NATM Issues Third Revision of Trailer Manufacturing Guidelines

THE NATIONAL Association of Trailer Manufacturers (NATM) has issued its third revision of manufacturing guidelines for trailers under 26,000-lb GVW.

The new guidelines were introduced during a seminar at the NATM 10th annual convention and exhibition in Las Vegas, Nevada. The guidelines are divided into parts A, B, C, and D.

Part A covers technical recommendations; part B covers administrative recommendations; part C covers federal and state agencies; and part D covers Canadian federal regulations.

The revised guidelines were reviewed during the seminar by Steve Tuskan, product engineer at U-Haul International in Phoenix, Arizona. The guidelines were revised by a panel of NATM members.

Much of the work was done by panel members including Tuskan; Dick Klein, an NATM consulting engineer; Jack Klepinger, general manager of Wells Cargo in Phoenix, Arizona; and Ron Jackson, president of CM Trailers in Madill, Oklahoma.

The guidelines include industry practices, federal regulations, and state statutes, Tuskan said. The guidelines have information the panel thinks will benefit NATM manufacturer and supplier members.

One-Source Document "The NATM guidelines are a reference manual," Tuskan said. "The panel tried to eliminate our interpretations.

"It's a one-source document, and that's the value of the book. The NATM has saved you the trouble of going to the National Highway Traffic Safety Administration (NHTSA), the Federal Highway Administration (FHWA), the Society of Automotive Engineers (SAE), the Recreational Vehicle Industry Association (RVIA), and the different states."

Each section of the revised guidelines has a number of regulations and standards, which apply in that section. On each page, the number for each regulation is in the upper right hand corner. A cover sheet behind the tab for each section highlights the regulations found in that part of the guidelines.

For example, in part A the cover sheet behind the tab for the underride section lists two federal rules for underride guards on trailers. The cover page lists 49 Code of Federal Regulations (CFR) Federal Motor Vehicle Safety Standard (FMVSS) 223, which covers rear impact guards and 49 CFR FMVSS 224, which covers rear impact protection.

Tuskan reviewed other sections he said were of most importance. In the lighting section, a new three-color lighting matrix shows where different colored lights and reflectors should be located on the trailer, Tuskan said. The matrix also shows where to locate conspicuity tape.

"The matrix saves a lot of time compared to thumbing through many pages of documentation," Tuskan said. "When you're trying to find out where a reflector goes and what color it should be, this matrix can save someone a lot of grief."

The brake section includes a brake standard for commercial trailers and a state-by-state brake matrix. The brake matrix was in last year's guidelines, but now includes a statute number on the left-hand side of the page.

"When you are researching brake codes in a state, trying to research them in a book two inches thick can take two hours," Tuskan said. "So the NATM thinks including this number is a real benefit."

Developing A Standard When SAE establishes a standard for gooseneck and fifthwheel trailers, it will be included in the guidelines, Tuskan said. Currently the SAE is drafting this standard.

This is an opportunity for NATM members to become an integral part of developing a standard for fifthwheel and gooseneck trailers, Tuskan said. If NATM members do not participate in the SAE committee that develops the standard, the result may be an unworkable standard.

Former NATM president, Jack Klepinger, is the co chair of the SAE committee developing the standard, Klepinger said. Four or five NATM members are on this SAE committee.

"The SAE is excited to have the NATM on board and would like to see more participation from our members," Tuskan said.

Another section of the guidelines has separate sections for tires and rims, Tuskan said. Three federal tire standards are included in this information. Underride Standards

A section that covers federal underride standards has information that affects NATM members, Tuskan said. For interpretation of these rules, members can send a request with photographs of their trailers to the NHTSA.

The definition section has been updated with new information. The last section in Part A is the metric conversion table.

In part B, which is the second major section of the guidelines, the administrative recommendations have been consolidated and described.

This section covers Manufacturer Certificate of Origin (MCO), which is printed on bank note paper and lists the vehicle identification number (VIN), GVWR, and other information. A new section in part B of the guidelines lists warning standards from the American National Standard Institute (ANSI).

SIC Code Classification Another section in Part B lists Standard Industrial Classification codes, Tuskan said. The NATM is using SIC codes to try to gather information about the trailer manufacturing industry in US census figures.

NATM members manufacturing trailer with a GVWR of less than 26,000 lb should use SIC code 3799-6-00, Tuskan said. Industry classification 3799 is made up primarily of manufacturers of transportation equipment not classified elsewhere.

"If manufacturers and members use this number, the NATM can use SIC codes to understand where our industry is going and what size it is," Tuskan said. "The SIC code will become a valuable to gather a lot of data."

The last section of Part B has information on excise taxes. The information on excise tax included last year is unchanged this year.

Trailers with GVWs up to 26,000 lb are exempt from excise tax. For manufacturers that build trailers over 26,000-lb GVW, guidelines, simple equations, and a table are included in Part B to calculate excise tax.

Part C lists federal offices, including contacts for most of the offices needed by trailer manufacturers, Tuskan said. Among the telephone numbers listed are those for the FHWA, the NHTSA, the Department of Labor, the EPA, and various state agencies.

Part D lists Canadian federal and provincial regulations that apply to manufacturers building trailers sold in Canada.

"These guidelines are an evolutionary document, and the NATM needs your input to keep it moving in the right direction," Tuskan said. "In the future, we are considering including in the guidelines information on living quarters, flooring, and obviously the gooseneck fifthwheel standard."

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