However, his letter continued, “we are incredibly disappointed that the agency did not acknowledge our concerns regarding the language on the graphic in the middle of the page that refers to the number of people killed by tire-related accidents.”
TIA's “primary issue with the ‘In the Garage' piece,'” Mr. Littlefield continues, “is the statistic related to the number of people killed as the result of a tire failure. First of all, TIA is unaware of any data that quantifies what led to the tire failures in the first place. It is one thing to say that ‘400 people die every year as a result of tire failure due to improper inflation' and something completely different to just say any number of people die as the result of tire failures.
“The message as it stands tells consumers that tires are dangerous products because they kill hundreds of people each year. The actual number is inconsequential because it does not tell the whole story unless it is tied directly to the lack of maintenance. Given its location and size (in the piece), it appears to be the most important message of the piece and potentially causes more problems than it solves.”
While NHTSA apparently lowered the number of tire-related deaths it plans to use in the “Garage” piece, Mr. Littlefield pointed out that “nothing has changed since September of last year, because lowering the number to 200 doesn't make it any less misleading — 200 people die every year in tire-related crashes as a result of what?
“Is this a collective number of deaths where tires were determined to be factors in fatal accidents? If so, then the agency should refer to its own April 2012 report on Tire-Related Factors in the Pre-Crash Phase. According to the 2005-2007 National Motor Vehicle Crash Causation Survey (NMVCCS), when tires are underinflated by 25 percent or more, they are three times as likely to be cited as critical events in the pre-crash phase.
“And when the tread depth on tires was 2/32 of an inch or less, 26 percent of the vehicles experienced tire problems in the pre-crash phase.”
Mr. Littlefield noted that “the NMVCCS data also showed that of all the vehicles that had prior tire damage to one or more of their tires, 31.6 percent experienced tire problems and about 68.4 percent did not experience tire problems. On the other hand, among vehicles with no prior tire damage, only 4.5 percent were tire-related crash vehicles and 95.5 percent were other crash vehicles.
“Clearly there is a correlation between tire-related factors in the pre-crash phase and improper tire inflation, insufficient tread depth and general tire damage. If NHTSA cannot quantify what caused the tire failures/factors that led to the tire-related accidents and eventual fatalities, then this statistic must be removed altogether.”
TIA cannot support or endorse the NHTSA infographic as presented, Mr. Littlefield continued, “because it still implies that tires are unsafe. If the agency chooses to ignore our concerns for the second time and proceed with the current language regarding fatalities and tire-related crashes, TIA will advise our members and the industry to refrain from using, posting or disseminating ‘In the Garage' until the data is quantified or removed from the infographic.
“Tires have an impeccable safety record given the hundreds of millions that are sold and the hundreds of billions of miles driven,” he added, “so even the suggestion that they are unsafe cannot be given any credibility or validity that would accompany an endorsement from the association.”
He said TIA remains “hopeful that the agency will reconsider the fatality language and either quantify it or remove from ‘In the Garage,'” noting that the Bowie-based trade group “would like to support every effort to educate consumers on the importance of proper tire care and maintenance, but the messages must be clear and accurate.
“Using a statistic such as 200 people die every year in tire-related crashes is incredibly misleading when the tire factors that went into those accidents are not explained. While we are not questioning the accuracy of the data, the lack of clarity cannot be overlooked or underestimated, so the association will not promote the current version of ‘In the Garage.'”
