Industry Vitals Presented at 10th Annual NATM Convention

THE National Association of Trailer Manufacturers' annual convention hosted speakers from the industry who discussed a variety of critical industry issues.

Presenters ranged from opening keynote speaker Dr. Scott Sindelar, who discussed increasing productivity, to Jack Klepinger of Wells Cargo Trailers Inc, who presented the latest NATM survey results. Other speakers focused on how to avoid certification citations and fines, and the necessity of safety warnings and labels.

Increasing productivity does not mean working more hours, according to Sindelar. He emphasized simple, yet powerful methods to improve motivation.

If people are spending time doing something, that activity is rewarding to them. Identify the sources of those rewards.

Motivation changes. Keep watching, listening, and asking to identify what motivates your employees.

Practice the "diamond rule." Treat others the way they want to be treated.

Recognition is one of the most powerful rewards, but not everyone likes it.

How do you find out what is rewarding to your employees? Ask, then keep asking.

Turn problem people into research assistants. If you have rapid turnover ask one of the soon-to-leave survivors to do research to find out why employees leave and what could be done to keep them. Give them the time and resources to find out and have them give a presentation about it.

Survey Yields Statistics A recent survey by the NATM gives a benchmark of current trailer industry trends and statistics.

Jack Klepinger of Wells Cargo Trailers Inc presented partial results of the survey at the association's annual convention. The survey was conducted by Association Research Inc. New to the survey this year were financial issues including wage scales and productivity issues.

Forty-five percent of the association's manufacturing members participated in the confidential survey. Sixty-six participants returned surveys, but only 57 of those were used due to incomplete responses. Klepinger presented results to the convention as follows:

Labels and Warnings Necessary The failure to properly warn can result in trailer manufacturers being found guilty of negligent conduct and liable for damages resulting from this act, according to Kim Mann, NATM general counsel.

Both statutes and common law require trailer manufacturers to provide warning labels with their products. Competitors also influence the extent to which manufacturers will go to warn consumers of the potential hazards of their products, Mann said.

The common law obligation is of major concern for manufacturers. "The courts require every manufacturer to 'reasonably' and 'adequately' provide warnings and instructions to the end user," Mann said. "What is 'reasonable' and 'adequate' is extremely difficult to define."

This depends on circumstances that surround the manufacture, sale, and end use of the product. Factors include the sophistication and intelligence of the end user, he said. Familiarity with the product is another factor.

"The manufacturer will be measured by the industry standard for providing a reasonable warning," Mann said. "The new guidelines of the NATM have incorporated the American National Standards Institute's voluntary labeling standard. This is the new industry standard label."

Mann urged manufacturers to inspect their current labels for compliance with the new standard. Failure to provide a reasonably adequate warning can result in manufacturers being liable for damages.

"With only one minor exception, there is no explicit statutory source that obligates manufacturers to warn," Mann said. "The Uniform Commercial Code has, under its warranty section, an implied warranty of adequate labeling that's probably broad enough to embrace an obligation to warn."

State consumer protection laws and federal regulations may also come into play. The National Highway Transportation Safety Administration and Federal Highway Administration have labeling and instruction requirements that usually apply to certification.

Adequate labels must be clearly worded and adequately displayed. Two types of written warnings are applicable to the industry: a label that is applied to the product and one in the product's operation manual.

"Manufacturers probably need both types of labels," Mann said. "Certainly manufacturers need safety warnings in their product manuals, but the necessity of labels depends on the kind of product being manufactured."

Labels normally contain four pieces of information. Labels demonstrate and describe the level of risk involved with the operation of the product.

Risk is categorized at four levels. Labels demonstrate and describe the risk involved with operating the product. Varying levels of risk are categorized using one of three labels including danger, warning, or caution. Risk levels range from death to minor injury.

The second piece of information describes the risk. The third piece of information describes the consequences of the risk due to non-compliance. The last piece of information should be the steps necessary to avoid the risk.

Mann gave an example of a caution label and described the three standard colors associated with the varying gravity of the labels. Caution labels are surrounded with yellow; orange indicates a warning label, and red is associated with danger labels. Labels must be applied to the product and should be as close to the risk area as possible, Mann said.

Safety messages in product user manuals are critical as well. The warning should be in the safety message section in the front of the manual and surrounded in a bold frame or bold letters, and should be clear. The message should depict locations of warning labels on the product and should describe the severity of the warning.

"The manual should also identify any hazards or risks that are not covered by labels," Mann said. "Manuals should also include a message about what steps to take if a label comes off or becomes illegible."

Trailer Conversions Must Meet Regulations The Code of Federal Regulations 49 and ANSI's standard for recreational vehicles both can drastically affect manufacturers of horse trailers having onboard living quarters.

Bruce Hopkins of the Recreational Vehicle Industry Association (RVIA) addressed CFR 49 and ANSI codes for trailer manufacturers. Manufacturers first are required to register with the government by writing a letter to the National Highway Transportation Safety Administration.

Section 566 states the requirements that the letter must contain. The letter must include the company's corporate name, and indicate locations of multiple plants if applicable. Also necessary in the letter is a list of what products the company produces and their range by GVWR. The regulation also states that a company must submit the letter within 30 days of going into business, Hopkins said.

Section 567 deals with certification and contains a label to be completed with manufacturer information. Company name, location, vehicle VIN number, and date of manufacture are included on the label. Labels must be applied to the left front corner six inches above the floorline of the trailer.

Section 571.108 contains exterior lighting requirements. Lighting requirements are federal, Hopkins said. States are required to follow the federal guidelines. Also included in the section are requirements for reflective tape, which must be used on trailers without living quarters.

"These requirements are good to post on the wall in your manufacturing facilities," Hopkins said.

Section 575 of the code requires that manufacturers publish the NHTSA hotline telephone number.

"Manufacturers must have a system in place to be able to identify the first purchaser of their products," Hopkins said. "Product recalls force manufacturers to identify the first purchaser."

Because the RVIA designates horse trailers with living quarters as recreational vehicles, they must comply with ANSI standards, according to Hopkins. More than 500 requirements exist under this code. The goal of the RVIA is to gain consistency using the ANSI requirements to build vehicles that are 50-state compliant.

"The RVIA collects information from states, manufacturers, suppliers, and its own personnel to find consistency and publishes its handbook containing guidelines," Hopkins said. "The book is published every three years and has regular updates with revised information."

Electrical Regulations Hopkins summarized the most important areas in the book. Electrical sections are split into two parts: low voltage systems (12 volts), and high voltage systems (120 volts). Low voltage codes include stipulations on connector type, wire gauge, fuse block wiring, lighting, and several battery requirements.

"Batteries cannot be inside the vehicle because they emit explosive hydrogen gas during charging," Hopkins said. "Batteries must be secured to the vehicle and enclosed in a vented box without spark producing equipment."

High voltage requirements include the recent addition of ground fault circuit protection. Any electrical outlet within six feet of a sink must use ground fault protection. Also included in the high-voltage prerequisites is a power cord requirement.

"We created a power cord requirement to prevent consumers from buying their own extension cords without ground wires," Hopkins said. "The use of an improper cord can result in electrocution."

Fuel System Considerations Fuel systems using propane gas also are subject to ANSI standards. Department of Transportation (DOT) cylinders equipped with a quick disconnect valve and an overfill prevention device are now required.

"Containers are supposed to be filled to only 80% capacity so there is still vapor space at the top of the container," Hopkins said. "If the container is filled all the way to the top, liquid can get into the system and vaporize--creating pressure inside which will cause problems."

Containers must be secured according to the container manufacturer's specifications and contained in boxes that are vapor tight to the inside of the vehicle. Venting is required to the outside of the vehicle for compartment circulation. Boxes must be sized for one square inch per seven pounds of propane gas, according to Hopkins.

"Many common mistakes occur on fittings," Hopkins said. "Flared fittings are not designed to use a sealant such as Teflon tape."

Manufacturers must execute two tests for the propane gas system, according to Hopkins. All appliances must be capped off while the system is pressurized to three pounds per square inch for ten minutes. If there is no decrease in pressure during ten minutes, the system is acceptable. After all appliances have been installed, another pressure-drop test must be run. This test is for the fittings on the individual appliances.

Fire Precautions Fire safety is another concern. Smoke detectors are required and fire extinguishers must be placed near exits. Emergency exit doors must be at least 24" x 17".

"Extinguishers are placed near doors to get people safely out of the vehicle in the event of a fire before they try to fight it," Hopkins said.

Generators must have a suitable exhaust-fastening system to prevent fire hazards and must be contained in a steel box. No fuel lines may penetrate the box.

Trailer manufacturers also must comply with plumbing regulations. These include specifications on the size and type of materials to be used, and techniques for venting sewer lines and constructing traps.

Trailer Certification Regulations As many as 75% of today's trailer manufacturers are not complying with vehicle certification rules and regulations, according to NHTSA and the Consumer Product Safety Commission (CPSC).

Michele Mor of Micro Computer Services Inc reported on the current state of certification laws and the compliance of today's trailer manufacturers in a growing industry. Mor illustrated the growth in the industry by comparing the number of citations and fines issued in 1978 and 1997. In 1978 there were 225 citations issued in the United States compared to 4,750 in 1997. Fines brought in $5,000 in 1978, while in 1997 fines totaled $1.1 million.

"Currently 40 states are enforcing vehicle certification violations using fines and/or citations," Mor said. "Twenty six of these states have received phenomenal budgets in the last three years."

California was given $5,000 five years ago to search out certification violations. The state's budget in this area is now in the millions, Mor said.

Government agencies issuing fines and citations also have grown. Groups such as the CPSC now receive government funding and are authorized by the DOT to issue fines and citations. Transport Canada has stepped up its enforcement of certification.

Top Five Reasons Mor listed the top five reasons that citations are issued in the United States, according to David Coleman, national safety compliance officer at the DOT. Reasons are as follows:

Invalid or incorrect check digit (ninth digit of VIN) found 85% of the time.

Nonconforming VIN certification labels.

Incorrect information on VIN certification labels.

Incorrect placement of VIN certification label.

Invalid or outdated World Manufacturing Identifier code.

"The good news is that we have the technology to easily and efficiently conform to these changes," Mor said.

Transport Canada and the DOT have come to agreement on a single certification tag, according to Mor. The new tag requires trailer manufacturers to list specifications in both metric and English measurements.

"If the new tag is on your vehicle, it is now your responsibility that the vehicle conform to all US and Canadian regulations," Mor said. "If you don't want to take on that responsibility then put on both tags and you can't be cited."

Standard for Certificates The CPSC is trying to create a standard for certificates of origin by the year 2000 despite the fact that some states don't require them, according to Mor. The NATM is opposed to this standard due to the extra cost it will force on trailer manufacturers. The motor vehicle act 16 months ago mandated that the manufacturer's certificate of origin is now the title to the trailer.

"This means that it is now subject to a tremendous amount of regulations that title comes under," Mor said. "The best thing manufacturers can do is to go to the NATM and support a lobby against the standard."

Mor said government rules and regulations are continuing to change rapidly. New budgets at the DMV level are promoting more research that in turn uncovers problem areas, according to Mor. Problem areas promote new legislation that allows issuance of citations and fines. Fines then bring money back to the DMV. Mor urged manufacturers to stay clean in the areas that are likely to result in fines.

In closing, Mor discussed Professional Micro Computer Service's vehicle certification software called VIN-EZE. This software was the first to be DOT and Transport Canada compliant. The software has been reviewed and recommended by SAE and NHTSA, according to Mor. It eliminates fines using sophisticated error checking and includes annual updates consisting of new regulations, rules, and standards for both the US and Canada.

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