The Canadian Transportation Equipment Association (CTEA) has presented its “Job-File Level of Excellence” program to Canada's national transportation enforcement group, Transport Canada, and is now seeking input from CTEA members on its viability.
The idea of Job-File, a compliance program aimed at intermediate- and final-stage Canadian upfitters, has been around for over 10 years.
The CTEA Board of Directors discussed Job-File at the 2007 conference board meeting and the staff was charged with investigating the idea and bringing the proposal back to the board, which was done at the March 2008 meeting.
At a meeting in Ottawa later that month with Transport Canada officials, the process was presented and viewed “favorably,” according to CTEA director of technical programs Eddy Tschirhart.
“We laid it on the table to see what their comments would be,” he said. “In vehicle compliance, this thing could give the folks at Transport Canada an awful lot more warm and cozy feeling. They have other fish to fry, so anything that CTEA can help the government do on this particular aspect is great. It builds credibility for the industry and also gives that validity — a chance to be recognized by Transport Canada as a valid program. This would be a favorable thing for the program.
“There were no promises or conditions. But this program has been presented to the director of Transport Canada. They saw that we're serious about what we're doing.”
Tschirhart said it's important to remember that the truck-equipment and trailer industries are responsible to be self-compliant.
“We're helping ourselves to have more validity and more professionalism,” he said. “The using world out there will consider that we're building a vehicle that is compliant. We have the opportunity to take it from there. This is kind of like throwing a dog a bone. Do we want to pick it up and run with it? This program could have the possibility to grow into a higher level of acceptance to companies and their self- certification ability.
“The Job-File to date has raised ‘the bar level’ for the compliance calculations and record-keeping process with truck-equipment upfitting. To use an example, for the people who have wheelbase modifications or GA/GVWR, it doesn't matter if they're doing it by adding axles or by suspension, tire, rim, etc changeouts — the bottom line is that in order to do those programs, those people have suffered through what it takes. They have the written statements of chassis OEs to carry out that kind of work onto that chassis. The chassis OE makes it well known in those letters that whoever is doing that work is actually on the book for the responsibility of it.
“I was just at a dealership six weeks ago, working on an application. The written statement in their hands didn't exactly agree with the way the chassis OE had written it out. I said to this guy, ‘I think it would be wise if you contacted that OE. I'm not sure this is what you would call a solid letter.’ I'm sitting there with him. He puts the phone onto speaker, talks to the fellow and says, ‘I have Eddy from CTEA with me. Eddy doesn't like the way you have written the letter.’ The guy from the OE actually said, ‘Use the CTEA compliance calculation software they have and send that in to me so I can see what we're doing.’ I said, ‘Wow, a chassis OE is actually asking to see CTEA's software on that deal in order to decide.’ We're looking for feedback.”
The natural progression
CTEA executive director Don Moore said this is a long-term project that is in the early stages. He believes it is a natural next step in the process CTEA started to provide assistance with the National Safety Mark (NSM).
“Having worked as a compliance engineering manager for an OE, I know what it takes as far as testing requirements and documentation requirements,” he said. “I went through ISO 9001. There really isn't a lot of real solid and specific information. Job-File is guidance on what a good management system should look like. What we're saying here is, ‘This is an opportunity to have a program in place where we would provide at the end of this, I would think, a certificate and also maybe a sticker you could use that says you have gone through the process. It's something that will help verify that you have the documentation and good record-keeping process.
“A third party would go through your facility and make sure everything is in place. We're not going to be crawling underneath the truck or checking torque values. We want to make sure paperwork is in place. We are going to look at this as a quality program. You set up rules and follow them. Every vehicle that goes out the door should be able to be traced back to compliance documentation. This is a method of following up.”
Tschirhart said CTEA's membership provides many types of vehicles for transportation of varying goods, commodities, and equipment, and the complexities of the products produced by the CTEA membership are many. That's what makes the Job-File program such a necessity.
“We're all over the map — heavy crane to a dump truck to a towing truck to a ready-mix unit,” he said. “Garbage to utility to fire trucks. These are all vehicles produced by this membership. And same thing on the trailer side. With the trailers, most members build from the ground up. We have everything from utility trailers to heavy-haul, and a lot of stuff in between. You take a look at the products we're creating: Our membership has a lot of exposure on highways.
“Here's something we have to own up to: Attention to compliance and road safety details has in some cases been met at a minimum, if at all. I guarantee you if I talked to you all individually, we'd all be able to discuss ‘Joe's Welding’ down the road, who has never done anything right. Something interesting in the truck-body industry: Quite often, to get started in it, it's been a fabricator who decides to build a truck body or he's done one job for somebody that involves a truck body or one job that involves cutting a frame and putting a piece in it.
“So the bottom line is, the entry level can be fairly low and a person does not understand the industry. The four pieces of equipment you really need to start in the truck-equipment business: a welding machine, a plasma machine or cutting torch, a sledgehammer, and an adjustable wrench. Get those and you're pretty much up and running. Those kinds of people have no idea what vehicle compliance requirements are. So this program could become an accepted standard needed to become a successful bidder in a public tender, or to just serve the public.
“It could also become a valuable tool, if you're qualified on the system, for your customer maybe to someday have a better chance at insurance. I heard recently about a truck that had a wheelbase modification done to it by ‘Joe's Welding.’ He did it very cheaply and saved somebody a lot of money. Problem is that the unit was involved in an accident. There was an investigation. It was one of these cases where the air-brake system, after the modification, didn't have a chance of working correctly because it was done with improper fittings and wrongly sized. The insurance carrier representing the truck lost. This starts setting up a precedent.”
Set an industry standard
Tschirhart said the program, like similar ones developed by the National Association of Trailer Manufacturers (NATM) and the National Truck Equipment Association (NTEA), is designed to set an industry standard and thus a measuring stick for the following examples:
Evaluation of companies as suppliers of their products to their end users.
Capability of meeting compliance and other standards pertinent to the products being built.
Capability of meeting provincial or territory requirements and regulation.
For truck equipment, all NSM classifications would be included for available assessment: body and equipment; wheelbase modification; GA/GVWR increase by adding an axle; GA/GVWR increase/decrease by tire, rim, suspension, axle change, or combination thereof; alterer for all of the above.
For trailer manufacturers: again all classifications for Transport Canada application; utility trailers with GVWR of 10,000 lb or more; air-braked trailers.
There are four levels of excellence:
CTEA could evaluate a company's Job-File paperwork only, with no site visit.
Completed vehicle and Job-File paperwork, with a site visit.
“We take a completed vehicle and personally work from the completed vehicle backwards to the paperwork,” Tschirhart said. “You kind of have to see what it looks like and then ask, ‘Does the paperwork really match up? The importance of record-keeping in vehicle production: It cuts down your liability down the road. We want to make sure it's properly updated in your records. It's always good to visit a customer, but you obviously have the customer who phones you up and says, ‘Build me another one just like you did five years ago.’ And you don't have enough paperwork, so you call him back and say, ‘We've made some changes in the product. We really have to come out and take a look at the truck with you.’ Going to visit customers is an important part of your business. You have to have records so that theoretically you could put this thing back together exactly as you built it years ago.”
Completed vehicle and Job-File paperwork from sales through the proposal to completed vehicle, with a site visit. “This would be covering the complete process. The Job-File software we have out there is used more and more as a sales tool.”
Completed vehicle and Job-File paperwork/record-keeping from sales/proposal to completed vehicle, with a site visit plus a minimum premise assessment. “This is not a quality assessment. This is when somebody drives up to your company: Do they feel welcome? This is nothing detailed or cast in stone. Just, how does everything appear as I walk through your door?”