Just say no, NHTSA.
That's what sources from the tire and auto industries-to varying degrees and for varying reasons-are telling the National Highway Traffic Safety Administration about its proposal to tighten federal tire performance standards.
These standards, according to the Rubber Manufacturers Association (RMA), could cost the industry more than $1.5 billion the first year and more than $400 million annually thereafter without providing any concrete safety benefits.
The comments turned in before the June 5 deadline, however, set up the potential for fights between the various factions that provided input. For example, General Motors Corp. opposes the requirement to change the vehicle's normal load at each corner from 88 to 85 percent of the rated load of the tire at maximum inflation pressure. The RMA, however, not only supports the change but says it doesn't go far enough, renewing its call for a tire pressure reserve load limit.
Federal tire safety standards have not been revised since 1968, a fact emblazoned across newspaper headlines at the height of the Ford Motor Co.-Bridgestone/Firestone tire recall controversy. Less widely publicized was the RMA's petition to update the rule, which NHTSA granted in January 1999 but had yet to act on in August 2000 when BFS announced the recall of 6.5 million Firestone tires.
Creating new tire performance standards was the major issue during congressional hearings that led to passage of the Transportation Recall Efficiency, Accountability and Documentation (TREAD) Act in October 2000. The testing rules NHTSA proposed March 5 of this year, however, were met with raspberries from the tire and auto industries.
At the very least, NHTSA should specifically exclude bias tires, snow tires, speed-restricted tires, temporary spares and certain trailer tires from the rule, according to the RMA. It also should change its tests to better reflect real-world tire performance.
The agency was wrong to say that one-third of all tires currently on the road will fail its proposed tests, the association claimed.
``The tire testing data released by NHTSA is the percentage of tires that did not meet the agency's...proposed, unvalidated tests,'' the RMA said. ``Therefore, the test `failure' rates are not indicative of any engineering principle and are not indicative of safety performance.''
The RMA proposed its own high-speed and endurance tests as ``a truer gauge of tire performance'' than NHTSA's. It also said the agency's aging test was redundant, and the need for its road hazard and bead unseating tests was unsupported by data.
RMA testing procedures, the association said, will cost the industry $716 million the first year and $216 million annually thereafter-or only about half what it estimates the NHTSA proposals will cost.
Adoption of the test procedures put forth in the March 5 proposal will ``necessarily lead to an overengineering of the tires concerned and thus a waste of material and energy in tire production,'' said the European Tyre and Rim Technical Organisation. Heavier, less road-friendly tires, increased fuel consumption and greater tire disposal and recycling problems also will result, according to the ETRTO.
Like the RMA, the European group objected to NHTSA's one-third failure rate estimate. ``As a logical consequence, every vehicle fitted with LT tires and running in the U.S. should be declared unsafe because, on a statistical basis, at least one unsafe tire could be fitted on it,'' the ETRTO said. ``Can the proposed action be considered as reasonable and justified when the rate of accidents due to tires...is below 2 percent?''
(In a chart attached to its comments, the RMA put the percentage of tires cited in accident statistics compared with the total tire population at 0.0013 percent.)
The tire performance and selection requirements in the new standard should be made optional when published and not made mandatory until Sept. 1, 2007, GM stated in its comments. They also should be mandatory only for tires installed as original equipment, and optional indefinitely for replacement tires.
A five-year leadtime is necessary for two reasons, the auto maker said. ``The first is that there are many significant unknown implications of this rulemaking at both the component and vehicle level,'' it said. ``The second justification is to allow manufacturers sufficient opportunity to identify and mitigate the potential adverse implications of this rulemaking, particularly since any safety benefits are highly speculative.''
GM also called the proposed rule ``among the agency's worst ever from a cost/benefit perspective.''
One of the provisions GM most disliked, however, the RMA supported. Regarding the normal load percentage, GM said it was never a reserve load mechanism, but intended simply to adjust the laboratory test procedure, and therefore must be left alone.
The RMA, however, called the percentage change ``encouraging but, in some cases...inadequate when combined with a tire pressure monitoring system that allows tire pressures to drop 30 percent below placard pressure before the driver is warned of the pressure drop. NHTSA should adopt a specific tire pressure load reserve limit.''
The Tire Association of North America and the International Tire & Rubber Association, filing jointly in anticipation of their July 1 merger, largely agreed with the RMA's recommendations. They also endorsed the proposal of the Specialty Equipment Market Association (SEMA) that specialty bias and radial tires for antique or racing cars should be exempted from the standard.
SEMA's comments, not yet on the NHTSA Web site as of June 5, in turn endorsed the comments of Hoosier Racing Tire, Denman Tire Corp. and Specialty Tires of America Inc., which said the proposed tests would put them out of business and destroy the specialty tire market.
This cry was taken up by other commenters as well. Scott Ward, president of Pro Competition Tire Co. in Compton, Calif., and Steve Olmstead, president of Truckmaster Distributing in Coldwater, Mich., sent identical letters asking for an exemption for specialty tires.
``Thousands of consumers, light truck hobbyists, mud racers, rock climbers, hunters and even farmers will be deprived of a perfectly safe bias-ply alternative to the radial tire,'' Mr. Ward and Mr. Olmstead said. This letter was a draft letter recommended by Specialty Tire and Denman.
TANA and ITRA argued strongly against changing the current bead unseating test.
``It would be reasonable to anticipate that tire manufacturers, to comply with the new standard, will design stiffer sidewalls, lower beads and possibly even reconfigured rims,'' the groups said. ``This could have unintended consequences on many small tire businesses. If it becomes more difficult to unseat a tire from the bead, it will become more difficult to mount or dismount a tire.
``This development may leave tire technicians more prone to damaging the beads during installation or removal from a vehicle.
``Also, the tire technician will need higher pressure to seat the bead when mounting a tire, placing tire technicians in a potentially harmful position,'' they said.