Interpretation ID: aiam0466
Chairman
Defect Report Committee
Blue Bird Body Company
Fort Valley
GA 31030;
Dear Mr. Milby: This is in reply to your letter of September 13, 1971, concerning th Defect Reports regulations (49 CFR Part 573). You request a ruling concerning S573.7, which requires manufacturers to submit a copy 'of all notices, bulletins, and other communications, other than those required to be submitted under S573.4(c)(8), sent to more than one dealer or purchaser of his vehicles regarding any defect, whether or not safety related, in such vehicles.'; You ask whether this requirement includes letters that your compan writes that are of a personal nature concerning possible defects, when the letters deal with more than one item, but have at least one item in common. If these letters are included in the requirement, you request that we specify a time span for which you would be responsible.; The intent of S573.7 is for manufacturers to provide the NHTSA wit certain information each time a defect other than a defect under S573.4(c)(8) is found to exist in more than one vehicle. Thus, assuming the defect is not one on which information has been submitted pursuant to S573.4(c)(8), you may satisfy the requirement of S573.7 by submitting a copy of any one letter that pertains to a defect found in more than one vehicle, as long as the letter is appropriately marked so that we can determine for which defect it is being submitted.; The regulation does not limit the time span for which manufacturers ar responsible, and manufacturers must be sufficiently familiar with their repair programs so that if a defect appears at two or more points in time, the necessary information can be submitted.; Sincerely, Lawrence R. Schneider, Chief Counsel