THE three men who made a joint presentation to the TTMA engineering committee during the association's annual convention this year are arch rivals. But recently they have been standing together as teammates.
The three appeared at the engineering committee at this year's TTMA convention to deliver some good news. Just before leaving the office and celebrating New Year's Eve last year, the National Highway Traffic Safety Administration issued a notice of proposed rulemaking announcing plans to revise the federal motor vehicle safety standard (FMVSS 108). The standard regulates the lighting that goes on commercial truck bodies and trailers.
The notice included language that our industry isn't used to hearing. NHTSA said it wants to amend the standard to provide “a more straight-forward and logical presentation of the applicable regulatory requirements” — all without imposing “any new substantive requirements on manufacturers.”
Brad Van Riper, vice-president of research and development of Truck-Lite, called the notice of proposed rulemaking “our Christmas present.” Van Riper, Art Hernandez with Grote Industries, and Tim Murphy with Peterson Manufacturing have been part of a multi-organizational effort to request changes to FMVSS 108, one of NHTSA's oldest safety regulations.
The lighting standard, first implemented in the 1960s, references some Society of Automotive Engineers (SAE) standards that are so obsolete that copies of them are no longer available through SAE. For this and other reasons, the Transportation Safety Equipment Institute (TSEI), Motor and Equipment Manufacturers Association (MEMA), and the Motor Vehicle Lighting Council (MVLC) have combined forces to convince NHTSA that we need a kinder, gentler (or at least more current) version of FMVSS 108.
But while the groups were encouraged by the contents of NHTSA's notice, more work needs to be done, the trio said. That was the real purpose of their presentation — to brief trailer engineers on the 122-page response to the proposal that TSEI, MEMA, and MVLC composed during the 90-day public comment period that the notice of proposed rulemaking provided. For details on the issue, see our story on Page 38.
The effort that has gone into the revisions of FMVSS 108 is by no means the only instance in which individuals who normally compete against one another work together to address a common cause. In fact, it isn't even the only example in this edition of Trailer/Body Builders. In a similar scenario, brake manufacturers are working together to respond to another NHTSA notice of proposed rulemaking, this one contemplating shorter allowable stopping distances for air-braked truck tractors.
As our story on Page 34 reports, the Heavy Duty Brake Manufacturers Council supports NHTSA's desire to reduce the stopping distances for tractors. But the council questions the impact that the proposal may have — including the compatibility between more aggressive tractor brakes and today's truck trailers.
Neither of the proposed changes in FMVSS 108 or FMVSS 121 have the potential to impact the industry the way some regulations (such as the 2007 emissions regulations) have done. They aren't hugely complex issues (such as The TREAD Act) that will require special seminars to understand. Nor are they dramatic rescue efforts such as the successful lawsuit the industry filed against NHTSA to overthrow what federal judges called “arbitrary and capricious” rulemaking.
Rather, these recent cases are routine examples of how trade associations should work — encouraging competing companies to put aside their differences temporarily and work together for the common good. They involve a lot of behind-the-scenes work that isn't always noticed by those who benefit from it.
Over the decades, we have seen individual companies and individual trade associations cooperate with one another. The National Truck Equipment Association, the National Association of Trailer Manufacturers, and other industry groups have worked hard to explain to regulators in Washington offices what goes on day to day in manufacturing plants and truck equipment shops — and how the rulemaking being considered will impact them. The result has been far less adversarial relationships with federal regulators and more workable, feasible regulations.
But these benefits do not come without a price. Individuals who tackle these projects do so sometimes at the expense of their companies and sometimes pay costs out of their own pockets.
All of us are asked to do more in less time — and with zero reimbursement. Yet our industry often needs the help of those who work in it, and the efforts that volunteers contribute rarely return void. We applaud the work of those whose efforts benefit us all.
Meanwhile, after leaving the TTMA engineering committee meeting, one of the presenters grinned and said, “We can go back to being competitors tomorrow.”