The fight not only pits new ways against old, it also reveals modern-day ruptures in the labor market.
Now that 1990 is coming to an end and the limousine manufacturers have addressed many of the safety questions brought up by the National Highway Traffic Safety Administration (NHTSA), what direction will the industry take?
Marty Averbuch, president of the Limousine Industry Manufacturers’ Organization (LIMO), recently outlined some of the achievements of the fledgling group and its plans for 1991 and beyond.
Marty Averbuch of LIMO inspecting the crash dummies in preparation for the coachbuilder organization’s test of a Lincoln Town Car. Among other things the group is now looking into a possible Cadillac crash test.
Limousine & Chauffeur: How would you describe the first year of LIMO’s existence?
Marty Averbuch: A good part of the year was spent on organizational matters which out of necessity had to be done. I wish we had more time to spend on substantive things, but I believe we accomplished a tremendous amount. For instance, we got this group of diverse people to congeal; conducted engineering analysis; and spent a lot of time gathering data from the members to identify problems or potential problems because everyone does not build the same identical car.
We also outlined a program which was acceptable to NHTSA and laid a groundwork in terms of our credibility as an organization. We spent lots of time and effort analyzing brake data and decided that we did not have to do our own test on Lincolns. And we spent more time and resources getting the crash test done and analyzed. That’s where we stand now.
A seal program is the other part of the crash test. It is meant to monitor our members’ compliance and at the same time give the public a readily identifiable means of seeing who is certifying their vehicles in compliance with NHTSA.
L&C: Does NHTSA have the crash test data?
Averbuch: The Transportation Research Center in Ohio has just given them the data. NHTSA wanted information on models, weights, and lengths. In particular they were concerned about the braking and the crash test criteria and most of the safety things such as seat belts, vision out of windows, and obstructing the view of the center high-mounted brake lamp in back. They wanted substantiation. The point of the brake test and crash test is to provide NHTSA with substantiation that verifies when we put the labels on and certify the vehicles, there is some sound engineering and test data to back up these claims.
NHTSA is analyzing the data for three purposes: One, is there sufficient data? Two, that the data indicates test results within acceptable limits. Three, if the people who performed the test were credible. Assuming the review comes up positive, they will be satisfied that we are not falsely certifying our vehicles to the safety standards.
It is within NHTSA’s discretion to accept the data from a group. The Recreational Vehicle Industry Association went through the same thing. You must establish a program with a structure, checks and balances, and some kind of enforcement teeth to the program in case of noncompliance. We did all the groundwork and assuming NHTSA accepts the data, the final step is our seal program.
Basically, the end result of the seal program is that a coachbuilder is allowed to place a gold shield that says “LIMO” on a par which is a clear indication to the buying public that the vehicle was manufactured with the applicable standards in mind. To be allowed to place this on the car, a manufacturer has to be a member in good standing, and sign and comply with a commitment form for the seal. This is not just an empty thing where he can just sign the piece of paper and get away with it. The form has certain requisites of what is needed to be in compliance. For instance, the manufacturer obviously has to have a copy of the FMVSS and the LIMO manual; have registered with NHTSA, as required; and have documentation that shows that a system is in place which addresses the specific techniques and methods used to maintain compliance with FMVSS on all vehicles.
Obviously, a manufacturer could still just sign a piece of paper that doesn’t have any real teeth to it, so at the last board meeting we added the final test to the puzzle. LIMO is initiating a program in which we will hire independent inspectors who are trained in the FMVSS and will monitor the manufacturers’ approach to compliance with the federal standards. They will also be checking to make sure the documents comply with how the car is actually being built. Inspectors will travel around on unannounced, surprise visits throughout the year to each member of the organization. They will make sure the documentation is in proper order and inspect the plant and the cars.
L&C: What would happen if the documentation was insufficient?
Averbuch: The inspector will be writing up a report on his visit to each member. If a manufacturer is in noncompliance, it will be noted and he will have a specific amount of time in which to comply and be reinspected. It is a complicated setup and it is obviously going to have a few bugs in it until it smooths itself out. The intent is that after the grace period for compliance has expired, a coachbuilder will not be able to put the seal on, and they won’t be a member in good standing. They will be suspended from the membership list and we will publicize the suspension. Hopefully we don’t get to that point because the idea is not to keep people out, but to get everyone into compliance.
L&C: The crash test was done on a 7100-pound limousine and that documentation is being shared by all the coachbuilders who are part of LIMO. All the coachbuilders aren’t going to have to individually crash test their 7100-pound cars?
Averbuch: That’s correct. Assuming that the limousines are being built in the prescribed manner and the cars are within the weight, each member can draw upon that information to claim that he is properly certifying his vehicles to the federal safety standards.
L&C: How’s the seal program going?
Averbuch: Everyone who is a member has signed onto the program and has received seals. They should be affixing them to their vehicle and every vehicle that is being delivered should have the seal on it. Obviously it is going to take a little time for the public to become aware in order for the program to have a real impact. But as time goes on, this is going to become a standard in the industry. We will be doing whatever promotions we can to publicize it.
L&C: What other things can we expect to see LIMO working on?
Averbuch: About six months ago, we realized that we had done a lot of work on a narrow issue — albeit an important one. We thought about what else we could do as an association for the industry and our members and sent out a questionnaire and asked everyone to list in order the top three or four issues that we could help them with.
One of the issues listed by coachbuilders was serving as a better information source to the industry. We want to help educate the public because there are a lot of misconceptions about the NHTSA situation. We will be working through L&C, through the NLA newsletter, at the L&C Show, and eventually through the local shows. We hope to eventually start our own newsletter which would go to livery operators as well as our own members. We want to conduct research and testing and improve our products and services.
L&C: What else is on the agenda?
Averbuch: Further testing and research with respect to safety issues. We will be addressing a Cadillac test. Obviously, a good percentage of cars are Cadillacs and we need to test them. Cadillac is coming out with a new model soon and it probably doesn’t make a lot of sense testing something that is going to be relatively obsolete in the near future. I know that NHTSA is looking into Cadillacs on its own.
L&C: What about product liability insurance?
Averbuch: That was one of the things that people were interested in. We have an insurance consultant working on that now. The problem is that you have to gather an awful lot of specific data from every manufacturer before they are willing to insure you as a group. We had an exceptional turnout in terms of people supplying information to us for our programs.
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