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Monday, June 13, 2016

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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