THE National Highway Traffic Safety Administration has postponed the deadlines for large manufacturers to submit Early Warning Reporting (EWR) required by the TREAD Act, according to a notice published in the June 11 Federal Register.
The action comes as a partial response by NHTSA to petitions for reconsideration. The petitions were filed by multiple organizations, including the National Association of Trailer Manufacturers and the National Truck Equipment Association.
Among the changes:
The initial reporting period for quarterly incident and statistical data reports is now the third quarter of 2003, rather than the second.
The reporting period for the one-time report on historical data has been adjusted to include the second quarter of 2003.
NHTSA extended the reporting deadlines 90 days “to ensure that we have consistent data and that manufacturers have time to incorporate all needed changes into their data collection systems.”
The deadline for filing the third-quarter 2003 data is December 1 — the allowable 60 days after the end of the reporting period.
“To make it more convenient for manufacturers to submit their data and to protect against a possible system overload that could occur if every manufacturer tried to submit its data on the afternoon of December 1, we plan to work with the larger manufacturers to develop a schedule under which their data will be submitted over several days at the end of November and/or early December,” NHTSA wrote in the Federal Register notice.
The original final rule established a schedule for the reporting of information and documents by calendar quarters. Under that original schedule, the first reporting quarter was the second quarter of 2003 (April 1-June 30), with reports and copies of non-dealer field reports due no later than 60 days after the end of the quarter (Aug. 29, 2003). In addition, all manufacturers of 500 or more motor vehicles annually, manufacturers of child restraint systems, and manufacturers of tires must file a one-time report of historical information on the numbers of warranty claims or warranty adjustments and field reports that they received in each calendar quarter from April 1, 2000 to March 31, 2003, due no later than Sept. 30, 2003.
There are three basic types of EWR data that are to be reported quarterly by large-volume manufacturers: Information about incidents involving deaths and injuries in claims and notices received by a manufacturer; statistical data about the number of items produced, property damage claims, consumer complaints, warranty claims, and field reports; and copies of non-dealer field reports.
Small-volume manufacturers report only on incidents involving death.
NHTSA is also extending the requirement for the submission of copies of non-dealer field reports for a longer period. They are deferring the initial reporting period for the submission of copies of non-dealer field reports for two calendar quarters beyond the calendar quarter for which numerical reports will be required (i.e., until the first quarter of 2004).
In addition, NHTSA has decided that the submission date for non-dealer field reports should be different from the date that other EWR information is due so as not to interfere with the electronic transmission of that other information. Thus, NHTSA is changing the regulation to provide that copies of non-dealer field reports will be due 30 days after the other quarterly EWR data are due.
With regard to one-time historic reporting, NHTSA has recognized the Sept. 30, 2003, due date is presenting a challenge to some manufacturers and has delayed the due date for this report. The period covered by the one-time historical report is also delayed by one quarter (e.g., for motor vehicles, the period for which data must be reported begins on July 1, 2000, rather than April 1, 2000), and ends on Sept. 30, 2003 (rather than March 31, 2003). Therefore, the due date for one-time historical reports will be December 31, 2003.
In addition to petitioning to delay the reporting, NTEA petitioned NHTSA to expand the definition of small-volume manufacturers (currently defined as manufacturers of fewer than 500 vehicles per year) so as to provide relief from the majority of the reporting requirements for a larger population of NTEA members. NHTSA has not yet ruled on that.
TTMA request accepted
NHTSA also has responded to TTMA's request that NHTSA consider requiring trailer manufacturers to identify the “model” of trailers using the DOT VIN code designation.
NHTSA has accepted this suggestion, but says that the “models” described by TTMA are more properly considered “types.” NHTSA is making an appropriate amendment to Section 579.24, adding a “type” field to the template, and amending the definition of “type” in Section 579.4(c) to specify, for trailers, that it refers to one of the 10 separate categories, the nine suggested by TTMA (van trailer, flatbed, trailer converter dolly, lowbed, dump, tank, dry bulk, live stock, boat, auto transporter, and other), plus recreational trailers.
NHTSA previously had required manufacturers to identify the “type” of light vehicles and of child restraint systems. The TTMA request has led NHTSA to conclude that it also would be appropriate to require manufacturers of medium-heavy vehicles and buses to identify the “type” of such vehicle. Viewed broadly, these types include truck, tractor, school bus as defined in 49 CFR 571.3, transit bus (a bus for local travel), coach (a bus for intercity travel), recreational vehicle (a motor vehicle other than a trailer that is designed and equipped for leisure travel), emergency vehicle (a motor vehicle, other than a light vehicle, designed for emergency service, such as fire fighting, ambulance, rescue, police use, and similar applications), and other (a medium heavy vehicle or bus not otherwise included in the types listed above). NHTSA is making appropriate amendments to Sections 579.22 and 579.4(c), and to the template for this category of vehicles.