DOT Tire Safety Regulations

 Occasionally I will get questions about some specific feature in a tire or asked why tire engineers didn't design tires to perform in a different manner. Sometimes some even want to question why I didn't design a tire to perform some task such as supporting more load so the RV owner wasn't forced to buy a more expensive tire. The primary reason is that there are numerous federal Safety regulations that all tires sold in the US for highway use must pass or face fines that could be as high as $1,000 per tire.  For those that think they can do a better job of designing tires I can save them some time when they do the research themselves so they can ignore people such as myself who do have experience on the subject.

For those interested in the various safety regulations as they pertain to vehicles you can start HERE:

https://www.ecfr.gov/current/title-49

Then start digging down to the appropriate specific standard.

 For my 40 year career, I had to live every day under Chapter V National Highway Traffic Safety Administration, Department of Transportation and most of the time focus on section 571 ( but occasionally confirm others sections such as 569, 573, 574 and a few others.

I found myself most concerned with Sub Part B and 571.109, 571.119 and of course 571.139. Our focus would of course change depending on the type and size tire we might be tasked with developing or evaluation.

I doubt that you want to have to learn all the appropriate sections but if you don't want to accept my experience and expertise you are welcome to read and research all of 571 and then contact the appropriate department in DOT to get a clarification on some of the apparent contradictions.

Good luck with your research and education.

 

##RVT1030

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

Who to believe on tire inflation?

I was reading an RV forum and found a number of folks offering their interpretation on what the proper inflation is for tires in RV application. Some insisted the only correct inflation pressure was what was shown on the "Tire Placard" or "Vehicle Certification label"
.
Here is my reply:

We have two separate issues to consider when selecting the minimum cold tire inflation pressure in RV application.

A vehicle MFG has DOT requirements they need to follow. They are to specify the minimum inflation needed in the tires they provide on the new RV. That inflation is required to be sufficient to support the stated GAWR divided by the number of tires on that axle. Basically this means the axle rating is used to establish tire inflation based on the published load & inflation tables from the tire company.

The owner of the RV needs to confirm the actual loading for their RV and should confirm they are not exceeding the GVWR or either GAWR or the individual tire load capability.

You will immediately note that the RV company is making an assumption that is just not a reflection of reality, that being that axle loads are always split exactly 50/50 side to side. While many RVs may have the load split only a couple percent off of 50/50 some have discovered one end of an axle may carry more than 1,000# more than the other. Others have learned their unbalance is closer to 40/60 and some have discovered that their tires are overloaded as soon as they fill their fuel tank before loading anything else into the RV. Obviously a responsible owner needs to do a better job than some RV companies are doing.

While some feel it is sufficient to just read the regulations about the vehicle certification label I and other tire engineers know that policy is not always the best way to get the best combination of ride, handling and tire durability.

Lets see what Goodyear says in their RV tire application web page.
"Correct tire inflation is a key component in tire care. The recommended maximum inflation pressures for your tires are indicated on the certification label or in your owner's manual. Since RVs can be loaded with many different configurations, the load on each tire will vary. For this reason, actual air pressure required should be determined based on the load on each individual tire.
Inflation pressure should be adjusted to handle the tire carrying the heaviest load, and all tires on the axle should be adjusted to this standard."

Maybe you don't think Goodyear knows more than some RV owners. What does Michelin say in their RV documents Here on pg 4:
"The amount of inflation pressure required in each tire depends on the weight of the fully loaded vehicle, to include passengers, cargo load, fuel, and water."
" To determine proper inflation pressure, Michelin recommends weighing each wheel position of the recreational vehicle individually. Weighing each axle end individually will give a clear
indication of how the weight of the recreational vehicle is distributed across the axle. "

Also in their tire maintenance document on tire inflation:
"Unlike commercial light truck and truck applications, we recommend weighing motorhomes at each wheel position of the vehicle (right front corner, left front corner, etc.). This is the only way to get a clear indication of exactly how the weight of the motorhome is distributed. Otherwise, one wheel position may be significantly overloaded even though the G.A.W.R. has not been exceeded. Tire inflation for a given axle should be set according to the pressure corresponding to the higher of the two end loads."

Others are allowed to have and express their opinions and their interpretation of how the regulations are to be applied, but it was my job as a tire engineer to understand and work within FMVSS regulations for some 40 years.

I will leave it up to you to decide if the only acceptable inflation is what is on the vehicle certification label or that inflation is learned by reviewing what major tire companies say in their  published guides.

__________________
Retired Desi

Want better quality tires on your RV?

Many people want to complain around campfires or on RV forums about the poor quality of various components on their RV. While I can't address systems such as Refrigerators, Holding Tanks, or Furnaces, I can comment on the quality of tires selected for placement on RVs.

With an industry that focuses on quantity and low cost, is it any wonder that tire performance isn't as good as we would like? We need to remember that while there are laws specifying the minimum performance and capabilities of RV tires, I am not aware of any legal requirement against providing tires that can support more load than the minimum requirement or with speed capabilities higher than what most feel is a reasonable and safe operating speed for large RVs and/or trailers.

I have written a few times about how to file a complaint with NHTSA (National Highway Traffic Safety Administration, the federal agency that establishes minimum performance requirements for tires) and you can easily find those posts using the list of links on the left side of this page.

I feel this topic continues to be important given recent posts on RVTravel.com and rvdailyreport.com that have been on the low quality of RV components.

I just read a post from a fellow RV owner that had a couple of tire failures. When I asked if he filed a complaint with NHTSA, he said: "Couldn't report anything. We were on the side of I-95 middle of nowhere going south. All I know is tire blew out on inside, there was a hole. Front passenger tire."

So, because he no longer had the tire he can't provide the info needed by NHTSA for their database.

I replied: "Well, that's a perfect example of why it is important for everyone to have a written record of the tire DOT, size and brand info on file with other important information you keep for other components of the RV such as Refrigerator, Furnace, Generator, TV, etc.

"Many complain about the poor durability of tires in RV application but very few bother to take the basic steps needed to get the information to the DOT. NHTSA (department of DOT) can investigate products if there are sufficient complaints received, and if they find an automotive component doesn't meet the required standards they can order a recall. Recalls can result in replacement tires being given to owners.

"However for a complaint to be minimally helpful in establishing poor performance the full DOT (including date code) is needed. All too often there is confusion in the terminology of tire company, brand and model. Some owners do not provide the correct or complete tire size, giving info such as 225-15 for example.

"I have a number of posts on my blog about recalls and NHTSA if people want to learn more.

"If not interested in getting better-performing tires on your next RV, that's your choice. But I have little compassion for people who have problems but aren't willing to spend 10 minutes filing an actionable complaint. Remember a bit@# session around the campfire or on an RV forum will never result in an improvement in RV component quality."


I have also read an account of an RV owner who did file a complaint and apparently the tire importer read the NHTSA report and the guy ended up getting a set of tires free. Now, this is very unusual but it did happen. But again, if you don't have the DOT S/N, I do not see how you can file a complaint, and if you don't file complaints why would you expect there to be a recall?


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Post a complaint with NHTSA - Part 3

 Lets finish up this thread.

How to write a useful Description of tire failure for NHTSA

Lets take a short break from all those screen shots and review how to write a meaningful "Description" of the failure as seen in Step 1 of my post of Jan 8.

You need to remember that NHTSA needs facts if they are to take any further steps as they consider if an investigation is warranted.

Just ranting "My tire exploded, tore up my RV and I want new tires and compensation for the repairs and my expenses." is not useful to NHTSA. If you can't be bothered to provide critical information such as tire DOT serial why should NHTSA make an effort to investigate? Other information such as location of the incident, your cold inflation and info on what warning you received from your TPMS, if you still have the tire and can provide pictures or contact information on who has the tire, would be bonus information and potentially very helpful to the engineers at NHTSA. I previously outlined the MINIMUM information needed in my post on Dec 31 2012.

Here is an example of an actual complaint #10262837    "I  OWN A 2004 GMC SIERRA 3500. THE VEHICLE HAS POWER KING TOWMAX TIRES, SIZE LT235/80R16E. WHILE PULLING THE TRAILER AT 65 MPH, THE SIDEWALL ON THE PASSENGER TIRE BLEW OUT."

Looking at the Power King catalog on pg 10, I do find a Towmax STR in ST235/80R16 LRE size but ST type tires are not approved for use on passenger carrying vehicles such as a GMC 3500 pickup. Moving on to LT tires on pg 14 & 15 I find no metric sizes such as LT235/80R16.

So we are confronted with a few questions.   Did the owner provide the correct tire name but wrong size?
Did the owner provide the correct size but wrong tire name?    Did the owner mean the tire on the passenger side or that the tire was actually a passenger type tire?   Was the tire that failed on the GMC?
No mention of an RV or trailer brand is made by the owner. I also note that the tire manufacturer is entered as Cooper Tire and Rubber Co but according to my contacts at Cooper, they do not have a Power King or Towmax tire line and have not made ST type tires for many years.

If you were NHTSA would you consider this person a reliable witness to what actually happened  with a tire?

Now you are wondering what a good report looks like. Lets look at #10471651
" THIS COMPLIANT IS FOR A TANDEM AXLE TRAILER TIRE FAILURE USED ON TRAVEL TRAILER CAMPER. THERE ARE THREE TIRES FAILURES WITH THE SET OF FOUR ON MY TRAVEL TRAILER. THIS REPORT IS FOR THE FIRST TIRE. THE TIRE IN QUESTION IS A DENMAN ST225/75R15 LOAD RANGE D. TYPE: ST EXPRESS RADIAL DOT CODE: 4FEH M5M 1908 TIRE INSTALLED: 4-5-2009 FIRST TIRE FAILURE OBSERVED ON 4-21-2012 MILES USED UNTIL FAILURE NOTICED, 10,164 MILES TOWING SPEED: 55 TO MAX OF 60 MPH AS STANDARD TOWING SPEED ON HIGHWAY. AIR PRESSURE OF 65 PSI CHECKED AT THE START OF EACH CAMPING TRIP. TIRE FAILURE OCCURRED WHEN THE TIRE WAS MOUNTED IN THE LEFT REAR POSITION. I HAVE CERTIFIED SCALED WEIGHT SLIP THAT CAN BE PROVIDED OF THE CAMPER AFTER THE FAILURE.
THE REAR AXLE LOAD IS 4,040# ON BOTH REAR TIRES. THE TOTAL RATED CAPACITY OF THE REAR TIRES ARE: 2,540 X 2 = 5,080# AT 65 PSI COLD PRESSURE. CAMPER VIN [XXX] CAMPER MANUFACTURE: SUNLINE COACH COMPANY, DENVER, PA MODEL TRAVEL TRAILER: SOLARIS SR, T310SR, GVWR: 10,000# GAWR: 10,000# I AM THE ORIGINAL PURCHASER OF THESE TIRES WHICH REPLACED THE ORIGINAL TIRES ON THIS CAMPER. THE SIZE, LOAD RANGE AND INFLATION PRESSURE MATCH THE OEM TIRE PLACARD. I HAVE PICTURES AND CAN SEND IF NEEDED. THE TIRE HAD A TREAD BULGE INCREASING THE OD OF THE TIRE IN AN APPROX. 180 DEGREES OF THE TIRE AND WAS FOUND DURING CAMPER AXLE MAINTENANCE. THE TIRES WAS REMOVED FROM SERVICE UPON FINDING ON 4-21-2012 BEFORE TOTAL FAILURE OCCURRED DURING TRAVEL AND TO PREVENT CAMPER DAMAGE. THE TIRE WAS SENT TO A TIRE ENGINEER AND SECTIONED FOR ANALYSIS. NAME CAN BE PROVIDED IF NEEDED. I HAVE PICTURES THAT CAN BE PROVIDED TO MATCH WITH THE ENGINEERS REPORT ALONG WITH HIS
NAME AND ADDRESS. THE REPORT DECLARED THE TIRE FAILED DUE TO DETACHMENT. THE FAILED TIRE WAS REPLACED WITH A NEW TIRE OF THE SAME SIZE AND LOAD RANGE, HOWEVER A DIFFERENT BRAND. I HAVE ALL PICTURES AND REMAINS OF THE TIRE IF NEEDED FOR FURTHER INVESTIGATION."

See the difference?

You do not need to write as detailed a complaint as in the last example but IMO the MINIMUM information you need to provide would be:

1. A brief description of the tire condition, i.e., "Tread and belts came off" or "sidewall disintegrated"  along with a list of damage done to the RV with the associated costs would be desirable.

2. Vehicle VIN - This is on the vehicle label and probably on your registration slip.

3. Tire DOT serial - The complete serial number including the date code at the end.

4. Brief statement letting NHTSA know if you have additional information such as: "I have photographs of the tire" or where the tire is: "Tire is in my possession" or "Tire delivered to Fred's tire in Anytown, USA.

5. If you were using a TPMS that would definitely be information I would include.




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NEW DOT serial info but date code portion to stay the same

NHTSA Standardizes Tire Identification Number

Change Accomodates Increasing Number of Global Tire Plants

WASHINGTON, DC, April 14, 2015 – The National Highway Traffic Safety Administration (NHTSA) announced a final rule to standardize the Tire Identification Number (TIN) imprinted on tires sold in the U.S.  The new regulation creates a 13 digit TIN for new tires and seven digit TIN for retreaded truck tires.

NHTSA initiated the rulemaking because it had exhausted the number of two-digit plant codes the agency issues to every tire plant making tires for the U.S. market.  The new TIN will have a three-digit plant code.

The Rubber Manufacturers Association commented to NHTSA when its membership voiced concerns over some aspects of the proposed rule.

“RMA appreciates NHTSA’s effort to create an effective regulation to continue its obligation to provide plant codes to manufacturers while making common-sense accommodations to limit unnecessary costs,” said Dan Zielinski, RMA senior vice president, public affairs.

RMA commented on the proposed rule urging NHTSA to drop a proposed requirement for a 50 mm blank space after the TIN. RMA argued the additional space would add significant cost to the rulemaking with no safety benefit while causing extensive remodeling to tire molds around the world. The final rule eliminated the proposed 50 mm requirement.  Additionally, RMA successfully argued that tire manufacturers be given 10 years to phase in the new rule’s requirements.  RMA noted to NHTSA that a majority of tire molds last as long as 10 years. NHTSA agreed with RMA.

“RMA agrees that NHTSA needs to change the TIN to a three-digit plant code,” said Zielinski.  “RMA members had several concerns with the proposal that would have needlessly raised costs to tires produced in the U.S. and NHTSA agreed to make key changes.”

In response to other stakeholder requests to change the date stamp portion of the TIN, NHTSA said, “…we do not believe a change to the date code is necessary for consumers to determine when their tires were manufactured.”  NHTSA added that sufficient information to understand the date stamp is available online or by asking a tire dealer.”

Click here to link to NHTSA rule.

# # # #

The Rubber Manufacturers Association is the national trade association for tire manufacturers that produce tires in the U.S.  All RMA press releases are available at www.rma.org.

===========================
 I am confident that the info on the plant look-up web site http://www.harriger.com/tires.htm
will be updated as new plant locations are added.



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Soften the blow to your wallet when buying tires

Recently read a blog post about the "sticker shock" of the cost of "truck type" tires for the large RV. I would like to offer a suggestion on how to soften the financial hit. This strategy can work for all RVs be they trailers, Class-B, Class-C or Class-A size units.

It a simple plan and will only take a few minutes to lay-out. With the planning behind us we will be prepared to take advantage of any special deals or short term sales we might come across.

Now to follow this plan there are a few bits of  information you need to have:

You need to know the exact size, Load-Range and DOT serial date for your current tires.
Sorry but just thinking you have 235-16 size tires that you bought in 2009 doesn't cut the mustard.

If you are not sure how to get this information I suggest a quick refresher is in order so you might read the post on "Reading a Tire". So lets assume you have collected the details on your tires so you know exactly what you will be looking for over the next few months.

Here is how my suggestion works.
If all your tires are the same size I would suggest you plan on replacing the two oldest tires first. The new tires would go on the front positions and the others in dual position in the back.

Next year I would buy two more new tires, place them on the front and move the tires that were on the front back to one pair of duals.

Then the third year buy two more tires, place them on the front position and move the older fronts back to the rear.

The above schedule serves a few purposes:

1. It spreads out the purchase over a three year period.
2. It has you running on the newest tires on your front position.
3. With this plan you can spend months shopping for the best deal and avoids the need to accept tires that may be years old before you even buy them. Since you know you have a plan and you know that over a six to 10 month time period to do your shopping.
4. When you are done you know your oldest tires are three years old and if you plan on changing tires when they get to seven or eight years you now have a four year period to set aside some cash for when you start the cycle over again. You can continue this schedule for as long as you own your RV and never be confronted with having to buy more than two tires in any year.


Now if your fronts are different size than your rears as seen on some large Class-A units you can't do the front tire rotation but you can still limit the purchase of your rears to just two a year

With a little planning no one should have to buy more than two tires in any one year. It just takes some thought and planning.



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DOT Date Code - Why do they make it hard to find and read?

How old are your tires? 

How do you learn the answer?

What is the DOT date code and why is it so hard to find and read?

Answers to these and other important quests can be found right here at RVTireSafety.com.


DOT regulations (Law) specify the size of the serial ( 1/4" min) and parts of the content as well as placement (below the midpoint of the sidewall).

The first two characters are a "Plant Code" which as far as I know is standard as I have never seen a variation from the industry code list.

Characters #3 & 4 are not uniform across all tire companies but would be uniform within a tire company and these are a code for the tire size. Sorry but I have never seen a list for all tire size codes for all tire companies. In reality you don't need to know how to "translate" the code as you simply read the size off the tire sidewall.

The next series are optional. These may be used by different tire companies for internal coding. Some companies us no code others may use 1, 2, 3 or 4 characters.

The last four NUMBERS  are the date code, with the first two numbers being the week number starting with 01 and ending at 53 ( The code is changed on Sunday and some years have 52 and some have 53 Sundays. Bet you didn't think of that.) The last two are the last two characters of the year.
Prior to May 2000 the year portion was just a single number but since you should not have tires older than TEN years on your RV you better not have a tire with just  three digits!
The year part changed in 2000 as before that only the last number of the year was used along with another symbol but it was decided in late 1990's that this was too complex so the switch from three to four numbers for the date code.

Since the date code MUST by law, be changed each week this presents some challenges to the manufacture of tires as a person has to do this change. This presents safety issues as reaching the top part of the mold would require a person to climb into the cure press which is HOT (250° to 350°F) and the equipment could accidentally close on the person, so only the bottom side of the mold gets the date portion of the code.

Some car companies have a practice of placing the side of the tire with the full code on the outside but with dual application this means that for RVs the rear tires will have to be different than the front or the date code would be facing the tire that is its mate and very difficult or impossible to read without dismounting the tires from the RV so RV companies do not have this requirement.
This is one reason why whenever buying new tires you should ask for the full DOT serial to be recorded by the dealer on your invoice and that information be stored along with other important papers and information you keep available for future use.

 Here is some information from earlier posts on the DOT serial. If you want to read more just search using the Label list on the left side of this blog.
The DOT Serial

This has important information used in determining the tire age. Other information such as the location of the tire plant that made the tire is part of this code ( first two characters  8X in this example). If there is a recall, this code is used to identify which tires are covered by the recall. NOTE that the last portion, the 4 digit date code, 3908 in this example is only molded on one side of most tires. Every tire sold for use on the highway in the USA must have a full DOT serial including the date code molded on at least one side. This tire was made the 39th week of 2008.

 

 Do not confuse the fact that the 6E7378 ends with four numbers as there is no 73rd week of the year 2078.

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Autoguard LT245/75R16 being recalled

I have previously written about tire recalls. Here is what can happen when it is confirmed that some tires do not comply with DOT regulations. 

 Some Autoguard LT245/75R16 tires are being recalled by the manufacturer.

Tires manufactured June 25th, 2012, through November 11th, 2012. These tires failed the endurance test standards of FMVSS 139 and contain incorrect maximum load load data on the sidewall. Thus, these tires fail to to comply to the requirements of Federal Motor Vehicle Safety Standard No. 139, "New Pneumatic Radial Tires for Light Vehicles."

You can get more information at NHTSA Campaign ID Number: 13T007

Owners may contact Tire Group International, Inc., BCT's U.S. contact, at 1-305-696-0096 extension 5538.  

Have you read a tire lately? Tire Marking

Have you read the information provided to you by the tire manufacturer? If you have, did you bother to record the important numbers in your log book so you only need to do this job once in the life of a tire?

There is a lot of information molded into the sidewall of your tires. Most of this is required by law. Most of this is important for you to know so you can look up the correct inflation for your tires or if buying new tires be sure to get replacements that can carry at least the same as the original tires.
Here is some information from one tire.

First the SIZE

This tire is a "Passenger" type as it starts with the letter "P" other types might be "LT" for Light Truck, or "ST" for Special Trailer. Small tires intended for passenger cars migth not have the "P" if made to European specs. Large tires like 19.5 or 22.5 rim dia have no letter and are "TBR" of Truck Bus radials and are found on Class-A RV. The "114S" is the Service Description which is a Load Index (from a published table but using the actual Max Load is better). The "S" is the Speed Rating or max operating speed. Like the Red Line on your engine. Not all tires have this description.

The DOT Serial

This has important information used in determining the tire age. Other information such as the location of the tire plant that made the tire is part of this code ( first two characters  8X in this example). If there is a recall, this code is used to identify which tires are covered by the recall. NOTE that the last portion, the 4 digit date code, 3908 in this example is only molded on one side of most tires. Every tire sold for use on the highway in the USA must have a full DOT serial including the date code molded on at least one side. This tire was made the 39th week of 2008.

The Load & Inflation information

This is the maximum load capacity for the tire when the cold inflation is set to this pressure. In this example (2601 lbs) when the inflation is set to( 44 psi max press) when the tire is at ambient temperature. NOTE for LT and TBR type tires there is a second lower load limit for dual application (tires side by side on the same axle as on the rears). If you have two axles and ST type tires I personally suggest you not exceed the "dual" tire load as you need a safety factor in your tire loading due to extreme side loading unique to tandem axle trailers.

Tire Materials

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 TBR tires will only have 1 ply of steel in the sidewall.

Safety Warning

This is for the person mounting and inflating the tires for the first time. Do not confuse the inflation number here ( 40 psi) with the inflation number associated with the load (44 psi). This is the max inflation to seat the bead. If you have ever watched a tire being inflated it is the "Pop" or "Bang" first heard. If the tire doesn't seat by this inflation then it should be deflated, re-lubed, re-centered and re-inflated. People can die if they ignore this warning.

Bottom line
If you get new tires and they match the Size and Load & Inflation information you are good to go. If ANY of these numbers are different you need to be sure you completely understand why and that you are not getting a tire with lower load capacity.

Reporting tire failure to NHTSA Part 2

Now we get to the details. Following are instructions and screen shots of what you will see once you visit the NHTSA web site.

Before you start:
You need to collect all the information you will need to complete the complaint form. This information includes Tire Make or Brand, Tire Line, Size, Complete DOT serial. Also the RV Make, Model, year, VIN and mileage.

I suggest you review these steps first.
 

Intermission

OK we have covered a lot of ground and are not done yet but I feel this is enough for now as I don't want to put anyone to sleep.

I think you can see why it is a good plan to assemble all the information details you will need before you start the complaint form process.

It really isn't important that you remember all these steps. I do suggest you bookmark this series of posts so that if you ever do need to file a complaint you can come back to these instructions.

One more post and we will be done with this topic of how to file a complaint.

Here's the link to Part 1 of this series.

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.