Interpretation ID: aiam1686
Service Manager
Construction Equipment Division
Kyster Company
P. O. Box 289
Kewanee
IL 61443;
Dear Mr. Heinrich: This is in reference to your defect notification campaign (NHTSA No 74-0165) concerning 79 trailers with Standard Forge brake shoes which may be defective.; The letter which you have sent to the purchasers of the subjec vehicles does not contain the precise language which is required by Part 577 (49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter describes the defect as existing in the brake shoe assemblies. Part 577.4(b) requires, however, that vehicle manufacturers describe the defect as existing in the vehicle itself. The reference in Part 577.4(b) to motor vehicle equipment applies only to equipment campaigns where vehicle (sic) are not involved.; Since in our opinion this discrepancy in your notification letter doe not appear to adversely affect the performance of this campaign, mailing of a revised letter will not be required. A copy of Part 577 is enclosed.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs;