The big rewrite
Feb 1, 2008 12:00 PM, BY RICK WEBER
NHTSA says that many regulated parties complained that they were not fully confident that they could identify all applicable requirements and ensure that they were satisfied. Many parties also pointed out that some of the older versions of SAE standards incorporated by reference into FMVSS 108 were no longer readily available from SAE International.
“It is a re-write that is long overdue,” he says. “The industry has been asking for it for 15 or more years. That said, it was a daunting process that many had started with good intentions, but it's so overwhelming. Finally, TSEI actually re-wrote it for them and submitted it, but they couldn't accept the input from the industry so finally a consultant was commissioned by NHTSA. He went through it and was responsible for much of the re-write.”
In December 2005, there was a supplemental notice of proposed rulemaking indicating what their intentions were, and a proposal was made.
The agency received comments from 27 entities in response: 11 lamp or lamp-component manufacturers, 11 manufacturer or user associations, three vehicle manufacturers, and two test organizations.
Commenters included: TMA, Motorcycle Industry Council (MIC), Koito Manufacturing Co Ltd, TTMA, General Electric Automotive Plastics, General Motors North America, Specialty Equipment Market Association (SEMA), Grote Industries, Innovative Lighting Inc, Calcoast Industrial Testing Laboratory, General Electric Automotive
Lighting, Valeo Sylvania LLC, Guide Corporation, Alliance of Automobile Manufacturers (AAM), 3M Traffic Safety Systems, Valeo Lighting Systems, Association of International Automobile Manufacturers (AIAM), Owner-Operator Independent Drivers Association Inc (OOIDA), Atlas Material Testing Solutions, ATA, Honda Motor Co, Nissan North America Inc, and Bayer Material Science LLC.
A joint response was submitted by Motor and Equipment Manufacturers Association (MEMA), TSEI, and Motor Vehicle Lighting Council (MVLC).
The final rule is effective September 1, with voluntary early compliance permitted immediately. Van Riper says that doesn't have an impact because there are no changes to the law — just restructuring and reorganizing it.
He would, however, have liked more time to pore over the document's 207 pages. Petitions for reconsideration of the final rule had to be received by January 18 — just 46 days after it was published in the Federal Register.
“There was an incredible effort by technical experts in both the truck and trailer industries in reviewing the re-write to assure that there were no unintended circumstances that occurred as a result of the good intentions — things that might have fallen through the cracks,” Van Riper says. “It's just unfortunate that it came during the Christmas holiday and came in such a short period of time.
“We probably had 40 people on a conference call one day, trying to review it, make assignments, and study sections. It's been a really concentrated effort by many businesses that are, on a day-to-day basis, competitors. But we shared the burden of trying to make an assessment.”
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