Overview of the OEM Website Audit Process
Background
On June 27, 2003, EPA finalized regulations requiring auto manufacturers to launch full-text websites containing all required service information for 1996 and later model years (68 FR 38427). In order to assess the effectiveness of the site regulations, EPA believes that input from independent technicians must be of primary consideration. As part of a broader effort to evaluate the OEM websites, EPA is initiating a process to gather feedback directly from the technician community on their experiences with the websites and to communicate those findings directly to the OEMs and the service industry as a whole.
To assist in these efforts, EPA has procured the services of Perrin Quarles Associates, Inc. (PQA). PQA, an independent consulting firm, will oversee the entire process, including facilitation and participation in meetings and conference calls, development of communications tools, and the creation of reports and documents. PQA will also perform other support work as needed.
Process
Formation of an Industry Steering Committee
To maintain a neutral approach to the process, PQA assisted EPA in the development of a small steering committee to oversee the evaluation. The OEM Website Audit Steering Committee is comprised of industry representatives such as OEMs, tool companies, independent technicians, and after-market associations. Participation on the Committee is entirely voluntary.
Development of Audit Methodology
The Steering Committee will develop a recommended overall methodology for conducting the audit, including developing a plan for recruiting independent technicians/shops, providing access to the sites, and developing a feedback mechanism on the sites. As appropriate, the Committee can consider other audits that may have been conducted by other parties. The Committee will seek input on the audit plan from industry stakeholders and EPA. EPA will ensure that the plan remains within EPA’s authority and meets other legal obligations.
Implementation of the Audit Methodology
Technicians will conduct the website audits. PQA and the Steering Committee will provide a questionnaire or similar tool for the technicians to use in providing feedback. PQA will then gather the feedback from the technician community.
Final Report of Audit Findings
Upon completion of technician feedback, PQA will draft a final report detailing all of the findings. PQA will make the draft report available for comment to the Steering Committee. OEMs will also be provided an opportunity to comment. Comments will be incorporated as appropriate and a final report will be issued.
Scope and Limitations of the Project
While EPA has approximately one year to complete the audit, it is important to note that the scope of the project is somewhat limited. Given the time needed for developing the methodology and drafting the final report, EPA expects that the technicians who participate in the actual audit of the websites will have a time period of approximately 3 months to use the sites and to provide their feedback to PQA. In addition, EPA expects that the number of technicians who participate will need to be limited in order to keep the process manageable in the given time frame.
Communicating Progress
The Steering Committee believes that there will be significant industry interest in this audit, and that the project website will ensure an open process and a convenient means for keeping the industry as a whole informed about the project.
Regulatory and Compliance Implications
This audit will provide EPA an independent evaluation of the OEM websites. Regardless of the audit findings, EPA retains its full authority over any regulatory changes or manufacturer guidance that it may deem necessary as a result of the findings, as well as full authority for any compliance and enforcement remedies.
