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.
Note that member login is required to view Tech Connections articles
and OEM body builder information. For personalized login assistance, contact
NTEA Membership Coordinator Emily Herberholz at 1-800-441-6832, ext. 134, or
emily@ntea.com.