Manufacturer defect reporting requirements in the work truck industry

By Bob Raybuck, NTEA Director of Technical Services

This article was published in the February 2017 edition of NTEA News.

Many work truck upfitters understand that as motor vehicle assemblers, they are considered manufacturers by the National Highway Traffic Safety Administration (NHTSA) under vehicle certification regulations (49 CFR Part 566).

Additionally, they know they are responsible as final-stage manufacturers to certify the work trucks they alter or complete from incomplete vehicles to the required Federal Motor Vehicle Safety Standards. However, some do not fully understand their duties and obligations for maintaining records and documentation involved in their vehicle manufacturing operations.  

Most upfitters are aware of NHTSA’s early warning reporting requirements, as part of 49 CFR Part 579—Reporting of Information and Communications About Potential Defects. Based on the number of vehicles produced annually, early warning reporting requirements may not apply to a large number
of upfitters.

However, also under Part 579 is section 579.5, which requires upfitters (those defined as manufacturers by NHTSA) and motor vehicle equipment manufacturers, installers and assemblers to provide copies of all documents sent or made available to more than one dealer, distributor, owner, purchaser, lessor or lessee in the United States concerning customer satisfaction campaigns, consumer advisories, recalls or other activities involving the repair or replacement of vehicles or equipment. This involves all communications regarding any defect in its vehicles or equipment, including any failure or malfunction beyond normal wear and tear, performance failure, or flaw or unintended deviation from design specifications whether or not the defect is safety-related.

The communication must be submitted to NHTSA so it can determine whether or not a safety issue is involved and to engage in proactive communications with manufacturers where NHTSA believes there is a misunderstanding or misidentification of the risk or particular issue. These communications must be submitted to NHTSA no later than five working days after the end of the month in which they are of issue.

This requirement applies regardless of the number of vehicles or pieces of equipment manufactured or assembled. It impacts all facets of the work truck industry, from upfitters and body and equipment manufactures to alterers and final-stage manufacturers as well as importers of such equipment and vehicles for resale.

Learn more
NHTSA representatives will present a concurrent session, NHTSA Reporting Requirements for Multi-Stage Manufacturers, on March 15 from 9:30–10:45 a.m. during The Work Truck Show 2017 at the Indiana Convention Center in Indianapolis, Indiana. Presenters will address the various reporting requirements and help attendees understand what information should be provided to NHTSA to reduce risks and potential fines. Register for this informative session to get your questions answered about the documentation you must report to satisfy your communication requirements.

Visit for more details about the 2017 event, including a schedule of sessions and registration options.