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Wilson argues that if the NHTSA requires additional information on parts from manufacturers, recyclers, for example, will be much better able to participate in recalls, diminishing the argument made in the past by companies such as Chrysler LLC, which said in an August 2010 document entitled "Structural Repair Parts Usage:" Salvage components are not traceable should a component recall be required in the future.
Of course, many service stations and collision shops depend to some degree on salvage parts. A few larger companies, such as LKQ Corp., sell salvage parts to aftermarket retailers.
The battle between recyclers and manufacturers is over NHTSA's implementation of a provision in the Moving Ahead for Progress in the 21st Century (MAP-21) Act passed by Congress last July. One of its requirements is that NHTSA make motor vehicle safety recall information available to the public on the Internet, and make that data be searchable by vehicle make and model and vehicle identification number. Additional information that would have to be submitted, but which is not currently required, includes the brand name, model name and model number of the equipment recalled. Recall information would have to be updated by the manufacturer daily, and uploaded to www.safercar.gov, which would be equipped with a new, enhanced search tool.
But the ARA's Wilson says NHTSA should demand that manufacturers produce more information. That should include Original Equipment Numbers, Part Identification Numbers for both the recalled part and the remedied/replaced part, along with build sheets with textual part description, published service and recall bulletins, remedy/repair procedures, along with all current and superseded numbers for the recalled items. In addition, Wilson wants NHTSA to group that data in such a way that it can be accessed by third parties in a "batch format so that these parties can download the complete recall database into their locally installed inventory management systems.
Wilson argues that providing this information "poses no significant hardship to the OEMs." That is because they already share VIN, product number and build sheet data with insurance and service/repair facilities through systems such as service repair providers Motor, Mitchell 1, ALLDATA, along with collision repair providers Audatex Estimating and AudaVin, Mitchell’s UltraMate and Repairmate and CCC’s Pathways and Comp-Est products.
That may be true. But the Alliance of Automobile Manufacturers isn't likely to buy the recyclers "expanded data" request, since the association doesn't even want to supply the data to NHTSA. Robert Strassburger, Vice President of Vehicle Safety and Harmonization for the Alliance, explains that the auto manufacturers already put the information NHTSA wants, including by VIN, on their own websites where consumers can find it. That is where it should stay, he adds.
NHTSA itself concedes that the language of MAP-21 is unclear as to which website the new information should go on. The proposed rule NHTSA issued admits the law "is silent with respect to who is required to make safety recall information available, which manufacturers are subject to the requirement, the types of safety information to be made available and how and when the information is placed on the Internet."