WASHINGTONThe proposed rule to change federally mandated tire identification numbers (TIN) would cost tire manufacturers nearly $350 million and prove unnecessarily burdensome, the Rubber Manufacturers Association (RMA) told the National Highway Traffic Safety Administration (NHTSA) recently.
However, safety advocacy group Safety Research & Strategies Inc. (SRS) said NHTSA should rewrite the proposal to place a non-coded, machine-readable TIN on tires.
The RMA, SRS and about 10 other groups submitted comments to NHTSA on its notice of proposed rulemaking to revise TIN formats by the Aug. 25 deadline, though the RMA commented Aug 12 that the agency should extend the abbreviated 30-day comment period to a full 60-day period.
The association also asked NHTSA Aug. 12 to divide the rulemaking into two parts: one for new tire plants, and one for existing facilities.
Unfortunately, reopening the comments period will not remedy the harm suffered by RMA due to the lack of response to the comment deadline extension request, the association said in its Aug. 25 comments. The RMA was forced to submit its comment by the deadline to protect its interest, although it needed more time, it said.
NHTSA was incorrect when it assumed that the costs to the industry of changing TINs would be insignificant, the RMA said. The association estimates it will cost tire makers nearly $324 million to make the required changes to tire molds by the end of the five-year lead-time, plus another $20 million for information technology.
Among the RMA's recommended amendments were:
c Extending the lead-time for changing molds to 10 years from five, which alone would cut compliance costs by 94 percent;
c Eliminating the proposed requirement of a 50-millimeter blank space after the TIN, which would decrease the cost of mandated mold changes by 70 percent;
c Making changes to other regulatory requirements and the soon-to-be-issued Global Technical Regulation; and
c Making a technical correction to clarify the symbol height requirements for mileage-contract tires.
SRS argued that a non-coded date of manufacture is imperative, especially since NHTSA decided against rulemaking on tire age in favor of consumer education. Requiring a standardized, computer-readable TIN would provide a much-needed automated method for manufacturers and service providers to quickly address recalled tires or tires that were beyond their service life recommendations, it said.
The Tire Industry Association (TIA) said it agreed with the RMA's suggestions.