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Interpretation ID: aiam1420

Bert W. Rein, Esq., Kirkland, Ellis & Rowe, 1776 K Street, N.W., Washington, DC 20207; Bert W. Rein
Esq.
Kirkland
Ellis & Rowe
1776 K Street
N.W.
Washington
DC 20207;

Dear Mr. Rein: We have reviewed the revised defect notification letters i International Harvester campaigns numbers 73505, 73503, 73511, 73513, G-73520 and G-73521 which you forwarded to us. We believe these revised letters conform to 49 CFR Part 577. However, we believe the letters in campaigns 73505, 73513, and 73521, which involve an accelerator problem, should, in response to the requirements of S 577.4(c)(4), include some guidance as to how the driver can stop the vehicle.; While we find the letters you submit to conform to the requirements, w are of the opinion that, in general, the format you use to describe the defect (577.4(c)) goes little further than meeting the regulation's literal requirements. We suggest you review the letters we have received from other companies in order to obtain an indication of other, more complete approaches to meeting the requirements. While we had indicated that we might furnish you specific letters as examples, we prefer not to recommend any specific letter as a model or to imply that it is preferable to others.; Sincerely, Lawrence R. Schneider, Chief Counsel