Interpretation ID: aiam1689
Vice President - Engineering
Matlock Truck Body and Trailer Corporation
P. O. Box 7385
Nashville
TN 37210;
Dear Mr. Eddy: This is in reference to your defect notification campaign (NHTSA No 74-0203) concerning trailers equipped with Standard Forge axles which may have defective brake shoes.; The letter which you have sent to the owners of the subject trailer does not completely meet the requirements of Part 577(49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter describes the defect as existing in the brake shoes. Part 577.4(b), however, requires that in cases where a vehicle manufacturer is notifying owners of vehicles, the letter must state that a defect exists in the vehicle itself. The reference to motor vehicle equipment applies only to equipment campaigns where vehicles are not directly involved. Your letter also fails to adequately evaluate the risk to traffic safety as required by Part 577.4(d) since it does not state that the vehicle crash without warning may occur. Although the statement that reduced braking power or lockup may result may suggest the possibility of a crash to many owners, it is not entirely adequate.; Although mailing of a revised notification letter will not be required it is expected that in the event that another defect notification campaign ever becomes necessary in the future, the notification letters conform completely with the regulations.; A copy of Part 577 is enclosed. If you desire further information please contact Messrs. W. Reinhart or James Murray of this office at (202) 426- 2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs;