What a tangled web we weave
Last Tuesday’s blog was probably the most unusual of all those I have posted in terms of the response it generated. Little did I realize that a simple inquiry into why seals are missing from some recreation vehicles on dealer lots would mushroom quickly into a story of huge significance for the entire RV industry.
Last week, a dealer wondered why some seals were missing from RVs. It was puzzling to him because most RVs from the same manufacturer had seals, but a handful did not. He wondered aloud if that was a signal manufacturers were trying to sidestep quality and control issues put into place by the RV Industry Association.
Maybe dealers are just genuinely skeptical about quality issues after dealing with so many problems with so many years. But, he knew the seals were somehow tied to construction standards. If an RV bore the official seal of the RVIA, that meant it was constructed in accordance to strict standards put in place to ensure quality workmanship –at least that’s what he has been telling his customers. So, in his mind, if an RV was missing a seal, that must signal that the unit somehow didn’t meet the standards. I am very happy to report that is not at all the case. If an RV is missing a seal, it does not indicate the manufacturer has failed to live up to some type of quality standard. It does not mean the RV is unsafe. It was likely built on the same line by the same workers to the same level of quality for which that particular manufacturer is known. Quality is not at all the issue. The lack of a seal simply means the vehicle was constructed illegally.
I have posted a full report on this issue that has already polarized a significant segment of the RV industry. You can read that report by going to our Web site at www.rvtradedigest.com and clicking on the featured article box on the center of the home page. But for those of you who would rather golf this weekend than wonder why seals are missing from your RVs, here are the facts in a nutshell.
- If an RV is less than 8.5 feet wide and its total interior space when erected is less than 320 square feet, it’s a “travel trailer” regulated by National Fire Prevention Association rule 1192. Units built to this standard by RVIA members bear the seal of the RVIA.
- If the RV is 8.5 feet or wider (when traveling down the highway) OR the interior space is between 320 and 400 square feet, it is a “park trailer” regulated by the American National Standards Institute rule A119.5. Units built to this standard by members of the Recreational Park Trailer Industry Association, bear the seal of that organization.
- Any unit without an engine and larger than 400 square feet is a “manufactured home” regulated by the U.S. Department of Housing and Urban Development. These units bear no seal from any RV industry association.
- If the RV can be driven down the highway, it’s a motorhome regulated by the U.S. Department of Transportation regardless of its size.
Here’s the problem. Thanks to slideouts, some RVs are larger than 400 square feet when fully erected. That means the RV becomes a “non-conforming recreation vehicle.” So what? Constructing and selling manufactured homes opens OEMs and dealers to a bees’ nest of regulation – rules and laws that are currently being ignored by the industry as it operates under the radar.
This week I learned the RVIA’s board of directors has instructed the RVIA staff to lay the foundation for legislation to eliminate all size requirements for fifth wheels and, thus, is inviting the federal government to regulate a segment of the RV industry. Those of you who own businesses know what that means. The federal government just doesn’t regulate a portion of any business. Once the beast gets its snout in the door, it pushes the door wide open and heads for the cash register. If RVIA is successful in its effort to change federal law to eliminate size requirements for fifth wheels, it could pose significant challenges to RV dealers and RV users around the country. Why? Because although they were successful in changing federal law, there are 50 state governments that may not be so easily convinced that 55-foot fifth wheels driven by 70-year-olds behind the wheel of a 20-foot toter don’t need special licenses. A few years ago, the industry was embroiled in a size issue as only a few states allowed 45-foot RVs on the highways and others cited drivers for crossing their borders.
But that’s just one of nearly two dozen concerns people have already identified with this issue. The RVIA initiative is already being strenuously opposed by the Recreational Park Trailer Industry Association and the National Association of RV Parks and Campgrounds. For the full story, visit www.rvtradedigest.com.
Due to the complexity of the issue, the fact senior staff members are traveling and because other key people at RVIA are feverishly getting ready for Committee Week in nine days, the staff at RVIA has postponed comment on this story. When they can take the time to comment, they’ll be afforded full access to this forum. So, I’ll apologize in advance if anyone thinks the story is one-sided.But, even others outside the RV industry are scratching their heads over the direction this issue is moving. “Why, in God’s name, would the RV industry want to give up the security and sanity of building anything in a self-regulating environment and even dare risk bringing their industry under the control and authority of the federal Department of Housing and Urban Development?,” asked one person involved in the manufactured housing industry. His struggling industry is heavily regulated by HUD code. “Rather than dealing with association ‘regulators’ periodically visiting a manufacturing plant for a routine inspection, the RV industry is inviting federal regulators to make unannounced visits to their plants. The interpretation regarding compliance with a variety of complex federal laws can be made on the spot by an inspector who may be upset because his kid kept him up all night or he didn’t have enough cream in his coffee on the way into work that morning.
“For years, I have admired the RV industry for its ability to operate under the radar,” he added. “By opening up this can of worms, the RV industry better hope it doesn’t get what it wishes for. Why make units so big they invite regulation and fall under the realm of the HUD code?” That’s a good question.

June 4th, 2007 at 12:33 pm
Hi Ya’ll….I’ve been away on an extended vacation (not my choice but the Doc’s) and I’ve missed participating in these spirited responses. Hope all is well with you and yours.
Now,….to THIS mess! What in the name of Sam Houston is the RVIA Board think it’s doing by stirring up this nonsense?!?! In my mind, there is, obviously, a political motivation within this type of proposal. (But since I’m not a political scholar, I won’t venture into the ‘why’s and wherefores’ of that side of the matter.) But suffice it to say, that for a prominent industry participant, such as RVIA, to willingly venture into this territory under this premise is inviting a further diminishment of what has been very beneficial mutual arrangement for both consumer and dealers alike. Background investigation by someone or some group more familiar with the inner workings of RVIA into HOW this matter came about is fully warranted now. Otherwise, left unchallenged and unchecked, this matter has the full potential of becoming a donkey-ride-through-Hell scenario before it’s all over with. And that would be a needless blow to an already undervalued and overtaxed industry.
Ya’ll Honk As You Go By……
June 2nd, 2007 at 5:35 pm
It may be beneficial for RVIA to start posting shipment statistics that mirror the categories established by these standards. I think it would benefit the industry to know how many units are being shipped in each product category, but further defined by those with seals and those without seals. A quick calculation of those without seals will show how much revenue the association is leaving on the table by not enforcing their seal program on every single RV manufactured by every single member of RVIA.
June 1st, 2007 at 1:30 pm
Greg
NFPA 1192 there are seperate definitions in the Annex portion of the standards hand book which is revised every 3 years. In the Annex portion Recreational Vehicles are divided into 5 catagories. In the 2005 standard the catagories are;
1. Motor Home which is a self propelled unit as you have indicated.
2. Camping Trailer which is often refered to as a fold down camping trailer with often with canvas type sides.
3. Fifth Wheel Trailer which is permitted to have up to 400 square feet in the set up mode.(All slide outs extended fully)
4. Travel Trailer which is limited to 320 square feet.
5. Truck Camper which is designed to be mounted on a pick up truck.
All of the above units must be of a size that when in the transportation mode (slideouts in the “in” position) are legal on US highways with out a permit (less than 8.5 feet wide).
I think most persons in the general public do not realize that there are two seperate size restrictions for “trailers”. One for the standard type of bumper hitch and the other for the “bed” mounted hitch for a fifth wheel. It seems that is the case for some in the industry.
As an owner of a fifth wheel trailer and an employee of the RV industry I know the variation in construction methods of units. Ther are units that friends have purchased simply because of price. The quality was even lower than the price. I am pleased to say that my unit was not purchased on price alone but on quality. The quality is what endures.