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diana. Pa. I ask that his statement be printed in its entirety in the record.

Senator HARTKE. It will be a part of the record. I understand that he is here and has requested that he be heard.

STATEMENT OF HARRY C. MCCREARY, JR., CHAIRMAN, MCCREARY TIRE & RUBBER Co., INDIANA, PA., RELATIVE TO THE NEED FOR UNIFORM STANDARD FOR PASSENGER CAR TIRES

The Rubber Manufacturers Association recently published its recommended minimum standards for new passenger car tires. Our company feels that these standards are fine, as far as they go. Their weaknesses are: (1) They are strictly voluntary as far as any compliance therewith is concerned; and (2) they do not incorporate any provisions for regulating maximum tire loadings. We feel that the interests of highway safety would be considerably advanced if the Federal Trade Commission were to adopt and make mandatory: (1) The Rubber Manufacturers Association's minimum standards, and (2) the Tire & Rim Association's load and information tables for passenger car tires, which provide for maximum tire loading weights.

For years, the tire industry has tried to establish maximum tire carryingcapacity weights through the Tire & Rim Association, Inc. These efforts have been largely ignored by Detroit's engineers, who insist upon equipping their new cars with tires which are designed to carry the empty weight of the vehicle, plus "22" passengers.

One of the quickest ways to ruin a perfectly good tire is to pile onto it more load than it was designed to carry, and then start it rolling down the road. For example, a 7.50 by 14 four-ply-rating passenger car tire carries a maximum tire and rim loading of 1,090 pounds, at 24 pounds inflation pressure. Most tire manufacturers design a safety factor into their tires which will permit them to carry greater loads without failing. Most 7.50 by 14's will carry a 20-percent overload with safety, provided the inflation pressure is kept up to 24 pounds minimum. However, let this overload rise to 50 percent and let the inflation pressure on any one tire drop off to around 20 pounds or so, and the occupants of this particular car are in a very dangerous spot. The worst part of it is that they quite probably don't realize just how dangerous the situation is.

The average new car buyer can probably be pardoned for assuming (wrongly, in some cases) that he can fill up his vehicle with people and baggage, and then drive off-safely. If he had just bought a six-passenger station wagon, he might be surprised to learn that if he put six 170-pound men in it, each of whom has placed his 30-pound suitcase in the back of the vehicle, the tires might be overloaded by as much as 20 percent. If any one tire on this vehicle was underinflated by as little as 4 pounds, a 3-hour turnpike trip, at 65 miles per hour would be a rather dangerous one.

At present, the average car driver is completely uninformed with regard to (1) the maximum rated load for his particular tire size, and/or (2) the empty weight of his car. These two rather important figures are not furnished to him by the vehicle manufacturers.

Our company feels that every new car should have in it a placard, easily visible from the driver's seat, showing the net number of pounds of people and/or baggage that can be put into the vehicle before any tire on said vehicle becomes loaded to the tire and rim maximum.

Then if the driver insisted on piling in more people and/or baggage, he would at least have some "ball park figure" which would indicate the degree of overloading. He would at least know that he was skirting the danger area. As things stand now, the average driver simply doesn't give any thought to the matter, because no one has ever told him that he was placing himself, his passengers, and every oncoming driver in a potentially dangerous situation. We think it's time somebody gave him some facts.

And speaking of facts, let me speak out in defense of the tire manufacturers. It's a fact of life that in 1964, the automobile manufacturers bought approximately 35 million new passenger car tires. This made them very important customers in Akron. When Detroit snaps its fingers, Akron jumps through the hoop-backward, if necessary.

This fact of life explains why the decision as to what kind of tire shall be put on new automobiles is, and has been for years, made in Detroit. not Akron.

If you are a tire manufacturer, you are not apt to argue very loudly with your biggest customer. You give him what he demands, not what you feel he should have. If you don't like it, he can always get his tires from your competitor, right across the street. So, you give him what he demands. Unfortunately, the car manufacturer is not willing to put his warranty on the tires. This means that you, Mr. Tire Manufacturer, are going to put your warranty on them—and pray that what the Detroit engineers said was good enough will really do the job.

Naturally, Mr. Tire Manufacturer, this gives you some incentive to fight mildly for putting a better tire on all those new cars. But if you put up too hard a battle, your car manufacturer might just take his business across the street. So, you try to get him to put on a better tire. But when it comes right down to the wire, the decision as to what kind of a tire will go on those new cars is made in Detroit.

This decision, incidentally, will determine just how much (if any) of a safety cushion the new car buyer will have, as far as his tires are concerned.

And now, I guess I should speak out in defense of the car manufacturers. Detroit is probably the only place in the world where a 10-cent saving per tire looks like $32 million. Ten cents per tire, times five tires per car, equals 50 cents per car. Fifty cents per car, times 7 million cars, equals $3,500,000.

Personally, I can't blame the car manufacturers for trying to save money on their tire purchases. They operate in a very bitterly competitive business, indeed. If Ford can save 10 cents per tire, as compared with what Chevrolet is paying, that 10 cents can become a million dollars in a year's time.

So, let's not "blame" the car manufacturers for trying to stay competitive. Instead, let's use the Rubber Manufacturers Association's minimum standards and the Tire & Rim Association's load and inflation tables as mandatory figures. Doing this would make it unlawful for any tire manufacturer to sell a tire which wasn't strong enough to carry its rated load. It would also make it unlawful for any car manufacturer to install, as original equipment, a tire which was simply not big enough to carry the load imposed on it when: (1) all the vehicle's seats were occupied by 170-pound people, and (2) there were 200 pounds of baggage in the trunk.

Let's also require the car manufacturers to install permanently a placard in every new car, easily visible from the driver's seat, which gives the net number of pounds of people and/or baggage which can be put into the vehicle before any tire on said vehicle becomes loaded to tire and rim maximums.

These don't sound very earth shaking; but in my opinion, they would represent a major step forward in protecting American drivers from being sold tires (whether as original equipment or as replacements) which are neither strong enough nor big enough to do the job.

Senator NELSON. I ask to have printed a letter dated October 27 from the General Counsel of the Department of Commerce in the record. And I ask that a letter dated January 4, 1965, signed by Mrs. Esther Peterson, special assistant to the President for consumer affairs, also be put in the record.

Senator HARTKE. All of these will be a part of the record.

GENERAL COUNSEL OF THE DEPARTMENT OF COMMERCE,

Hon. GAYLORD NELSON,
U.S. Senate, Washington, D.C.

Washington, D.C., December 22, 1964.

DEAR SENATOR NELSON: Secretary Hodges has asked me to furnish you with the Department's report regarding the effectiveness of the recommended minimum standards for new passenger tires published by the Rubber Manufacturers Association, Inc.

We requested the National Bureau of Standards to make a technical evaluation of those standards. The Bureau responded as follows: "We are not able to comment fully on the Rubber Manufacturers Association's recommended minimum standards for new passenger car tires since we have no experience with the high-speed performance test and limited experience with the tire strength test using a plunger three-fourths inch in diameter. Further, the tire endurance test is not equivalent to the one described in Federal specification ZZ-T-0038ij, since cuts are not placed in the tread grooves and the hours of test are less.

"The minimum cross sections listed in appendix A differ from the corresponding tire sizes by amounts ranging from 0.10 inch for the 8.90 by 15 tire to 1 inch

for the 9.00 by 15 tire and 0.95 inch for the 9.50 by 14 tire. This minimum dimension should be a fixed percentage of the tire size (e.g., 97 percent).

"The breaking energies listed in the last column of appendix A range from 1,000 to 1,300 inch-pounds for the four-ply-rating tires, whereas the load ratings range from 730 to 1,470 pounds. The minimum breaking energies should be proportional to the load ratings and, judging by our limited experience, should be considerably higher. Tire strengths determined on new tires do not indicate potential rapid deterioration in service. We recommend that the tire strength test be made after the endurance test, since some tires markedly decrease in strength with this flexing, whereas most tires show little or no change in strength.

"The Federal specification has a requirement for cut-growth that is not included in the Rubber Manufacturers Association specification. Small cuts are placed in the tread grooves prior to the endurance test. These cuts increase in length during the test, and in some unsatisfactory tires may result in loss of tread. An unsatisfactory tire may pass the endurance test if no cuts are placed in the grooves. In service, sharp stones, glass, and other objects on the highways cause small cuts in the tire tread. If these cuts increase rapidly in length, early failure of the tire results."

It should be recognized that the foregoing comments are based on limited information. An extensive program of testing and evaluating would be needed to produce complete and reliable data on the numerous types and quality levels of tires now available to the public. This would be a costly program. Preliminary estimates indicate that it might cost in excess of $150,000 to obtain the data required for sound technical recommendations.

The industry expects to spend more than $300,000 in implementing the new standards. We also understand that the participants are underwriting these standards by warranties that their products conform thereto.

The standards developed by the tire industry represent a type of self-regulation or self-discipline that has been 60 years in the making. These standards represent a substantial degree of progress. It should be recognized, however, that no standard can provide perfect performance. Protection against such factors as over- and under-inflation, excessive wear, poor alinement, bad driving practices and the like cannot be obtained through standardization.

Industry evaluation of the effectiveness of the new standards in actual practice is desirable. With appropriate consulation with the National Bureau of Standards, we think industry will be in a good position to make further progress in its tire standardization program.

Sincerely yours,

ROBERT E. GILES.

Hon. GAYLORD NELSON,
U.S. Senate,

Washington, D.C.

EXECUTIVE OFFICE OF THE PRESIDENT, PRESIDENT'S COMMITTEE ON CONSUMER INTERESTS, Washington, D.C., January 4, 1965.

DEAR SENATOR NELSON: Thank you for your letter requesting information on tire safety. I was very pleased to learn of your interest in this field.

The continuing number of traffic fatalities proves the need for further investigation of tires and some positive action to protect the consumer from any shoddy tire construction and deceptive tire advertising. Perhaps, Federal safety standards such as you proposed in your bill would be the answer.

Another solution to the problem might come from the Federal Trade Commission hearings to be held on January 13 and 14. The fact that such hearings are to be held is further recognition that a problem does exist, and I shall be very interested to learn of the Commission's proposals.

My own experience with tire safety has been limited. I cannot offer you any technical information, but, from the consumer's standpoint, I can tell you that my office receives a great many complaints about faulty tires and misleading advertising. The public wants and has a right to know that what they are buying is safe.

I want to emphasize my pleasure at the national recognition that this problem is receiving and assure you that I will do whatever I can to help in finding a solution.

Sincerely,

Mrs. ESTHER PETERSON,

Special Assistant to the President for Consumers Affairs.

Senator NELSON. Mr. Chairman, this is all I have for submission into the record. I think it is perfectly clear that some legislation is necessary to protect the safety of the driving public, and that though this particular piece of legislation may not be the perfect answer, though testimony may indicate that it needs some revisions, I think it is perfectly clear that we will not achieve a standard that will protect the driving public on the highway without some regulatory action. Senator HARTKE. Senator Nelson, You are to be congratulated for bringing some rather startling news and information to the unsuspecting public. I want to congratulate you for your statement. Senator NELSON. Thank you.

Senator HARTKE. Senator Prouty has asked me to inform the committee and inform you that he had to attend a Labor and Public Welfare executive meeting. He will return as soon as possible. I have no further questions.

Senator NELSON. Thank you.

Senator HARTKE. The next witness is the Honorable Paul Rand Dixon, Chairman, Federal Trade Commission. Good morning, sir. Mr. DIXON. Good morning.

Senator HARTKE. It seems as though you and I are visiting each other quite often.

Mr. DIXON. Yes, sir. I am always happy to be here.

STATEMENT OF PAUL RAND DIXON, CHAIRMAN, FEDERAL TRADE COMMISSION; ACCOMPANIED BY JOHN V. BUFFINGTON, ASSISTANT TO THE CHAIRMAN, GERALD T. MCDONOUGH, FEDERAL TRADE COMMISSION STAFF, AND FLETCHER G. COHN, ASSISTANT GENERAL COUNSEL, LEGISLATION

Mr. DIXON. Mr. Chairman, may I introduce my colleagues? To my right is my assistant, Mr. J. V. Buffington. To my immediate left is Mr. Gerald T. McDonough, Federal Trade Commission staff, and to my right is Mr. Fletcher G. Cohn, Assistant General Counsel, for legislation.

It is a pleasure to appear before you to comment on S. 1643, a bill now under consideration which would provide regulations for motor vehicle tires.

The bill would direct the Secretary of Commerce to prescribe regulations establishing minimum safety and performance standards and a grading and labeling system for motor vehicle tires in order that the public will be provided with safe tires.

The bill stipulates that such regulations shall become effective 1 year after the date of enactment and that its enforcement shall take effect between 180 days and 1 year after issuance of the regulations.

The bill would prohibit the manufacture, sale, and transportation in interstate commerce, and the importation into the United States of tires manufactured on or after the effective date of the regulations which did not comply with them. Criminal penalties are provided for willful violation.

Prior to making specific comment on the bill under consideration, I believe that it may prove useful to refer to some background information we have relative to the current nature of the tire industry.

The tire manufacturing industry is an integral part of our national economy, since the automobile has long since become far more than a mere luxury item for the average American family. Cars today, traveling as they must on tires, are higher powered, traveling farther distances at higher sustained speeds, and carrying greater loads on our ever-growing system of improved superhighways.

To meet this consumer need, the 14 domestic tire manufacturers are producing passenger car tires at an annual rate of well over 100 million. Statistics at our disposal reflect that in 1964, approximately 4212 million original equipment tires were placed on new automobiles, and that over 87 million new tires were sold in the replacement passenger car market.

In addition, it is our understanding that 35 million retreaded tires were sold in the replacement market during 1964. It is also estimated that there were 288 million passenger car tires in use at the close of the year 1964. In view of these staggeringly large totals, it is clear that the pricing practices, guarantees, quality, and safety of tires are all matters of considerable concern to the public.

In addition to the aforementioned 14 domestic tire manufacturers who market tires under their own brand names, we are informed that there are, at present, approximately 120 private label tires available in the replacement market, and a total of over 940 different tire names from which the consumer may choose.

The Commission has been aware, for some time, of the ever-mounting degree of public interest in the subject of traffic safety. The increasing number of interstate highways with higher speed limits, the ever-increasing number of automobiles and drivers making use of these highways, and the annually mounting toll of deaths, injuries, and property damage on our roads have resulted in a growing awareness of the need for remedial measures in the area of traffic safety.

During the past 5 years, this public concern has been increasingly focused on the relationship of tire safety to the overall problem of traffic safety and has been evidenced by legislative activity on both a State and Federal level; by industry and trade association activity; consumer communications; and the spate of articles which continue to appear in the trade and public press.

Activity seeking solutions to this national problem is currently in progress on Federal, State, local, and private levels. For example. during 1962, the National Tire Dealers & Retreaders Association applied to the Department of Commerce's Division of Commodity Standards for assistance in the formulation of voluntary safety standards for tires.

Several meetings were held and attended by dealer and retreader representatives, engineers representing tire manufacturers and Bureau of Standards personnel, but the project was apparently abandoned because of the inability of the various parties to reconcile their views.

In the latter part of 1963, 31 States joined together to form the Vehicle Equipment Safety Commission to recommend codes or other regulations embodying performance requirements for vehicle equip

ment.

In New York State, the Joint Legislative Committee on Motor Vehicles and Traffic Safety conducted a series of hearings during 1963 and 1964 which culminated in the introduction of proposed legislation which would have established mandatory minimum safety standards.

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