Interpretation ID: nht74-5.4

DATE: 02/19/74

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

TO: White Motor Corporation

COPYEE: J. W. MURRAY; MR. PESKOE; MR. VINSON

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of February 4, regarding the proposed owner defect notification letter for defect notification campaign #73-0140.

Your letter fails to conform to 49 CFR, Part 577 as it states in the second sentence that the defect exists in equipment items manufactured and supplied by Rockwell International Corporation. We do not consider this statement to be responsive to 577.4(b)(1). As White Motor Corporation in the manufacturer of the motor vehicles involved, its determination and the statement required pursuant to 577.4(b)(1) must be to the effect that it has determined that a defect exists in the vehicles you identify in the following sentence.

The wording used by White Motor Corporation in the owner letter for defect notification campaign #73-0242 is an example of a letter which does conform to the regulation.

The National Highway Traffic Safety Administration (NHTSA) is aware that there is a disagreement between White Motor Corporation and Rockwell International as to the exact cause of the defect. The NHTSA does not wish to become a party to this disagreement and in our opinion we cannot allow White Motor Corporation to use the owner notification letter as a forum to air their views.

I trust that you will make the appropriate changes to the owner notification letter and submit a revised copy to this office.