This article was published in the November 2013 edition of NTEA
News
Question: We are a truck equipment distributor and
have heard that there are some new changes to the early warning reporting (EWR)
requirements that may impact our company. We have not been able to connect with
the National Highway Traffic Safety Administration (NHTSA) due to the government
shutdown, so can you please help us understand which new requirements we need to
meet?
Answer: Between engine controls, transmission
controls, anti-lock braking controls, electronic stability control systems,
etc., today’s modern truck chassis have multiple electronic control systems. As
such, upfitters need to On Aug. 20, 2013, NHTSA published a final rule to add
and modify some of the EWR requirements, as well as elements of the requirements
for recall and foreign defect reporting. While this final rule became effective
on Oct. 21, changes to the EWR requirements that can make a difference in the
actual information vehicle and equipment manufacturers must report have
lead-times of one year from the effective date of this final
rule.
Also, if you are not currently subject to the quarterly reporting
requirements based on your production levels of different vehicle types
AND you do not export vehicles that are “identical or substantially
similar to a vehicle” model you sell domestically, you will not likely notice
anything different due to this final rule.
Key
Changes
One of the most notable changes to the EWR
portion of the requirements for the work truck industry is an expansion of the
categories of information NHTSA is requiring for the quarterly and related
reporting for manufacturers annually producing:
- 5,000 or more light vehicles,
medium/heavy vehicles or trailers;
- 100 or more buses; or
- 500 or more emergency
vehicles.
Also, for manufacturers of any size that export vehicles falling under
an “annual list of substantially similar vehicles” as required by 49 Code of
Federal Regulations Part 579.11(e), NHTSA will be mandating all annual lists of
substantially similar vehicles to be submitted only by electronic means.
Previously, NHTSA has accepted other list-submission methods for companies that
export vehicles that are equivalent to the models they produce for sale in the
U.S. Starting with the annual lists due Nov. 1, 2014, submission will be limited
to the existing electronic means. For the latest information, instructions and
forms for submission of EWR data, visit www-odi.nhtsa.dot.gov/ewr.
Other portions of this final rule apply to recalls and defect
reporting, and there are shorter lead-times for some of these requirements as
they relate to owner notifications and reporting. One of the most notable
portion changes to the recall requirements involves “large light vehicle”
manufacturers (those that annually produce 25,000 or more light vehicles).
Companies in this category must provide VIN-based search capability for open
recalls on — or linked from — the main page of their U.S. website. These
manufacturers must also allow NHTSA to access open recall data using standard
protocols so that users of www.safercar.gov can access this same information.
These requirements do have a lead-time of one year from the effective date of
the final rule, but NHTSA is encouraging early adoption and will provide
technical instructions and details to the manufacturers affected.
If you have any questions, call the NTEA Technical Services Department
at 1-800-441-6832 from 8:00am–5:00pm EST,
Monday–Friday. We’ll be glad to help!