NATM Makes Its Move With Compliance Audits

LONG-time NATM board member Jerry Shipman was feeling pretty good about the organization — its successful efforts to produce a safer, higher-quality trailer, its voice in Washington DC to work toward regulations that make sense to those in the industry.

And then a representative from the National Highway Traffic Safety Administration approached him last year and asked: “What does that logo you put on the side of your trailers really mean?”

Shipman started thinking a lot about that logo. He concluded that while it means a lot to the members, it doesn't mean what they want it to mean to consumers.

“I think we would all like the NATM logo to be the Good Housekeeping Seal of Approval for our industry and respected universally,” he said. “How do we accomplish that goal? Initially, we have to ensure that all of our members are following the guidelines, and then they must market and promote the NATM logo and what it means. But we can't, in good faith, promote our logo until we've accomplished the first part of the goal.”

The soul-searching set in motion a chain of events starting with the formation of a Guidelines Compliance Committee chaired by Shipman. The committee drafted a Guidelines Compliance Checklist and a Quick Guide to understanding what's required of trailer manufacturers, then recruited TR Arnold & Associates of Elkhart, Indiana, to conduct third-party audits of NATM-member companies that had volunteered.

The convention's “Guidelines Compliance Workshop” not only unveiled the findings but the news that the board had approved a proposal to pay $300 of the $500 audit charge this year for any facility owned by an NATM member.

“We'd like to get 100%,” said president Roland Gehman hours before he surrendered his post to Jim Callaway. “Pass the word. Tell your buddies.”

Past president Bob Bushnell said this is an aggressive attempt to let the lawmakers know that the NATM is serious about compliance.

“The development of a voluntary guidelines compliance program has been a goal of NATM for many years,” he said. “In my opinion, as a small trailer manufacturer, the audit program is one of the most valuable services available to the NATM membership.

“The board meets annually in DC and has used that opportunity to build communications with some of the key personnel of DOT. We have assured the agencies of the commitment of the membership to follow the rules without the necessity of active enforcement by the federal government. Nobody likes the difficulty of following complicated and changing rules. But it's a fact of life and it's a necessity. The consensus of the board has been that it's better to build a relationship with regulators than to avoid or ignore them.”

TR Arnold & Associates performed 40 voluntary audits last year, with the inspections involving safety regulations, and not engineering or the trailer-building process — a misconception the NATM is trying to clear up. Shipman summarized the results as being “overwhelmingly positive.”

“Almost all of the ones that have been audited have made changes,” he said. “These third-party compliance audits are extremely helpful because we might procrastinate about what we may perceive as minor or small issues. And it's easy to overlook some regulations.

“It's evident that since almost all of the members have made changes, these audits are necessary if we are to accomplish our goal. We realize the program is a work in progress and needs to be modified as time goes on.”

Said Marlen Luff of Whiteman Industries in Boise, Idaho, whose company was one of the voluntary audits: “I've been in the trailer business longer than most of you have been alive. I thought all my T's were crossed. Not. I thought I was pretty smart. Not. I think it's high time we did this. I am very, very, very, very high on this program.”

Ron Jackson of CM Trailers in Madill, Oklahoma, said that while his company isn't doing anything dangerous or shortchanging its customers, Arnold & Associates' Ted Huff pointed out some things that could become important if the company ever becomes involved in litigation.

“His ideas kind of took the gray area out of it for us,” Jackson said.

The most significant issue, Jackson said, was safety-chain compliance.

“If you're a manufacturer today and you're buying a chain from one vendor, and you're buying a hook from another vendor, and you're attaching that hook to that chain and that chain to your trailer, you become a safety-chain manufacturer,” he said. “Are you certified to be a safety-chain manufacturer? I wasn't. But we had been manufacturing them for years. We had a hook that was certified and a chain that was certified. But we put them together and became a safety-chain manufacturer.

“So we figured we would buy chains that are certified. It cost us a little more to do this. But if we lose a trailer or that safety chain fails, we've got a partner when we go to court. When we were making that chain ourselves, we didn't have a partner. Just that one item, to me, was worth more than $500.”

Beyond that, Jackson said Huff's arrival and the subsequent analysis of the operation served to unite all the departments of CM Trailers.

“I had been involved in this from the jump-go, so I had a simple understanding of what it took to be in compliance,” he said. “But our people in the plant had not been exposed, other than just the things I explained. You know that's sometimes like a father telling his children something. They listen, but say, ‘OK, we've heard that before.’”

Huff said the typical audit takes about a half-day in the plant, followed by an exit interview. He said that although he didn't find any “perfect” plants, he was impressed with the general level of compliance.

“I've had several follow-up conversations, and the questions I'm getting are good ones,” he said. “Most of what we've found that needs to be changed is not because someone didn't want to do the right thing. It's because they didn't know. I've done this with a few other industries in the past. I think you're going in the right direction. I'd like to see it go farther.”

While the tone of the NATM's announcement was positive, a published summary of interviews with the first 20 volunteers revealed some dissatisfaction.

While 18 of the 20 felt the audit was worthwhile, one respondent said it wasn't worth $500 because he wanted “more feedback and more information” and another said he “didn't think the inspectors knew as much as they should have.”

Five of the 20 said the inspector didn't answer all of the company's questions, with one saying electrical issues went unresolved.

Eight of the 20 said there are problem areas in the industry that aren't being addressed. One respondent characterized the inspection as “too casual,” feeling the inspector failed to look at enough trailers and provide specific analysis on various models.

Suggestions to improve it? Two respondents said they want a written report. Another said he wants a choice of inspectors.

Seventeen of the 20 said they had made changes as a result of the inspection, including clearance light positions, conspicuity tape, wire colors, VIN tags, and serial numbers on tires (instead of a batch system).

Bottom line? It is being embraced by members as long overdue.

“This is the only way to go,” one wrote. “We need to come out of adolescence and into adulthood — meaning we need to level the playing field. All quality manufacturers should do self-imposed or mandated inspections.”

Beyond the audits, the NATM's Guidelines Compliance Checklist and Quick Guide are valuable tools.

The checklist includes items that are to be charted on the first inspection of the facility and anytime the facility has moved to a new location or added a new classification of product: corporate documentation (VIN identifier on NHTSA data base, a system for assigning GVWR and shipping weights, owner's manual containing the notification statement required by the NHTSA); general records (weigh slips to justify shipping weights and GVWR assignments, safety chain/cable capacity, lighting, axle, tire, rim, and coupler capacity); unit records; production unit inspection (trailers a maximum 102" overall width, Federal Certification Label, wiring color-coded, adequate brakes, approved rear-impact protection, lighting, conspicuity tape).

The six-page Quick Guide describes all the safety regulations and issues that are on the checklist.

The NATM's heightened interest in improving standards has not gone unnoticed.

“The association has done a wonderful job of bringing the industry together,” one survey respondent wrote. “If the NATM decal became the Good Housekeeping Seal of Approval, (our) company would use it. Right now, (we) don't feel it enhances (our) sales — but it would if customers were looking for this seal. Possibly have brochures at the point of sale. Right now, it doesn't mean anything… (It would) if it enhanced sales because it told the world that the trailer met specific safety criteria.”