The Tire Industry Association (TIA) has released a bulletin for retailers who service C-Type light truck tires. Earlier in the year, TIA asked the Occupational Safety and Health Administration (OSHA) for an interpretation on whether C-type light truck tires were covered by 29 CFR 1910.177. The standard excludes light truck tires designated “LT” and C-type tires are considered light truck tires by the manufacturers even though they do not have the letters “LT” in the size designation. TIA’s position was that the exemption given to light truck tires designated “LT” should be extended to C-type tires because the service procedures are identical.

OSHA’s response was that C-type tires are not interchangeable with light truck tires in the same size therefore they are covered by 1910.177. The Agency described it as something that could be considered a “de minimus” condition. The lack of clarity regarding “de minimus” forced TIA to create recommendations for tire retailers to assist them with OSHA compliance when servicing C-type light truck tires.

“We met with OSHA officials on video conferences and in person to help them understand that C-type light trucks are serviced the exact same way as light truck tires with the letters ‘LT’ in the size designation,” said Dick Gust. “Based on OSHA’s response, TIA had to respond with service and training recommendations for passenger and light truck tire dealers who service C-type light truck tires to help them comply with 1910.177.”

TIA does not believe that commercial tire dealers who participate in the Basic 200-Level or Certified 300-Level Commercial Tire Service (CTS) program need to provide additional training for technicians who have already completed the program(s). Their training is already compliant with 1910.177 but commercial dealers are encouraged to inform their technicians that C-type light truck tires should be inflated in the same manner as truck tires.

Since a C-type light truck tire has a higher inflation pressure than an LT tire in the same size, TIA believes any additional hazards related to service would be focused on inflation. Therefore, the inflation procedures for C-type light truck tires must comply with 1910.177. The safety and training bulletin includes the inflation procedures that should be followed including the necessary inflation equipment to stay compliant. TIA also created an OSHA Tire Inflation Skills Demonstration Form that retailers can use to document their employees demonstrated the ability to inflate a tire in accordance with the requirements contained in 1910.177.

“This has been uncharted territory for TIA training, so the Board of Directors has been discussing our response for months,” said Debra Hamlin. “Without clear direction from OSHA, TIA will stay true to our mission and improve tire safety through training and education by informing retailers on how they can safely service C-type light truck tires given the OSHA response.”

The main difference from a service perspective is that C-type light truck tires must be inflated in a restraining device (i.e. safety cage) using an OSHA-compliant inflation device or the tire must be secured to the vehicle with the lug nuts fully tightened during inflation. TIA believes that inflating an unrestrained C-type tire on a tire changing machine would constitute a violation of 1910.177. Likewise, if the tire machine has restraint capabilities, then the device must be able to withstand 150 percent of the maximum force transferred during a separation or sudden release of compressed air to be compliant.

TIA has posted the OSHA letter, Safety and Training Bulletin, and OSHA Tire Inflation Skills Demonstration Form on the Association’s website to assist retailers with OSHA compliance when servicing C-type light truck tires. Light truck tire service providers are encouraged to have a completed skills form for each employee so the employer can prove that technicians have demonstrated the ability to inflate a tire using the equipment and procedures outlined in 1910.177.

For copies of these resources, go to https://www.tireindustry.org/training/tire-technician-training/automotive-tire-service/.

Tagged: commercial tire dealers

TIA Releases Safety and Training Bulletin for C-Type Light Truck Tires