November 16, 2012
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.
In the past, when tire recalls were relatively rare, and before the problems associated with tire age came to the fore, tire-makers were successful in keeping the TIN an obscure set of alpha-numeric characters that even some retail tire salesmen couldn’t decode. The Ford Explorer-Firestone tire recalls of 2000 and 2001 forced regulators and manufacturers to look at the TIN with fresh eyes. But neither has finished the work of making this information accessible so that consumers can fully participate in recalls and make good purchasing decisions.
In October 2009, as part of an EWR rulemaking, the agency started requiring tiremakers to include a range of TIN numbers for a recalled tire population. Prior to the rulemaking, some manufacturers submitted them voluntarily, some did not. This was an important step, because most recalls are manufacturing defects and refer to specific lots of tires.
Nonetheless, manufacturers and large retailers do not have a database for checking recalls at the service level.
“What’s amazing is that in 2012, when you go to a service center to get a tire safety check no one can tell you whether your tires are recalled,” says SRS President Sean Kane. “There is no database that allows you to determine specifically if an individual tire is recalled. And that should be shocking to consumers.”
The only public repository of tire recall information is located on the NHTSA website. It requires users to enter the tire’s make and model to determine whether it has been recalled, then retrieve the documents associated with the recall to determine if that make and model is actually part of a recall. The defect report on file with the agency contains the TIN range of the recalled tires – and a consumer or tire tech can only rely on that information being there if the recall is after 2009, when manufacturers were required to provide it. This process is time-consuming and challenging for the uninitiated and is completely unrealistic for the service industry.
In addition to the difficulty of finding the recall information specific to a particular tire, the TIN itself remains obscure on two levels. One, the complete TIN may still be located on the inside sidewall, where consumers cannot easily read it. Two, manufacturers have been successful in dissuading NHTSA to require that the tire date of manufacture be expressed in a non-coded form.
The obscurity of the TIN and the lack of a database to determine if a tire has been recalled are among the contributors to the low rate of return on tire recalls and why defective tires keep finding their way onto vehicles, failing, causing injuries and deaths. Absent these basic elements of information, defective recalled tires get re-sold on the used tire market, or rotated into service from the spare position.
“As long as a tire looks okay – has good tread on it, it will be used,” Kane says. “And that’s why we continue to see cases in which people are injured and killed by recalled tires. If you have a recalled tire from 10 years ago, which the tire shop learned about from a bulletin in 2002, how is a tire tech going to know today that this tire has been recalled? Many tire changers were probably still in grade school at the time.”
“Similarly, this applies to aged tires – if the tire has good tread it will likely find its way into service regardless of how old it is. Despite the bulletins and owner’s manual warnings the industry has done virtually nothing to educate service techs on tire age and safety.”
And that brings us back to another critical item of the agency’s unfinished tire agenda – tire age. NHTSA first initiated a proposed rule on tire aging in 2003 that suggested several potential methods to artificially age a tire and test it. The industry opposition was strong and the agency, which had little experience in tire testing and lacked data was relying on the industry to provide technical insight in order to promulgate a rule. For the most part the tire industry simply denied an aging affect event existed despite the material science and its own internal testing. This setback for NHTSA was significantly offset by Ford Motor Company researchers, whose work, along with NHTSA’s developed artificial tire aging protocol.
For years, NHTSA has been evaluating the feasibility of a tire aging standard and weighing the potential benefits and costs of a minimum tire performance requirement based on an aging method. In 2008, NHTSA published Vehicle Safety Rulemaking and Research Priority Plan for 2009-2011. Among its priorities was the development of a regulation to require an oven-aging test for tires prior to running them through an endurance test. This could help reduce tread separations that occur in hot weather States by ensuring a minimum level of robustness.
The agency didn’t publish a proposal last year. It has not required the complete TIN to be molded on both sides of the tire and the date of manufacture is still in code. Now the agency is revamping its recall search web portal to include VINs but not TINs.
Will the agency complete its work?