The Motor & Equipment Manufacturers Association (MEMA) and its affiliate, the Original Equipment Suppliers Association (OESA), support the National Highway Traffic Safety Administration’s (NHTSA) approach in its new system for early notification of possible vehicle or automotive equipment defects.
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The Early Warning system regulations, published in the July 10 Federal Register, are among several new requirements mandated by the Transportation Recall Enhancement, Accountability and Documentation (TREAD) Act of 2000.
“Throughout the lengthy rulemaking on early warning, we have enjoyed a strong working relationship with the NHTSA staff,” said Ana Lopes, director of government relations for MEMA and OESA. “Their willingness to review our data and consider our recommendations greatly contributed toward a final rule which grants more protection to every person on the road while still providing our industry with an appropriate and effective role in NHTSA’s daily work.”
As originally conceived by NHTSA, the early warning system would have forced equipment manufacturers to keep extensive records and periodically report to the agency on several broad categories of information. Items such as field reports, internal investigations and running production changes would have been subject to record-keeping and reporting requirements. These burdens would have been excessive on the approximately 23,000 equipment manufacturers NHTSA determined would be affected by the early warning rule. Many of these manufacturers are small businesses and play a critical role in the health of the domestic economy.
In response to the initial proposal, MEMA and OESA provided NHTSA with information on the small business cast of the automotive supplier industry. Legal analysis conducted by the associations showed that NHTSA could devise a more focused reporting programme to achieve the TREAD Act’s mandates without overly burdening automotive suppliers.
NHTSA’s early warning final rule drastically reduced reporting and record-keeping requirements on the automotive supplier industry. The agency has estimated that far less than 1% of the rule’s costs will fall on automotive equipment manufacturers.
“MEMA/OESA individual member companies served as critical partners in this effort,” said Lopes. “Our TREAD Act working group represented both the original equipment and aftermarket segments of the supplier industry. It provided daily input and assistance as we sought to address the proposed legislation on Capitol Hill. This participation only increased in number and in importance during the TREAD rulemaking process. The benefit of this innovative collaborative effort is clearly reflected in the early warning final rule.”
