Comments collected from a task force of North American motor vehicle parts suppliers regarding the National Highway Traffic Safety Administration's proposed importer best practices were submitted this week
by the Motor & Equipment Manufacturers Association; the Automotive Aftermarket Suppliers Association, its aftermarket segment association; the Heavy Duty Manufacturers Association, MEMA's heavy duty market segment association; the Original Equipment Manufacturers Association, MEMA's original equipment market segment association; and two independent groups managed by MEMA: the Transportation Safety Equipment Institute (TSEI) and the Motor Vehicle Lighting Council (MVLC).
The comments were in response to NHTSA's request for comments on guidance and recommended best importer practices to enhance the safety of imported motor vehicles and motor vehicle equipment.
The supplier task force held weekly meetings for a month to review the NHTSA draft document, discuss the intent and prepare extensive comments. Chief among the MEMA task force's recommendations were:
* NHTSA's product marking recommendation go beyond just the "country of origin" mark by adding the following: manufacturer name or trademark; date or date range of manufacture; and, any marking requirements from an industry standard or recommended practice.
* The NHTSA guidance include more details regarding documentation - particularly to incorporate the principles behind "design to conform" methodology and standardized quality planning and process systems.
"We appreciate the fact that NHTSA is seeking input on its proposed guidance and recommended best practices," said Bob McKenna, MEMA president and CEO. "Our members have a long history of working with the agency to help improve product safety. We hope that our joint efforts will continue that work and reduce the number of non-compliant or unsafe products."
"Our HDMA members and councils have worked diligently with NHTSA to reduce the number of non-compliant imported truck parts and increase the safety of trucks on U.S. highways," said Tim Kraus, HDMA president and COO. "Their valuable input and the continued collaboration with NHTSA again reinforce the commitment of our organizations to improve product safety."
by the Motor & Equipment Manufacturers Association; the Automotive Aftermarket Suppliers Association, its aftermarket segment association; the Heavy Duty Manufacturers Association, MEMA's heavy duty market segment association; the Original Equipment Manufacturers Association, MEMA's original equipment market segment association; and two independent groups managed by MEMA: the Transportation Safety Equipment Institute (TSEI) and the Motor Vehicle Lighting Council (MVLC).
The comments were in response to NHTSA's request for comments on guidance and recommended best importer practices to enhance the safety of imported motor vehicles and motor vehicle equipment.
The supplier task force held weekly meetings for a month to review the NHTSA draft document, discuss the intent and prepare extensive comments. Chief among the MEMA task force's recommendations were:
* NHTSA's product marking recommendation go beyond just the "country of origin" mark by adding the following: manufacturer name or trademark; date or date range of manufacture; and, any marking requirements from an industry standard or recommended practice.
* The NHTSA guidance include more details regarding documentation - particularly to incorporate the principles behind "design to conform" methodology and standardized quality planning and process systems.
"We appreciate the fact that NHTSA is seeking input on its proposed guidance and recommended best practices," said Bob McKenna, MEMA president and CEO. "Our members have a long history of working with the agency to help improve product safety. We hope that our joint efforts will continue that work and reduce the number of non-compliant or unsafe products."
"Our HDMA members and councils have worked diligently with NHTSA to reduce the number of non-compliant imported truck parts and increase the safety of trucks on U.S. highways," said Tim Kraus, HDMA president and COO. "Their valuable input and the continued collaboration with NHTSA again reinforce the commitment of our organizations to improve product safety."
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