Interpretation ID: aiam1626
Vice President - Operations
Krown Manufacturing Company
Inc.
1165 Reynolds Road
Charlotte
MI 48813;
Dear Mr. Wirt: This is in reference to your letter of October 4, 1974, concerning you recall campaign (NHTSA No. 74-0124) involving improperly machined P.O.L. nipples which were attached to L.P. gas regulators furnished by the Marshall Brass Company for use on camping trailers.; Since your company had not determined that a safety-related defec within the meaning of the National Highway Traffic Safety Act of 1966 (the Act) existed until after receipt of our letter of September 23, 1974, we agree with your reasoning that the first quarterly report should cover the period ending December 31, 1974.; Although your revised owner notification letter is not technicall correct, it appears to be adequate from the owner's point of view. An additional revision and mailing will therefore not be necessary. Specifically, the second sentence of your letter is incorrect in that it states that the National Highway Traffic Safety Administrator has determined the existence of the safety-related defect. Our letter of September 23, 1974, did not constitute a formal determination by the Administrator, but was merely intended to explain your company's legal obligations and to persuade your company to make such a determination. Since you stated in your letter of August 5, 1974, that a potential defect exists, but only expressed your opinion that the Act did not apply, it was felt that a defect determination by your company was likely to occur. A campaign number was therefore assigned for recordkeeping purposes.; The second sentence of your letter should also have described th defect as existing in the vehicle itself, rather than describing the defective part. The reference to 'item of motor vehicle equipment' in Part 577.4(b) refers only to campaigns in which vehicles are not involved.; It is hoped that these comments will assist you if the necessity o conducting another safety defect notification campaign should ever occur in the future.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs;