Interpretation ID: nht74-4.44

DATE: 01/17/74

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

TO: Gillig Brothers

TITLE: FMVSR INTERPRETATION

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

The Defect Information Report involves: 1600 coaches manufactured during a period dating from January 1, 1972, through December 13, 1973, with Ross HPS71 and HF64 power steering gear boxes. Possibility that the lower steering shaft bearing has failed due to a lack of lubricating and/or the failure to maintain proper alignment with the gear box.

The following National Highway Traffic Safety Administration (NHTSA) identification number has been assigned to the campaign 73.0247. 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 first purchasers does not meet the requirements of 49 CFR Part 577, "Defect Notification." Specificantly, it does not evaluate the risk to traffic safety in the manner set forth in section $ 77.4(d). (If vehicle crash is the potential result of steering (Illegible Word) as appears likely, your letter should reflect the requirements of 577.4(d)(1).) The letter also fails to conform to

2 section 577.4(e)(3), requiring a statement of the measures to be taken to repair the defect when the manufacturer does not bear the cost of repair. Specifically, it is not clear from the drawing you enclose which parts may have to be replaced. For each part section 577.4 (e)(3)(i) required the name, part number, and suggested list price to be included. You are also required to specify the day after which parts will be generally available (section 577.4(e)(3)(iii). If parts are presently available, the letter should so state.

For your information, your December 1973 quarterly report which you sent to this office does not meet the requirements of Part 573 (49 CFR). This regulation requires the submission of quarterly reports not more than 25 working days after the close of each calendar quarter, that is, the end of March, June, September, and December. Also, each report shall contain the total number of manufacturer's vehicles by make, model, and model year produced or imported during the quater whether or not they are involved in a recall campaign. Therefore, the NHTSA requests that in the future quarterly reports be composed in accordance with Part 573.

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 Maxx Eliott of this office at (202) 426-2840.

ENC. PART 577 -- DEFECT NOTIFICATION