Tire recalls and Registration

Here are some details on the recent RV tire recall:

 NHTSA Campaign ID Number: 14T015 
Synopsis: Dynamic Tire Corp. (Dynamic) is recalling certain Towmax STR tires, size ST225/75 R15 manufactured June 15, 2014, to October 14, 2014. The affected tires may have the Incorrect Load Capacity and Inflation Pressure Stampings. Thus, these vehicles fail to comply with the requirements of the Federal Motor Vehicle Safety Standards (FMVSS) 119. The misinformation on the label could lead a driver to over-inflate the tires. Tire over-inflation may increase the risk of a tire failure which can increase the risk of a crash. Dynamic will notify owners, and dealers will replace all eligible tires, free of charge. Owners may contact Dynamic customer service at 1-905-595-3593.

The details are that 17,000+ Load Range D Towmax tires with DOT serial ADB4GPD2414 through  ADB4GPD4214are subject to the recall and are to be replaced FREE of charge.

One bit of information that many will skip over is the part where it says Dynamic will notify owners. While this is standard language in recall notices it overlooks a major problem. Just how is Dynamic supposed to know the owner's name & address?

According to Federal law all DOT tires are supposed to be registered and that information is supposed to be entered in a big database to enable future contact in case of a recall. The problem is that according to various studies only about 17% of tires sold by dealers have the necessary registration forms completed and sent to the registration authority.

Do you know if all your tires have been registered? If not then you will probably never know about a tire safety recall.

WHAT SHOULD YOU DO?
        Note this is not limited to Towmax brand tires but applies to all of your car, truck, trailer or motorhome tires.

Confirm that your RV Dealership registered the tires on your trailer or motorhome. If you bought your car or truck new from the company dealer the tires are probably registered.
 You might start by asking what their policy is. You may find some confusion or hemming and hawing on the part of the dealer, I would take as indication that they did not do the task they are supposed to do by law.

Car and truck dealers may do a better job but we all know what can happen if we "assume" someone is doing the job they are supposed to do.I would see nothing wrong with using the on-line registration process below,just to be sure.

If you bought tires directly from a tire dealer you should ask them what their policy is. Some will have clear statements such as we see from Tire Rack. BUT if you get that uncertain response there is a good chance the tires you bought were not registered. Probably the smaller the tire or RV dealership the lower the probability the tires were registered

You can do the job yourself at TireRegistration.com    or simply Google Tire registration and see if your tire brand has a sight just for registering your tires.

Please don't be concerned that this is some "Big Brother" conspiracy. I have never heard of this information being used for any purpose other than notification of a recall.

Finally if you have changed mailing address you might want to update the tire registration. Remember you will need the full DOT serial including the date codes for each tire.

If in doubt on how to read your tire serial number, reviewing THIS post will help.

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DId your RV company or dealer follow Federal law?

Been reading a number of posts on recalls, violations of federal safety standards in the RV industry and on tire and fire extinguisher recalls.
If you have been a reader of my blog you know that I am a strong proponent of filing complaints on failures of safety-related systems and of tires to NHTSA.

You can read a portion of the Federal Regulations on what RV companies are supposed to do HERE as far as the regulations relate to identifying who owns what tire in case there is a recall.
Obviously, if the S/N ( full DOT serial including the date numbers at the end) of a tire is not recorded when the tire is sold there is no reliable way for a tire company to contact owners of tires that are under a recall order.

Selling dealers have the following responsibility
"The National Highway Traffic Safety Administration (NHTSA) requires that tire dealers must provide every tire purchaser with a pre-addressed completed tire registration form OR complete the tire registration process electronically on behalf of the tire purchaser (49 CFR Part 574.8). This is not voluntary, tire dealers must do one or the other"

When a vehicle is sold (car, light truck, or RV) the tires are "sold" with the vehicle. The regulation says "tire dealer" but obviously just because a company sells vehicles and doesn't think of themselves as a "tire dealer" they are in fact selling tires.

However, I have found that few people have received the appropriate forms. Did you receive a form with the purchase of your last set of tires at the tire store, or with the tires that were shipped to you if you bought them online?  How about when you bought a new or used RV?

You say you bought your RV used so you don't think the tire ownership needs to be registered? Well, I know of nothing prohibiting a tire being covered under a recall just because ownership was transferred. The entire reason for this registration is simply to let either NHTSA or the tire company contact the owner of tires covered by a recall. The information is not used for any other purpose.

IMO the odds are that very few of you received the pre-addressed form or if you did you may not have bothered to complete the information.

Well HERE is a website that you can fill in the information and submit it online and don't even need a stamp.

I started this post and mentioned Fire Extinguishers. If you have following the RVTravel.com blog you know about the recall and free replacement of potentially defective extinguishers. You may have discovered you have one or more of the covered units. Unlike tires, fire extinguisher ownership is not registered so there will be millions of extinguishers that are not replaced simply because people do not know about the recall and Kiddy company has no way of contacting the owners.

Do yourself a favor and register all your tires RV, Car or truck. Who knows you may just end up with a new set of tires if the ones you have are covered under a recall.

Do you have defective tires? How would you know your tires should be recalled?

While many may suspect their tires are defective because they have had a tire failure, that isn't really a recognized way to know for sure.

US DOT National Highway Traffic Safety Administration does make official determinations on which tires are in a group that might fail. They do issue tire recall orders just as they issue recalls for other suspect defective automotive components.

 A major problem with tires, however, is that according to a brand new report only 1 in 5 tires that are subject to a recall are actually replaced. The suggested primary reason for the low replacement rate is blamed on the low level of tire registrations that are submitted by either vehicle sales outlets or retail tire dealers.

I bet if you think back to the last set of tires you purchased either for your car, truck or RV you were not given a form to complete and mail in to ensure that you would be notified in the event there was a recall issued by NHTSA. This might also apply to the purchase of the tires that came on your RV.
I know that my RV dealer didn't have a clue when I asked them, so I went online and registered them directly with the tire manufacturer.

I have written a number of times on the importance of filing a complaint with NHTSA when you suspect a tire was defective. NHTSA makes a decision on starting an investigation or not, based on complaints received and the seriousness of the consequences of a tire failure. So while you may think the failure is important, unless there are a number of complaints on file there will likely never be an investigation started and with no investigation there is almost certainly not going to be a recall. You need to remember that posting information on an RV forum grousing about tires while sitting around the campfire may make you feel better but it will never result in an investigation or recall or real improvement in the quality of tires applied to RVs.

I have also written a few times here on the importance of registering your tire and these two topics Registering and Recalls are closely related.

If you haven't registered your tires, it is never too late to do so. It doesn't have to be done when new -- it's just easier. Review my posts on the process. You can contact your tire dealer and ask about registration. If they can't or won't help, then I suggest a simple Google of "Tire Registration" will provide the information you need to complete the process.

Of course, a letter to NHTSA, 1200 New Jersey Avenue, SE, West Building, Washington DC 20590   about difficulty you may have in registering your tires might spur them to address the problem outlined in the article.

As Pogo said "We have met the enemy and he is us". When it comes to making the minor effort to file a complaint when you have a tire failure and to ensure you will be notified in the event of a recall by submitting the card with the appropriate information to register your tires, we RV owners as a group certainly have nothing to be proud of.


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Why you should have road hazard tire insurance

 Are you prepared for the cost of tire failure? When buying new tires for your RV, one thing to consider is road hazard tire insurance. That is especially true for ST-type tires you put on a trailer or fifth wheel.

  ( A bad "Fork" in the road)

If you have a failure, it could be blamed on some impact or cut which would not be covered by any manufacturing warranty. But with road hazard insurance any failure would be covered. Even something unusual, as seen here.

Road hazard tire insurance can be worthwhile in all RV applications

Not all brands and not all dealers offer this insurance for RV applications. But when I recently got new tires for my Class C, the Firestone store offered road hazard insurance. I said yes, as I wanted 100% coverage and some assurance that I would not have any expenses related to tire failure. No, my tires are not ST-type. But my advice to consider road hazard insurance applies to all types of tires when used in RV applications.

All I have to do is keep track of the sales receipt and I'm good to go if there ever is a tire problem. The receipt has the full DOT serial along with the notation that I purchased the insurance. So that makes keeping the invoice information doubly important as I do not have to go crawling around under my RV trying to read the DOT identification number aka "tire serial".

Speaking of keeping important papers, I keep copies of papers like car insurance, registration, truck scale weights, roadside assistance insurance, and tire invoices, etc., on my phone in a folder that is backed up "in the cloud" so the information can't get lost.

 

 

Be Prepared

I am pretty sure the Boy Scouts were not thinking about RV tires when they selected the motto of "Be Prepared".
However that motto does provide good guidance for RV owners when it comes to their tires and being prepared in the event of a failure or even better yet being prepared for travel in a way that can decrease the chance of having a failure.

Right now most RV owners either have their rig parked under cover for the winter or are keeping relatively warm in our southern states. In either case there are not many RVs on the road this time of year. But in another couple of months it will be time to get the cover off the rig, dig out the campground guides and start planning their adventures.

I would like to offer some suggestions on a few things to do that can make your life a bit easier when it comes to maintaining your tires and steps to take that may possibly save you grief down the road.

1. Have your tires inspected
       You should be able to find a dealer for your tire brand that is willing to give your tires an external visual inspection. I covered this in detail in this post.  They should look for bulges in the sidewall or an out of round tread. Cracks or cuts that exceed the specifications provided to the dealer by the tire manufacturer of your brand of tires. I believe that all competent and properly trained dealers should have a guide with specifications on what would be considered an "adjustable" level for depth or width of crack or cut. Even if the tire is out of warranty those levels would be a good guide for what the manufacturer considers safe or not.

2. Inflate the tires to the level required for your unit.
     For trailers this usually means to the inflation on the tire sidewall. I covered my suggestion for trailers in depth in a post just for trailer owners. I would include all towable units, even dollies in this category. For motorized units this would probably mean the minimum needed to carry the highest expected load plus 5 to 10 psi "cushion". You can refresh your memory about the importance of proper inflation here. If you haven't had your RV weighed and calculated the individual tire loads I strongly suggest you read this post. You can check the RVSEF web site for the schedule of locations they will be doing RV weights. Here is a site with downloads and worksheets on how to calculate actual loads.

3. While at the tire dealer confirm your tire gauge matches the calibrated master gauge the dealer has.
     It doesn't do you much good to check your tires if your gauge is off by 10%. I covered gauge accuracy in a post and you can see the high failure rate observed based on actual calibration checks..

4. Record your full DOT serial, including the date code.
     If you write this information in your record book and file it along with other important papers such as insurance and registration you will only need to do this once in the life of the tire. If you have this you can easily calculate the tire age and even check if the tire is on a recall list in the event of a recall or safety campaign.

5. Install your TPMS and confirm the batteries are working.


I hope you all have a safe and enjoyable 2013 RV season.

How to File a Complaint with NHTSA Part 1

In my last post I asked the question of Why Dont RV Tires Get Recalled? Today I want to outline the process of how to file a proper complaint with NHTSA so there might be an actual investigation started.

 The National Highway Traffic Safety Administration is a part of the US Department Of Transportation. They cover vehicle safety issues. There is an Office of Defect Investigation that looks at vehicle and tire related failures and the ODI has on-line forms you can submit if you think your tire or vehicle has a safety related defect or failure. We will be focusing on tire related issues in this series of posts.

The process:

Data on tire failures is normally submitted by tire manufacturers or importers or vehicle owners. This information is reviewed by ODI and a mandatory recall may be ordered by NHTSA or a voluntary recall may be initiated by the tire manufacturer. Michelin initiated a voluntary recall in the case of the BFG light truck tire recall. If the volume of tires produced or imported in a specific size/type is less than 15,000 there is no requirement for warranty data to be submitted as I understand the rules. If there are a number of valid consumer reports to NHTSA of tire failures, the ODI can decide if a full blown investigation is justified.

If the investigation reveals there was a manufacturing or design defect NHTSA has the legal authority to order the manufacturer or importer to recall and replace the suspect tires. Many times at no cost to the consumer.

Your Responsibility:

Many times the volume of tires used on RVs is well below the reporting threshold so even if there are a number of failures there may no report filed. Also sometimes the importer does not have the organization in place to track tire failures, so if the user doesn’t report the problem there will be no investigation. So the responsibility of reporting suspect tires is yours. Simply spouting off on a RV forum may make you feel better but it will never result in an investigation.

Before you file a complaint:

You need to make an effort to assure the tire failure was not the result of a puncture, impact, leaky valve or due to the failure of some other vehicle part. A review of these posts Blowout, Run-Low Flex, Puncture or Impact will help you confirm the failure was not service related. If a tire dealer says there was nothing wrong with your failed tire ask them to point to the physical evidence they are relying on to make their statement.

Just because you had the tire "adjusted" does not mean you can't file a complaint with NHTSA. I would not be surprised to learn that there have been cases where some tire failures were not reported to NHTSA by the importer.

Information needed to file a complaint

Below is a list of information you will need.  I will use some of the information from the BFG recall as a sample. DO NOT USE THIS SAMPLE INFORMATION. You need to use the correct information or the complaint will be just a waste of your time and will get no results.  

Tire information needed

o    Tire Brand                         (e.g., BF Goodrich)

o    Tire Line                            (e.g., T/A A/S)

o    Tire Size                  (e.g., LT235/85R16 120Q LRE)

o    Component          (I suggest you identify Tread or Sidewall or Bead as appropriate)

o    DOT Number (Tire Identification Number) (Very Important see this example)

·          
















Vehicle information needed         (even if you are reporting a tire, you need the RV info)

o    Model Year

o    Make  This would be the Manufacturer

o    Model

o    Component                       (just select "tire")

o    Vehicle Identification Number (VIN) Found on registration or insurance card and on the placard affixed to the side of your trailer.. 

Now I am sorry to report that NHTSA does not provide the name of every RV or Tire brand in their drop down list. This makes it doubly important for you to provide the correct vehicle VIN and the tire DOT serial in the body of your complaint

It would also be a good idea to get a number of pictures of the tire failure for possible future use. These should be done in full sunlight and you need to be close enough to be just of the tire. If you look at the pictures I have posted in my blog you will see examples. A shot of the failed tire in full shade from 20 feet away will not be of much value. A close-up of the placard will also be of value as it is supposed to have make and manufacturer of the RV as well as the VIN. These pictures will not be submitted to NHTSA unless they contact you but if you end up trashing the tire it will be too late to collect the evidence.

The rest of the process will be covered in the next post. 
 In the time being you could practice and see if you can collect the DOT serial for all your tires and the vehicle VIN. You could even try and take some pictures of your placard and tires to see what it takes so you don't end up with just a black blob.

What information is on your tire sidewall? Could it be worth $Hundreds?

 I bet that few of you have ever bothered to read and copy down the important information provided on your tire's sidewall. There are a number of reasons for you to spend the few minutes it will take to collect and write down the information. Having the facts,  might even be worth a free set of tires!

1. DOT serial number for each tire. They might all be the same or each tire could be unique. The complete 10 to 13 character code would be used if you have a failure and want to file a complaint with NHTSA, the division of the US DOT that is responsible for initiating recalls of vehicle components that have been judged to not meet the safety standards that DOT establishes. For tires, the DOT Serial is used to identify which tires are being recalled, and replaced for FREE. Without the serial number you have no way of knowing if your tires are subject to a recall or not. It is definitely a lot easier to plan and to collect the serial number on a nice sunny afternoon, than on a rainy morning in the mud. You need to include all the letters and numbers, especially the last 4 numbers which are the "Serial Date Code" that identifies the week and year the tire was manufactured. Here is an example of an older 11 character serial number.

  In this example the Date code is 3908  which would correspond to the 39th week (October) of 2008. If you have a tire this old, I would strongly recommend you replace it ASAP as it is well over the 10 year Max age limit for any tire in RV application.

When you start looking at your tires you may find something that looks similar but the last four characters and not numbers. This means you need to inspect the other side of the tire as not all tires have the date code on both sides. I have suggested a flashlight and a 12 year old and a $5 or $10 bill might be called for as you hire some young helper to collect the Date Code from the other side of the tire. I know, that I no longer find that crawling around under my RV is easy on the knees. Some of you will discover that you managed to park your RV so the date code is hidden by the frame or exhaust so you may need to move the RV a couple feet. Don't move the RV with the 12 year old under the RV. Not Safe! Suggestion. When you buy new tires get the dealer to give you the registration sheet that has the full DOT of every tire recorded. Same when you buy a new RV. It's easier to get the dealer to crawl around to get the numbers.

OK, the DOT serial is the most important number to record and keep in an easy to find location along with the manuals for the furnace, stove, AC and other features of your RV.

2. A picture of your Certification Label AKA Tire Placard, would be a good idea to have on your computer or phone. The placard has a statement of complete tire size, Load range and the GAWR PLUS the recommended inflation. Here is an example from an Airstream.

All of this information is important and should be easily available. It is very helpful when buying a new set of tires. I have read more than one post of an RV owner getting the wrong Load Range for their RV which would be a serious safety concern.

3. All tires also have information on their construction like this:

 This is really just FYI and is more like truth in advertising to let you know the materials used in the sidewall and center of the tread of your tires. In this case there are two ply of Polyester in the sidewall and in the tread there are two ply of Polyester + 2 ply of Steel + 1 ply of Nylon. Most 19.5 & 22.5 tires will only have 1 ply of steel in the sidewall. This information might help you understand why "Ply" and Ply rating" is no longer used since most tires only have 1 or maybe 2 layers in the body. This is why we use Load Range terminology.

Don't worry as we tire engineers have a large selection of materials and different strength of those materials so can choose the appropriate materials for the tire we are designing.

Just as I did, you can capture a picture (Bright Sunlight is best) and just keep that picture so you can refer to it in the future.

OK so now you are asking "When do I get my free tires?" 

You can check to see if you vehicle or any of your tires or other parts are covered under a recall HERE.  You will need the vehicle VIN and or the tire DOT serial to check the list.

So where does having this information handy come into play?  Well, lets assume someday you have a tire failure or simply wear a tire out because an axle is out of alignment. So you replace it and give the worn or damaged tire to the dealer. BUT if that tire is on the DOT Recall list you could get it and any other tire covered by the recall replaced. FOR FREE. But here is the catch. You have to turn in the old tire to get the free replacement. Just saying "I had a tire" will not work. Even having a picture is not enough. So just think of how you would feel if after replacing one tire or even your entire set, you were to discover the tires were subject to a recall but you no longer have the tires as proof.

NOTE: Tires are not the only parts that get recalled. I have heard of shocks or door locks or brake parts or wheels and many other parts being recalled and REPLACED for FREE.

##RVT988

What "Size" Tires do you have Part 2?

Last week in Part 1 I covered Passenger car type / size tires. This week we move on to LT and ST type.

The next type tire is “LT” or Light Truck. These will be found on both Class-B and Class-C and possibly a few small Class-A RVs. Since these RVs are larger and heavier vehicles, they will normally have tires that come in larger physical size and stronger Load Range. For example a popular tire for Class-C motorhome might be an LT225/75R16 115/112 LR-E. The double number 115/112 is the different Load Index for single (front) application and dual (rear) application where two tires are mounted side by side. Note that some RV trailers may have two axles, one in front of the other, this is not called “dual” but would be a “Tandem axle” and the tire loading is considered “single” when looking up the capacity in the tables. The Load Index number can be applied to a group of tires that have similar but not identical load capacities. When replacing tires, you should not go to a lower Load Index number.

In LT type tires, the abbreviation of LR for Load Range is used. You can think of the Load Range as a replacement for Ply Rating. For RV application you will see that Load Range starts at C (old 6 ply rating) and moves through D, E, F, and G. This is really an indication of the strength of a tire to hold the inflation pressure, not the ability of a tire to support additional load. It is important to remember it is the inflation pressure and not the tire construction that supports the load. This is why we have Load and Inflation tables not Load and tire construction tables. You should not consider moving to a lower Load Range than selected by the RV manufacturer. The LR along with the original size and type tire and minimum inflation is shown on the RV Certification Label. Basically, the Load Range identifies the highest level of cold inflation to be used starting at 50 psi and moving up to 100 psi or even higher as identified on the sidewall of your tires. Like Speed Symbol you should never consider moving to a lower Load Range than selected by the RV manufacturer.

Do you know where your Certification Label is for your RV? If not, you can contact your RV dealer or post the question on almost any RV Forum on Facebook. The tires on this RV are Load Range C. 

 

 

Once you find the label / sticker, I suggest you take a picture as there is important safety information the label that you should keep along with other important papers like your Registration and Insurance card.

Next, we will cover "ST" or Special Trailer tires. This is a special type tire, unique to the US market. It was developed and introduced in the late 60’s for exclusive use on trailers. In fact, it is against safety regulations to use ST type tires on vehicles designed to carry passengers. In this category we might find an ST205/75R15 101K LR-C. For these tires the ST205/75R15 101K is similar in meaning to what we saw in the Passenger type tires. The primary difference is that the Speed symbol K, L, or R is lower for these applications than for passenger type vehicle. The K stands for up to 68 mph. Because the ST type tires are expected to carry higher loads at higher inflation levels the trade-off is the restriction to be operated at lower speeds. The load formula used by tires engineers when designing ST type tires is based on a stated upper operating speed of 65 mph. While today highway speeds can be significantly higher than 65 we should remember that when ST tires were introduced we had a nationwide Speed Limit of 55 mph so a tire design limit of 65 mph was not unreasonable.

While on the topic of Speed Rating people need to understand that the test is designed for Passenger car tires and only requires a new tire be capable of running up to the stated speed for 10 minutes while running a reduced load of 88% of the tire stated max.

You should be aware that in 2002 both P and LT type tires had the DOT test and durability requirements significantly updated and improved by requiring more durability for those tires, but ST tires only need pass the same tests as in 1970. Many consider this increase in performance and durability desirable as it can be considered a measure of “Quality”.

Next time we will cover the heavy duty tires used on Class-A Motorhomes. These include 19.5 and 22.5 rim diameter and a few others.

##RVT1020