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Old 02-11-2019, 02:30 PM   #1
CWtheMan
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Tire identification and recordkeeping

Normally I spend, on average, about three hours a day researching my hobby, tires. When regulations and standards are updated I replace the older ones in my data base with the newest ones. Today it’s tire identification. The new CFR is dated 1/4/19 and is included below.

Throughout all the forums I follow, there is always someone posting how they talked their dealer into replacing the tires on their new – from the factory – RV trailer?

I’m going to first quote from FMVSS. It has very stern and specific directions to the trailer manufacturer and the dealer, that says in part that the tires on the trailer at the time of first sale MUST be the same designated size as those described on the trailer’s certification label. There is wiggle room there but not much. A designated size (ST225/75R15) does not include a load range. If there is not a load range described on the vehicle certification label, then the recommended inflation pressure provides the minimum load capacity the OE tires must provide. So, a LRD could be replaced with a LRE and comply with the certification label. Tire size designation is not tire brand sensitive.

Tire size options approved by the vehicle manufacturer would not present a dealer with a problem because the trailer manufacturer would be receptive to changing the certification label for an option they approved in advance. However, they would be required to insure the optional tires serial numbers are sent in for record keeping.

That leads me into tire identification. Here I’m going to quote verbatim from the reference. “Each motor vehicle manufacturer, or his designee, shall maintain a record of the new tires on or in each vehicle shipped by him or a motor vehicle distributor or dealer, and shall maintain a record of the name and address of the first purchaser for purposes other than resale of each vehicle equipped with such tires. These records shall be maintained for a period of not less than 5 years from the date of sale of the vehicle to the first purchaser for purposes other than resale.” Those records contain the tires serial numbers. Now, those rules may not be binding on the purchaser but they surely are for the manufacturer and his dealers.

https://www.ecfr.gov/cgi-bin/text-id...#se49.7.574_19
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Old 02-11-2019, 04:01 PM   #2
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Good information, thanks.
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Old 02-14-2019, 07:34 PM   #3
Tireman9
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FMVSS is not doing RV owners any favors by retaining the 0% Reserve Load Capacity while RVIA is over a year ahead by upgrading their standards and requiring at least a 10% margin.
Yes FMVSS is law but in this case the RV industry, through their own standards have done the right thing. The RVIA +10% is better and makes things safer and more reliable for RV owners. I guess you can decide if you are willing to risk having a tire failure because you went with no extra margin.
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Old 02-15-2019, 07:22 AM   #4
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Quote:
Originally Posted by Tireman9 View Post
FMVSS is not doing RV owners any favors by retaining the 0% Reserve Load Capacity while RVIA is over a year ahead by upgrading their standards and requiring at least a 10% margin.
Yes FMVSS is law but in this case the RV industry, through their own standards have done the right thing. The RVIA +10% is better and makes things safer and more reliable for RV owners. I guess you can decide if you are willing to risk having a tire failure because you went with no extra margin.

Where did this come from? What's it got to do with tire identification?


The FMVSS are written to insure minimum safety standards are complied with by the vehicle manufacturers. RVIA may be a tire rules committee member but it has no authority. It's recommendations to its members is with an "or else clause". However, the end results will be; all OEM trailer tires will now have a minimum of 10% in load capacities above GAWR. So despite the FMVSS rule the vehicle manufacturer will be fitting OE tires they deem APPROPRIATE. By doing so they establish the minimum standard for that application. The tire industry standard says to use replacement tires with load capacities equal to or greater than what's on the certification label. Thus, a minimum 10% load capacity reserve for RV trailer tires will be established.


This is the minimum standard from FMVSS; Tires. The size designation (not necessarily for the tires on the vehicle - meaning brand) and the recommended cold inflation pressure for those tires such that the sum of the load ratings of the tires on each axle is appropriate for the GAWR.
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Old 02-15-2019, 07:57 AM   #5
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Originally Posted by CWtheMan View Post
Now, those rules may not be binding on the purchaser but they surely are for the manufacturer and his dealers.
Have there been issues with manufacturers shipping product with tires that don't match the certification label or dealers swapping out different tires before the initial sale? I could see how that would cause problems with recall notices or safety issues if somebody didn't catch it. Seems like that wouldn't happen too often but I really don't know.

Also, do the manufacturers really keep the individual tire serial numbers on file? They don't go into detail about that part in 574.10. Must be part of the "entire tire identification number" that they talk about? I suppose that might be important if there was a recall on a specific range of serial numbers. Does that mean that if a tire was damaged in shipment, or the dealer blew a tire on the lot, they have to report it to the manufacturer so they can update the records? That must be part of the final sale paperwork.

Always interesting stuff.
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Old 02-15-2019, 12:26 PM   #6
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Originally Posted by rjrelander View Post
Have there been issues with manufacturers shipping product with tires that don't match the certification label or dealers swapping out different tires before the initial sale? I could see how that would cause problems with recall notices or safety issues if somebody didn't catch it. Seems like that wouldn't happen too often but I really don't know.

Also, do the manufacturers really keep the individual tire serial numbers on file? They don't go into detail about that part in 574.10. Must be part of the "entire tire identification number" that they talk about? I suppose that might be important if there was a recall on a specific range of serial numbers. Does that mean that if a tire was damaged in shipment, or the dealer blew a tire on the lot, they have to report it to the manufacturer so they can update the records? That must be part of the final sale paperwork.

Always interesting stuff.
§574.10 Requirements for motor vehicle manufacturers.

Each motor vehicle manufacturer, or his designee, shall maintain a record of the new tires on or in each vehicle shipped by him or a motor vehicle distributor or dealer, and shall maintain a record of the name and address of the first purchaser for purposes other than resale of each vehicle equipped with such tires. These records shall be maintained for a period of not less than 5 years from the date of sale of the vehicle to the first purchaser for purposes other than resale.
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Old 02-15-2019, 01:04 PM   #7
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Originally Posted by CWtheMan View Post
shall maintain a record of the new tires on or in each vehicle shipped by him or a motor vehicle distributor or dealer
That's the part that wasn't clear to me as to how "a record" is defined. Elsewhere they refer to the "entire tire identification number" but as a non-tire expert, I don't know what that means either. If it's a serial number then it's down to the individual tire. If the main purpose is for size validation and recall notices, I would assume that model number and lot number would be sufficient. To be honest, I didn't even know that tires had individual serial numbers. Learn more here by accident than elsewhere by design. :-)

EDIT: I did some additional searches and it looks like "serial number" and "DOT number" are used interchangeably. If that's the case, then it's not what I had in my head as being the definition of serial number. I guess the DOT numbers just identify tires as a group down to the week of manufacture (lot number) as opposed to uniquely identifying individual tires. That seems a little easier to manage and makes more sense from a recall notice point of view. Eventually I'll get all this tire vocabulary figured out. :-)
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Old 02-15-2019, 02:00 PM   #8
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Originally Posted by CWtheMan View Post
Where did this come from? What's it got to do with tire identification?


The FMVSS are written to insure minimum safety standards are complied with by the vehicle manufacturers. RVIA may be a tire rules committee member but it has no authority. It's recommendations to its members is with an "or else clause". However, the end results will be; all OEM trailer tires will now have a minimum of 10% in load capacities above GAWR. So despite the FMVSS rule the vehicle manufacturer will be fitting OE tires they deem APPROPRIATE. By doing so they establish the minimum standard for that application. The tire industry standard says to use replacement tires with load capacities equal to or greater than what's on the certification label. Thus, a minimum 10% load capacity reserve for RV trailer tires will be established.


This is the minimum standard from FMVSS; Tires. The size designation (not necessarily for the tires on the vehicle - meaning brand) and the recommended cold inflation pressure for those tires such that the sum of the load ratings of the tires on each axle is appropriate for the GAWR.


I jumped too soon. My bad.


I have written about tire registration and of my concerns that RV dealers may not be followint the tire registration process. Maybe you can help the folks out by providing the info on where they can sent the TIN to ensure their tires (new and any replacement tires) are registered with the tire company.
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Old 02-16-2019, 01:06 PM   #9
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Here is a reference.

https://www.cimstireregistration.com...mers/index.cfm
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