June 6, 2002
Tiremakers say new tire standards “unwarranted and extreme”
Washington, D.C. — Reacting to proposed new U.S. tire testing standards, the Rubber Manufacturers Association says that more than 40 percent of passenger car tires and more than 50 percent of light truck tires would not withstand the new standards.
The group, which represents tire manufacturers, called the proposal “unwarranted and extreme” given the high level of safety and performance of today’s tires.
“Today’s tires are safe,” said RMA President and CEO Donald B. Shea. “Tires last longer than ever before and often perform safely even when driven for periods of time while underinflated and overloaded. However, no tire can withstand an unlimited amount of abuse and be expected to perform.”
An analysis by RMA found that as many as 42 percent of passenger car tires and more than 50 percent of light truck tires may not meet NHTSA’s proposed new standard – far greater than the 30 percent that NHTSA believes would not meet the proposed standard. RMA noted that NHTSA’s own data shows that the percentage of tires cited in accident statistics compared to the population of tires is 0.0013%.
“NHTSA has absolutely failed to demonstrate that a significant population of today’s tires is not performing in a safe and reliable manner,” Shea said. “In fact, NHTSA’s own data shows an extremely low number of tire-related problems.”
In its comments, RMA said that NHTSA’s proposal fails to abide by a number of important government guidelines for major regulations.
“NHTSA’s proposal fails government guidelines to show that safety will be improved,” said Ann Wilson, RMA senior vice president, government relations. “This is clearly a contradiction of a mandate not only of the National Traffic and Motor Vehicle Safety Act of 1966 (“Safety Act) but also the TREAD Act.”
The regulation for revising federal tire testing standards was included in the Transportation Recall Enhancement, Accountability and Documentation (TREAD) Act, which Congress passed in November 2000.
In January 1999, RMA petitioned NHTSA to revise the 34 year-old federal tire testing standards — nearly two years before passage of the TREAD Act. Tire makers sought revised testing standards to reflect current “real world” conditions faced by tires as well as to bring U.S. test standards in harmonization with other nations.
RMA also stated that NHTSA’s proposals violate government guidelines for “practicability” and “objectivity.” Under these standards, NHTSA cannot require manufacturers to “perform the impossible or impose standards so imperative as to put a manufacturer out of business.” Furthermore, the agency’s testing standards must be “capable of producing identical results when test conditions are exactly duplicated.”
“RMA’s comments provide a reasonable, science-based approach to tire testing standards,” Shea said. “Our proposed test standards are designed to subject tires to rational, real-world conditions.”
RMA’s testing comments make moderate changes to the NHTSA proposal to create testing standards that are pro-safety, revise the current 34 year-old standards and reflect sound tire engineering. Under the RMA proposal a significant number of tires will need to be modified.
“Tire performance relative to temperature resistance, endurance, strength, bead unseating, traction, treadwear, and rolling resistance remains a complex balance involving aspects of both physics and chemistry,” RMA wrote in a cover letter to its comments. “It is not possible to engineer a tire that possesses, at once, the highest performance in all categories, while at the same time operating, for extended periods at or beyond maximum design loads, at high speeds, and underinflation.
“NHTSA’s failure to recognize this important principle has led the agency to propose testing standards that do not have a sound scientific foundation and also fail to meet legal standards required of government agencies in rulemakings of this nature.”
Founded in 1915, the Rubber Manufacturers Association is the national trade association of the rubber industry. Its membership includes more than 100 member companies that manufacture tires and other rubber products.