WASHINGTON (Feb. 21, 2002)—Federal proposals on tire labeling and tire disposal after recalls are significantly flawed and should be rewritten, the Rubber Manufacturers Association said in comments to the National Highway Traffic Safety Administration.
Both proposed rules are mandated under the Transportation Recall Efficiency, Accountability and Documentation Act, which was motivated largely by Bridgestone/Firestone's recall of 6.5 million tires for tread separation problems.
The RMA liked several things about NHTSA's tire labeling proposal, such as the requirements for uniform placement of tire information placards and explanations of sidewall labeling symbols.
For example, the rule as written would allow a 10-percent load increase for passenger tires used on light trucks, vans, sport-utility vehicles and trailers, and this would go against the intent of the TREAD Act, the association said.
NHTSA's plans for tire identification numbers are even worse, according to the RMA. The agency's proposal to change the order of TINs would cost the tire industry $83.9 million and only create consumer confusion, it said.
“Does the agency really want to embark on a multi-year transition period…during which there will be tires in circulation with two conflicting identification schemes?” the association asked.
Similarly, the proposal to require molding TINs on both sides of the tire would involve a one-time cost of $113.5 million to the tire industry, plus annual costs of $224.1 million to make required weekly changes, the association said. Furthermore, workers would be put at risk by being forced to enter tire molds heated at more than 300 degrees Fahrenheit just to change the numbers.
The tire recall proposal, meanwhile, is too inflexible, according to the RMA.
“The majority of tire recalls are completed successfully, and there is very little evidence regarding why some consumers do not bring in their vehicle or tire for repair or replacement,” the association said. But the NHTSA proposal, with its stringent paperwork requirements, assumes from the start that the process will fail, it added.
Furthermore, the agency's language against using scrapped recalled tires in landfills fails to acknowledge the growing, economically and environmentally viable use of scrap tires in land-related applications, the RMA said.