Developing FMVSS Compliance Documentation Part One

This article was published in the September 2014 edition of NTEA News

Question: We are a truck dealership and are now branching into building our own new vehicles from the chassis we sell. We attended the recent NTEA webinar on certification and, while we have the labels, we would like to know more about the paperwork necessary for certifying the vehicles that we build.

Answer: As you hopefully gathered from the webinar, as well as the NTEA’s other certification resources, certification is more than just putting a label on the vehicles that you complete. The labels are probably the most visible step in the certification process, but they are really the last step. The conformity statement on the final-stage labels reveals the ultimate responsibility of the company manufacturing a new vehicle — to represent that the vehicle “conforms to all applicable Federal Motor Vehicle Safety Standards (FMVSSs).” Making this representation goes well beyond the function of just labeling the vehicle.

The materials you’ll develop to support your representation of compliance to these standards starts with understanding the different FMVSSs, including which ones must be met for the vehicles you build, and then documenting the rationale to support how the requirements of these standards are met. Developing and documenting your compliance rationale is not a “one-and-done” event — certification and FMVSS compliance are part of an ongoing process, so you will be best served by preparing the groundwork around this fact. 

 

It is highly recommended that you begin this process by designating someone within your organization to become familiar with the various regulations, including the FMVSSs and associated certification requirements. The chassis on which you build will change; the OEM engineering methods (to meet different FMVSSs) will change; and, like other regulations, the FMVSSs will evolve and increase in stringency. As such, having an internal champion for your vehicle certification responsibilities will help you manage this process (see the “Additional Compliance and Certification Resources” section below for links to reference materials for FMVSSs and associated National Highway Traffic Safety Administration regulations).

 

Incomplete Vehicle Documents
The FMVSSs themselves are performance-based requirements for different vehicle systems and required equipment, so these regulations are more related to the function of a particular aspect of safety rather than the system or equipment design. While these regulations may be daunting to read, a good way to become familiar with their individual requirements is to review the incomplete vehicle documents (IVDs) from the OEMs of the chassis upon which you intend to build. These documents are required to be supplied by the OEM of the incomplete vehicle and are typically shipped in the glove box, included in a sleeve in the cab or otherwise included in dunnage with a new chassis. 

 

Reviewing the IVDs is a necessary next step in developing your compliance rationale anyway, so reading them will not only offer familiarity with the FMVSSs and insight into their requirements, but also serve as a framework for the compliance rationale of your completed vehicles. Some OEMs provide a convenient chart in their IVDs that show which FMVSSs apply to the vehicle types and gross vehicle weight rating you are completing. This will help identify the range of FMVSSs you will need to address. Additionally, a reference summary of the FMVSSs is contained in the NTEA’s Truck Equipment Handbook as well as on the National Highway Traffic Safety Administration’s website at www.nhtsa.gov/staticfiles/rulemaking/pdf/FMVSS-QuickRefGuide-HS811439.pdf.

 

OEMs will cover as many chassis and variations as possible with individual IVDs for reasons of efficiency, so the same document will typically address a “family” of chassis models. Reviewing these documents ahead of time allows you to begin developing your compliance rationale before receiving a certain chassis. Although checking for updates is important, the IVDs typically change when FMVSSs and/or chassis change, so reviewing these documents at the beginning of a model year to create your rationale for the upcoming year puts you in a position to just monitor for changes. Ideally, this will enable you to determine the combinations of bodies/equipment/chassis you will be able to certify so you can avoid contracting or advertising to build vehicles for which you are unable to establish compliance with all of the applicable FMVSSs.

Next Time
Part Two of this series will explore IVD conformity statements for different FMVSSs and how to use them in the development of your compliance rationale.

 

Additional Compliance and Certification Resources
As a manufacturer of motor vehicles, you will need to become familiar with a number of federal regulations, even if only to understand that some may not currently apply. For example, manufacturers need to have an understanding of the Early Warning Reporting requirements, even if they are not subject to the quarterly reporting requirements due to applicable vehicle production levels falling below the established thresholds. (See the November 2013 Tech Connections article, What’s New with Early Warning Reporting?)

 

The following resources are recommended for anyone with compliance and certification responsibilities:

 

  • National Highway Traffic Safety Administration’s New Manufacturers Handbook
  • Current FMVSSs
  • NTEA’s Multi-Stage Vehicle Certification Guide
  • Tech Connections articles on certification, various FMVSSs, the Incomplete Vehicle Document, and more
  • OEM body builder websites — Visit www.ntea.com/content.aspx?id=970 and select the “Technical” link next to the name of any of the OEMs.

 

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