Entry DateSeptember 3, 2020
Issue Number20-020-VEH
NameStephen Hobbs, Safety Manager
AgencyTerminal Transportation Services
Address1657 A South Highland Ave.
Baltimore, MD 21120
United States
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Phone410-246-0500 ext1563
Fax(410) 327-1608
EmailEmail hidden; Javascript is required.
Issue NameOOSC, Part II, Item 12. Tires, a. and b. - Tire Has Noticeable Leak
Summary of Issue

There is currently no inspection code to differentiate between a flat tire/audible air leak and a minor audible air leak in a tire on a vehicle equipped with a tire air maintenance system.

Justification or Need

Due to the new technology of air maintenance systems a minor audible air leak on a tire from small debris picked up on the road no longer justifies an OOS violation for a drive or trailer tire on vehicles equipped with tire air maintenance systems. These systems compensate for small air leaks due to road debris that prevent the leak from becoming a safety hazard or causing a tire failure. They also have indicators to alert the driver that there is a leak so the driver can get the tires checked for a leak and corrected. We are specifically requiring these systems on all our new equipment to address these issues but being cited for these kind of minor things at a high level can be very discouraging for companies like ours that are trying to utilize as much technology as possible to be safe but are continuing to be penalized as if these systems have no value. I have included pictures of a recent example of a violation we received an OOS violation for. This small carpet tack in a tire on a trailer with an air maintenance system was in no way a violation that was so egregious that it required being OOS but there is no other code that could be cited so we were placed OOS and slapped with an 8+2 CSA OOS point violation.

Request for Action

Add an enforcement code for minor air leaks in a drive or trailer tire on a unit equipped with an air maintenance system and such tire is properly inflated. This code should not carry an OOS designation and should be much lower than the current 395.75(a)(3) 8 CSA points plus 2 OOS.

Action Taken by Committee

The committee and representatives from the tire industry agreed that any leak in a tire has a significant impact on the integrity of the tire and should still be placed out of service if the tire is actively leaking. However, this discussion moved into the fact that some inspectors will cite a object embedded in a tire even when it is not leaking. This resulted in guidance being drafted for Operational Policy 15 to provide direction to inspectors, not to remove the object or cite the object unless the tire is actively leaking. The presence of a tire inflation system has no affect on whether a tire is in violation and/or OOS.

The committee unanimously voted to add the following question to Operational Policy 15 and the board of directors approved the language as follows:

12. TIRES

b.(2) If a nail, screw, or other foreign object is embedded in a tire and the tire is not leaking, should a violation be recorded and the object be removed?

ANSWER: This condition is not a violation if a leak is not present. An inspector shall not remove or direct a driver to remove a foreign object from a tire.

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