INDUSTRY ADVISOR
Finally, A Line in the Sand By Harry Baergen – Autoregs Consulting NMEDA CRP COORDINATOR Harry Baergen was previously the Regulation Enforcement Officer for Transport Canada. Currently, he acts
The CRP has cautioned manufacturers
impossible. Even if new vehicle test
as the Compliance Review Program
about this problem in past Circuit
data could be obtained from the OEM,
(CRP) Coordinator for NMEDA.
Breaker issues and has actually
Transport Canada (TC), or NHTSA
noticed some improvement in the
for the exact same model, it can only
If you have any questions about the
industry regarding test vehicles.
be new vehicle data and can only
contents of this article, or about
However, there are still some
be compared to the test results of
the NMEDA CRP, contact Harry
companies that are not only testing
one particular used (unmodified)
Baergen at 778.888.2210.
used vehicles, but are taking it to
vehicle, because every used vehicle
the extreme. In these cases, where
is different depending on its life
A
CRP is presented with a certification
history. Just the replacement of
package showing aged and high
certain parts, such as engine mounts,
mileage test vehicles, CRP has
fuel system parts, brake parts or
to communicate back and forth
airbags, could make the used vehicle
situation and/or solution that arose
with the company in an effort
perform differently, better or worse,
to get justification or rational to
in a dynamic certification test, for
demonstrate that the old test vehicles
example. Even if the used vehicle
are like new and can still represent
were to perform better in a dynamic
new vehicle production. To do this,
test, due to replacement parts, it
the company has to provide CRP with
is still not a representation of new
maintenance records, warranty claims,
vehicle production. Also, there is the
“
fact to consider that the government
rticles published here by the Compliance Review Program (CRP) are often
about a particular problem, question, from a NMEDA member, or members, in the field. The CRP issues these articles with the hope that they might edify other NMEDA members who could be confronted with similar situations. The most recent problem is not new, but it is one that arises from time to time between CRP and the adaptive manufacturing industry. Lately, the CRP is again beleaguered with some certification packages from NMEDA manufacturers that contain
Carfax, records of all the parts that
An old vehicle is a unique vehicle and can only represent itself.”
have been replaced in the vehicle, rust
compliance test data cannot be used
analysis, etc. This requires time and
to compare any vehicle, because the
expense for the company and CRP,
government, to avoid discrepancies,
a company’s vehicle models on the
causing frustration for both.
conducts its compliance testing
NMEDA website as “certified” when
For a company to present any
at lower targets than the standard
the test vehicles used to certify the
other type of analysis, such as crash
company’s new vehicle production
comparison analysis, to show that old
are questionable.
vehicles perform the same as new
test reports showing aged and high mileage test vehicles. This makes it extremely difficult for the CRP to post
ones in a dynamic test is virtually
20
NMEDA Circuit Breaker
requires. The OEM, on the other hand, carries out certification testing at slightly higher targets, to allow for slight variables in production, but OEM
