CSA and underinflation

Aug. 11, 2014
Industry and government work together to find a reasonable solution

Without a doubt, the Compliance, Safety, Accountability (CSA) program has changed the way commercial vehicles are operated by drivers, maintained by fleets, and inspected by vehicle enforcement officials.  And with government data that supports the positive impact it is having on reducing accidents and identifying carriers in need of intervention, the trucking industry can be certain it is here to stay.

One of the advantages that the Federal Motor Carrier Safety Administration (FMCSA) repeatedly communicates is the ability for CSA to adapt to change.  It’s already happened in a number of areas, so hopefully the trend will continue, especially when it comes to the subject of underinflated tires.

According to 49 CFR 393.75(h), “No motor vehicle shall be operated on a tire which has a cold inflation pressure less than specified for the load being carried.”  To the outside observer, this makes perfect sense.  A tire that is incapable of supporting the load is prone to over-deflection in the sidewalls, which leads to excessive heat that ultimately results in a separation.  FMCSA has even attempted to account for the inflation pressure increase that is the result of heat from normal operation.  On paper, it appears to be a perfect solution.

But in reality, things that look good on paper sometimes do not translate into anything beneficial.  For the past year or so, a group of tire manufacturers and other industry experts within the Technology & Maintenance Council (TMC) have been searching for a real-world solution for the Commercial Vehicle Safety Alliance (CVSA).  Since underinflation is currently a three-point violation under CSA, it’s causing significant heartburn for fleets because there is no reasonable definition or reliable formula for determining if a tire has insufficient inflation pressure.

As someone who has invested hours of time on this discussion, I can assure you that the solution is far from simple.  The factors that determine if a tire can carry the load are so numerous that it is completely unreasonable to expect vehicle enforcement officials to make an on-the-spot regulatory determination during a CVSA roadside inspection.  In fact, without a portable scale, calibrated air gauge, and load/inflation table, it simply cannot be done.

So, the TMC group worked with CVSA to explain the issue, and both organizations came to the same realization: 49 CFR 393.75(h) should be repealed.  The existing definition of a flat tire being 50% of the maximum inflation pressure molded on the sidewall makes perfect sense and should remain unchanged.  Even with all of the variables, everyone agreed that there must be a threshold where a tire is considered flat during a roadside inspection.

It’s a perfect example of the industry working with the government to develop a solution.  CVSA is primarily interested in getting it right and after the issue was thoroughly explained, it agreed that enforcement officials cannot be expected to make the necessary calculations during a roadside inspection.

Now it’s in the hands of FMCSA.  Three of the stakeholders have weighed in that the only solution to the problem is to repeal 393.75(h).  I want to believe that everyone is motivated by the same principle that highway safety is the main priority, so I remain optimistic that FMCSA will agree that, in this particular situation, the responsible approach is to listen to the industry experts and the law enforcement community.

Kevin Rohlwing can be reached at [email protected]

About the Author

Kevin Rohlwing

Kevin Rohlwing is the SVP of training for the Tire Industry Association. He has more than 40 years of experience in the tire industry and has created programs to help train more than 180,000 technicians.

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