Safety Standards for RV Construction???

[Dutch_12078]

1 hour ago, Kirk W said:

While I have not been in the new RV market for several years and have not bought a new one in 10 years, based upon the posts here about the standards of RVIA, the new RVs today must be nearly perfect as they arrive from the factory as long as they have one of those RVIA decals! 

                                                

The manufacturers are claiming the unit meets the minimum requirements called for in the standards when they apply the sticker. Is that "perfection"? Nope, we all know better than that...

[HMFunk]

 

I’ve been reading this thread, and thought I should perhaps post some comments. Now, I may not know a lot about this topic, however in times past I was the Corporate Director of Codes & Standards at &%$#@ (name omitted, but a top-5, multi-facility, full-range RV manufacturer)..........

Please excuse the long post, but this is a complex topic. Based upon my experience, I make the following comments:

1. RVIA is indeed an Industry-specific organization, composed of Industry-specific people who are knowledgeable in Industry-specific construction, performance and safety issues. They are not an unbiased organization, because they are aiming to ensure that certain levels of design, build and performance parameters are consistently met by RV manufacturers as reflected in their products.

2. Respectfully, Kirk W, RVIA standards compliance DOES PROTECT the RV consumer, not just the manufacturers. This is accomplished by requiring the manufacturers to ensure that their products (RV’s) meet certain established minimum Industry-relevant standards. This provides a level of protection to the RV consumer. Of course, the manufacturers are also protecting themselves, and limiting their legal liability at the same time in that same process.

3. Many states have adopted the RVIA standards as adequate representation that the RVIA-sealed RV’s have been designed and manufactured in an industry-acceptable manner. Some states require that any RV sold in their state demonstrate this by bearing the RVIA seal. “Non-sealed” units cannot be sold to dealers in those states. This is a factor to be considered by the individual manufacturer, because if they want to sell units to dealers in those states, those units must be RVIA – sealed.

4. Some states have no regulations regarding the standards that RV’s sold to dealers in their state must meet.

5. Certain states have their own requirements that the manufacturers must meet. For instance, in addition to the RVIA seal, these states may require a manufacturer to submit floor plans and system plans (structural, mechanical, electrical, safety, etc.) for each model of RV to be sold in their state. Upon approval of those plans, that model RV may then be sold in that state. Those states usually require that a state-specific sticker be affixed to each RV to be sold in that state. Examples of this during my time at &%$#@ were Arizona, Nebraska, Oregon, Washington, West Virginia and others. Some states require a monthly report of approved RV’s (by model designation) sold to dealers in their state. That list of states will change from time-to-time, based upon their current legislation. The Codes and Standards Director of each manufacturer must ensure that compliance with those state requirements is maintained, if that manufacturer’s RV’s are to be sold there.

6. Canadian Standards Association (CSA) requires a physical inspection, and the use of a seal certifying that inspection, for each unit sold in Canada.

7. The RVIA inspections are both announced and un-announced. The RVIA inspector always has the right to choose which facility, production lines and on-hand inventory will be observed and/or inspected during those visits. RVIA inspectors have the authority to halt a production line if a serious defect/non-compliance is found during their visit.

8. The RVIA is available for consultation by member manufacturers during their design processes, to ensure compliance to RVIA Standards.

9. RVIA oversight IS REAL OVERSIGHT! I respectfully disagree with Kirk W’s comment that the RVIA exists to protect RV manufacturers from folks like NHTSA (National Highway & Traffic Safety Administration), because, just like the EPA, the NHTSA can enforce their standards anytime and anyplace they desire. Each manufacturer should aim to meet all NHTSA requirements, or know that they risk legal exposure if the requirements are not met. As it happens, compliance to RVIA standards helps the manufacturer cover most of the NHTSA requirements. However, the fine print in the RVIA contract specifically states that compliance to RVIA standards SHOULD NOT BE CONSTRUED as a guarantee of NHTSA compliance……

10. Certainly, the RVIA seal is an aid to sales, because it is a sign that certain design and manufacturing efforts have been utilized so as to provide a certain measure of compliance with relevant standards. It is not a sales gimmick or promise of quality, but it does give the consumer a bit of confidence when making a purchase.

11. Not all manufacturers are RVIA members or participants in RVIA seal procurement and usage on their products. For example, my Class-8 Chassis motorhome was manufactured by a very-low-volume manufacturer, and it does not wear the RVIA seal. No matter though, as the mode of design and manufacture they use is totally different from a high-volume manufacturer. That low-volume manufacturer, however, cannot sell coaches to dealers in states requiring the RVIA seal or having their own certification standards.

DISCLAIMER: The Codes and Standards scene constantly changes. During my years at &%$#@, I had a current list of states and their individual requirements, but that list was the property of &%$#@, and I left it there when I left that company. Due to the “laps around the sun” since my time at &%$#@, I’m sure there have been changes of which I am not aware. However, I am confident that a great bulk of what I have written here is still correct. My apologies for any inaccuracies written above.

Hope this helps clarify a few things!

Travel Free!

H&M Funk

2008 NRC 45-Foot ”Super-Duper C” Motorhome on 2007 Freightliner Columbia Chassis

2006 Pre-Emissions Detroit 14L Series 60 Engine w/ 12-speed Meritor Freedomline

 

 

[Kirk W]

5 hours ago, HMFunk said:

Many states have adopted the RVIA standards as adequate representation that the RVIA-sealed RV’s have been designed and manufactured in an industry-acceptable manner. Some states require that any RV sold in their state demonstrate this by bearing the RVIA seal. “Non-sealed” units cannot be sold to dealers in those states.

My question remains, what states have adopted the RIVA standards into law and document somehow that they have done so? If that is true it should not be that difficult.

[Dutch_12078]

15 minutes ago, Kirk W said:

My question remains, what states have adopted the RIVA standards into law and document somehow that they have done so? If that is true it should not be that difficult.

Kirk, maybe this article will answer your question at least in part:

RV Industry Association State Team Lays Out Policy Priorities For 2022

https://www.rvia.org/news-insights/rv-industry-association-state-team-lays-out-policy-priorities-2022

[Kirk W]

23 minutes ago, Dutch_12078 said:

Kirk, maybe this article will answer your question at least in part:

Quote

In Nebraska and Washington, manufacturers have run into several issues getting plans approved to allow certain RVs to be eligible for a state seal, a requirement for selling to dealers in those states.

Quote

In many states, RVs are covered by automobile franchise laws even though auto dealers and RV dealers operate under very different business models. Unlike the automobile industry, there are no true franchises in the RV industry.

Your article not only comes from RVIA, but it does not list any states that have adopted their standards. Name the states that have adopted the RVIA standards. 

[Dutch_12078]

1 minute ago, Kirk W said:

Your article not only comes from RVIA, but it does not list any states that have adopted their standards. Name the states that have adopted the RVIA standards. 

None that I'm aware of, and I have no idea why they would feel the need to do so unless they could use it as a revenue source. I'll bet the state seals issued by NE and WA aren't free.

[Dutch_12078]

18 minutes ago, Kirk W said:

Your article not only comes from RVIA, but it does not list any states that have adopted their standards. Name the states that have adopted the RVIA standards. 

On further thought, it occurs to me you're asking the wrong question. The RVIA has adopted NFPA 1192 as its standard, so the question should be which states have also adopted 1192 as their standard. Here's a link to a good start for your research: 

https://www.google.com/search?q=which+states+have+adopted+nfpa+1192

[HMFunk]

 

OK, here is my short answer to the question about states’ adoption of RVIA standards for commerce regulation purposes:

States that have no requirements of standards compliance for new RV’s sold: more than 10

States that utilize the RVIA standards (and the RVIA seal) as acceptable evidence of standards compliance: fewer than 30

States that have established their own approval system and dedicated state certificate of standards compliance, model-by-model: Fewer than 15

These are my estimates only, based upon past experience. Getting up-to-date and more detailed information would only be possible directly from an RV manufacturer’s Manager of Codes and Standards Compliance.

 

Now I have a question for everyone (quoting an infamous retired politician): “What difference, at this point, does it make?” Every dealer selling new RV’s can give information about their own state’s requirements. And, unless one really digs into reading (and thoroughly understanding) the text of the applicable NFPA, ANSI, NSF, NHTSA, EPA, NEC or other standards, even knowing which standards have been adopted by which state will have only marginal value……..

Frankly, I’m glad to no longer be responsible for being kept current on these matters!

Travel Free!

 

 

 

[jblo]

Mr. Funk,

Thank you for taking the time to make these posts, not an easy deal.   

I personally feel that "having/adhering to a standard" does not cross over to quality control, which seemingly is the basis for most complaints about RV construction. Until mfgs find it more cost-effective to improve quality than to rebuild/repair units under warranty, nothing will change on that front.  

"conducts more than 2,000 unannounced inspections of member company RV manufacturing plants annually"   Would really be interested in knowing the extensiveness of these inspections and the qualification of the inspectors. How many inspectors do they have?

Edited November 21, 2022 by jblo

[Ray,IN]

Kirk, theres a big step from theory to reality, and IMO RV mfgrs. missed it.

[Kirk W]

8 hours ago, Ray,IN said:

Kirk, theres a big step from theory to reality, and IMO RV mfgrs. missed it.

I agree with you. The RIVA supporters sound like politicians as not one bit of evidence that some state has adopted the RIVA standards into law is offered in the responses which is the question asked. Do you know of any state that has officially adopted the RIVA construction standards? If you do can you direct me to something that addresses the standards?

Look at the many threads about poor quality new RVs, RV warranty problems,  or buying used RCs to avoid warranty issues and then tell me how well the RIVA standard is improving the quality of RV construction.

[oldjohnt]

I have no idea about standards and compliance HOWEVER as a 50 year RV owner and past used dealer its MY OPINION most RV's, especially the entry level, suffer poor quality in manufacturing materials and methods (built fast, light and cheap) but if built better the price would obviously increase.. Even if you had a higher quality build/chassis like an Airstream or Prevost they may have the same usual suspects such as Dometic, Norcold, Suburban, Atwood, Lippert components. I follow the industry and I swear I see soooooooo many often very premature failures of modern gadgets such as slide outs, levelers, power awnings, some of the aqua heat and water systems, on and on and hear horror stories of months repair wait times. If a person had to have all the latest bells n whistles and couldn't do most of his own repairs it would drive him to drink and/or get out of the camping all together.

Sorry dont mean to rant n rave Ive RVed 50 years (pretty well made own repairs) still doing it and hope for more years Good Lord willing. When young and raising a family we went CAMPING (coleman stoves, lanterns, camp fires, always cook outside etc etc) however nowadays we RV TRAVEL still love it.

 Have a Happy Thanksgiving everyone   

John T  Somerville Lake Texas headed to Lakeway for T Giving with my favorite daughter and favorite SIL mooch docked in their driveway, you dont wear out your welcome so fast that way lol

[HMFunk]

On 11/20/2022 at 7:11 PM, jblo said:

 

"I personally feel that "having/adhering to a standard" does not cross over to quality control......Until mfgs find it more cost-effective to improve quality than to rebuild/repair units under warranty, nothing will change on that front."  

"(RVIA) conducts more than 2,000 unannounced inspections of member company RV manufacturing plants annually"   Would really be interested in knowing the extensiveness of these inspections and the qualification of the inspectors. How many inspectors do they have?

jblo:  You're very welcome.  And you're absolutely correct on 2 points:

1.  RVIA standards compliance does not impact product quality directly, since RVIA standards relate to systems safety, systems performance and product design, not to the care/lack of care taken in the actual production of the RVs.  An RV built with poor quality ("fit and finish") and questionable longevity (anticipated useful lifetime) can still be totally compliant with RVIA standards.

2.  Overall RV product quality will absolutely not improve until manufacturers decide that the cost of warranty activities is too much of a "drag" on their profit margins.

Another reality not described in this thread is that RV product quality will not improve until consumers actually refuse to buy RVs of poor quality, and choose instead to buy units of better quality.  Admittedly, this statement assumes that RV buyers are capable judges of product quality.  However, this scenario is more-or-less a "pipe dream" that has not happened to any impactful extent in the past, and is unlikely to ever be a significant factor in the future.  Looking in the rear view mirror, it is clear that RV buyers have judged past and present RV product quality as "acceptable" by voting clearly with their money.

RE: RVIA Inspections (announced VS unannounced).

1.  The thoroughness or nature of an unannounced RVIA inspection during my time as Corporate Director of Codes and Standards at &%$#@ was virtually equal to an announced inspection.  All inspections involved (at a minimum) tours of production lines as requested by the inspector, and inspections of designated finished products in inventory. 

2.  The qualifications (and competence) of the RVIA Inspectors was never an issue for me.  They all seemed professional and fully knowledgeable of the Standards to which they were inspecting the products.  The same can be said of the third-party inspectors for CSA compliance whom I contracted as needed.

I cannot comment on the current number of RVIA inspectors.  However, they always seemed to show up on time and rarely re-scheduled their announced visits.

Hope this helps!

Travel Free!

      

[jblo]

Thank you, very in-depth statements.  If I understand you correctly, an RVIA inspection has little to do with quality control, and/or operation of various systems?

[Kirk W]

5 minutes ago, jblo said:

If I understand you correctly, an RVIA inspection has little to do with quality control, and/or operation of various systems?

True and there is no state that has made that code part of the requirements to sell them or by any other means enforce that code. As far as I am able to learn, none of the manufacturers who build RVs for the "price is no object" market belong to RIVA.

[HMFunk]

On 11/28/2022 at 8:09 PM, jblo said:

Thank you, very in-depth statements.  If I understand you correctly, an RVIA inspection has little to do with quality control, and/or operation of various systems?

Yes, jblo.  In relation to Quality Control, that is generally correct.  RVIA inspections  are not directed toward Quality Control issues UNLESS those issues directly relate to systems safety in performance or proper operation of that component. 

In relation to systems operation,  the RVIA inspector WILL indeed want to see that the safe OPERATION of the system(s) is/are being maintained or ensured by adequate adherence to installation guidelines.

For example, sloppy sealant application in the (gas) refrigerator compartment (behind the refer) is not an RVIA concern UNLESS that compartment is not properly sealed.  Allowing interchange of air from that compartment and the interior of the coach (instead of ensuring that compartment air is being vented solely to the  roof vent) IS an RVIA concern because it relates to occupant safety and proper systems venting.  But if there is a large "glob" of sealant that has dripped from an area where it was applied, and onto some 12V electrical wiring (but that area is still sealed properly), that is not an RVIA concern, only a cosmetic issue.

Manufacturers are concerned that installation parameters given to them by component suppliers are observed, maintaining the component's Certification at the end of the manufacturing process.  For gas, electric, vehicular or safety-related components, that is how they ensure compliance to RVIA (inspection) standards.  But, beyond that, each manufacturer sets their own Quality standards.

Hope this helps!

Travel Free!