MEMA, OESA File TREAD Early Warning Comments

Members of the Motor & Equipment Manufacturers Association (MEMA) and the Original Equipment Suppliers Association (OESA) recommended a pilot program comprised solely of vehicle manufacturers to test the early warning reporting requirements of the Transportation Recall Enhancement, Accountability and Documentation (TREAD) Act, in comments filed with the National Highway Traffic Safety Administration (NHTSA) on March 23.

The associations’ Washington DC office collected and compiled member comments in response to the agency’s advance notice of proposed rulemaking (ANPRM). The comments are available at the MEMA website ( clicking on the link, “MEMA/OESA Final Comments on NHTSA’s Early Warning Reporting Requirments ANPRM.”

“Ostensibly, NHTSA would have the opportunity to circumvent problems caused by defective parts through examination of the data,” said Neil De Koker, OESA managing director. De Koker continued, “However, it is widely believed that the data in its raw form would be of little use to NHTSA, and that the reporting requirements would be burdensome to the manufacturing industry.”

“We believe that an initial pilot program including only vehicle manufacturers would fulfill the congressional mandate behind the TREAD Act while also providing NHTSA with the valuable data it requires,” said Ana Lopes, MEMA director, public affairs.

The associations’ comments note that the ANPRM’s proposed initial reporting requirements would place an undue financial burden on small businesses. In addition, large and small original equipment suppliers either do not have the information needed or are already required to report the data to carmakers as proprietary information, the comments said.

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