RMA: TIN costs will be high for tire makers

WASHINGTON—The proposed rule to change federally mandated tire identification numbers would cost tire manufacturers nearly $350 million and prove unnecessarily burdensome, the Rubber Manufacturers Association told the National Highway Traffic Safety Administration.

However, safety advocacy group Safety Research & Strategies Inc. 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 (NPRM) 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 just to protect its interest, although it needed more time, it said.

NHTSA was incorrect when it assumed the costs to the industry of changing TINs would be insignificant, according to the RMA. 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.

“The NPRM can be amended to achieve the agency's objectives while significantly lowering the burden imposed on the tire industry,” the RMA said. Among the RMA's recommended amendments were:

• Extending the lead-time for changing molds to 10 years from five, which alone would cut compliance costs by 94 percent;

• 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;

• Making changes to other regulatory requirements and the soon-to-be-issued Global Technical Regulation; and

• Making a technical correction to clarify the symbol height requirements for mileage-contract tires.

SRS, meanwhile, argued that a non-coded date of manufacture is imperative, especially since NHTSA decided against rulemaking on tire age in favor of consumer education.

“When the agency fails to consider human factors in rulemaking, safety suffers,” SRS said. “If the TIN is to be worthy of its intended purpose, the agency should take the next step and require machine-readability.

“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.”

SRS recommended radio frequency identification technology as a reasonable solution to tire identification problems.

“With a chip embedded in the sidewall, and inexpensive readers installed in service shops ... motorists could have the status of their tires checked every time they take their vehicle to be serviced, or through their instrument panel,” SRS said.

“In the meantime, if the agency wants to put the burden on consumers—rather than manufacturers—to understand and act on the dangers of tire age, then it is the agency's absolute obligation to make it possible to the public to understand a tire's age,” it said.

Most of the other comments were variations on the RMA or SRS comments. The National Transportation Safety Board said it applauded the concept of revising TINs but said NHTSA's proposals fell short of the goal of making TINs more user-friendly. It suggested making the date of manufacture more conspicuous within the TIN and also requiring a full TIN on both the outer and inner sidewall of a new or retread tire.

The NTSB's interest in TINs stem from two current accident investigations, it said. In one, a tire dealer failed to note that a tire was part of a recall, and four months later the tire failed, causing a deadly crash. In the second, police provided the NTSB with only the partial TIN of a failed tire, not realizing that the full TIN was on the outer sidewall.