6, 2001

ITRA submitted comments September 6, 2001

Final Rule (part 1) published June 5, 2002

Comments due July 22 - TIA will submit comments

Final Rule (part 2) will be published in 2005 after further study

TIA Position

Support Direct TPMS

Underinflation defined as anything below vehicle placard

recommended inflation

Concern over independent dealers having information to install,

service, maintain, and recalibrate TPMSs

Rulemaking

Early Warning Reporting System

Description

NHTSA is proposing to collect data (fatalities, injuries, warranty adjustments, property damage claims and field reports) from manufacturers that will detect problem trends in tires.

NHTSA has proposed a system that will allow the government to track potential problems in tires by having the tire manufacturers submit data into a new federal database. Information includes tire-related fatalities, injuries, property damage claims, and warranty adjustments. Retreaders are exempt from the reporting requirements except in cases of fatalities. TIA is sure that tire dealers will be less likely to make adjustments to keep customers satisfied, knowing the information will be turned in to the government. TIA is very concerned with the confidentiality of this information. The TREAD Act in mandating an EWRS stated that unless there was a need for a recall the information would be kept confidential. NTHSA is contemplating making the information available to the public. TIA believes this would be fodder for trial lawyers and information that the general public could easily misinterpret.

Docket

2000-8677

History/Status

ANPRM published January 22, 2001

Comments due March 23, 2001

NPRM published December 21, 2001

TIA submitted joint comments February 4, 2002

Final Comments due June 30, 2001 - realistically late summer 2002

Confidentiality Proposal published April 30, 2002

Comments due July 1, 2002

TIA Position

Retreaders should be exempt from reporting requirements except in the case of fatalities or serious injuries.

Concern over dealers making adjustments and affects on business

Rulemaking

Safety Recalls in Foreign Countries

Description

Manufacturers must report recalls or "safety campaigns" even if in a foreign country.

NHTSA now requires that any automobile or tire manufacturer who conducts a recall or "safety campaign" in a foreign country must report that campaign to the U.S. government if the same or similar tires are sold in the U.S.

Docket

2000-10773

History/Status

NPRM published October 10, 2001

Comments Due November 11, 2001

Self-implementing regulation

TIA Position

Did not submit comments

Rulemaking

Sale or Lease of Recalled Tires

Description

Penalties and Safe Harbor Provisions for the sale or lease of recalled tires.

NHTSA has stated that knowingly selling or leasing a recalled tire is illegal. There are safe harbor provisions for people who accidentally sell or lease a recalled tire. Stiff penalties are in place for individuals that try to sell illegal tires.

Docket

2000-8509 and 8510

History/Status

NPRM published December 26, 2000

TANA submitted comments February 26, 2001

Final Rule Published July 23, 2001

TIA Position

TANA requested "reasonable time" to be 21 days from date of discovery of errors to report

Rulemaking

Reimbursement Prior to Recall

Description

NHTSA's proposal on how manufacturers are to reimburse individuals who replaced tires at own expense prior to official recall.

If a customer has a problem with or hears rumors about his/her tires and replaces them at his/her own expense, and then a recall is issued, this regulation lays out a timeframe in which the tire manufacturer must repay the consumer.

Docket

2001-11107

History/Status

NPRM published December 11, 2000

Comments due February 11, 2001

Final Rule

TIA Position

Did not submit comments

Rulemaking

Acceleration of Recall

Description

The speed at which tires are available from manufacturers for consumer replacement. NHTSA can mandate that competitive products may be substituted if needed.

In the event of a recall, this proposal allows NHTSA to mandate a competitive product as a substitution if the recalled tire replacement is not readily available. This will help speed up the recall process.

Docket

2001-11108

History/Status

NPRM published December 11, 2000

Comments due February 11, 2001

TIA Position

Did not submit comments

Rulemaking

Disposal of Recalled Tires

Description

How manufacturers dispose of tires that are the subject of a recall.

NHTSA is asking that in the event of a recall, tire manufacturers create a plan for the timely disposal of the recalled tires, rendering them out of service or returning them to the manufacturers for inspection/testing promptly.

Docket

2001-10856

History/Status

NPRM published December 18, 2001

Comments due February 19, 2002

A Supplemental NPRM published on June 26, 2002

TIA submitted comments on August 21, 2002

TIA Position

TIA supports returning recalled tires to the manufacturer. Recommended that manufacturers seek the highest and best recycling/reuse opportunities for recalled tires when it is practical and safe to do so. Suggested that manufacturers be required to accept a shipment of tires from dealers/distributors every 30 days, or once the manufacturer recommended weight is reached, whichever comes first.