ROCHESTER HILLS, Mich. (Feb. 9, 2001)—You´ve probably read and heard plenty about the Transportation Recall Enhancement, Accountability, and Documentation (TREAD) Act.
This is the legislation that swept swiftly through Congress on the heels of the Firestone tire recall and a groundswell of public outcry and was passed Oct. 11 last year.
The law establishes early warning reporting requirements of safety-related tire and automotive defects, establishes criminal penalties for falsifying or withholding information on vehicle safety-related defects, and protects corporate whistle blowers.
There are a few other less sensational requirements in this act that have received only passing attention but have the potential to impact your business, the products you sell, and in some measure affect your company´s very survival.
New standards due
The first is the revision and update of the tire endurance and resistance standards 49 CFR 571.109 and 49 CFR 571.119. These are the tests the government currently requires passener and truck tires, respectively, to pass in order to be sold in the U.S.
They have been around for 32 years and probably need revision. However, there undoubtedly will be some fallout. The Rubber Manufacturers Association recommends that the National Highway Traffic Safety Administration adopt the "Global Tire Standard 2000" developed under the aegis of the Transatlantic Business Dialogue in an effort to standardize world tire safety standards.
The tests used are SAE J1561 for passenger and SAE J1633 for light truck tires.
Reportedly, auto makers currently use these tests to select tires for OE fitment. However, tires sold in the aftermarket are subjected only to the government´s old safety tests. It is possible that a sizable percentage of these tires will not pass the more rigid SAE tests. Therefore, many of the tire makes/models you currently sell and earn good margins on may disappear or go through some creative re-engineering at a significant cost in order to be sold in the U.S.
It is expected that the passenger test issue will be resolved in 2001 and the light truck tire test revision will be handled in 2002. They both have to be completed by June 1, 2002, according to the Act.
The question that should make retreaders nervous is: "If the tests for new tires are updated by 2002, can revision of the safety requirements for retreaded tires be far behind?"
With the clamor about rubber on the road being a constant issue—and the common but erroneous belief that most of it comes from retreads—it is safe to assume retreads will be targeted next.
Retread standards too?
If the feds focus on retreads, then expect to have to pay for having your retreaded tires tested. If you are lucky, your retread rubber/process supplier will have to pay for this work. And tire tests, as we all know, run into the tens of thousands of dollars.
Just hope you pass. Fail and you could be out of the retread business. If you pass, great, but your costs for doing business just went up.
Another issue—tire labeling—was raised when it came to light that consumers had a tough time determining if their tires were involved in the recall when the tires had been mounted on the vehicle with the DOT code on the inside. So now NHTSA is looking at requiring DOT codes on both sides of the tire. (This would apply to retreaded tires as well.)
New tire companies don´t want to put the DOT code on both sides of the tire because the procedure of changing DOT code plates in the manufacturing process is much more time consuming, difficult and dangerous if both the upper and lower portions of hot molds have to be addressed.
From a retread standpoint, it adds another level of expense at the least for precure retreaders and poses the same problems for many mold-cure retreaders as for new tire makers. Nobody in the tire industry wants this.
The authors of the TREAD Act also were concerned that the public be made aware of the importance of observing tire load limits and maintaining proper tire inflation levels.
RMA already has launched a campaign to educate motorists about tire safety. It has conducted a radio, television and print media tour in six states to promote the effort and more such activities are scheduled.
The association also has established a safety related Web site—www.rma.org/tiresafety—to educate those interested in this subject.
But RMA is also proposing that the maximum load and inflation pressure be removed from the tire in an effort to make a short story out of the novel that currently is written on a tire´s sidewall.
I personally don´t understand the reasoning for this. I can´t tell you how many times I have heard consumers, truck drivers and fleets tell me that they check the sidewall and put the pressure stated on it in their tires.
Heck, they don´t walk around carrying the Tire & Rim Association´s Load and Inflation Tables with them, so where else are they going to look? It may not be the exact pressure they should run, but it is better than having them guess!
It has also been suggested that a label be applied over the wheel well of the vehicle that states the proper pressure the tires should have. This won´t do the monster truck guy any good when he changes his tire size to 445/65R22.5s on his pickup, nor will the Porsche driver appreciate this on the side of his vehicle. (Would you want it on your car?)
Many fleets now do this on their own tractors and trailers. However, such labels do have to be replaced when tire sizes or operations change and different air pressures are needed. I don´t think mandating them is the answer to every situation.
The last issue that could affect your business and that of your customers is the requirement that all new motor vehicles have a warning system to indicate to the operator when a tire is significantly underinflated. This requirement is supposed to become effective no later than October 2003.
While technically this is no problem for cars since the technology already has been developed and now is used in conjunction with run-flat tires, it will raise the price of the cars, pickups and service trucks you operate in your business. Furthermore, this mandate is not necessarily the way to go for the trucking industry.
The trucking industry has been salivating for this technology for the past 10-15 years. However, the technology has not yet been successfully developed for trucks, since they are very different from passenger vehicles and their operating environments pose greater obstacles.
Radio transmissions from tire tags must travel 65-70 feet in the case of tractors with 53-foot trailers and 100 feet in the case of triple trailers. This poses a monumental task: A radio wave with data on it must be transmitted a great distance with an electronic device powered by a very tiny battery—and it still must be small enough to fit on a rim or inside a tire.
Many tire and component makers are working on tire pressure monitoring/management systems, but as yet they are not really ready for prime time. And every application is different.
Owner-operators and fleets that don´t see their equipment often or hold the driver responsible for the successful operation of the vehicle´s tires really could benefit from on-vehicle monitors. However, many fleets—especially the large LTL fleets and other domiciled fleets that see their equipment often—would be better off using gate readers at their facilities to improve tire maintenance and reduce costs.
Gate readers would allow a vehicle to have the pressures read as it passes by when entering the yard. Low-pressure conditions would be corrected before the vehicle is dispatched again. They also could be used for pre-trip inspections and advising drivers to return to the garage if a low pressure condition exists.
These fleets would only have to purchase enough readers for their maintenance locations (10-15 for the big LTL fleets) rather than the many thousand of on-vehicle readers that would have to be installed in all their tractors.
Electronic monitoring of tire pressure will certainly reduce costs associated with tire maintenance and improve tire performance. However, the questions really are:
1) Is the technology ready to be mandated to the trucking industry?
2) At what cost?
3) Will mandating this technology before its time preclude product development that may be more productive and economical for the trucking industry?
Your voice needed
Rulemaking for all of these provisions of the TREAD Act is still in the formative stage. All of the tire industry associations—RMA, the International Tire & Rubber Association and the Tire Association of North America—as well as the American Trucking Associations (ATA) are weighing in with their ideas, viewpoints and suggestions.
If you feel strongly about any of these issues, be sure to make them aware of it. Find out what their positions are on these subjects and let them know your ideas and whether you support their positions.
This is democracy in action. You have a voice—use it to protect your business.
Ms. Fisher is president of Fleet Tire Consulting, based in Rochester Hills, Mich.