Comment Log Display

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.