CEO’s Message

You Gotta Stand for Something

By Danny Langfield

NMEDA CEO

No, this article is not directed

at our U.S. Congressmen and women, although one can certainly be forgiven if that was the first thought that came to mind upon reading the title.

Instead, I am speaking to all NMEDA members, and specifically to the notion of QAP and what it means.

As the vast majority of you are well aware, NMEDA is the association that administers the Quality Assurance Program accreditation, affectionately (!) referred to by its friends and adherents as QAP.

QAP has many requirements, from properly trained technicians to annual mandatory audits, all aimed at the overarching goal of consumer safety.

Are we the only ones interested in safety? Certainly not. From a regulatory standpoint, the National Highway Traffic Safety Administration (NHTSA) oversees and enforces the Federal Motor Vehicle Safety Standards (FMVSS). But here’s the thing: NHTSA allows for vehicle alterers to be selfcertifying: in other words, while the law requires that conversions be compliant, it does NOT require the submission of any evidence of compliance. Conversion companies must register with NHTSA and are required to place a label on all altered vehicles that states the vehicle is in compliance with all applicable standards at the time of manufacture.

NMEDA came to a realization well over a decade ago: NHTSA’s system of self-certification is not sufficient in the real world for verifying crashworthiness. In other words, folks, registering as an alterer and slapping a sticker on the B-pillar isn’t enough.

So, the association created the Compliance Review Program (CRP). Under the unofficial motto, “Trust, but verify,” CRP set out to provide a mechanism for validating converters’ claims of compliance. NMEDA’s Manufacturer Quality Assurance Program (MQAP) accreditation

requires all manufacturer members to submit crash test data to CRP for all personal-use conversions they manufacture. This has been a powerful tool in raising the standard for safety and accountability for the entire auto mobility industry.

Back on the dealer side of the equation, the Quality Assurance Program, under Rule 5.T., prohibits the sale of new, personal-use conversions without verified evidence of compliance to certain of these federal motor vehicle safety standards.

That means that a QAP-accredited location must be in possession of valid crash test data or engineering analysis data (the data itself, not a report summarizing the data) that demonstrates compliance to said requirements for every new, personaluse conversion it sells.

Such data is complex and extremely difficult to interpret without significant automotive engineering expertise, expertise typically not found (or expected) at an auto

Thirty states and the province of Quebec currently either require or strongly recommend QAP for all vehicle mods they approve. These “

entities and countless others have placed their full faith in the Quality Assurance Program, and for good reason.”

mobility dealership. Enter CRP, whereby NMEDA offers converters the opportunity to submit the data directly to the association, or to work directly with a NMEDA-approved test lab. In the former case, CRP contracts with automotive engineering experts to carefully review the data to verify that the conversions in question are indeed compliant to those federal requirements. (In the latter case, the test lab performs the verification and provides the completed reporting form to NMEDA.) In either case, once accepted by CRP, the conversions are posted to the Safety Reviewed Vehicles section of nmeda.org. This satisfies the dealer QAP requirement under 5.T.

There are those who take the position that 5.T. is an unreasonable intrusion into their business practices, and that a QAP dealer should be able to sell any new, personal-use conversion to a customer he or she sees fit to sell.

To those who take that position, let me ask you something, point-blank: Do you believe there are any WAVs currently available to consumers in the marketplace that are not compliant with NHTSA’s federal safety standards for crashworthiness? If not, give me a call. I have a bridge you may be interested in buying.

If so, then you probably also realize why the Compliance Review Program was established, and why it plays the essential role it does in our industry.

A dealership taking the position above is essentially demanding that the association grant it QAP accreditation, despite the fact that the dealership may be willing to sell new, personal-use conversions to its customers without objective, verified evidence that those conversions are crash-worthy.

The Board of Directors’ position on the matter is clear: That isn’t going to happen. 30 states and the province of Quebec currently either require or strongly recommend QAP for all vehicle mods they approve. These entities and countless others have placed their full faith in the Quality Assurance Program, and for good reason. To our friends at the VAs and Voc Rehabs, the regulatory agencies and everywhere else that cares about the safety of the consumer: know that NMEDA is deadly serious about the QAP accreditation.

Have we lost members over this? Yep. And that’s unfortunate—but you gotta stand for something.

While I have you, there are a couple of rumors I’d like to dispel:

This is just a play by NMEDA to force manufacturers to become members and generate more dues revenue for the association.

For starters, you do NOT have to be a member to submit conversion data to CRP—that opportunity is open to all. Furthermore, non-member companies may submit an individual conversion ala carte (MQAP-accredited companies are required to submit ALL personal use conversions). One more note—the cost of submission is the same for members and non-members.

The reality is there are maybe a half dozen non-member manufacturers at stake here. Industry Member dues are either $1,575 or $2,100 annually (depending on gross revenue). Taking the larger number, the cash in question here maxes out at less than $13 grand. NMEDA is a $2.5M association. So, while we are always delighted to welcome new members, 0.5% of our revenue…is not really a needle mover.

This is all because (mystery company X) doesn’t want dealers to be able to sell anything but their stuff.

Nothing personal, but these folks might need to be fitted for tin foil hats. Everyone in auto mobility is HYPER aware of the severe inventory shortages in the marketplace. And keep in mind, DEALER members make up nine of the 13 NMEDA board member positions. The association would love nothing more than to be able to post as many conversions as possible, providing more potential inventory sources for dealers and more choices for customers. Come on.

In conclusion, conspiracy theories notwithstanding, Rule 5.T. is in place for two reasons: the safety of the customer, and the legitimacy of the Quality Assurance Program.