Nearly 120 executives paid $225 last week (Nov. 14) to take a peek at a bad dream for the RV industry: The Transportation Recall Enhancement, Accountability and Documentation Act (TREAD).
Beginning in August, manufacturers of more than 500 units a year – motorhomes, towables or the two combined – are supposed to have compiled three years of statistics regarding deaths and injuries, property damage, warranty claims, field reports and consumer complaints concerning their products, and then keep quarterly statistics after that to be reported to the National Highway Traffic Safety Administration. (NHTSA).
Additionally, manufacturers must report the number of vehicles they have manufactured by make, model and model year for the same period.
“It’s going to be a nightmare,” said Bruce Hopkins, vice president of standards and education for the Recreation Vehicle Industry Association (RVIA). “This is truly the worst example of ‘I’m from the government and I’m here to help you.’ The effort is good, but the logistics are going to be terrible. If people have a squeal in their brake system for any reason, that becomes a reportable issue.”
Hopkins coordinated the Thursday’seminar in Washington, D.C. It was attended by 118 people who heard attorney Erica Jones, a partner in the law firm Mayer, Brown, Roe and Maw, explain TREAD’s impact on the RV industry. (Transcripts and materials from the seminar are available from RVIA.)
Although estimates weren’t available for the RV industry, Hopkins said Jones estimated 90 million warranty claims alone are filed each year with the major automobile manufacturers.
The law is in response to the deaths attributed to accidents in the late 1990s caused by Firestone Wilderness AT tires and the subsequent recall of 6.5 million tires.
The idea behind TREAD is that NHTSA can get an “early warning” by discerning safety-oriented trends in the statistics.
Congress passed TREAD in 2000, and its provisions go into effect in August.
According to Hopkins, estimates are that complying with the law will cost manufacturers an average of $100,000 a year.
Although the law applies to the automobile and truck industries as well, it will be a particular problem for small to medium-sized RV manufacturers because of the industry’s fragmented nature.
“Detroit has people who can sit down and figure this stuff out,” Hopkins said. “I’ve got manufacturers who don’t even know this is going on.”
The scope of the difficulty the industry will have complying with the law cannot be understated, Hopkins said.
Hopkins said many RV manufacturers aren’t likely to have three years’ worth of statistics to report, nor systems in places to gather them.
“Many of our companies are very small,” Hopkins said. “The government is going to find that some of our members don’t have that information. The government doesn’t understand the size of the companies in the RV industry. They look at the big car companies and think that everyone is like that.”
In comments filed with NHTSA, the RVIA asked NHTSA to reconsider the 500-unit floor and increase it to 5,000. NHTSA has not responded.