October 1, 1998
Chairman James Sensenbrenner
House Committee on Science,
Sub Committee on Technology
U.S. House of Representatives
Washington, DC 20515
McCoy Bolt Works Inc., is a manufacturer of U-bolts, eye bolts, J-bolts and other threaded fasteners that are designed for specific applications for the medium and heavy duty truck and trailer markets. We have received no federal contracts or grants either this year or in the preceding two years, and appreciate the opportunity to submit this testimony.
When the Fastener Quality Act (FQA) was originally written, its goal was to protect United States consumers from poor quality and fraudulently represented, high strength fasteners. The original problem was caused by imported fasteners but the legislation involved regulating U.S. manufacturers who had previously been successfully operating under market driven forces. In the years since the FQA was first drafted, the industry has responded to the market driven demand for higher quality by adopting quality assurance systems such as QS-9000. This shifted the emphasis away from relying on final inspections, to a meticulous system of controlling quality during each manufacturing operation.
These quality assurance systems require the manufacturer to have control plans for every step of the manufacturing process and to collect statistical data on key manufacturing variables. These systems allow the manufacturer to identify and correct problems that could lead to a non-conforming product before it ever reaches the end of the manufacturing process. Furthermore, companies like McCoy Bolt have obtained QS-9000 certification by a third party who regularly audits the system to assure it is still in conformity.
Under its current interpretation, the Fastener Quality Act does nothing to improve or enhance these quality systems. In fact, because it relies more on added inspections rather than controlling processes, if implemented, it will ultimately lead to lower productivity, added costs, lower wages and even lost jobs.
While there are several others that could be mentioned, one example of what would be required under the law is that each lot of coated fasteners must be salt spray tested before it can be released for shipment. Unfortunately, most of these coatings require at least 72 hours and some 1000+ hours for the test to be completed. This is from three to 42 days. In order for a small company like McCoy Bolt to be compliant with such a requirement and be responsive to our customers' "Just in Time" needs, we would be forced to carry a level of inventory that could ultimately force McCoy Bolt out of business.
The law also transforms traditional specifications, or standards, into rigid, inflexible legal documents. Many times a fastener designer will begin by referencing a particular standard and then add modifications to meet their desired performance criteria. In these cases, the standard was never intended to be used as the controlling document but rather as a reference tool to help explain how the product should be produced. Most often, these changes are made to make their particular product more competitive in the market. Unfortunately, the current law requires the fastener manufacturer to produce a product to the complete standard, regardless of the customer's wishes or needs.
Our opinion is that the law should be repealed as the current quality control systems have already accomplished the intended end result of the original legislation; and if enacted, will simply add significant costs with no added benefits. An alternative, if repealing the law is not feasible, is to allow third party quality assurance systems, like QS-9000, to fulfill the requirements of the law.
Thank you for your time and consideration.
Sincerely,
Nick Knappenberger
Engineering Manager
McCoy Bolt
2811 Congressional Parkway Fort Wayne, Indiana 46808 Fax 219-483-6775
219-482-4476