First Name | Erich |
---|---|
Last Name | Lucht |
Email Address | erich_lucht@irco.com |
Affiliation | |
Subject | Thermo King Reply to Proposed ATCM Amendment |
Comment | Thermo King has several comments in response to the TRU ATCM, Title 13, CCR, section 2477, subsection (f), paragraph (3) amendments as proposed, specifically those amendments that add requirements for TRU and TRU generator set original equipment manufacturers to report TRU and TRU gen set production information. TK COMMENT-1: The amendment described in subparagraph (f)(3)(B)2.a. is not immediately feasible as drafted, because the information requested currently involves a manual entry process that is highly prone to human error. In order for an OEM to comply in a responsible manner, an automated process must be put in place. The timeline and work required to automate all stages of the overall process has not yet been determined. Bar coding by the engine manufacturer must be implemented and made compatible with the OEM process control network. It is estimated that study and implementation of the automated process will take at least 18 months after the effective date of the amendment. Final implementation at the OEM will require substantial financial and personnel commitments from the TRU manufacturer and its suppliers. TK COMMENT-2: It is requested that language protecting the OEM and the engine supplier from liability in the case of unintentional distribution of inaccurate information to the end user of a TRU be added to the amendment. TK COMMENT-3: It is requested that language protecting against misuse of proprietary data submitted to ARB by the OEM and the engine supplier be added to the amendment. Thank you for your consideration. |
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Original File Name | |
Date and Time Comment Was Submitted | 2010-11-15 14:14:15 |
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