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Monday, December 31, 2012

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.

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