WASHINGTON (Aug. 27, 2014) — A regular 60-day comment period, instead of an abbreviated 30-day comment period, is necessary for a proposed rule changing tire identification numbers (TINs), the Rubber Manufacturers Association (RMA) has told the National Highway Traffic Safety Administration (NHTSA).
The RMA disagreed with NHTSA's position that the proposal is a mere technical change to TINs.
“To the contrary, the amendments proposed by NHTSA in the NPRM would make substantive changes to the TIN requirements and impose significant cost burdens on the tire industry,” the association said in an Aug. 12 submission to the NHTSA docket.
The RMA supports the agency's plan to change the current two-symbol plant code to a three-symbol code to address the shortage of unused plant codes.
“However, NHTSA should not assume that new tire manufacturing plants would use all new tire molds,” the RMA said. “To the contrary, when a tire company builds a new tire plant, typically some existing molds are transferred from existing plants.”
The association said it also is concerned:
- By the change in format for TINs to make them all the same length;
- The proposed implementation time for the change; and
- The proposed 50-millimeter space between the TIN and the date code—all of which the RMA said will impose undue cost burdens on tire manufacturers.
Initial estimates suggest that total implementation costs to the tire industry from the TIN proposal will be more than $100 million, according to the RMA.
The RMA also said NHTSA should bifurcate the proposed rule for separate consideration of new and existing tire plants. The association said it would submit its comments on the TIN proposal as it relates to new tire plants by the agency's Aug. 25 deadline. It sometimes takes several days for docket comments to post on Regulations.gov, and the RMA comment on new tire plants had not appeared as of Aug. 26.
Also on Aug. 26, the Tire Industry Association (TIA) issued a press release regarding its comments on the TIN proposal. TIA said it agreed with the RMA's suggestions, including changing the lead time from five years to 10 years for all existing molds.
“(O)n this issue, the industry speaks with one voice,” said TIA Executive Vice President Roy Littlefield. As of Aug. 26, TIA's full comments also had not appeared in the NHTSA docket.