Tread Act Information

Tread Act Information


by Paul Hyatt

In the year 2000, a series of high-profile product recalls brought automotive safety to the centre of public attention.  After a great deal of finger pointing, legal disputes and investigations, the U.S. federal government decided that some initiatives on their part were in order.  They needed products that would deliver maximum safety for the consumer and they needed ways to quickly identify potentially defective products.

As Secretary-elect of the Tire Industry Association (TIA), I had the pleasure of addressing the OTDA group in Cuba in February where we presented and considered the impact of the newly legislated TREAD Act.  The Act, passed into law by Congress and administered by the National Highway Traffic Safety Administration (NHTSA), is a piece of legislation called the Transportation Recall Enhancement, Accountability and Documentation Act - hence the acronym 'TREAD' Act.  This piece of legislation will impact all of us in the tire business; manufacturers and dealers alike.  As a TIA spokesperson noted; the TREAD Act " is the most significant tire legislation ever in terms of government interference".

There are four (4) components to this Act; (1) tire testing and safety standards; (2) tire pressure monitoring systems; (3) a tire labelling system and (4) the early warning reporting system.

1. Tire Testing Standards

Based on five new tests that all tires must pass to comply with new passenger standards, the costs for the manufacturers will reportedly be up to $1 billion for initial changes and another $400 million to comply on a yearly basis.  These new testing standards, required for a DOT code eligibility, were certainly long overdue.  They will update the 1968 version of standards which was established before radial tires were such a major market segment.  The high costs, which will be passed through to the consumer, may eliminate some tire lines from our current manufacturers in that their market may not justify the expense of complying. (bias, snow, specialty, trailer, etc.). 

New testing standards will include upgrading high speed and relevant endurance tests, underinflation failure test, aging performance (like the writer) and determining the frequency of tire failure caused by road hazards and bead disengaging with harsh maneuvers.  A final rule has not been publicized at this time of writing but is expected soon. 

Unfortunately the huge advances of tire technology and safety receive little attention from the press and the public and according to NHTSA, there is only one tire-related accident for every 435 billion miles driven.  Not a bad record.  The Tire Industry Association (TIA) are initiating a public awareness program, in cooperation with some manufacturers, to educate the media and the public on the fantastic quality, performance and value that is found in a tire.

2. Tire Pressure Monitoring Systems (TPMS)

The purpose of this regulation is to warn drivers that their tires may be losing air pressure. Dashboard low-tire-pressure indicators were mandated by the TREAD Act and after much input from interested stakeholders, the final rule was published June 5, 2002.

One of the systems under consideration is a direct monitoring system that requires four (4) sensors, each in a separate tire.  The sensors warn the driver when a tire’s pressure has dropped below 25% of the manufacturer’s recommended cold inflation pressure. This system is more precise and will be used on vehicles not equipped with ABS.  Some systems can be calibrated to higher standards than NHTSA requirements.

The second system, which is an indirect system - no sensor in the wheel - works with the vehicle’s anti-lock brake system (ABS).  It reads a tire’s RPM and compares the rotational speed of each wheel with that of the other wheels.  As any single tire pressure drops, its relative rotational speed increases and sends an 'alert' signal.  This system alerts the driver when pressure drops below 30% of the manufacturer’s recommended cold inflation pressure.  NHTSA estimates that 49 to 79 deaths could have been prevented if all vehicles were equipped with TPMS.  The TPMS device, direct and/or indirect, will be mandatory OE equipment on 10% of the 2004 vehicles with the percentage increased each year thereafter.


DIRECT - Sensor in each tire

INDIRECT -  with anti-lock brake system

  • Alerts when any or all tires drop in pressure
  • Only alerts when pressure drops 25%
  • Drivers may rely on system for ‘alert’ before checking inflation pressures
  • Drivers may pay less attention to air pressure and rely on 'alert'
  • Load carrying capacity could be dangerously affected (e.g. Explorer 26 psi)
  • O.E. costs would be $65-$75 per vehicle
  • Air pressure monitored separately in each individual tire
  • Instant alert when pressure drops below pre-set level
  • Indicates to driver which tire is low
  • Investment by dealer for new equipment
  • Will technicians receive info and technology needed to install, service, recalibrate and maintain TPMS
  • System reads actual air pressure
  • Favoured by tire professionals
  • Dealers will need TPMS training
  • Alerts when any single tire loses pressure
  • Only alerts when pressure drops 30%
  • Drivers may rely on system for ‘alert’ before checking inflation pressures
  • Drivers may pay less attention to air pressure and rely on 'alert'
  • Load carrying capacity could be dangerously affected (e.g. Explorer 26 psi)
  • O.E. costs would be $22 per vehicle
  • Won’t ‘alert’ in time to prevent tire damage especially if heavily loaded
  • No ‘alert’ if all tires are losing pressure over time or at same rate
  • Won’t indicate to driver which tire is low
  • Investment by dealer for new equipment
  • If all tires are losing air, ‘alert’ may sound with unsafe, severely underinflated tires
  • System ‘reads’ rotation of tires, not actual air pressure
  • Favoured by vehicle manufacturers
  • Dealers will need TPMS training

3. Tire Labelling System

Congress asked NHTSA to examine and update tire labelling requirements after the public outcry on the lack of information that was found on the sidewall of a tire.  After initial investigation, NHTSA proposed a new tire labelling regulation which met heavy industry criticism.  Their revised proposal, beginning this September, mandates that tiremakers and passenger retreaders must place the full tire identification number (TIN) on the intended outboard side of the tire and a partial TIN, without the date, on the other side.  This will enable dealers and consumers alike to readily see the serial number of the tire and determine if that tire is part of any ongoing recall.  Investments in the molds will be substantial, and with the time-consuming mold changes, the price tag will be over $200 million.  This cost will be passed on to the consumer in the price of the tire. 

The vehicle placard that lists the manufacturer's recommended inflation pressure and load limit information will now also include the maximum load the vehicle can safely carry including passenger and cargo weight.  It will be a colour coded format and will be mounted on the driver’s side pillar or door jamb.


4. Early Warning Reporting System (EWRS)

NHTSA proposed and is compiling a data base which allows the government to track potential problems in tires by having tiremakers, private branders and importers submit pertinent data to them. Retreaders are exempt from this filing unless a fatality is involved.

This data will include information on tire manufacturing, adjustments, property damage claims, injuries and death related to tire failure.  They must also report any customer satisfaction campaigns, consumer advisories, recalls or other actions involving tire replacements.  This part of the TREAD Act will obviously change the industry’s policies of “adjusting” tires, including the definition of tire defect, as well as everyone's reporting systems pertaining to adjustment tires.  Will government officials interpret adjusted tire data as defective tire failures?  Then “adjustments” will become no longer desirable. This could transform tire adjustments from a customer satisfaction/warranty function to a more formal legal function to mitigate the burden of liability to manufacturers and dealers.

The dealers’ role is vital in this exercise of data collection.  When the tire is sold, it should be registered with the proper tire registration forms provided by your tire supplier.  And when the tire is adjusted, knowledgeable staff, with adjustment expertise, must fill out the forms accurately and submit back to your tire supplier.  The manufacturer then submits, after verification of cause, to NHTSA. 

Dealers will need to know, through training programs, cause of failure, what is acceptable as an adjustment and what is not.  TIA has identified 122 failure causes so far which are contained in their soon-to-be published booklet “Tire Wear Analysis and Out-of-Service Conditions”.  The booklet also publishes photos of failed tires and the reasons for failure.   It will be an excellent tool for customer relations.

The TREAD Act ‘Reporting System’ will create the largest data base known to the federal government.  Starting April 1, 2003 (April Fools Day), manufacturers, brand owners and importers must submit to NHTSA each quarter all tire adjustment data and all relevant reports of tire related injuries.  In 2004, data must be submitted every month.



The TREAD Act will undoubtedly create some unwanted paperwork and expense for the industry but through compliance and analysis of the data, certain benefits are gained.  Potential problems with tires, auto parts, and automobiles can be identified early avoiding serious defect problems and accompanying costs.  We will receive products manufactured to the highest quality while providing improved reliability.  We will have lower exposure to liability with potentially lower insurance rates.  It also gives our industry a golden opportunity to tell motorists what great safety and value that they have in their tires.  Additional services will be needed by the motorist giving dealers additional profit opportunities

The Tire Industry Association (TIA) has been very active in monitoring these regulations on behalf of tire dealers and all stakeholders in the tire industry.  Through strenuous and effective lobbying of relevant officials, TIA has been succesful, not only in voicing our concerns with certain parts of the TREAD Act, but in lessening the impact of the original, more stringent regulations.

Although there are still some sections of the TREAD Act waiting for a final ruling such as the sale or lease of defective or non-compliant tires, recall and remedy programs, disposition of defective tires, replacement products and new testing and safety standards,  TIA will continue to monitor and appraise each stage of the TREAD Act as it develops on behalf of all the members of the Tire Industry Associ



Nine Issues Affecting the Tire Industry Today

Nine major changes.  Professionals in the tire industry today are experiencing nine major changes, primarily due to shifting market trends and government involvement.  The tire industry may never be the same again.

In our opinion the top nine issues in the tire industry today are: the effect of NHTSA’s tire pressure monitoring system ruling; auto dealerships entering the replacement tire market; the economic impact of new industry labeling requirements for tires; economic pressures on tire manufacturing companies; the effect of an “early warning system” being proposed by the government; the rapid growth of the performance tire market; the overwhelming costs of the new tire safety standards; the rising cost of insurance for all businesses; and the need for consumer education and public advocacy efforts. 

The authors will describe the potential affects of these issues on the tire industry.  While the “nine most important issues” certainly are different for every professional in the industry, this is our short list. 

Background: A short explanation of the TREAD Act

In case you are not familiar, the Transportation Recall Enhancement Accountability and Documentation (TREAD) Act was the legislation passed by Congress two years ago – right after the Firestone recall.  In short, the passage of the TREAD Act resulted in rulemakings by the National Highway Traffic Safety Administration, NHTSA, concerning many aspects of our industry.  To vastly oversimplify the process, the rulings are proposed by NHTSA, and associations, such as the Tire Industry Association (TIA), have 60 days to comment.  Then NHTSA makes the final rule.  The regulations being made through this process will change the tire industry forever.

The first issue is the effect of NHTSA’s tire pressure monitoring systems (TPMSs) rule.  The TREAD Act and its resulting regulation will require these systems on all vehicles in the future.  The theory, which is absolutely correct, is to inform consumers when their tires are underinflated.  This is a great idea.  Unfortunately the ruling, issued by NHTSA in late May, represents a negative turn of events for the tire industry.  NHTSA has ruled that in the coming years, automobiles and light trucks under 10,000 pounds must be equipped with one of two types of systems to monitor air pressure in the vehicles' tires.  Depending on the system, the driver will be alerted when the pressure in any single tire falls to 25 or 30 percent (or more) below the vehicle manufacturer's recommended cold inflation pressure for the tires, or a minimum level of pressure specified by NHTSA, whichever is higher.

The result – and this is the bad part – is that consumers will be “warned” by the TPMS only after their tires are 25 or 30 percent below the recommended pressure.  This system will effectively train consumers to run their tires under-inflated.  Ironically, this is not the intent of either the government or the tire industry, but the resulting rule will have this effect.

This ruling has a significant impact on tire dealers and automotive service businesses.  The Tire Industry Association (TIA) is concerned about servicing of these systems in the future. We believe that all vendors of tire and auto service should have access to the information, technology, parts and tools needed to properly service tire pressure monitoring systems. Let’s face it, sometimes OEMs don’t share all of the information and parts necessary to get the job done, and as an association we must lead the fight to ensure this information is available to all in the industry.  TIA will also seek to train all of our members in any related changes to basic tire and wheel service that results from TPMS.

The second major shift in the marketplace is the entrance of auto dealerships into retail tire sales.  Sales of replacement passenger tires at auto dealerships increased by 191 percent between 1998 and 2000, according to the research group Mintel, almost entirely as a result of Ford’s “Around the Wheel” program, designed to sell tires directly through Ford dealerships.  GM followed Ford’s lead in 2001 by starting its “On-a-Roll” program. The two programs will have effectively added more than 5,000 outlets to the already crowded replacement tire arena.  Clearly this will have a significant impact on the retail tire market.  In the opinion of the authors, the key to competing successfully with auto dealerships is offering superior service, not necessarily lower prices.

Another looming issue is the economic impact of the proposed information and labeling rules – a serious concern for TIA. Proposed revisions to the Tire Identification Number (TIN) would prove to be very expensive for manufactures of new tires and for retreaders. Investments in molds would be significant, and reworking them would be time consuming. The process of manufacturing will be slowed significantly for the safety of the worker loading the TIN in both sides of a mold cavity. In addition, the current arrangement of letters and numbers representing plant code, shift and week of manufacture are proposed to be rearranged, resulting in the need for all in our industry to understand and supply information in two different systems for a period of many years. The costs in mold investments, lost pro

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