The Tire Industry Association (TIA) has submitted comments to the National Highway Traffic Safety Administration (NHTSA) on behalf of its members in regard to the NHTSA’s recently-published Advanced Notice of Proposed Rulemaking (ANPRM) and request for public comment on Federal Motor Vehicle Safety Standards on tires.
NHTSA is seeking comment on matters related to the existing strength test, the bead unseating resistance test and the tire endurance test. Lastly, the agency is seeking comment on the current use and relevance of some tire marking regulations and other matters related to new tire technologies.
Comments to this notice will inform NHTSA as it considers regulatory reform aimed at reducing regulatory burden while maintaining existing safety levels for motor vehicle tires, TIA says. The organization will focus their comments on tire marking regulations.
TIA is recommending that NHTSA continue to require ply description on passenger and light truck tires, the organization said in its weekly legislative update. The organization says it believes there are benefits to most of the tire markings currently required in FMVSS 139 for motor vehicle safety, while the word “radial” is obsolete. TIA argues removing important information from the sidewall creates safety risks for technicians as well as motorists, and it will make tires less retreadable and/or repairable. TIA recommends that NHTSA continue to require ply description on passenger and light truck tires. TIA concludes that ply rating is not necessary as long as the load index or load range is molded on the sidewall. TIA recommends that the “tubeless” or “tube-type” markings remain on the sidewall so there is no confusion or improper repairs performed. TIA does not object to the removal of the word “radial” from the sidewall.
TIA says knowing the ply material is imperative for workplace safety when it comes to inflating light truck tires. Without that information molded on the sidewall, technicians will not know if the tire needs to be inspected and inflated in accordance with USTMA recommendations. There is no way that technicians can determine if a tire has fabric or steel sidewall plies without that marking on the sidewall, TIA says. The tire retread and repair industries also rely on the ply description markings to determine how the tire will be retreaded or repaired. For example, light truck tires with steel sidewall plies are better candidates for retreading, so knowing that information is important, TIA says. Removing the information from the sidewall will make tires less retreadable and/or repairable.
Additionally, TIA says the tire recycling industry frequently relies on sidewall markings to identify the material content within the tire. For example, when the recycler knows that the tire has a Kevlar ply in the tread, they can segregate the Kevlar tires from the others and process them into products that have less stringent requirements, like tire-derived fuel or tire-derived aggregate. Removing the ply description marking from the sidewall will make passenger and light truck tires less recyclable, TIA argues.
If all of the tires covered by FMVSS 139 are tubeless, then removing the marking would appear to be reasonable as long as the tire manufacturers agree that every tire is both tubeless and tube-type, TIA says. If the manufacturers do not agree that all tubeless tires can be operated with an innertube, then removing the markings creates safety concerns if a technician installs an innertube in a tubeless tire. Without any direction from the manufacturers, technicians are left to guess whether or not a tube is necessary, unnecessary or optional. Given the potential for various safety issues, TIA recommends that the “tubeless” or “tube-type” markings remain on the sidewall so there is no confusion.
Molding the word “radial” on the sidewall is redundant because the tire size designation will include the letter “R” if the tire has radial construction, TIA says. Any other symbol in the size immediately before the bead diameter reflects a bias-ply tire. TIA believes that most tire industry professionals will check for radial or bias construction in the tire size, and the organization does not object to the removal of the word “radial” from the sidewall.
