Tire Safety: Start With the Consumer

TIRE SAFETY: START WITH THE CONSUMER
R. DAVID PITTLE, PH.D.
SENIOR VICE-PRESIDENT, TECHNICAL POLICY
CONSUMERS UNION (1)

18TH ANNUAL TIRE INDUSTRY CONFERENCE
HILTON HEAD, SC
FEBRUARY 27, 2003

Good afternoon. I feel fortunate to have the opportunity to address this audience today. Tire safety and tire design are critically important to consumers, but for too long, people have viewed tires simply as things that, if they weren't flat, they were probably O.K.

We at Consumers Union (CU) certainly don't believe that, and over the last 11 years, we have increasingly devoted more of our resources to evaluating tire performance and advising consumers on the selection and care of their tires. In this presentation I will tell you-based on our testing and research-what we have observed about tires over the last decade, starting with the successes and finish by sharing with you where we think you need to focus more of your energy and talent. Think of this as a Consumer Reports "report card" on the current products you design and manufacture-and an urgent vision of things to come (we hope).

Before I get to our tire tests, I need to tell you a little more about Consumers Union, the publisher of Consumer Reports magazine, Consumer Reports Online, and other information products designed to give consumers fact-based advice on the quality and value of products and services. To help you put our test findings on tires in perspective, I will describe briefly who we are and how we operate.

First the numbers: Consumer Reports magazine is among the top 10 magazines in the country in terms of circulation, with some 4 million copies sold to consumers each month. Our main website, ConsumerReports.org, has more than 1.1 million subscribers, which makes it the nation's largest subscription website. Our headquarters and product test laboratories are located in Yonkers, NY and include some 50 different laboratory spaces dedicated to evaluating major appliances, home entertainment electronics, lawn and garden equipment, computing equipment, foods, household chemicals, power tools, and almost everything else consumers use in and around their homes. For today, however, I want to focus on our auto test facility, which is located in East Haddam, CT.

In mid-1980's, we acquired an abandoned drag strip situated on 327 acres in southeastern Connecticut. It has been fully renovated and designed to help us test a wide range of motor vehicles and tires. Prior to owning our own track, we competed with others to rent time on a Connecticut race track-literally available to us only a few hours at a stretch during any given month. If it rained during our reserved time, we could not test that day-which put great pressure on us to find another open time interval to complete our testing to make the publishing deadline. Having our own track enables us to greatly expand the scope of our information. In addition to some 45 - 50 new cars, pickups, minivans and SUVs, we now evaluate tires on an annual basis. We have, for example, developed a split-mu course to test anti-lock brakes on wet pavement, and we regularly evaluate the hydroplaning resistance of tires on a dedicated road course.

Our roster of 18 engineers, technicians, and support staff are dedicated to testing automotive products in the ways we believe consumers will use them. My point here is to illustrate to you that we will do what it takes to provide consumers with information that is based on objective, technically sound test results using standardized procedures, road surfaces and routes capable of evaluating the complexities inherent in modern automotive products.

While our test facilities have undergone considerable change, our core operating principles have stayed the same. We revisit them from time to time, and invariably they are reaffirmed. For example, independence is the cornerstone of our work. For our ratings to have credibility, we must remain totally independent of the suppliers of the products and services we evaluate and rate.

It is, of course, possible that one could disagree with our findings-and I would venture a safe bet that some of you have disagreed with us in the past-but that disagreement should always center on test method or interpretation of results. There should never be any question regarding even the possibility of bias or favoritism toward a particular manufacturer or brand name. We make every effort we can to eliminate even the slightest chance that bias or favoritism could creep into our work.

We don't, for example, accept any test samples-free or otherwise-from any manufacturer. We buy all our test samples on the open market with cash or credit card, just as a consumer would. Since none of our test samples is ever ordered directly for manufacturers for shipment to our research labs, whenever a product sample shows up in our mailroom, we ship it back immediately, usually unopened. The largest I can remember was a snowthrower.

We don't accept any contributions, grants, or gifts of any kind from any commercial entity, especially ones whose products or services we rate. In short, the work we do-buying and testing cars, tires, TVs, computers, to name a few-is supported solely by the sale of the information to consumers or from contributions from individuals.

And our staff follows very clear guidelines on what is appropriate behavior when on business travel: The default operating principle is that we pay our own way-period. And every year, each staff member files a financial disclosure statement to help assure that no one is working on a project where there could be a conflict of interest.

Finally, as many of you know, Consumer Reports does not take any outside advertising. The same is true for all of our other publications. We consider this principle to be of utmost importance in maintaining the independence we consider essential to our work and essential to the interests of our readers. Consumers need objective, balanced product information, and they can be assured that our ratings are free from any influence by manufacturers whose advertising revenues we might otherwise seek or grow to depend on.

From this group of operating principles, we have evolved a work ethic that focuses on the quality of our testing and not on any particular results. We are organized to do our work in such a way that we literally do not care which product does the best. We are set up so that we have no stake in the outcome of our tests.

A brief word about our test protocols. Much of what we do is taken directly from standard industry tests, but very often we create our own test procedures where we believe they are warranted. Our test procedures have indeed influenced industry standards, and sometimes are themselves adopted as the industry standard. Our primary goal is to evaluate the product in a manner that provides information pertinent to the consumer's purchase decision-and incorporates our view of the consumer's anticipated use-behavior. We start and end with the consumer. We pay careful attention to what we believe the consumer is likely to do, as well as what the manufacturer advises the consumer to do. Sometimes the two are quite different.

In general, comparative testing does not yield the same information gained from compliance and quality control tests. They are two different approaches, serving two distinctly different needs. Testing to meet a standard of performance is a requirement for most of you; testing to determine which product in a group offers the best performance or value to the consumer is a requirement for us. Sometimes the two overlap, but very often they don't.

Let me now move to our test program on tires.

CU may well be the only independent organization that regularly conducts unbiased tests of passenger car and light truck tires in the United States. CU has published numerous test reports during the last 67 years, with yearly test reports on tires since 1992. Over the last decade, including our most recent test program, which appeared in the November 2002 issue of Consumer Reports, the organization has tested 158 different tire models. We have selected a series of tests that focus on performance and safety first and foremost. We do not evaluate tire durability, a difficult characteristic to assess, and one that has dogged the tire and SUV industries relentlessly over the last two years. However, CU has been a vigorous voice supporting tougher tire standards and more intuitive tire labeling such as has been proposed in the TREAD Act. We have been a strong supporter of tire pressure monitoring systems. And CU believes that one of its best paths to increased tire safety is through usable information to consumers on the proper selection and care of tires.

Tire testing at CU is a lengthy process that takes about six months from the time tires are purchased to when the tests are completed. All the tires are bought off the shelf from various retail outlets. Nearly all the testing is done by CU's auto engineers at our Auto Test Facility. Every year, a tire program is developed in a popular category of tires in a widely used size. Early on, CU's marketing research group will request from every major tire company information about tire models that compete in the chosen category. We also ask about the product's life cycle in the market, given the fact it may be eight to nine months before the article is in print. Associate and private brand tires are generally not considered unless they're available nationwide.

HOW WE TEST

CU's tire testing follows a program developed by our auto engineers and utilizes vetting and statistical procedures developed over many years by CU for general product testing. Some of the tests have been drawn from the methods used to evaluate vehicle performance, and others are developed by CU's tire engineers to evaluate specific tire characteristics. CU also uses tests developed by members of the tire industry, as well. Philosophically, the tests and rating system are designed to show differences that could be appreciated in the real world use. As I said earlier, that philosophy may be different from tire makers who may need more specialized tests to distinguish small differences for purposes of developing new products or meeting contract commitments.

CU welcomes manufacturers whose products we test to visit our research facilities to discuss our published reports, and, when appropriate, our auto engineers have visited several test facilities of major tire companies to discuss new testing technologies.

Once tire samples are received, each one is weighed, measured for tread depth, visually inspected for possible defects, and identified as the proper tire model, size, and speed rating sought. Also, the DOT code is noted and, whenever possible, we buy the latest production of tires available.

After this documentation process, the selected test tires are mounted, balanced, and each one is identified by a project code. Before the testing begins, all tires are driven for a break-in period to remove mold release agents, flashing, and vents. Nearly all the testing is done at our own test facility except for rolling resistance which is subcontracted to an independent laboratory. Tests for snow traction and ice braking are performed at our test facility if wintry conditions occur. Otherwise, snow traction is performed at a New England ski resort, and ice braking is done at an indoor ice skating rink.

Tire models within a given group are tested in a random order using the same test car. Internal control tires are often run periodically throughout an evaluation, particularly if the ambient conditions can influence the results. Tests sensitive to temperature, such as braking and cornering, are routinely rerun one or more times to nullify the effect. Tire performance is characterized by an overall score, a compilation of all the tests, with braking, hydroplaning, emergency handling and winter grip weighed most heavily. Higher overall scores are earned by those tire models that are well rounded for all seasons. Listed below is an overview of the tests.

· Dry braking is performed on a smooth asphalt surface from 60 to 0 mph with the ABS set.

· Wet braking is performed on a wetted asphalt surface from 40 to 0 mph, both with and without the ABS set. Because shorter stopping distances can make all the difference in avoiding a collision, we highly recommend ABS brakes since they provide short, controllable stopping distances, especially on wet or slippery surfaces. Since some cars do not have ABS brakes, wet and ice brake tests are run with and without ABS brakes. Dry brake tests are performed only with ABS brakes, since non-ABS braking would quickly flat-spot the tires.

· Ice braking is generally performed in an indoor ice skating rink from 10 to 0 mph, both with and without the ABS set.

Loss of steering and braking control occurs with hydroplaning, and we consider this a significant tire safety issue. Hydroplaning resistance is assessed by incrementally increasing the entry speed through a sheet of water, 10 mm deep, traveling along an arc of 690 feet in radius. Initial hydroplaning is noted when the car veers off the arch and the driver experiences a loss of steering control; i.e., when water can no longer be evacuated from the contact patch. Lateral force is recorded, noting the decay in cornering force as the tires slide wide of the arc. We recognize that all tires will hydroplane at some speed. However, we believe that the better tires resist hydroplaning until higher test speeds are reached.

Our tire reports provide a handling rating, which includes emergency handling, dry and wet cornering, and steering feel. Emergency handling is evaluated using CU's emergency avoidance maneuver, where the course, outlined with cones, requires a swerve to the left, then back to the right, and then left again. The highest successful entry speed and each driver's confidence rating are recorded. Cornering is a measure of how well the tire grips in a turn. Lateral force is measured from a gyroscopic accelerometer while driving around a 200 foot diameter skid pad. Steering feel is a subjective rating based on the driver's trained assessment of steering feedback and directness of the vehicle reaction to steering inputs. Steering feel is rated by a jury of two experienced, trained drivers during the ride comfort session of the test.

A tire's ride comfort is rated by driving over a prescribed road course including secondary-like road and highway surfaces built into CU's Ride Evaluation Course (REC road). General ride and impact harshness are also rated.

Rolling resistance determines how easily the tire rolls, a factor influencing vehicle fuel consumption. SAE J1269 is the procedure followed for determining rolling resistance force.

Our snow traction score indicates how well the tires grip on a moderately packed snow surface, recording the distance required to accelerate from 5 to 20 mph.

There is one constant in all our testing: These tests are upgraded when technologically and economically feasible.

TIRE CARE

In every tire test report, Consumer Reports advises its readers on tire care and how to select the right tire for the vehicle. Each tire report outlines how to decipher the information on the sidewall of the tire, where to find the proper size tire for the vehicle, the correct inflation pressure, and how often to inspect the tires and check the inflation pressure.

Last year we published the results of our one-year study on tire air loss of 108 new tires (36 models, 3 samples). Coming as no surprise to many of you, we found that all tires lose air, but some lose more than others. Our tests found models lost as little as 4 psi over a 12-month period while other models lost nearly 13 psi, a whopping 40 % loss from the initial pressure of 30 psi. Worth noting as well was that samples of the same model showed essentially consistent losses.

CU performed this study to determine the extent that tires lose air, to determine whether some models lose more air than others, and to give fact-based advice to consumers about the need to check inflation pressure regularly. CU also gave NHTSA a summary of the air loss test data for their consideration in the rulemaking for tire pressure monitoring systems.

Indeed, there is little doubt about the need for tire pressure monitors, and more specifically, the direct method. A recent study by NHTSA found that 27% of the cars and 32% of the light trucks surveyed had at least one underinflated tire. It also found that 50% of the 11,500 vehicles surveyed had at least one half-worn tire and 10% of those had at least one bald tire. In our January 2003 issue, we explored how a tire with half its tread depth would perform against new, full tread tires. We found some marked improvement in dry stopping (+3.4%), cornering (+2.4%) and handling (+1.4%), but it was overshadowed by longer wet stops (-6.8%), a greater tendency to hydroplane (-8%) and much less grip in snow (-14.5%).

Our recommendations are that consumers need to pay nearly as much attention to tread loss as they should with air loss. We provided simple tips on monitoring tread depth with a penny or preferably with a tread depth gauge. In some areas of the country where wet and wintry weather is common-place, consumers should consider replacing tires well before the tires are "officially" worn-i.e., to the 2/32 " minimum, at which point they begin to experience a loss of tire grip.

For those who drive in snow and ice, winter tires are highly recommended by Consumer Reports as a good investment for safety and performance-provided that all four wheels are equipped with winter tires, and they are used only during the winter season. In our December 2002 report, we directly compared two front-wheel drive cars with winter tires against models with an all-wheel drive option and OE all-season tires. On snow, the winter tires had a clear advantage over all-season tires, but all-wheel drive had even better grip. More of an eye opener was the brake testing on ice, which showed little difference in stopping performance between all-wheel drive and two-wheel drive vehicles. Obvious almost as a matter of principle, as they both ride on four tires, but illuminating nonetheless. Our advice is that winter tires on a two-wheel drive vehicle should suffice in less snowy areas, whereas an all-wheel drive vehicle makes sense in more snowy regions. And shod with winter tires, an all-wheel drive vehicle would provide added peace of mind.

PRODUCT STANDARDS

It took a monumental recall of one of the most popular tires on one of the most popular SUVs to give national attention to the need for proper tire care and the urgent need for new tire regulations, the first significant change in more than thirty years. CU has been a vocal proponent of the TREAD Act of 2000 (Transportation, Recall, Enhancement, Accountability, and Documentation). This keystone legislation covers an upgrade of the minimum tire performance standards, improved tire labeling, safer child safety seats, dynamic tests for vehicle rollover assessment, and tire pressure monitoring systems to be installed on new vehicles starting in November 2003.

Appraising the first tire-related action under TREAD, CU is deeply disappointed that the government is allowing indirect tire pressure monitoring systems to be used in new vehicles.

We believe our air loss data clearly demonstrated the inherent weakness of indirect pressure monitors to warn of a low-pressure condition, especially since it focuses on a single tire being under-inflated. Our tests showed that four tires of the same brand will likely experience similar air losses, and thus, the indirect's alarm is more difficult to trigger, and hence renders it almost useless. In our view, the best technology available today is the direct pressure monitoring system-it is the only type that measures tire pressure directly and can diagnose and warn of air loss in one, two, three, or four tires. It also has the ability to warn of a low pressure condition far more quickly than indirect systems. It is our hope that in November 2006, the government will reconsider the use of indirect pressure monitoring systems in its final determination of the technologies suitable for tire pressure monitoring. Despite the controversy, CU believes tire pressure monitoring systems are an invaluable tool in reducing catastrophic tire failures.

But the tire industry must be relentless in continuing its promotion of proper tire care to consumers. CU concurs with the Rubber Manufacturers Association's (RMA) effort to have the government develop a reserve load ruling to prevent tires from operating in an overload state caused by the 30% loss in air pressure needed before the indirect tire pressure monitoring systems alerts the driver.

Tire standards have not been significantly updated since 1967 when bias tires were the common design. Today, virtually all passenger car tires and most light truck tires are of radial design. To the industry's credit, tires last far longer and perform better than when the standards were developed, and these standards were conceived at a time when the light truck market was limited mostly to commercial users. CU supports the NHTSA's proposed inclusion of light truck tires and passenger car tires under one standard called FMVSS 139 and believes the more stringent set of performance requirements will provide safer and more robust tires to the consumer. These standards more closely resemble normal driving conditions, but more importantly, challenge the durability of the tires. When in compliance, tires will provide enhanced and safer performance at highway speeds in high temperature climates, especially helpful when encountering road hazards, and even with lower than recommended inflation pressure or higher than recommended vehicle load.

The tire industry seems reluctant to endorse such standards stating that 42% of passenger car tires and as many as 54% of truck tires would fail the new tests. But, the government estimates that only about one-third of the 287 million tires sold in the U.S. might have to be redesigned. And automakers say they may have to redesign some vehicles affected by the new tires to compensate for loss of grip and higher rolling resistance.

CU recognizes that meeting the new standards won't be business as usual, but the technology does exist to improve tire durability. The trend to higher speed rated tires (40% sales growth of H speed rated and higher tires since 1995) in the new car fleet will only improve the success rate in the years to come. CU understands the argument that tire failure rates are quite low and that direct correlation of any proposed test standard to consumer use may be difficult if not impossible. But again, let's start with the consumer. To the individual consumer, the consequences of a sudden tire failure can be tragic. The tire industry must be relentlessly proactive in enhancing tire integrity and promoting safe use of tires to all their customers.

· Tire manufacturer web sites offer meaningful description of tire model features. Many have tire selectors to help provide the appropriate model for your car. Some are sophisticated enough to provide the tire that matches your driving style and performance desire. Some mail order retailers provide information describing tire model features, correct use for your vehicle, and maintenance tips.

· Most tire manufacturer web sites provide tire care tips and some will give email reminders of when to rotate your tires and check your tires inflation pressure. The massive Bridgestone/Firestone Recall has encouraged many owners to do routine checks, and more aggressive campaigns by the tire industry (Be Smart Play Your Part) and the government (Tire Safety Everything Rides On It). · All-season tires provide all-weather performance but fall short in wintry weather. The industry is encouraging the use of effective winter tires for people who often or must drive in snow and icy conditions. The snowflake-on-the-mountain symbol established by the industry helps the consumer to identify a winter tire. · Manufacturers' treadwear warranties provide the most accurate and the most intuitive information of a tire's expected tread-life. CU encourages tire manufacturers to provide treadwear warranties on all tires. See "Where improvement is needed" on UTQG Grades.· The tire industry asserts that the direct system is the most accurate and the most responsive of the two methods and is the only one to identify more than one tire low on air. CU agrees.· It is perceived that tire quality has declined over recent years as viewed by the flurry of recalls in recent years. CU believes recalls are a positive mode of action taken by responsible tire makers to get potentially unsafe tires off the road. Recalls are not a reflection of poor quality, but a pro-active and effective accountability of doing the right thing for the consumer.· Based on US Department of Transportation figures, the cost of car ownership per mile has increased about 3.5 times in the last twenty seven years, while tire cost per mile has increased about 2.5 times. Competitive pressures have limited price increases and promoted longer lasting and better performing tires. Tires last almost twice as long they did in 1973 and about ten times longer than in 1920's. CU's own performance tests show most tires are capable in a variety of weather conditions.

· Many consumers erroneously use the maximum inflation stamped on the tire instead of the correct inflation recommended by the vehicle manufacturer found on a label often-inconspicuous place in the vehicle. The TREAD Act correctly addresses the issue of correct tire pressure by mandating that all labels be of a similar design and placed on driver's door B pillar, and directly spells out the load carrying capacity of the vehicle.

ATTENTION NEEDED:

· Consumer education is still insufficient. The auto and tire industry must aggressively provide proper tire care tips at the point of purchase. NHTSA's "Tire Safety Everything Rides On It" pamphlet is an excellent resource that spells out pertinent tire terminology and fundamental tire characteristics, and has a practical safety checklist. Consumers need additional information on how matching size, speed rating, type is important and the consequences if they change.

· Tire companies should take the offensive in promoting tire care, particularly in maintaining proper inflation pressure. Give out inflation gauges with the purchase of tires. Promote or provide service stations with working air pumps and make them accessible at the fuel pumps. A government survey shows about 14% of the gas stations in the US are not equipped with air pumps or have malfunctioning pumps, and fewer than half provide a tire pressure gauge, many of which are inaccurate.

· Tread-depth bars in tire are not enough. Many consumers do not know they exist and CU's own test shows that tire performance wanes well before the 'legal wear-out' limit. Give out tread-depth gauges with the purchase of tires, or at least promote the purchase of these gauges and educate consumers on the performance changes associated with tire wear.

· Promote more intuitive information on the tire sidewall. There are too many obscure codes and inconsequential or redundant forms of information. Do we really need M&S, 4 ply rating, and why is H a higher speed rating than some alphabetically higher ratings? Clean up the sidewall and make it intuitive to consumers, dealers, and retailers alike. Spell out the information rather than hiding it behind symbols or tiny lettering i.e.: Speed Capacity: mph, Inflation Pressure: Consult vehicle placard, Production Code: Plant/Date. Add tire type as another source for ensuring correct replacement.

· Too many tire types and too many sizes. Consumers are confused on what type of tire they have and the variety of types offered in the market place. Few dealers and retailers can accommodate all the sizes, and, based on letters from our readers, sometimes offer incorrect replacement tires they happen to have in stock. Consumers are left with few choices or none at all when they need tires, and the trend is getting worse.

· Historically, tire failure rates are low on a percentage basis, but failures can be catastrophic. The government's proposed tire test standard would raise the performance bar that is needed to provide an added safety margin. The industry should support or propose meaningful tests that raise the performance bar. Not doing so hurts the consumer and impacts on the liability of the tire makers.

· Some tires will not pass the proposed government test standards, particularly the high speed test where most of the affected tires are lower than H speed rating. Recognizing that the trend is to H and higher speed rated tires on new cars, consider utilizing design features used in these to meet the need for tires that suit the rigors of present day driving.

· Despite government efforts to provide meaningful treadwear comparison among tires through the Uniform Tire Quality Grading System (UTQGS), the grades are unintuitive and provide more confusion than help. Self-certification makes it impossible to compare models from different manufacturers. Codes are not directly translatable to actual mileage. Temperature grades would be best if substituted with a "Speed Capacity" in mph as dictated by performance in high-speed tests. Proposed standards would also potentially eliminate grade "C" tires. Traction grades are the most informative of the three and is information that is not available anywhere else on the tire.

· Too often, tire and auto marketing tends to overshadow consumer needs for potential profit, and too readily give-in to "fads," e.g., plus sizing. Customers are not made aware of the pitfalls associated with performance oriented, lower aspect ratio, higher speed-rated tires. "Sport" and "high performance" packages are marketed readily without customers being made aware of the potential disadvantages, such as higher replacement cost, possible wheel damage, wear or winter performance and are often highly dissatisfied or "surprised" when one or more occurs.

· And finally, we all know tires lose air over time. But if some manufacturers achieve 4 psi loss over a year, why do we see some models at 13 psi loss over a year? You must do better. This must improve.

In conclusion, let me emphasize that in the automotive area, tires have been a success story overall. Today's tires are, in general, far better that those made only a few years ago, and yet prices have remained relatively low. But this is still a story without an ending. Despite the strides tire and auto manufacturers have made, even better, safer tires that are easier to shop for and maintain are within our grasp right now. We urge those of you who make these critical components and those who regulate the safety of these products to be fiercely proactive in delivering the best tires, the most transparent labeling and nomenclature, and the safest air-pressure monitoring systems now-rather than waiting to react to the next tire tragedy.

Thank you for your attention.

______

(1) Consumers Union is a nonprofit membership organization chartered in 1936 under the laws of the state of New York to provide consumers with information, education and counsel about good, services, health and personal finance, and to initiate and cooperate with individual and group efforts to maintain and enhance the quality of life for consumers. Consumers Union's income is solely derived from the sale of Consumer Reports, its other publications and from noncommercial contributions, grants and fees. In addition to reports on Consumers Union's own product testing, Consumer Reports, with more than 4 million paid circulation, regularly carries articles on health, product safety, marketplace economics and legislative, judicial and regulatory actions which affect consumer welfare. Consumers Union's publications carry no advertising and receive no commercial support.