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Monday, November 16, 2015

When to file a complaint with NHTSA

I have previously strongly suggested that when people have a tire failure they need to file a complaint with NHTSA.

Got this question "Thanks, Tireman. My next question is when is it appropriate to report to the NHTSA? After any flat? Or are there specific indicators?"

Excellent question as we don't need to be "crying wolf"

If we start at the end of the process I think it will help us understand when and why we would want to contribute to the database of tire failures.

I think we can sum up the primary objective for NHTSA as to decrease the number and severity of injury or accident costs due to a failure of an automotive system or component. One way to achieve that goal would be to hold the manufacturer responsible for providing parts that deliver reliable service for normal and expected operating conditions.

One way to hold a manufacturer accountable and maybe "hold their feet to the fire" is to order and require a manufacturer to replace a part that has been found to have an abnormally high failure rate due to either design or manufacturing problems.

Based on data submitted to NHTSA, that agency decides if an investigation should be started. The investigation could be limited to a review of test and manufacturing data or it could involve NHTSA conducting it's own tests.

So what data does NHTSA use to decide it an investigation is justified? There is suppose to be a combination of warranty data from the part manufacturer plus a review of complaints filed by individuals.

This presents a problem for NHTSA. How should they judge consumer complaints when they know that consumers seldom have the technical knowledge to do a proper or thorough evaluation of a product failure?

So the question really is.... Should the tire manufacturer be held responsible for a tire loosing air due to puncture or leaking valve? It may be difficult or nearly impossible for the consumer to do the proper investigation to learn the root cause of the failure.
It is well documented that over half of RVs on the road have one or more tire in an overload and or under inflated condition. Should the tire company be held accountable for an overload or low inflation?

Bottom Line
If you believe the RV company or the tire manufacturer should be held responsible for the tire failure then you probably should file a complaint.
If you take a few minutes you might even decide the failure was not the fault of the tire company but of the RV company that selected a tire with no margin for any loss of air or load variation.
  You still need to provide tire information but in the last case of poor tire selection I would be sure to include statement with actual measured loads and the small reserve load the tire selected provided.

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1 comment:

  1. A fellow tire engineer here. Allow me to second what Roger wrote!


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