Originally Posted by Tireman9
Thanks for the quote. So according to NHTSA if consumer bases their purchase decision on the various certification labels, the consumer is wrong to expect the RV to be able to actually carry the calculated capacity? What is a consumer suppose to do when making a purchase decision if not rely on the Federally Regulated and required cert labels?
Suppose an RV was delivered with labels indicating GVWR of 10,000# and GAWR of 4275#. Empty weight (not required on cert label) was 8000 leaving 2000# load capacity.
This puts 14.5% of TT weight on the ball. It is recommended that hitch weight be 10 to 15% of the trailer weight.
So then it is discovered the RV company actually used 3,000# axles and tires. So the NHTSA recall is covered simply with new stickers showing GAWR of 3,000 and of course the much reduced GVWR of maybe 8000 to 8,400# with a new load capacity of 0 to 400#.
Explain how the owner should respond? Will NHTSA say it was the buyer who made it incorrect assumption that the certification labels were correct and simply didn't do proper shopping?
Sorry I don't buy the "Fix" as appropriate if the error is much more than 100# especially if a buyer compares the certification lable number on similar RVs from a variety of different companies or maybe even from the same company.
The trailer manufacturer is not going to change an existing GVWR, that's a vehicle modification. However, reducing the load capacity is basically a pen & ink process. So is reducing the total GAWR down to a new value to coincide with the new cargo capacity and allow the OE tires to provide the load capacity to support the axles. Those steps are authorized by the FMVSS building regulations. Another pen and ink process would be to leave all the specs as they are. IMO FR will not do that because it would require them to recall all of the to small tires and replace them with some that fit the axles load capacities.
When you read the procedures used to make pen & ink changes on the cargo capacity labeling nothing in the trailer's specs changes except it's available cargo load. When FR submits it's remedy for the situation we are writing about here it's most likely going to reduce the cargo capacity and each GAWR to a value that will allow the OE tires to stay on the vehicle. My guess is the GAWRs (2) will be reduced to 6750# ea. The loss of 500# of load capacity is not going to make any of the current owners happy.
All of the cargo instructions were rewritten in the 2007 rules package and are in the current FMVSS 571.110 & 571.120 standards.
Here is a reference containing the rational used to gather the information necessary for the committee to make it's final ruling. Although good reading that provides a lot of insight into the process of change, the reader must understand that only the information in the actual final ruling at the end of this document is used to change the documents effected by the ruling.