AKRONCompliance with federal tire safety standards is mandatory, but not always easyespecially when different governments have different standards.
This was the message of three government and industry experts who spoke at the recent International Tire Exhibition & Conference (ITEC) in Akron.
The purpose of the National Highway Traffic Safety Administration (NHTSA) is simple and clear, according to Jack Chern, NHTSA safety compliance engineer.
Our mission is to reduce deaths, injuries and economic loss from vehicle crashes.
In support of that mission, NHTSA establishes and enforces regulations involving tire and vehicle safety, including rules for consumer information, recordkeeping, data submission and safety recalls, Mr. Chern said.
Self-certification is a key concept within NHTSA, according to Mr. Chern.
Tire and vehicle manufacturers are responsible for testing their own products to assure compliance with safety standards; to recall or withhold from sale any products that have safety defects or don't meet federal standards; and to submit to NHTSA any information that might indicate the presence of safety defects or noncompliance.
Tire and vehicle manufacturers are expected to exercise due care in ensuring compliance with all NHTSA regulations, Mr. Chern said. Those that don't face penalties of up to $7,000 per noncompliant tire or vehicle, up to a maximum of $35 million, he said.
In the case of imported tires, the importer is the manufacturer of record, according to Mr. Chern.
This can create major problems for importers who don't keep close watch on foreign manufacturers, he said, especially if the manufacturers:
c Do not file the necessary paperwork with NHTSA, or file incomplete reports;
c Confuse NHTSA's assignment of a plant code with NHTSA approval or endorsement;
c Do not understand that Federal Motor Vehicle Safety Standards (FMVSS) are minimum standards;
c Perform incorrect or inadequate performance testing; or
c Do not exercise due care in assuring that defective or noncompliant tires are not shipped to the U.S.
One of NHTSA's most constant concerns is trying to increase the rate of tire registration, which has been very low for more than 40 years, Mr. Chern said. Tire registration is the surest way of locating a tire in case of a recall.
In my opinion, to get the dealers who sell the tires to register them is the best way, he said. However, Congress banned mandatory tire registration in the 1980s at the behest of tire dealers.
It's a Catch-22 situation, Mr. Chern said.
NHTSA is in the process of requesting information from tire manufacturers and dealers as to how they meet their registration obligations, he said.
The tire identification number (TIN) is NHTSA's basic method of recording and locating tires. However, plant code identification and uneven numeric lengths have forced NHTSA to revise the TIN, according to George Gillespie, president and CEO of Gillespie Automotive Safety Services.
NHTSA was running out of the two-digit plant identification codes it had used since the 1970s, said Mr. Gillespie, a former NHTSA official.
Also, the length of full TINs became extremely uneven, ranging from six to 12 characters, and the partial TINs required on inner sidewalls could have anywhere from two to eight characters, he said.
Even if you're an expert, you might not be able to decode a TIN without looking at the other sidewall, Mr. Gillespie said.
NHTSA's current proposed rule on TINS would establish three-digit plant codes, thus increasing the number of possible codes from 900 to 27,000, according to Mr. Gillespie. Retreaders, which have had three-digit plant codes for many years, have only used about 5,000.
Hopefully, TINs won't have to be revised for decades, he said.
The pending NHTSA rule will also standardize the length of full TINs at 13 characters and partial TINs at nine characters for new tires, Mr. Gillespie said. For retreads, TINS will be standardized at 7 symbols for full TINs, three symbols for partial TINs.
Once this is phased in, you'll be able to tell what you're looking at simply by the length of the number.
Nevertheless, the tire industry has raised reasonable objections to the rule as it is currently written, according to Mr. Gillespie. For example, the proposed two-inch space after the date code is problematic in a way NHTSA didn't anticipate.
The industry said it would conflict with other requirements, such as the Canadian Maple Leaf after the TIN, he said. Also, it would reduce space for other markings.
In addition, tire manufacturers argued the five-year phase-in period for the rule was too short, he said. Many new plants use molds transferred from existing plants, and having to replace all molds within five years would be difficult and needlessly expensive, the tire makers said.
Safety advocates asked NHTSA for a literal date on tire sidewalls to replace date codes. In my opinion, this is just too much, Mr. Gillespie said. It does not take too much effort to learn how to decode a date code.
NHTSA is taking industry comments very seriously as it writes the final rule, according to Mr. Gillespie.
No one knows when the final rule will come out, but I hope it will be sooner rather than later, because of the shorter comment period.
A Global Technical Regulation (GTR) for light vehicle tires, as part of the World Forum for the Harmonization of Vehicle Regulations (WP-29) under the United Nations Economic Commission for Europe (UNECE), could be voted on as early as mid-November 2014, according to Jim Popio, vice president and general manager for Smithers Rapra and Smithers Pitra Ltd.
International harmonization of tire regulations would be a tremendous boon for tire makers, according to Mr. Popio, an American recently transferred to the U.K. As it is, he said, U.S. and European tire standards are currently developed under completely different regulatory philosophies.
With NHTSA, self-certification is the operant idea, according to Mr. Popio.
NHTSA does not issue approval tags, stickers or labels, he said. Manufacturers take whatever actions they deem appropriatelaboratory testing, analyses, etc.to ensure their products fully comply with Federal Motor Vehicle Safety Standards. It's your responsibility to assure the quality of the product.
The UNECE and the European Commission, however, adhere to the concept of type approval, in which the relevant national agencies assure Conformity of Production (CoP) in an industry through third-party laboratory testing.
Product testing, quality system auditing and surveillance of production are all part of the CoP process, according to Mr. Popio. Within the European Union, reciprocity of results is accepted by all member nations, he said.
There are differences between virtually all tire regulations in the U.S. and Europe, according to Mr. Popio. The EU recently issued its labels for tire fuel efficiency, with grades for rolling resistance, wet braking and noise, he said. When NHTSA issues its fuel efficiency labels, it will have grades for rolling resistance, wet braking and treadwear.
One of the few points of agreement between the U.S. and Europe is that both use the ISO 28580 test to measure rolling resistance, Mr. Popio said.
There's a pile of regulations in the U.S. and Europe, he said. It's awfully confusing for tire makers to know what to do.
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