TIA offers to administer proposed federal Tire Fuel Efficiency Consumer Information Program

As the National Highway Traffic Safety Administration (NHTSA) embarks upon creating a Tire Fuel Efficiency Consumer Information Program, the Tire Industry Association (TIA) contends that “as one of the world’s leading authorities on tires and wheels, TIA believes they are the best entity to run this program.”

The organization recently made its pitch in written comments submitted under an official NHTSA Notice of Proposed Rulemaking (NPRM).

“TIA has the history, resources and expertise to make this important consumer education effort a success. We also have a history of working together with many different aftermarket organizations – not to mention the tire manufacturers – to formulate a successful consumer education effort,” says Roy Littlefield, the TIA’s executive vice president.

“TIA and its members know consumers and how to reach them. We have the know-how and a long track record of working with, and being supported by, the relevant industry representatives. And, we are fully confident that, given this overwhelming evidence, TIA remains the best organization to administer this effort,” Littlefield maintains.

The association has concerns about the agency’s proposed approach for initiating the plan.

The program “takes the guesswork out of buying the best tires for your vehicle,” says U.S. Transportation Secretary Ray LaHood. “Our proposal would let consumers look at a single label and compare a tire’s overall performance as it relates to fuel economy, safety and durability.”

A December deadline has been set for completion of the rulemaking process.

The TIA points out in its written submission that “while NHTSA’s NPRM focuses on an point-of-sale poster to educate consumers about tire fuel efficiency ratings, TIA contends that, based on TIA’s experience representing tire retailers, a poster or pamphlet should be a component, but not the core feature of the campaign.”

It goes on to note how “the notice does not even mention the dialogue between the salesperson and the consumer as a viable means of education. TIA proposes to bridge this ‘communication gap’ by embarking on a comprehensive course of training to tire sellers in addition to a massive public outreach campaign in order to keep tire maintenance in consumers’ minds.”

The association offers that “under NHTSA’s direct supervision and advisement, TIA would create and implement a program to engage the consumer in person-to-person education from a trained sales force, based on its current training models which are used to educate tire technicians on a variety of maintenance and diagnostic techniques.”

The TIA has asked NHTSA staffers to conduct additional research into the proposed program, explaining that the “TIA feels strongly that the efforts mentioned in the NPRM, such as an informative poster, interactive mediums, Web site development and paper brochure materials, will be inadequate to attain the goals of consumer education ‘about the effect of tires on automobile fuel efficiency, safety, and durability.’ Further testing should be conducted to evaluate the effectiveness of the poster and other means versus a face-to-face dialog.

“In addition, the majority of the focus of the NPRM seems to be in developing a labeling system for rating rolling resistance on tires. This requirement is that a rating system label be affixed to a tire’s tread surface ‘so as not to be easily removable.’ Many tire retail outlets offer consumers hundreds of tires of varying sizes, performance criteria, load indices, models and brands. Tire retailer showrooms are not large enough to display so many tires and those tires that are displayed may or may not have a paper tread label. Since the current paper tread label is removed by the retailer when the tires are installed, consumers are unlikely to see the actual label that had been affixed to their new tires. Therefore, any requirement under this NPRM to place rating information on the paper tread label would not help consumers to make a tire choice for their vehicle.

“However, it will be critical for the tire sales personnel to be able to convey this information on those rare occasions when the consumer does come into contact with the tire label.

“The NPRM outlines several methods of educating consumers; however, TIA believes NHTSA continues to underestimate the extreme importance of the dialog between the sales associate and the consumer at the point of sale. In Section VII.B of the NPRM, it states that NHTSA ‘believes(s) that the most successful method of encouraging consumers to consider the new ratings at the point of sale is to have a poster in each tire retailer/dealer location that would be visible to consumers.’ However, based on TIA’s experience representing the retailers and given (consumer research), a poster or pamphlet should be an additive feature, not the core vehicle for information dissemination. Unfortunately, Section VIII.B.2, which focuses solely on the point of sale efforts, does not even mention the dialog between salesperson and consumer as a viable means of education.”

A presentation of graphics outlining NHTSA’s plan can be viewed here:
http://www.nhtsa.dot.gov/staticfiles/DOT/NHTSA/Rulemaking/Rules/Associated%20Files/Label_Examples.pdf

NHTSA’s 148-page written proposal in its current form is available here:
http://www.nhtsa.dot.gov/staticfiles/DOT/NHTSA/Rulemaking/Rules/Associated%20Files/Tire_Label_FR.pdf

For more information, visit www.tireindustry.org.