NATM Developing Guidance Document on EWR

The National Association of Trailer Manufacturers (NATM) has engaged international law firm K&L Gates to develop a user-friendly guidance document on Early Warning Reports (EWR) and recall reporting requirements, including information on the National Highway Traffic Safety Administration’s 49 CFR §579.5, to assist members in understanding and complying with those requirements.

The National Association of Trailer Manufacturers (NATM) has engaged international law firm K&L Gates to develop a user-friendly guidance document on Early Warning Reports (EWR) and recall reporting requirements, including information on the National Highway Traffic Safety Administration’s 49 CFR §579.5, to assist members in understanding and complying with those requirements.

Pam Trusdale, executive director of NATM, said NHTSA is particularly interested in the reporting requirements for manufacturers relating to notices, bulletins, customer satisfaction campaigns, consumer advisories, and other communications. Manufacturers that produce more than 5,000 trailers annually are required to submit quarterly EWR.  However, all manufacturers, regardless of the number of trailers manufactured, must comply with the submission requirements in 49 CFR §579.5. Failure to submit copies of these documents to NHTSA could result in penalties to the manufacturer, and NHTSA is currently reviewing manufacturers’ compliance with these reporting and submission requirements.

“The agency is assessing how effectively the requirements are being followed,” Trusdale said. “Both trailer manufacturers and component manufacturer-suppliers must comply with 49 CFR §579.5 regardless of the number of trailers or components manufactured.

“NHTSA has already levied fines for non-compliance with EWR (including 49 CFR §579.5) and recall requirements in excess of $100 million, and given its current interest in how effectively 49 CFR §579.5 is being adhered to, we strongly encourage all manufacturers to be on alert for information coming from NHTSA. With these things in mind, it is imperative for all members, manufacturers and suppliers, to keep informed. Work on the EWR guidance document is well under way.”

She said that once completed, the document will be provided to all NATM members and will be covered in Tracks articles, as well as a workshop at the NATM Convention in Las Vegas, Feb. 10-12, 2016.

“Last year alone, NHTSA levied more fines than in the history of the agency,” she said. “Again this year, there have been record fines levied, and trailer manufacturers are included in those numbers. It is imperative that trailer manufacturers keep informed and comply with the regulations. Ignorance of the law is not an excuse for non-compliance.

“NATM plans to be very proactive in working with the agency and keeping members informed of their responsibilities. In the meantime, if your company is contacted by NHTSA about this or any other compliance issue, I strongly urge you to reply promptly and comply fully. You should acknowledge receipt of the notification and promptly furnish the requested information. If you don’t believe you have anything to report, you should still acknowledge receipt of any communication and respond to the inquiry.

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