Comment Log Display

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.