Kim Mann, general counsel for the National Association of Trailer Manufacturers (NATM), believes that the National Highway Traffic Safety Administration's (NHTSA) delay in acting on NATM's Early Warning Reporting rule petition is "inexcusable." In the latest edition of NATM's TRACKS publication, Mann addresses the issue of NATM's petition asking NHTSA to re-classify all manufacturers of trailers under 26,000 lbs GVWR as "small manufacturers." EWR reports for the second quarter must be submitted electronically to NHTSA electronically by Aug. 30.Mann says that NHTSA's failure to act on the petition is particularly damaging because "that decision may very well relieve most NATM manufacturer-members from EWR's recordkeeping and reporting requirements."He says that NHTSA has made several interpretations, one of which modifies the reportability of consumer complaints as they relate to trailer performance and its components and systems. NHTSA has advised NATM that trailer manufacturers do not have to report consumer complaints, even when received during the normal course of business, if the means of their communicatin is verbal -- unless the trailer manufacturer, as part of its standard practice, ordinarily prepares a written report or other written record of oral complaints.