Tow vehicles and CCC ratings

[huntindog]

Just to muddy the waters a little, according to the following NHTSA Interpretation, “. . . NHTSA does not approve vehicle alterers, and consequently maintains no list of such enterprises. . . . “

https://www.nhtsa.gov/interpretations/nht95-166

Note that this interpretation is from 1995. I have not found anything that indicates it has been voided or superceded.


2020 2600RB,
2017 Silverado Crew Cab 1500, 6.2L

After reading all of this, it is clear that getting a new weight sticker is not legal unless the vehicle hasn't been titled yet.
So how is this spring company doing it? Lack of enforcement. Govt, agencys are generally staffed with people that are not interested in doing more than is necessary. They get paid the same no matter what so they have no incentive.
This subject is not in the media at all. The only place it is discussed is on RV forums.... And we all generally want to be able to do it, so there is no squeeky wheel that needs greasing. So this spring company is just going ahead and doing it, and making some pretty good money too. Unless there is a public outcry, it will continue. If this were 100% legal, there would be a lot of places doing it.

At one time there were many companies making tuners for diesel trucks. A lot of them got into big trouble with the EPA.... Oh they were slow to respond at first.... But all of those kids rolling coal got a lot of greenies upset. They became a squeeky wheel that needed greasing......But for a few years those companies made a lot of easy money

[Larry and Kathy]

Thanks for the comment. If my insurance dropped me, my agent would probably have to sell his summer home.

[JKellerJr]

After reading all of this, it is clear that getting a new weight sticker is not legal unless the vehicle hasn't been titled yet.
So how is this spring company doing it? Lack of enforcement. Govt, agencys are generally staffed with people that are not interested in doing more than is necessary. They get paid the same no matter what so they have no incentive.
This subject is not in the media at all. The only place it is discussed is on RV forums.... And we all generally want to be able to do it, so there is no squeeky wheel that needs greasing. So this spring company is just going ahead and doing it, and making some pretty good money too. Unless there is a public outcry, it will continue. If this were 100% legal, there would be a lot of places doing it.

At one time there were many companies making tuners for diesel trucks. A lot of them got into big trouble with the EPA.... Oh they were slow to respond at first.... But all of those kids rolling coal got a lot of greenies upset. They became a squeeky wheel that needed greasing......But for a few years those companies made a lot of easy money

Sorry, I disappeared for awhile, second covid shot, happy its over but the second one wasn't fun.

So I went back and did a bunch more research after huntindog's last quote on my post about the definition of alterer. I hadn't caught that before, or at least fully understood its meaning. I have changed my opinion some but mainly its just semantics.

BTW this is only my opinion, I'm not a lawyer or expert in any way. Just a guy on the internet who enjoys research and a good debate

NHTSA regulations as far the sticker and its meaning only apply to new vehicles. So saying that the original manufacturers rating can not change would be accurate. The only way that ORIGINAL sticker/rating can change is the original manufacturer making a correction (i.e. Fords current payload debacle)

But it does not mean that one can not modify there individual vehicle to carry more/less weight. There is nothing illegal about it. And I would argue the reason a "lot of places" are not doing it is said place now assumes the liability for that rating. The very reason why the air bag people and spring helper companies go out of their way to say it Does not increase your payload. I applaud that someone out there is willing to take on risk providing a, IMHO, common sense solution. And standing behind it by putting their name and rating right on the truck. But those against it, don't worry, at some point I'm sure a lawyer will get involved and ruin it for everyone.

My OPINION is based on rereading the link I posted earlier with the conversation with the person from the NHTSA and the quote below pulled directly from a letter written by the chief counsel of the NHTSA to someone looking for a clarification on rating changes. The letter is linked if you want to read the whole thing. It does NOT directly refer to our discussion at hand but I think the quote does and is very clear.

"We recognize that certain modifications that might be made to a used vehicle (e.g., adding or deleting an axle) could make the originally assigned GVWR inappropriate for the vehicle as modified. While not required by our regulations, we believe it would be appropriate in such situations to add a label to the vehicle which indicates the appropriate loaded weight of the modified vehicle."

https://www.nhtsa.gov/interpretations/nht93-49

So I guess IMO everyone is right. The NHTSA rules that has been linked by many including myself do not apply in any way to this discussion, either for or against. All our vehicles are "used". But modifying your truck is also perfectly "legal". If one wants to take the OEM rating as gospel regardless than that is fine. But so is upgrading if one sees fit to do so.

Take it FWIW (which isn't much).

I'm sure this will end the disagreement for all time

[House On Wheels]

For all those naysayers out there. I had this work done to my truck and I can only talk about how good and professional they are about the entire process. Let's start the fact that Tampa Springs will not recertify any truck for a customer who comes off the street. So don't start calling them about having your truck recertified. They will only do this work via Lazydays. Lazydays will compute the increase in CCC you will need and they will send the request to Tampa Springs, which in turn will review all of the specs of your truck and make the determination if your CCC can be increased by what is being requested. In my case they made me change all 4 tires on the truck to withstand the additional payload and I had to show proof of the new tires before Tampa Springs will accept the appt for the work to be done. In addition, they will only increase the CCC of the truck by the number that Lazydays provides them with. So for example if they install additional leaf springs of 1,000# and Lazydays calculations are 656, your CCC will only increase by 656#. Tampa Springs is not a fly by night shop they are a very reputable business with a sound operations. They primarily work on true heavy duty trucks such as dump trucks and Class 8.

So for all of those who say you can't increase the CCC unless it is done my the manufacturer, let me pose a question for you? So how are limousines legal because I can assure you that any super-stretch Lincoln Continental is well over Ford's factory sticker?? Maybe do some research on your own and look up vehicle upfitters or vehicle modifier and you will see how vehicles can be modified and be legal. Or just go to https://www.fordupfits.com/ and see for yourself.

[CWSWine]

Sorry, I disappeared for awhile, second covid shot, happy its over but the second one wasn't fun.

In this case, the upgrade also has a Class change from a Class 2 to Class 3 truck which is in the 4 positions of the VIN. The majority of violations written for box-style tucks are operating outside of their Class of truck which is a safety violation that must be correct before they are allowed to proceed. That is where the VCO comes into play and the requirement to have an amended VIN to reflect the class change approved by Ford.
I have been told that the fine print on the work order from the Florida Spring Company states that they don’t take responsibility and I'm sure a lot of thought and legal advice has been put into the fine print. I would like to see what really says. I find really unusual that there are not hundreds of companies doing the upgrades.

Added: A good example of that is replacing your tires. Read the small print and states that if you are not using the specs for tires provided by the manufacture your take full responsibility. When I had my after-market bumper put on my jeep the fine print stated that if it alters crash certifications and I take full responsibility for the change. These guys know how to cover their you know what.



https://en.wikipedia.org/wiki/Truck_classification

[WhittleBurner]

When you have people like the couple who set the cruise on their motorhome when driving down the road then went to bed thinking the motorhome would drive itself. Companies had better cover their butts. By the way the brilliant jury awarded the couple the case and gave them everything they asked for.

[JKellerJr]

In this case, the upgrade also has a Class change from a Class 2 to Class 3 truck which is in the 4 positions of the VIN. The majority of violations written for box-style tucks are operating outside of their Class of truck which is a safety violation that must be correct before they are allowed to proceed. That is where the VCO comes into play and the requirement to have an amended VIN to reflect the class change approved by Ford.
I have been told that the fine print on the work order from the Florida Spring Company states that they don’t take responsibility and I'm sure a lot of thought and legal advice has been put into the fine print. I would like to see what really says. I find really unusual that there are not hundreds of companies doing the upgrades.

Added: A good example of that is replacing your tires. Read the small print and states that if you are not using the specs for tires provided by the manufacture your take full responsibility. When I had my after-market bumper put on my jeep the fine print stated that if it alters crash certifications and I take full responsibility for the change. These guys know how to cover their you know what.



https://en.wikipedia.org/wiki/Truck_classification

My head hurts.

I have no idea here, on this point I will defer. My only question is are we back to commercial vs. private?

Its just crazy, Vehicle class, commercial vs private, GVWR, GAWR, registered weights, Non commercial CDL's, etc. 50 different states, etc. Is anyone fully compliant???

[JKellerJr]

When you have people like the couple who set the cruise on their motorhome when driving down the road then went to bed thinking the motorhome would drive itself. Companies had better cover their butts. By the way the brilliant jury awarded the couple the case and gave them everything they asked for.

Yep and stories like this:

https://www.cnbc.com/2021/03/24/rise...-industry.html

One of the largest stemmed from a 2014 crash in Odessa, Texas, involving Werner Enterprises. During a winter storm, the driver of a pickup truck lost control and crossed the median, striking a tractor-trailer head-on. The accident killed a 7-year-old passenger and seriously injured three others. The family successfully sued and was awarded $90 million. The case is currently under appeal.

Unfortunately, even following all the rules in everyway means almost nothing anymore. Minding your own business driving down the road and someone else crosses the centerline and kills people in their car. Too bad your screwed.

IMO, its one of the biggest problems we face in this country period.

I don't think that's a political statement, its not meant to be.

[Ra&Ta350]

49 CFR 567.7 Requirements for persons who alter certified vehicles

In addition to assuming legal responsibilty for all duties and liabilities and labeling requirements, the alterer has a duty to determine continued conformity of the altered vehicle with applicable Federal motor vehicle safety, Bumper, and Theft Prevention standards.

2020 2600RB,
2017 Silverado Crew Cab 1500, 6.2L

People who add items to your truck after you have purchased it do not fit the definition of “altered” according to the CFR definitions contained in section 567.3. Anyone can add heavier duty springs to your truck to increase its carrying capacity, heavier duty bearings to increase your carrying capacity and larger axles. All without placing any altered or additional information on your pillar.

An alterer is someone who alters the vehicle after manufacture; but before first sale. 49 CFR 567.3

[dkayak]

People who add items to your truck after you have purchased it do not fit the definition of “altered” according to the CFR definitions contained in section 567.3. Anyone can add heavier duty springs to your truck to increase its carrying capacity, heavier duty bearings to increase your carrying capacity and larger axles. All without placing any altered or additional information on your pillar.

An alterer is someone who alters the vehicle after manufacture; but before first sale. 49 CFR 567.3

Visit the Wrangler Forum to see Jeep owners’ modifications. Many start the day it comes home and it never ends. Some built Gladiators out of Wranglers, so Jeep resurrected the Gladiator. Many dropped V8’s in so Jeep now offers a Hemi. Lifts, springs, steering linkages, bumpers, axles, are changed every day (often significantly raising the center of gravity), and many are done by commercial shops. They drive among us all the time but nobody ever changes VIN’s. I haven’t seen much discussion of insurance effects either. There’s no mechanism to notify the insurance company and I can’t imagine how any company could rate the endless potential Jeep mods. Your premium probably boils down to VIN and driving/accident history. Wouldn’t a non-commercial pickup be the same?