Interpretation ID: aiam1746
Designer
FWD Corporation
Clintonville
WI 54929;
Dear Mr. Steenbock: This is in acknowledgment of your Defect Information Report, i accordance with the defect reporting regulations, Part 573.; The Defect Information Report involves: 316 - 1965 through 1973 FWD an Seagrave firetrucks. Possibility that the upper steering arm may crack and in some cases break in the mid-section of the steering arm resulting from excessive stresses due to power steering assist. This information was furnished in your letter of December 18, 1974.; The following National Highway Traffic Safety Administratio identification number has been assigned to the campaign *74-0245*. The first quarterly status report for this campaign is required to be submitted by February 5, 1975. Please refer to the above number in all future correspondence concerning this campaign.; The letter which you have sent to the owners of the subject vehicle does not meet the requirements of Part 577(49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter does not conform to Part 577.4(b) due to inclusion of the word 'may' and because the defect is described as existing in the steering arm rather than the vehicle itself. In cases where a vehicle manufacturer is notifying owners of vehicles, the letter should state that the defect exists in the vehicle itself, even though it may be caused by only one specific part. If the defect is not present in every vehicle, this may be stated in an additional statement.; Your letter also does not evaluate the risk to traffic safety a required by Part 577.4(d). Furthermore, since it appears that the labor cost for performing the corrective action must be born by the owners, Part 577.4(e)(3) should have been followed. It is therefore necessary that an estimate of the labor time necessary for replacing the arm and recommendations as to where the necessary work can be done be given. Your instructions for replacement of the arm are also inadequate since they seem to be limited primarily to the visual inspection and do not outline the actual replacement procedure. It is therefore necessary that you send a revised notification letter to those owners who have not yet had their vehicles corrected. A copy of the revised letter should also be sent to this office.; We also wish to inform you that it is not necessary to submit a copy o every single notification letter that is mailed. When letters are identical, except for the address, only one sample copy need be submitted. The names and addresses of vehicle owners need only be submitted when specifically requested. 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, Director, Office of Defect Investigation, Motor Vehicle Programs;