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OEM & Compliance

Doing the OEM Procedure and Documenting It Are Two Different Jobs

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A technician in safety glasses applies a bead of structural adhesive to a pickup quarter panel, with a closed repair manual sitting untouched on the bare workbench behind him

Body shop liability around OEM procedures doesn't start with a lawsuit. It starts with a technician who did the repair exactly right and a file that has no way to prove it.

"We Already Follow OEM Procedures." That's Not the Question.

Every shop owner says some version of this at some point, on a sales call, in an audit, or in a conversation with a consultant trying to sell them something. It's usually true. The tech pulled the spec sheet. The adhesive was OEM-specified. The calibration ran. The work happened correctly, start to finish.

That was never the question. SCRS's position, signed by AASP, ASA and a coalition of state and regional associations, is that documented OEM repair procedures are the standard of repair, and that disregarding them exposes consumers to safety risk and repairers to liability. The same principle cuts the other way too. Following the procedure without a record of following it leaves a shop unable to show it did anything differently from a shop that skipped the step, because nobody downstream can tell the difference from the file. Not the carrier reviewing the estimate. Not an attorney reading the repair order two years later.

Take a 2023 Ford F-150 in for a quarter panel replacement. The tech applies OEM-specified structural adhesive correctly, the way he's done it a hundred times before. If the carrier pays and nothing ever happens to that truck again, no one checks the file. If that truck is in a second collision and the repair becomes part of a liability claim, "we always do it right" is a weak answer in a deposition. A citation to Ford's procedure, a photo of the adhesive bead before the panel closed, and a line note tying both to the billed operation gives you something specific to point to. One of those is a belief about your shop. The other is a record a carrier, or an attorney, can check for themselves.

A technician in safety glasses applies a bead of structural adhesive to a pickup quarter panel, with a closed repair manual sitting untouched on the bare workbench behind him
The procedure and the proof of the procedure are two different outputs of the same repair.

The Gap Between Following OEM Procedures and Proving It Is Where Body Shop Liability Lives

The spring 2024 "Who Pays for What?" survey from Collision Advice and CRASH Network found that 61% of shops now research OEM repair procedures on all or most of the vehicles they repair, a nine-point gain since 2020. That's the compliance side, and it's trending the right direction across the industry.

Getting paid for that research is a separate question, and the best available number is older and narrower: in a December 2021 wave of the same survey, among shops that asked insurers to pay for OEM research, about 20% said they were paid always or most of the time. Either way, the research is work the shop does before a single wrench touches the car, and it only shows up on the bill if something in the file connects the research to the operation. Carriers have a financial incentive to treat an undocumented claim as an unverified one. That's not malice. That's how a claims department processes risk when there's nothing in the file to check against.

Here's the self-check. Pull ten repair orders from the last month that required at least one OEM-specified step: a calibration, a structural repair, a single-use fastener, a corrosion treatment. For each one, look for a photo and a specific citation, a bulletin number or position statement, attached directly to that line item. Not a general note that says "per manufacturer guidelines." A citation a carrier, or a jury, could look up.

Run the same check on refinish and corrosion operations, not only structural and ADAS steps. The gap shows up anywhere an OEM citation could apply, not only in the categories that feel high-stakes.

Under 50% of those ROs with a real citation-and-photo pair is red territory. Over 80% is green: the file is doing its job, and what's left is closing the last few gaps. Remember what's at stake. In the 2017 John Eagle Collision Center case in Dallas County, Texas, the shop was ordered to pay about $31.5 million after a roof on a 2010 Honda Fit was bonded with adhesive where Honda's procedure called for welds. That shop skipped the procedure. A shop that follows it but can't show it is left arguing from memory.

What the File Needs to Say

Three things have to attach to every OEM-required step, and many shops don't do all three consistently, not because they can't, but because nobody ever built the habit.

  • The citation. A specific bulletin number or position statement, not "per OEM guidelines." On a 2022 Honda CR-V requiring ADAS calibration after a windshield replacement, that means citing Honda's actual position statement number, not a paraphrase of what someone remembers reading.
  • The photo. Taken during the step, not after the panel is buttoned up and the car is out the door. For the CR-V, that's the calibration target setup and the scan tool readout, timestamped before the vehicle leaves the bay.
  • The line note. A sentence that connects the citation and the photo directly to the billed operation, so an adjuster reading the estimate doesn't have to hunt for context that lives somewhere else in a separate folder.

Plenty of shops stop at step zero: the tech did the work, and everyone internally trusts that it happened. That trust doesn't transfer to a carrier, and it doesn't hold up if the file ever gets pulled into a dispute years later. It also doesn't scale. A shop with twelve OEM certifications and a shop with two are making the identical mistake if neither one attaches proof to the work it already knows how to do correctly. The three-part structure turns "we calibrated it" into "here is Honda's bulletin, here is the calibration photo, here is the line item it supports." That's not extra paperwork for its own sake. It's the difference between a line a carrier has to take on trust and one it can check.

A grease-stained finger points at a highlighted paragraph on a printed repair procedure, next to a repair order and a small digital camera on a workbench
A citation without a photo is a claim; a citation with a photo and a line note is a record.

The Bottom Line

The compliance was never the gap. Shops that carry a dozen certifications and shops that carry two are exposed the same way if neither one attaches proof to the work. Every Estimate Optimizer™ audit ties each recommended operation to its OEM procedure and a copy-and-paste line note, so the citation part of the file is already in your hands before a carrier asks whether you did it. The photo still comes from your bay. The work was always right. Now the file can say so.

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Frequently Asked Questions

What is body shop liability for OEM repair procedures?
Body shop liability for OEM repair procedures is the exposure a shop carries when a repair departs from the manufacturer's documented procedure, or when the shop can't show it followed it. SCRS's position, signed by AASP, ASA and a coalition of state and regional associations, holds that documented OEM procedures are the standard of repair and that disregarding them exposes repairers to liability. A shop that followed the procedure but has no record of it has no way to show the difference. Liability itself is decided case by case, so talk to an attorney about your situation.
Do insurance companies have to pay for OEM-required repair procedures?
It depends on the policy and the state, and many state insurance departments do not treat OEM procedures as binding for claims purposes. In practice, an OEM-required line is far easier to get paid when the estimate includes the specific citation and proof tied to that line item. Without a bulletin number, photo, or line note connecting the procedure to the bill, carriers often remove the line because nothing in the file supports it.
What happened in the John Eagle Collision Center lawsuit?
In October 2017, a Dallas County, Texas jury returned a verdict of about $42 million in Seebachan v. John Eagle Collision Center, with the shop responsible for 75%, about $31.5 million. The shop had bonded a replacement roof on a 2010 Honda Fit with adhesive where Honda's procedure called for welds. The case is the industry's best known example of the liability a shop carries when a repair doesn't follow the manufacturer's documented procedure.
How do I document that my shop followed an OEM repair procedure?
Attach three things to every OEM-required line item: the citation, a specific bulletin or position statement number, a photo taken during the step, and a line note connecting both directly to the billed operation. A general note like "per manufacturer guidelines" doesn't hold up; a citation a carrier or a jury could look up does.
Why does my shop get denied even when we followed the OEM procedure?
Carriers can't verify compliance they can't see in the file. If an estimate lists a procedure without a citation, photo, or line note tying it to the manufacturer's requirement, the claim reads as unverified, not as compliant, and gets treated accordingly. The fix is documentation, not a different repair process.
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OEM proceduresinsurance claimsstructural repairADAS calibrationcollision repairshop owners
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