RVDA SPECIAL: Understanding

RV Specific Regulations

Brett RichardsonDirector of Regulatory Affairs, RVDA

Eric SchmitzVP, Product and Business Development, KPA

Moderator

Rebecca Ward

Sr. Marketing Content Specialist

(303) 219-7802

rward@kpaonline.com

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Management, and Sales & Finance Compliance.

• 8/10 of the largest dealership groups in the

country count on KPA.

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state dealer associations

• Founding member of the Clean Auto Alliance.

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Compliance programs that help our clients achieve regulatory compliance, control risk, protect

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largest dealership groups in the country, count on KPA for Environmental Health & Safety, HR

Management and Sales & Finance Compliance programs that save them time and save them

money.

KPA minimizes risks and maximizes profit for

5,200 dealers nationwide.

Presenter

Brett RichardsonDirector of Regulatory Affairs BRichardson@rvda.org

Presenter

Eric SchmitzVP, Product and Business Development, KPA

eric@kpaonline.com

303-228-8766

Questions

If you have questions during

the presentation, please

submit them using the

“Questions” feature

Questions will be answered

at the end of the webinar

OSHA Safety Issue

• Question: How does your dealership move RV’s around the premises? – Truck?

– Tractor?

– Forklift?

– Power Mover ?

– Other?

OSHA – Forklift Attachment

• What is a Forklift Attachment

• What Are OSHA Rules

– Approval Required

• How to Get Approval

– Forklift Mfr or Engineer

• Risks / Alternative

FMCSA – USDOT Numbers

• Issue: Dealership employees being pulled over and being asked for USDOT Numbers, and fined if they don’t have them.

• How many of you?– Pick up RVs from Manufacturers?

– Deliver RVs to customers?

– Transport RVs to RV shows within / outside the state?

– Transfer RVs between Dealerships in different states ?

FMCSA Definition Commercial Motor Vehicle

• Commercial motor vehicle means any self-

propelled or towed motor vehicle used on a

highway in interstate commerce to transport

passengers or property when the vehicle –

• (1) Has a gross vehicle weight rating or gross

combination weight rating, or gross vehicle

weight or gross combination weight, of 4,536

kg (10,001 pounds) or more, whichever is

greater;

If you operate a CMV in Interstate commerce

• A USDOT number is required if you have vehicles that are over 10,000 lbs,

• No fee is required. But you must complete the MCS-150 (Motor Carrier Identification Report) and a MCS-150A (Safety Certification Application) to obtain a USDOT number.

• The forms can be found on http://safer.fmcsa.dot.gov.

Commercial Driver’s License: Classes of License

• The Federal standard requires States to issue a CDL to drivers according to the following license classifications:

•– Class A -- Any combination of vehicles with a GVWR of 26,001

or more pounds provided the GVWR of the vehicle(s) being towed is in excess of 10,000 pounds.

– Class B -- Any single vehicle with a GVWR of 26,001 or more pounds, or any such vehicle towing a vehicle not in excess of 10,000 pounds GVWR.

– Class C -- Any single vehicle, or combination of vehicles, that does not meet the definition of Class A or Class B, but is either designed to transport 16 or more passengers, including the driver, or is placarded for hazardous materials.

NHTSA – Tire Information Safety Rule – FMVSS 110

• Tire Size and Pressure

– Not too applicable to RV Dealers

• Motorhome and RV Trailer Cargo Carrying

Capacity

– A dealership adds components that change the

combined occupant/cargo capacity weight limit listed

on the manufacturer’s FMVSS placard.

NHTSA – FMVSS 110 Tire Placard “Vehicle Placard”

A “vehicle placard” is the label or notice displayed on a vehicle

indicating the appropriate tire size and tire pressure, as well as the

cargo carrying capacity of the vehicle.

Motor Vehicle

Placard

Trailer Placard

Cargo Carrying

Capacity

Cargo Carrying Capacity Labels

• RV Dealers have compliance obligations when they add additional weight

(over a certain threshold) to an RV that impacts its Cargo Carrying Capacity

Thresholds for Dealer Compliance

• Compliance is triggered when the RV dealer changes the weight

of a Motor Home OCCC labels or RV trailer CCC labels by the

following amount:

– By the lesser of 1.5 percent (.015) of GVWR or 100 pounds.

– E.g. 6,000 lb RV X .015 = 90 lbs

– E.g. 10,000 lb RV X .015 = 150 lbs

• The total weight added by the dealer cannot exceed the load

carrying capacity weight value initially provided by the RV

manufacturer since that would cause to RV to exceed the GVWR

established by the chassis manufacturer.

Dealer Compliance Options

• Dealers / service facilities are offered three options that can be used to correct load carrying capacity information when dealer added weight exceeds the threshold. Dealer / service facilities are permitted to:

– (1) Replace existing tire placards, motor home OCCC labels or RV trailer CCC labels with new placards / labels containing correct load carrying capacity information;

– (2) Modify existing tire placards, motor home OCCC labels or RV trailer CCC labels so they display correct load carrying capacity information; or

– (3) Add a load carrying capacity modification label within 25 mm of the existing tire placard and/or motor home OCCC label or RV trailer CCC label.

• When correction of load carrying capacity is needed, this rule permits the use of generic labels where corrected values can be legibly entered using a black, fine point, indelible marker. This permits dealers to stock one generic load carrying capacity modification label.

Option 3

RV Dealers Subject to CFPB

• Traditional RV Dealers, along with automobile

dealers are exempt from direct CFPB oversight.

• However, RV Dealers may be subject to CFPB

direct oversight if:

– RV Dealers without a service operation

– RV Dealers operating a Buy-Here-Pay-Here business

– Potentially sales to fulltimers who intend to use the

RV as a residence

OSHA – Fall Protection Requirements

Fall Protection:

• Equipment

• Written Program

• Training

• Use

EPA – Refrigerant Service

Note that while buses using CFC-12 are MVACs, buses using

HCFC-22 are not MVACs or MVAC-like appliances, but rather are

high-pressure equipment covered under Type II of section 608

EPA ∫608 vs. EPA ∫609

• Employee training is key

OSHA – General Industry / Construction

Hazards Associated with:

• Plumbing Repair

• Word working

• Interior Finishing

• Upholstery

Top OSHA Citations for RV Dealerships

Oct, 2013

through

Sep, 2014

Questions and Answers

Contact Information

The recorded webinar and presentation slides will be emailed to

you today including your local representative’s contact information.

www.kpaonline.com