Interpretation ID: aiam1629
Federal Codes and Standards Engineer
Starcraft Company
3010 College Avenue
Goshen
IN 46526;
Dear Mr. Hooley: This is in reference to your defect notification campaign (NHTSA No 74-0170) concerning some camper trailers which may have incorrect inner wheel bearing grease seals installed.; The letter which you have sent to the owners of the subject trailer does not completely meet the requirements of Part 577 (49 CFR), the Defect Notification regulation. Specifically, your letter does not provide an estimate of the day by which dealers will be supplied with parts and instructions for correcting the defect as required by Part 577.4(e)(1). Your statement that the inspection and repair procedure 'should not take very long,' is too vague to qualify as an estimate of the time reasonably necessary to perform the necessary labor as required by Part 577.4 (e)(1). The second sentence of your letter is also incorrect in that where the vehicle manufacturers are concerned, the defect should be described as existing in the vehicle itself rather than a specific part or component of the vehicle.; Since the discrepancies in your notification letter do not appear t discourage owner response in this case, mailing of a revised letter will not be required. It is, however, expected that all future defect notification campaigns will conform completely with the applicable regulations.; Although it may be desirable to issue a service bulletin as soon a possible, we do not believe that justification exists for delaying the submission of a defect report beyond the five working days time limit specified by Part 573 (49 CFR). It is therefore expected that all future reports will be submitted on a timely basis.; Copies of Part 577 and Part 573 of the regulations are enclosed. Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs;