Understanding the National Safety Mark

Any company manufacturing vehicles in Canada, or that vehicle ships from one province to another, must affix their National Safety Mark (NSM) number to those vehicles. As well, most provincial Highway Traffic Acts require companies affix an NSM to all vehicles they manufacture. The purpose of the NSM is to certify their vehicle production complies with the regulations under the Motor Vehicle Safety Act.
CTEA can help manufacturers prepare their application for an NSM, and also offers guidance in the administrative and technical requirements associated with the process.
Join CTEA's director of government and industry relations, Don Moore, in conversation with CTEA’s technical programs manager, Jeremy Harrower. It's everything you need to know about the national safety mark but didn't know who to ask. 

In this episode we cover: 

• lighting requirements
• vehicle stability
• braking requirement
• document retention
• how to apply for a national safety mark
• and much more. 

Resources

•  Canadian Transportation Equipment Association 
• CTEA NSM Application Review 
• Transport Canada NSM FAQ
• Transport Canada Vehicle Safety Standards
• Transport Canada Motor Vehicle Safety Regulations (C.R.C., c. 1038)

Transcript

Don Moore: 0:02

Okay. This is Don Moore with another on the radar ba podcast. My I'm kind of hosting my colleague today Jeremy Harrower, who is the CTAs technical programs manager. One of his key responsibilities is assisting new and existing members with applying for transport Canada's National Safety Mark or NSM. VLSM is required by domestic law on road vehicle manufacturers to sell their product in Canada across provincial boundaries. The NSM is the little maple leaf logo with three digits in the middle and on a deckle on the door jamb of any car operating in Canada, you can just go out to your own car and have a look in the door jamb, you should see that little circle with the maple leaf. So welcome, Jeremy.

Jeremy Harrower: 0:57

Thanks for having me done.

Don Moore: 0:58

Okay. We are going to start out by to talk about some of the general requirements for applying for an NSM. And some of the common issues that Jeremy runs into a crock as he's been doing this for a number of years, as he's assisted members, basically across the country. So, Jeremy, let's start out with the National Safety Mark. Well, and where is it defined?

Jeremy Harrower: 1:30

So the National Safety Mark is defined in the Canada Motor Vehicle Safety Act. It is a registration that's put through by manufacturers to Transport Canada to ensure that they are building to a compliant set of regulations per that type of vehicle. There are different types of national safety marks, we range from Final stage to intermediate stage to altered stage for trucks. And we get into the trailers and the different types of trailers in the main division between those two would being non airbrake versus Arabic versions of the trailer. One of the major things that we encounter when we first start talking to these companies that are manufacturing product is what the actual definition of manufacture is. And that's pointed out directly in the Motor Vehicle Safety Act is in a state's manufacturer in relation to a vehicle includes any process of assembling or altering the vehicle prior to its sale to the first retail purchaser. And that's a very important statement in that last little section about that first retail sale. That means that the vehicle is brand new, it has not been registered yet. We do get into some gray areas when we talk about alterations and what happens in that search for vehicles that potentially have been sold or haven't been sold. But for the most part, when we deal with the truck side, we're looking at the final stage manufacturers more more so than any of the other the other levels. And what we talk about is when a company is installing a body onto a truck chassis, whether that be a pickup sites truck chassis up to a very large classic type chassis, like a Peterbilt, Mack International, whatever it may be. And on the trailer side, when we look at that, again, there's that large distinction between non airbrake and airbrake trailers, but they both have to have their National Safety Mark.

Don Moore: 3:19

Okay, now, CTA offers assistance for members applying for a National Safety Mark. And how does that work? For any association?

Jeremy Harrower: 3:32

What's correct on we do offer that and that's one of my main caveats as, as the technical programs manager hears that I assist companies in some way, shape or form to get their National Safety Mark. There are basically three different ways of doing it. There's either in house where I would visit a company directly to go through step by step to get the application done. And one of the misnomers about the application is that it's just that's all you need to do to for Transport Canada, for that particular vehicle. But in essence, what you're doing for Transport Canada is showing that you're building that particular vehicle that's being used in the application as being compliant, but also showing that you have a process in place that demonstrates the Transport Canada that with every vehicle that you're going to manufacture, that you're following this set of processes to make sure that you get the record keeping done properly. And we'll probably touch on this a bit more as we go through. But Transport Canada does have the ability to audit whether it be in person going to the company's front door and knocking on the door saying we want to see your NSM records for vehicles x y Zed, or they can do it via remote audit. Similar to what we do in some cases, when we do our own audit kind of work where we work with companies remotely to get that done. It's obviously more efficient. Travel is a little bit daunting at this point with the cost of travel. So we see that transport Canada's doing more of these remote audit type setups as far as what we do in the National Safety Mark aspect It is, again, we do have the in house where I can travel to the company. Obviously, it's a little bit more expensive, but it tends to be a bit more comprehensive, where I can show the companies what to do as I'm there. Although that does take some time out of people's days to make sure that that gets done. But it ensures that we get things done properly in the first goal that when I'm looking at a particular vehicle, I can pull it point out any deficiencies that are issues that we might encounter that need to be taken care of prior to getting the NSM application done and sent to Transport Canada. The other methodology is that we do have what are called NSM asst packages that are specifically designed or catered towards a certain type of NSM application. Again, predominately when we look at the truck side, we're looking at final stage, body and equipment. On the trailer side, we either have the airbrakes type application, or the non airbrake type application. And the packages are go document by document and template by template as to what needs to be completed. In my eyes, I prefer doing it this way, this puts the onus on the compliance contact at that company to deal with the paperwork directly to show them exactly the steps they need to go through to get that done. It's a good learning curve, even though I'm not there to point out directly, they do have contact with us via phone or email, I can go through step by step on what needs to happen. On the truck side, we obviously have the load expert program, which is a big step and what needs to happen with the truck side of NSM applications where we have to go through calculations for combined vertical center of gravity load distribution on the axles, and the maximum payload. There are other programs out there that do accomplish this in the same way. And it can be done manually as well. But we've paired up with a company called C tech over the years that has provided us with the access to the load expert program, which many of our members use on the truck side of the application, and in some cases, the trailer sides as well.

Don Moore: 7:02

Well, yeah, I think I want to dwell on that just a little bit, or at least talk a little bit about the reason for using the software. And the whole idea of dealing with the center of gravity. Where does that come from.

Jeremy Harrower: 7:21

So the center of gravity is described in the Motor Vehicle Safety regulations, there is an a set value that is prescribed by Transport Canada, that we derived from what's called the incomplete vehicle document in the case of trucks. So each manufacturer provides an incomplete vehicle document for an incomplete chassis. And that would be a bare chassis that does not have a body installed on it as of yet, when we do get into the lighter side of the market, we do see people that use pickup trucks that they will take the box off and then add a body to that's where we get into the alternate side of the National Safety Mark. And you can go to the manufacturers websites to obtain some generic information in regards to vertical center of gravity or a lot of cases, a generic version of an incomplete vehicle document for that particular make model and year of vehicle. So that's something that we make sure that we have to have there is as part of the record keeping the incomplete vehicle document has to be included with your record keeping in the case of trucks. In the case of an altered vehicle again, we use that generic version with that the incomplete vehicle documents give us the value for for the vertical center of gravity. And what that is is a point that's prescribed by the vehicle manufacturer to say that if you stay within this envelope, the braking system will braking system will perform as as required for stopping distance timing and whatever it may be. So that has become a very important aspect of what needs to be done as far as calculations to ensure that the vehicle is operating properly in regards to braking, which in the case of hydraulic brake systems really can't seem VSS 105 Will will mention CMBS several times over the course of the podcast today. That is the Canadian Motor Vehicle Safety Standard. And that is in regard to what is prescribed under the motor Motor Vehicle Safety Act. And under that the Motor Vehicle Safety regulations for Canada. In the case of in the case of airbrake vehicles, we're talking about one, which tends to be a little bit more elaborate than 105. But is regardless of which aspect we're looking at the center of gravity is an important factor in both.

Don Moore: 9:36

I think it's important to stress the fact that although it isn't specifically spelled out in the Motor Vehicle Safety regulations in a CMBS s 121 or 105 that it is really the envelope that the OEM is is providing to, say, an upfitter, to ensure that the that center of gravity is such that it's not so high that it affects the stability of vehicle. And it's also not affecting the braking, in that the weight transfer to the front end of the vehicle in the braking action is not overloading that that front axles braking capability. And so you know that that is an important element. Absolutely. You know, I think that's that that's the good the the key reason for it. So if there's anybody out there scratching their head saying, you know, what's this all about. And

Jeremy Harrower: 10:45

in that center of gravity is very much looks like when we harken back to high school physics, when we look at the beam calculations with the two little triangles supporting the beam. Essentially, when we look at a truck chassis, it's that beam, and it's got three points or two points of contact under it. And when we talk about that center of gravity calculation, we're doing torque calculations, and torque is simply force times distance. In this case, it's the weight of whatever you're added to the vehicle. And taking that torque calculation around that, that center of rotation, which is the center of gravity of the chassis. And then as you add components to it, it changes that overall value there. And again, there are ways to do it manually, there are people that are more than capable of it when we look at the level of complication of some of the vehicles that we've dealt with over the years, we've got some companies that are adding dozens, if not hundreds of components to trucks, and having to do calculations for each at three different points to make sure that it all works properly, can be a bit daunting and a little overwhelming. In some cases, having a program like a load expert or a truck science or whatever it may be, you can actually build the vehicles virtually. And it allows you to build the vehicles ahead of time to see well what happens if we do this with this particular chassis. Or we choose another manufacturer use this chassis, are there any differences, we can change modify things like wheel base quite easily, we can add and take away axles. So there's a lot of built in options that make that simplify the process, and then actually allow you to, even before it's purchasing a vehicle, you can put the vehicle together virtually and see what happens and show a client, a client or a customer, or fleet, whatever it may be that this is what happens when we use this particular chassis with this particular wheelbase. Here's what happens if we choose a different manufacturer. And here's a different wheelbase, and see what happens here and see what makes the most sense in that aspect. But it all harkens back to what we need to do for the National Safety Mark part of the record keeping aspect, right.

Don Moore: 12:44

And if those what ifs that can be very time consuming. So this is a way to save time.

Jeremy Harrower: 12:50

Absolutely. And some of the manufacturers have built in calculations that you can do for vehicles, they tend to be on the less complicated side and we deal with things called water level loads are safe, we're talking about a water tanker. If you were to put an even load in that tank, we know that it's always going to be even across the board. But when we start to get into the more unique aspects of vehicles, like we've got crane carriers or emergency vehicles, there's a lot of different components that go into those being manufactured. And we have to accommodate for all of those factors when dealing with dealing with load at the axles and then dealing with the combined center of gravity as well. Right?

Don Moore: 13:31

Seems like we've been spending a fair amount of time but it is really when we get into the truck updating side of our membership, it is one of the more important more challenging parts of applying for the National Safety Mark and documenting across all of your products. And the whole idea is that you will be keeping this information on an ongoing basis for virtually every vehicle you build, essentially. Now

Jeremy Harrower: 14:07

one of the common questions we get is How long do we have to keep our records and Don and I have had this conversation several times over the years were the minimum recommendation from transport Canada's five years, when we look at income tax. And this is kind of the approach that I take with National Safety Mark record keeping is it's a very, it's very much like keeping track of things for CRA when you're doing your taxes. So we look at that seven year limit for taxes and a vehicle has taxes involved with it. So seven Yes, but both Don and I agree that I think 10 years is is a reasonable amount of time for keeping records for particular vehicles. And there are some vehicles that only last five or six years and they're taken off the road or repurposed and in many cases, they will last tend, if not up to 10 to 25 years in some cases for things like cement mixers. So there are there's a big variation in the types of applications of vehicles But 10 years seems to be a reasonable amount of time for keeping records. And one of the other aspects in regards to record keeping is how do we keep records is it all digital is it all paper is a combination of the two. And that's something that you have to gauge with your company. Obviously, when we talk about things like the incomplete vehicle document, it is a paper document that comes with the chassis. So having that as a piece of paper is a likely scenario that you're going to have to address when keeping your records. Over the years, we've seen companies that have completely digital records and their systems have gone down, or they've been hacked, or they've had fires and they've lost computers, or they've had employees walk away with a laptop that's got everything on it, or they've kept things on a USB key and lost the USB key. There's a lot of scenarios. So you've got to do have your due diligence in regards to record keeping. If you're doing paper, make sure you've got a secure place to keep it that somebody more than one person knows where it is, again, Don and I have talked about this several times over the years and having companies where there's been one particular compliance contact and they retire, quit pass away or change jobs. And there was only one person that knew where anything was or how anything happened. So it's valuable to have more than one person or even more than two people in your company that know what's going on from that aspect of record keeping, because of the situations can evolve over the years, with employees coming and going and passing away and retiring. There's a lot of protectionism in some cases where people don't divulge a lot of information, but it's valuable to a company, regardless of its size on having more than one person know what's going on and not in regard to the record keeping aspect.

Don Moore: 16:48

Right. And I think the the 10 years is a reasonable sort of average, particularly with the truck up fitter side. But I think, well, and I just want to stress that you've got to consider the, you know, expected lifespan of the vehicle, I think, you know, and really, maybe also have a chat with your legal counsel. You know, what's appropriate for the products that you're you're building, because to a certain extent, it comes down to, you know, what potential issues might pop up in the field over time, and, you know, maintaining appropriate documentation to help in dealing with those possible situations, so might be worth a chat with, with counsel. And, you know, you get into some of the trailers that last, as Jeremy said, 25 years, you may want to consider certainly a longer period of time, but also, as he pointed out, Transport Canada, minimum five years, but remember, that is a bare minimum. Anyway, let's move along, where to members run into problems that you've encountered over the years, when they're applying for their NSM.

Jeremy Harrower: 18:11

A lot of times on the trailer site, especially in the late duty trailers, we'll see manufacturers that tend to copy other manufacturers product and yes, in some ways, that's That's all right. But in the aspect of lighting is where we tend to see a lot of issues where companies interpret what lighting should be, or they say, well, Company X, Y Zed down the road is building trailers this way with this kind of lighting. And they haven't been caught or told to do anything different. And that's all fine and good. But Transport Canada has a specific interpretation of the way lighting is supposed to look, we've worked very closely with them to make sure that we're relaying that information to our manufacturers, both on the truck and the trailer side. We did publish a couple of articles back in 2019, on both the truck and trailer aspect where the articles were heavily vetted by Transport Canada and make sure that we were relaying the information they expected to see from trailer and truck manufacturers in the business. And it is something that I get into arguments with with many members saying that Why are you doing this? Why are you doing that? We do see a lot of pushback from US manufacturers that come into Canada as well. We do deal with foreign manufacturers coming into Canada and in order to have a loving level playing field. They also have to follow the same regulations as we do here in Canada, and in some cases even a little bit further and above and above when it comes to the record keeping and keeping track of vehicles but lighting is a big one. Transport Canada has reference to every specific lighting and reflector location on a vehicle. And there are interpretations of certain things but those interpretations are very specific. One of the big things I see a lot is how to interpret clearance lamps at the back of vehicles and up front the front of vehicles so it's those Amber clearance lamps at the front of a trailer, the red clearance lamps at the back of a trailer. When I first started, there was Transport Canada was a bit more lenient about allowing lights that are mounted on the rear side being able to use be used for the rear clearance lamps. And when we published that article Transport Canada made it very clear that if you're going to combine the rear and rear side clearance lamps, they can be one light but they have to be more mounted on 45 degrees and they have to be PCT rated. When we talk about PC ratings, the SAE the Society of Automotive Engineering has very specific values assigned to particular lighting locations. And in in turn, when we talk about lighting in Canada, it's Canadian Motor Vehicle Safety Standard one a weight and the US uses the same standard for the most part, light for light and reflector for reflector. But Transport Canada has taken a bit more of a hard line in regards to lighting and a lot of aspects, especially when you talk about things like those clearance lamps. Same thing at the front on a trailer, you need rear end or front end front side clearance clearance lamps, they can be combined, but they have to be on that 45 degree angle conspicuity tape is another one that gets used a lot on vehicles on a vehicle that is over 10,000 pounds or 4536 kg. You can use conspicuity tape to replace reflectors on a vehicle that's under that weight. You can use conspicuity tape, but does it count for anything. And if you do use that constantly QD tip, you have to keep in mind that it can only be really located it relative to certain colored lights within a certain distance, there's a note that we provide that's provided in that lighting trip that we do send out and for those that are listening that don't know what that lighting chart is feel free to get a hold of me and we can provide one to you. We've got digital versions of it available on the website under the government links with successful by our members. Again, there's some very specific aspects of lighting you have to be careful of just because you see a trailer rolling down the road or a truck rolling down the road that has particular lighting on it doesn't necessarily mean it's right. It just means that Transport Canada hasn't been informed or the provincial inspectors haven't really taken a close look at it. And there's there are different perceptions of what the provincial regulatory bodies look at for lighting versus what Transport Canada would look at.

Don Moore: 22:33

Okay. And now what do you foresee in the future members should be aware of as we move forward with technology, environmental considerations that that type of thing. On

Jeremy Harrower: 22:50

the environmental side, we do have the GHG regulations, which unfortunately, what the delays that have happened on the US side in regards to trailers has affected Canada as well. There was some anticipation that Environment and Climate Change Canada would push forward with this next level of GHG regulations on trailers, but we've been informed that it has been delayed once again, and it all likelihood may not come to fruition at all. Unfortunately, one thing that we have seen on the environmental side, again, is the break materials being more heavily vetted and more more heavily monitored. We've seen the state of California and Oregon look at limiting the factors for copper in brick materials. Obviously, asbestos was a big thing for several decades. And we have the industry as a whole has done its level best to try and get rid of asbestos as a whole and breaks. And we seem to have been very successful at that. This next stage seems to be copper, where it does have some detrimental effects when it's released into the environment in a powder or gas form.

Don Moore: 23:57

Okay, and also, it's something that that we were we're monitoring fairly closely. I think that's important to note that these changes, particularly for our generic trailer park brake program. I think what it comes down to is we will see more new test reports. We've got what 200 Plus reports currently on file with our program that if members become stakeholders in that program, they can take advantage of using any of those test reports and Transport Canada will will accept that as proof of compliance for the specific combinations that you're using. That are in line with the test report that that's in the The database. The I guess the thing that we see coming down because of these potential changes is that we will see potentially a lot of new combinations new materials being used, therefore more of these reports will be available. And Jeremy, I guess that's along with disc brake. We're seeing that being used more out there as well. Yeah,

Jeremy Harrower: 25:26

absolutely. The One. The One variation with disc brake is that we see that there are manufacturers of disc brake system. And it seems to be the axle manufacturers pair up with those that don't have their own systems, like a web CO or a a holodecks. And they use their systems and they do their test reports are they produce their test reports from those combinations. And as Don said, because of the changes in brake systems and brake pad material, we will see some updates to those test reports in Riyadh on average of probably 10 to 12 tests a year from all the many of the major manufacturers that are involved with the program. When we go into the aspect from the truck side, obviously Evie is is front and center on what's going on. Unfortunately, there haven't been any real major developments on that side. As far as standards, we've talked to Transport Canada about it, it's on their radar. And again, because we are quite reliant on the US for guiding the regulations, we tend to wait and see what they're doing before we push forward. We have seen Transport Canada take initiative on a lot of things. And they're just because we're so harmonized with the North American trade, and that includes Mexico now as well. We want to try and keep the a level playing field across the board between the three companies to make it as easy as possible for manufacturers, first of all, and then obviously, fleets and truck manufacturers and those in our industry so that we can make it as easy as possible. But we have seen some need for attention, especially when we talked about converting internal combustion engine type vehicles over to electric. There are some companies that are interested in doing that with brand new chassis is at as it stands now, Transport Canada says they just need to meet the current regulations. But I would say in some cases, those regulations are lacking in specifics in regards to those vehicles. Another thing that we need to look at is regenerative braking. It's not something that's ever been taken into consideration. The if Transport Canada said, well, it can fall under 105 or 121 the way it stands, but I think there's potential where we need to look more specifically what's going on from that aspect. Obviously, the high voltage and high amperage wiring that's on vehicles is much different than what we've been dealing with for the last 90 years for commercial vehicles, potentially, almost 100 years now. So that has to be taken into consideration as well and will likely need its own standards in that regard. We've spoken with a lot of the major manufacturers that have wandered into this, this realm, and obviously bodybuilders, especially those that are membership are very interested on how they can or can't work on these vehicles and what you have to be cognizant of when you're working on these as well.

Don Moore: 28:23

So the last thing you want to do is put a drill through a frame rail and hit a 700 volt wire on the other side. It's extremely shocking experience,

Jeremy Harrower: 28:37

to say the least.

Don Moore: 28:39

Anyway, yeah. No, carry on, please. Yeah.

Jeremy Harrower: 28:43

And again, we were hoping that the regulations get put into place before we get to that point. Transport Canada is aware of our position, we see it a lot in the US. Both Don and I attend conferences in the US and EVs have been front and center for quite a quite a while, especially on the truck side. I've talked to a lot of the US manufacturers when I visit visit them and say, Well, are you bringing your product to Canada? And they said, Oh, of course we are. But I said Do you know how and that's the next step. We're dealing with Canadian regulations for foreign manufacturers. Again, it's the same as what we deal with internally as the Canadian, the Canadian marketplace, but they seem to be a little bit lacks when it comes to the know how of how to getting things like that into Canada. There are Canadian manufacturers that are in this realm already, like electric being one of the big ones. We've seen a couple of our members that have started development on their own Evie chassis as well. And it's it's great to see it's something that's obviously going to be required, if not necessary in the coming 10 to 15 years. The province of Quebec expects to be fully electric by 2035. I think we all know that maybe be a little unrealistic at this point, but we have to move forward, there's isn't a choice at this point, we have seen the effects of what's going on with internal combustion engines and the side effects on our, our environment from all of that, plus all the rest of industry that contributes to that as well. So it's something to look forward to, it'll be very interesting to see. Obviously, the transition from from internal combustion engines to EVs is very interesting. EVs have a huge advantage in regards to simplicity of how the vehicles perform, and the number of parts. But we have a severe issue when dealing with a country the size of Canada, and how do we use Evie vehicles outside of just urban centers, and how to get from St. John's, Newfoundland to Vancouver, BC without having to stop 60 or 70 times for eight to 10 hours each time to get the vehicle charged up?

Don Moore: 30:56

Yeah, infrastructure is a big deal. There's no two ways about it. You know, I've had conversations with that, and how realistic particularly long haul, in our in our membership, particularly in the vocational truck area. Those are areas that yeah, though, they're going to be earlier adoption of electric hybrid, any number of these solutions simply because, you know, they are typically used close to home. So, you know, therefore, having our chassis manufacturing members fully aware of what the risks, what the issues are surrounding electric vehicles is important. And we continue to try to be, I guess, a clearinghouse as much as anything for information on these topics, particularly related to regulations that may be coming forward. You know, we constantly are talking with the government, federal, provincial, even though every so often, even a municipality will throw up their hand saying, you know, there's there's going to be certain requirements. So, yeah, it's, it's a moving target. And I think one of the things that Jeremy would share with me and in, in speaking to our listeners is, that's kind of why we're here. That's why the CTA the Canadian transportation equipment association exists. And if there's anything that we can do to help in understanding things, or digging into it to find out more detail, we're more than happy to do that. So you know, please let us know. So, Jeremy, any final comments?

Jeremy Harrower: 32:58

Certainly, I mean, even continuing on on that Evie side of things, we're looking at that from the trailer aspect as well, we're, we're trying to improve efficiency with long haul vehicles and heavier vehicles. We've seen some movement on the powered axles on trailers as well, which will have a major effect on the regulations because, in essence, a trailer is defined as a non Motive Power type of vehicle. And if we do add power to it in some way, shape, or form, that will change the definition of the vehicle as a whole. So that's something that we've looked at over the last couple of years, when this has been brought up a few times, we've seen some manufacturers on the actual side and the transmission side, wander into this into that realm and trying to figure out trying to figure out how to navigate through through the regulatory side of things like that. And it's hopefully something that we'll see develop more and more over the next few years. As far as the National Safety Mark goes, it's great to see the number of companies that are still getting registered. That means there's new companies in it that are coming into existence. We saw it even during COVID When there was a major downturn on a lot of industry, the trucking industry was extremely strong. We've seen it leveled out a little bit the last year and a half to two years. It was to be expected. But we do see the need for equipment. Canada is a bit of a unique market as far as vehicles go. We're not as generic as what we see in the US for a lot of vehicles and we see a lot of specialty vehicles. And even Canadian manufacturers that build in our market are selling a lot into the US and overseas as well. So it's encouraging to see from that aspect and it's great to see that companies understand that they need to follow the regulations. One of the things that we've seen over the years, especially in in province tight manufacturing where on the trailer side we see a lot of homebuilt VINs being assigned to vehicles. The provinces are getting less and less comfortable with that which is encouraging for are members that are that have their national safety marks are looking to get their national safety marks to even up the playing field to make sure that things are happening they were they should happen and that the shop around the corner that says they'll do a job for $4,000 Less aren't getting the work just because it's cheaper. Companies are aware that the National Safety Mark is in play and if they want to deal with that, legally and not have to deal with liability, it's an absolute necessity.

Don Moore: 35:28

Right on. So anyway, we'll I think we'll conclude there. I really want to thank you, Jeremy for helping me out with this topic today. It's really important. And I want to thank everyone for listening and please keep an eye out for future podcasts. Have on the radar. From the CTE bye for now.