UK Tire Age Bills Moves Forward

While the National Highway Traffic Safety Administration has put aside tire age regulations, Great Britain is inching forward with a bill to ban tires older than 10 years on commercial buses and coaches.

The legislation is the result of a campaign by Frances Molloy, whose 18-year-old son Michael died on July 16, 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, with legal tread-depth, had been purchased secondhand by Merseypride Travel, which owned the 52-seat coach. In December 2013, after a public inquiry by the North West Traffic Commissioner, Merseypride lost its license to operate public vehicles.

The bill, sponsored by Walton MP Steve Rotheram, requires that Public Service Vehicle operator’s license be granted on the condition that the tires on the vehicle be no more than ten years old. It is an amendment to an existing The House of Commons had ordered the Tyres (Buses and Coaches) Bill 2015 to be printed in July, after its first reading, and later this month, the bill is scheduled for a second reading in the House of Commons. (These are very preliminary stages in the British legislative process. The second reading allows members of Parliament to generally debate its merits. The bill gets closer scrutiny in the next, committee stage, in which experts and interest groups can testify. If the bill survives the committee stage, it returns to the chamber for a debate.)

Molloy has been lobbying for a tire age law since 2012, drumming up political and industry support. In 2012, Molloy and accident re-constructionist David Price met with Secretary of State Patrick McLoughlin, who reports directly to the Prime Minister, to solicit his support. While McLoughlin declined to support a tire age bill, in December 2013, the Department of Transport issued guidance for firms registered with the Vehicle and Operator Services Agency: “As a precaution, the Department for Transport strongly recommends that tyres over 10 years old should not be fitted to the front axles of buses and coaches.”

In October, Molloy, chief executive of Health@Work and chair of Liverpool Community Health NHS Trust, spoke at Brityrex International’s TyreTalk seminars. Molloy also won the backing of the Chief Fire Officers Association – fire departments respond to road crashes – and The National Tyre Distributors Association, which represents new tire retailers.

Molloy says that the NTDA acknowledged that tire age was a conversation that the organization’s members didn’t want to have, but had to have. She made her position clear:

She was willing to listen to the science of tire aging in order to develop the most appropriate policy: “But [the solution] cannot be anything but legislation,” she said. “It has to be something in law, that if you don’t follow it there will be consequences. I’m not negotiating on that.”

In advance of the second reading, Molloy will be featured in a BBC documentary called Inside the Commons. The February 17 episode will show Rotheram’s work with Molloy on tire aging, and she hopes it will win the proposal more advocates in that chamber.  But, if the timing of the documentary episode is good, the timing of the second reading is not. It will be the last of three bills to be heard on a Friday afternoon. Molloy and her bill have to keep at least 100 MPs around long enough to support it, before it can advance to the Committee stage. If it fails to garner enough support, any further legislative action will have to wait until after the general elections in May.

“The second reading is very important, there’s a lot of challenges,” Molloy says. “But I will not give up. I will keep going and I will wear them down before they wear me down.”

The Run Down on the NTSB Tire Symposium

Last week, the National Transportation Safety Board (NTSB) brought together tire industry players, federal regulators, and consumer advocates for a tire safety symposium to evaluate the tire recall system, new technologies, tire age and service life, and consumer awareness in preparation for a tire safety report and recommendations scheduled for release next year.  The intervention by the NTSB, which provides formal safety recommendations independent from NHTSA, signifies an important step in pressing for industry and regulators to address these unresolved safety issues.

But turning around the leaky super-dreadnaught that is our tire recall system isn’t going to be easy. Forty years after the Tire Identification Number (TIN) system was created, techs and consumers are still forced to rely on pen and paper and a lot of searching to figure out whether a tire has been recalled.  While most vehicle and tire manufacturers have issued recommendations and warnings on tire age (i.e., maximum service life), these practices are still little known and rely on consumers and service providers to decode the date of manufacture hidden in the alphanumeric TIN. While most other industries have installed automated systems to individually track goods, but the tire industry has no such mechanism – despite its important role on a vehicle. And TIN numbers are not machine readable; thus, when they move through the distribution chain, retailers and servicers cannot easily determine the tires’ age and recall history in their inventory or for customers who rely on them. The result is that recalled and over-aged tires (that look like perfectly serviceable tires) slip through the cracks undetected. 

Symposium Highlights

By far, the best moment in the two-day confab was symposium chair Earl Weener’s rebuke of the Rubber Manufacturers Association’s assertion that it just can’t change anything about the way it does anything. For example, Tracey Norberg, the RMA’s Senior Vice President of Regulatory Affairs and General Counsel argued that it would be too difficult to radio-frequency identification (RFID) chips into tires. (RFID chips could store the tire’s age and recall information allowing dealers and service techs to scan the tires every time they inspect a vehicle.) Such technology would be challenging, she said, because it could change the structural integrity of the tire – not to mention all the complicated questions about what information to put on the chip, how it’s used, and who will read it and how.

Weener wasn’t buying it:

“That’s interesting because I think an awful lot of people in this audience have an iPhone. That iPhone can read QR codes, can read barcodes, can read UBS codes. But somehow that is too much technology for the tire manufacturers and for the tire distribution process. You know, you go to the airport and about every third person checks in with their iPhone, with a barcode on them,” he said. “So it seems to me that maybe some imagination is required.”

Imagination? Tire manufacturers have been developing RFID technology in tires since 1994. Michelin, Goodyear and others have been embedding RFID tags into commercial and racing tires for years.

Weener noted that despite the TREAD Act, in place for 14 years, NHTSA’s revisions to the tire endurance and resistance standards, and the tire pressure monitoring systems (TPMS) requirements, “…we are still seeing accidents—accidents these measures were intended to address. By holding this symposium, our goals are to explore the effectiveness of these various initiatives in improving highway safety, and identify what additional work needs to be done.”

Much of the symposium was littered with the same arguments we’ve come to expect: NHTSA and the manufacturers continued to point the finger at consumers—tire-related crashes would be minimal if only consumers would perform weekly tire inspections, constantly monitor air pressure and tread depth, have service stations regularly rotate and inspect their tires, do extensive research before purchasing a tire, know better than to buy a used tire, and promptly send in the registration card dealers always helpfully provide so that diligent manufacturers can inform them as soon as there is a recall. As the RMA’s Dan Zielinski said, “there certainly are a number of people talking about [the importance of tire maintenance] and in very a consistent way, and it’s easy for consumers to find, but we’re still facing a significant population that’s not always paying attention to it.”

Other noteworthy moments:

  • NHTSA cites faulty data. Randy Whitfield, of the data-analysis firm Quality Control Systems Corp., dropped a bomb during his presentation on tire safety data, showing that the data that NHTSA has relied on to show that tires are safer is not accurate. Whitfield performed a detailed analysis of the NHTSA’s Fatality Analysis Reporting System (FARS) database—which records all tire-related fatalities. Whitfield’s assessment, sponsored by non-profit The Safety Institute, indicates that the number of tire-related crashes and resulting deaths has remained relatively constant since 1995. Despite acknowledging that Whitfield is right about the FARS data, NHTSA pointed to a study showing that tire-related deaths and injuries have decreased by half since Federal Motor Vehicle Safety Standard 139 made tires more robust. But Whitfield told the NTSB “that’s just not true” because the agency is looking at a survey with a small sample size of crashes involving light passenger vehicles towed for tire-related damage, rather than evaluating all tire-related crashes. Whitfield’s science-based conclusions failed to stop the data-driven NHTSA from quoting the same incorrect figures later in the day. 

“It was stunning to me that a speaker following my talk and following even NHTSA’s statistician’s talk, which confirmed my numbers, was making statements that tire-related casualties have come down,” Whitfield said. “That means we live in a fact-free zone, and that’s dangerous.”

  • Infighting in the industry. There was also dissention in the industry ranks. The RMA, whose members include eight tire manufacturers, and the Tire Industry Association (TIA), made up predominantly of tire dealers, have always held fast to the voluntary system that requires retailers to hand consumers the manufacturers’ registration cards. But now the RMA wants to put the burden solely on the retailers. At the symposium, RMA’s Norberg announced that the group wants a mandatory registration system requiring retailers to electronically register the tire at the time of the sale.

That drew ire from the TIA’s Kevin Rohlwing, who said it’s already too big of a burden for retailers to have to stock registration cards from several manufacturers—instead, retailers should just have to give the customer the TIN and tell them what website they can use to register the vehicles. For too long, the industry has put the entire burden for the registry system on the dealers without providing them with the tools they need to easily do the job, and it looks like the dealers have had enough. (The same can be said about the tire age recommendations.)

  • Tire aging got some of the spotlight. The industry leaders stuck to the same old story that tire age isn’t nearly as important to preventing a crash as keeping the tires properly inflated, without explaining how air pressure is going to keep a 13-year-old spare tire from detreading on a hot highway when it’s put into service. The RMA also offered its age-old argument that there is no “one date” when a tire becomes too old, so a tire expiration date of six or 10 years would force consumers to spend money on a tire that could still be serviceable for several more years. (The RMA continues to ignore the 10 year recommendations of many of its members.)  Sean Kane of Safety Research & Strategies, who presented at the symposium, countered by comparing it to blood alcohol content, saying “we have recommendations for blood alcohol. The states have adopted a .08. And there’s a reason for that. Does that mean that everybody at .08 is going to crash their car on the way home? I don’t think so. I think we understand that there’s an increased risk at that point, and it’s a good point at which we want to cut that off and draw a line in the sand.”

Norberg also mentioned offhand that if tire makers were only interested in money, they would want a tire-aging standard because then they could sell more tires. What she and the manufacturers forgot to mention is that rubber manufacturers have an antiquated logistics and supply chain that doesn’t individually track tires.  The result is that, especially with the proliferation of sizes, tires in the retail stream can be in excess of a year old. When a customer knows that the product has an expiration he or she will likely insist on newer tires or a discount on the older ones. Someone has to pay for that. The only way to avoid those costs is to implement an individual tracking and automated system.


The NTSB’s Tire Safety Report

The NTSB’s 2015 report that will include detailed examinations of at least two fatal tire-related crashes that occurred in February 2014. On February 15, the left rear tire on a 2004 Kia Sorrento detreaded, causing the driver to lose control, spin out through an interstate median, and crash into a school bus carrying 34 members of a Louisiana high school baseball team in Centerville, La. Four of the Kia occupants died, and the fifth was severely injured. Thirty of the bus passengers suffered injuries. The Michelin Cross Terrain tire was 11 years old when it failed. 

A week later, on February 21, the left rear tire on a 2002 Ford 350 XLT 15-passenger van experienced a complete tread separation while driving on an interstate in Lake City, Fla. The driver lost control, and the van swerved onto an embankment and rolled over. Two adults died, and all of the other occupants, including several children, suffered injuries. The tire had been recalled shortly after Sam’s Club put it on the vehicle in 2012 because it had a potential for tread loss or rapid air loss from a tread-belt separation. Sam’s Club mechanics inspected the tire in November 2013 but failed to identify and remove the recalled tire.  Neither retailers nor the tire manufacturers have a recall system that allows consumers or service professionals to determine whether a specific tire is recalled. 

The two crashes highlight the dangers of the outdated tire identification and recall system.

Tire recall notification relies on retailers providing consumers with registration cards that need to be completed with the TIN and sent to the manufacturers.  In some cases tire dealers register tires at the point of sale – but that still requires a manual process of transcribing 11 alpha-numeric characters off each tire (accurately) into a system that is then transmitted to the manufacturers.  It’s a slow arduous process that is not conducive to high registration rates and remediation which is in part why tire recall return rates average less than 30 percent. 

Assuming consumers do learn of a recall, there is no database that allows them to search for recalls by TIN number.  (Date codes on tires are found in the last four digits and are coded by the week and year.  For example 4313 equates to the 43rd week of 2013. Tires prior to 2000 relied on three digits and confounding this system are the NHTSA requirements which mandate a complete TIN with the date code only on one side of the tire.  TINs also contain codes associated with the plant of manufacture, size and model and are not unique identifiers, thus thousands of tires can have the same TIN number. 

So to determine if the tire has been recalled, servicers and consumers must still find the full TIN—sometimes requiring that they lie down under the vehicle with a flashlight, if only the partial TIN is showing—then search through NHTSA’s database by make and size and pour over the lists to see if the TIN number is included. It’s a confusing and laborious process retailers and servicers do not have time to undertake and consumers often don’t understand.

On the tire age/service life front, most of the industry has acknowledged in the last decade that tires degrade over time regardless of use and should be removed after about six to 10 years.  Spare tires, tires on little used vehicles and used tires with adequate tread often exceed these recommendations and still appear serviceable (See “Aged” Tire Case Numbers Grow

NHTSA has been researching the issue of tire aging since 2003 and has confirmed that age plays a role in tire safety but has declined to do anything other than advise consumers to follow recommendations from automakers and tire manufacturers.  Nearly every automaker recommends removing tires after six years, and many tire manufacturers recommend removal at 10, but those recommendations are buried in owner’s manuals and technical bulletins, and—despite all the talk about increasing consumer awareness and education—the industry players have consistently failed to tell even their own dealers and servicers that aging is a safety concern. And if consumers were better informed about the dangers of tire aging, the only way to find out a tire’s age is to decipher the odd date code in the TIN.

These problems could be fixed by utilizing scanning technology that’s been available for years that can include RFID or QR codes for example (see Tire Recalls and Tire Safety: The RFID Solution) that could automate the information needed.  But efforts to seriously consider these changes have been repeatedly stymied by the tire manufacturers, led by the RMA, which is intent on passing the responsibility to everyone else – NHTSA, dealers, and consumers. 

The general take: the NTSB is really paying attention and may issue recommendations urging NHTSA and the industry to finally implement some common-sense tire safety regulations and practices. The NTSB is best known for its investigations of aircraft crashes, but the board has played an important role in advancing motor vehicle on issues ranging from the inclusion of rear-seat lap and shoulder belts in the 1980s to recent improvements in highway and rail grade crossings.  More than 80 percent of NTSB recommendations have been adopted.  Typically, NHTSA’s first reaction to the NTSB’s advice is to ignore it, but maybe for reasons we cannot fathom, this time will be different. The Safety Record can dream anyway.

A webcast of the symposium and the panelist presentations is available here.

Texas Attorney Asks NHTSA for Tire Investigation

National Highway Traffic Safety Administration Chief Counsel O. Kevin Vincent’s message to the defense bar a few months ago at a legal conference was pretty clear – keep us in the loop, or risk the consequences. NHTSA’s message to the plaintiffs’ bar has been more like radio silence, so it will be interesting to see what the Recall Management Division does with a request to investigate the failure of a tire distributor to recall a defective Chinese tire already recalled by a different distributor, marketing the same tire under a different brand name. 

Michael Cowen, of the Cowen Law Group in Brownsville, Texas wrote to the agency today asking for an Equipment Query regarding Hercules A/T radial tires sold by the Hercules Rubber & Tire Company.

Cowen represents Krystal Cantu, 25, who lost half of her right arm in an August 2, 2013 crash caused by a catastrophic tread separation. Cantu was a front-seat, belted passenger in a 2004 Ford Explorer Sport Trac, when the left-rear tire – a Capitol Precision Trac II – failed as the vehicle traveled southbound on Interstate 37 in Atascosa County, Texas. The driver lost control when the vehicle skidded; Ms. Cantu’s right arm was crushed in the subsequent rollover.

ITG Voma cited this crash in its October Part 573 Notice of Defect and Noncompliance to recall 94,890 Capitol Precision Trac II tires manufactured between December 2008 and May 2010. The defective tires, actually manufactured by Shandong Yongsheng Rubber Co., Ltd., lacked a nylon cap ply, which made the tires less robust and prone to tread separations.

“Selling essentially the same tire and under a different brand that isn’t covered under the recall needs to be thoroughly investigated by NHTSA.  Our request and the information submitted to the agency should assist them in obtaining a complete accounting of all the tires that need to be taken off the roads” Cowen said in a press release. 

On April 2, 2014, Cantu filed a lawsuit against Voma and the Shandong Yongsheng Rubber Co., Ltd., among other defendants. During the discovery phase of the case, a manufacturer’s representative revealed that the Capitol Precision Trac II shared a common green tire designation with another tire branded as the Hercules Radial A/T in eight different sizes. NHTSA defines a common green tire as “tires that are produced to the same internal specifications but that have, or may have, different external characteristics and may be sold under different tire line names.”  This means that the Hercules A/T and Capitol tires are essentially the same.

Under federal recall regulations, the company that brands the tire is considered the manufacturer, and is responsible for reporting defects to NHTSA and launching a recall. In a December 17 letter, Cowen asked the agency to open a defect investigation called an Equipment Query to pursue the Hercules Rubber & Tire Company, a marketer of replacement tires, headquartered in Findlay, Ohio and a partner of the Cooper Rubber & Tire Company, to launch a recall.

In 2007, Foreign Tire Sales (FTS), a tire importer based Union, New Jersey launched a recall after discovering that tires manufactured by the Hangzhou Zhongce Rubber Co. Ltd for FTS had been built without or with inadequate .6mm c-shaped gum strips used to prevent the separation of belts. The recall followed a legal claim alleging that a catastrophic tread separation of a Telluride 245175R16 tire manufactured by Hangzhou and sold by FTS caused a fatal rollover crash. FTS had claimed to NHTSA that Hangzhou sold similar tires via other importers. The agency’s Recall Management Division responded by sending letters to 17 tire importers/distributors of Hangzhou tires.

The EQ was eventually closed with no further action – all 17 distributors claimed that they had none of the defective tires.

“This underscores the important role litigation plays in identifying safety defects” says SRS President Sean Kane. “It will be interesting to see how many of these defective tires actually come out of service in this campaign given the failed recall system.”

The weaknesses of the current tire recall system were among the topics discussed at length last week at a tire safety symposium hosted by the National Transportation Safety Board. The NTSB held the meeting in advance of a tire safety report and formal recommendations, expected to be issued next year.

How About a Tire Identification Number Consumers Can Read?

NHTSA’s tinkering with the foundation of the tire recall system, but we doubt it will do anything to make it stronger. The proposed changes to the Tire Identification Number regulations will make things less confusing for manufacturers and NHTSA – consumers and tire technicians that use the TIN to determine if tires are recalled or too old – not so much. Safety Research & Strategies has submitted comments suggesting that the agency actually make the TIN useful for the public it was intended to serve. Read them below: 

August 25, 2014
The Honorable David Friedman
Acting Administrator
National Highway Traffic Safety Administration
1200 New Jersey Avenue, SE
West Building
Washington, DC 20590
RE:       Comments on Tire Identification Number and Recordkeeping; Docket 2014-0084
Dear Acting Administrator Friedman:

We are pleased that the agency is proposing to standardize the length of the Tire Identification Number (TIN) “to eliminate confusion,” and perhaps “assist consumers with identifying whether their tires may be subject to recall.” As the Notice of Proposed Rulemaking notes, the TIN: “plays an important role in identifying which tires are subject to recall and remedy campaigns for safety defects and noncompliances.”

The TIN plays another critical role in tire safety: it assists consumers, tire technicians and other service providers in determining a tire’s age. For this reason, Safety Research & Strategies urges the National Highway Traffic Safety Administration to add to this proposal a section requiring the TIN to include a non-coded date of manufacture. This amendment is made more imperative by the agency’s decision to forego a rulemaking on tire age, in favor of consumer education.
In March, the agency released a report summarizing its research on the hazards of tire age. [1]  The Executive Summary clearly defines the phenomenon:
Tire aging is a phenomenon involving the degradation of the material properties of a tire which over time can compromise its structural integrity and jeopardize its performance. Tire aging takes place whether a tire is driven or not and for this reason is a concern for spare tires and tires that are not regularly driven. The effect of aging may not be visibly detectable on these tires and their integrity may be compromised even though they could be showing a great deal of remaining tread.
Further, Tire Aging: A Summary of NHTSA’s Work acknowledges the effect of tire age on tire failures:
NHTSA research also found that especially in the warmer parts of the United States, including Arizona, Florida, Texas and Southern California, there appears to be a relationship between the age of the tire and the propensity of the tire to fail.
Finally, the report documents the agency’s recognition of hazardous tire age scenarios:
Tire aging is still a concern in the more southern parts of the Sun Belt states, during the summer months when heat build-up can cause a failure. Spare tires remain a concern as well, since they are not replaced regularly and may still show enough tread, even though the structural integrity of the tire may be compromised by aging. Adding to this concern, spare tires are often rotated into use and are sold as used tires.
In this report, the agency announced its intention to coordinate “a promotional and educational initiative to raise consumer awareness about tire aging issues and how to prevent these types of failures,” including “social media messages, fact sheets, infographics, and other web content.”
But before the agency begins to tweet about tire age and build its message on social media platforms, it ought to give consumers a basic tool for identifying a tire’s age on the tire itself – a non-coded date of manufacture.
In 1970, when the Tire Identification Number was established, tiremakers expressly protested the National Highway Safety Bureau’s attempt to create a TIN that consumers could decipher. Firestone, in particular argued that the bureau should adopt
what was then the Rubber Manufacturers Association’s two-symbol date code to obscure a tire’s age.
Tires are not perishable items. Therefore, a conspicuous disclosure of tire age would unavoidably introduce into the marketplace a totally artificial measure of quality unrelated to product performance and effectiveness.[2]
Even by 1970, tiremakers had long been aware, through their own research dating back to the 1930s, of the material degradation caused by thermo-oxidative aging.  Forty-four years later, that knowledge is no longer the sole provenance of the rubber industry – NHTSA, auto manufacturers and a number of the major tire companies publicly acknowledge that aged tires should be removed from service for safety’s sake. But none of these entities has made it easy for consumers to follow their recommendations.
In December 2001, the agency published a Notice of Proposed Rulemaking to establish a new standard to the existing labeling requirements and addressed, among other issues, the TIN and tire markings.[3] As part of its research, the agency conducted a series of eight focus groups to determine what consumers knew about tires and safety and what they would like to know. The agency’s research, which formed the basis of the proposal, found that consumers were confused by the codes, but wanted to learn more about what they meant.[4] Among the specific findings of the study were:
  • No more than one or two study participants had any understanding of more than a little of the information on tires. Some know that they can find tire pressure, tire type, weight/load rating and brand name. But few had any concept of the full range of information available. And no more than one or two could begin to explain the codes, ratings and other information.
  • Most study participants were perplexed by the array of alpha and numeric codes appearing on the demonstration tire. Although they suspect that the codes may hold interesting, even useful, information, none of the persons taking part in this study could identify or describe the meaning of the majority of codes, grades and scores.
  • Many wanted to know what the tire codes and ratings mean. Although some study participants indicated little or no interest in knowing anything more about tires than they already know, a number expressed a desire to know more about the meaning of the information that appears on tires. Most said that they felt it would make them better informed consumers.
  • Some study participants wished additional information was shown on tires. After they had looked at the information already contained on tires, some suggested that the following information was also displayed: Date of manufacture. Recommended replacement interval.
  • Study participants wished tire information was presented in “plain language.” Since they tend to believe that information provided on tires “is there for a reason,” they wished it was displayed in a more understandable format. Codes may be appropriate for the trade, they suggested, but not for consumers.
The agency failed to heed the results of its own study. Instead of adopting a “plain language” standard, it proposed re-ordering the TIN information and requiring that the information be molded on both sides. In the Final Rule, the agency amended its proposal and only mandated that the full TIN be molded on the outward sidewall. This has added to the confusion for consumers trying to discern their tire’s age, because unfortunately, tires are not always mounted with the complete TIN on the outside.  
Beginning in 2003, Safety Research & Strategies and its predecessor, Strategic Safety have been submitting comments to rulemakings related to tire age, tire identification and tire recalls. In many submissions, we have suggested that the agency improve tire safety by making the TIN readily accessible and understandable with the same aims stated by NHTSA: to ensure that consumers can identify recalled and aged tires. Most recently, we recommended that NHTSA add a TIN search function to its public Web portal and require tire makers, as well as automakers to maintain the recall remedy status by TIN, as improvements to the recall notification regulations are established. NHTSA declined our recommendation, because Congress had not mandated that it do so.
When the agency fails to consider human factors in rulemaking, safety suffers. An example from NHTSA’s regulatory history is permitting keyless, electronic ignition systems without considering how these systems would disrupt long established driver behaviors. In allowing the “key” to be an invisible electronic code, housed in a fob that only plays a role in starting the vehicle, but not in shutting it off, the agency re-introduced the rollaway hazard and added a carbon monoxide poisoning problem that had not existed heretofore. The agency is still in the process of a rulemaking to fix this error.
If the TIN is to be worthy of its intended purpose, the agency should take the next step and require machine-readability. A non-coded date of manufacture will help the average consumer and tire tech determine a tire’s age. Requiring a standardized, computer readable TIN would provide a much needed automated method for manufacturers and service providers to quickly address recalled tires or tires that were beyond their service life recommendations.  I refer the agency to our 2007 report on RFID in tires, “Tire Recalls and Tire Safety: The RFID Solution,” which explains how RFID tags could improve the tire recall system: “With a chip embedded in the sidewall and inexpensive readers installed in service shops (or an interface with the vehicle computer), motorists could have the status of their tires checked every time they take their vehicle to be serviced, or through their instrument panel.”[5] RFID in tires is not new and appears in many manufacturers tires – and it is but one available technology.  Laser-etched QR codes are another that allow access to vital tire information via a scan.  The agency can play an important role in shepherding the TIN into the 21st century. 
In the meantime, if the agency wants to put the burden on consumers – rather than manufacturers – to understand and act on the dangers of tire age, then it is the agency’s absolute obligation to make it possible to the public to understand a tire’s age. We urge NHTSA to amend this rulemaking to require a TIN with a non-dated code of manufacture, before it focuses on boosting its Facebook likes. 

[1] Tire Aging: A Summary of NHTSA’s Work; Pg. 3; National Highway Traffic Safety Administration; March 2014

[2] The Firestone Tire & Rubber Company; Docket 70-12-No.1-076

[3] Docket 2001-11157; 66FR 65536; December 19, 2001

[4] Tire Labeling Focus Group Report; Docket 2001-11157-07; Equals Three Communications; May 14, 2001


Tire Industry gets Anti-Aging Reality Check

It’s not often we encourage our readers to read a trade journal article, but a recent  commentary in Tire Review by Editor Jim Smith is a go-to.  The article is shockingly honest and puts the brakes on the industry’s claim of victory following NHTSA’s announcement that it wouldn’t pursue a tire aging standard. 

Smith also points out the agency’s findings on tire aging – while no surprise to tire and automakers – should make it abundantly clear the industry’s problems are far from over.  And it’s refreshing that we’re not the only ones who are continually confounded by NHTSA’s reports.  “NHTSA couldn’t decide on what it is defending” says Criswell.  Take a read of Decoding NHTSA’s Tire Aging Report.

If you missed our earlier blog see: NHTSA to Initiate Consumer Awareness Campaign on Tire Age – No Standard Needed

[Note: The initial version of the Tire Review article was credited to Kristen Criswell and later changed to Jim Smith.]

NHTSA to Initiate Consumer Awareness Campaign on Tire Age – No Standard Needed

NHTSA to Initiate Consumer Awareness Campaign on Tire Age – No Standard Needed.    

No surprise that NHTSA isn’t going to regulate tire age – but now that agency plans to initiate a consumer awareness campaign about tire aging after years of research data showing that aging can present a safety problem particularly in the high heat states.

NHTSA has (again) announced that it will not create a safety standard based on tire age.  In a recently released report NHTSA stated “At this time, the agency does not believe it is necessary for motor vehicle safety to add a tire aging requirement to its light vehicle tire standard.”  The basis for this decision was that revised safety standards promulgated following the passage of the TREAD Act in 2000 made tires more robust.  The agency also claimed that “light vehicle tires are performing better on the road as reflected in our most recent crash data” and that “TPMS (tire pressure monitoring system) on light vehicle tires since 2007 has helped alert consumers to underinflation that is also known to degrade tires faster.”

This comes as no surprise to veteran NHTSA watchers and those who have followed the tire age debate during the past decade. 

“The real problem associated with aged tires and aged tire failures is rooted not in the lack of a new test regimen, but in the tire labeling and manufacturers unwillingness to adequately educate dealers and motorists about when tires should be removed from service” said Sean Kane, President of Safety Research & Strategies, a long-time advocate for addressing tire aging hazards. 

It is undisputed that tire age is a factor in tire safety.  NHTSA research data has shown for years that tire aging can present a safety problem particularly in the high heat states.

In November 2004 Safety Research & Strategies petitioned NHTSA to initiate rulemaking to require a consumer-friendly date of manufacture molded into tire sidewalls and requested a Consumer Advisory. SRS’ petition requested that tire labeling rulemaking commence separately from the tire performance standards.  The agency denied this petition and the result was the continuation of an antiquated and unknown date code buried in the Tire Identification Number (TIN).  SRS reiterated its request in 2006 for the issuance of a Consumer Advisory when NTHSA was modifying the TIN requirements.  In a 2012 submission to NHTSA, SRS again asked for a requirement that tire manufacturers use a non-coded date of manufacture, mounted on both sidewalls so that consumers can easily determine the age of a tire and follow the age recommendations of auto and tiremakers. The agency did neither an advisory nor rulemaking on labeling and again allowed the industry to continue with a virtually indecipherable code to the dis-benefit of consumer safety. 

Nearly 20 years ago, automakers, such as Toyota and Volkswagen, first acknowledged that tires have limited service life – regardless of use or tread depth and that aged tires increased the risk of failure. In their 1990 owners’ manuals, foreign automakers warned motorists against the use of tires older than 6 years.  These advisories followed studies published in Germany in the late-1980s that found a disproportionate number of tire failures in tires older than 6 years.  Throughout that decade, tire age notices spread to many other vehicle manufacturers’ manuals, but the issue received little attention until federal investigations into the ATX and Wilderness tires showed that they were more likely to fail after several years in service. In the last few years, tiremakers Continental, Michelin, Bridgestone-Firestone, Yokohama and Cooper have also acknowledged that tires have limited service life and have issued Technical Bulletins specifying that all tires should be removed after 10 years regardless of the remaining tread depth. The bulletins also advised consumers to have their tires inspected annually once a tire reaches 5 years old.  Vehicle manufacturers and some tire associations have taken a stricter approach, recommending tire replacement after 6 years, regardless of tread depth. 

These guidelines are fairly useless without a fundamental change to the way a tire’s age is discerned. If you can’t find or understand the code, how will you know how old your tire is? The non-coded date of manufacture and the difficulty in locating the TIN hamstrings any conscientious consumer trying to follow them.

Aged tires, with acceptable tread and no significant visible signs of wear, find their way onto vehicles in a variety of ways: little or unused spares are rotated into service, consumers purchase used tires or buy a “new” tire that may have been sitting in inventory for 10 years, or consumers keep an old tire on a little-used vehicle.

This lack of visual indicators accounts for the continuing hazard of aged tires to consumers and service personnel, regardless of industry warnings and recommendations. It also underscores the need for a quick and easy way to determine a tire’s age. Consumers and service providers can’t adhere to safety guidelines, unless the tire age is readily accessible and understandable. Instead, they are left to decode the 11- or 12-symbol alphanumeric TIN. 

The result: Preventable death and injury crashes. SRS has provided NHTSA with a steady stream of catastrophic failures of tires that appear serviceable but have internal material degradation due to age and heat.  For their part, the manufacturers have settled hundreds of cases involving death and injury.  

Last year NHTSA’s Dr. Merisol Medri’s SAE presentation (click here for a copy) cited the following:

“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.”

While NHTSA’s taken its position on tire age rulemaking, the non-regulatory National Transportation Safety Board (NTSB) earlier this year announced its first tire safety investigation that will examine tire age and recalled tires (also the subject of recent ABC Nightline story).   

According to Sean Kane “the public are still at risk because they have little or no information about a mostly invisible hazard. The tire industry, vehicle manufacturers, and NHTSA recognize that tire age degradation presents a hazard – even on tires that have little use. It’s past time to give consumers the same level of awareness and the tools to protect themselves.” 

ABC Exposes Broken Tire Safety System

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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? Continue reading

Antique Tires!

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When you’re trolling ebay looking for good deals on antiques, don’t forget to peruse the vintage tires. Some enterprising soul doing business as TireNetUSA has put up for purchase nearly 1,000 odd-ball, and very old “new” tires. Check it out:

One (1) New 225/45R16 Hankook Ventus Plus Tire. Free Shipping.  This tire is new, not a blem, and has never been mounted.  Please check fitment before you bid, and e-mail with any questions.  This tire is 1998 production. 

Seventy-nine bucks and free shipping? Such a deal!

Our interest was piqued by an ad we saw in Tire Business. It proclaimed: “We’re not afraid of older discontinued product and will make fair offers to clear out all unwanted product.” Hmm, what would someone be doing with “older discontinued” product? One, two, three, Google and we had our answer. They are being re-sold on ebay.

And that Hankook Ventus Plus? It’s not even the oldest tire for sale. Mr. or Ms. TireNetUSA is offering 14 tires pre-1998, including six items from 1995 production. Yes! 19-year-old tires! There’s a pair of 8.00 – 16.5LT LRD 8 Ply Goodyear Workhorse Tires for the low, low price of $279. That’s right, ladies and gentlemen, a bargain at twice the price!

To be fair, only about a tenth of TireNetUSA’s stock at this particular moment is 10 years old or older. Many of the new ties are actually new – 2013 production, and fairly new, 2012- 2010.

This is what happens, dear regulators, when you research and research tire age, continue to publish your research up to the present day, but never take one teeny weeny regulatory step off base. This is what happens, industry age deniers, when you fight tooth and nail for a status quo that has fewer and fewer adherents. And yay, tire manufacturers! Some of you have dutifully issued technical service bulletins recommending the removal and disposal of tires 10 years and older, but not one of you have done a credible job of educating consumers, tire technicians or retailers about these recommendations. All-around epic fail. 

It’s all good, though. Each TireNetUSA ad comes with its very own disclaimer: “If this concerns you at all, please do not purchase this tire.  Tires will not be taken back due to age.” So, you can’t return them. What happens when you use them and suffer a catastrophic tread separation?

Anyway, in the interests of commerce, we thought we’d class up TireNetUSA’s inventory wanted ad. You know, give it a literary uplift. Here goes, with apologies to Emma Lazarus:

“Give me your tired tires, your poor 11-year-old Pirellis,

Your huddled Hankooks from 1998 yearning to be mounted,

The wretched refuse of your Phoenix warehouse.

Send these, the ancient, tread-tost to me.”

Yes, we’ve re-written the ad. The lawsuits practically write themselves.

More on Tire Aging

Tire Age Crusade in UK Begins

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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.” Continue reading

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

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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. Continue reading