TIA Submits Comments to NHTSA
Bowie, Md. - The Tire Industry Association (TIA) submitted comments today to the National Highway Traffic Safety Administration (NHTSA) in response to an Advance Notice of Proposed Rulemaking (ANPRM) and request for public comment on Updating Means of Providing Notification [to consumers] and Improving Efficacy of Recalls.
While TIA recognizes the importance of notifying owners when a tire recall becomes necessary, the Association is focused on the recovery process in the comments. TIA notes that improved notification processes are necessary in order to remove defective tires from the highway. However, in the context of recalled tires, TIA believes that electronic identification will be the most significant factor in improving recall efficacy and effectiveness.
In response to SEC. 24333 of the recently passed FAST Act that reinstates mandatory tire registration, TIA convinced Congress to add SEC. 24334, which requires the Secretary to conduct a study to examine the feasibility of requiring tire manufacturers to include electronic identification on every tire to reflect the information currently contained in the tire identification number or TIN. By incorporating technology into the tire registration and recall recovery systems, retailers could easily and accurately scan every tire that is sold. The TINs could then be automatically recorded in a database and human error dramatically reduced. If the TIN was permanently linked to the Vehicle Identification Number (VIN) and therefore, the most current registered owner, it will be much easier to notify the owners of defective tires even after address or title changes. TIA refers to this concept as “TIN to VIN”.
TIA goes on record to state that the Association strongly suggests that, “the Secretary mandate a TIN to VIN system where all of the tire registration data is collected and stored by a single third party designee.” Utilizing an independent designee would eliminate concerns about personal privacy as well as the registration data being used by the manufacturers for marketing purposes. TIA cites another benefit of electronic identification linked to a centralized recall database in a TIN to VIN system would be that it would allow service providers to identify recalled tires during the course of normal tire service and maintenance. TIA suggests that TIN to VIN also be required of used tire dealers to close another loophole in the recovery process. In concluding the comments, “TIA is confident that when a TIN to VIN system for tire registration is combined with electronic identification, the recovery rate for recalled tires can be significantly improved.”
Additionally, TIA strongly encourages that vehicle inspection programs be reinstated in every state. If motor vehicles were required to pass an annual inspection, the inspector could scan the electronic identification and immediately determine if any of the tires on the vehicle or the spare were subject to recall.
“Although the Association remains disappointed that the political system enabled mandatory tire registration to become law at some point in the future, we are totally focused on making sure the emphasis stays on recall recovery,” said Roy Littlefield, TIA Executive Vice President. “While we recognize that tire registration is important, the primary goal must be to remove defective tires from the highway. TIA is confident that electronic identification is the first step towards that goal.”