In response to the significant number of fatalities that resulted from the recent Ford-Firestone tire fiasco, Congress took swift legislative action to protect American motorists. The U.S. House of Representatives' Committee on Energy and Commerce determined that federal regulators could have detected the problems with the tires more quickly if they had obtained reports about those problems in a timelier fashion.

Had a recall on Firestone Radial ATX and Wilderness AT tires been initiated in 1998 instead of 2000, some observers argue that it might have saved the lives of 143 people out of a total of 192 who died as a result of alleged tire tread separation. As a result, the TREAD Act was signed into law by Bill Clinton in 2000. After several years hearing testimony and ironing out details, bureaucrats will finally begin enforcing the TREAD Act in 2004.

The TREAD Act delegates new rulemaking authority to the U.S. Department of Transportation's National Highway Traffic Safety Administration (NHTSA, Washington, DC) and mandates that the agency carry out the following critical tasks:

• Require passenger and commercial vehicle manufacturers to report information about potential safety defects to NHTSA's new early warning database.

• Improve tire labeling requirements.

• Develop a rollover test for its consumer information crash testing program.

• Require a tire pressure monitoring system to warn motorists of low tire inflation pressure.

• Update requirements for child safety restraints.

According to many observers, the most significant provision of the TREAD Act is the creation of an early warning database containing up-to-date defect-related information submitted by auto manufacturers on a quarterly basis. Under those provisions, OEMs are required to tell NHTSA about customer complaints and accidents involving their vehicles every 3 months. The first reports were due Dec. 1, 2003, and the next are due at the end of this month.

"Time is ticking and a lot of folks are scrambling right now to get solutions in place or to validate what they have been developing," warns Marianne Grant, director of the business innovation center at Syncata Corp. (El Segundo, CA). "They don't have time to waste."

The TREAD Act requires automakers to report on 24 different categories, including air bags, brakes, electrical system, engine and cooling system, exterior lighting, fuel systems, latching, powertrain, seats, steering, structure, suspension and wheels.

"This early warning reporting system is intended to identify defects in vehicles and equipment," says Andrew Cummins, executive director of the Automotive Industry Action Group (AIAG, Southfield, MI). "Noncompliance can result in civil penalties of up to $15 million. Company personnel may face prison time as well."

Everything from air bags to wheels is impacted by the legislation. In addition, the TREAD Act specifically includes "mounting elements, such as brackets and fasteners" in its definition of components and systems that are covered. Since many warranty issues stem from fastener problems, screwdriving operations must be carefully documented to avoid potential penalties.

Common Culprits

Many warranty complaints can be traced to fastening problems or errors. Every month, NHTSA publishes a list of recalls. It identifies the make and model of the vehicle involved, with a brief description of the safety problem. Missing or broken mounting brackets are commonly cited.

According to Bill Pierce, president of Common Sense Fastener Technology (Russiaville, IN), the No. 1 reason why fasteners are behind warranty problems and recalls is the lack of up-front design engineering of the screw or fastener for that specific application.

"Unfortunately, the fastener is the last item to be considered in any design," claims Pierce, who is a retired General Motors engineer. "A NASA study back in the 1960s found that the most common [reason for joint failure] is the misapplication of the fastener , not the . . . fastener [itself]. Most engineers [specify whatever fastener] they may happen to have in their desk drawer at that instant in time."

Several years ago, Pierce surveyed local car dealers to find out what consumers were complaining about. "The No. 1 problem was squeaks and rattles from loose or missing fasteners," says Pierce. "Many times, they would find extra fasteners lying loose on the floor boards, in the luggage compartment area and even in the engine compartment. One dealer even showed me a body mount bolt that was just stuck in the frame."

The bulk of the early warning reporting requirements of the TREAD Act apply to large automotive OEMs, in addition to manufacturers of child restraint systems and tires. Those manufacturers must file a report to NHTSA pertaining to any deaths or injuries that occur in the United States.

In addition, they must report the numbers of claims for property damage that occur in the United States that are related to alleged problems with certain components and systems, regardless of the amount of such claims. Additional information, such as consumer complaints, warranty claims information, field reports and production figures, must also be reported.

Small OEMs-companies that assemble fewer than 500 vehicles in the United States-and manufacturers of equipment or replacement equipment other than child restraint systems and tires are required to submit reports containing information about claims and notices of deaths allegedly caused by their products, but are not required to submit other information.

Comprehensive Coverage

A wide variety of automotive components are covered, including brake, steering and suspension systems. Section IV of the TREAD Act's Final Rule outlines the components and systems covered.

The term "brake system" is defined as the "brake pedal, master cylinder, fluid lines and hoses, braking assist components, brake calipers, wheel cylinders, brake discs, brake drums, brake pads, brake shoes and other related equipment installed in a motor vehicle. This term also includes systems and devices for automatic control of the brake system, such as antilock braking, traction control, stability control and enhanced braking."

The term "steering system" is defined as "the steering system mechanism and its associated hardware, the steering wheel, steering column, steering shaft, linkages, joints (including tie-rod ends), steering dampeners and power steering assist systems."

The term "suspension system" is defined as "control arms, steering knuckles, spindles, joints, bushings, ball joints, springs, shock absorbers, stabilizer (anti sway) bars and bearings that are designed to minimize the impact on the vehicle chassis of shocks from road surface irregularities that may be transmitted through the wheels and to provide stability when the vehicle is being operated through a range of speed, load and dynamic conditions. The term also includes all electronic control systems and mechanisms for active suspension control."

Each term also includes "all associated components, such as switches, control units, connective elements (e.g., wiring harnesses, hoses, piping, etc.) and mounting elements (e.g., brackets, fasteners, etc.)."

In addition to submitting information about problems and complaints, the early warning reporting rule requires OEMs to submit data on the number of vehicles produced during the model year of the reporting period and the prior 9 model years. While such data is readily available for cars and light trucks, production figures are closely guarded by manufacturers of specialized vehicles, such as motorcycles, school buses and delivery trucks.

Those OEMs want to maintain the confidentiality of their production figures. For instance, Harley-Davidson Inc. (Milwaukee) claims that production numbers by model have never been generally available in the motorcycle industry. Other niche manufacturers, such as Blue Bird Corp. (Fort Valley, GA) and Utilimaster Corp. (Wakarusa, IN), point out that production numbers in their segment of the industry are confidential and likely to lead to substantial competitive harm if released.

"People are still grappling with how to balance NHTSA's need for information with the manufacturers' need for confidentialty," says John Clark, general counsel for Textron Fastening Systems (Troy, MI). "Privacy over production data is a legitimate concern. It's an area that will continue to be looked at."

Mixed Reaction

Most companies affected by the TREAD Act are still attempting to understand its implications and determine how they will comply with its reporting mandates. Many people are still trying to figure out what to do.

"There's a lot of confusion downstream," notes David Cole, chairman of the Center for Automotive Research (Ann Arbor, MI). "There was a sense of urgency after all the notoriety [caused by the Ford-Firestone incident]. It takes a while for things to percolate through the supply chain. The industry is trying to sort out many issues. It's still a work in progress."

Until recently, there was tremendous confusion, because the TREAD Act was still evolving and being fine tuned. In fact, the deadline for submitting data was revised and pushed back several different times.

Many observers agree that the TREAD Act is a poor name. "It encompasses more than just tires," says Morris Brown, AIAG program manager for materials management. But, like or not, the TREAD Act is here to stay. Brown expects NHTSA to "make an example of someone. They're going to send a message to the industry to let people know that they're serious. That way, they'll get more exposure.

"The heart of the TREAD Act is traceability," explains Brown. "Right now, more pressure to comply is on OEMs [because they have much broader reporting obligations]. But, suppliers are not exempt. It could impact any supplier, [even if it's something as seemingly minute as] a screw holding an air bag in place or a bolt holding a wheel in place.

"A lot of people have questioned how effective the TREAD Act will be," adds Textron's Clark. "It was done with great intention, but it's a massive undertaking. For an industry this size, it will take a while for everyone to digest it. And, it will take NHTSA a long time to catch up and go through the first set of reports. One year from now, it will be interesting to see how they've been able to evaluate and learn from all that data."

Tom Rougeux, sales manager at Visumatic Industrial Products Inc. (Lexington, KY), believes the TREAD Act may ultimately lead to higher quality by insisting that OEMs and suppliers start tracking data that aren't currently tracked. One of the act's unintended effects may be that manufacturers will need to upgrade their screwdriving equipment to include torque and angle control, data logging and archiving software, and error-proofing sensors. This will raise the cost of screwdriving systems.

"Few manufacturers will be spending additional money simply to comply with TREAD," claims Rougeux. "The current language does not require companies to step up their data acquisition measures, only to make what they have available. For those companies that currently invest in data acquisition for the purpose of improving their quality, I think the road takes one of two directions: They will either be spending even more money to comply and report or conclude that [gathering the] information falls under ‘burdensome requirements.'"

Several Solutions

Is TREAD compliance an engineering problem or an IT issue? Should the legal department handle it or the safety guys? Many manufacturers have been asking those questions as they try to figure out how to comply.

To cover all bases, some OEMs and suppliers are relying on cross-functional teams that include representatives from engineering, materials, quality, design, legal, sales, service, technology systems and warranty.

"The TREAD Act impacts everyone in an organization," says Brown. "It's not just an IT issue or a quality problem. Everyone needs to be aware of what to do in case there's an incident.

"Transmitting your reports electronically is the easy part," claims Brown. "The real challenge exists when companies must answer to NHTSA when asked for clarification on their reports."

Much like the cottage industry that sprang up to handle the Y2K computer scare 4 years ago, numerous software companies and consultants have popped up recently to guide manufacturers through the TREAD Act. In addition, several types of fastening tools are available to address documentation requirements.

Manufacturing engineers concerned about documenting process information to ensure that a fastening operation was performed correctly can turn to controlled tools. "They use transducers to measure dynamic torque," says Steve Bulleit, director of training at AIMCO (Portland, OR). "A controller uses the signal from the transducer to shut off the tool at a preset torque." Controlled tools are available in electric and pneumatic models.

A less expensive alternative to fully controlled tools is a system that provides process verification without transducers. "A tightening monitor confirms that the tool fully completed its cycle and shut off," says Bulleit. "Using a simplified controller, you can monitor the cycle time of each run-down, verify cycle completion, and count the [screws] that have been installed." Many existing tools can be retrofit to perform these functions.

However, documentation comes with a price tag. For instance, controlled tools cost $8,000 to $10,000. A tightening monitor is more economical and costs approximately $3,500, compared to a standard pulse tool that averages $2,000.

Other error-proofing tools, such as smart part bins and light-guided picking systems, are a less expensive way to reduce the risk of errors and monitor assembly processes. Ideally, the potential of an error occurring should be identified beforehand. Indeed, errors and defective parts are cheapest to address up front, early in the assembly process. Once errors and mistakes get passed downstream, the TREAD Act threatens to trace it back to the source.

Sidebar: OEMs Are Ready, But Suppliers Are Not

More than 85 percent of vehicle manufacturers claim they are prepared to generate and submit early warning reports to the National Highway Traffic Safety Administration (NHTSA) as required by the Transportation Recall, Enhancement, Accountability and Documentation (TREAD) Act. In contrast, more than 40 percent of suppliers responding to a recent study conducted by Syncata Corp. (El Segundo, CA) stated that they were "not at all" or only "somewhat" prepared to generate and submit reports to NHTSA.

"NHTSA's requirements are complex, frequently changing and subject to multiple [legal] interpretations, which has made it difficult for many companies to understand their specific compliance steps," says Marianne Grant, director of the Syncata business innovation center. "As a result, we're seeing companies from all industry segments [that] have begun building TREAD Act compliance systems in-house and are seeking additional help to determine the most effective, accurate and rapid road to compliance."

Of the manufacturers that stated they were prepared to generate and submit reports, just over 15 percent said they were "extremely well" prepared and slightly more than 30 percent said they were "very well" prepared. Almost 40 percent said they were "adequately" prepared. The remaining 15 percent of respondents stated that they were only "somewhat" prepared to generate reports to NHTSA.

Manufacturers of medium and heavy vehicles, trailers and recreational vehicles reported the highest preparedness, with 89 percent claiming that their systems and assembly data are coded and mapped "very well" and "extremely well" to the required NHTSA categories. More than 53 percent of this segment of respondents felt that they understood the changing early warning reporting (EWR) requirements "very well" or "extremely well."

Approximately 70 percent of all those surveyed found industry associations, such as the Automotive Industry Action Group (Southfield, MI), National Association of Trailer Manufacturers (Topeka, KS), National Truck Equipment Association (Farmington Hills, MI), Recreation Vehicle Industry Association (Reston, VA) and the Motorcycle Industry Council (Irvine, CA) helpful in preparing them to meet EWR requirements.

Who, What, Where, When

Traceability is a key component of the Transportation Recall, Enhancement, Accountability and Documentation (TREAD) Act. Until recently, few people understood the benefits of recording a component's birth date and other historical data.

Engineers at Visteon Corp. (Dearborn, MI) are experimenting with an electronic "birth certificate" that helps trace where and when a component was assembled. The company's Rawsonville plant in Ypsilanti, MI, assembles the engine induction system (EIS) used in the 2004 Ford F-150 pickup.

The "sound" of trucks and other niche vehicles has become an increasingly important part of their brand image. After months of market research, Ford engineers agreed upon a "tough truck" rumble for its redesigned flagship vehicle. The challenge was to make this acoustic signature affordable and easy to manufacture.

An EIS inlet duct under the hood gives the F-150 a unique rumble that is immediately apparent to the driver and passengers. It integrates resonators into the air intake duct at maximum cost efficiency.

Visteon engineers developed a robust, low-cost, acoustically accurate method of locating specifically sized and strategically placed drain holes in resonators. This approach to fine tuning the resonators eliminated the need for even more resonators and sound tuning devices.

The Rawsonville plant created a method of storing a part's history and test data in an electronic file, which technicians can activate by scanning a 2D bar code on every EIS.

Information is collected even before the first parts are assembled. For example, an integral part of the system supplied to Visteon is the manifold. The supplier sends each manifold with a bar code of its own containing information about when it was made and the results of the supplier's internal quality tests. Starting with this information, a computer file is created for each EIS that is assembled.

As the system is assembled, every operation on the line that can transmit data, such as torque, angle or leakage, sends the information to an electronic file. At the final operation, a bar code is generated and attached to the housing of the EIS before it gets packed in a crate and sent to Ford's engine plant in Windsor, ON. The information is kept in a database for 10 years.

"This is a pretty sophisticated engine, so this information will be valuable in diagnosing any future issues," says Jeff Riedel, lean manufacturing manager and EIS launch manager at Rawsonville. "When a customer comes into the dealership with an engine issue, we can scan that bar code and look at the history of that part or a group of parts. They can compare it with the data they have and try to troubleshoot the problem. The ‘genetic code' is going to make it much easier to get a response back and get the customer's [problem] fixed quickly."