Comments of the Rubber Manufacturers Association On
Comments of the Rubber Manufacturers Association on Advance Notice of Proposed Rulemaking on Tire Sidewall Labeling Requirements National Highway Traffic Safety Administration U. S. Department of Transportation Docket No. NHTSA-00-6296-// 30 January, 2001 Staff Contact Steven Butcher, Vice President Technical and Standards Rubber Manufacturers Association 1400 K Street, N.W. Washington, D.C. 20005 I. Introduction The Rubber Manufacturers Association (“RMA”) is a national trade association representing the domestic tire and rubber products manufacturing industry. RMA’s tire industry members include every major U.S. tire manufacturer: Bridgestone/Firestone, Inc., Continental Tire North America Inc., Cooper Tire & Rubber Company, Goodyear Tire & Rubber Company, Michelin North America, Pirelli Tire North America, and Yokohama Tire Corporation. There are over 1 billion tires in use on our nation’s highways and these manufacturers produce approximately 90 percent of them. They operate 40 manufacturing facilities and employ almost 160,000 people in . this country. Tire design and production involves sophisticated engineering in product design, testing, manufacturing, and analysis. Designing and building today’s complex tires is no simple task. Producing a tire involves a combination of chemistry, physics, and engineering plus more than 200 raw materials including natural and synthetic rubbers, metals, fabrics, oils, pigments, and other chemicals. RMA is pleased to provide NHTSA with these comments regarding Docket No. NHTSA-OO- 8296, which, among other issues, specifically addressesthe information that tire manufacturers should be required to place on tire sidewall& Our comments addresstire labeling issues for passengercar tires and light truck tires (through load range E, or load index 124), plus motorcycle tires and recreational, boat, baggage, and special trailer tires.
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