Since 1992, the National Association of Trailer Manufacturers (NATM) has annually published the Guidelines for Recommended Minimum Manufacturing Practices for Light- and Medium-Duty Trailers, otherwise known as the Guidelines. These updates are researched and compiled by NATM Staff, NATM Members, and NATM’s committees with approval by NATM Staff, and the NATM Compliance Committee. One drawback to the annual update process is only updating once a year. Members are required to wait until each new edition to gain any new or edited information. Starting this year, NATM will periodically update its membership on upcoming changes for the next edition of the Guidelines via Tracks magazine, social media, and NATM Tech Talk, a brand-new electronic newsletter keeping you up to date on all things technical and compliance. Sign up for this newsletter and more at www.NATM.com/email.

The intention of these general updates is not to provide an official new version of the Guidelines, provide a full context, or provide immediate changes, but to notify members of the upcoming changes so they may be prepared and take action if needed. Contact NATM Technical Director Terry Jones at Terry.Jones@natm.com or call (785) 272-4433 for more information.

Upcoming Changes

Section B11 – VIN / Data Plates and Manufacturer Information

The addition of:

• 49 CFR § 567.1 Purpose
• 49 CFR § 567.2 Application
• 49 CFR § 567.3 Definitions
• 49 CFR § 567.5 Requirements for manufacturers of vehicles manufactured in two or more stages.
• 49 CFR § 567.6 Requirements for persons who do not alter certified vehicles or do so with readily attachable components.
• 49 CFR § 567.7 Requirements for persons who alter certified vehicles.

Purpose:
Manufacturers may have additional requirements based on the type or stage of manufacturing they participate in, and the
addition of these regulations will assist in navigating these requirements.

Appendix 2 – Quick Guide and Checklist

The addition of:
Checklist question: 7.41 Underride properly labeled on the forward or rear of the underride, including the manufacturer’s
name and address, date of manufacture statement, and DOT marking.

Correlating Quick Guide information:

The addition of:
S5.3 Labeling. Each guard shall be permanently labeled with the information specified in S5.3 (a) through (c) of this section.  The information shall be in English and in letters that are at least 2.5mm high. The label shall be placed on the forward or rearward facing surface of the horizontal member of the guard, provided that the label does not interfere with the retroreflective sheeting required by S5.7.1.4.1(c) of FMVSS No. 108 (49 CFR 571.108), and is readily accessible for visual inspection.

• The guard manufacturer’s name and address.
• The statement: “Manufactured in ____” (inserting the month and year of guard manufacture).
• The letters “DOT”, constituting a certification by the guard manufacturer that the guard conforms to all requirements of this standard.

Purpose:
Information on rear underride labeling and enforcing existing federal regulation which requires specific labeling of the rear
underride guard and aligning the Compliance Verification Program with federal regulation.

For more information on these changes, the Guidelines, or any other technical or compliance issue, contact NATM Technical Director Terry Jones at Terry.Jones@natm.com or (785) 272-4433.

Supply chain disruptions, material and component availability, and workforce shortages have caused the light- and medium duty trailer industry continued headaches. NATM recognizes the challenges and is curating the 2022 Convention & Trade Show to assist its industry’s success. The NATM Convention & Trade Show is the perfect one-stop-shop for trailer manufacturers and dealers to meet with suppliers and service providers as they exhibit on the trade show floor.

​Looking for a new chain supplier? Interested in checking out new light options? Shopping around for new software to make life easier? If so, plan to walk the trade show floor and meet directly with suppliers and service providers in the industry! Educational events relevant to both suppliers and trailer manufacturers alike will be featured, including government affairs updates, a trade/tariff workshop , and information about addressing the workforce shortage. Stay tuned to www.NATM.com and the NATM Insider for updates about workshop topics.
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Host Location
The 2022 Convention & Trade Show is headed to the Tampa Convention Center in Tampa, Fla. Feb. 1-3, 2022. Florida continues to be a popular location for NATM’s Convention & Trade Show as it boasts sunny weather and great sites for dinners with customers, golf outings, shopping, and family-friendly vacation activities, but this will be the first time that Tampa has been the host location for NATM’s event.

The Tampa Convention Center is located along the Riverwalk in the heart of downtown and will serve as the site of educational workshops, networking events, and the trade show. Attendees of the show can access the NATM special room block rates at the Embassy Suites by Hilton Tampa Downtown Convention Center and the Marriott Tampa Waterside. More information will be provided via the NATM Insider newsletter and email. To sign up for the NATM Insider, contact NATM Marketing Director Savana Morrison at Savana.Morrison@natm.com.

Booth Selection
Trade show space opened to the 2020 Sponsors starting June 1. Following sponsors, companies that chose to roll their 2021 booth funds over to 2022 began to select their spaces July 6. The opportunity to select space for the general membership will begin Aug. 4, and non-members can select booths starting Aug. 18.

Sponsorships
As always, the NATM Convention & Trade Show would not be possible without the support of its generous sponsors. There are sponsorship opportunities available from $500 to $50,000 to fit any budget. Being a sponsor allows you to select your booth before previous exhibitors and the general membership, as well as provides a wide range of exposure, both electronically on NATM’s website and mobile app and in print on the convention program map and branded events. This creates name recognition which helps drive customers to your booth. Watch your email for sponsorship information coming in May.

New Attendee Promotion
Are you a new member trailer manufacturer? Are you a trailer manufacturer whose company has not attended in the last five years? Are you a Trailer Dealer Affiliate? You may qualify for NATM’s New Attendee Promotion! The New Attendee Promotion includes two complimentary full registrations and up to two complimentary hotel room nights at the host hotel for the convention. Those interested in participating should contact NATM Assistant Director Meghan Ryan soon— complimentary hotel rooms are on a first-come, first-served basis and will go fast.

Stay tuned for more information about NATM’s 2022 Convention & Trade Show at www.NATM.com. Questions about the show sponsorship opportunities or exhibit space? Contact Meghan Ryan at Meghan.Ryan@natm.com or call (785) 272-4433.

NATM is soliciting nominations for awards to be presented at the annual NATM Convention & Trade Show Feb. 1-3, 2022 at the Tampa Convention Center in Tampa, Fla. Please consider and nominate individuals who may be eligible candidates for the following awards.

The Outstanding Member Award is presented each year to an individual who has made a significant contribution to the trailer manufacturing industry. The nominee must be an employee of an NATM Regular (trailer manufacturer) Member. The nomination must include the name and address of the nominee and nominator along with a brief narrative about the
contributions the nominee has made to the trailer manufacturing industry.

The Pam O’Toole Trusdale Woman in Manufacturing Award is given to a woman from the manufacturing floor to the C-Suite in the light- and medium-duty trailer industry who has demonstrated excellence in their role. The award recognizes the contribution of the recipient to the success of their organization and/or industry. The nominee must be an employee of an NATM Member company.

The nomination must include the name and address of the nominee and nominator along with a brief narrative about the
accomplishments of the nominee.

The purpose of the Young Professional Award is to recognize the accomplishments of young individuals in the trailer
manufacturing industry. Nominees should be individuals under the age of 40, who have been innovative and successful in the trailer manufacturing industry. Both Associate and Regular member company employees are eligible for this award.

The nomination must include the name and address of the nominee and nominator along with a brief narrative about the
accomplishments of the nominee.

The Innovation Award is open to member companies that exemplify creativity and innovation in the areas of technological
advancement, green practices, or workforce development. Applicants for the award must submit a written description of the company’s innovative practices, including both qualitative and quantitative evidence of success. This award is open to all NATM Members and will include a charitable donation made in the company’s name.

Awards will be presented at the Annual Awards Luncheon on Tuesday, Feb. 1, 2022. To request the award nomination form, contact NATM Assistant Director Meghan Ryan at Meghan.Ryan@natm or (785) 272-4433. Nominations are due by Nov. 30, 2021.

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?
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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:

1. The trailer owner is towing his own horses to a horse show or his livestock to the state fair where monetary prizes are awarded. That familiar scenario is likely to be categorized as a commercial undertaking or commercial purpose from the vantage point of the diligent state trooper who pulls over the driver looking for that CDL.
2. Suppose instead those horses belong to a stable whose owner charges the public by the hour to ride them. Another commercial purpose according to a strict interpretation of the term. It does not matter that no business name or logo is displayed on the side of the truck or trailer towing these horses.
3. Now suppose it is a college student behind the wheel of Dad’s 16,000 lbs. GVWR truck towing his family’s lawn mower around the neighborhood in Dad’s utility trailer to earn a few bucks mowing lawns to off -set that college tuition. He is likely to need a Class A CDL if that trailer’s GVWR exceeds 10,000 lbs. Remember, this is in intrastate commerce—see below for discussion of further complication.

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.
 

Booth Sales
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
 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.
 
Sponsorships
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. 

Hotel Reservations
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!
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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!
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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:

• Trailers as “motor vehicles” – educating legislators that by definition, trailers are motor vehicles and as such any legislation using the term “motor vehicle” includes trailers – an often-unintentional inclusion.
• Trailer Safety Week – highlighting the industry’s commitment to trailer safety and the need for legislation to direct support to trailer safety efforts.
• Workforce Shortage – highlighting the critical nature of the workforce shortage and asking legislators to look for opportunities to support skills training, improving access to automation, and communicating the challenges presented by increased unemployment benefits.
• Supply Chain – educating legislators about the significant challenges posed by a disrupted supply chain, lack of domestic production for critical components, and the resulting detriment incurred by tariffs.
• Infrastructure Package – as of this writing, a final Infrastructure Package has yet to be passed. The trailer manufacturing industry has a vested interested in a long-term solution to infrastructure spending and investment in roads and bridges, with a specific interest in potential language related to rear and side underride guards.

 
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! 

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. 
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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. 

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. 

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. 

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. 

• Lock in prices (components, shipping, etc.) as far in advance as possible to avoid inflated prices.
• To find the best ports to ship to, analyze the company's inland network to see where the resources are the most bountiful (i.e., alternative routes if needed, enough drivers and containers, strong infrastructure).
• If there are not enough resources to serve all customers equally, prioritize certain demographics or types of customers. Focus time, attention, and resources on the segments that will bring the most financial stability. 
• Build incentives into supplier agreements such as penalties if they do not deliver on time or cannot hold their end of the contract.
• Give suppliers visibility of the customer base and focus on long-term partnership. The stability may be enticing for them.
• Remember, there is always a lag between normalcy and prices going down. The return to normal is estimated to take another three to six months in the best-case scenario. 

There are, unfortunately, no instantaneous fixes to the supply chain issues present today. The information here is meant to help you think critically about your own supply chain in hopes of preventing or mitigating future issues. Time and the return to normal will eventually bring inflated prices down and allow for more movement within the manufacturing industry. If you would like more information on Sordi's presentation, contact NATM Tracks Editor Elizabeth Moore at Elizabeth.Moore@natm.com

 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.
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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.
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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.
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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.

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Trailer Safety Week (TSW) is an annual nation-wide awareness campaign aimed at increasing awareness of the importance of being committed to trailer safety, educating end-users about proper trailer maintenance and usage, and creating a stronger alliance between stakeholders of the industry including trailer dealers, manufacturers, and end-users. Last year alone, TSW reached over 90,000 individuals.

First launched in 2018, TSW sought to help bridge the gap of communication between trailer manufacturers and end-users. Talking about the importance of trailers built to meet required Federal Motor Vehicle Safety Standards (FMVSS) can be a daunting task as end-users do not understand the complex regulations governing compliant trailer manufacturing. They recognize that they would not purchase a car without seat belts, but they do not understand that buying a trailer without key safety features can be just as dangerous. End-users are vastly under-educated on the proper use of trailers, and it is crucial to utilize the connections that dealers and manufacturers have with consumers in order to raise awareness of proper towing techniques and maintenance.

Getting involved in this important industry campaign shows potential customers that not only is the dealership a leader in the industry, but truly committed to trailer safety. Impress customers and instill confidence in the company’s dedication to safety by joining this trailer safety movement. Participating in TSW is easy!

Becoming an Official Trailer Safety Week Ally is a wonderful opportunity for companies who want to be involved in the safety movement but don't have significant time to invest. The TSW team provides Allies with the official Trailer Safety Communications kit to promote their involvement in Trailer Safety Week and to share information about safe trailering practices. This digital kit includes:

• Pre-crafted social media posts
• Downloadable Trailer Safety Week graphics
• A blog post
• And much more!

Promoting the dealership’s involvement with Trailer Safety Week is a breeze with this jam-packed kit. The content can even be customized to include content specific to the dealership’s typical customer.

TrailerSafetyWeek.com also houses a free towing safely guide to ensure trailer-users have readily accessible safety information at their fingertips. Wow your customers by highlighting this free safety resource that reminds them the dealership is looking out for them and their well-being long after they leave the lot. Topics include:

• Hitching
• Loading
• Trailer Maintenance
• And more!

Now especially, safe trailering practices are important. NHSTA is cracking down on compliance violations, and two recent accidents have brought to light the importance of safe trailering practices. One accident, previously covered in an article on behalf of NHTSA, resulted in a fatality due to inappropriately connected safety chains between the tow vehicle and towed unit which led to disconnection on a highway. More recently, safety chains saved a couple dangling nearly 100 feet above a river.

Safe trailering practices save lives, and with millions of trailers—used by businesses, local governments, and individuals—traversing the nation’s roadways every day, it is crucial to ensure that trailers are being towed safely for the sake of everyone on the roads. NATM calls upon trailer dealers to join the movement in making roadways safer one trailer at a time.
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Learn more at www.TrailerSafetyWeek.com/interest or email TrailerSafetyWeek@natm.com.