Interpretation ID: nht74-3.28

DATE: 09/24/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: B.F. Goodrich Tire Company

TITLE: FMVSR INTERPRETATION

TEXT: This is to respond to the draft defect notification letter submitted by B. F. Goodrich at a meeting with NHTSA personnel on September 4, 1974. While we provided you with some preliminary comments at that time, our position regarding your notification is as stated in this letter.

We believe your letter fails to comply with 49 CFR, Part 577, "Defect Notification" in several respects. Some of our comments are also directed at what we view as a lack of clarity in your letter arising, it seems to us, from some disorganization in the text.

The first sentence in your second paragraph does not follow satisfactorily the requirements of @ 577.4(b)(1). This requirement should be met by simply stating, "The B. F. Goodrich Tire Company has determined that a defect which relates to motor vehicle safety exists in its Space Saver Spare tire."

Section 577.4(c) requires the notification to describe the defect by including specified information. We believe your letter confuses the items of information and presents them in an order which clouds an understanding of the safety problem. As we understand your presentation of the facts, the item of motor vehicle equipment affected (@ 577.4(c)(1)) is the tire; the malfunction that may occur (@ 577.4(c)(2)) is an explosion of the tire; and the operating or other conditions that may cause the malfunction to occur (@ 577.4(c)(3)) are damaged beads, excessive air pressure, and beads not seated properly on the rim. With respect to this letter requirement, we find the reference to the "combination" of factors in your second paragraph, and your fourth paragraph, in which you state that "some or all" of the causal conditions listed can produce the defect, to be inconsistent and too imprecise to conform to the requirement. In addition to describing factors which can singly cause an explosion, if certain combinations of factors must exist in order for the defect to occur these combinations should not be stated generally as you have done, but should be specifically described. Moreover, we indicated to you at the September 4 meeting that we disagree that broken beads and excessive pressure must exist in combination in order for an explosion to occur.

Most importantly, we cannot agree upon your characterization of the bolting of the tire to the wheel before inflation as a precaution the owner can take to reduce the chance that the malfunction will occur under @ 577.4(c)(4). Both literally and by implication your second and fourth paragraphs read that if the tire is bolted to the vehicle before inflation, an explosion will not occur. The malfunction, however, is an explosion of the tire, not only those explosions which cause injury. While we agree that bolting the tire to the vehicle before inflation can potentially reduce the chance of injury, it should be characterized only in this fashion. Therefore, both on page 1 of your letter and in the instructions which you begin on page 3 for persons who have need of the tire before its inspection by Goodrich, you must make it absolutely clear that bolting the tire to the vehicle has no effect whatever on whether the tire will explode, but that bolting will serve only to reduce the chance of injury if an explosion occurs.

We have the following points with respect to the remaining provisions of your letter. On page 2, in the first complete paragraph, beginning "In the majority of usage situations . . . etc" we find the use of the word "majority" confusing. The implication to us is that in a minority of situations the danger is not reduced at all. This should be clarified.

The third complete paragraph on page 2 is also confusing. There is no apparent connection between its first and second sentences. If you are attempting to say that despite what earlier labels may say that the instructions provided in this letter should be followed, then this can be stated more clearly.

The use of the word "solely" in the fourth paragraph on page 2 is a disclaimer, prohibited by section 577.6, and should be stricken.

On page 3, we believe the requirements of section 577.4(e)(1) call for more detail than you have provided in the third paragraph on page 3. We suggest you include a description of the inspection and test cycle. As we indicated to you on September 4, the second and third paragraphs could be combined for clarity. Finally, the second sentence in your second paragraph on page 3 should be reworded to indicate more clearly that the date you have inserted is the date by which repair facilities will have necessary parts and instructions. In its present wording the meaning of the sentence is unclear.

Apart from these deficiencies, we believe your letter conforms to 49 CFR Part 577. At the same time, we believe your letter unnecessarily obscures the safety problem, and hope that, apart from literal compliance with Part 577, this is eliminated in the letter sent to purchasers. You should note that our determination of the conformity of the letter to Part 577 does not in any way indicate our agreement with Goodrich's analysis of the safety defect. We will continue to look into this matter, as appropriate, in order to determine whether Goodrich's analysis of the defect, and its consequent remedy, are fair and accurate statements of the safety problem. You should be aware that if subsequent events do show that attributing the safety defect to a mounting problem does not adequately describe the defect, further notification may be required.

Yours Truly,

PROPOSED DRAFT

9/4/74

DEAR CUSTOMER:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

The B.F. Goodrich Tire Company, a division of The B.F. Goodrich Company, has determined that a defect which relates to motor vehicle safety is caused when its Space Saver Spare tire is improperly mounted or subsequently remounted on the rim and is not properly seated on the rim. When the wheel is not securely bolted to the axle at the time the tire is inflated, the combination of broken tire beads and excessive air pressure can cause the tire to burst or erupt in which case serious personal injury or death can result.

Since the introduction of the Space Saver Spare in 1967, approximately 1,000,000 tires have been produced and provided to automobile manufacturers. During this period a total of nineteen injury cases, including two fatalities, have been reported.

Bursting or eruption of the Space Saver Spare tire assembly which has the potential of causing injury can only occur when some or all following three conditions are present:

1) A broken tire bead caused by improper mounting or remounting of the tire exists.

2) The tire is not securely bolted to the axle of the vehicle before inflation is started.

3) Excessive air pressure, from a high pressure air supply is forced into the tire.

In the majority of usage situations when the caution and warning labels are followed in a step by step fashion, the danger or potential of injury or serious accidents is greatly reduced. It is extremely important that at all times the Space Saver Spare tire is inflated with the approved canister (inflator) provided for road use of the tire.

Your Space Saver Spare tire was designed to be carried in a deflated condition, while being stored in the trunk of your vehicle. Its unique folding sidewall configuration permits the saving of considerable space in your trunk.

Many Space Saver Spare tires have been furnished with caution and/or warning labels. When the spare tire assembly is securely bolted to the axle of your vehicle before inflating with the canister bottle, and the tire is only inflated with the canister inflator, maximum safety will be achieved.

The above statements are made solely to comply with the notice procedures of the National Highway Traffic Safety Administration, 49 CFR, Part 577.4, and does not constitute an admission of liability or wrong doing on the part of the B.F. Goodrich Company, but is made to the public at large for the general purpose of improving highway safety.

Our review of the use of the Space Saver Spare has proven that unless specific instructions for installing and inflating the tire are followed, it could burst or erupt.

The B.F.Goodrich Tire Company is presently completing arrangements for conducting an inspection and inflate/deflate test cycle of your Space Saver Spare. Final details along with distribution of anticipated replacement components will be completed by

Date

Enclosed with this letter you will find a listing of all B.F.Goodrich Regional Service Departments. You are urged to contact the Service Department located most conveniently to your area, by collect phone call, and make arrangements to take your Space Saver Spare tire assembly to a designated service facility for inspection and test cycling. Inspection, test cycling and any necessary tire replacement will be provided at no charge to you. Since inspection and test cycling can take approximately one hour, we urge you to call the phone number listed above in order to make an appointment thereby avoiding long delays on your part.

If, prior to the time the inspection and test cycle have been completed you have need of your Space Saver Spare tire, it is important that follow these procedures:

1) Before inflating, bolt spare on car axle making sure that all lugs are securely fastened.

2) Rotate spare tire/wheel assembly so that the valve is down

3) Use only the canister inflator to inflate the tire. Inflate by holding canister bottle on tire valve approximately one minute after sound of gas flow stops.

4) This tire is designed for emergency use only. Return it to the spare tire position in the trunk of your vehicle as soon as possible.

5) When the Space Saver Spare is in use, do not exceed 50 MPH.

6) Do not remove Space Saver Spare tire from the wheel. Tire is not remountable. Do not use wheel cover on Space Saver Spare wheel as it may not be retained.

NOTE: If the canister inflator has been used, a replacement canister should be obtained.

Present this letter and enclosed form "Authorization for Space Saver Spare Inspection - Test Cycle" as authority for no charge inspection, test cycle and replacement of any malfunctioning compon

This is an important safety matter to you. We urge that you take action as described in this letter.

(Signed)