April 16, 2015
On Tuesday, the National Highway Traffic Safety Administration amended the Tire Identification Number, the alpha-numeric code used to identify specific tires in a recall. This time, the agency expanded the first portion of the TIN, known as the manufacturer identifier, from two symbols to three for manufacturers of new tires, because the agency is quickly running out of unique two-digit combinations. It also standardized the length of the tire identification number to 13 symbols for new tires and seven symbols for re-treaded tires to eliminate confusion that could arise from the variable length of tire identification numbers, to make it easier to identify a TIN from which a symbol is missing.
These changes will compel tire mold changes – dreaded and to be resisted at all costs by the tire industry. And, NHTSA accommodated tiremakers’ antipathy for changing the molds by setting the lead-time to 10 years into the future. The new rule will take root when today’s molds wear out and need to be changed anyway. With the pervasive mold problem addressed, the agency might have taken this occasion to make some significant changes to the TIN – such as requiring a non-dated code of manufacture, and placing the complete TIN on both sides of the tire – so that consumers could use the TIN to identify a tire that had been recalled.
After all, as the agency pronounced in the Federal Register, the TIN “plays an important role in identifying which tires are subject to recall and remedy campaigns for safety defects and noncompliances.”
Safety Research & Strategies and the National Transportation Safety Board, which has taken on tire safety as a priority recently, both made these helpful suggestions during the public comment period of the rulemaking. The NTSB pointed out that NHTSA had recognized the importance of determining the full TIN in “identifying a tire for safety recall management; enabling regulators, manufacturers, and safety advocates to process owner complaints; and tracking tire production.” It argued that standardizing the TIN to better distinguish between full and partial TINs rests on the erroneous “assumption that anyone looking for the TIN is aware that passenger tires can have both a full and a partial TIN molded on the sidewalls. It also noted that the date of manufacture code plays a significant role in identifying recalled tires. “Unless an entire tire line is the subject of a recall or investigation, the date of manufacture will often define the scope of an action. Because many tires can be mounted with either sidewall facing outward, placing the TIN on both sidewalls would ensure better access and identification, and NHTSA should consider expanding the scope of this NPRM to include this requirement.” The NTSB suggested that the economic impact could be mitigated by allowing the date code to be laser-etched into the TIN, negating the need to set the date code in the tire mold.
But, the agency said: People! We weren’t trying to fix the broken tire recall system, we just wanted some more plant codes, fer Chrissakes.
Longer version: “Given that we did not propose any changes to the date code portion of the TIN, nor did we discuss or request comment on any potential changes to the date code, such a change may be beyond the scope of this rulemaking. Even if it were in scope, however, we do not believe a change to the date code is necessary for consumers to determine when their tires were manufactured. NHTSA’s tire consumer Web site, http://www.safercar.gov/tires/index.html, explains in several places how to find and interpret the date code. Furthermore, a person should easily be able to determine the location of the date of manufacture on a tire is located either by querying an internet search engine or by asking a tire dealer.”
Shorter version: Google it.
You can tell that NHTSA truly believes that TIN “plays an important role in identifying which tires are subject to recall and remedy campaigns for safety defects and noncompliances,” by calculating how super effective it has been in the recall process. The last time we looked at return rates over a 10-year period of 1996 to 2006, the average historical rate for tires was about 30 percent – with wide ranges among campaigns. In contrast, vehicle recall completion rates hover in the low 70s.
And, we are compelled to note, the massive and high-profile Firestone Wilderness AT and ATX recalls of early 2000s boosted the tire recall repair average to as high as it was over that particular span. In 2000, the OEM tire failures shouldered the entire blame for the Ford Explorer rollover deaths and injuries. About 20 million P235/75R15 ATX and 15, 16 and 17-inch Wilderness AT tires were recalled. Using a fudge-y guesstimate method, Firestone claimed that it had collected 95 percent of the defective tires. But guess what? Recalled Firestone AT and ATX are still on the road, still being sold and rotated into service, and they are still killing people.
In fact, 45 years ago, when NHTSA’s predecessor, the National Highway Safety Bureau, established the tire recall system, the TIN was the linchpin: In 1970, the bureau noted : “An essential element of an effective tire defect notification system is a suitable method of identifying the tire involved.” But its suitability has always been shaped by the rubber industry, and the needs of consumers with a recalled tire they can’t readily identify has yet to rise to the level of an after-thought.
The rule’s history shows that every time the agency had an opportunity to improve the tire recall system so that consumers or tire professionals could reasonably use it, NHTSA chose to do nothing. Every. Single. Bleeping. Time. But don’t take our word on it. The Safety Record once spent weeks assembling the rulemaking history of the tire identification number so you don’t have to.
Great Moments in TIN History
1970
The National Highway Safety Bureau begins set-up of tire recall system. Proposes requiring manufacturers to keep tire consumer records and develop a standard identification number for tires that would be molded on both sides of the sidewalls. Industry begins amassing best batting streak since Ty Cobb. Recognizes that the date of manufacture is possibly the most important part of the code, but doesn’t want the consumer to be able to read it. Firestone sez: “tires are not perishable items. Therefore, a conspicuous disclosure of tire age would unavoidably introduce into the marketplace a totally artificial measure of quality unrelated to product performance and effectiveness.” Agency drops the TIN on both sidewalls part of the proposal, because, it reasoned, under the consumer records part of the proposal, first purchasers of tires would receive notification of defects
U.S. Senator Warren Magnuson, chairman of the Commerce Committee petitions NHTSA on behalf of the independent tire dealers and distributors— to create an independent tire registry to collect the names and addresses of first purchasers and report them to manufacturers along with an agreement that indemnify the manufacturers if the registry failed to uphold the record-keeping regulations. Tiremakers go postal: We don’t want to pay for it and it will ruin the current system, which works just great.
1973
NHTSA tries to establish a universal registration form for tire manufacturers, brand name owners and tire retreaders to provide to their distributors and dealers. Manufacturers crank Government Terror Alert Level to fire-engine Red: Time and money spent developing their own systems! Wasted forms! Computer chaos!
1974
NHTSA cops out by making the universal registration format optional. It drops the requirement to give a copy to the first purchaser, because manufacturers said that it served no purpose in facilitating recalls.
1980
In response to a petition by the Center for Auto Safety, the agency proposes requiring that the TIN to be molded on the white wall side of the passenger tire, so that consumers could read the damned thing. Industry goes nuts. Uniroyal, for example, says that bringing consumers into the recall process would actually be detrimental to them, because consumers can’t read serial numbers.
1983
NHTSA terminates rulemaking claiming it would not provide any safety benefits.
Congress prohibits NHTSA from requiring independent tire dealers and distributors from supplying manufacturers with names and addresses to first purchasers. Instead, consumers get registrations cards to send in. Tire dealers acquiesce to writing TIN on the form.
1986
Agency determines that tire registration rates suck and proposes a bunch of changes to beef them up: requiring prepaid postage on the registration forms; requiring dealers to give Uniform Tire Quality Grading Standards information to consumers highlighting the registration process; and establishing a tire registration clearinghouse. Industry refuses to click “Like” button.
1999
NHTSA drops all proposals to require tire dealers to give consumers tire info about the Uniform Tire Quality Grading Standards at point of sale. Move all such information to the well-thumbed pages of the vehicle owner’s manual. Other proposals vanish.
2000
TREAD Act requires NHTSA to improve tire recall process the tire labeling to help consumers identify tires in the event of a recall. Once again, the agency raised the question of placing the TIN on both sides of the sidewall to make it easy for consumers to locate and read.
2001
NHTSA proposes new rule to require complete TIN be molded on both side of the tire, among other format changes. Tiremakers say “Hell no.”
2002
Agency chickens out. Decides not to force manufacturers to mold the full TIN on both sides of the tire. However, does require the TIN to appear on the “intended outboard sidewall” and either a full or partial TIN –i.e. one without a date code—appear on the inside sidewall – perpetuating confusion that the current rulemaking – 13-years later – is supposed to address..
2004
Major mold protest saves the day. Agency eliminates the phase-in dates to put the TIN on the intended outward sidewall. Instead, manufacturers would have until September 1, 2009 – a concession to you-know-who who complained that it would cost too much to re-work all of the molds. By pushing the date ahead five years, it would give manufacturers time for current molds to wear-out, before their replacement.
2008
Only 38 years after making the TIN a key element of the tire recall identification system, agency notices that it doesn’t actually require tiremakers to list recalled tires by TIN in the mandated Part 573 Defect and Noncompliance Notice. Proposes to close that loophole. Good catch!
2009
Loophole closed.
2012
MAP-21, the Moving Ahead for Progress in the 21st Century Act, becomes law. It requires rulemaking within a year to make vehicle recall information available to the public on the Internet in a searchable database. NHTSA complies. Safety Research & Strategies submits comments requesting that the agency also consider adding a TIN search function to its public Web portal and require tire makers, as well as automakers to maintain the recall remedy status by TIN.
2013
NHTSA’s response to adding TINs to new recall database requirements: No. Congress didn’t make us do that.
In Conclusion
Here’s something you can Google. Anytime the agency says the TIN “plays an important role in identifying which tires are subject to recall and remedy campaigns for safety defects and noncompliances,” type “NHTSA to Tire Consumers: Google It” in the search box, and re-read the section of this blog entitled Great Moments in TIN History. This will remind you that NHTSA’s belief in the importance of the TIN has never been matched by its actions.