The Tire Industry Association (TIA) is supporting a request by Denman Tire Corp. to exclude limited production specialty radial tires from the National Highway Traffic Safety Administration's final tire testing standards rule.
In a letter to NHTSA administrator Jeffrey Runge, TIA wrote the following:
"The Tire Industry Association (TIA) is writing in strong support of a Petition to Reconsider submitted by the Denman Tire Corp. on Aug. 7, 2003, regarding the Tire Recall Enhancement, Accountability and Documentation (TREAD) Act final rule for tire testing standards (68 Federal Register 38116, June 23, 2003).
"TIA is an international association representing all segments of the tire industry, including those that manufacture, repair, recycle, sell, service or use new or retreaded tires, and also those suppliers or individuals who furnish equipment, material or services to the industry. TIA was formed by the July 2002 merger of the International Tire & Rubber Association and the Tire Association of North America.
"TIA strongly urges the agency to permit limited production specialty radial tires to remain regulated under Federal Motor Vehicle Safety Standards 109 or 119. Denman has proposed that the definition of limited production tires be those tires that are of similar size and design with less than 15,000 units manufactured per year.
"Both the U.S. House of Representatives and the Small Business Administration’s Office of Advocacy agree that NHTSA’s analysis and conclusion that small business would not be negatively impacted was incorrect, and TIA agrees with that assessment. TIA believes this final rule will have a significant economic impact on small manufacturers, contrary to NHTSA’s Regulatory Flexibility statement regarding this final rule. TIA believes NHTSA should conduct further analysis and minimize the impact on small tire manufacturers by granting Denman’s petition.
"The intent of the TREAD Act was to make the public safer regarding their tires. The specialty radial tires in question are primarily used by car hobbyists or enthusiasts -- people who know how to maintain their tires. These tires are not typically mass-produced and to our knowledge have never had significant safety problems. Putting small manufacturers through FMVSS 139 for these specialty radial tires will cause them to go out of business with no evidence to justify the need.
"In conclusion, TIA strongly urges NHTSA to grant the Denman Tire Corp.’s Petition to Reconsider and exclude specialty radial tires from FMVSS 139. Allow specialty radial tires that are limited in production with size and design of less than 15,000 tires per year to follow FMVSS 109 and 119 as you have done for specialty bias-ply tires.
"TIA appreciates the opportunity to submit these comments and is willing to assist NHTSA in any way possible."
