Government regulation of our industry has been increasing significantly over the last few years. Spurred on by incidents like the GM ignition switch recall and the Takata air bag recall, the National Highway Traffic Safety Administration (NHTSA) has been penalizing vehicle manufacturers (including members of our fire apparatus industry) with fines in the tens of millions of dollars. If you build a fire apparatus, even if you are only mounting a body on a commercial chassis, you are responsible for meeting a number of NHTSA regulations. The NHTSA is actively pursuing manufactures who are not meeting the regulations. If you are in this group, you risk serious fines once NHTSA finds out you exist.
Many smaller manufactures have been unaware of these responsibilities, but ignorance of the law does not excuse you from fines. The regulations are not easy to navigate, and even larger manufactures can get in trouble. The good news is that the agency appears to look favorably on those manufacturers who proactively educate themselves and begin following the regulations before they are discovered by NHTSA to be non-compliant.
As a service to its members, FAMA is conducting two half-day training sessions that will cover in detail the regulations that each fire apparatus manufacturer must meet. The morning session will cover those manufacturers who build their own chassis. The afternoon session will cover manufacturers who build exclusively on commercial chassis.
|Chassis or Body Manufacturer||Date||Time||Cost|
|Chassis Manufacturer Training||Wed April 26, 2017||8:00 – 11:30||FAMA Members – Free
Non-Members – $325
|Body Manufacturer Training||Wed April 26, 2017||1:00 – 4:30||FAMA Members – Free
Non-Members – $325
If your company is new to compliance, then you should send someone from management who can carry the message back, and someone at the detail level who will be responsible for ensuring compliance.
If your company already understands the importance of compliance, then this is a good session for compliance engineers to make sure they know all the regulations that apply.
How to Register
Complete the following registration link: www.fama.org/NHTSA-2017-training-registration/
Training will include all aspects of NHTSA compliance obligations tailored to fire apparatus manufactures.
- Definitions of incomplete, intermediate, and final stage manufactures
- What’s a VIN and how is it created
- Registering your company with NHTSA
- World Manufacturer Identifier (WMI)
- Monthly Communications Reporting Requirements
- The Certification Labels – Incomplete vehicle and final stage
- Correcting VIN mistakes
- NHTSA Response to FAMA on Apparatus Recalls
- Reporting a Safety Defect or Non-Compliance
- Recall Portal
- Equipment vs Vehicle Recalls – Who is responsible
- Early Warning Reporting (EWR) – Who must report and what they need to report.
Details of the following parts from the Code of Federal Regulations will be covered.
|Chassis Mfr||Body Mfr|
|556||EXEMPTION FOR INCONSEQUENTIAL DEFECT OR NONCOMPLIANCE||Yes||Yes|
|565||VEHICLE IDENTIFICATION NUMBER (VIN) REQUIREMENTS||Yes|
|568||VEHICLES MANUFACTURED IN TWO OR MORE STAGES—ALL INCOMPLETE, INTERMEDIATE AND FINAL-STAGE MANUFACTURERS OF VEHICLES MANUFACTURED IN TWO OR MORE STAGES||Yes||Yes|
|571||FEDERAL MOTOR VEHICLE SAFETY STANDARDS||Yes||Yes|
|573||DEFECT AND NONCOMPLIANCE RESPONSIBILITY AND REPORTS||Yes||Yes|
|577||DEFECT AND NONCOMPLIANCE NOTIFICATION||Yes||Yes|
|578||CIVIL AND CRIMINAL PENALTIES||Yes||Yes|
|579||REPORTING OF INFORMATION AND COMMUNICATIONS ABOUT POTENTIAL DEFECTS||Yes||Yes|