OEM Repair Procedures vs. Repair Standards Explained

Lately, the hot topic of discussion has been about the development of "collision repair standards," which all started when the Collision Industry Conference (CIC) decided to form a subcommittee to discuss developing them. This led to a growing debate either for or against their creation, and opinions on the matter can be found in social networks like Facebook and LinkedIn and in industry magazines. We have decided to assist all in the collision repair industry with an explanation of the issues surrounding OEM repair procedures versus general repair standards.

In the past five to eight years, OEMs have been forced to develop the following:

1. Advanced high strength steels and composites, such as carbon fiber and hybrid vehicle construction (a mix of multiple different substrates) to lighten the vehicle for better fuel economy, due to Corporate Average Fuel Economy (C.A.F.E.) rules, while retaining strength and safety.

2. Waterborne primers and basecoat paint systems, due to the EPA's 6H rules, to limit the amount of volatile organic compounds (VOCs) and hazardous air pollution (HAP) emitted by collision repair and other industries utilizing refinishing products.

3. Multiple advanced electronic control systems for accident avoidance, occupant safety and even pedestrian protection.

4. The advancement of more hybrid and electric-powered vehicles.

The future of automobiles and the evolving technologies required by government pressure and consumer wants and needs will make collision repair even more complex in the coming years, which in turn will cause collision repair specialists to make educated business decisions as to the repair of a collision-damaged vehicle. The risk to the facilities' liability is greater than it has ever been (see our recent H&D article on gross negligent manslaughter). You may ask what you can do to ensure that a collision-damaged vehicle has been repaired properly and safely (according to the available tested procedures and utilizing the required proper materials) by a qualified technician, and that it will react in the manner in which it was designed in a subsequent collision event. Surprisingly, the answer is pretty simple. Collision repair facility owners must send their technicians to recognized training classes (such as those offered by I-CAR, some OEMs, P&L Consultants and IACDA), and classes by structural repair equipment manufacturers (such as Car-O-Liner, Celette, CarBench and Chief), material suppliers (such as Lord Fusor, 3M, SEM, Duramix and IES) and paint manufacturers (such as Akzo Nobel, PPG, DuPont, Sherwin-Williams and BASF/Glasurit) and then have these technicians certified by passing the ASE collision repair tests (B2, B3, B4, B5 and B6).

Additionally, the facility owners must subscribe to the OEM collision repair information available at the OEM's website, ALLDATA Collision or Mitchell and start instituting standard operating procedures (SOPs) to ensure that all personnel involved in the repair of a collision-damaged vehicle are held accountable through a system of checks and balances. We know most reading this article will argue that the above explanation might work in a perfect world, but let's be honest; in reality, you are the only one in control of your business and the amount of liability you are willing to expose by not following the OEM recommendations, procedures and required training. It is your decision alone.

Let's clarify some definitions and terms used in the collision repair industry:

Standard: An accepted or approved example of something against which others are judged or measured. An acknowledged measure of comparison for quantitative or qualitative value; a criterion. Something, such as a practice or a product, which is widely recognized or employed, especially because of its excellence. A degree or level of requirement, excellence or attainment.

Procedure: A manner of proceeding; a way of performing or affecting something, especially an established method. A series of steps followed in a regular, definite order.

Position Statement: Written description of the objectives of a positioning strategy. It states how the firm defines its business or how a brand distinguishes itself, how the customers will benefit from its features and how these benefits or aspects will be communicated to the intended audience.

Requirement: Something wanted or needed, a necessity. Something essential to the existence or occurrence of something else. To call for as suitable or appropriate or demand as necessary or essential.

Common examples of standards, procedures and requirements are found in building codes, food preparation procedures and beautician and manicurist licensing. Standards, procedures and requirements for the aforementioned are generally developed by state lawmakers, enforced by agencies of the state and may outline in great detail what gauge wire to use for an electrical outlet in a home or business, how high off the floor it must be and how far apart the outlets must be; how to handle and store food as well as how long this food may be kept; and the manner in which hair and nail clipping tools must be sanitized and discarded.

Questions and Answers

Let's look at some of the questions that have come up due to the idea of developing collision repair standards, and provide some answers:

1. Who develops the standards? The answer, in our opinion, is simple: The manufacturer of the product(s) and/or component(s). In this case, the OEM develops, tests and produces the standard procedure. Almost every OEM produces repair procedures for their vehicles and makes some of them available for free on their websites, while all OEMs offer full access for a fee. The OEMs also have allowed third-party companies such as ALLDATA Collision and Mitchell to reproduce the full access to the repair procedures for a monthly fee. OEMs spend millions of dollars to develop their repair procedures to ensure that their product can be restored to pre-loss condition and provide the originally designed safety protection, durability and longevity. OEM procedures are the standard; in fact, one OEM has stated that they will no longer call their repair documents procedures, but will call them "requirements."

2. Can the standards be enforced? They are not — and cannot — be enforced by the OEM unless something goes wrong. What could go wrong? Let's see:

a) A failed component could cause the vehicle to not operate properly. The warranty could be voided if an improper repair and/or unapproved component was the root cause and caused other components to not operate.

b) An improper repair could cause an injury and/or death, and the case goes to a court of law.

c) An improperly-repaired vehicle and/or unapproved components on a leased vehicle could be discovered upon lease return, and the customer could be charged for the corrective repairs or a case for diminished value could occur.

d) It is not the responsibility of the OEM to enforce their repair procedure; that's the job of the repair facility through due diligence. The repair facility must enforce this and adhere to the recommended and/or required repair procedures, materials and methods on their own.

e) After carefully reading multiple industry articles and social website blogs, the following can be opined: Adherence to the OEM-provided repair procedures, recommendations, requirements and position statements must be a collective industry effort to ensure that the utilized repair procedures are attempted and completed in a high-quality manner, which would benefit the general public with reliable, safe and efficient repairs. This commitment would directly affect the repair facility and the insurers as well.

Repair standards are already recognized by the collision repair industry. For example, most OEMs have very specific procedures for replacing and/or sectioning of structural components; these procedures generally include exact cutting locations and attachment methods. Most OEMs have position statements that prohibit the use of heat during straightening procedures, and almost everyone in the collision repair industry (including collision facility owners, technicians and insurance companies) follows them.

Conversely, most OEMs have position statements prohibiting the use of reconditioned wheels and aftermarket and/or salvaged components for repairs to their vehicles, but many in the collision repair industry disregard and/or refuse to recognize them or state they are only a "recommendation." Additionally, many industry people state that I-CAR says this or that…but only when it benefits them. I-CAR is a training organization that does a very good job of teaching the repair standards set forth by the OEMs, and in no way are they a policing or enforcement agency. In a December 2007 article in I-CAR's Advantage ("Are General Sectioning Guidelines Still Applicable?"), I-CAR discusses that the Uniformed Procedures for Collision Repair (UPCRs) they developed years ago may not be applicable anymore due to the type of substrates utilized and repair procedures provided by the OEMs. We do agree that some general guidelines (UPCRs) are required for any OEM that does not produce (or refuses to produce) repair procedures in the United States, so collision repair professionals are able to make educated decisions as to how to repair a collision-damaged vehicle. The proposed "New/Updated UPCRs" should address and advise procedures where none exist and be made available on the I-CAR website.

Developing repair standards is problematic. Due to all the articles, statements and mission statements we have read about their development, none have stated or made mention of any evidentiary value that the "made-up repair procedures" would be independently tested and supported by scientific and engineering principles.

Thatcham Research Centre, which has facilitated the development of collision repair standards in Great Britain, has been mentioned multiple times as an example of what could be done, but the liability laws in Great Britain differ greatly from those in the USA. Thatcham is basically ASE, I-CAR and the Insurance Institute for Highway Safety (IIHS) all rolled into one entity, which is heavily financed by the insurance industry. In the USA, this type of system could be a conflict of interest.

Industry Position Statement

The Alliance of Automotive Service Providers (AASP), the Automotive Service Association (ASA), the Society of Collision Repair Specialists (SCRS) and the Assured Performance Network signed a joint statement detailing their position at the 2011 SEMA Show in November. The statement is as follows:

The undersigned organizations continue to be the leading voice of collision repair businesses and technicians across the United States, just as they have for decades. Representing their interests, we hereby recognize published repair procedures, as provided by automotive original equipment manufacturers (OEM), as the official industry recognized "Repair Standards" for collision repair. These standards, where they exist, shall be the basis for the establishment of training, testing, repair practices and documentations.

Whereas, we acknowledge that OEM repair procedures are incomplete in comparison to the full scope of vehicles and repair operations which exist in the marketplace, the OEM published repair procedures shall serve as the baseline for industry repair standards, with the recognition that further development of procedures will be necessary in areas not covered by published procedures.

Therefore, we officially ask the Board of Directors for the Inter-Industry Conference on Auto Collision Repair (I-CAR), to establish within their overall organizational structure, an industry council to identify gaps in existing OEM procedures and develop processes to close gaps, vet industry proposed alternatives, modifications and additions to OEM procedures. The Council will include volunteer representatives serving at least ASA, SCRS, AASP and I-CAR.

We agree with this idea, but would add that some government, insurance and collision industry pressure on the OEMs to develop missing procedures may settle this debate once and for all. Additionally, representatives from I-CAR, ASA, SCRS and AASP could conduct open conversations with the OEMs and with the Society of Automotive Engineers (SAE) to discuss what needs to be done and how it can be accomplished. This may be a starting point.

We also would recommend that ALLDATA and Mitchell develop and conduct training classes for their subscribers on how to utilize their systems. This can be done at trade shows and association meetings or through Web-based training to ensure that collision repair professionals know how to find the information. ALLDATA already offers an online training program for their subscribers, but maybe they need to develop a few more training sessions that test the user's skill. ALLDATA has conducted multiple training seminars in the northeast about OEM information, and they have been met with great success.

Barrett Smith from Auto Damage Experts (ADE) recently asked three very interesting questions in a LinkedIn blog:

1. Are aftermarket parts still viable alternatives whereas the OEM does not endorse their use?
2. Are reconditioned wheels still viable alternatives whereas the OEM does not endorse their use?
3. Are salvaged airbags viable alternative parts whereas the OEM does not endorse their use?

We would have to say the answer to all three questions is a definitive NO! Pressures in reducing claims costs have resulted in the promotion of reconditioned wheels and salvaged airbags components (when the OEMs specifically have statements prohibiting their use). Such pressures have put the consumers and the repairers at risk. Our past articles have delved deep into each of these issues, and we will not cover these issues again in this article. We will say that insurance carriers, shops and/or trade associations cannot arbitrarily pick and choose the OEM procedures and position statements they see fit to satisfy their own needs. Insurers have no say in the repair methodologies and replacement components when an OEM has specific procedures in place. We have participated in litigations for insurers, repair facilities and consumers to testify, as experts, on repair quality, parts usage, accident reconstruction and collision damage analysis. Time and time again, we have utilized the OEM repair information as evidence to substantiate our opinions, and the courts have consistently agreed that the OEM procedures are paramount, and that the collision repair facility employees are the repair experts.

We hope this article has helped the industry to better understand the complex issue of the debate over OEM repair procedures vs. repair standards and what should or, better yet, what needs to be done about the few missing procedures. Please remember that we are not taking a stand to support any one entity of the collision repair industry; we are taking a stand for the safety and well-being of the general motoring public utilizing the roadways of the United States of America. We, as an industry, have a moral obligation to ensure that the repairs we perform do not expose the general public to peril. We are also obliged to protect ourselves and each other by insuring that no one is injured — physically or economically — by incompetence, ignorance or utter disregard for published repairs recommendations, standards and/or procedures.

Feel free to contact us if you have any questions.

Executive Director's Thoughts: With the reduction in profit margins in this type of economy, it is even more important to heed the message of this article so that your liabilities are kept to a minimum. A lawsuit over the use of a specifically OEM-prohibited part or procedure could cost you your business. No pressure of any kind should cause you to put your business and employees' livelihoods in jeopardy. — Jordan Hendler

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Larry Montanez, CDA is co-owner of P&L Consultants with Peter Pratti Jr. P&L Consultants work with collision repair shops on estimating, production and proper repair procedures. P&L conducts repair workshops on MIG & Resistance Welding, measuring for estimating and advanced estimating skills. P&L also conducts investigations for insurers and repair shops for improper repairs, collision reparability and estimating issues. P&L can be reached by contacting Larry at (917) 860-3588 or via email at larrygoju@aol.com.

Jeff Lange, PE is president of Lange Technical Services, Ltd. of Deer Park, New York (www.LangeTech.net). Jeff is a Licensed New York State Professional Engineer who specializes in investigating vehicle and component failures. Lange Technical Services, Ltd. is an investigative engineering firm performing forensic vehicle examinations and analysis for accident reconstruction, products liability and insurance issues. Jeff can be reached at (631) 667-6128 or by email at Jeff.Lange@LangeTech.net.