Interpretation ID: aiam1372
President
Gillig Brothers
P. O. Box 330
Hayward
CA 94543;
Dear Mr. Marx: This is in acknowledgment of your Defect Information Report, i accordance with the defect reporting regulations, Part 573.; The Defect Information Report involves: 1600 coaches manufacture during a period dating from January 1, 1972, through December 13, 1973, with Ross HPS71 and HF64 power steering gear boxes. Possibility that the lower steering shaft bearing has failed due to a lack of lubricating and/or the failure to maintain proper alignment with the gear box.; The following National Highway Traffic Safety Administration (NHTSA identification number has been assigned to the campaign *73- 0247*. The first quarterly status report for this campaign is required to be submitted by February 5, 1974.; Please refer to the above number in all future correspondenc concerning this campaign.; In addition, the letter which you have sent to first purchasers doe not meet the requirements of 49 CFR Part 577, 'Defect Notification.' Specifically, it does not evaluate the risk to traffic safety in the manner set forth in section 577.4(d). (If vehicle crash is the potential result of steering loss, as appears likely, your letter should reflect the requirements of 577.4(d)(1).) The letter also fails to conform to section 577.4(e)(3), requiring a statement of the measures to be taken to repair the defect when the manufacturer does not bear the cost of repair. Specifically, it is not clear from the drawing you enclose which parts may have to be replaced. For each part section 577.4(e)(3)(i) required the name, part number, and suggested list price to be included. You are also required to specify the day after which parts will be generally available (section 577.4(e)(3)(iii). If parts are presently available, the letter should so state.; For your information, your December 1973 quarterly report which yo sent this office does not meet the requirements of Part 573 (49 CFR). This regulation requires the submission of quarterly reports not more than 25 working days after the close of each calendar quarter, that is, the end of March, June, September, and December. Also, each report shall contain the total number of manufacturer's vehicles by make, model, and model year produced or imported during the quarter whether or not they are involved in a recall campaign. Therefore, the NHTSA requests that in the future quarterly reports be composed in accordance with Part 573.; Failure to comply with this regulation can result in the imposition o civil penalties and injunctive sanctions.; If you desire further information please contact Messrs. James Murra or Marx Elliott of this office at (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs;