Tire Industry Association

Anthony Hufford
United States Postal Service
Category Management Center
615 Chestnut Street
Philadelphia, PA 19106

Dear Mr. Hufford:
As a follow-up to our January 7, 2004, meeting in Philadelphia, PA, I am writing on behalf of the Tire Industry Association (TIA) regarding the retread program that the USPS is planning to implement. TIA remains concerned for our members who currently retread 14- and 15-inch tires for the USPS.

You requested that TIA submit a proposal as to how we can help the USPS better implement a national retread program. Without knowledge of which company (or companies) will be awarded the national contract(s), we will not be able to go into great detail in this proposal.

TIA is most able to help the USPS Vehicle Maintenance Facility employees receive proper training in tire mount/demount procedures. We have already sent you a preview copy of our Automotive Tire Service (ATS) training program. TIA Senior Vice President of Education and Technical Services Kevin Rohlwing has put together a proposal that we believe would help the USPS recycle tires and save money.

TIA Training for United States Postal Service (USPS)
TIA has numerous levels of passenger, light truck and truck tire and wheel service training for USPS maintenance facilities. The Automotive Tire Service (ATS) Program covers passenger and light truck, while the Commercial Tire Service (CTS) Program covers medium and heavy-duty truck. Both Programs include a "Basic" and "Certified" level. The Basic programs cover minimum skills and provide both new and experienced technicians with valuable information and techniques. Basic CTS also meets the minimum Occupational Safety and Health Administration (OSHA) training requirements for all employees that handle inflated truck tire and wheel assemblies. The Certified programs are designed for tire dealers and include individual technician and instructor certifications, and utilize the train-the-trainer model. For the needs of USPS, we recommend the Basic ATS and CTS Programs.

Basic ATS
The Basic ATS Program is designed to provide new hires and experienced technicians with comprehensive passenger and light truck tire and wheel service training. It includes a workbook, VHS and DVD, and is broken down into 7 modules:

•	Module 1 covers basic tire construction, terminology and sidewall identification markings including sizing, UTQG, DOT Code, and Load Index/Speed Rating.
•	Module 2 explains the basic step-by-step procedures for properly lifting a vehicle using an above-ground lift and floor jack and jack stand. Special emphasis is placed on positioning the vehicle on the lift in addition to the use of proper lifting points for full-frame and uni-body vehicles.
•	Module 3 covers tire/wheel assembly removal and installation procedures including proper fastener torque. Rotation patterns for all types of vehicles and tire replacement guidelines are also discussed.
•	Module 4 outlines the step-by-step procedures for demounting, mounting and inflating tires on both rim clamp and center-post tire changing machines. This will be particularly helpful in reducing the number of torn beads as technicians are guided through each step in the process.
•	Module 5 covers the proper way to balance a tire using both a computer balancer and a traditional bubble balancer.
•	Module 6 identifies various types of tire-related problems and includes charts to diagnose the cause of ride complaints and/or vibrations. Step-by-step procedures for measuring assembly runout are also covered both on and off the vehicle.
•	Module 7 covers the step-by-step procedures for installing one-piece and two-piece nail hole repairs in addition to general repair guidelines.

Basic ATS also includes an Internet component that automatically tracks the progress of each employee. A central administrator has access to a real-time database that reflects which technicians have taken the training and which have passed the test. An administrator in each location also has access to the database, but only for that location. The cost for USPS is $120 each for each location.

Basic CTS
OSHA Regulation 29 CFR 1910.177 requires documented training for all employees that handle inflated truck tire and wheel assemblies in any way. TIA created Basic CTS to enable companies to comply with the minimum OSHA training requirements. Basic CTS includes an Instructor’s Guide and VHS, but Student Workbooks are sold separately. It’s broken down into 5 modules:

Within the next few months, TIA will add another module to Basic CTS that focuses on the relationship between torque and clamping force when installing disc wheels. The new component will provide additional information on how technicians can keep the wheels from becoming loose on the vehicle.

Basic CTS is best utilized as an instructor-led program, so the maintenance supervisors in each facility would ultimately be responsible for the training. TIA can provide an instructor for hands-on training in each location for $1,000 a day plus expenses and materials. If USPS is interested in multiple dates, the daily training fee is reduced.

We recommend that USPS put a copy of Basic CTS in every facility for a discounted price of $75 (down from $125). Student Workbooks are $25 each.

Besides our training initiatives, TIA is ready to help the USPS with the formation of a task force when it comes to the collection of information from your retread vendors. If one of the large companies is awarded the contract, TIA believes that it will not need our assistance, although we would give it if asked. If a smaller company is awarded the contract, then TIA will do everything to assist when asked by that prime company or the USPS. We are here as a resource for the tire industry.

I would also like to say TIA fully supports the alternative proposal set forth by the Tire Retread Information Bureau (TRIB) in their letter dated January 17, 2004 (attached). TRIB has come up with a way the USPS can streamline their process while saving money. TIA agrees that the eight steps TRIB outlined would help the USPS reach their goals without harming any small business retreaders that are currently working with the government. Please take TRIB’s proposal into serious consideration.
I hope this information is helpful to you as you move forward in the process. If you have any questions about our training proposal, please contact me at 703-642-3162.

Sincerely,

Becky MacDicken
Director of Government Affairs
Tire Industry Association

November 20, 2003

Anthony Hufford
United States Postal Service
Category Management Center
615 Chestnut Street
Philadelphia, PA 19106

Dear Mr. Hufford:
On behalf of the retread members of the Tire Industry Association (TIA) I am following up on my phone call to state our concerns over the United States Postal Service (USPS) nationwide retread contract proceedings (1DVPMS-03-A-1957). I know you are still in the process of reviewing the bids you received, and we believe our input is vital to the process.

The USPS did not contact TIA, the Tire Retread Information Bureau (TRIB) or any other groups of interest about this proposal before it was put out for bid. However, it is not too late to bring your Vehicle Maintenance Facility (VMF) managers together with said groups to discuss the goals of the USPS and come to an agreement on how best to achieve those goals with the retread industry before the contract is awarded. We strongly recommend that you consider our offer to do so.

I understand from you that the USPS is attempting to consolidate the business contracts and agreements of 191 VMFs into one, maybe two, nationwide contracts. Most of TIA’s retread members are small, family-owned businesses. While it is possible that many of these retreaders will be awarded subcontracts from whichever larger company is awarded the national contract, there is no guarantee of that business for these retreaders. If the larger company subcontracts only to its affiliate retread shops, many family-owned, small businesses could be cut out of the process.

The retread industry is already shrinking. Over the last decade it has seen the demise and consolidation of over 2,000 retreaders; there are fewer than 1,000 nationwide today. And passenger/light truck retreading is only a fraction of the market compared to that of truck and off-the-road tire retreading.

If the USPS lets the contract to a larger firm that stays within its own network of retread facilities, or if there is a change of heart by the USPS in a couple of years, there may be no independent retreaders left to answer the call.

While the USPS is consolidating in order to be more cost-effective and efficient, and that is an admirable goal, TIA has three options for you to consider:

1) Propose a national tire maintenance program with your VMFs. Anecdotally, we hear that many USPS tires brought in for retreading to our member retreaders still have valuable tread life. The USPS and its employees may benefit from professional training on tire maintenance and safety. This education could save the USPS valuable dollars, and TIA has the programs and the professionals on-hand to assist with development of such a program for your VMFs.

2) Create a uniform contract and accompanying forms for anyone retreading for the USPS, and have that information kept in a central location for auditing/monitoring. According to TIA members, most VMFs run independently and differently from one another. Creating a uniform process for the VMFs would allow the USPS to operate more efficiently, saving manpower and money without endangering the livelihood of the independent retreaders in the United States.

3) Awarding several regional contracts may better serve the USPS than one large, nationwide contract.

I can share with you two of our members’ stories: Community Tire Retreading in St. Louis, Missouri, is a third-generation retread company founded in 1935. It employs approximately 45 people and about 10 percent of its business is with the USPS. Next, Tire Recappers of Nashville, Tennessee, is also a third-generation retreader with nine employees. Approximately 70 percent of its current work is for local and regional USPS locations. Neither company will be able to bid on the national contract due to their size. These are the types of businesses that will suffer at the hands of a national contract. Even if the national contractor chooses these facilities as subcontractors, they are told how to do their job and how much they can charge – take it or leave it.

Before you move forward with the award of a nationwide contract, I sincerely hope you will accept this offer to meet as an industry (at a time and place of your choosing) to discuss our alternative proposals. We urge you to reconsider the massive USPS contract for the nation’s small business retread community.

Sincerely,
Becky MacDicken
Director of Government Affairs
Tire Industry Associationcc: Postmaster General Jack Potter
Donald Manzullo, Chairman U.S. House Committee on Small Business