WASHINGTON-The National Highway Traffic Safety Administration gave the tire and auto industries two Christmas presents: the proposed rules on tire information labeling revisions and early warning of product defects.
Both documents are mandated by the Transportation Recall Efficiency, Accountability and Documentation Act, which was signed into law in the fall of 2000.
Published in the Dec. 19 Federal Register, the tire labeling proposal among other things mandates the molding of the tire information number and size designation on both sidewalls. The Rubber Manufacturers Association, however, fears the provision may create workplace safety problems in tire molding operations.
The early warning rule, issued two days later, creates one set of reporting requirements for manufacturers of tires, child restraint systems and 500 or more motor vehicles annually, and another for manufacturers of other vehicle equipment and fewer than 500 vehicles annually.
The International Tire & Rubber Association has concerns about how both rules may affect retreaders.
NHTSA cited the recall of 6.5 million Firestone tires in August 2000 as justification for requiring the TIN on both sides of the tire.
That recall ``highlighted the difficulty that consumers have in determining whether a tire is subject to a recall when the tire is mounted so that the sidewall bearing the TIN and size designation faces inward,'' the agency said. ``Requiring the TIN and size designation to be on both sides would ensure that that information would be on the sidewall facing outward, regardless of how the tire is mounted.''
NHTSA also proposed making the TIN numbers 1/4 inch high, and changing the TIN so that the first six characters would contain the information required for determining whether the tire is subject to a recall.
The agency recommended several requirements for standardizing vehicle placards bearing tire inflation pressure and load limit information. The recommended pressure, for example, should either be bordered in red or placed on a separate label, to make sure it stands out, NHTSA said. Also, owners' manuals should be required to contain information on tire labeling, recommended inflation pressure, tire terminology, tire care and vehicle load limits.
An RMA spokesman said the association was pleased with the provision standardizing tire information placards, but was concerned about the both-sides rule for the TIN.
Tire manufacturers commonly use ``clamshell'' tire molds, the spokesman explained. Workers in the molding operations often have to change the molds while they're still hot; requiring the TIN on both sides would increase the time workers spent in the molds, leaving them more at risk to injury.
``Also, if the agency does require this, we would want a phase-in period to allow us to make the necessary changes,'' he said.
ITRA also has severe reservations about the both-sides requirement. ``That will cause us some problems, because we've never had to do anything like that before,'' said Roy E. Littlefield III, ITRA government affairs director, about his association's re-treader members.
That isn't the only issue about the tire labeling proposal that concerns Mr. Littlefield. For instance, the proposed changes in the TIN predicate a two-digit code for the tire manufacturing plant. ``Retreading plant codes have three digits,'' he said.
In the early warning proposal, the first group of reporting companies (including tires) would be required to report ``certain specified information'' about any U.S. claim or foreign notice involving a death or injury allegedly caused by one of the manufacturer's products.
Tire and vehicle manufacturers would have to report property damage claims of $1,000 or more, and all members of the group would have to report warranty claims and field reports. Tire makers, however, would be exempt from reporting consumer complaints.
All members of the second group (including vehicle equipment makers) would be required to report the information on deaths only. So would manufacturers of any tire line for which annual production and importation do not exceed 15,000.
Mr. Littlefield said it was unclear whether retreaders would be considered tire manufacturers under the rule, and thus subject to its reporting requirements. The RMA spokesman said Dec. 21 that his association had not had a chance to study the 73-page early warning document yet. A prepared statement from the Alliance of Automobile Manufacturers said only that it shared NHTSA's goal of faster information flow on potential motor vehicle defects.
``The agency's proposal is a thoughtful step toward faster information flow, and we hope it will be effective,'' the AAM said.
Deadlines for comments are Feb. 4 on the early warning proposal, Feb. 19 on the tire labeling standard. Mr. Littlefield said he would meet with officials from the Tire Association of North America, with which ITRA is merging, to decide the proper course of action.
``I will recommend meeting with NHTSA officials,'' he said. ``I also think we should meet with the new tire manufacturers, to hear their concerns and see if we should go with them on these issues.''
The industry still awaits the final rule from NHTSA on tire pressure monitoring systems, which was due in November but delayed because of issues related to the events of Sept. 11.