First Name | Mark |
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Last Name | Duranty |
Email Address | mduranty@automotivesol.com |
Affiliation | |
Subject | Tire Pressure Regulation |
Comment | Please note that: 1) Section 95550 (c) (13) defines "Under Inflated Tire" as "...a tire that is one pound per square inch (psi) or more below the recommended tire pressure rating." 2) Section 95550 (d)(1)(C)mandates the pressure be read using a pressure gauge that is accurate to +/- two pounds per square inch (2 psi) It would seem that specifying an instrument to read the required 1 psi pressure rating that is inherently 200% in error, is counter intuitive to the regulations intent. In regards to “Definitions” (16) “Vehicle Service Invoice” should be worded to include that if a separate tire inspection is performed that the subsequent inspection can include identifying items that would align the Vehicle Service Invoice to the Tire Inspection. These can be Vehicle Identification Number (VIN), or other indentifying items. The term “Invoice” connotes that there is a fee associated with this function. In reality this could be a no fee service from the ASP and therefore no invoice generated. A Tire Inspection form should suffice as standalone documentation for the inflations service performed. Additionally, the reporting requirements do not specifically address the electronic recording and storage that is important to generating and retaining the records required for such a large data base as this regulation will generate. If this regulation is to improve air quality, having to harvest trees and produce the paper to meet these reporting and retention requirements are also counter intuitive to the regulation's intent and our future. The ASP should not have to keep paper records if electronic reproduction can be retained and accessed as required. Addressing (109) “Tire Inflations Reference” with no recognizable authority that publishes an ‘industry standard’, the regulations need to be specific as to where the ASP needs to acquire the proper air pressure settings. For lack of alternative, tire pressure setting should be taken from the vehicle itself (door placard, owner’s manual, etc.) and noted on the Tire Inspection form or invoice. |
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Date and Time Comment Was Submitted | 2010-07-06 13:33:58 |
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