Interpretation ID: nht73-2.47

DATE: 12/14/73

FROM: AUTHOR UNAVAILABLE; A. G. Detrick; NHTSA

TO: Streamline Division

TITLE: FMVSR INTERPRETATION

TEXT: This is in acknowledgement of your Defect Information Report, in accordance with the defect reporting regulations, Part 573.

The Defect Information Report involves: 41 - 1973 SL, Regency, Imperial, and Crown Imperial Travel Trailors. Possibility that the 3/8" copper tube lines from the gas manifold to all appliances may have a defect thereby causing gas leakage, which may allow for a possible fire hazard.

The following National Highway Traffic Safety Administration identification number has been assigned to the campaign 73-0224. The first quarterly status report for this campaign is required to be submitted by February 5, 1974.

Please refer to the above number in all future correspondence concerning this campaign.

In addition, the letter which you have sent to the first purchasers does not meet the requirements of 49 CFR Part 577 (copy enclosed) in the following respects. It does not contain the specific statements required by sections 577.4(a) and (b)(1). Your reference to a "possible" safety hazard, moreover, is not permitted under paragraph 577.4(b)(1). We do not consider your letter to adequately describe the malfunction, as required by sections 577.4(c)(1) and (c)(2). You do not, for example. Indicate the effect or possible consequence of an "improper flare" on

a gas line. Nor do you state any precautions the owner can take to reduce the likelihood of the malfunction occurring as required by 577.4(c)(4). Your letter fails completely to evaluate the risk to traffic safety as required by section 577.4(d). Finally, we consider your reference to "no reported related failures" to be a disclaimer prohibited by section 577.6.

It is necessary for you to revise this letter as we have indicated and to provide this office and the owners with a copy of the revised letter.

Failure to comply with this regulation can result in the imposition of civil penalties and injunctive sanctions.

If you desire further information, please contact Messrs. James Murray or Marx Elliott of this office (202) 426-2840.

Enc.