Miss Klouser, I don’t mean to step into this email but I don’t see any reference to how you take all the defective parts off the road and off the cars that have been installed once a REPAIRER tells you they found a defect? Also how come I am constantly still getting CAPA certified parts that even physically look different then their OEM counter parts? Why does the shop have to perform all this parts testing and complaint filing for free? How is that our issue again? Who made the legal definition at CAPA as to what is and what is not a “cosmetic” part of the car? When you say “Regarding your specific concern, we agree that the critical performance, appearance, and material characteristics of a CAPA Certified part should mimic those of the car company brand part.” What is meant by “Mimic” shouldn’t it be LKQ Exactly like the same kind and the same quality.? Thanks and I am sorry to step in you just prompted some questions I had. Mark Cobb Cobb's Inc. D/B/A Cobb's Collision Center From: Debbie Klouser Sent: Wednesday, May 11, 2016 2:21 PM To: Mike Parker Subject: RE: CAPA Certified aftermarket structural & HSS parts Dear Mike – Thanks for your email and we appreciate the opportunity to respond to your concerns. First I would like to respond to your comment regarding CAPA’s failure to respond to your 9-16-15 inquiry through CAPA’s website. I did respond to that inquiry on 9-18-15. In my response I indicated that if you believed that the two CAPA Certified radiator supports that you referenced (or any other CAPA Certified part) were not comparable to their car company service counterparts, that you should submit a CAPA Quality Complaint so we could evaluate the parts in question. (See attached email). Regarding CAPA’s involvement with bumper parts, we didn’t introduce our CAPA 501 standard until 2010 and did not have any certified bumper parts in the program until November 2011. Because someone told you in 2007 that CAPA parts were crash tested, I clarified our position in an April 2007 email to you indicating that because the parts we were certifying at that time were generally cosmetic, there was no need for crash testing. With the implementation of the 501 bumper standard which includes stricter requirements and performance testing, we are able to further compare the parts performance to the car company branded service part. This is why, in developing the standard, we worked closely with the Insurance Institute for Highway Safety, the nation’s leading auto safety testing organization, performing both low and high speed crash tests to evaluate part performance which indicated that parts meeting the CAPA 501 standard performed the same as the car company service parts. Because the CAPA program is one that tests every significant aspect of a part to see that it performs the same as the car company brand service part, we work hard to ensure that the standards and tolerances are legitimate, fully transparent and, most importantly, effective. One of the ways we do that is to ensure that the standards and tolerances are fully vetted and approved by CAPA’s Technical Committee which includes key members of the collision repair industry. (see http://www.capacertified.org/about-capa/capa-technical-committee/). Regarding your specific concern, we agree that the critical performance, appearance, and material characteristics of a CAPA Certified part should mimic those of the car company brand part. To that end, we use tensile and yield tests to compare strength, which the material engineering community has determined are much more accurate, accepted, and useful than hardness tests for comparing material strength. Hardness tests are performed on metal components only when the design or shape of the part precludes tensile and yield strength testing. Theoretically, hardness correlates to strength, but it is not as accurate as tensile and yield tests in determining the actual strength of a part. Regarding the Subaru replacement part you mentioned, while we did not hear from you about it, an insurer brought it to our attention in May 2015 and we asked to have the part for testing. When we didn’t receive it, we purchased parts from the market and initiated our own testing. At that time, we were able to verify the concerns raised. The part, which originally met our tensile and yield strength comparative tests, no longer did so. We immediately decertified the part lots tested and prohibited the manufacturer from making any more CAPA Certified versions of the parts until they could demonstrate proper material properties based on yield and tensile strength testing. You mentioned, generically, a number of other parts which you believe may have material differences from the car company brand service parts. We would very much appreciate the opportunity to purchase the parts from you and put them through the CAPA testing process. If that is not possible, if you could identify the parts, we will purchase them from the market for testing. A key element of the CAPA program is our complaint process – we strongly encourage and appreciate shops telling us when they uncover a perceived issue. We understand that shops today want a chance to fix the car, not send it to the junkyard as a total. But to do so, they need access to high quality parts, and that is the reason why CAPA exists. As you know, we don’t market, sell, or profit from, or distribute parts. We test parts to identify which ones meet our comprehensive standards, which as you indicated in your email, is impossible to do in the field. In fact, we have tested a number of parts that look and fit just fine, only to find they are made of the wrong materials or improper construction. So as we did when we were first notified of the problems with the Subaru, we will take any actions necessary when a part surfaces that does not meet our standards for functional equivalency to the car company brand service part. As such, we look forward to getting more information from you on the parts that you have studied. It is clear that you are interested in quality and we would like to offer you the opportunity to take a tour of our testing facility in Grand Rapids, Michigan. In fact, our executive director, Jack Gillis would be happy to host you and some of your colleagues in Vermont for such a visit. We’ve had many (if not most) of America’s collision repair leaders visit our facility, including some of the most outspoken critics of aftermarket parts. Not only does this afford CAPA with a great learning experience, but nearly 100% of those visits have resulted in the knowledge that there is little difference in the goals of CAPA and of today’s collision repairers. For our part we assure a candid, honest, fully transparent look at the program with no questions, concerns or issues brushed aside. We hope you and some of your colleagues will take us up on this offer. There’s certainly a great deal of angst, anger and concern about the issue of aftermarket parts, so we believe anything we can do, together, to improve the situation would be an investment well worth the time. We hope you agree. Thanks again for getting in touch with us and we look forward to working with you as we continue our efforts to ensure that the market has access to high quality, safe and reliable alternative parts. Kindest regards, Debbie Deborah G. Klouser Director of Operations Certified Automotive Parts Association (CAPA) From: Mike Parker Sent: Monday, May 09, 2016 10:26 AM To: Debbie Klouser Subject: CAPA Certified aftermarket structural & HSS parts Debbie: This e-mail is in regard to metal hardness of CAPA certified aftermarket parts. Specifically parts that the original Equipment manufacturer (OEM) parts are high strength steel (HSS) and radiator supports, which are considered structural parts. Because a previous contact regarding this subject was ignored by CAPA I am copying this e-mail to some other parties to ensure this issue is brought to light. I’ve tested some CAPA Certified aftermarket replacement parts with a Rockwell Hardness tester and compared the hardness to the OEM part it was intended to replace. My sample size was small, but there was a 100% failure rate. The hardness of the CAPA Certified aftermarket parts were significantly different than the OEM parts they were supposed to replace. Because of the 100% failure rate I have to conclude there are a significant amount of CAPA certified aftermarket parts, presently on cars, that are made from different material than the OEM parts they are intended to replace. This brings up two issues. First in regard to the radiator supports there is a potential safety issue. Radiator supports are considered structural and play a role in the deployment of airbags. Secondly, if the CAPA aftermarket parts are not equivalent to the OEM parts they replace the vehicle owner isn’t made whole. The parts would not be of like kind and quality which is a requirement of most insurance policies. I am basing my concerns upon statements previously made by CAPA. The structural CAPA certified aftermarket radiator supports are not of the same hardness as the original equipment parts they intend to replace and in CAPA’s own words this puts the driving public at serious risk. The following are the statements that I refer to: In 2007 there was an appraiser in this area telling consumers that CAPA certified parts were crash tested just like the OEM parts. I knew that was untrue, but e-mailed you for verification to resolve the issue. I got your response in an e-mail dated 4/26/2007. This was your response: “No CAPA parts are crash tested because CAPA certified parts are only considered cosmetic parts. This includes bumper covers because they are only covers – they are not reinforced steel. If they were reinforced steel bumpers then we would be required to do crash testing. All of the parts material strengths etc. are tested and must be the same as the OEM in that respect as well as fit and appearance.” A couple years later during the Collision Industry Conference in November of 2009, repair organizations demonstrated testing an OEM and a NON-OEM bumper reinforcement for a 2009 Toyota Corolla that was not CAPA certified. These tests demonstrated that Toyota’s bumper reinforcement made of high strength steel (HSS) was exponentially stronger than the non-OEM bumper reinforcement that was made with ordinary carbon steel. On February 1, 2010 CAPA issued a press release. I will not quote the entire release, but there are 2 paragraphs that will help make my point. “For the past 2 months, CAPA has been conducting its own independent evaluations of aftermarket bumpers” said Gillis. “The results of these tests point squarely to the need for a CAPA bumper standard. CAPA is proud to be able to respond to this urgent need by developing independent certification standards for bumper reinforcement parts.” “In developing the standard, CAPA has tested numerous bumpers for comparability to their car-company-brand counterparts. In testing what appear on the surface to be reasonably well-manufactured aftermarket bumpers, our laboratories discovered serious deficiencies in mechanical properties such as strength and metal hardness, material thickness, and fit. These deficiencies potentially place the driving public, who trust body shops to repair their vehicles with safe quality parts, at serious risk.” The bumper reinforcements that CAPA has referred to in their press release are structural, as are the radiator supports. Because these parts are structural they both play a role in the proper timing of the deployment of the airbags. So the radiator supports should concern CAPA as much as the NON-CAPA bumpers and the supports were CAPA certified. In 2015 I had an insurer challenge me to first prove that a CAPA certified Subaru radiator support upper tie bar was not of like kind and quality (a policy requirement of insurers) and later on a Toyota CAPA certified radiator support to prove it was unsafe. In response to this I bought a $2,200 Rockwell Hardness Tester. In both radiator support tests I found that the CAPA certified part was significantly harder that the OEM counterpart it was meant to replace. There is a formula to convert Rockwell “B” scale values to tensile strength. I calculated difference in tensile strengths, between the OEM and CAPA certified aftermarket part to be around a 16,000 psi. The deployment of an airbag could be delayed by a part harder than the manufacturer of the vehicles intended it to be. I then had an insurer recommend a CAPA certified Chrysler hood. The factory hood is made from HSS. I could not tell you the difference as the CAPA certified hood was so soft I could not get a reading on my Rockwell hardness tester. Most recently, at a Congressional Hearing, Jack Gillis was quoted to say, “Well, first and foremost, the parts should be certified to be functionally equivalent to the car company brand part”. Obviously if the parts are not of the same hardness, different metals are being used and they are not functionally equivalent. Based on this information I believe CAPA should immediately decertify all aftermarket radiator supports and aftermarket parts intended to replace HSS OEM parts and to recall and replace all the CAPA Certified aftermarket radiator supports installed on vehicles with OEM supports. Mike Parker President of the Vermont Auto Body Association