16 CFR Part 20; Guides for the Rebuilt, Reconditioned and Other Used Automobile Parts Industry; Project No. P127702 #560948-00004

Submission Number:
560948-00004
Commenter:
JAMES PFAU
Organization:
BRYNER CHEVROLET
State:
Pennsylvania
Initiative Name:
16 CFR Part 20; Guides for the Rebuilt, Reconditioned and Other Used Automobile Parts Industry; Project No. P127702
THANK YOU for addressing this issue. I have written to the FTC in the past and was told it is outside your jurisdiction. The main concern I have with used parts is safety. It is my belief that installing anything related to suspension, steering and brakes from a salvage yard is a high risk. I challenge this every time an insurance company does a damage appraisal which includes salvage safety parts. This is a fact that can be supported with countless estimates written by insurance companies. It clearly states in the Pennsylvania Appraisers Act that an estimator is to consider the suspension, steering and brakes to be paramount while evaluating the collision damage. The law has no teeth and is NOT enforced. Example: A) Steering components have many wearable parts and every vehicle depending on many factors wears differently. No trained technician would argue that installing used shock absorbers (struts) is a safe practice. However it happens daily in our state. B) Salvage parts are not subject to manufactures recalls because there is no way of tracking them after a defective part is placed in another families vehicle. C) Many safety parts are constructed out of aluminum alloy and fine cracks cannot be seen on inspection. The vehicle was in the salvage yard for a reason. D) The word “recycled” implies reprocessing something and generating something useful. E) These parts are clearly salvage items and should be stated as such. I am indifferent to the use of salvage sheet metal however there is an added expense to using them in a repair for a collision shop. The insurance companies often refuse to pay the needed time to prepare the parts for refinishing. Thank you again for addressing the issue.