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 > RV Trailer Tire Replacement Information

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FastEagle

Taylors, SC

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Posted: 07/26/12 12:48pm Link  |  Print  |  Notify Moderator

I’m starting this topic so it wont be misunderstood as flaming or attacking on others posting information along these lines.

DOT regulations are woven together to produce an end product that is certified to be safe.

As the current regulations are written RV trailer manufacturers MUST achieve certain minimum requirements in establishing the trailer’s GVWR. To go beyond DOT minimum requirements is the vehicle manufacturers prerogative. Once the vehicle manufacturer has put it all together and added selected/requested options, the vehicle’s certification labels, tire placards, and cargo capacity information labels are completed and affixed to locations in/on the trailer as described in DOT regulations. Any of those labels may be changed by a dealer but not after the vehicle has been sold. The dealer cannot violate the minimum standards set by the manufacturer. Adding heavy options can cause the Cargo information to change and it’s the dealers responsibility to reflect those changes with a new cargo capacity label. Changing tire brands but not the recommended tire pressure (s) or load capacity does not require new labeling for that change. Changing tire size and increasing load capacity may be authorized by the vehicle manufacturer before first sale but the labeling for that change MUST be depicted on new labeling.

Certification information is set in stone. Nobody can legally change the vehicle’s GVWR (except the manufacturer). The total GAWR is set by the vehicle manufacturer and is the minimum standard for that trailer. The owner can change axles to a larger size but nothing lower than what the certification label depicts. Increasing axle size only reinforces the vehicle’s integrity, it cannot increase the GVWR. Certification labels also depict the minimum tire size, it’s required load capacity is set with the recommended tire pressure. They are not locked in by size or design. However, replacements MUST provide equal or greater load capacities.

This is an excerpt from CFR 49 PART 570—VEHICLE IN USE INSPECTION STANDARDS


§ 570.62 Tires. “(a) Tread depth. The tread shall be not less than four thirty-seconds of an inch deep on each front tire of any vehicle other than a trailer and not less than two thirty-seconds of an inch on all other tires. (1) Inspection procedure. For tires with treadwear indicators, check for indicators in any two adjacent major grooves at three locations spaced approximately 120° apart around the circumference of the tire. For tires without treadwear indicators, measure the tread depth with a suitable gauge or scale in two adjacent major grooves at 3 locations spaced approximately 120° apart around the circumference of the tire at the area of greatest wear. (b) Type. Vehicles should be equipped with tires on the same axle that are matched in construction and tire size designation, and dual tires shall be matched for overall diameter within one-half inch. (1) Inspection procedure. Examine visually. A mismatch in size and construction between tires on the same axle, or a major deviation from the size recommended by the vehicle or tire manufacturer, is a cause for rejection. On a dual-tire arrangement the diameter of one of the duals must be within one-half inch of the other as measured by a gauge block inserted between the tire and a caliper. (c) General condition. Tires shall be free from chunking, bumps, knots, or bulges evidencing cord, ply or tread separation from the casing.
Code of Federal Regulations / Title 49 - Transportation / Vol. 6 / 2010-10-01236(1) Inspection procedure. Examine visually for the conditions indicated. (d) Damage. Tire cords or belting materials shall not be exposed, either to the naked eye or when cuts on the tire are probed. Reinforcement repairs to the cord body are allowable on tires other than front-mounted tires. (1) Inspection procedure. Examine visually for the conditions indicated, using a blunt instrument if necessary to probe cuts and abrasions. (e) Special purpose tires. Tires marked “Not For Highway Use” or “Farm Use Only” or other such restrictions shall not be used on any motor vehicles operating on public highways. (1) Inspection procedure. Examine visually for tires labeled with specific restrictions.”

In accordance with the information above, recommending tires with a maximum load capacity of 3042# as replacements for tires depicted on the vehicle certification label/tire placard needing 3520# of load capacity is unacceptable.

The Vehicle in use inspection standards enforce replacement tire safety standards as described in the NHTSA safety requirements for replacement tires.

NHTSA Ref

The reference below is the easiest one to read.

In use inspection ref


FastEagle

p.s. I post this because so many people do not do a complete review of all the regulations leading to the bottom line. NHTSA gives simple instructions to follow but researchers are always hunting for loop-holes. In one set of regulations one might be lead to believe they have found one. But further investigation into another document will close the opening they think they had earlier found. If you find fault with this posting please post the reference I have faltered in. To post all the references I have read to come to these conclusions would be counterproductive because there are so many.

I don’t have access to a TRA manual but I don’t think there is any procedures there for RV trailer tire replacements, OE or plus sizing. So I invite the experts to chime in and enlighten us of any existing TRA procedures. To me plus sizing would be pretty standard across the board.


Tire Blog

DryCamper11

Hartford

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Posted: 07/26/12 01:45pm Link  |  Print  |  Notify Moderator

FastEagle wrote:

I’m starting this topic so it wont be misunderstood as flaming or attacking on others


You were so careful to tread lightly that I had trouble understanding your point or why you were posting. I read this:
Quote:

I post this because so many people do not do a complete review of all the regulations leading to the bottom line

But I'm still not sure. Are you commenting on end users who change tires/wheels or on something that manufacturers or dealers are doing or not doing? Sorry to be obtuse, but I'm not clued into what this is about.


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Fire Instructor

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Posted: 07/26/12 02:08pm Link  |  Print  |  Notify Moderator

Great post (as always), FastEagle! Thank you for the info. And to the potential flamers, .....


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DryCamper11

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Posted: 07/26/12 02:59pm Link  |  Print  |  Notify Moderator

Fire Instructor wrote:

Great post (as always), FastEagle! Thank you for the info. And to the potential flamers, .....


It was very informative, but why does it make anyone want to flame anyone else. I wish someone would explain it in simple terms to me.

phillyg

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Posted: 07/26/12 07:46pm Link  |  Print  |  Notify Moderator

I, too, am a bit confused about the intent of the post. As I understand it, you're just reciting what the law is about tires, axles, and certification thereof. And, while it's all nice to know info, there's nothing other than threat of prosecution for willful violation of the law, and we know that such prosecution is not always an impediment for those willing to skirt or avoid the law to their own advantage.


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Dayle1

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Posted: 07/26/12 08:08pm Link  |  Print  |  Notify Moderator

FastEagle wrote:



In accordance with the information above, recommending tires with a maximum load capacity of 3042# as replacements for tires depicted on the vehicle certification label/tire placard needing 3520# of load capacity is unacceptable.


The required labels on my fifth wheel specify tire size and PSI. But they do not specify tire type (i.e. ST or LT) and the label only defines GVWR, not GAWR. So, it would seem to be impossible to conclude that an LT tire with a capacity of 3042 lbs is in some way illegal. Certainly autos and trucks have labels that specify GAWR and it is ez to determine if an underrated tire is being used. But again, I don't see the same situation with the labels on a trailer unless I'm missing something.


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Chuck&Gail

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Posted: 07/26/12 08:21pm Link  |  Print  |  Notify Moderator

Thanks, great post.


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JIMNLIN

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Posted: 07/26/12 09:35pm Link  |  Print  |  Notify Moderator

Quote:

In accordance with the information above, recommending tires with a maximum load capacity of 3042# as replacements for tires depicted on the vehicle certification label/tire placard needing 3520# of load capacity is unacceptable.



Some trailer manufacturers may use a 5200 lb or a 6000 Lb axle and may install a ST235/80-16 E at 3400-3500 lbs capacity. Replacement tires need only to match or exceed the axle ratings. In that case there is no rules/laws/codes violation if a 3042 lb LT E tire is used on either of the two axles.
Granted if the owner chooses a ST he would be better served by going with the over capacity ST E 3500 lb capacity tire.


570 your quoting is simply a guideline "FOR A STATE" to set up a safety program if they so choose.



570.3 Applicability.
This part does not in itself impose requirements on any person. It is intended to be implemented by States through the highway safety program standards issued under the Highway Safety Act (23 U.S.C. 402) with respect to inspection of motor vehicles with gross vehicle weight rating of 10,000 pounds or less, except motorcycles or trailers.

and over 10000 lbs


570.53 Applicability.
This part does not in itself impose requirements on any person. It is intended to be implemented by States through the highway safety program standards issued under the Highway Safety Act (23 U.S.C. 402) with respect to inspection of motor vehicles with gross vehicle weight rating greater than 10,000 pounds, except mobile structure trailers.


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FastEagle

Taylors, SC

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Posted: 07/26/12 09:56pm Link  |  Print  |  Notify Moderator

Dayle1 wrote:

The required labels on my fifth wheel specify tire size and PSI. But they do not specify tire type (i.e. ST or LT) and the label only defines GVWR, not GAWR. So, it would seem to be impossible to conclude that an LT tire with a capacity of 3042 lbs is in some way illegal. Certainly autos and trucks have labels that specify GAWR and it is ez to determine if an underrated tire is being used. But again, I don't see the same situation with the labels on a trailer unless I'm missing something.


RV trailers over 10,000# GVWR are not required to have a tire placard. However, they MUST have a certification label that depicts GAWR, GVWR, tire size and the recommended tire pressure (s) for them. That label is required to be on the forward external portion of the trailer. It could be on the pin box or pasted on the side of the trailer. If you cannot find it, report it missing to the vehicle manufacturer. If they are slow in responding report them to the DOT. That will almost always get a quick reply from the vehicle manufacturer. They do not want to enter a recall situation for improper labeling.

Here is a picture of a typical certification label.

Certification Label

FastEagle

FastEagle

Taylors, SC

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Posted: 07/26/12 10:52pm Link  |  Print  |  Notify Moderator

JIMNLIN wrote:

Quote:

In accordance with the information above, recommending tires with a maximum load capacity of 3042# as replacements for tires depicted on the vehicle certification label/tire placard needing 3520# of load capacity is unacceptable.



Some trailer manufacturers may use a 5200 lb or a 6000 Lb axle and may install a ST235/80-16 E at 3400-3500 lbs capacity. Replacement tires need only to match or exceed the axle ratings. In that case there is no rules/laws/codes violation if a 3042 lb LT E tire is used on either of the two axles.
Granted if the owner chooses a ST he would be better served by going with the over capacity ST E 3500 lb capacity tire.


570 your quoting is simply a guideline "FOR A STATE" to set up a safety program if they so choose.



570.3 Applicability.
This part does not in itself impose requirements on any person. It is intended to be implemented by States through the highway safety program standards issued under the Highway Safety Act (23 U.S.C. 402) with respect to inspection of motor vehicles with gross vehicle weight rating of 10,000 pounds or less, except motorcycles or trailers.

and over 10000 lbs


570.53 Applicability.
This part does not in itself impose requirements on any person. It is intended to be implemented by States through the highway safety program standards issued under the Highway Safety Act (23 U.S.C. 402) with respect to inspection of motor vehicles with gross vehicle weight rating greater than 10,000 pounds, except mobile structure trailers.


Again you miss the point of government regulations. This one clearly reinforces the NHTSA safety requirement to use replacement tires of equal or greater values than the certified OE tires depicted on the vehicle’s labeling which are certified to be the minimum requirement by the vehicle manufacturer.

I posted that copy because it is certified to be current and still in compliance this year and is dated as such.

True, the minimum tire requirement for fitment onto the RV trailer axle must be equal to or greater than the vehicle manufactures certified GAWR. That requirement ensures the vehicle manufacturer meets the DOT minimum requirement.

DOT also requires the vehicle manufacturer to set the recommended tire pressure (s) for those tires depicted on the certification label. That action sets the stage for those tires to be the minimum standard for that vehicle. DOT again reinforces that position by directing the vehicle manufacturer to insure the tires depicted on the certification label/tire placard mathematically match the actual tires installed on the vehicle at the time of first sale. That action insures the new owner has the correct tire, rim, GAWR, and GVWR information when they take position of the vehicle. The owners manual will have DOT mandated instructions/recommendations of what to do with that information. (That’s in another DOT numbered regulation). Clearly in all owners manuals is a paragraph about tire size. It says in part to use replacement tires of the same size (or larger) as depicted on the labeling. When in doubt seek assistance from the vehicle manufacture or the tire manufacturer.

Nowhere in all my research have I found reference to use tires of any size with less load capacity than what the vehicle manufacturer has certified to be the minimum standard for a particular trailer. Every industry standard publication I’ve researched has supported the NASTA standard for replacement tires. And, to reach into the bottom of the bag for support from litigators along those lines would be fruitless. I’ve known some pretty savvy insurance investigators in my time. Their safety knowledge is more comprehensive than people might think. If anybody reading this personally knows someone doing that work you know what I mean.

FastEagle

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