"Defect Reporting"

I have asked RV owners who had tire failures if they have reported the failures to NHTSA or to the dealer that sold them the RV. Almost universally they said they didn't bother or were told by the dealer "it's not their job". 

 

The reality is that it is Federal law that tire failures be reported to US DOT. "defect reporting requirements, the focus of this memorandum, the TREAD Act requires automakers to notify the Secretary of Transportation within five days of discovery of a defect or the need for a safety recall. See 49 C.F.R. § 573.6." There are significant fines for failure to comply. NHTSA complaint needs the RV VIN and the complete tire DOT serial including the date portion.

 It is my opinion that if you have a failure or suspect failure and can't bother to file a complete report and include a picture you really have lost much of the right to complain about tire quality as you are effectively keeping the information from the tire company and from the Federal Agency that can order a recall after an investigation. No investigation will ever start because you posted a complaint on Facebook or an RV Forum.

##RVT1064

Why-don't-rv-tires-get-recalled?

 I read this question on an RV forum. It was asked by someone complaining that there were no recalls of what he considered "crappy" RV tires. Other posts in the thread went on to say that complaints to the BBB or the tire importer won't accomplish much. I posted a reply pointing out that expecting the National Highway Traffic Safety Administration (NHTSA) to recall tires when there had not been any usable complaints filed, was simply unrealistic.

NHTSA is the government agency charged with the responsibility of writing and enforcing the regulations necessary to achieve improved safety of vehicle systems and equipment. However they cannot order or even suggest that a vehicle or component be recalled without facts and data being collected and analyzed.

A while ago I worked with a reader of this blog, John B., who understood the necessity of providing the information NHTSA needs. He had suffered three tire failures. Luckily he discovered the failures before the tires suffered a detachment. In his case there was no loss of air and no flailing of tire pieces. What he did have was a tire that was no longer round or having a uniform tread contour.

Now lets be sure we all have the same understanding of the terms. In this case a "Detachment" would be when a part of the tread or tread & belt package came apart from the rest of the tire. This type of failure can result in damage to the RV as pieces flail around hitting fenders and the side and undercarriage of the RV.

    John wanted to file a complaint with NHTSA and he wanted to be sure his complaints would be useful to the engineers. He understood that partial or incorrect information would result in no investigation and with no investigation there was no possibility of any action being taken to remove "crappy" tires from use. So John contact me and I walked him through the process of collecting all the details needed. He also wanted to  dissect his tire so he could ship the important parts to me for further examination.


When I received the sample I first cut the tread in the locations John had identified but found no serious issues.

I then called upon my 40 years of experience and took the time needed to visually examine and take measurements with special tools to identify a location that was more probably of interest. After cutting the section at the location of interest and found the separation between the belts that was almost all the way across. This separation allowed the tread area to bulge out to the shape seen in the picture of the tire at the top of this blog.
For those interested these tires were not made in China as we decoded the serial and learned they were made in Mexico.

With the physical examination complete, John was able to file the three complaints with NHTSA. Now it is important to remember that NHTSA has budget constraints so investigations need to be prioritized. Obvious defects that result in physical injury would receive top priority. Also a single or small number of complaints will be of lower priority than a large number so if the only complaints NHTSA receives on these tires are the three from John there may not be any action. The same situation would apply to any complaint you might file BUT it is important to remember that if the majority of people with tire problems only post to RV forums or grouse to others around the campfire nothing will ever happen or result in the quality of tires improving.

Here are Links to John's information. Link 1     Link 2

A quick review of the complaint on file will show that the majority are of little or no value to NHTSA as the owner didn't provide the crucial information of a correct and complete DOT serial. Many complaints don't even provide the tire size or even the correct tire brand. I believe that if people spent half the time they do on RV forums but provided complete and accurate information to NHTSA we might all end up with better quality tires on our RVs.

I am working on another post on the topic or how to provide meaningful information to NHTSA.

BOTTOM LINE
If you have a tire problem you need to collect the facts - Size, Brand, the complete DOT serial and collect some good sharp pictures in case NHTSA needs them. Then make the effort to file a complaint. Who knows, you might just be able to grab the interest of the engineers and have an investigation started.

##RVT985

Do tires have to meet any quality standards? Can I expect all tires of the same size to support the same load?

Had a question on tire "Quality" and load capacity

"I have been under the impression that a certifying agency, American tire and rim?? Sets the standards in the US and then all tires sold in US must be designed to those standards. So a cheap unknown brand load range D tire from Wal Mart would have the same load and inflation specifications as a Firestone tire from a Firestone dealer?

 

 Tire & Rim Assoc. only lists dimensional standards and the Load & Inflation tables.This is a private industry Association

DOT (US Gov) has a dept, NHTSA  (National Highway Traffic Safety Administration) that published tests and performance requirements. I would consider these to be one measure of "Quality"

All tires for highway use, sold in the US must be certified by the tire MFG to be capable of passing the NHTSA tests.  The "DOT" symbol on a tire is the indication, from the MFG that the tire was capable of passing any of the NHTSA test when the tire was first sold.

There is no agency or organization that runs checks on the tires sold as that is cost prohibitive. BUT if tires are found to be non compliant NHTSA can order a recall  and free replacement of all similar tires. There is also a fine per tire that could be charged to the tire company for failure to ensure the tires meet the NHTSA requirements. These penalties could cost a tire company tens of millions so there is a strong incentive to comply. This is why tires all have a "DOT serial" number.  

It is important to remember that there is no way for anyone or any federal agency to establish Quality or performance standards that would cover all tires in all sorts of usage and still end up with tires that people could afford to purchase.

The second part of the question concerns the load capacity of tires from different manufacturers. Since NHTSA uses the TRA published dimensional and Load/Inflation tables when specifying the tests, all tires must be able to run and pass, you can expect that with the exception of a handful of tires, most from Michelin that were initially developed using metric standards rather than the inch-pounds standards, published in the TRA books that you will find that you can use the Load Inflation tables from any company and expect that your tires can support the same load.

##RVT984

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.

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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Why aren't there more recalls of bad RV tires?

In addition to writing this blog, I monitor a number of different RV forums for discussions on tires and related issues. I find that many times I am suggesting to people that they should file a complaint with National Highway Traffic Safety Administration about their tire problems. Many times I get replies asking "Why Bother". While this post focuses on trailer tires the information also applies to other RV applications.

"I get tired of hearing that most ST tire problems are caused by the RV owner. I simply don't believe it based on my own experience. NHTSA; never heard of them, much less knew I could file a complaint. So I asked my tire dealer. She said that they do turn in reports on tire problems themselves and/or turn the tires over to their tire reps for analysis. That went for tires they sold or other brands they replaced. So I don't believe the argument that NHTSA doesn't have enough data to see a trend for ST China bombs. Doesn't make sense if tire dealers are turning in info to them to protect their sales and customers."

Scott I have a number of posts on NHTSA. Here is my take on recalls and filing complaints.

They have a limited budget so must focus on most important first. That means things that can result in death or personal injury. TT only see financial loss so obviously would come last.

While your dealer may have sent information to the tire importer I have noted that many times the volume of tires in a "family" may be low enough to avoid the requirement for data be sent to NHTSA.

in 2014 207 Million passenger tires were sold, 29 Mil LT 18 Mil Truck or 254 Mil tires sold each year where a failure might result in personal injury

According to RVIA data there are 9 Mil RVs on the road but this includes approx 1.1 mil motorhomes so if we have 7.9 mil trailers with say 90% on ST type tires buying a set of 4 tires once every 4 years we are looking at maybe 7 mil St type tires sold each year

So if you were NHTSA where would you spend your research tax dollars? On the quality of 254 Mil tires where there might be injury or on the quality of 7 mil tires with almost no chance of injury?

There have been a few recalls on ST type tires but I am also aware of times when ST tires are not recalled simply because the records are poor as most are imports. In some cases the importer is a small company so does not have the money to do a recall that can cost many million dollars even for a small recall. IMO sometimes a small company would simply go out of business rather than try and handle a large recall.

The RV owners seldom file complaints and many times when they do they do not include the DOT serial so that complaint can not be used in the tally of number of complaints.

+++++++++++++++++++++++++++++++++++++
Here is a reply to another reader:

Tireman, this seems to me to be a big picture economics issue. Is it true that the auto and truck industry does not experience the failure rate or short life that the ST tires experience? If true then the RV tire industry and rv chassis mfgs apparently are not willing to manufacture to the same expectations of the auto industry leading to all the woes that we experience. Look in any parking lot and many of the cars are running on poorly inflated tires. My guess is that these do not fail at the same rate as ST tires. I also have an engineering/QA background and have abused tires for 50 years in racing, towing and with heavy Ag equipment and never seen the failure issues we see with ST tires. I do properly maintain and store my tires, even so I have had 3 failures out of 8 tires in the last three years. Anecdotally I also travel enough to see too many RV trailers on the side of the road with failures. If not for economics, why would ST tires only be made to be rated at 65 mph when we live in a faster world? I try to stay under this for fuel economy but find myself at higher speeds frequently. Impossible to practically operate within rated limits. Is this whole issue because RV mfg do not want to pass on the cost of safe tires? I understand Motorhome tire life is 5 to 7 years and tractor trailer operators get hundreds of thousands of miles on tires. ST tires 2 years? Please explain.

IMO the main reason RV TT mfg do not provide better tire fitment (load capacity) is they sell based on "Bling at low cost". When shopping the RV market you will almost never meet a salesperson who tries to sell based on specifications. Yes tires applied to TT are designed to meet 1970 driving speeds (55 mph speed limit) IMO RV Industry lobby actively opposes any change in requirements that might increase costs by even a few dollars.
Yes ST tire life is MUCH shorter than Passenger, LT or Truck tires.

Universal use of TPMS starting in 2005 on passenger cars has significantly lowered tire failure rates on cars but RVIA (mfg association) does not support TPMS as OE on RVs is one example. They also do not support applying 2002 DOT test requirements on ST type tires so you are stuck with 1970 performance in the 2016 world.

You could write to RVIA at info@GoRVing.com but I have been told that as an industry representative organization they may not be very interested in individual complaints.

If you want to learn more, read some of my posts about NHTSA.

PS While I have done training at NHTSA in Washington DC I do not work for DOT or any Gov agency.

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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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RV tire recall - Cooper 22.5's

Here is some SAFETY info.
Report Receipt Date: MAR 15, 2016
NHTSA Campaign Number: 16T003000
Component(s): TIRES

Manufacturer: Cooper Tire & Rubber Co.

SUMMARY:

Cooper Tire & Rubber Co. (Cooper) is recalling certain Roadmaster RM234 tires, size 295/75R22.5, manufactured August 6, 2015, to September 5, 2015 (weeks 3115-3515). The affected tires may have a pin-sized hole in the sidewall that can result in a loss of air.

CONSEQUENCE:

A loss of tire air pressure can cause sudden tire failure, increasing the risk of a crash.

REMEDY:

Cooper will notify owners, and dealers will replace the tires including the mounting and balancing, free of charge. The manufacturer has not yet provided a notification schedule. Owners may contact Cooper customer service at 1-800-854-6288. Cooper's number for this recall is 4Y.

NOTES:

Owners may also contact the National Highway Traffic Safety Administration Vehicle Safety Hotline at 1-888-327-4236 (TTY 1-800-424-9153), or go to www.safercar.gov.

=========================

I have mentioned that reporting tire failures to NHTSA is something all RV owners should be doing. I also have mentioned that you need to be sure your tires are "registered" so that in the event of a recall the company can contact you.  In the above notice it says the tire company will notify owners of suspect tires but if the owners didn't bother to register their tires there is no way the company or NHTSA can contact the owner.

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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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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When is Minimum inflation the Maximum inflation?

Sometimes the information on inflating tires can lead to some confusion.  OK a lot of the time it can be confusing to many.

As many of you know I try and follow a number of RV forums and offer comments. I try and focus the comments to correcting serious or significant errors or misunderstandings, especially when Safety Related.

Recently there was some confusion about the Maximum allowable inflation for a tire. Some wanted to co-mingle some information from PSR or passenger car tires with information about large TBR, truck bus radials. The discussion then went way off track. Rather than limit my audience to those following that thread, I decided a blog post would be more appropriate. Also I wanted to be sure to have all the information up to date and accurate I contacted an "old friend" from the tire industry and he sent me this nice summary. With his permission I re-print it here.

First some definition of terms may be appropriate as "tire engineer speak" may confuse some.

"Seating pressure" this is the inflation needed for the tire beads to "pop" home against the wheel/

"FMVSS" these are various Federal Motor Vehicle Safety Standards. If you need some reading that will put you to sleep HERE is a link offered by NHTSA.

 "NHTSA" NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

"PSR"  Passenger steel belted radials or the normal tire you find on todays cars

"TBR" Truck Bus Radial  as found on most Class-A RVs

"LTR"  Light Truck Radials 

"CIP" Cold Inflation Pressure

OK here is the nitty-gritty

"First, the max pressure to seat beads as a matter regarding the technician’s safety is 40 psi, whether passenger, light truck, or truck-bus.  This bead seating pressure is totally independent of the tire maximum operating pressure.

It is important to clarify the differences in sidewall markings of the tires you bring up:

PSR & LTR Tires (load range E or less):  Since FMVSS 139, these tires have sidewall markings indicating maximum load AND maximum pressure.  Maximum load means max [static] load, and maximum pressure means max [operating] pressure (cold).  With respect to the minimum pressure that carries the maximum load there is a difference:

·         Passenger Tires:  These tires are usually marked with a maximum pressure that exceeds the pressure necessary to carry the maximum load marked on the sidewall.  For example, the tire may be marked with 44 psi max pressure, but only requires 35 psi to carry the max load.

·         Light Truck Tires (load range E or less):  These tires are usually marked with a maximum pressure that is also the pressure required to carry the maximum load.  For example, a load range E tire marked with max 80 psi would need that same pressure to carry the max load.

TBR Tires (and light truck load range F and higher):  On these tires the sidewall markings indicate maximum load AT a certain pressure (the word “maximum” is not used in regards to pressure).  Maximum load means max [static] load, but the pressure is not the maximum operating pressure (cold).  This marking just follows FMVSS 119.  Essentially, the pressure marking is informative, simply telling the reader the pressure that is required to carry the maximum rated load.

However, for most practical purposes, on TBR tires the pressure marking is typically considered the maximum pressure recommended in the tire while in ordinary service.  Certain situations may permit cold inflation pressure higher than the marking, usually in consultation with a tire manufacturer for a specific product, application, and service.

Regarding load-inflation tables:  As long as you are looking at the right table, this is where you find the pressures needed to carry certain loads for a given tire type, size, load rating, etc.  Note that for truck-bus, you might need to make sure the tire is a “T&RA tire” or an “ETRTO tire” since the tables can differ, even though the size codes are the same (such as 295/75R22.5).  Also, a tire manufacturer may have unique load-inflation table(s) associated with certain tire models, sizes, etc.

If an operator is running at max load, and the pressure to do that happens to be max pressure, then yes, they need to be diligent.  But it is manageable, and they owe it to themselves and to others on the road to do so.  Pressure loss through permeation requires minimal adjustment approximately once a month.  For predictable swings in temp, set the pressure when it is likely the coldest, and try to consistently check it during those times, such as early in the morning before setting out.  No one is saying that everyone in all circumstances needs to set pressure to +/- 0.1 psi every morning, noon, and night with three hours of ambient cold-soaking before taking measurements.  I agree with you about reducing load; not just due to the tire influence, but also drivetrain/axle and chassis wear and tear, braking performance, fuel economy, etc."

So we see there are similar but different words on the sidewall of tires. Some have a stated Max cold inflation others do not. This is one reason why it best to have tire service done at a store that has the appropriate equipment and training to handle safe and proper mounting and inflation of the type tires you are working with. This does not mean you can't add 5 or even 10 psi to your tires but IMO if you need more than 20% of the CIP there is something wrong and you really need to consider having a professional inspect and re-inflate your tires. Inflating an improperly mounted, improperly repaired or damaged tire can injure or even result in death if not handled properly.
OK now back to our regular programming.
One other comment I have is that many times some think tire failure "Blowout" is caused by too high a pressure but this is essentially incorrect. Unless you have damaged the body ply cords, be they Nylon, Polyester, Steel or Rayon by over flexing and running significantly under-inflated, tires are designed to tolerate the normal pressure increase seen when running highway speeds at the approved load.

But if you have damaged or run the tires in overload or under-inflated for the actual load or perhaps at a speed higher than the tire rating you may have damaged the cord sufficiently that it has lost a portion of its strength so in that case even normal cold inflation may be too high. This is one reason any tire that has been damaged must be rendered un-usable or if it appears to be OK then inflated in a Safety Cage.


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Safety Recalls

The National Highway Traffic Safety Administration or NHTSA just made available a video to help people understand vehicle recalls.

“Understanding Vehicle Recalls” gives a quick overview.

This website allows you to check if your vehicle or tires are under a recall.

If a safety recall is initiated, your manufacturer will notify you of the recall through first class mail and offer to fix it for free. If your vehicle is recalled, please call your local dealer as soon as possible to make an appointment for a free remedy. By fixing your safety recall, you have the power to save your life, and the lives of your passengers and other motorists.

Sign Up to Receive Recall Alerts via email alert.

Report Potential Safety Problem.  I have previously posted information on the importance of reporting tire failures to NHTSA. Just complaining while you sit around the campfire or venting on an RV forum may make you feel better but it will never result in action that could improve the quality of RVs or the tires that go on RVs. Reporting a vehicle or equipment safety problem to NHTSA is an important first step to get the situation remedied and make our roads safer. If we receive similar reports from a number of people about the same vehicle, this could indicate a safety-related defect may exist that would warrant opening an investigation. Report your vehicle safety complaints on SaferCar.gov.

I am in the process of writing a post that will show that there is hope for RV owners. I am seeing an increase in load capacity  as well as an increase in speed ratings for trailer applications and will be covering this in depth next week.


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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.

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 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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Quality of complaints filed on Chinese made tires

One of the challenges of writing this blog is to have topics that you the readers find interesting and informative.
At times I feel I am just a broken record as I repeat Know the load, Inflate the tire, Report failures to NHTSA. One thing I do to try and get new ideas, is to read posts on various RV forums on people's questions on tires or statements of their problems. I also monitor which of my topics have drawn the most viewers. My most popular post to date was from Jan 2012 on Chinese tire quality.

I also note there continues to be references to "China-bombs" on various forums so I thought I would review the status of complaints to NHTSA on some tires some think are made in China, for without complaints that provide the information needed by the investigators at NHTSA, there will never be a recall and without a recall there is little real incentive to some companies to improve the quality of their tires.

Here are some current complaints:
Some say the Greenball brand is a "China Bomb"
01/25/2013 there was a complaint about GREENBALL TOW MASTER ST225/75R15 The claim the tires suffered sidewall cracks. There was damage to the RV.  I note that the tire manufacturer was not notified of the problem and that the tire DOT serial was not provided to NHTSA.

12/19/2012 there was a complaint about GREENBALL TOW MASTER with the claim "TIRE BLOW OUT in Sept 6" No tire size, mileage or DOT serial was provided to NHTSA

11/13/2012 there was a complaint about GREENBALL TOW MASTER size 225/75/15. The claim that both the front & rear passenger side tires failed at 1,000 miles. DOT NUMBER WAS NOT AVAILABLE.

10/24/2011 GREENBALL CORPORATION TOW MASTER TIRES, SIZE FT 205/75R15, SERIAL NUMBER: 9DUL2810 on a 2012 Heartland

Note the 9D indicates the tires in question were made by   P.T. Industries, Karet Deli, Indonesia
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I then looked at another non-US made tire  MISSION brand
 09/26/2012 MISSION ST TIRES, SIZE: 205 75 R15 are incorrectly identified as made by General Tire. Two tires "exploded" but no DOT was provided.

There were four other complaints field with various tire failures. All identified incorrectly as being made by General tire and no DOT serials were posted so we cannot identify the actual country of origin.
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I then looked for Power King Tow max
There are also problems with NHTSA data as this tire has been recorded as being manufactured by Cooper Tire Co. but I have looked for information and it appears the Powerking brand is imported  by TBC Wholesale

I did find there were 22 complaints on file and a couple actually provided the tire DOT which allowed me to identify the production plant as SHANDONG HENGFENG RUBBER & PLUSTIC CO., SHANDONG, China

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Bottom Line
SOme but not all tires that fail appear to be made in China. Also the NHTSA web site isn't very easy to use to find which tires have fewer complaints than others. One of the major reasons is what engineers call GIGO   Garbage In Garbage Out. 
People are not providing the tire DOT serial so numerous errors follow, making the complaint web site less than helpful, which means others can't gain knowledge needed to make informed decisions.

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.