Emily Reichard Named to NSBA Leadership Council

Emily Reichard of Kinetic Metrics was recently named to the National Small Business Association (NSBA) Leadership Council. NSBA is the nation’s oldest small-business advocacy organization, and operates on a staunchly nonpartisan basis. Reichard, a recognized leader in the small-business community, joins the NSBA Leadership Council alongside other small-business advocates from across the country as they work to promote the interests of small business to policymakers in Washington, D.C.

Click here for the full press release.

OIG Audits NHTSA's Recall Process

The Fixing America’s Surface Transportation Act, or FAST Act for short, required the Office of Inspector General (OIG) to audit the recall processes of NHTSA’s Office of Defects investigation (ODI) and Recall Management Division (RMD). In their most recent report, the OIG found that, despite a 92 percent increase in the number of light passenger vehicle recalls per year and a 199 percent spike in the number of vehicles involved in recalls since 2012, NHTSA has “inadequate controls and processes for verifying and collecting manufacturer - reported information,” which cripples their ability to oversee the implementation of recalls. The OIG’s report identified several key shortcomings in NHTSA’s process and offered recommendations to remedy them.

Primarily the report finds that NHTSA lacks the ability to manage recall remedies, scope, and risk reporting as well as the ability to oversee the implementation of recalls. “The ODI’s monitoring process for light passenger vehicle recall remedies and scope lacks adequate management controls.” The report indicates that the ODI’s process is too limited to ensure that recall remedies are quickly and completely reported by manufacturers. Manufacturers are currently required to report the scope of recalls and recall remedies on an online portal, however, the OIG found that “manufacturers did not submit 28.1 percent of the required scope information  in their initial recall reports, and submitted only 4.1 percent of the missing scope information in their final reports.” The RMD does not monitor manufacturers’ compliance with completing scope information which leads to this absence of required data. The report details that the portal used for reporting scope information only identifies some of the regulatory requirements and that there are no “written instructions to show manufacturer's how to meet those requirements.” Furthermore, the OIG found that the RMD does not take steps to verify the completion rates of recall work despite having the authority to do so. Currently manufacturers “obtain completion rate data from their dealerships. The manufacturers’ employees then manually input the data into RMD’s online recall reporting tool. One company official said that this manual process has resulted in reporting errors.” The OIG offered two recommendations to NHTSA to improve manufacturer reporting so that they receive more accurate and complete information. One, that NHTSA “develop, implement, and document management controls, including a supervisory review process, for monitoring recall remedies, scope, and risk reporting and oversight of recall implementation,” and two, that they “update the recall reporting portal and issue written guidance to identify all recall scope, risk, and completion rate information that regulations require manufacturers to submit.

The OIG’s report also indicates that the ODI lacks a way to monitor manufacturer reporting of recall remedies, scopes and risk information. Their processes are “incomplete, as they do not include management controls to ensure compliance with the specific regulatory reporting requirements.” The report also found that the (RMD) does not adequately assess the scope of recalls involving non- compliant or defective equipment. The ODI and RMD also do not have protocol in place to assess the completion of recall communications from manufacturers as the ODI’s process of monitoring “is too narrow to ensure that manufacturers report recall remedies completely and timely.” Finally, the audit found that the staff of the ODI and RMD lack sufficient understanding of what is required of them in terms of recall monitoring and oversight. While RMD policy states that an engineer must review the manufacturers’ technical remedy instructions for high and medium priority recalls, the  RMD did not document the engineers’ technical reviews in its official records. Instead, the engineers kept informal records of this work.” This lack of formal documentation lead to NHTSA being unable to verify that the Vehicle Defects Division, Office of Vehicle Safety Compliance, and RMD staff conducted appropriate technical reviews for 1,381 recalls, and that further action was not required. For these issues the OIG issued three recommendations. One, That NHTSA “develop and implement a risk-based process to monitor manufacturers’ reporting of recall remedy, scope, and risk information,” Two, that NHTSA “develop and implement a risk-based process—with specific timelines— that provides guidance for Office of Defects Investigation staff on identifying recalls with missing communications,” and three, that NHTSA “develop a training curriculum on staff responsibilities for updated recall monitoring and oversight processes.”

Overall, the Office of the Inspector General found that NHTSA’s management of light passenger vehicle recalls was lacking in several very important categories. NHTSA’s ODI and RMD do not employ adequate processes to ensure the proper reporting of recall scope and remedies, nor the completion of recalls, while their staff lacks proper training and understanding of their responsibilities. This leads to them having incomplete information and documentation of many large aspects of the recall process, making their overall approach to recall management inadequate. The gaps indicated by the OIG’s report highlight the need for manufacturers’ to be proactive and more self reliant when it comes to safety, and recall processes. This is no easy task given the sometimes confusing regulatory requirements of NHTSA. Kinetic Metrics has years of experience and expertise in NHTSA’s Processes and employs unique methods to assist manufacturers’ with this challenge. To read the full OIG report please go to https://www.oig.dot.gov/library-item/36626.

 

Kinetic Metrics Provides US Compliance Seminar

Last week the Kinetic Metrics team traveled overseas to meet with its partner IDIADA in a collaboration to present a US Safety Compliance Seminar. Our experts reviewed several topics, including Federal Motor Vehicle Safety Standards (FMVSS), the Office of Defects Investigation (ODI) process, EPA/CAFE standards and current issues in the US market today. It is important for foreign automakers to fully understand the requirements of the Federal Government as well as the needs of US consumers.

The compliance seminars are set up to not only educate but create a discussion amongst colleagues. We examined the importance of safety compliance and the communication necessary to build a successful product. The seminars that KM can provide may also be catered to specific products and issues at hand.  In addition to the seminars KM can also assist a new automaker with all the required submissions (recall, EWR, etc.).

In our continuing efforts to assist emerging overseas markets we plan to continue our outreach and are available for seminars and similar discussions with clients. Please contact us now for more information. 

Kinetic Metrics Attends Urban Mobility & Urban Planning Seminar

As part of Kinetic Metrics (KM) continuing drive toward its mission, co-founder Emily Reichard attended the Urban Mobility & Urban Planning Seminar on November 2 and 3. State and city DOTs, solutions experts and other innovative thinkers met for two days of information sharing and discussion of the current successes of Smart Cities and the challenges that the industry will need to overcome.

One of the challenges we wanted to highlight were the roadblocks experienced in dealing with Federal regulations. Luckily for the industry, Kinetic Metrics has a thorough background in Federal safety and regulation. Whether it is understanding the new Automated Vehicle Policy or working on how to implement safety policies that coincide with Federal laws, KM is here to help.

The same principles that KM uses to assess vehicle safety trends can also be applied to an assortment of products and services. Whether a community wants to implement bike shares or ride shares, we can assist in making sure the programs are safe and reliable.

Kinetic Metrics will continue to participate in discussions about Smart Cities and strives to be one of the leading supporters of this growing movement towards more sustainable, connected communities. 

Autonomous Vehicle Guidelines

On September 20, 2016 NHTSA released its long awaited guidelines on autonomous vehicle technology. As part of aiding regulation NHTSA will streamline its review process and has committed to issuing interpretations related to highly automated vehicles (HAVs) in 60 days, and ruling on simple HAV-related exemptions in six months.

Within the guidance NHTSA has outlined the framework for vehicle performance and requested that manufacturers and other entities voluntarily provide reports regarding how this framework has been followed. For NHTSA to consider Rulemaking with regards to HAVs, they must be able to support their decisions with data collected from the industry.

As part of our vision, we want to offer unique and efficient solutions to our clients. We can assist companies looking to enter the autonomous market by helping them develop their safety metrics and properly report data to NHTSA. We are also capable of working with smaller city or state governments to guide them in creating regulations that will not hinder the technology while having the flexibility to be adopted by other neighboring cities and states. 

NHTSA has posted the Policy in the Federal docket, under NHTSA-2016-0090 with the comment period ending on November 22, 2016. 

Member Emily Reichard Participates in Regulatory Roundup with NATM

Every year the National Association of Trailer Manufacturers meet in the Nation's Capital to discuss policy, safety and advocate to our congressmen and women the importance of trailer safety in the United States as part of its Regulatory Roundup. 

This year NATM focused on thanking those that signed the FAST Act,  which contained a very important provision for tandem trailer operations. This permits tandem trailer deliveries, making business across state lines easier for manufacturers, while still being in compliance with all state and federal regulations. 

Kinetic Metrics just celebrated its first year of membership with NATM and member Emily Reichard was excited to participate in her first Regulatory Roundup. She looks forward to attending this annual event for years to come as Kinetic Metrics continues to support safety and compliance in the industry.   

 Member Emily Reichard with Allison Malmstrom (NATM), Rep. David Young and Jake Morrison (H&H Trailers)

Member Emily Reichard with Allison Malmstrom (NATM), Rep. David Young and Jake Morrison (H&H Trailers)