Comment Log Display

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.