ABC Exposes Broken Tire Safety System

Yesterday, ABC’s Nightline and Good Morning America took two issues that Safety Research & Strategies has been chipping away at for a decade, and gave them big play: the broken tire recall system and tire age. Producer Cindy Galli and investigative reporter Brian Ross, working with reporters at local ABC affiliates, bought recalled and very old tires, told victims’ stories and skewered the Rubber Manufacturer’s Association.

The stories raised a number of key issues:

• The tire recall system doesn’t work: Recalled tires aren’t always caught by retailers and there is no quick, easy or efficient way for any consumer or tire technician to check the recall status of a tire.
• Aged tires are sold and put into service unknowingly because the date code is buried in the Tire Identification Number, and expressed in a non-standard format. Tire age recommendations by vehicle and tire makers are not well known to service professionals or consumers.
• The tiremakers’ trade group, the Rubber Manufacturers Association (RMA) has conceded that the tire recall system does need improvement, but continues to maintain that tire age has no bearing on safety, and has fought off regulations to keep old tires off the road.

ABC highlighted the National Transportation Safety Board’s first tire safety investigation into a February crash that killed two and injured seven members of the First Baptist Church in New Port Richey, Florida, when a two-year-old left rear recalled BF Goodrich tire suffered a tread separation. The tire had been recalled in July 2012. The NTSB is also investigating a second fatal incident involving an aged tire. With its investigative powers and advisory role to other regulatory agencies on safety policy, the NTSB’s recommendations have the potential to be a game-changer. Will the National Highway Traffic Safety Administration listen?

Tire Age Crusade in UK Begins

Advocacy has always been a long game. Frances Molloy, the mother of a young British musician who died in a bus crash caused by a the failure of a 19-year-old tire, has met her first hurdle in a letter from the Secretary of State for Transport, declining to take any immediate action to limit the age of tires fitted on commercial buses.

Secretary Patrick McLoughlin held out the possibility of a more comprehensive action “including - possibly - through the imposition of restrictions on the use of tyres above a certain age via the existing vehicle inspection regime,” but said more research needed to be done.

“He’s given a lot of words,” Molloy says. “There’s nothing in this response. It’s just basically, I will commission research. Research is a delaying tactic. It’s stalling. We already know tires have a shelf life.”

McLoughlin met with Molloy and David Price, an expert in crash forensic analysis, on November 20 to talk about policy responses to the death of 18-year-old son Michael Molloy, who died in September 2012 with another 23-year-old passenger and the driver in a bus crash caused by the catastrophic failure of a tire with legal tread depth, but was 19-and-a-half-year-old. The tire had been purchased secondhand by Merseypride Travel, which owned the 52-seat coach. Michael’s death has resulted in posthumous honors involving his passion for music, but Frances Molloy is aiming for a comprehensive policy change.

McLoughlin’s letter to Maria Eagle, a member of the House of Commons representing the Molloy’s neighborhood in Liverpool, makes clear that the rubber industry’s reluctance to acknowledge its own long-held technical research on the relationship between rubber age and robustness took precedence. McLoughlin wrote:

“Although research is limited, it is clear to me that the association between the age of a tyre and its structural integrity is not fully understood. I noted the advice that Mr Price provided in our meeting but also recognise that the tyre industry suggests that other factors such as the maintenance of correct inflation pressures, regular use, and inspection for damage are more critical than a single limit on the age of a tyre. I have noted research from the USA that indicates artificially-aged tyres can fail safety tests but also note that their study replicated conditions of high ambient temperature and therefore cannot necessarily be directly related to conditions of use found here in the UK.”

Will the UK Be the First with a Tire Age Rule?

The National Highway Traffic Safety Administration has had an open rulemaking docket on tire age degradation (i.e., thermo-oxidative aging) since 2003, but will the UK beat the U.S. to actual tire age legislation? Frances Molloy isn’t in an international race, but she is determined to see Great Britain adopt a tire age policy sooner rather than later. Molloy’s 18-year-old son Michael perished in September 2012 along with another 23-year-old passenger and the driver in a bus crash caused by the catastrophic failure of a 19-and-a-half-year-old tire. The tire had been purchased secondhand by Merseypride Travel, which owned the 52-seat coach. It had legal tread depth, but was older than Michael.

“The risk to life from old tires -- no one can put a price on that. It’s been complete devastation,” says Molloy of the impact on her family. Michael, a promising musician, was on his way home after attending a musical festival in the Isle of Wight. “He was only 18 -- there was no other reason for the crash in the inquest -- other than the tire.”

Molloy, forensic crash investigator David Price and Surrey Coroner Richard Travers are campaigning to change the laws in Great Britain to prevent another such crash. In July, Travers formally announced that he would be writing a rule-43 report to alert the Secretary of State for Transport to the threat aged tires pose to public health. Travers’ report gives the Secretary a matched set. Three years ago, the Gloucestershire coroner did the same, after the 2009 death of Nazma Shaheen, whose crash was tied to the failure of a 13-year-old tire.

On November 20, Molloy and Price met with Secretary of State Patrick McLoughlin, who reports directly to the Prime Minister. He assured her a response in two weeks.

NHTSA Chokes on Recall Rule

The NHTSA has published a Final Rule on Early Warning Reporting and recall requirements, and we are sorry to say that it misses the mark on a number of fronts. But – it certainly is a very traditional approach to auto safety. NHTSA’s most significant safety steps forward are almost exclusively at the behest of Congress, and the gaps in this bill reflect that Daddy-Didn’t-Make-Us-Do-It mind-set.

These amendments, weaker than they should have been, are the result of 2012 Moving Ahead for Progress in the 21st Century Act, (MAP-21, for short) MAP-21 is the first major highway funding authorization bill since the 2005 Safe, Accountable, Flexible Transportation Equity Act – a Legacy for Users (SAFTEA-LU). The comprehensive bill, among other things, could have fixed some significant problems with recall process and made the system more useful for its intended audience – consumers. Instead, NHTSA nibbled at the edges, and, if history is any judge, it will be another decade at least, before the agency makes more substantive changes – or Congress intervenes.  

The New Requirements

NHTSA was considering satisfying the MAP-21 dictate to make recalls Internet-based and searchable by Vehicle Identification Number (VIN), by requiring manufacturers to submit the VIN ranges of recalled vehicles directly to the agency to augment its current consumer search interface, which allows users to look up recalls by vehicle make and model, or by the recall campaign number. Frequently, a recall may not cover all vehicles in a particular model or model year, but ones manufactured in specific plants or in specific date ranges. Instead, the agency decided to require each manufacturer of large volume light vehicle and motorcycle manufacturers to offer their own recall look-up websites, which includes a VIN field.

Tire Aging: Is NHTSA Ready to Make Policy?

Last month, at the Society of Automotive Engineers’ annual government-industry conference, a National Highway Traffic Safety Administration (NHTSA) safety standards engineer presented a summary of the agency’s tire aging work, which continues despite not producing any regulatory changes.

The issue that took center stage more than a decade ago, in the wake of the Ford Firestone rollover scandal. The deadly Firestone tires at the center of the controversy met the federal safety standards but nonetheless were de-treading at high rates after several years in service.  In 2001, Congress suggested that the agency consider the feasibility of a tire aging test, and the agency and Ford embarked on a series of experiments to create an artificial oven-aging test for tires. In 2005, the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users directed the Secretary of Transportation document NHTSA’s progress on tire aging research, and its findings and recommendations. The agency’s 2007 report to Congress did not make any policy recommendations, but did allow that it was “evaluating the feasibility of a regulation related to tire aging by analyzing the safety problem (tire aging as a significant causal factor in crashes) and potential benefits and costs of a requirement for minimum performance based on an aging method.”

Six years later, no policy and the tire aging docket NHTSA opened in 2005 is officially closed for comments. But the agency (and Safety Research & Strategies -- see SRS Tire Safety) continues to file the results of its tire age research periodically. (The most recent agency submission was in July 2012, a report entitled: “Tire Aging Testing Phase 5.”) Could NHTSA’s Dr. Merisol Medri’s SAE presentation herald the arrival of a rulemaking? Her Powerpoint was not released, (click here for a copy) but our ears perked up at this slide:

“Based on analysis of data from 2005-2007 including databases (NMVCCS, GES, CDS), 90 fatalities and over 3,200 injuries occurred annually as the result of crashes that were probably caused by tire aging or where tire aging was a significant factor.”

This statistic stands out against the agency’s numerical analysis offered in the 2007 Research Report to Congress on Tire Aging: “From 1994 to 2004, NHTSA estimates that about 400 fatalities, annually, may be attributed to tire failures of all types.”

Doing the rough math -- does this mean that about quarter of the annual tire-related fatalities are due to tire age? And, how did NHTSA arrive at that figure? Tire Identification Numbers (TIN) – the only way to discern a tire’s age – are not available in the public version of some of those datasets. (We are aware that NHTSA has begun to collect TINs for some sub-sets of crash data.) According to Medri the agency will be publishing a more detailed account of its research in a new report that will be published in the tire aging docket, at some unspecified time.

Another Domino Falls: GM Adds Tire Age Warning

On July 3, 2010, three generations of the Taylor family were returning from a family vacation in Disneyland to their home in Phoenix, when the right rear tire on their 2003 Chevy Trailblazer experienced a catastrophic tread separation. John Taylor, a retiree who worked all 38 years of his career at General Motors, lost control of the vehicle on I-10, about 45 minutes from home. The Trailblazer rolled over, fatally crushing Taylor and killing his 8-year-old grandson Quinn Levi, who was ejected when the third-row seat belt unlatched. Taylor’s wife, Eileen, his son-in-law, Bill, and his daughter Susanne Levi, who bought the Trailblazer with her father’s employee discount, suffered upper body injuries. The youngest son, secured in a child safety seat, was unharmed.

The tire that failed was a seven-year-old full-sized spare that had been rotated into service in 2007. Before that, it stayed stored in the spare well, right up near the engine exhaust system, where the hot exhaust pipe, combined with the brutally hot climate of Phoenix, accelerated the thermo-oxidation of the BF Goodrich Rugged Trail tire, diminishing its strength.

“This was the perfect storm” says Phoenix attorney Curt Clausen, who represents the Taylor-Levi family in a civil lawsuit against manufacturer General Motors.

Moving Tire Recalls into the 21st Century

Safety Research & Strategies has urged the National Highway Traffic Safety Administration to add Tire Identification Numbers to a newly mandated web portal to identify recalls.

In September, the agency published a Notice of Proposed Rulemaking on the possible changes to the provisions regarding Early Warning Reporting data. It also proposed requiring automobile manufacturers to submit Vehicle Identification Numbers (VIN) of specifically recalled vehicles, and maintain records of the recall remedy status of each specific vehicle. This was a requirement of the Motor Vehicle Safety Improvement Act, contained within the highway re-authorization bill known as Moving Ahead for Progress in the 21st Century Act, MAP-21, for short.

The recall statute mandates that NHTSA require that motor vehicle safety recall information be made available to the public on the Internet, and authorizes the Secretary of Transportation to require each manufacturer to do so. In the NPRM, NHTSA explained that it already had a website where consumers can look up recalls by vehicle make and model, or by the recall campaign number.  It proposed to simply add a VIN field to its current search capacity.

The authors of MAP- 21, however, forgot to require the same of tire manufacturers. SRS has submitted comments to this docket suggesting that the agency add a TIN-look-up, along with a VIN.

The omission is another sad chapter in the history of the Tire Identification Number (TIN) and tire safety. The Tire Identification Number has its origins in a Rubber Manufacturers’ Association strategy to seize the regulatory reins from the National Highway Safety Bureau, predecessor to NHTSA, as the tire identification standard was promulgated more than 40 years ago. It was established to help consumers identify tires in a recall. But, as is the case in many rulemakings, industry fought hard to mold the regulations to its own ends and convenience.

It’s Tire Safety Week! Is There Anything to Celebrate?

In April, materials scientist John Baldwin bluntly schooled insiders at the annual Tire Industry Conference about things the rubber industry has known for decades from its own internal research. He pointed out that relying on tire tread depth to determine the viability of a tire is a bit of a crapshoot:

“In the tire industry, a lot of decisions are based on tread depth,” he said. “But what is the significance of tread depth? There is uneven wear on damn near every tire.”

He took note of the unsafe practice of rotating unused, but old spares onto vehicles:

“The average full-sized spare tire is nine years old,” he said. “You can tell your tire store to take that perfectly good spare tire and put it on your car. But if you’re in Yuma or Miami, do you really want that nine-year-old spare going on? “Meanwhile, the average mini-spare is 12 years old. That means you’re screwed.”

And he took exception to what he calls the Rubber Manufacturers Association’s (RMA) mischaracterization of his tire aging research for Ford Motor Company.

NHTSAball: How the Agency Plays the Game

Moneyball has opened in the movie theaters, starring Brad Pitt as the redoubtable Billy Beane, general manager of the Oakland Athletics. Beane had been a future baseball superstar who washed out after three seasons of bench-warming and bouncing between Triple-A and major league teams. He was, however, that rare individual who resisted his own PR, which was certain and glowing, and the perfect foil for the movie’s real subject: baseball statistics and how numbers could guide a poor team like the A’s to the playoffs more regularly than the conventional wisdom said was possible.

The A’s, as Michael Lewis, author of the book on which it is based describes the team, was populated with Major League’s castoffs – catchers and pitchers who looked more like beer-swilling bowlers, college prospects that the talent scouts had deemed too cold to bother with, and a computer nerd for an assistant GM.  But Beane knew from his own field experience just how wrong Major League Baseball could be in assessing players. He chose, instead, to exploit a different set of metrics developed by a passionate fan who happened to be statistically apt, but shunned by the rest of Beane’s peers. Using this recipe, he cobbles together victory after victory.  The book roughly follows the A’s during the 2002 season, from the June amateur player’s draft to the historic September 4th game, in which the A’s won their 20th consecutive game – breaking a 102-year old American League record.

Among the book’s heroes is Bill James. James is the quirky inventor of Sabermetrics, the statistical analysis of baseball data, used to better understand success and failure in the game. James had a restless, numerically inclined mind and, it would be fair to say, an obsessive interest in baseball. The marriage of his aptitude and his interests produced a series of abstracts and books on baseball metrics, beginning in 1977. At first, James was ignored by all but a handful of fans. But, eventually, he gained a following. And in 1997 one of them became the manager of the Oakland A’s.

If the narrative has a villain, it’s Major League Baseball itself. Wholly in the thrall of its own myths, this billion dollar enterprise, when it bothered with data at all, used it incorrectly. Rich teams could skim the obvious cream of talent, but beyond buying wins, hadn’t a clue how it was really done.

Lewis’s point was that even with huge sums of money at stake, those most vested in the outcome can be utterly blinded by their own subjective biases. Once biases are institutionalized, they become facts, stubborn in the face of new or competing or different information. Those who can’t even identify the data that should be informing critical decisions – let alone using it properly – are bound to make expensive mistakes.

So what’s The Safety Record’s point? We saw a number of striking parallels to the way NHTSA operates, when it comes to numbers.  The agency is, ostensibly, data-driven and science-based. Hell, it slaps that phrase on everything from Powerpoint presentations to appropriations requests. But there’s plenty of evidence that the agency dismisses – out-of-hand – outside information; that long-held beliefs hamper its data analyses; that it pays way too much attention to data that is not useful and fails to collect data that is.

Moneyball: For example, here Lewis characterizes James’ assessment of MLB’s metrics:

“Worse, baseball teams didn’t have the sense to know what to collect, and so an awful lot of critical data simply went unrecorded.”

NHTSAball: There’s lots of data NHTSA doesn’t collect. For example, the agency has promulgated a recall system for tires that is predicated solely on the Tire Identification Number. Years of rulemaking were devoted to debating the format of the TIN, popularly known as the DOT code, an 11-character, alpha-numeric code that represents the plant, size, date of manufacture molded into the sidewall of a tire. The aim of the TIN was to identify a recalled tire and it is the only definitive measure to do so.  Does NHTSA require tire makers who recall their products to list the range of TINs in the recall population? No, it does not. Some manufacturers report it; others don’t. NHTSA’s good, either way. The DOT code would be a nifty little data point in any tire-related fatality in the Fatality Analysis Reporting System. The agency could use such data to identify tire failure trends, but it remains information uncollected. And while we’re on tires, NHTSA doesn’t require manufacturers to report tire claims if the tire is older than five years – so no data, no problem for the aged tire issues that took center stage following Firestone recalls in 2000 and 2001 and remain a constant source of catastrophic crashes.

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