A tire registration firm and two associations representing tire dealers and retreaders are taking opposite stands on a government proposal to change federal tire labeling requirements.
Last Dec. 19, the National Highway Traffic Safety Administration issued recommendations on tire labeling revisions, as required by the Transportation Recall Efficiency, Accountability and Documentation Act. Among other things, the proposed rule provided a requirement for the tire identification number to be molded on both sides of light vehicle tires, both outer and inner.
CIMS Inc., an Akron-based private firm that provides tire registrations and recall systems for tire manufacturers, urged NHTSA to adopt the both-sides provision in comments dated Feb. 7.
The TIN's usual placement on the inside wall is ``a continuing life-threatening problem for consumers,'' said Paul J. Kruder, CIMS president. ``The consumer has no realistic, safe way to check the tire serial numbers'' in case of a recall, he said.
To check the TINs, you must put the car on an overhead lift, which is available only at a tire dealership or garage, according to Mr. Kruder. A conservative estimate of the cost of that service would be $100, and that could mean hundreds of millions of dollars lost in the case of a major recall, he said.
But the Tire Association of North America and the International Tire & Rubber Association argued that the requirement would be prohibitively expensive for tire manufacturers and retreaders and dangerous for workers.
TANA and ITRA-which have set a date of July 1, 2002, for their merger-said the cost to their retreader members of implementing the both-sides provision would be ``excessive.'' They quoted a figure from another association, the Rubber Manufacturers Association, of more than $100 million annually to change tire molds to meet the requirement.
Furthermore, ``changing the upper half of a mold (to bear the TIN on both sides) would require the employee to risk serious burns and possible other injuries, or the manufacturers to allow the molds to cool off before replacing the TINs, losing valuable time in the manufacturing process,'' TANA and ITRA said.
If the regulation as proposed is implemented, NHTSA should allow a phase-in of at least five years to change all molds to fit the both-sides rule, the associations said.
``The life expectancy of a tire mold is several years and the initial cost is thousands of dollars,'' they said.
The deadline for comments on the tire labeling rule is Feb. 19, and the RMA indicated it would wait until that date to submit its document to NHTSA.
The RMA did issue comments on two lesser TREAD Act-related regulations, involving accelerated remedies in case of a recall and reimbursement to consumers who replace defective tires before a recall.
In the first proposal, NHTSA assumes that recalls are always massive undertakings, and this is rarely the case in the tire industry, the association said.
``In the vast majority of cases a recall plan will be able to notify the owners of recalled tires in a fairly direct and straightforward manner and provide for an appropriate remedy,'' the RMA said. ``In these instances, an acceleration program will not be necessary.''
As for a reimbursement program, the RMA said it favored such a program but asked NHTSA to require consumers ``to demonstrate proof of purchase by a variety of methods.''