Wow - all exports temporarily suspended

[escape artist]

You realize that the clean water you drink is result of bureaucracy eh?
And your food isn't contaminated with e-coli because of bureaucracy? And the steering wheel shaft isn't piercing your chest because of bureaucracy?

Hi: gbaglo... You also realize that lawyers on both sides of the border get fat feeding on BUREAUCRAZY!!! Alf
escape artist N.S. of Lake Erie

 

[Jim Bennett]

I wonder, but I think it is more a case of government bureaucracy just creating more bureaucracy because that is really all they do. The bureaucracy doesn't solve problems, or prevent problems from occurring it just jumps in after the fact with an insatiable demand for documentation. Individual employees in the government don't have the incentive to make things more efficient or the authority to decide that a rule doesn't make sense, they just have to make sure the correct documentation is provided and they will get to reading it whenever they can.

Job protection?

I do realize that we need guidelines and standards for manufacturers to adhere to for the protection of the consumer. Long gone is buyer beware, but to be fair, many buyers are just not wary. They just don't know the ins and outs of the product very well. BUT, I have witnessed many a time like this where it has gone too far. There are already codes to follow in Canadian manufacturing.

I am sure Escape will get through this and then have it down pat. It will just either cost them or the consumer for the added costs in time to comply. I only glanced the link from Janet, but I saw one part where the forms must be mailed in with an ink signature, that is a very dated requirement costing more time and money. Heck, I just did a $500k real estate deal with an e-signature, and have done hordes of stuff with signed emails.

 

[Brian B-P]

It looks like this is what may have changed - note the update is just a week old for these regs. A terribly tough situation for both buyers and Escape http://www.nhtsa.gov/cars/rules/maninfo/trailer002.pdf

Thanks Janet. I wasn't planning to dig into detailed documents, but I skimmed this one, and it both correlates with the information from NHTSA that I linked earlier, and provides some detail about issues the Sarah mentioned.

Where did you see an update date from a week ago? The document was created on 2007-11-07 1017:48 AM (eight and half years ago), this year (the string "2016") doesn't occur in the document, and the only effective dates mentioned are in 2005. Was a recent update mentioned on a web page where you found a link to this document?

Hi: All... What would happen if during a World Series game the "Gubermint" changed the rules... Eh? Alf
escape artist N.S. of Lake Erie

That would be bad, but I don't see any indication of a "during play" change in this document.

This is protectionism at it's best... and I only read to page 5!!!

I skimmed those first five pages, and although they (plus the next four) set requirements for foreign manufacturers, I didn't see anything close to unreasonable or protectionist... but of course that's a personal opinion. It looks like a lot of paperwork, but it's mostly just a detailed description of the one-time setup of an agent.

The later parts of the document (starting at page 10) apply to all manufacturers (foreign or not), and include this:

The VIN shall consist of four sections of characters which
shall be grouped accordingly:
...
(b) The second section shall consist of five characters, which occupy positions four through
eight (4-8) in the VIN. This section shall uniquely identify the attributes of the vehicle as
specified in Table I.
...
Table I -Type of Vehicle and Information Decipherable
Passenger car: Line, series, body type, engine type and restraint system type.
Multipurpose passenger vehicle: Line, series, body type, engine type, gross vehicle weight rating.
Truck: Model or line, series, chassis, cab type, engine type, brake system and gross vehicle weight
rating.
Bus: Model or line, series, body type, engine type, and brake system.
Trailer, including trailer kits and incomplete trailer: Type of trailer, body type, length and axle
configuration...

There's a "VIN Decoding Requirements" issue which may be the one that Sarah mentioned: current Escape VINs don't appear to provide this information readily. This section of the VIN for an Escape 17' is "TF6A2", while the same section for an Escape 19' is "TF6B2"; there's only one character difference, yet they are different lengths and have different axle configurations. The example on page 18 (which isn't part of the rules, just a helpful example) shows a more typical configuration of this section of a VIN.

 

[gbaglo]

Bureaucracy keeps a company from building a carcass rendering facility on the lot next to yours.

 

[SFDavis50]

You realize that the clean water you drink is result of bureaucracy eh?
And your food isn't contaminated with e-coli because of bureaucracy? And the steering wheel shaft isn't piercing your chest because of bureaucracy?

And Takata airbags aren't blowing shrapnel in your face because of bureaucracy?

Sorry, I have worked many years in the FDA regulated medical industry and believe that the FDA is responsible for killing far more people than their regulations have ever saved. And, I worked many years in the Defense Industry and $600.00 is a bargain for a cheap plastic toilet seat. $5.00 for the molded plastic and $595.00 for the paperwork burden.
I also don't believe that people, companies, engineers, production workers get up in the morning and go to work with a desire to design and build shoddy products. They aren't being forced to do good work because of government policies but those policies often lead to shortcuts and production and design delays which end up causing serious safety issues and huge cost impacts.

The Hartford Steam Boiler Company is a very good example of businesses solving a major problem without government interference.

I also think that the clean water I drink is the result of people deciding that they want clean water therefore an industry can provide it and not a government mandate.

 

[Brian B-P]

I wonder if it is possible to go back to the procedure several years ago whereby trailers were picked up by the new US owners and transported (imported) by the individual.

An interesting option, but under current U.S. rules that may not be easy, either.

 

[gbaglo]

And Takata airbags aren't blowing shrapnel in your face because of bureaucracy?

Had my say, but vehicles with those airbags are being recalled, because of bureaucracy.

 

[Greggo]

You realize that the clean water you drink is result of bureaucracy eh?
And your food isn't contaminated with e-coli because of bureaucracy? And the steering wheel shaft isn't piercing your chest because of bureaucracy?

"hmmmmm, you're papers do not appear to be in order"

 

[Brian B-P]

I only glanced the link from Janet, but I saw one part where the forms must be mailed in with an ink signature, that is a very dated requirement costing more time and money. Heck, I just did a $500k real estate deal with an e-signature, and have done hordes of stuff with signed emails.

Yes, but that's a description of a process from a decade ago. The current NHTSA Manufacturer Portal replaces most - perhaps all - of these paper processes.

 

[Jim Bennett]

"hmmmmm, you're papers do not appear to be in order"

I know nuthink....

 

[Brian B-P]

I can't help wonder if ETI's success and inroads into the U.S. market share hasn't resulted in one or more U.S. manufacturer complaining to their local rep. Probably paranoid to think that, on the other hand, business is business.

I suspect that it would be far cheaper and easier to hire hit man to take out a company's key people than to change U.S. federal regulations to get in the way of that one little company.

 

[cpaharley2008]

According to the regulations mentioned, Section 30112 ((3) excludes from the provision any manufacturer who makes a product specifically and marked "For Export only" and in addition these rules are 10 years old, dated 2006
30112. Prohibitions on manufacturing, selling, and importing noncomplying motor vehicles and equipment

(a) General.--

(1) Except as provided in this section, sections 30113 and 30114 of this title, and subchapter III of this chapter, a person may not manufacture for sale, sell, offer for sale, introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or motor vehicle equipment manufactured on or after the date an applicable motor vehicle safety standard prescribed under this chapter takes effect unless the vehicle or equipment complies with the standard and is covered by a certification issued under section 30115 of this title.

(2) Except as provided in this section, sections 30113 and 30114 of this title, and subchapter III of this chapter, a school or school system may not purchase or lease a new 15-passenger van if it will be used significantly by, or on behalf of, the school or school system to transport preprimary, primary, or secondary school students to or from school or an event related to school, unless the 15-passenger van complies with the motor vehicle standards prescribed for school buses and multifunction school activity buses under this title. This paragraph does not apply to the purchase or lease of a 15- passenger van under a contract executed before the date of enactment of this paragraph.

(b) Nonapplication.--This section does not apply to--

(1) the sale, offer for sale, or introduction or delivery for introduction in interstate commerce of a motor vehicle or motor vehicle equipment after the first purchase of the vehicle or equipment in good faith other than for resale;

(2) a person--

(A) establishing that the person had no reason to know, despite exercising reasonable care, that a motor vehicle or motor vehicle equipment does not comply with applicable motor vehicle safety standards prescribed under this chapter; or

( holding, without knowing about the noncompliance and before the vehicle or equipment is first purchased in good faith other than for resale, a certificate issued by a manufacturer or importer stating the vehicle or equipment complies with applicable standards prescribed under this chapter;

(3) a motor vehicle or motor vehicle equipment intended only for export, labeled for export on the vehicle or equipment and on the outside of any container of the vehicle or equipment, and exported;

 

[cpaharley2008]

If Escape marks their US trailers for Export and their domestic trailers are not subject to these rules, I think this is much to ado about nothing.

 

[freespirit]

doubt this has anything to do with a small company such as Escape or any other conspiracy theories...just more bureaucratic red tape..looks like they are trying to corral any mfg that doesn't have a traceable VIN to the government std...it will probably cost ETI some more for a lawyer or someone to act as an legal agent in US (if they don't have one) to comply and put up with the paperwork....yes this may impact buyers for the immediate future, but it will get resolved. It may force the production schedule to be pushed out and may result in inventory and cash flow headaches for ETI for the short term. Perhaps they can compress the production schedule for Canadian buyers to keep the doors open until the issues exporting to the US are resolved.
reminiscent of the 80's and 90's when ISO9xxx was somewhat forced on all US mfgs...lots of paperwork and for those mfgs that didn't have good process documentation , it forced them to do a better job and both the mfg and the consumer ended up with a better product in the long run...
this is just about a VIN process it appears, and with no disrespect... one can only imagine what it would take for some small trailer mfg's to pass a ISO9xxx process if they can't even provide a simple wiring diagram....

 

[Iowa Dave]

Hopefully the parties involved can engage in some productive and fog clearing dialog shortly.
I feel bad for anyone expecting to get a trailer in the immediate future, especially those who have had one stored at Escape in anticipation of pickup. As I used to say before I swore off being a passenger on aircraft landing in thunderstorms. "Steady, Steady." No reason to panic here. The cash flow thing would make me crazy. Maybe all the Canadians get to move up in the queue to keep the home fires burning Eh. Bureaucrats, politicians, and curmudgeons need to get stuck in a snowstorm, on a bus, all together, with food, water and heat, and a club for everyone.
Dave

 

[cpaharley2008]

They have companies that are "legal agents" recognized by each state and the courts that will accept a summons or subpoena on behalf of the company and act as their legal agent. This is why you will see a lot commercial truck trailers with tags from Maine or some other low tax state, it allows a company with headquarters in place A to open a office in another state which exists only on paper but have a registered agent that can accept legal documents.

 

[cpaharley2008]

Yes, I'm aware of at least 2 members here that left last week to pick up their trailer later this week, vacation time and $$$ are all in limbo. But as I read the reg's, other than some bookkeeping, "Export" only units are not involved and of course those sold to Canadians are not subject to US regs.

 

[freespirit]

Yes, I'm aware of at least 2 members here that left last week to pick up their trailer later this week, vacation time and $$$ are all in limbo.

yes that is very unfortunate.... perhaps they should "import" their trailers across one of those border crossings that supposedly ain't manned...just kidding of course.

 

[freespirit]

Bureaucrats, politicians, and curmudgeons need to get stuck in a snowstorm, on a bus, all together, with food, water and heat, and a club for everyone.
Dave

surely you mean "NO" food, water and heat, and a club for everyone...
gets the job done quicker.

 

[gbaglo]

US buyers used to import the trailer themselves, which meant they had to pay Canadian sales taxes etc. and then apply to be reimbursed. It also caused headaches for ETI.
Not sure, but importing the trailer yourself might be a fallback.