FAILURE ANALYSIS OF A TREAD SEPARATION INCIDENT INVOLVING A GOODYEAR WRANGLER LIGHT TRUCK TIRE by Dennis Carlson, M.S.M.E., P.E. Professional Engineer and Tire Failure Analyst Member: Society of Automotive Engineers and the American Chemical Society December 5, 2014 My File #3719-Hall I. INTRODUCTION At your request, I have examined and performed failure analysis on a Goodyear Wrangler Silent Armor, Pro Grade tire that failed by a tread-belt separation while mounted on a 2008 Ford F-150 FX4 Crew Cab pick-up. According to the Texas accident report, the accident occurred on August 01, 2011 and was a single vehicle accident that was precipitated by the separation failure of the tire. The tire that failed was reportedly mounted in the left-rear wheel position at the time of the accident. II. EVIDENCE The subject tire carcass, tread and belts and the subject wheel were examined at my facility in Tucson, AZ. The subject tire is a Goodyear Wrangler Silent Armor Pro Grade radial light truck tire of size LT275/70R18 125/122R LR-E. The DOT number is PJ15 35HV 1609 which indicates it was manufactured at Goodyear/Kelly-Springfield’s Fayetteville, NC plant in the 16th week of 2009. The subject tire had failed by a complete separation of the tread and belts. The three companion tires and wheels were also examined at my facility in Tucson, AZ. All three tires are the same type and size as the subject tire. The right-rear and right-front tires have the same DOT number as the subject tire--PJ15 35HV 1609, while the left-front tire's DOT number is PJ15 35HV 1709, indicating it was manufactured the week subsequent to the subject tire. In my career, I have performed scientific failure analysis on well over 2000 tires. As part of my work as a tire failure analyst, I have also conducted cut tire analysis on more than 700 tires and conducted numerous x-ray and shearography analyses on Goodyear and other manufacturers' tires. I have reviewed numerous documents such as patents, technical papers and government reports. I have reviewed documents on design, testing, manufacturing, quality control and other subjects from all of the major tire companies, including Goodyear. I have published scientific papers on tire failures and developed test procedures and conducted testing on tires. In this case, I have also reviewed the following: – X-Rays of the subject tire and left-front tire – Shearographs of the companion tires 1 Hall 9331 PE000414 – Accident report – Photos of the accident scene and of the accident vehicle – Expert Report of Micky Gilbert – Depositions taken in this case of Gary Smith, Dina Smith, Gerri Hall, Gerry Lynn Wilkinson, Trooper David Hoard and Magan Johnson – Depositions taken in this case of Goodyear employees Kelly King, Richard Scavuzzo, John Renner, Melissa Montisano, Michael Manning, Mike Peterson, Vicki Faircloth and Leroy Morel – Sworn statements taken in this case of Goodyear employees Olivia Parsons, Danny Crawford, Garland Whitley, Ronnie Lewis, Maria Elena Ayala-Sanchez, Exalando "Sean" Quinn and Alton Dale Gautier – Depositions of Goodyear employees taken in Patel v. Goodyear of Exalando Sean Quinn, Maria Elena Ayala-Sanchez and Garland Whitley – Bates numbered documents produced by Goodyear in this case – Advertisements for the Silent Armor tires – Recall documents for the Silent Armor tires – Cut Tire sections of Silent Armor and other Goodyear tires – Numerous publicly available documents listed at the end of this report III. TIRE & WHEEL POSITIONAL REFERENCE For purposes of identification, tire examiners use a clock face to designate regions on the tire. Twelve o’clock is set at the DOT number. This side of the tire is designated the serial number side (SS). The opposite side uses a reversed clock face and is designated the opposite serial side (NSS). A reversed clock face is used so that adjacent sides of the tire will have the same clock designation. This tire was also marked with degrees to facilitate x-ray analysis. This same clock designation is used to identify regions on the wheel. For the wheel, twelve o'clock is set at the valve stem. SERIAL SIDE (SS) NON-SERIAL SIDE (NSS) 2 Hall 9331 PE000415 IV. EXAMINATION The subject tire and separated tread and belts were examined at my facility in Tucson, AZ. Photographs, notes, measurements and x-rays were taken during these examinations. The subject tire was also examined using magnification devices. This examination followed accepted scientific methodology. The subject tire experienced a complete separation of its tread and belt package from the carcass. One large detached piece of tread and belts was recovered and examined. The tire was received by my office mounted on its wheel with the hub assembly still attached. The tire was mounted non-serial side outboard prior to being dismounted from its wheel at my office. During my examinations, the following observations were made: The SS bead has minor pressure grooves while the NSS bead was chewed up by accident damage. There are no radial splits in the NSS (outboard) sidewall or the SS sidewall. There are some gouges in the NSS sidewall. The outer surface of the carcass is devoid of both steel belts. The cushion rubber exhibits pattern marks, smooth rubber and knit lines on both the SS and NSS. The cords of the carcass plies are abraded and broken due to the road contact during the accident event. The carcass plies in the crown are devoid of skim rubber. The tread and steel belts separated from the carcass in one large piece. At both ends of the detached piece of tread and belts, there is belt to belt separation between the belts from approximately 240 to 270 degrees at one end and 285 to 350 degrees at the other end. The belt wire cables are heavily corroded especially under the major tread grooves. There are areas where the steel cord of belt 2 are virtually in contact with the aramid (a blend of Kevlar and nylon) cap ply cords. An example of this phenomenon is at 285 degrees under the major tread groove on the NSS, as shown in the photo below: 3 Hall 9331 PE000416 There is minimal undertread between the bottom of the major tread grooves and the cap ply cords. There are areas where the cap ply is visible on the outside of the tread. The remaining tread depths measure approximately 6/32" in groove 1, 5/32" in groove 2, 4.5/32" in groove 3 and 5.5/32" in groove 4. There is moderate gravel road wear in the tread. The x-rays show multiple areas of damage to steel belt 2 around the circumference of the tire as a result of stone drilling and corrosion. There is a large dog-ear splice in steel belt 2 located at 210 degrees SS that measures approximately 0.11". The other end of this splice was located at approximately 270 degrees NSS, an area where belt to belt separation occurred, but this portion of belt 2 was not recovered. The inner liner shows no evidence of puncture, over-deflected operation or pre-accident impact. The minimum inner liner thickness was measured to be .033” which is far below Goodyear’s specified minimum of .050”. The subject wheel is a Ford OEM alloy wheel of size 18 x 7.5J with a date stamp of August 3, 2007. The valve stem is a TR-414 and appears to be in good condition as does the valve core. The three companion tires were received by my office mounted NSS outboard. The tires were dismounted from their wheels and examined. The tires exhibit wear similar to the subject tire and appear to have been placed into service at the same time as the subject tire. The remaining tread depths of the right-rear tire measure 5.5/32" in groove 1, 4/32" in groove 2, 4/32" in groove 3 and 5/32" in groove 4. There are multiple areas around the circumference of this tire where the cap ply can be seen in the tread area. The remaining tread depths of the leftfront tire measure 6.5/32" in groove 1, 6.5/32" in groove 2, 7/32" in groove 3 and 7/32" in groove 4. The remaining tread depths of the right-front tire measure 5.5/32" in groove 1, 5.5/32" in groove 2, 6.5/32" in groove 3 and 7/32" in groove 4. Shearography of the left-front tire shows localized separations in multiple locations around the tire. This tire was also x-rayed and found to have damage to steel belt 2 in multiple locations around the tire as a result of stone drilling. No through punctures were found in the right-rear tire or right-front tires. The left-front tire had a nail through the inner liner at 65 degrees in rib 2. All of the companion wheels are the same type and size as the subject wheel with the same manufacturing date. The subject vehicle came originally equipped with P275/65R18 tires with an optional size of LT275/65R18 LRC. The subject tire and companion tires are slightly larger size at LT275/70R18 LRE and were capable of carrying a larger load. V. TIRE MANUFACTURE There are four main stages of tire manufacture: rubber mixing, component assembly, tire assembly and curing (Tire Building Videos). 4 Hall 9331 PE000417 A. Rubber Mixing In the manufacture of steel belted radial tires, each rubber compound goes through a mixing process where additives are added at different points. Tests are conducted which are used to check the compounds at this stage. The rubber is in the “green,” uncured stage at this point. It is soft, sticky and has little strength. There is a time limit for most compounds from the time of mixing to its curing in the finished tire (Tire Building Video: From The Milk Tree). B. Component Assembly A tire is constructed from rubber compounds, steel wire formed into bead grommets and into cords for the tread belts and polyester cords for some carcass plies. Rubber components requiring complex shapes such as the sidewall, tread and fillers are extruded. Extruders are essentially pumps that force the green rubber through a shaped hole to produce extended lengths of material of the defined cross-sectional shape (Tire Building Videos). Rubber components that are flat such as the inner liner and the skim stocks are formed by rolling between two parallel rollers. This process is called calendaring (Tire Building Videos). Steel belts are made from wires that are coated with brass to greatly improve their adhesion to rubber. They are then twisted with other wires to form cords. Many cords are laid parallel and then, in one process, pressed between two sheets of skim stock rubber to form sheets of the steel belt assembly. This assembly is cut and reassembled to facilitate the manufacturing process and to conform to the tire design requirements (CE000014, 15 & 280). The components are transported through the factory by conveyors made of an open weave fabric or placing them on plastic sheets with a surface pattern. The open weave fabric and patterned plastic are used so that the green rubber does not stick to these carriers. The pattern of the plastic and fabric transfer to the tacky, uncured rubber surface (CE000044 & 45). C. Tire Assembly Tires are assembled on an expandable drum-like machine. The components are laid on the rotatable drum. The tire at this time has a cylindrical appearance instead of a donut-like shape. The inner liner, beads, bead filler, sidewalls, chaffers and protectors, if used, and belt fillers are assembled at this time. The tire is then conformed to a more tire-like shape for the assembly of the steel tread belts and tread rubber (Tire Building Videos). At the end of this process, the tire is still in the green or uncured state. The tire is held together by the stickiness of the green rubber. It is weakly bonded, and therefore, the tire must be carefully handled. 5 Hall 9331 PE000418 D. Curing The green tire is placed into a mold where the tire is cured. The curing mold or curing press subjects the tire to high temperatures and pressures for a specified time. During this process, the tread design, sidewall markings and other surface features are molded into the tire and the rubber is cured or vulcanized into its cured state. During the curing, all of the rubber compounds adjacent to each other form chemical bonds with each other, the steel belts and plies adhere to the surrounding rubber and the rubber compounds change chemically. It is intended that all discontinuities between the components of the tire be eliminated in this process. Before curing, rubbers are soft, sticky and relatively weak. Afterwards, they have strength, flexibility and elasticity without surface tackiness. VI. TIRE DESIGN Tires are designed to carry a vertical load, to develop traction for cornering, braking and acceleration, to cushion the vehicle ride and to last without failure for many thousand miles, among other requirements. Tires carry the load primarily by the internal air pressure. The structural stiffness of the sidewall of un-inflated radial tires is only equivalent to that of a few psi of inflation pressure. A tire carries a load that is directly proportional to its inflation pressure. This relationship is specified in the load-inflation tables found in the Tire and Rim Association (TRA) Yearbooks, tire manufacturers’ yearbooks and many other trade publications (CE000281 & 282). In fact, tire companies know that their tires are frequently subject to underinflation in highway use and build a safety factor of approximately 20% into their tires over the published load-inflation tables (CE000283). Tires are also rated for speed. Passenger tires are rated for maximum speed, but the tire companies do not recommend sustained running at or slightly below these maximums (CE000147). Tires have three main sections: the tread, the sidewall and the bead. Some of the functions of the tread are that it is designed to provide traction for cornering, braking and acceleration, puncture protection, wear resistance and vehicle handling. The structural elements of the tread are the body ply and the steel belts. The edge of the steel belts is the most critical area of a steel belted radial tire (CE000007). This is because they are located at a hinge point at the junction between the very stiff tread/steel belt structure and the flexible radial sidewalls. There can be very high stresses in this area. Several design measures are available in order to reduce the stresses concentrated in this vulnerable area. These include: 1. The tread belts arranged to be of differing widths so the edges of the belts are not adjacent to each other. This causes the flexing and the associated stresses at the belt edges to be spread over a larger area. 6 Hall 9331 PE000419 well. 2. Layers of extra skim stock rubber laid near the edges of the belts or between the belt edges to provide more cushioning and adherence at the belt edges and to reduce the intra-ply stresses. These components are called insulators or wedges (CE000140 & 461). 3. Belt fillers used between the edge of the bottom belt and the carcass ply. This is usually a triangular shaped section of rubber used to stiffen and mitigate the hinge effect in this region. 4. Nylon belts at a 0° orientation to the median equator of the tire tread which can be used to overlie the belt edges. Specially treated nylon which contracts with increased temperature is employed to reduce the adverse influence of manufacturing defects, high speed use, high operating temperatures or other conditions which promote separations (CE000027, 28 & 32). 5. Another countermeasure which is normally employed is an insulation layer over the edge of the top belt. This makes up for rubber gauge lost during the manufacturing process and prevents tread rubber from contacting the belt edges (CE000346). Other design components have been found to severely affect tread-belt separations as 1. The adhesion between the steel and the rubber was a critical factor in the early radials. Most manufacturers have learned to control the wire drawing operation and the creel room operation as well as found the proper additives that promote good adhesion. However, careless manufacturing and controls can still cause this failure. Wire design also played an important part in this problem. 2. The deterioration of the skim stock or other materials can be reduced by additives which reduce this degradation, by good inner liner materials, and by designs which minimize the internal running temperatures of the tires (CE000009, 55 & 388). 3. In the early eighties, manufacturers started using under treads to reduce rolling resistance. An under tread is a separate layer of rubber in the tread that is formulated with a rubber that has little hysteresis or resistance to flexing. An added benefit is that the tire runs cooler in the tread area and is more resistant to separations. The sidewall constrains the air pressure, withstands the flexing under use and occasional impacts with curbs, etc. The sidewall is very flexible and is composed structurally of the body ply and the sidewall rubber. 7 Hall 9331 PE000420 The bead region’s main purpose is to anchor the body ply, resist inflation pressures and seal air pressure with the rim. The bead region consists mainly of the bead wires, the ply turnups and the chaffers and protectors, if used. An important part of the tire that is found in all three areas is the inner liner. The inner liner is the “tube” of a tubeless tire. Made of a special rubber that is relatively impermeable to air flow, it not only keeps the tire from deflating but extends the life of the tire by preventing oxygen and moisture from entering the internal tire structure. Breaches in the inner liner will drastically shorten a tire’s life and cause premature failures (CE000042, 55, 383, 385 & 461). VII. TIRE FAILURE MODES 1. Material Failure Modes Materials fail because the stress on the material is too large for the strength of the material or because the strength of the material is too low for the applied stress. A corollary to these cases is when the material starts out relatively strong enough but weakens with aging deterioration to the point where it fails. The mode of failure for tires is the same mechanisms that other structures fail. These modes of failure include overload, fatigue, defects and corrosion. Overload is a failure from a one-time event. In tires this would be equivalent to a blow out due to an impact with a curb or sharp road hazard. Fatigue is a repetitive stress failure requiring often hundreds of thousands or millions of stress-cycles before failure occurs. Corrosion failures occur usually because the material is weakened with time to a point where its strength is insufficient to withstand the applied stress. Defects in the material hasten the onset of any of these failure modes. Tires, like other structures, can fail by overload. This is the case where a single catastrophic event, such as rolling over a large piece of metal in the road, cuts the tire and it fails. That is, the materials are subjected to a one-time stress that exceeds their strength (CE000285). Tires can also fail by fatigue or repetitive stress failures. Separations are primarily a fatigue failure. These failures may take many millions of cycles to cause a failure. A typical size tire rotates 700 times per mile, so a tire with 40,000 miles would have 28 million rotations or cycles. This is neither uncommon nor unexpected. Tire designers design for these conditions. Fatigue failures in most materials follow three stages. In the first stage, the material flexes without visible effect, but the material is weakening. This is sometimes called the embryo stage. In the second stage, a crack forms and propagates. In the third stage, the material fails in the final portion by fracture (CE000285 & 522). Tires that fail by separation on the highway do so in the same three stages. A tire that fails may operate for an extended period in the first stage, usually approximately 2 years. In the second stage, the separation forms and propagates. In the third, the tread and belt(s) are thrown from the carcass. The first stage lasts two years or more, the second stage lasts a couple of thousand miles, while the last stage occurs over a hundred feet or so. One aspect of the fatigue failures of tires that is particularly troublesome is that the tire materials normally deteriorate or age adversely affecting their fatigue properties. The fatigue life of the body of the tire should be much greater in miles than the tread wear life. The preferred 8 Hall 9331 PE000421 reason for removing a tire is that the tread wears out, not that the tire structure fails, which is a very serious event (CE000287). The design goal is for a tire to wear out in stage one. Tire manufacturing defects cause and accelerate the failure process so that the tire fails much sooner (CE000004, 7, 285, 286 & 328). Strict quality control decreases the rate of this process of deterioration, as also do certain design safety measures (CE000004 & 27). Any type of manufacturing defect that reduces the initial strength of the components or their bonding to each other will reduce the fatigue life of the tire. Many different manufacturing or design defects can cause the tire body to fail before the tread wears out (CE000004, 44 & 45). Tires can also fail by corrosion. The wire in the steel belts is particularly vulnerable to corrosion that will affect its adhesion to the adjacent rubber. The wire cord design can drastically affect the durability of the carcass as well as the type and amount of anti-degradants. All tires that are run under normal conditions “heat up” as they are run. This is normal and expected. Rubber has a characteristic called hysteresis, which causes the rubber to generate heat as it is flexed—the more flexing the more heat. Temperature effects are and should be considered by the tire designer. The tire internal temperature also rises with increased ambient temperatures. This is also accounted for by competent tire designers. 2. Tire Tread-Belt Separations A tread-belt separation is a fatigue failure mode in steel belted radials which usually starts as a tiny crack at the edge of the outer belt (CE000140). The cracks start at the end of the belts because ends of the belt wire are not coated with brass and therefore have virtually no bonding to the adjacent rubber and because the belt edge is an area of high stress. The high stress is caused by the hinge point effect at the end of the belts. The transition from a relatively stiff steel belt to a relatively flexible carcass produces a natural hinge point and stress concentration. This area was found to be the critical element in the design of radials very early in their history. Consequently, internal temperature measurements will show that this region is the hottest part of a running tire. As discussed in another part of this paper, designers have reduced this hinge point and the subsequent high stresses effect by the use of stepped belts, cushions, nylon overlays and wedges. Once the radial tire develops belt edge cracks, the crack will proceed inward through the rubber of the wedge or skim stock, the rubber layers’ interface or at the rubber-steel interface. Photographs in Ford’s Root Cause Report and Dr. Govindjee’s Firestone Report show this progression, while an article written by Dick Baumgardner in a 1985 Retreader’s Journal describes this failure mechanism in detail as does the more recent DOT study. This crack progresses circumferentially around the tire and laterally across the tread until the circumferential force of the tread and outer belt overcomes the remaining areas of adhesion and the tread and belt(s) detach. In the case of the subject tire, the corrosion to the outer belt caused a breakdown of its adhesion to the bottom belt in certain locations, resulting in a belt to belt separation. During the 9 Hall 9331 PE000422 final catastrophic failure phase, both belts detached from the carcass as a result of centrifugal force and reduced adhesion in the cushion area. 3. Tire Company Defenses The tire companies will most certainly blame under-inflation or over-loading (overdeflection), impact, cuts in the tread and/or punctures/improper repairs as the cause of the separation. In fact, there is no scientific evidence that any of these cause tread-belt separations of this type. There is actually strong evidence that most of these factors do not cause separations. Underinflation or over-loading (these conditions are often described by tire engineers with the single term over-deflection) generally produces a sidewall failure. B.F. Goodrich published two studies in the 1980’s where tires were run for long distances at over-deflected conditions and did not produce separation failures. In one study, they holographed the tires at the end of the test because they had expected tread-belt separations. They did not find even the initiation of a separation (CE000036 & 37). Standard Testing Laboratories, Inc. (STL) ran a series of tires at 63% over-loaded for 20,000 miles and did not fail the tires (CE000070). These tests show that under all practical, real world conditions, a properly designed and manufactured tire will not fail by tread- belt separations. During the investigations of the Firestone ATX and AT tires, it was found that FS had several hundred times the separation failure rate as a similar Goodyear tire. In fact, the GY tire had virtually no separations. Approximately 3 million FS and GY tires were mounted on Ford Explorers during the same three year period (CE000140). It is inconceivable that only the Firestone owners over-loaded or under-inflated their tires, had impacts to their tires or had punctures or improper repairs to their tires. It should be noted that the Goodyear tire had a much larger wedge and ran much cooler than the Firestone tire. Ford indicated that the use of proper tire technology can make a tread-belt separations virtually nonexistent (CE000107). A recent paper published in the SAE journal showed that over-deflection does not produce tread-belt separation failures even in aged tires (CE000647). There have been no scientific studies that link over-deflection or any of the indicators of over-deflection to tread-belt, fatigue separation failures. There are, in fact, many studies that show that over-deflection does not cause tread-belt separations (CE000036, 37, 163, 647 & 691). The manufacturer will probably opine that the failed tires had been impacted by a “road hazard” up to 15,000 miles before the failure which weakened the tire and eventually produced the separation failure. The Goodyear tire experience related above is one example of how that is a technical impossibility when the tire is properly designed and manufactured. Second is the fact that no tire company has ever produced testing evidence that it can even occur. Further, there are no technical papers or patents that I am aware of showing this effect. Because rubber has approximately twenty times the flexibility of steel, any deflection in the tire produced by an impact would necessarily break or deform the steel before the rubber. Most impacts produce an immediate L or T-shaped side-wall failure. The Standard Testing Laboratories (STL) paper which has been used to support this theory, in fact, supports the opposite conclusion. This paper’s conclusion states that they were able to damage the tires (with a fixture that was not 10 Hall 9331 PE000423 designed to replicate any real road object) and “this may lead to further damage”. There was no mention of what actual damage they imagine and the word separation was not used. This is extremely indefinite and not in any way a scientific conclusion or, in fact, relevant to real world impacts on tires. There have not been any scientific studies to link impact to tread-belt, fatigue separation failures. I have conducted testing that demonstrates that impact does not cause tread-belt separations. This work was published in a paper by the Society of Automotive Engineers (CE000780). Tire punctures and improper repairs can produce failures in modern tires but they rarely produce a separation failure. The Goodyear-Firestone comparison related above is a good example of the fact that punctures do not cause tread-belt separations. Data produced by Firestone comparing the recalled tires to the failed, claims tires purported to show an effect of punctures but if the data is correctly analyzed, it shows no significant difference between the failed (separated) tires and the recalled tires. About 30 years ago, tire companies started using low void cable designs that virtually eliminated puncture and tread cut complications. There have not been any scientific studies to link punctures or repairs to tread-belt, fatigue separation failures. The responsibility for these types of separation failures lies solely with the tire company and not with the tire user. Ford stated in their tire report that "it has been perfectly feasible, for many years, to design and manufacture tires with separation failure rates approaching zero…” (CE000107). This has been verified in testing and real world experience. The manufacturer may also allege that this tire met all government (DOT) standards. First, this tire did not meet the government standards since the DOT endurance tests are destructive and would have destroyed this tire. DOT tests are run on samples, usually one or two tires a month out of a plant that can produce 40,000 tires a day. Secondly, the DOT tests were developed in the 1960’s during the bias ply era and failed to detect or predict the separation problems of the Firestone 500 in the 1970’s, the Firestone ATX and Wilderness of the 1990’s, or the Goodyear, General, B.F. Goodrich and Uniroyal separation problems. These tests have been updated as a result of the Tread Act. VIII. DISCUSSION & CONCLUSIONS 1. The fundamental responsibility of an engineer is to identify potential risks, hazards and dangers that can cause serious injuries including death. Several engineering techniques used to identify potential risks, hazards and dangers include dfma, fmea, fault tree analysis, risk hazard analysis, root cause analysis and engineering triad analysis. Each of these engineering techniques has been used for decades. Once potential risks, hazards and dangers have been identified, including common patterns of misuse and abuse, a designer and manufacturer must try and eliminate/design away the hazard. If the hazard cannot be eliminated, then the hazard must be guarded against. If neither elimination nor guarding 11 Hall 9331 PE000424 against hazards is possible, the hazard must at least be warned about (CE000025, 53 & 424). When thorough testing and engineering is not conducted, a defectively designed and manufactured product can be introduced into the marketplace. The subject tire was designed as an All-Terrain light truck tire. The advertising stressed its toughness, its suitability for use on gravel and unpaved surfaces Yet, it was particularly susceptible to a failure from this very usage which resulted in Goodyear recalling approximately 41,000 tires, including the subject tire, in February 2012. According to Goodyear, it received in the Fayetteville plant. The subject tire failed by a complete separation of the tread and belts. This separation was caused by moderate gravel road wear which produced holes in the tread rubber that extended into the undertread, the cap ply and steel belt 2. The resulting corrosion caused a marked decrease in the belt adhesion which lead to the separation failure. This failure mode was facilitated by the design in the tread and the minimal undertread, as well as the infiltration of the aramid cap ply into steel belt 2. The tread design used in the subject tire is a design defect, while the inadequate undertread and the infiltration of the cap ply into steel belt 2 are both design and manufacturing defects. 2. A tire depends on the adhesion between its components and the physical strength of these components to withstand the normal stresses it experiences in use. Each piece of rubber must bond to its neighbor during curing, and each wire in the belts or plies must bond to the adjacent rubber (CE000061). Each piece of rubber must be manufactured correctly, have the correct antidegradants mixed in and be cured properly. Additionally, each component must be placed properly in relation to its adjacent components. When these processes are not correctly accomplished, premature failures can occur during normal and expected usage. 3. The Goodyear Wrangler Silent Armor Pro Grade Technology tire line was designed with . Stone drilling is a term of art in the tire industry to describe a certain failure mode. The classic stone drilling failure mode occurs when a stone is trapped in a groove of the tread design and is pushed through the rubber into the belt materials causing a corrosion failure. Two classic countermeasures which are partially incorporated into this tread design are . These countermeasures were not effective as they are not incorporated in all the grooves. Additionally, the main grooves are too wide in that they would allow stones to contact the tread groove base directly from the pavement. This defect is validated by x-ray analysis of the subject tire and one of the companion tires which show belt damage in the main grooves, the smaller grooves and the tread blocks. It is significant that the tire designer for the subject tire had never heard of 12 Hall 9331 PE000425 There are other countermeasures to stone drilling which do not appear to have been incorporated into this design. One is the use of a small tread lateral radius which concentrates the stone damage to the tread center. This tire has an unusually large tread lateral radius (flat tread) which is not only unusual for all-terrain tires but for most highway tires as well. Another classic countermeasure is the use of a tough, chip resistance tread rubber. There are numerous cuts, slices and penetrations to the tread area of the subject and companion tires. However, the relatively low amount of gravel road damage shows relatively little gravel road use and it is surprising that this resulted in a catastrophic failure. One accepted test for stone drilling resistance is called a salt test. This involves running a candidate tire design on gravel roads with a periodic salt water bath. This tests the penetration resistance and corrosion resistance of the tire design. Although Goodyear The property damage claims data for the recalled tires show 4. The Wrangler Silent Armor tires are a line of Goodyear light truck tires that boast of a unique feature--a cap ply using aramid fiber rather than nylon. The aramid fiber (five times the strength of steel and used in bulletproof vests) was to provide a strong belt structure. The aramid belts are in fact a Kevlar-nylon blend. Nylon cap plies have been used for approximately 46 years to reinforce radial tires and prevent or reduce separation failures. It is unknown whether . This question was asked of the did not know. However, Goodyear designated tire designer, In the 1990s when Goodyear was experiencing a large number of tread-belt separations in its LT tires, it incorporated nylon cap plies into these tires and found that they were effective in greatly reducing separations (CE000026, 447, 680, 805 & 806). It is clear from the depositions of Goodyear's corporate representatives that the decision to use aramid belts--to give the "impression of toughness"--was 5. The subject tire is defective in manufacturing in that there is a large dog-eared splice in steel belt 2 that was in the failure zone. This indicates a variation in tire assembly practices and little quality control. Additionally, this variation in the belt offset caused additional stress at the belt edges, precisely in the area where the belt to belt separation occurred in the subject tire. The subject tire was also defective in manufacturing in that it exhibited liner pattern marks, knit lines and smooth rubber. All of these conditions indicate trapped air and reduced adhesion during the manufacturing process as well as poor quality control at Goodyear's Fayetteville, NC plant (CE000044, 45, 82, 84, 475, 13 Hall 9331 PE000426 476, 513, 514, 640, 758 & 837). After the initial belt to belt separation, the entire belt package separated from the carcass. The aforementioned adhesion defects are evidence that there was substandard adhesion which facilitated this failure mode. The adhesion defects found in the tire are a result of the use of over-aged materials and/or contamination. According to Fayetteville plant workers, both of these conditions existed at the plant. Contamination includes oil, water, sweat and dirt, all of which existed at the Fayetteville plant and builder stations. The plant had leaky roofs that required tarps and buckets to be mounted over the tire assembly machines. The tire assembly workers reportedly sweated because of frequent high temperatures in the plant and the demanding work load. Workers stated that the plant had very poor housekeeping. Overaged materials refer to the time limit that is placed on green (uncured) rubber and rubber components. Green rubber has a time limit, usually two to three weeks where it must be assembled into a tire and cured before the rubber properties change and become unsuitable. The tire assembly workers often found problems with overaged materials because one of these properties is green tack, and a loss of tack makes it very hard to manufacture a tire and reduces cured tire durability. One tire worker reported sending green material back but the same material was subsequently returned to her. This is an indication of very poor or non-existent quality control and a sacrifice of quality for quantity. All of the manufacturing defects found in the subject tire indicate a lack of inspection which is further supported by the testimonies and statements of plant workers. Tires built to the subject specification failed An investigation revealed that a likely cause Instead of searching for the root cause The second batch of tires This incident shows very poor engineering in several ways. First, Second, 6. I have performed cut tire analysis (CTA) of exemplar Goodyear light truck tires. Three of these tires were Wrangler Silent Armor Pro Grade tires, two of which were included in the recall and a third tire that was manufactured in 2012. Also examined for reference was a Wrangler HT manufactured in 2002 that incorporated a nylon cap ply and a Wrangler S/A manufactured in 2005 that incorporated an aramid cap ply. The principal difference noted amongst these tires was that the two recalled tires had significant pinching below the tread groove and between the cap ply and steel belt 2. One of the 14 Hall 9331 PE000427 recalled exemplar tires, shown in the photo below, actually exhibited infiltration of the cap ply into steel belt 2, the same condition that was found during my examination of the subject tire. Significantly, Mr. Richard Scavuzzo, a Goodyear engineer, testified that He described this phenomenon This is bad practice that promotes unacceptable manufacturing variations as seen in the subject tire, my cut tire analysis and recall investigation. 7. A review of the tire specifications produced by Goodyear showed rubber compounds for the cap ply skim stock and both of the undertreads compound for the cap ply skim stock and one of the undertreads 15 Hall 9331 PE000428 date of the subject tire and at the end of the production period included in the recall. Also, the . 8. Goodyear first noticed an increase in property damage claims in the subject tire line This is inexcusable. Further, according to Mr. Scavuzzo's testimony, Goodyear attempted . This philosophy is completely mistaken and self-serving. 9. The size of the subject in this application had no effect on its failure. There are no indications of underinflation, overloading, road hazard impacts, through punctures or high-speed use. These conditions are sometimes referred to as abuse factors and have been discussed separately above. These factors cause tire failures but will and should not cause a fatigue tread-belt separation in a properly designed and manufactured tire. To do so would belittle 60 years of development to eliminate this most dangerous failure mode. 10. The design and manufacturing defects listed above, including but not limited to poor design and manufacture for stone drilling and corrosion resistance, poor belt placement, poor adhesion and inadequate testing, caused the tread-belt separation failure of the subject tire. 11. I have discussed my failure analysis with other tire failure experts, and they agree with my methodology, analysis and conclusions. IX. EXPERIENCE AND QUALIFICATIONS My experience and qualifications are as follows. I have a Bachelor of Mechanical Engineering (B.M.E.) degree from the Georgia Institute of Technology. I also have a Master of Science in Mechanical Engineering (M.S.M.E.) degree also from the Georgia Institute of Technology. Mechanical engineering is the branch of engineering that is concerned with the implementation of the sciences of thermodynamics, heat transfer, fluid flow, materials and machine design into practical devices for industry and for consumers. The branch in which I specialized was machine design which involves the design of machine elements and systems. Machine design incorporates stress analysis, failure analysis, testing, mathematical modeling, material properties and statistics. I am a registered professional engineer registered in the state of Georgia. On the test for registration, I scored in approximately the top five percent. 16 Hall 9331 PE000429 I was a tire designer and tire test engineer for Michelin Americas Research a Development (MARC) for approximately ten and one-half years. For the ?rst one and one?ha] years I was involved with indoor testing of passenger, light truck and heavy truck tires. This involved measurement testing of rolling resistance and cornering force and endurance testing of road wheel endurance. DOT testing, ozone resistance. bead strength. and inner-liner testing. Secondly. for approximately four and one-half years, I was a tire designer responsible for the development of new tire designs and the modi?cation of existing designs that were being introduced into the stream of commerce. This involved the initial design, manufacture and testing of prototypes. creation of new test procedures. startup of regular production. and monitoring of performance in the ?eld. Included was modi?cation of tire designs to improve the tires resistance to tread-belt separations with testing to validate design changes. Thirdly. I was involved in adherence measurement and endurance testing at a test track facility for approximately ?ve years. I ran the Michelin tire separation resistance test and other endurance tests at this location. Endurance testing consists of running tires under carefully controlled conditions to produce a speci?c failure. such as tread-belt separation failure. and analyzing the results. During my career at Michelin. I tested hundreds of tires to failure and analyzed the results. At my exit interview, I received a letter stating that I had been ?a valued member of the Michelin team?. Since leaving Michelin, I have been an independent tire consultant for approximately 25 years. I have examined and performed failure analysis on more than two thousand tires. I was involved on some of the earliest Firestone ATX tread separation failures, two of which were the ?rst to reach national attention. I was the expert chosen to assist the group of Attorney Generals from all ?fty states in their investigation of the Firestone separation problem. I have also investigated the ?les and test results regarding tread separations from several tire manufacturers including the Goodyear Light Truck tire tread separation problem. These tires were modi?ed to eliminate tread separations by adding nylon overlays. which was effective. My opinion that nylon overlays are practical, feasible and would have prevented the subject tread separation is further supported by Mr. Rex Grogan?s book (CE000044 45) as well as learned treatises on the subject by Mr. David Osborne. Dr. Alan Milner and Mr. Ronald Smith (CE000321-323). I was one of the ?rst independent tire experts to champion nylon cap plies for separation resistance. As discovery is ongoing in this matter, I reserve the right to supplement and/or modify my opinions as new information is made available. a .77 7 kit/MM Dennis Carlson, RE. 17 Hall 9331 X. REFERENCES Note: The use of references does not imply that the author of this paper agrees with every aspect of every reference. 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