First Name | Craig |
---|---|
Last Name | Phillips |
Email Address | cphillips@ironmanparts.com |
Affiliation | |
Subject | Input to the modified Text for Verification Procedure. |
Comment | Page 4 (29) top of page – “Installer” or” Authorized Installer” need to include authorized by applicant to conduct VDEC Service and applicant warranty work on application VDEC with verified service components. Page 6 either add under a Valid Warranty claim – which is well defined as it relates to the Applicant – Please define a valid Warranty claim on the Authorized Service Installer – Page 37 – document starts to talk about a “person” – Ironman shares the following concern and requests a clear definition of what a person means – At different times Ironman have various different levels of installer personnel – in fact we have several categories of installers with different skill levels – so just because personnel have been trained to install a VDEC for example – does not mean they can install a VDEC on any type of application. We have examples where staff leave and either work for an end user or themselves and claim to be authorized by the applicant to install – The applicant does not intend them to be authorized installers unless they are working under the supervision and control of a current VDEC authorized Installer Page 34 – Under component Device Swapping and redesignation – (2) Applicant must receive a written approval from the EO prior to approving a diesel emission control strategy re-designation. We know the EO must approve an applicant redesignation approval – but this reads as if for every redesignation the applicant must get the EO approval – Ironman consider that this may be too time consuming and could create delays that frustrate end user clients. Page 35 – System labelling (1) second last paragraph – The end user must notify the applicant in the event of a damaged or destroyed or missing original strategy label – While it is possible that an end user contacts the applicant – 90% of the time they contact the Authorized Service Installer and we request this from the applicant –practically most end user contact is with the “authorized service Installer” for service and warranty. Page 41 – (4) The assessment must be performed no more than 15 days prior to installation – practically Ironman have complained about this before – sometimes we have literally hundreds of trucks being PIC fail and being repaired for several reasons - the coordination of meeting 15 days with all the various scheduling issues that arise with fleets is unrealistic – I have been asked well how long – is reasonable – 30-45 days will cover most issues – I realize what the intent is – but doing a good job of PIC and getting repairs completed – and then product and scheduling availability – create a time line that for the most part is not under the authorized service Installers control. (Truck busy/out on a route etc.). Page 42 – Training Requirements – The concern Ironman has is the wording of the sentence “The applicant or their authorized installer is responsible for ensuring that this training is presented to the end user before the vehicle, equipment or engine is put back into Service. When Ironman deal with Fleets – we make end user fleets aware of this need for training – especially for their drivers – we offer them various forms of training including on line – but we specifically do not and cannot control who will drive the client trucks and when. While Ironman plays a role in this training – and an important one – this wording of the training responsibility needs to be shared by the fleet owner as well – Page 49 – (d) Installation warranty Report – please release a specific report outline for Authorized Service installers similar to the report that exists for Applicants – And if the recommendation is accepted to define a valid Installer warranty claim (page 6)– then that will resolve any issue we have for clarification purposes here – if not in the definitions – then expand on what makes it a valid warranty installer claim here – Recall provisions in the Verification procedure – CARB have clearly learnt a great deal from the Cleaire recall scenario and there is plenty of new details to follow if the need arises for another Recall – however CARB need to ensure that while the technical process is well defined – the real issue is that the applicant must have the financial or product insurance support to financially ensure completion – Lets learn that the real problem is a financial one when a significant recall is required and that the applicant must have the financial balance sheet or product liability insurance that covers a recall in place – or this is just an academic exercise – to follow if the applicant could ever afford to complete a recall. Pg. 45-47-48 (3) All new section on warranty claim resolution… - This section should cover the issue of the trucks in the field with Longmile installs which for some time will have a Cleaire/ESWT CMM installed -so that clarification and guidance can be provided. |
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Date and Time Comment Was Submitted | 2013-06-11 11:44:20 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.