NATM headquarters receives frequent questions from trailer dealers and end-users about state troopers and local enforcement oﬃcers pulling over towed trailers the drivers thought did not require a commercial driver's license (CDL). Is this a result of overly-diligent law enforcement at work? Or a lack of awareness regarding CDL laws? Perhaps a combination of both?
What appears to be behind these inquiries is the vagueness of the CDL laws and the general confusion and disagreement this vagueness naturally generates. So, let’s try to clear up some of this confusion. Congress has charged the U.S. Department of Transportation’s Federal Motor Carrier Safety Administration (FMCSA) with responsibility for implementing the federal CDL laws through federal regulations and has directed the states to issue CDLs in conformity with these regulations. The FMCSA’s CDL regulations appear in the Code of Federal Regulations, 49 C.F.R. Part 383. The FMCSA requires drivers to have a CDL—either a Class A, Class B, or Class C (for transporting passengers or hazardous materials)—in order to operate deﬁned types of commercial motor vehicles (CMVs) in interstate, intrastate, or foreign commerce.
To clarify its regulations, the FMCSA publishes a graphic illustrating the various vehicle conﬁgurations constituting the groups of CMVs requiring a Class A or Class B CDL. That graphic can be found to the left. State and local law enforcement often refer to it for guidance.
The FMCSA requires drivers to have a CDL to operate a motor vehicle if that vehicle meets the FMCSA deﬁnition of a “commercial motor vehicle” and is used in “commerce.” The FMCSA deﬁnes both terms in this two-part requirement in 49 C.F.R. § 383.5. The great misunderstanding out there, within the trailer industry and perhaps within the law enforcement community, about the CDL requirements springs from those two deﬁnitions, particularly the word “commerce.”
The FMCSA deﬁnes a “commercial motor vehicle” as a motor vehicle, or a combination of motor vehicles, in certain GVWR-based conﬁgurations, when used in “commerce” to transport “property or passengers.” The physical conﬁguration component of the CMV deﬁnition is very mechanical, very objective. When dealing with a tow vehicle-trailer combination, you look at the gross combination weight rating (GCWR) of the tow vehicle if the tow-vehicle manufacturer has assigned it a GCWR and displays it on its certiﬁcation label. With respect to the familiar combination, a tow vehicle (whether truck, automobile, or tractor) towing a trailer, the driver needs a CDL if the tow-vehicle manufacturer’s assigned GCWR exceeds 26,000 lbs. (as shown on its cert. label) and the trailer’s gross vehicle weight rating (GVWR) exceeds 10,000 lbs. If there is no assigned GCWR, the FMCSA regulations require the driver to have a CDL only if the sum of the GVWRs of the tow vehicle and the trailer together exceeds 26,000 lbs. and the trailer’s GVWR exceeds 10,000 lbs. In either scenario that satisﬁes the deﬁnition of “commercial motor vehicle,” the driver will need a Class A CDL, assuming the trailer’s use also satisﬁes the second component of the CDL requirement, “used in commerce,” as discussed below.
With respect to a single vehicle, the FMCSA requires the driver to have a Class B CDL to operate that truck, bus, van, or automobile in commerce if that vehicle has a GVWR of more than 26,000 lbs. It is required even if that vehicle is a power unit (truck, automobile, or van) and is towing a trailer with a GVWR of 10,000 lbs. or less. If the trailer’s GVWR exceeds 10,000 lbs., a Class A CDL is needed if its use also satisﬁes the second prong of the CDL requirement.
The second prong of the CDL requirement, and of the CMV deﬁnition, is much more troubling, much more subjective, and the primary source of the confusion. To qualify as a CMV requiring a CDL, that vehicle, even in a qualifying GCWR/GVWR conﬁguration, must be used in “commerce.” “Commerce” has its own separate deﬁnition in § 385.3 of the FMCSA’s regulations. The FMCSA deﬁnes it broadly as any trade, traﬃc, or transportation between points in one state and points in another state or any trade, traﬃc, or transportation that “aﬀects” trade, traﬃc, or transportation in the U.S. between points in one state and points in another. Not exactly an enlightening deﬁnition, to say the least. How this “use” assessment turns out often varies depending upon who is doing the assessing. And that is often the law enforcement oﬃcer on the scene.
As a starting point, the proper inquiry, then, is whether this questionable CMV is transporting property (across state lines) for some commercial purpose, as opposed to for the personal use of the owner, driver, or some other person. What the trailer owner considers his or her own “personal use” may in fact, upon close examination, turn out to be for a “commercial purpose” when viewed through the critical eyes of the state or local law enforcement oﬃcer. Let’s examine several tricky examples:
Complicating the question of whether a CDL is necessary are a hodge-podge of state CDL laws, many of which are at variance with the federal law that FMCSA has issued. States are not prohibited from enacting their own state CDL laws, applying them to non-interstate movements (i.e. the trailer does not cross the state line), if those state laws are stricter than the federal law. In theory, the state law of State A might require its residents to have a diﬀerent class of CDL, perhaps designated as a “Class D,” to tow a 26,000-lbs. GVWR trailer when used for personal use. In the third “tricky example” above, even if the student does not need a CDL under federal law to haul his lawn mower (because the trailer’s GVWR is less than 10,000 lbs.), he may need one anyway because the state law of the state where he resides requires one even to pull a light-duty trailer.
State A must, however, honor the out-of-state driver’s license issued by State B to its residents: for example, if State B does not require a CDL for its residents to operate a vehicle for personal use, then State A may not require a State B resident to have a CDL while operating a vehicle for personal use in State A even if State A requires its own residents to have a “Class D” CDL for this purpose.
The CDL complaints that NATM ﬁelds typically revolve around the smaller, medium-duty trailers (between 10,000 lbs. and 26,000 lbs. GVWR) and the debate over personal use vs. commercial use. In sum, assuming commercial use, when the GVWR of the truck exceeds 26,000 lbs., a CDL is required, regardless of the GVWR of the trailer, and when the GVWR of the truck is less than 26,000 lbs., a CDL is required only if (1) that truck’s GVWR and the trailer’s GVWR, added together, exceed 26,000 lbs. and (2) the trailer’s GVWR exceeds 10,000 lbs.
Dealers should be prepared to provide that objective guidance about what tow vehicle-trailer conﬁgurations may need a CDL when asked by their customers, but they would be well advised to stay away from declaring, when asked, that the customer’s intended end-use of the trailer meets or does not meet the FMCSA definition of “used in commerce.” This precaution is especially warranted if the trailer’s intended use, as described by the owner, falls within the murky, gray area of personal vs. commercial use or the dealer is unsure about the niceties of the state CDL laws that might apply. It is also important for the dealer to keep in mind that a trailer’s use might be “personal” on one or more trips but “in commerce” on others. Better that the driver have that CDL and not need it than not to have one when stopped and forced to try to explain to the oﬃcer that this “trip” is really only a “one-oﬀ ,” a rare exception to his usual personal use.
NATM’s booth sales continue as the industry looks forward to the 2022 show! Booth selection for the 2022 Convention & Trade Show began on June first. On July 6th, companies that chose to roll their 2021 booth funds over to 2022 begun to select their new booth locations. Starting August 4th, the general membership will be allowed to choose booth space.
Exhibiting at NATM’s Convention & Trade Show is affordable, with the cost per 10’ x 10’ booth at $1,457 for NATM members and $2,914 for non-members. Exhibitors can choose to carpet their booth or request electricity through Freeman this Fall. If you would like to purchase a booth, contact NATM Assistant Director Meghan Ryan at Meghan.Ryan@natm.com or call (785) 272-4433.
Registration will open Sept. 13 online. All exhibiting suppliers must register their booth workers online at NATM.com. Each exhibiting company receives two complimentary booth workers per 10’ x 10’ booth purchased. Additional booth workers can be registered for the Early Bird rate of $75. This price increases by $50 per person when registering after Jan. 30, 2022.
Think outside the booth! Sponsorships are still available for the Annual Convention & Trade Show. The success of the NATM Convention is directly tied to the support of its generous sponsors. There are marketing and general sponsorship opportunities available from $250 to $50,000 to fit any budget, including networking receptions, the Top Golf Tee-Off event, trade show lounges and more! Being a sponsor allows your company early access to booth selection for the 2022 show and provides a wide range of exposure, both electronically on NATM’s website and mobile app, as well as in print on the convention program map and in Tracks magazine. This name-recognition will help drive customers to your booth.
NATM will work with you to find the sponsorship opportunity best fit to get your company’s name in front of industry decision-makers. You can find the full 2022 Sponsorship Brochure at www.NATM.com/sponsor.
For 2022, the NATM host hotels are the Tampa Marriott Waterside Hotel & Marina and the Embassy Suites by Hilton Tampa Downtown Convention Center.
Tampa Marriott Waterside Hotel: The Tampa Marriott is conveniently located directly across the street from the Tampa Convention Center. NATM has negotiated a room block rate of $289/night.
Hotel Address: 700 S Florida Ave, Tampa Fl 33602
Phone Number: (813) 221-4900
To make your reservation at the Tampa Marriott Waterside Hotel for $289/night click here.
Embassy Suites by Hilton Downtown Convention Center: The Embassy Suites is conveniently located directly across the street from the Tampa Convention Center with a second level walkway directly to the convention center. NATM has negotiated a room block rate of $279/night.
Hotel Address: 513 South Florida Avenue Tampa, Florida 33602
Phone Number: 813-769-8301
To make your reservation at the Embassy Suites for $279/night click here.
Arrgh! Scammers Ahoy!
Unauthorized third parties have begun contacting NATM Members about hotel reservations for NATM's Convention & Trade Show. NATM advises that you do not engage or make reservations with any third-party group!
Trailer Manufacturers & Dealers:
Take Advantage of New Attendee Promo
NATM trailer manufacturers and dealer affiliates who have never attended the NATM Convention, or who have not attended in the last five years, are eligible for two complimentary full registrations and two complimentary hotel room nights (while available) as part of the New Attendee Promotion. Full registrations include access to all events and meals (except Top Golf Tee-Off) outlined in the show calendar. This is an affordable opportunity for trailer manufacturers to receive top-notch education, networking, and develop supplier relationships while in Tampa.
NATM is excited to once again offer free full registrations for trailer manufacturers’ spouses. NATM hopes you will plan to bring your other half along to enjoy the show!
Click here to apply for the
New Attendee Promo!
The NATM Regulatory Roundup & Capitol Hill Visits are scheduled for September 22, 2021. Along with the Convention & Trade Show, this is one of NATM’s most important events of the year. The day of activities is divided into two distinct parts: the Regulatory Roundup which is held in the morning featuring expert presenters, and the Capitol Hill Visits in the afternoon. The Regulatory Roundup is a speaker series that in the past has featured Congressional staffers, officials from the National Highway Traffic Safety Administration (NHTSA) and experts from the National Association of Manufacturers (NAM). Capitol Hill Visits are meetings with legislators discussing industry needs and educating Members of Congress about the impact of the light- and medium-duty trailer industry on the economy and in local communities.
With continued meeting restrictions, the 2021 event will be a hybrid format with both virtual and in-person meetings with legislative offices. All NATM Members and Dealer Affiliates are invited to participate in the Regulatory Roundup which will be hosted virtually. For those individuals who are interested in what’s happening in Washington, D.C. and within federal agencies, this is the perfect chance to get a feel for the event, which is usually hosted in person, without investing in a trip to the Capitol. As of this writing, the current speaker lineup includes Congressional members and staffers to talk about infrastructure, a NHTSA official, and a speaker from NAM to discuss workforce. To see the up-to-date slate of speakers and sign up to attend, visit https://www.natm.com/regulatory_roundup.html
Meetings with legislators will happen both virtually and in-person for a small group of attendees. The NATM Government Affairs Committee has established talking points to ensure the needs of the industry are being heard. Talking points for 2021 are as follows:
While in-person attendees have already been selected, members interested in virtual legislator meetings scheduled to occur Sept. 20 – Oct. 1, can sign up online here: https://www.natm.com/regulatory_roundup.html.
If virtual legislator meetings are not workable for you, NATM invites all of its members to host their legislators for a plant tour at any time of year. Plant tours are an easy way to not only showcase member companies and their impact on the community, but are also an opportunity to discuss key priorities for the industry and business more specifically. NATM has invitation templates for members to use, and NATM staff will work with the Congressional office on scheduling, and can help companies prepare for the tour. If you are interested in hosting a plant visit, contact Assistant Director Meghan Ryan at Meghan.Ryan@natm.com or call NATM Headquarters at (785) 272-4433.
For members interested in attending the event in person, the next Regulatory Roundup and Capitol Hill Visits are scheduled for April 2022!
NATM is excited to welcome trailer dealers to the 2022 NATM Convention & Trade Show in Tampa, Fla. Feb. 1-3, 2022!
The NATM Convention & Trade Show is the annual trade show for the light- and medium-duty trailer industry. With more than 1,000 trailer manufacturer and supplier attendees per year and growing, this “must attend” event provides education, networking, and communication for those in the industry. The 2020 sold-out trade show boasted over 200 exhibiting companies, with 37 new exhibitors, which gave attendees a variety of products and services to view. The show also included attendees from over 100 trailer manufacturing companies from across North America.
Dealers will be invited to attend all regular workshops and technical forums, as well as the Dealer Workshops & Luncheon on Wednesday, Feb. 2, 2022, and the Trade Show Floor Reception on Wed. 4-5 pm.
Please note: Dealers are not able to attend the Top Golf event, or the Trade Show Floor during the hours of 11:30 - 4 pm on Wednesday, Feb. 2.
Dealers are invited instead to tour the trade show floor and shop for components, materials, and service providers on Thursday, Feb. 3, from 9:00 a.m. to noon. There will be no trailers on exhibit at this show.
NATM will be offering the “New Attendee Promotion” to help offset costs for dealers attending the show. NATM Dealer Affiliates are eligible for two complimentary registrations and two free hotel room nights while available! NATM will email the link to sign up for the New Attendee Promotion on July 8th, 2021. For more information, visit www.NATM.com/convention.
Online registration will open on Sept. 13. NATM looks forward to seeing you in Tampa! For more information about the Convention & Trade Show or the NATM Dealer Affiliate program, contact NATM Assistant Director Meghan Ryan at Meghan.Ryan@natm.com or (785) 272-4433.
Supply chain issues have been a hot topic since the pandemic started, making their way into headlines across the world. IBEX 365, in partnership with the National Marine Manufacturers Association (NMMA), held a webinar addressing supply chain concerns for manufacturers on April 29, 2021. IBEX 365 is North America’s largest technical trade event for marine industry professionals. NMMA is the leading trade organization for the North American recreational boating industry. Andrea Sordi, Clinical Professor Supply Chain Management, University of Tennessee, spoke with Scott Berry, Director of Engineering Standards, NMMA, to answer questions about planning for disruptive events such as costly shipping, innovation, and consolidation.
Global and environmental factors are shaking the principles on which the supply chain has built itself. The pandemic, trade wars, tariffs, etc. have all impacted the global supply chain over the last 18 months. With these tumultuous landscapes changing daily, many manufacturers are struggling with no end in sight. Sordi explained that extreme solutions do not solve these problems. He said, "You need to find balance. Extreme doesn't work. Some materials can be sourced nearshore [vs. offshore], so the question becomes how do you control that balance?" He encouraged manufacturers to think critically about their supply chains and pivot quickly when issues, like costly shipping, arise.
How can manufacturers plan for disruptive events?
Although no event can be fully anticipated, some preparations can be made in advance. Sordi explained that too much time is spent perfecting data and forecasts when the truth is accurate forecasts are entirely subjective. Each company has to decide for what "accurate" means for them. However, Sordi elaborated that what matters is the ability to turn those forecasts into directional data and understand how different scenarios might play out. Accuracy is less important than ability to be flexible. This can be difficulty to do since the supply chain has built itself around the bottom line and growth, which downplays risk management; all industries need to move to a supply chain that is lean and has groundwork built on flexibility instead.
Another way companies can prepare for disruptive events is to ask the question, "How can the company shape demand in the future?" Sordi posed this question so companies look beyond current demand and determine how they can influence it. Looking for new customers and tracking new customer interests are ways the companies can shape demand; the idea is to get ahead of the curve and lead demand in the business's favor. Investing in infrastructure, personnel, and automation can also help anticipate or lessen the effect of disruptive events. For example, if companies take the time to understand where bottlenecks occur in their supply chains, they can mitigate those effects now instead of waiting until the bottleneck causes issues.
Innovation and the Supply Chain
Manufacturers are constantly looking for ways to innovate their products, services, and processes, but there are many hurdles to innovation, including the supply chain. It is unlikely innovation will be found within the supply chain; businesses may need to forge relationships with more than one supplier to create the desired result. Use long-term tactics and strategies with suppliers so a stable, symbiotic relationship is made. When looking for suppliers, small and medium enterprises may be worthwhile investments. According to Sordi, small and medium businesses are more diverse and 20 to 30 percent more creative than big businesses.
Many companies start with a tool and then build business around that tool. However, that is not a sustainable business model. It is much more effective to have a goal or an answer to the question "why are you making this tool/product/service/etc.?" and work backward from there to create a business. Understand why this particular product needs innovating. Even working from this model, innovation can still fail if the values and goals are not aligned internally. If the team does not understand why this innovation needs to be made, not only will confusion run rampant, but trust between leadership and employees could break down.
Consolidation in the Supply Chain
When questioned about consolidation within the supply chain, Sordi did not believe it was a solution. "Consolidation means putting too many eggs in the same basket," he said. It is not a solution the the issues that exist right now. He explains there was a big push for consolidation several years ago because it made managing more efficient. Keeping the supply chain diverse does not only spark innovation, as mentioned above, but can also create competitiveness within the industry. Overall, diversifying supply chins is a much safer solution than consolidation.
Quick Tips to Improve Supply Chains
Update courtesy of the National Association of Manufacturers.
New Supply Chain Plan Released This week the White House released a report on “Building Resilient Supply Chains” and outlined measures our government will undertake to address the supply-chain challenges that continue to plague manufacturers. The report includes policy recommendations and highlights work that is underway to address supply chain vulnerabilities, including: steps to strengthen U.S. manufacturing capacity for critical goods, to recruit and train workers to make critical products here at home, to invest in research and development that will reduce supply chain vulnerabilities, and to work with America’s allies and partners to strengthen collective supply chain resilience.
You can read NAMs response here.
By Jim Hanni, Jennifer Haugh of AAA
Entering into another busy moving season, AAA wants to be sure you’re securing that load! Whether you’re moving the whole family, the college student, or cleaning out the garage and hauling things off, take these precautions to avoid causing trouble on the roadways.
AAA is calling for drivers to properly secure their loads to prevent dangerous debris.
AAA researchers examined common characteristics of crashes involving road debris and found that:
About two-thirds of debris-related crashes are the result of items falling from a vehicle due to improper maintenance and unsecured loads. Crashes involving vehicle related-debris increased 40 percent since 2001, when the Foundation first studied the issue. The most common types of vehicle debris are:
Drivers can decrease their chances of being involved in a road debris crash by:
“Continually searching the road at least 12 to 15 seconds ahead can help drivers be prepared in the case of debris,” said William Van Tassel, Manager of Driver Training Programs for AAA. “Always try to maintain open space on at least one side of your vehicle in case you need to steer around an object. If you see you are unable to avoid debris on the roadway, safely reduce your speed as much as possible before making contact.”
AAA also recommends that drivers avoid tailgating and remain alert while on the road.
AAA provides automotive, travel and insurance services to 56 million members nationwide. AAA advocates for the safety and mobility of its members and has been committed to outstanding road service for more than 100 years. The not-for-profit, fully tax-paying member organization works on behalf of motorists, who can now map a route, find local gas prices, discover discounts, book a hotel and track their roadside assistance service with the AAA Mobile app for iPhone, iPad and Android. For more information, visit www.aaa.com.
According to the Bureau of Labor Statistics, the current average length of service for employees is four years, with those between 25-32 years of age even lower at two years. With service periods shortening, it’s natural to experience higher levels of turnover. Data from a Society of Human Resource Management survey estimated annual turnover at 18 percent with costs between 50 and 75 percent of average total compensation, indicating turnover can have a significant impact on the cost of doing business. For example, a 100-person company with an 18 percent turnover rate and average total compensation of $60,000 could experience direct and indirect turnover costs of $530,000 to $800,000 on an annual basis. From a financial standpoint, employee retention is key to a successful business, and company culture is one factor that can help retain employees.
Mike Krizman, Human Resource Advisor at TMAC and The University of Texas at Arlington, spoke on organization culture at NATM’s Workforce Development Summit in November of 2020. He covered organizational culture and its importance during his presentation. He touched on what organizational culture is comprised of as well as barriers and tips to forming the type of culture that benefits both employees and employers.
TMAC is a NIST (National Institute of Standards and Technology) MEP (Manufacturing Extension Partnership) and is the official representative of the MEP National Network in Texas. TMAC’s mission is to accelerate profitable growth and competitiveness of Texas manufacturers by developing and improving profit, products, processes, technologies, and people.
What is Organization Culture?
Krizman defined culture as the conscience and subconscious of an organization. It is universally understood and influences the success of a company. Culture is comprised of the values and behaviors of employees and is unique to that individual group. It is dynamic which means it is affected by many different factors, both internal and external. Most importantly, culture impacts an organization’s ability to succeed.
Culture is made up of a variety of factors including the company’s vision or mission as well as what employees bring to work every day. Experiences, beliefs, attitudes, opinions, etc. all make up the organization’s culture. Leadership can help set the cultural example for employees to follow by enacting it themselves.
Barriers to Successful Organization Culture
Although building a successful culture is a key part to a business’ success, it is not without its challenges. Culture relies on all parts (employees, leaders, systems and processes, etc.) working seamlessly together; if one part breaks, the entire culture takes a hit, and regaining the loss can be tedious. Be on the lookout for these barriers to success:
These three things can negatively impact the growth of organizational culture. If leaders do not support the culture, there is no reason for other employees to be supportive. If HR does not have the practices in place to act in line with the culture, it will be unable to take root. If what employees see does not line up with the culture, it is something fake and out of reach, something they are not meant to be a part of.
Tips for Building a Successful Culture
A successful culture is one established from the top-down and bottom-up. It is systemic and written into company policies and plans. A successful company culture is one that employees see themselves in.
Examples of actionable steps to take to ensure consistency and success across the company include:
Leaders should be at the forefront of the organizations culture. Here’s some examples of actions they should take to ensure knowledge is passed on to the appropriate parties:
Organizations have a greater likelihood of success when leaders create vision, mission, and value statements to drive their desired cultural and performance expectations. Leaders should work to establish an environment where employees can reach their full potential while also meeting their basic physical and psychological needs. This requires the introduction of a competitive HR management program, extensive communication systems, and an engaged workforce which will help create the link between employee and organization needs.
For more information about how TMAC can assist your company in Texas, contact TMAC by phone at (800) 625-4876; on their website at www.TMAC.org; or, contact speaker Mike Krizman at Mike.Krizman@tmac.org.
The trailer industry, like many industries in the United States, has been greatly impacted by ongoing supply chain disruptions and trade issues. With sourcing of parts and materials primarily coming from foreign manufacturers and material and component shortages, the industry has experienced great volatility as a result of tariffs and the COVID-19 pandemic. Understanding the changing trade climate and adjusting your business practices accordingly can be difficult, which is why NATM is hosting the Tariff & Trade Webinar on June 22, 2021 at 2:00 pm CST.
As trade and tariff issues are regularly evolving, Stacy will curate her presentation on the most current challenges and topics. The agenda will include current trade issues, how the trade arena has changed under the Biden Administration, the recent implementation of USMCA, and predictions on how the trade arena could continue to change.
Stacy Ettinger, Partner at K&L Gates, has received high praise from NATM Members that have attended her presentations at the NATM Regulatory Roundup & Capitol Hill Visits, as well as NATM’s Coffee & Conversation Event with Rep. Walorski. She has over 25 years of experience working with U.S. and foreign businesses and foreign governments on international trade as well as regulatory, investment, and policy matters. Stacy advises U.S. and foreign companies operating across a diverse range of sectors, including manufacturing, energy, and infrastructure. Her practice covers international trade and investment and regulatory matters, including trade investigations, tariff actions (232, 301, 201), customs rulings, national security reviews of foreign acquisitions and investments (CFIUS), free trade zones, bilateral and multilateral negotiations, market access issues, international IP, and food/product standards.
If there are additional topics or hot-button industry issues that you would like addressed through NATM’s educational content, contact NATM Assistant Director Meghan Ryan at (785) 272-4433 or Meghan.Ryan@natm.com.
NATM Tariff & Trade Webinar
June 22, 2021
Presenter: Stacy Ettinger, Partner, K&L Gates
Time: 2:00 pm CST, 3:00 pm Eastern
Cost: FREE for NATM Members and Dealer Affiliates
Register: Click here to register
In the past year, NATM has implemented several changes to the Compliance Verification Program (CVP) due to the Association’s continual effort to improve, while also protecting the health and safety of members and staff in the wake of COVID-19. These changes, combined with the vast diversity in our membership in types of trailers produced and geography, make it an interesting career as we assist members with their compliance requirements across the country. NATM currently has two compliance consultants on staff who regularly conduct compliance consultations, and as Technical Director, I complete a small number of consultations each year.
Pre-COVID-19, the average week looked much different for consultants than it does today. They would fly to a region and
conduct the entire consultation process onsite. This process would typically take around three days and would include anywhere from a handful to a dozen consultations. At present, due to safety precautions, consultants avoid air travel whenever possible to minimize possible exposure to the virus. Further, NATM has separated consultations into two parts, the onsite trailer inspection and the remote documentation/informational portion rather than conducting the entire consultation onsite to reduce possible exposure to virus both for our members and consultants. This means the amount of time onsite has also been minimized, and thus more consultations can be conducted within the same time frame.
The concentration of members varies wildly across the United States. Certain parts have a cluster of members such as Elkhart, Ind. or northeast Texas while other parts of the country have very few member facilities like areas in Nevada or Wyoming. In early March, I travelled to Elkhart and I was able to conduct 21 trailer inspections within two and half days. On the other hand, I have also travelled thousands of miles in many more days only to be able to conduct a fraction of the inspections completed in Elkhart.
When determining the length of consultations, the type of trailer involved is yet another factor. Inspecting a utility trailer that is 79 inches wide and has a GVWR of 2,990 lbs. can be fully inspected in less than a few minutes, while a horse trailer or car hauler with a GVWR over 10,000 lbs. will take significantly more time. This drastic change in inspection time is due to the number of relevant items on the CVP checklist that need to be accounted for, such as clearance lamps. The small utility trailer will not require them but the horse trailer will. Conspicuity treatment (DOT tape) is another example; a car hauler is required to have the tape while the small utility trailer is not. If the consultant is inspecting a boat trailer, the hand winch must also be inspected. Each of these checklist items will add to a compliance consultation’s length.
Additionally, new members and re-certifying members usually have differing consultation lengths. Re-certifying members’
consultations typically flow smoother and conclude quicker than new member consultations. This difference in length is expected. A new member will usually have more questions or need more clarification as they have not been through the process. The plethora of regulations governing trailer construction are complicated, so it is unusual for a new member to have all of their trailers align with regulations the first time around. In addition, just over half of recertifying members pass their consultation outright; though, these members are generally familiar enough with the regulations that explanations do not take as long.
I can’t speak for the other two compliance consultants, Scott Crimmins and Sean Sloan, but I am a talker—guilty as charged. If a member is unable to accompany me during the trailer inspection, I can move quickly through the process, but if I’m conducting a consultation where the member is present and that member is also a talker, I could be on-site for considerably longer. Favorite college football teams (Kansas State), my or the member’s children (I have three boys and always have a story), outdoor vacation spots (Glacier National Park or Yosemite), and many more topics have been discussed during consultations.
More serious topics of conversations include the workforce shortage or component availability. These discussions help me
better understand that particular member and the trailer industry as a whole. If I receive the same questions or concerns over and over again or notice other trends from consultations, then I know our members would benefit from further education on said topics. These topics often result in webinars, forums, Tracks articles, or any other form of communication we think would best disseminate the information.
Although the structure of the day is pretty straight forward, the times can vary wildly. While many manufacturing operations begin well before 8:00 a.m., some do not. With this in mind, we typically start our day with the first consultation at 8:00 a.m., followed by as many consultations as we can fit within the day while still allowing ample time for the consultations themselves, driving between member locations, and time for lunch. With many operations starting before 8:00 a.m., often times offices will close before 5:00 p.m. which limits how late into the day we can conduct consultations. Usually, consultations begin no later than 3:30 p.m. Deceivingly, this sounds like an early day, but I usually eat lunch in my car driving between member facilities, and at the end of the day, I can either be five minutes from the hotel or five hours. I’ve gotten to the hotel as early as 2:00 p.m. or as late as 2:00 a.m. The rare early days are much preferred as they allow me to input reports, answer member questions, and catch up on email, rather than an overloaded workday once I return.
Speaking of hotels, we all have our favorite companies to use while traveling. The NATM Board is fantastic in allowing
consultants to plan and schedule their own travel as long as it is cost conscious. While each consultant differs, my favorites
include Southwest Airlines, Hertz or Dollar Rentals, and Holiday Inn Express. When it comes to food, I’m famous around the office for eating McDonalds or pizza multiple times a day and certainly multiple times per trip! For example, I had pizza five times in three days on my recent trip to Elkhart, Ind. Food options have been limited as we attempt to avoid any unnecessary potential exposure to COVID-19; we often use drive-thru or delivery options.
Having great conversations and seeing this wonderful country is fun and exciting, but our purpose is to support our members. This is the driving force behind all of our processes and recent changes, and why we gladly accept repetitive, subpar food or time away from our families. We are constantly putting effort into molding our program, travel-related and not, to reach the Association’s goal of an extremely high level of member support.
For more information or questions on NATM’s Compliance Verification Program, contact NATM Technical Director Terry Jones at Terry.Jones@natm.com
The National Association of Trailer Manufacturers (NATM) is gearing up for the fourth annual national Trailer Safety Week to be held June 6-12, 2021! With this traffic safety campaign, the Association hopes to improve the safety of the nation’s roadways by raising trailer safety awareness through education of trailer end-users, dealers and manufacturers. The goal is to close the communication gap between trailer manufacturers and end-users to make towing safer. This weeklong celebration is the perfect opportunity to share some safe trailering tips with your community.
The truth is most end-users are vastly undereducated on the proper use of trailers, and with millions of trailers traversing the nation’s roadways every day, safe trailering practices are life-saving. We recognize we wouldn’t buy a car without key safety features, such as seatbelts, but purchasing a trailer with missing safety components can be just as dangerous. It is crucial that trailers are being towed safely for the sake of everyone on the roads.
NATM makes it easy to learn about safe trailering practices. From driving tips to trailer maintenance and components, the Trailer Safety Week website provides need-to-know information regarding trailer safety in an easy-to-understand format. Visit www.TrailerSafetyWeek.com to access these materials and more! The website houses the Safely Towing Brochure which contains important information on hitching, cargo securement, tires, driving tips and the importance of purchasing NATM compliant trailers. It is free, easily accessible and mobile friendly.
We encourage you to join the hundreds of companies, associations and end-users already celebrating Trailer Safety Week! If you are part of an organization that would like to further support Trailer Safety Week, visit www.TrailerSafetyWeek.com/interest to sign up as a Trailer Safety Ally. As an Ally, you will receive a pre-crafted marketing kit to promote your involvement in TSW and share safe trailering practices.
Don’t delay, join this trailer safety movement taking the nation by storm today.
Questions? Contact the Trailer Safety Week team at TrailerSafetyWeek@natm.com.