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Differing standards make compliance challenging

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George Gillespie, Gillespie Automotive Safety, Jack Chern, NHTSA
Photo by RPN photo by Miles Moore George Gillespie (left), president and CEO of Gillespie Automotive Safety Services, watches as Jack Chern, NHTSA safety compliance engineer, adjusts his microphone prior to a panel discussion on compliance in the tire industry.

AKRON—Compliance with federal tire safety standards is mandatory, but not always easy—especially when different governments have different standards.

This was the message of three government and industry experts who spoke at the International Tire Exhibition & Conference in Akron Sept. 9-11.

The purpose of the National Highway Traffic Safety Administration 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,” he said.

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, he said.

Self-certification is a key concept within NHTSA, according to 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, 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, he said. This can create major problems for importers who don't keep close watch on foreign manufacturers, he said, especially if the manufacturers:

• Do not file the necessary paperwork with NHTSA, or file incomplete reports;

• Confuse NHTSA's assignment of a plant code with NHTSA approval or endorsement;

• Do not understand that Federal Motor Vehicle Safety Standards are minimum standards;

• Do incorrect or inadequate performance testing; or

• 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, 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,” Chern said. However, Congress banned mandatory tire registration in the 1980s at the behest of tire dealers.

“It's a Catch-22 situation,” he said.

NHTSA is in the process of requesting information from tire manufacturers and dealers as to how they meet their registration obligations, he said.

Codes can be confusing

The tire identification number 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 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,” 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, he said. Retreaders, which have had three-digit plant codes for many years, have only used about 5,000, he said.

The pending NHTSA rule will standardize the length of full TINs at 13 characters and partial TINs at nine characters for new tires, Gillespie said. For retreads, TINs will be standardized at seven 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,” he said.

Nevertheless, the tire industry has raised reasonable objections to the rule as it is written, according to Gillespie. For example, the proposed 2-inch space after the date code is a problem in a way NHTSA didn't anticipate, he said.

“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, 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,” 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 Gillespie.

Global regulations would help tire makers

Jim Popio, Smithers Rapra.
Photo by RPN photo by Miles Moore Jim Popio, Smithers Rapra.

A Global Technical Regulation 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, could be voted on as early as mid-November, said Jim Popio, vice president and general manager for Smithers Rapra and Smithers Pira Ltd.

International harmonization of tire regulations would be a tremendous boon for tire makers, according to Popio, an American recently transferred to the United Kingdom. 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 operative idea, he said. “NHTSA does not issue approval tags, stickers or labels,” he said. “Manufacturers take whatever actions they deem appropriate—laboratory testing, analysis, 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 European Commission, however, adhere to the concept of type approval, in which the relevant national agencies assure Conformity of Production 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 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, Popio said. 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.

“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.”