Interpretation ID: aiam1690
Jr.
General Manager
Vulcan Trailer Manufacturing Company
P. O. Box 5099
Pratt City Station
Birmingham
AL 35214;
Dear Mr. Davis: This is in acknowledgment of your Defect Information Report, i accordance with the defect reporting regulation, Part 573.; The Defect Information Report involves: 114 trailers equipped wit Standard Forge axles which may have defective brake shoes.; The following National Highway Traffic Safety Administratio identification number has been assigned to the campaign *74-0223*. The first quarterly status report for this campaign is required to be submitted by February 5, 1975. Please refer to the above number in all future correspondence concerning this campaign.; The letter which you have sent to the owners of the subject trailer does not entirely meet the requirements of Part 577(49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter states that the defect exists in a number of axles. In instances, however, where a vehicle manufacturer is conducting a campaign, Part 577.4(b) requires that the defect be described as existing in the vehicle itself. The reference in the regulation to motor vehicle equipment applies only to equipment campaigns where vehicles are not directly involved. Your statement that reduced braking power or lockup may result is not an adequate evaluation of the risk to traffic safety since Part 577.4(d) clearly states that if vehicle crash without prior warning is a potential occurrence the letter must state this. The letter also does not give an estimate of the time reasonably necessary to perform the required labor. Since it appears that the owner must bear the labor cost, this information is especially significant. A date by which parts will be available should also have been given.; It is therefore necessary that you send a revised letter to thos owners whose vehicles have not yet been corrected and who have not yet indicated their intention to do so. A copy should also be sent to this office.; We also wish to point out that the National Traffic and Motor Vehicl Safety Act of 1966 requires that defect notification letters be sent to all known retail purchasers. Notifications to dealers therefore do not satisfy this requirement and need not follow the format of Part 577. It is therefore recommended that dealers either forward to you the addresses of the retail purchasers or mail a notification letter to each purchaser directly. Addresses of owners, however, need not be submitted to this office unless requested.; 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;