Coachbuilders Move Toward Compliance

Posted on March 1, 1990

Jerry Loftus of LIMO discusses NHTSA investigation

Limousine & Chauffeur. What is your personal background?

Jerry Loftus: I am with Humphries & Loftus in Reston, VA. I’ve been with that firm since 1974. We became Humphries & Loftus in 1978. The firm itself has represented the RV industry since the late 1950s, early ’60s. Our firm has represented the recreational vehicle industry since before NHTSA was even around.

L&C: How exactly did you become involved with the coachbuilders?

Loftus: That’s an interesting situation. I sometimes wonder how it happened myself. The van conversion segment of the RV industry over the last five or six years has really gone through a major explosion. We had to create a whole program with regard to the federal standards for the RV industry. We created programs with regard to the standards that applied simply to van conversions. That is not unlike what we have here in the limousine industry. We submitted a representative copy of our program to NHTSA. They eventually put out a release on how effective the program was and evidently, down the line, when they initiated their investigation against the limousine manufacturers, they suggested they come out and talk to me.

L&C: When the coachbuilders first approached you in May 1989, what were some of the organizational things you had to go through?

Loftus: Essentially we had a meeting in Chicago and there were certain things that I foresaw that they had to do. Other than normal legal things like incorporating, they needed an automotive expert because they were going to be involved with automotive standards. And they needed to know how to approach the National Highway Traffic Safety Administration (NHTSA). How to respond to them in a responsible way. They needed to have an understanding of the standards, and for that reason alone they needed an automotive expert. They needed a mechanism whereby they could inform their members of their responsibilities of how to approach the questions in the government’s inquiry. If you don’t, they can kill you. They have the power to subpoena all of your records, they have the power to recall. If you can’t recall the vehicle they can demand that you buy it back.

L&C: What are some of the specific similarities between the limousine industry and the RV industry?

Loftus: The biggest similarity between the RV industry and the limousine industry are the van conversion people who convert vans into family wagons or whatever. They are traditionally part of the RV industry but a different segment than the motor-homes and the travel trailers. They’re like the limousines because essentially they take a vehicle which is certified and they alter it — they do something to the inside of the vehicle, and then they have to certify it themselves. The two are akin.

When the van industry first started to blossom into the family-type vehicle that it has now become, the van conversion manufacturers themselves felt that something had to be done in order to promote the safety of the vehicle and to prevent black marks getting on their

‘There have been a couple of accidents but there is no serious accident data.”

production because of somebody else who was not complying. So they chose to get together as a group. They wanted an inspection program to be imposed on their industry and they wanted a special inspection program. They wanted something which would make them a cohesive group and also to assure themselves of their product. Then they could advertise their product as being in compliance.

There were a lot of standards that applied. Flammability for instance, fuel system integrity, weight, front end crush, — some of the things we have talked about in LIMO. The majority of the standards that apply to the van people also apply to limousines. So they came and asked us to get a program for them. And we did. We created a program for them. We created a book of the federal standards, explaining the federal standards, and giving them guidelines on how to meet those standards. We established an inspection program to assist them in their efforts to comply.

We don’t inspect to the federal standards because they are too complex. What we established is a system whereby the manufacturer needs documentation to show how he is incompliance with the federal standards. For instance, flammability. There is no way you can determine if your material meets the federal standard unless you burn it. So how do you show the compliance? You get documentation from your fabric supplier to show your fabric complies with the standard 302. He gets that documentation and puts it in a book and our inspectors can see that. For seat belts, he has plans and indications showing where he places them and how he anchors them. So we don’t inspect for the federal standards, but the inspector has a system to follow to determine what is necessary to certify the vehicle.

L&C: So it is a matter of engineering documentation?

Loftus: Not necessarily engineering documentation because in some instances you wouldn’t need an engineer to document it. Documentation to show knowledge of the standards and to show an approach to compliance.

L&C: How would they go about in the limousine industry documenting, for instance, the frontal crash?

Loftus: That choice of example might be poor. Those Vehicles come from Detroit certified. Unless a manufacturer does something that would alter that certification, then he wouldn’t have to retest or recertify. I don’t know with regard to the frontal crash at what weight Detroit would say, “Now you have altered this to a certain degree, we no longer will certify it.” That will be in the documentation from Detroit to the limousine manufacturers. If it were a matter of limousine people having to recertify, then they would have to test. And this is why we have Bob Madison involved — to determine just what we have to do or how far we have to go.

L&C: So if Lincoln certifies their Town Car to 7100 pounds GVW, as they are proposing to do, then the limousine convertor would only need Ford’s documentation if they build a vehicle less than that weight? Would he have to recertify it?

Loftus: He is an alterer — so he would still have to recertify. He has to recertify his altered vehicle so it is in compliance with any of those applicable standards which his alteration has affected. He possibly wouldn’t have to recertify the front end crush for instance if he remains within the weight given by Detroit because you would presume that if he stays within that weight, it will pass.

L&C: Tell me how LIMO is addressing each of these standards Hydraulic braking — is that a weight question?

Loftus: It definitely is a weight question and it is something that Bob Madison is looking at right now. We have approached a couple of testing laboratories to determine what would be involved cost-wise, time-wise, etc with regard to testing vehicles with regard to weight. And I think what we have to determine is where do we go from here? Do we want to take a unit and load it up completely, put as much weight as we can in it, test it to see just exactly how far we can go with that vehicle. That is something we have to determine.

L&C: Tire selection?

Loftus: That is pretty self-evident because your tires have to support the load or they don’t.

L&C: How many coachbuilders are upgrading their tires?

Loftus: I would presume that they all are. Again, this is an educational process. They are determining what their gross vehicle weight is and then are matching tires to meet that weight.

L&C: Steering displacement?

Loftus: That again is a weight question and remains to be seen. At this point we have no reason to question compliance. Madison feels that we could very well be in compliance.

L&C: Cadillac and Lincoln seem to be helping by increasing the GVW of their vehicles.

Loftus: It is helping quite a bit. For Lincoln, if you figure the jump, not only to 6400 pounds but also to 7100 pounds, the curb weight of those vehicles is around 5400 pounds. So you see when it comes up to 6400 and 7100, that’s 1700 pounds that you can add. Calculating that available weight, you have to include 150 pounds times the number of available passenger seats.

NHTSA has no specific weight you have to calculate for inside the trunk space, but they say a reasonable amount of luggage. And what is reasonable. I’ve seen studies done that say the average load on these vehicles is only 2-3 passengers, and the average trunk is nowhere near 200 pounds, it’s more like 50-60 pounds. So the added capacity that Lincoln is giving is probably going to go a long way to solving the problem. And NHTSA understands this. NHTSA knows that they are adding capacity and it’s going to help quite a bit. Also, NHTSA does not have any data on problems. There have been a couple of accidents but there is no serious accident data.

L&C: What about fuel system integrity, we haven’t heard a lot about that?

Loftus: No we haven’t. It’s a question that has to be answered and can only be answered in conjunction with Cadillac and Lincoln in knowing the parameters to which they are testing. Normally, our guys don’t mess around with the fuel system other than extending the line. Mainly they are just cutting and adding to the fuel line. And if they use the proper tubing, I’m not an engineer but I find it hard that they could do anything else wrong. And I’m pretty sure that’s what Lincoln and Cadillac do. We call FMVSS 301 the martini standard because it can’t spill an ounce of fuel when you crash the vehicle into the wall and successively turn it over in quarter turns. They rotate the vehicle and if it spills an ounce of fuel, it is in violation. But if they are extending lines, most of these guys use OEM tubing.

The only other problem is that you have to know the parameters to which Detroit has tested that vehicle. The added weight may cause crush to the fuel system, where it shouldn’t be. I don’t know. That is something that Madison is checking. The way that they have developed the chassis in these cars, when you hit a wall, the chassis will bend at a specific crush point to avoid the engine being forced back into the passenger compartment. There is built-in crush. They’ve built in programmable crush so that chassis will bend at a certain spot. With that type of thing, added weight may or may not affect it. It is going to crush at that spot anyway.

L&C: What about the labeling?

Loftus: That is another obvious thing that they should do. Because they are alterers, by federal regulations they are required to attach a certification label to their vehicles.

L&C: Will NHTSA expand into other vehicle standards? They have concentrated on these so far.

Loftus: I think these are the most important ones. But NHTSA will expand into every standard that is applicable and they will expect conformance with those standards.

L&C: So are the members of LIMO to examine each standard?

Loftus: Yes, because it is a self-certification law. It requires the manufacturer to certify and only if he fails in that certification will NHTSA step in.

L&C: Are there any other standards where you are concerned about non-compliance?

Loftus: Other than the window glazing standard, no. Only peripherally — for instance, side-door crush and side-door strength. That’s a standard that is applicable to all passenger cars. The way the coachbuilders reinforce their doors, it would be hard for me to believe that the vehicle would not be in compliance. There are standards that do apply, but any one of them I’m not really concerned about.

L&C: How would you describe LIMO’s working relationship with NHTSA?

Loftus: NHTSA can be either a watchdog or an enforcer. They have been in their watchdog mode right now and have given the limousine people time. We have really convinced them that the limousine manufacturers need to be educated. So NHTSA hasn’t really come down on the manufacturers hard because they need to be educated. They feel very confident that the LIMO people are responding.

I think in the future, they are going to put on their enforcer hat, more so than their watchdog hat. In other words, NHTSA will now move into their enforcer role. I think in the future year’s production, they are going to be looking to see what the manufacturers have done to assure compliance with those standards. The law is stated for self-certification by the manufacturers, if the manufacturer fails to do so, then NHTSA steps in.

From our standpoint, NHTSA has been very reasonable I think in the meetings we’ve had with NHTSA, we’ve convinced them that this is an association of manufacturers who are concerned about the standards and the safety of their product. And will do what has to be done in order to conform once they know what has to be done. NHTSA understands that the manufacturers are trying. Otherwise they would have jumped in and ordered recalls all over the place. It is a growing process.

L&C: Is it to LIMO’s advantage to declare a length and weight limit?

Loftus: Associations cannot do that because, first of all, it would be infringing on the anti-trust laws. There is no indication that a given length or given weight has anything to do with each other. Detroit says they are certifying this vehicle at 7100 pounds — if I build a vehicle at 500 feet and still remain within that 7100 pounds, I’ve got a complying vehicle. If I build a vehicle of whatever length and exceed the 7100 pounds and go out and get it tested to show that it will comply with the standards, then I’ve got a complying vehicle. So it is not the role of the association to say. “You must build this type of vehicle.” That would lead to an attack on competition, boycott, antitrust laws, and the government would be right on top of us.

L&C: But LIMO’s objective is to determine which vehicles will be in compliance?

Loftus: No. LIMO’s objective is to educate its members on the steps that need to be taken in order to comply. Through information, through testing, whatever, the association wants to help its members in what they need to know in order to certify their vehicles. It is not the association’s purpose to tell the members what they have to build. It’s purpose is to show how they can approach compliance.

L&C: So it is just to give them the parameters of compliance. It will not say, “If you want to be part of LIMO, you have to build to this length or weight.”

Loftus: That’s right. I think also it could come down to the point that if the association test, and the tests show, “All right, fine. You cannot exceed this length in order to pass the test.” Well that’s where the line is drawn — simply giving the manufacturers that information. The association cannot say, “Therefore if you build past that length, you can’t belong to the association.” That would infringe upon anti-trust laws. There is nothing to say that a manufacturer who builds past that recommendation hasn’t found a way to certify it.

L&C: What about the manufacturers who are not part of this association? Some of them are conducting their own testing. I heard mention of a LIMO sticker put on each vehicle, how will that affect companies not in the association?

Loftus: The object is to certify your vehicles. I would hope the manufacturers would come to appreciate the fact that the reason for the association goes far beyond the ability they will achieve in understanding the standards and certifying their vehicles. If somebody goes out and tests and certifies their vehicle, that is fine. But the association is helping those members who either can’t do it or don’t understand what the standards are. The association is performing a function in those areas. I would hope the members appreciate that the value of the association goes far beyond the response to NHTSA.

L&C: The association is a service to the operators to a certain extent also, isn’t it?

Loftus: There is always strength in numbers. And the operators know that if there is an association backing this program, they will be more prone to listen than if somebody else does it on their own.

L&C: Will LIMO members have to pay an annual dues?

Loftus: That’s up to the board. I think they are envisioning something like that.

L&C: What direction will the limousine industry take in the future with regard to the LIMO organization, the limousine market itself, and the dealings with NHTSA? Will this weed out some manufacturers?

Loftus: I think the standards are pretty well set. I don’t see any major changes from the ones we have already in the next decade with a few minor changes. These are passenger cars and are treated as passenger cars. And for all intents-and-purposes, the standards have been in place since Day 1. So I don’t see any major shifts in the standards.

So far as the association is concerned, if the members can perceive the value of it, then I see a cohesive group where they can present themselves not only to the customers but to the general public as a viable force. It certainly would aid the marketing of their product. I’ve seen it in a variety of other associations that I’ve been involved with. It will continue to grow and become a force in the market.

I know they are in rough times right now. Every industry has rough times and they will come through it. The RV industry in 1979-80 lost 80 percent of its products. It came back fine. But the fact that the limousine manufacturers have come together into a nucleus is really a positive step and I hope they can use it to its fullest extent — whether it is through trade shows or marketing. It is a valuable step but unfortunately what brought them together was the threat of federal government action. By the same token, it could be a blessing in disguise. There is strength in numbers and what they can do in a group far exceeds what they can do individually.

A Message From LIMO

A federal inquiry into limousine safety, begun early in 1989, has sparked some concern and confusion. It gave rise to a new association of manufacturers which will positively affect the industry’s future. Through this young organization — the Limousine Industry Manufacturer’s Organization (LIMO) — manufacturers are taking a responsible approach toward basic compliance with federal vehicle safety rules.

LIMO was born in response to last April s inquiry into vehicle compliance by the National Highway Traffic Safety Administration (NHTSA), the federal agency which issues auto safety regulations. NHTSA wrote to some 57 limousine producers, asking for evidence of compliance with a number of regulations.

For some of the questioned rules — such as seat belt requirements, a certification label, and headlamp requirements — determining compliance is a fairly straightforward matter. Evaluating adherence to other regulations, however, is more complicated, involving detailed engineering analysis and/or crash testing. Other areas questioned by NHTSA concern the relationship of “stretch” and added weight, chassis-manufacturer-certified braking systems and steering wheel rearward displacement standards, the adequacy of tire and rim assemblies, and the effect of extending fuel lines on compliance with fuel system integrity standards; and flammability rating of interior materials. Also questioned was whether tinting of windows affects compliance with glazing standards.

We have held meetings with NHTSA staff to clarify the regulations and establish our interest in cooperating to maximize vehicle safety.

LIMO hired an engineering expert to analyze member companies’ vehicle data, give advice on areas where compliance may be questionable, and suggest methods for determining compliance.

Meetings were organized with original equipment manufacturers to secure information on the safety parameters of their cars, possible effects of “stretching” on maintaining their certification of compliance, and components available for altering systems affected by added vehicle weight and length.

LIMO consistently had urged members to act, to evaluate their vehicles, conduct voluntary recalls if necessary, and to certify compliance with standards for current and future production.

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