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NATM Adds Secondary VIN as CVP Recommended Practice By Kendra Ansley, NATM Executive Director The National Association of Trailer Manufacturers (NATM) is committed to continuous improvement. As part of this commitment, the Compliance Committee annually looks at the Compliance Verification Program (CVP) checklist and its recommended practices to ensure the integrity of the program is maintained and the Association is continuing to add value to member companies. Noting a rise in calls from law enforcement officers and consumers relying on the serialized NATM Decal to identify stolen trailers or older units where the vehicle identification number (VIN) label was damaged or worn, the NATM Compliance Committee sought to address these issues. In July, the NATM Board of Directors approved the committee’s recommendation, and a new recommended practice was added to the Compliance Verification Program checklist: “VIN label is uniformly placed in a location and is protected from wear and tear, and a secondary identifier is hidden on the trailer.” This recommendation asks that members consider the placement of their VIN label, subject to existing regulations (see below), such that the label is placed in a location that is not exposed to regular wear and tear that would cause the label to be unreadable or damaged. Further, the manufacturer should consider placing a secondary identifier in a consistent but hidden location, so
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if a trailer is stolen and the VIN label is removed, this hidden identifier could be used to identify the unit. Some manufacturers choose to utilize the VIN for this purpose, others choose to use a code the manufacturer has linked to the VIN. This hidden identifier should be placed in a consistent location so manufacturers can direct law enforcement to its location. While NATM Members are not required to comply with recommended practices like the newly implemented VIN and secondary identifier recommendation, VIN labels are required per 49 CFR Sec. 567.4 to be “affixed to a location on the forward half of the left side, such that it is easily readable from outside the vehicle without moving any part of the vehicle.” In July 2019, the NATM Board of Directors determined for the purpose of the NATM CVP, VIN labels installed on the front driver-side of a trailer or on the inner frame rail of the front driver-side of a trailer are compliant VIN label mounting locations, satisfying Section 567.4(d). If you have any questions about the NATM Compliance Verification Program or this recommendation, please contact compliance@natm.com or call NATM headquarters at (785) 272-4433. ■
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