Interpretation ID: nht74-1.33

DATE: 02/20/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Spartan Design Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 21, 1974 asking for our comments on your defect notification letter.

In describing the defect (your third paragraph) as required by Section 577.4(c), you should state specifically that the placement of the lamps fails to conform to Federal Motor Vehicle Safety Standard No. 103, and indicate, in general terms, what is the appropriate location. In addition, section 577.4(c) requires the inclusion of precautions the purchaser can take. We believe one precaution that should be included where a lighting problem is concerned is to recommend that night driving be limited as much as possible.

When we have received a corrected copy, we will close our files in this matter.

Sincerely,

ATTACH.

January 21, 1974

Lawrence R. Schneider -- Chief Counsel, U.S. Department of Transportation, National Highway Traffic Safety Adm.

Ref: #N40-30, (ZTV) CIR618

Dear Mr. Schneider:

Enclosed is a copy of the rewritter letter as you requested. (Illegible Word) read the letter and see if it meets with your approval and let us know so that we may then mail it to all our Converta-Trailer owners.

We are sorry to have caused you any inconvenience and if there is any further information you need please let us know.

Sincerely, SPARTAN DESIGN INC.;

Robert W. Borgert -- Vice President

enclosure

Spartan Design Inc.

Dear Converta-Trailer Owner:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

Spartan Design Inc. has determined that a defect which relates to Motor Vehicle Safety exists in Converta-Trailers manufactured between January 1, 1969 and December 8, 1971. According to our records, you are the owner of a 1971 Converta-Trailer bearing the vehicle serial number on the enclosed reply form which has this defect.

(Illegible Word) defect involves the combination rear lamps which are improperly located. Due to the poor visibility of these lamps, a rear end crash can occur.

To prevent the possibility of a rear end crash to your trailer, please contact Spartan Design Inc., who will remove the lights from back of fenders and reinstall them to the far rear of trailer frame, at no charge to you.

The actual time necessary to perform the labor required to install the rear lamps is approximately 2 hours. It is suggested that you make an appointment in advance so work can be scheduled in an orderly manner.

In the event you no longer own your trailer, or these modifications have been performed already, please complete and mail the enclosed form post-paid, in addressed reply envelope so that we may update our records.

We are sorry to cause you this inconvenience; however, we have taken this action in the interest of your safety and continued satisfaction with our product. Your prompt cooperation will be (Illegible Word).

Your truly, SPARTAN DESIGN INC.