WASHINGTON (March 26, 2001) — The Rubber Manufacturers Association, speaking on behalf of its tire manufacturer members, has urged federal regulators to design a "focused" early warning system to help identify potential safety-related issues with motor vehicles and equipment, including tires.
The RMA submitted its comments March 23 to the National Highway Traffic Safety Administration (NHTSA), which is developing regulations to create an early warning system to detect potential safety-related issues in autos and auto parts. The regulations are being developed in accordance with legislation enacted last year.
The Transportation Recall Enhancement Accountability Documentation (TREAD) Act, enacted last year, requires that NHTSA create such an early warning system. The deadline imposed by Congress for final regulations to implement the early warning system is June 2002.
"NHTSA´s objective in this proceeding should be to construct and implement an effective and focused early warning reporting system," the RMA wrote.
RMA Vice President of Government Relations Ann Wilson, in a prepared statement, said: "NHTSA should take care to maintain its focus on the types of data that will most effectively provide such early warning rather than casting a wide net seeking vast amounts of data that may not be reliable or relevant."
The RMA suggested that NHTSA´s early warning system concentrate on four categories of data: claims of serious injuries and fatalities allegedly involving tires; lawsuits involving tires; property damage claims paid by tire manufacturers; and warranty adjustments.
The association said that when Congress passed the legislation it specifically rejected earlier versions that would have required auto makers, tire manufacturers and other auto parts manufacturers to submit an exceedingly broad array of data to federal regulators.
The association said its recommendations are designed to create an "efficient and effective" early warning system. In addition to the categories of data that should be collected, the RMA´s comments also addressed the frequency of information that will be reported; which manufacturers should be subject to reporting requirements and how NHTSA should manage and use the reported data.
"A properly constructed early warning system," the RMA´s Ms. Wilson said, "must be focused on available data that best provides an indication of safety-related issues."
"An overly broad data collection system that overwhelms regulators could result in a safety issue being missed," she said, adding that the RMA wants to work with NHTSA to help design a system that is consumer and safety focused.
Ms. Wilson said that since the planned early warning system would be the first of it kind, "...we expect a great deal of scrutiny and deliberation before a rule is finalized." She said the RMA is urging NHTSA to hold at least one public meeting before it issues any official rulemaking proposal in order to give interested parties an opportunity to express their views and respond to others´ concerns."
Besides the views of tire makers, RMA also addressed concerns of its rubber products manufacturer members in separate comments urging NHTSA to follow an incremental approach when including certain auto parts in the early warning system.
"First, NHTSA should focus on those systems with a history of safety-related defects, namely: child restraint systems, fuel tanks, air bags and related components, and axle/suspension/brake components," the RMA wrote.
"This could be followed by an expansion to parts covered by a Federal motor vehicle safety standard (FMVSS) if appropriate."
Furthermore, the RMA said, since auto manufacturers will be required to report a significant amount of data on their products, NHTSA should be careful to avoid duplicative reporting from other sources.
"Although Congress did not limit the automotive parts subject to the reporting requirements, common sense and a desire to create and maintain a workable system should compel NHTSA to move cautiously in the reporting of data," the association said.