Interpretation 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