Proof of fire protection standard?

[Small but Sweet]

We’ve been trying to get our trailer titled and registered since last July, in Oregon. We did receive the license plate at long last, and registration. This week we got a letter from the DMV saying that they can’t give us a title because they are missing some proof of the fire protection standard. They say it might be on the MCO (which they have, our original) or a separate statement from the manufacturer.

Escape sent me a copy of our MCO, and it doesn’t seem to have any mention of fire protection standard. I asked if they have a form or anything that states what fire standard the trailer is built to, and they said they do not. Just that the sticker on the side of the trailer says that it meets the Canadian fire standard.

This is frustrating! I’m sure other people have come up against this before. What was the solution?

[TTMartin]

Originally Posted by Small but Sweet

We’ve been trying to get our trailer titled and registered since last July, in Oregon. We did receive the license plate at long last, and registration. This week we got a letter from the DMV saying that they can’t give us a title because they are missing some proof of the fire protection standard. They say it might be on the MCO (which they have, our original) or a separate statement from the manufacturer.

Escape sent me a copy of our MCO, and it doesn’t seem to have any mention of fire protection standard. I asked if they have a form or anything that states what fire standard the trailer is built to, and they said they do not. Just that the sticker on the side of the trailer says that it meets the Canadian fire standard.

This is frustrating! I’m sure other people have come up against this before. What was the solution?

As I recall the MCO states the trailer meets ALL Canadian and U.S. standards for travel trailers in effect as of the date of manufacture.

edit: The title bureau in Ohio accepted the MCO and that and the bill of sale was all that was required to get the title.

If they had not accepted the MCO statement that it met all standards, the trailer would have to be inspected by the Highway Patrol to ensure that it did. So, if they won't accept the MCO statement that it meets ALL standards, ask them where you can get it inspected.

[rubicon327]

I found the following in the Oregon DMV title and registration handbook. Ask ETI again - their trailers should most likely meet one of the standards listed in my opinion. If they do meet it ask if they can provide this statement on a company letterhead to satisfy the DMV.

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DMV TITLE AND REGISTRATION HANDBOOK Chapter L: Vehicle Types
A travel trailer is a tent trailer or any other trailer that is designed to be used on the highways and provides facilities for human habitation. It is not more than 8½ feet wide when the trailer is in a travel position. It is six feet or more in height from floor to ceiling as measured with the trailer telescoped to its full extent, or with the sides (tip-outs) expanded. Except for a tent trailer, it has four permanent walls when it is in travel position. (ORS 801.565)

Campers and travel trailers must be built to the NFPA 1192, NFPA 501C or ANSI A119.2 standard, depending on the year of manufacture.
1. If an MCO is submitted, the manufacturer must certify.•This may be on the MCO or a separate letter. Note: A letter can be on company letterhead and/or signed and countersigned.
2. If the camper is assembled, the certification is made by the applicant, or builder, on an Assembled, Reconstructed or Replica Vehicle Certification, Form 6511 or the applicant can make the certification when completing the title application (on the back of the Form 226).
3. If the camper has an Oregon title issued prior to January 1, 2020, or out-of-state title, the applicant can make the certification when completing the title application (on the back of the Form 226).

[rubicon327]

At risk of muddying the waters the blue QAI stickers (purple for single axle) near the door on Escapes say CSA Z240. This is the Canadian Standards Association Recreational Vehicles standard to which all trailers should be built.
https://qai.org/rvs-and-trailers/
Comment to note: "Recreational Vehicles and Recreational Park Trailers intended for the USA market are typically designed and built to comply with NFPA 1192 “Standard on Recreational Vehicles”..."

Direct link to Escape Trailer Industries QAI listing:
https://qai.org/directory/escape-tra...ndustries-ltd/

CSA Z240: "This Standard specifies dimensional and safety requirements for recreational vehicles. Its purpose is to specify minimum criteria for providing a degree of protection against loss of life from fire and explosion."

I found an article from 7/2019 that states, "The Canadian RV Association continues to work alongside the RV Industry Association to align the CSA Z240 RV Series Standard to the NFPA 1192 as best as possible."

[Donna D.]

At the bottom of the decal, which has the VIN, on the drivers side of my trailer, it says this:

THIS VEHICLE CONFORMS TO ALL APPLICABLE U.S. FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE.


Because I have a double-axle, this is the QAI decal.

[Small but Sweet]

Thank you everyone. I confess, I’m about as confused as I was before. It seems that the fire standard is buried deep within trailer standards. I can’t imagine that the DMV expects people to be up on separate components of a more general standard? I have started a help ticket with the DMV, which is very slow this year. At least we have our registration and plate, we know that it does meet standards and we can use it while we wait to sort this out.

[rubicon327]

I guess what I was getting at with my posts is that if ETI cannot say they specifically meet NFPA 1192 maybe they would write a letter stating that they are designed to meet CSA Z240 which for all intents and purposes is aligned with NFPA 1192.

[Small but Sweet]

Originally Posted by rubicon327

I guess what I was getting at with my posts is that if ETI cannot say they specifically meet NFPA 1192 maybe they would write a letter stating that they are designed to meet CSA Z240 which for all intents and purposes is aligned with NFPA 1192.

I could kind of imagine the DMV wanting me the consumer to somehow show that the standards are equivalent. In other words, that not being good enough. Paperwork... It seems no-one else in OR has had this difficulty, so maybe a different clerk just needs to look at the MCO and agree that all standards are met. The trouble “right now” is that every response takes up to a month!

[rubicon327]

Originally Posted by Small but Sweet

I could kind of imagine the DMV wanting me the consumer to somehow show that the standards are equivalent. In other words, that not being good enough. Paperwork...

That burden shouldn’t be put on you! Many travel trailers manufactured in Canada are surely already titled in Oregon including many Escapes.

[Ron in BC]

Originally Posted by Small but Sweet

It seems no-one else in OR has had this difficulty, so maybe a different clerk just needs to look at the MCO and agree that all standards are met. The trouble “right now” is that every response takes up to a month!

That would be a good start. It's always a bit suspicious to me when an official raises an issue like that when lot's of other folks using different clerks didn't have any problem at all. Power trip? Insecurity? Who knows, hopefully another clerk will be more cooperative .

Ron

[75thRanger]

Originally Posted by Ron in BC

That would be a good start. It's always a bit suspicious to me when an official raises an issue like that when lot's of other folks using different clerks didn't have any problem at all. Power trip? Insecurity? Who knows, hopefully another clerk will be more cooperative .

Ron

It doesn't appear local DMV clerks were involved here. OP said the state DMV contacted them regarding the title. The locals had already done their thing.

TX is hit and miss when it comes to local DMV offices.

[Small but Sweet]

Originally Posted by 75thRanger

It doesn't appear local DMV clerks were involved here. OP said the state DMV contacted them regarding the title. The locals had already done their thing.

TX is hit and miss when it comes to local DMV offices.

I never got to deal with local clerks, that might be part of the problem. I had to mail everything to the Salem OR office and it takes months or weeks to communicate back and forth. I still imagine it came down to one clerk failing to read the MCO properly. It’s disconcerting when they ask us to send the MCO, and they have our original MCO in their hands, LOL.