ID: nht74-2.38

DATE: 05/09/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Henke Manufacturing Corporation

COPYEE: MR. PESKOE; MR. SHIFFLETT; MR. FAY

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of March 12, 1974, asking several questions regarding the sale of snow plows and related equipment and their installation on vehicles. Your questions are restated below, followed by our responses:

1. Question A: "When we sell a plow, lift frame, lights and brackets to a dealer, do we have to report to you what dealers we sold light kits. Lights meet the code. Yes or no."

No. The sale of lighting equipment to a dealer, without any concurrent installation on a vehicle, does not give rise to any reporting or other requirements.

Question B: "When we receive an order for a snow plow and no light kit is ordered, what is our responsibility in this case: We assume the dealer furnishes his own light kit."

As long as you do not install the plow no requirements apply.

2. "We mount a lift frame for a county or city and they want to mount their own lights. We instruct them that lights are mandatory before they affix the plow. The lift frame only does not affect the present requirement for lights. Are we violating the law and what must we do?"

The addition of a lift frame to a completed vehicle (to which a "readily-attachable" plow will later be added) would make you a vehicle alterer and subject to section 567.7 of the Certification regulations. The alterer label should take into account the weight of a plow. As lights may be considered to be readily attachable, you may deliver the vehicle to the county without the additional lights. The county must install them, however, and you should obtain written assurance that it will do so. If the lights were not installed by the user, you would be responsible for a violation of section 108(a)(1) of the Vehicle Safety Act (15 U.S.C. 1397(a)(1)). Your certification as an alterer would also be invalid, as the altered vehicle would not conform to all applicable standards.

3. "Henke receives a truck with a dump box and no certification label and nothing noted on incomplete registration. We certified the truck and informed the county that they should get the dealer mounting the box to put an addendum to the incomplete vehicle form to the effect that he mounted the box. Is this correct?"

Yes, if in fact the vehicle conforms to applicable standards, and its weight ratings are correct; no, if it does not conform or its weight ratings are not correct. In completing and certifying a vehicle without complete documentation required under Part 568, you run the risk of having no "due care" defense to a finding of nonconformity.

4. "Henke receives a truck that has a final certification. We mount lift frame, (Illegible Word) and front hydraulic power system. The county wants to mount their own lights. Do we have to put on an addendum sticker? We warn them regarding light requirements when plow is mounted."

Section 577.7 of the Certification regulations requires an alterer label when non-readily-attachable components, or any components whose installation modifies the stated weight ratings, are installed. We assume the equipment you mount in this case falls within one if not both of these categories, and an alterer label is therefore required. Your failure to install lights has the same effect here as in our answer to question 2.

5. "We receive a truck with a box capacity when loaded with sand which is more than the GVWR rating and we mount snow plow lift frame and wing. We instruct the customer to mount the plow and wing and add their normal ballast and take the truck to a scale and trim the load not to exceed the axle ratings as stated on the certification label. Our equipment does not overload any axle. Do we have any further liability in regard to the overloading of axles?"

As a vehicle alterer, you are required to recertify the vehicle, and modify its weight ratings if necessary, following the alterations you perform. The gross vehicle weight rating you establish must be based on the vehicle's rated cargo load. Normally, manufacturers are not required to determine what specific loads a vehicle they certify may carry, and are certainly not responsible for overloading by users. However, where the manufacturer (or alterer as the case may be) actually knows that a vehicle he certified is being purchased to carry primarily a particular commodity, the rated cargo load on which he bases his ratings should not be less than what he can reasonably expect the user to consider a "full load" of that commodity. If he knows that a normal full load of sand, for example, to be carried in that truck will weigh 5 tons, we would consider it false and misleading to rate the cargo load at 4 tons to avoid having to use heavier-duty running gear. In the example you describe, the answer would depend on what you (the manufacturer) know, or can reasonably be expected to know, about how the plow trucks are likely to be loaded. A warning to the buyer not to exceed the rated cargo load or the weight ratings, in that case, would not be sufficient if it were reasonable to expect that the vehicles would, in practice, exceed these ratings at normal full load despite the warning.

With respect to your request for a code number, no final requirements have been issued on this matter, and no number is presently required.

ID: nht74-2.39

DATE: 03/18/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Continental Gummu-Werke

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 29, 1974, raising certain questions about the effective date (September 1, 1974) of the Uniform Tire Quality Grading regulation. You pose two hypothetical questions, asking whether tires must be quality graded when they are to be placed on vehicles manufactured or imported after September 1, 1974. In the first situation, the tires are manufactured in July 1974, while the vehicle is manufactured in August 1974 and imported in October 1974. In the second, the tires are manufactured in August 1974; the vehicle is manufactured in September 1974 and imported in November 1974.

The Quality Grading regulation applies to tires rather than vehicles. Its effective date of September 1, 1974, means that all passenger-car tires manufactured on or after that date must be graded in accordance with the regulation. There is no requirement, however, that vehicle manufacturers must use tires manufactured after that date. In each hypothetical question you present, the tires are manufactured before September 1, 1974, and therefore are not required to be graded. The date of manufacture or importation of the vehicle is immaterial.

Yours truly,

ATTACH.

Our Ref.: 61011-Ga-gs

January 29, 1974

Subject: U.T.Q.G. - Docket 25 Notice 7

Gentlemen:

As you know, the tire industry is faced with considerable difficulties in adhering to the date set, i.e. September 1, 1974.

This applies in particular to tires we supply to European vehicle manufacturers whose passenger car production is partly shipped to the United States.

Tires for such vehicles which arrive for instance in the United States in September 1974, have to be manufactured by us already in June. Therefore, your interpretation of paragraph 575.4a, reading as under, is very important for us:

". . . . . . . each section set forth in Support B of this Part applies according to its terms to motorvehicles and tires manufactured after the eff. date indicated, . . . . .".

To clarify matters, please permit us to put up for discussion the following two possibilities: Case Production Date Date of Import No. Tires Car of the Cars into USA 1 July 1974 August 1974 October 1974 2 August 1974 September 1974 November 1974

We would be very much obliged if you would inform us as to whether the tires of the vehicles in the above two cases have also to be provided with the statutory U.T.Q.G. marking.

Looking forward to hearing from you, we remain

Yours very truly, Continental Gummi-Werke Aktiengesellschaft; NEBE; (Illegible Word)

ID: nht74-2.4

DATE: 05/19/74

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Alfa Romeo, Inc.

TITLE: FMVSS INTERPRETATION

ID: nht74-2.40

DATE: 08/05/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Frank Schoen

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of June 19, 1974, inquiring as to what information must be included in a bill of sale upon the transfer of a motorcycle.

The Motor Vehicle Information and Cost Savings Act requires that a written disclosure of a vehicle's recorded mileage be provided by the seller to the purchaser at the time ownership of a vehicle is transferred. If the correct mileage is unknown, the Act requires a statement to that effect to be furnished in written form to the buyer. The disclosure statement need not, however, be included as part of the bill of sale and may be executed to the buyer as a separate document. If Northline Honda failed to comply with this disclosure requirement, a civil remedy in the amount of $ 1,500 or treble damages, whichever is greater, may be available to you under section 409 of the Act, if the violation was committed with the intent to defraud.

Section 403 of the Act makes it unlawful for any person to disconnect, reset, or alter the odometer of a vehicle with the intent to change the number of miles indicated thereon. If Northline Honda violated this section with the intent to defraud, section 409 of the Act would provide you with the same civil remedy as noted above.

One way to determine if such an alteration has occurred is to compare the current mileage with that indicated on the disclosure statement provided to Northline Honda by the motorcycle's prior owner. If Northline has no such document you might attempt to find out who the prior owner was and contact him about the mileage. A mechanic might also check out the motorcycle to see if there is any evidence indicating that the odometer has been tampered with or that the cycle has travelled more miles than the odometer registers.

On the basis of the information you have supplied, I suggest that you contact an attorney about the possibility of bringing an action against Northline Honda. I am enclosing relevant portions of the Act and the odometer disclosure requirements for your use.

If you are in need of any further information, please do not hesitate to let us know.

YOURS TRULY,

June 19, 1974

Dear Sir

I want to see if you can help me no one in Houston, Texas can.

I bought a used bike from Northline Honda which was missented to me and unsafe to ride. I bought it on on May 23, 1974 carried it back May 24, 1974 and told them that it was (Illegible Word) (Illegible Word) and unsafe to ride and wanted them to put the money paid for it on a new bike and that I would pay the difference. Mr. Jim Handcock would not do it, they did a few minor repairs on it and told me to come and get it that afternoon, so I did. I brought it back home rode it around in our yard a little that afternoon and sat on May 26 I carried it to the school yard and a friend was riding it and the handle bar broke into and fliped the bike me got to looking at it and the handle bars were almost into in two places.

I call Northline Honda and told them what happen and they said they couldn't do anything. I wrote to U.S. Department of Transportation in (Illegible Word) Texas, and they sent me a letter saying if I could prove that the odometer reading were incorrect that I could get my money back.

Do you know how I would go about checking on it and who and where do they keep a record of odometer readings.

And do you know anything about Delinquent Transfer penality. They put this one in my name when it should have been in their name.

I am sending you a copy of the bill of sale that they gave me.

So you can see they didn't put the odometer reading or the plate number didn't put the date or sign it.

Mr. Jim Hardcock say's that that is his business and that no one can tell him how to run it.

Is the (Illegible Word) number all that is required on a bill of sale or do you (Illegible Word) to put the motor number on it.

Help me if you can or tell me who I can go to for help.

(Illegible Word) Schoen 8022 Cabat St Houston, Texas 77028

ID: nht74-2.41

DATE: 02/05/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Trailmobile Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of January 21, 1974, you cite the provision of Standard No. 108 under which "the height of the rear clearance lamps is optional if the identification lamps are located at the top of the trailer", and suggest that a similar option be adopted for identification lamps, i.e., that their height location "be made optional if the rear clearance lamps are located as close to the top of the closed van trailer as practical".

Clearance lamps are required by Standard No. 108 to "indicate the overall width of the vehicle . . . as near the top as practicable". The primary purpose of these lamps is to indicate the overall width of the vehicle, and the secondary purpose is to indicate the overall height. Identification lamps on the other hand are a system (three lamps with specified spacing) located "as near the top as practicable". The sole purpose of this system is to identify a vehicle as one of large size. When the widest part of a vehicle is at a point other than the highest point, such as when the fenders are separate or protrude from the body, the option in Standard No. 108 in effect allows the clearance lamps to be mounted at the widest point even though it would be practicable to mount them higher, as long as the identification lamps are mounted at the top of the vehicle, thus fulfilling the secondary function of the clearance lamps. Since the identification lamps are a system serving only the one function of identification, the clearance lamps cannot act as substitutes and the system must be mounted at the point of maximum visibility ("as close as practicable to the top of the vehicle"). To adopt your suggestion would allow a manufacturer to mount the system at the bottom of a vehicle even if it is practicable to mount them at the top, thus substantially negating the identification function the system serves. For this reason we cannot adopt the option you suggest.

Yours truly,

ATTACH.

TRAILMOBILE TECHNICAL CENTER

January 21, 1974

Richard B. Dyson, -- Assistant Chief Counsel, U.S. DEPARTMENT OF TRANSPORTATION, National Highway Traffic Safety Administration

Dear Mr. Dyson:

Thank you for your ruling on the rear identification lamps in a trailer shallow header (N40-302TV).

Although the ruling was not what we had hoped for, it did however contain the nucellus of a solution to the problem that would satisfy everyone concerned.

Today, the height of the rear clearance lamps is optional if the identification lamps are located at the top of the trailer. Obviously, the intent is to have the top of the rear of a van trailer marked by lights (but not necessarily by all of the required lamps).

To solve some of the problems that we manufacturers face, I request that the height location of the rear identification lamps be made optional if the rear clearance lamps are located as close to the top of the closed van trailer as practical.

I believe that this request is consistant with the intent of MVSS #108 and, in fact, is consistant with the requirements for open top, grain, and dump trailers.

Your prompt consideration and reply will be greatly appreciated.

Very truly yours,

Evan Hammond -- Manager - Central Engineering

cc: E. E. Lungren; R. J. Deller; J. E. Cook

ID: nht74-2.42

DATE: 08/07/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Royal Industries

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 23, 1974, question concerning the certification responsibility of a small manufacturer of trailers that must conform to Standard No. 121, Air brake systems. You ask if road testing of any or all vehicles produced would be necessary to satisfy the requirements.

A manufacturer must "exercise due care" in certifying that the vehicles manufactured by him comply with the applicable standards (National Traffic and Motor Vehicle Safety Act of 1966, @ 108(b)(2), 15 U.S.C. @ 1392(b)(2)). What constitutes due care in a particular case depends on all relevant facts, including such things as the time to elapse before a new effective date, the availability of test equipment to small manufacturers, the limitations of current technology, and above all the diligence evidenced by the manufacturer.

A small manufacturer of standard and custom trailers might fulfill his due care responsibility to assure that each of his trailers is capable of meeting the standard in several ways. For example, he could establish categories of models which share a common brake and axle system and certify them all on the basis of tests on the most adverse configuration in the category. Calculations should be written down in such a case to establish that reasonable care was taken in these decisions.

Alternatively, joint testing might be undertaken with a trade association or with a major supplier of brake and axle components. In the case of standard models, you might be able to rely on the supplier's warranty of his products' capacities.

Neither of these methods would require road testing of each vehicle manufactured, nor would every model have to be road tested. A manufacturer must simply satisfy himself that the trailer is capable of meeting the stopping performance requirements if it were tested by the NHTSA.

Yours truly,

ATTACH.

PEERLESS DIVISION ROYAL INDUSTRIES

July 23, 1974

Chief Council -- National Highway Safety Administration

Dear Sir:

This concerns a recent telephone conversation between Loretta Carlson of the National Highway Safety Administration in Seattle and myself.

As a custom trailer manufacturer, we seldom manufacture any number of trailers of the axact same model. While we may build saveral trailers a year to perform the same job, there could be sufficient change from order to order that could conceivably classify them as different models.

My question of her was whether or not we, as a custom commercial trailer manufacturer, would be required to road test all models of trailers that we build to meet the requirements of FMVSS121.

Loretta Carlson talked to your office and relayed your answer to me in that for a manufacturer to satisfy the requirements of FMVSS121, he has to exercise due care to certify his equipment as meeting the requirements of FMVSS121.

Also, your office felt that if we road tested a trailer that we felt would be the worst configuration to meet the requirements of FMVSS121, then we could be considered as exercising due care.

I am very grateful for the assistance of Loretta Carlson and would greatly appreciate a letter from your office confirming your conversation with her on this matter.

C. J. Baker -- Research & Development Engineer

ID: nht74-2.43

DATE: 05/24/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Dorsey Trailers

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 3, 1974, question concerning the certification responsibility of a manufacturer of trailers that must conform to Standard No. 121, Air brake systems. You ask if the substitution of parts not specified by an axle manufacturer will affect certification if the parts are nearly identical in their specifications and performance to the recommended parts.

In the case of substitution of parts, you must simply satisfy yourself that your vehicles are capable of meeting the requirements of the standard in a test by the NHTSA. If you are satisfied that the supplier's recommended package will meet the requirements, and you determine that a substitution would not adversely affect the vehicle's performance to the point where it no longer would meet the requirements, you are free to make the substitution. It would be advisable to make some record of your calculations of the effect of such substitutions.

Yours truly,

ATTACH.

May 3, 1974

James B. Gregory, Administrator -- National Highway Traffic Safety Administration

Dear Sir:

Dorsey Trailers, Inc. has selected Wagner Electric Corporation and The Berg Manufacturing Company to supply the air actuation and anti-skid equipment for all trailers manufactured by this company. Other companies have been reviewed as suppliers on special customer request but our Engineering and Production techniques are only developed for the above two suppliers at this time. Both of the suppliers have assured us of adequate inventory of the required material to start shipping trailers by September 1, 1974 with the F.M.V.S.S. 121 specifications.

The two major axle suppliers which we use, Kershaw Axle Division of C. & M. Spring Company and Standard Forg and Axle Company, have both promised axles with brakes to meet the 121 specifications by September 1, 1974.

The problem that concerns us is the dynamometer brake rating. We have just been given a new interpretation of the requirements for the dynamometer rating, stating that if any portion of the combinations of components such as air chambers, slack adjusters, brake drums, etc. is changed from the exact specified part number and brand name used in certifying an axle with a given brake lining, the certification is voided and not acceptable. If this is true, then there does not seem to be enough dynamometer time available to meet a deadline even by January 1, 1975 for all combinations of parts available to the trailer industry.

As a smaller manufacturer of trailers we do not enjoy the luxury of telling our customers that certain parts are our standard materials and we won't furnish other components. Our customers usually have their own part specifications to simplify their maintenance.

If we had an axle certified with B-W slack adjusters, 6" long and B-W type 30 spring brake chambers, but our customer specified his axles must have Berg 6" slack adjusters and Berg Type 30 spring brake chambers, would this affect the certified axle? The substitution would be of equal parts and performance but different brand names.

Another example would be an axle certified with a Webb #66518 drum weighing 96 pounds and the customer specifying a Webb #67518 drum which weighs 106 pounds. The addition of the 10 pounds of weight would increase the fade-away characteristics by better heat dissipation but would this change require another dynamometer test?

Some customers specify cast brake shoes while others prefer fabricated brake shoes. With all other components being the same, would the change in brake shoes require a new certification?

If our suppliers meet their commitments, we could offer certain of our options to meet "121" specs on September 1, 1974. To certify all of the options that we are required to furnish, there could possibly not be enough dynamometer time available by January 1, 1975. Please give us an interpretation on varying the components and how this would effect the certifications.

Due to material shortages, the privilege of switching suppliers of certain assemblies is almost prohibitive since allocation of material is very common. This problem will only multiply the above problem of dynamometer testing time. If your regular supplier does not have his own dynamometer, it will be very difficult to secure time on an independent test machine and impossible to get the service of your competitors' equipment.

Yours very truly,

DORSEY TRAILERS; Roy C. Belcer - Vice President -- Manufacturing and Engineering

CC: G. L. Collier

ID: nht74-2.44

DATE: 05/11/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Adams & Westlake Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 13, 1974, asking whether S5.3.2 of Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release," permits the use of more than one release mechanism on any one opening if each mechanism requires a separate motion to release.

Standard No. 217 does not prohibit the use of more than one separate release mechanism for a single opening. However, S5.3.2 does limit to two the number of total force applications, and this limits the number of separate release mechanisms to two. If two release mechanisms are used, each must be operated by only one force application, and one of these force applications must differ by 90 degrees to 180 degrees from the direction of the initial push-out motion of the emergency exit.

Of course, in using this configuration, the other requirements pertaining to emergency exists and release mechanisms in Standard No. 217 must also be met.

YOURS TRULY,

March 13, 1974

Office of Chief Consul National Highway Traffic Safety Administration

Attention: Mr. Larry Schneider

In regards to Motor Vehicle Safety Standard #217, "Bus Window Retention & Release", please refer to S5.3.2 which states:

"The release mechanism or mechanisms shall require for release one or two force applications."

Is this to be interpreted that more than one mechanism, each requiring a separate motion to release, can be used on any one opening?

This question is prompted by reason of a car body structural member, at center line of rear window opening, which makes a single mechanism unsuitable.

Your earliest reply will be appreciated.

Earl V. Gordon -- Manager of Engineering, THE ADAMS & WESTLAKE CO.

cc: H. C. Gildner, Vice-President, Transportation Sales; C. M. Miller, Vice-President, Engineering

ID: nht74-2.46

DATE: 12/04/74

FROM: AUTHOR UNAVAILABLE; Andrew G. Detrick; NHTSA

TO: Matlock Truck Body and Trailer Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reference to your defect notification campaign (NHTSA No. 74-0203) concerning trailers equipped with Standard Forge axles which may have defective brake shoes.

The letter which you have sent to the owners of the subject trailers does not completely meet the requirements of Part 577 (49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter describes the defect as existing in the brake shoes. Part 577.4(b), however, requires that in cases where a vehicle manufacturer is notifying owners of vehicles, the letter must state that a defect exists in the vehicle itself. The reference to motor vehicle equipment applies only to equipment campaigns where vehicles are not directly involved. Your letter also fails to adequately evaluate the risk to traffic safety as required by Part 577.4(d) since it does not state that the vehicle crash without warning may occur. Although the statement that reduced braking power or lockup may result may suggest the possibility of a crash to many owners, it is not entirely adequate.

Although mailing of a revised notification letter will not be required, it is expected that in the event that another defect notification campaign ever becomes necessary in the future, the notification letters conform completely with the regulations.

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 Defects Investigation Motor Vehicle Programs

Enclosure

ATTACH.

MATLOCK TRUCK BODY & TRAILER CORP.

February 11, 1975

Wolfgang Reinhart -- Office of Defects Investigation Motor Vehicle Programs, U.S. Department of Transportation, National Highway Traffic Safety Administration

RE: N41-62 re

Dear Mr. Reinhart: I received Mr. Andrew G. Detrick's letter of December the 4th, 1974 in regard to our defect notification campaign (#74-0203). He stated that my letter did not completely meet the requirements of Part 577 (49 CFR) in two specific items. I am returning a copy of his letter with the two points in question underlined in red and marked 1 and 2. Also, I am enclosing a copy of my letter of defect notification with the "answers" underlined in red and marked 1 and 2.

Please note that in the point marked 1 that my letter states that the defect exist in the brake shoes on Matlock MTE (electronic trailers).

In the second point, perhaps we were not specific enough about the possibility of a crash, but we were only quoting the statement in Standard Forge's letter to us.

We sent all the information to Standard Forge concerning the recall after receiving a letter from Mr. Detrick on January the 6th, 1975. In accordance with his letter, we will not submit the quarterly reports. A copy of the letter to Standard Forge is also enclosed.

Yours truly,

Curtis Eddy Vice President - Engineering

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

Matlock Truck Body and Trailer Corporation has determined that a defect which relates to motor vehicle safety exists in the brake shoes of Standard Forge axles with 12 1/4" x 7 1/2" brakes on Matlock Model MTE (electronic trailers). These axles are used only with 15" wheels and on trailers produced between February 1, 1974 and October 31, 1974.

Standard Forge and Axle Company, one of the world's largest manufacturers of trailer axles, made a change in the brake shoe attachment on some of the axles made for highway trailers early in 1974. After several months of operation, some of these axles have caused brake problems.

Standard Forge has been very prompt in their actions to correct any problems of approximately 5000 axles that are involved. Matlock received only 438 of these axles or about 9%. The other 91% have gone to others, including most of the leading trailer manufacturers.

The axles concerned are only those with 15" wheels with 12 1/4" x 5 1/4" or 12 1/4" x 7 1/2" brakes. Matlock uses only the heavier 12 1/4" x 7 1/2" brakes. If you have a trailer other than a Matlock, as a safety precaution, you might check the brakes yourself or contact your trailer supplier.

Approximately 200 of the 438 axles supplied to Matlock have been corrected already, or are in our plant and will be corrected prior to shipment of new trailers.

For your information, a copy of the letter from Standard Forge alerting trailer companies of a possible problem is enclosed.

The second paragraph of Standard Forge's letter explains the condition that might cause the malfunction and the result of such an occurance. Note that breakage can occur without warning, resulting in reduced braking power or lockup.

We instruct you to remove from service immediately any trailer that has an axle in the list that follows until the brake shoes can be replaced.

Also enclosed is a drawing showing both the correct and incorrect brake shoes. The casting number on the brake shoe will be 201103 on both the correct and incorrect brake shoe. However, the two can be easily distinguished by the shape of the end of the brake shoe. The ones that should be replaced have had the ends milled off; the replacement, or newer parts, have a closed end.

Matlock is attempting to do everything possible to minimize any inconvenience to you. Your cooperation will be appreciated. Please follow the procedure as outlined below:

1. Check the serial number on each axle used with 15" wheels. The serial number is located in the center of the axle on the name tag. If it is a Standard Forge axle and has one of the serial numbers in this list, the brake shoes should be checked and changed if they are the incorrect brake shoes. Some of the axles in this list, however, have already had the brake shoes replaced. If the brake shoes are the correct type on one end of the axle, it will not be necessary to pull the drums on the other end. We will allow one and one-half (1 1/2) hours labor per axle for checking only. In order to be reimbursed for this labor, you MUST send us the trailer serial number and the axle serial number. Be sure that the axle serial number is contained in this list, as we will not pay for labor for axles not contained in this list. 14074 thru 14083 33207 thru 33242 20199 " 20212 34011 " 34035 20213 " 20226 34036 " 34060 24535 " 24634 34111 " 34210 25128 " 25137 36406 " 36465 25348 " 25357 42395 " 42494 27572 " 27589 46360 " 46365

NOTE: If you have a Matlock trailer with 15" wheels, and you cannot read the serial number on the axle, pull the brake drum on one side of each axle to be sure that you do have brake shoes that are the correct type.

2. You may bring your trailer to our plant in Nashville or to our branch in Knoxville for the required rework. You may do the work in your own shop, or you may take it to any reputable trailer repair shop such as, but not limited to, Dorsey, Fruehauf, Great Dane, Lufkin, Nabors, Strick, Timpte, Trailmobile, or Utility. If you have any question as to where you should take your trailer for repair, you may call Mr. Jim Waters of Standard Forge and Axle Company, in Montgomery, Alabama, (205) - 269-1271.

3. The replacement parts are available now and should be ordered from Matlock Truck Body and Trailer Corporation, 1070 Visco Drive, Nashville, Tennessee 37210 - (615) - 259-2000.

The replacement parts will be shipped and invoiced to you at regular parts prices. We will allow up to five (5) hours labor per axle to replace these parts, although we believe that four (4) hours will be sufficient in most cases. Oil seats will be furnished and must be replaced.

You will be given full credit for parts, labor and freight both ways when the parts that are replaced are returned to us in Nashville, freight prepaid. The parts should be returned to the above address and marked to the attention of Mr. Tom Hartigan.

IMPORTANT: All parts returned MUST have the trailer serial number and the axle serial number on the shipping crate and on your invoice to us.

If you have sold or otherwise disposed of a trailer that was built between February 1, 1974 and October 31, 1974, please send us the name and address of the buyer or the disposition of the trailer.

We want to tell you that when you deal with Matlock, you are dealing with a reliable supplier that wants to correct this safety defect. We appreciate your business and would like to take this opportunity to solicit your order for the coming year for your trailer and truck body needs.

Yours truly,

Curtis Eddy Vice President - Engineering

ID: nht74-2.47

DATE: 08/27/74

FROM: Frank Berndt; NHTSA

TO: Armstrong Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT: This will confirm that the suggested defect notification letter, enclosed in your letter of August 14, 1974, meets the requirements of 49 CFR Part 577.

We appreciate your taking this action with respect to the Steel Belted Surveyor 78 tire.