TIA offers recall efficacy enhancements

WASHINGTON (March 11, 2016) — The Tire Industry Association (TIA) is urging the National Highway Traffic Safety Administration (NHTSA) to mandate a number of practices to enhance the use of electronic identification in tires in order to improve “recall efficacy and effectiveness.”

TIA, in comments submitted to NHTSA March 10, called on the agency to:

• Complete a feasibility study on the use of electronic chips embedded inside tires that would store the information now contained in the tire identification number (TIN) — i.e., date and place of manufacture — and which would allow retailers to scan this information “easily and accurately.”

• Mandate a system that would designate an independent third party to collect and store tire registration data to “eliminate concerns about personal privacy” and protect independent dealers' integrity.

• Reinstate vehicle inspection programs in every state as a way of ensuring that tires are scanned on a regular basis to determine if any of them, or the spare, were subject to recall.

Having electronic identification in tires would faciliate linking a vehicle's tires to the vehicle itself using the vehicle identification number (VIN) — or “TIN to VIN” — making it easier to notify the current registered owner, even if that owner changes address or the vehicle title changes hands, TIA told NHTSA.

Being able to scan this information would “dramatically” reduce human error in this vital record-keeping step in the recall process, TIA said

The association's comments were made in response to NHTSA's recent request for public comment on how to update the means of notifying consumers in the case of recalls and improving the efficacy of recalls.

The NHTSA notice was in response to the Fixing America's Surface Transportation (FAST) Act signed by President Obama in December.

The FAST Act contains several tire-related provisions, including one directing NHTSA to require tire sellers to register tires at the point of sale and transmit the information electronically to tire makers.

The Rubber Manufacturers Association wrote and supported that provision. TIA, however, argued that a return to the 1970s-era mandatory registration language would be both hopelessly antiquated and unfairly punitive.

Regarding third-party data storage of the TIN to VIN data, TIA said using such a system would alleviate retailers' concerns about the registration data being used by the manufacturers for marketing purposes.

TIA also suggested that a TIN-to-VIN system also be required of used tire dealers to close another loophole in the recovery process.

TIA said it is “confident that when a TIN-to-VIN system for tire registration is combined with electronic identification, the recovery rate for recalled tires can be significantly improved.”

In conclusion, TIA Executive Vice President Roy Littlefield said, “While we recognize that tire registration is important, the primary goal must be to remove defective tires from the highway. TIA is confident that electronic information is the first step towards that goal.”