On December 20, 2021, the Washington State Department of Labor and Industries issued an Emergency Rule (WSR 22-01-190) to address the growing backlog of plan approvals in the Factory Assembled Structure (FAS) program. The program, responsible for the approval of all RV and PMRV plans, has been facing significant delays in issuing approvals to manufacturers. Each plan approval is necessary in order to receive the Washington State seal legally required to sell an RV or PMRV in the state.
The plan approval program has been met with significant delays as staffing has been reduced in response to the ongoing COVID-19 pandemic. The emergency rule states that as of the filing of the rule, FAS has 2,000 plans waiting for review by the program's two remaining plan examiners and that these plans include everything from simple RV trailers to large commercial buildings. At full staffing, the program has seven plan examiners.
The Emergency Rule authorizes a new initiative aimed at reducing the backlog. Rather than hiring additional staff within the FAS program, the emergency order allows for "licensed professional" plan reviews. Professional engineers, architects, or other licensed firms can now seek approval to participate and take on these approvals outside of the state’s plan approval program. While this action could reduce the backlog, the order does not stipulate any timeline for the approval of said firms, or if any firms have already been approved.
The Washington State Department of Labor and Industries does make note of the burden the backlog has placed on the RV Industry, adding “lacking plans for some of their designs, the RV and [PMRV] industries face delays in sending their products to Washington as they cannot apply Washington labels to models that have not been reviewed and approved.” The RV Industry Association state affairs team is monitoring this change in the plan approval program to see its effect on the ongoing approval backlog.
For more information on this issue, contact RV Industry Association Senior Manager of Government Affairs Nick Rudowich at firstname.lastname@example.org.