13E-061 (30 pages) - Amended 49 CFR Part 573 Noncompliance Information Report for Original Equipment Report Date: November 19, 2013 On November 1, 2013 Indiana Mills and Manufacturing Inc. (“IMMI”) determined that a potential noncompliance with Federal Motor Vehicle Safety Standard (FMVSS) 209 exists in certain seat belt assemblies that are equipped with L9 seat belt buckles. These seat belt assemblies were sold to numerous customers as items of original equipment. IMMI is furnishing this notification to the National Highway Traffic Safety Administration in accordance with 49 CFR Part 573, Defect and Noncompliance Responsibility and Reports. IMMI’s investigation is ongoing. 1. Manufacturer: Indiana Mills and Manufacturing Inc. 18881 US 31 North Westfield, IN 46074 Contact Person: Lisa Hanson Director of Corporate Quality Phone: 317‐867‐8451 Fax: 317‐896‐2142 IMMI Page | 1 13E-061 (30 pages) - Amended 2. Identification of Motor Vehicle Equipment Potentially Containing the Noncompliance Certain IMMI seat belt assemblies that are equipped with L9 end‐release seat belt buckles are potentially noncompliant with S4.3(g) of FMVSS 209. The suspect L9 buckles were produced at IMMI manufacturing facilities in Westfield, IN between August 2, 2013 and September 13, 2013, and in Saltillo, Mexico between August 8, 2013 and September 13, 2013. Seat belt assemblies, incorporating the suspect L9 buckles, were manufactured between August 2, 2013 and October 25, 2013 at IMMI’s Westfield, IN manufacturing facility and between August 8, 2013 and October 31, 2013 at IMMI’s Saltillo, Mexico facility. Basis for determining the recall population and description of how the equipment differs from similar equipment not included in the population The component of the seat belt assemblies that caused them to be noncompliant is the locking pawl (part number 916030) inside the L9 buckle. The suspect L9 buckles contain locking pawls from specific manufacturing lots. Some of the locking pawls from those lots were produced with an excessively large burr on the locking surface. The locking pawls were manufactured in the United States. The company that manufactured the locking pawls is: Mursix Corporation 2401 N Executive Park Drive Yorktown, IN 47396 (765) 282‐2221 The name, address and telephone number of each customer that purchased the suspect seat belt assemblies for use or installation as original equipment in new motor vehicles or new items of motor vehicle equipment is attached as Appendix A. Appendix A also shows the IMMI part numbers of the seat belt assemblies sold to each customer. 3. Total Number of Potentially Noncompliant Items of Equipment The total number of potentially noncompliant seat belt assemblies that are subject to FMVSS 209 is approximately 74,000. The number of such assemblies shipped to each customer is shown on the list in Appendix A. However, IMMI has been informed that some of those customers have replaced the suspect L9 buckles in assemblies in their inventories and in their vehicles before those vehicles were delivered to dealers or customers. As of the date of this report (revision 1), IMMI estimates that approximately 6,700 potentially noncompliant L9 buckles have been captured and replaced before vehicles were sold to purchasers. 4. Percentage of Items of Equipment Estimated to Contain the Noncompliance Approximately 1%. IMMI Page | 2 13E-061 (30 pages) - Amended 5. Description of the Noncompliance Certain IMMI seat belt assemblies equipped with L9 buckles do not satisfy the requirements of S4.3 (g) of FMVSS 209. When the push button on the buckle is pressed to release the latch plate for egress, the latch plate can become partially engaged with the buckle. Under this circumstance, the partially engaged latch plate may not separate from the buckle when a force of 22N is applied. The root cause of the noncompliance is associated with the locking pawl (part number 916030) inside the L9 buckle. Some locking pawls from specific manufacturing lots were produced with an excessively large burr. The burr on the locking pawl can catch the edge of the latch plate when the button is pressed to unlatch the buckle, causing a partial engagement condition. 7. Information Considered by IMMI in Deciding That a Noncompliance Exists On October 15, 2013, IMMI received a complaint from a vehicle manufacturer indicating that inspectors in its assembly plant had encountered difficulty in releasing some seat belt assemblies equipped with L9 buckles. On October 16, 2013, IMMI personnel traveled to the customer’s assembly plant to investigate the situation. The suspect seat belt assemblies were brought to IMMI for evaluation. On October 17, 2013, IMMI personnel traveled to another vehicle assembly plant to investigate a similar complaint. Suspect seat belt assemblies from that plant were also brought to IMMI for evaluation. Beginning on October 16, 2013, IMMI Quality Assurance and Engineering personnel tested and measured the returned buckles as well as other buckles on‐hand. The results of those tests indicated that each returned buckle latched completely when the latch plate was inserted. When the push button on the buckle is pressed to release the latch while the latch plate has some lateral force applied to it, the latch plate can become partially engaged with the buckle. To better assess the issue, IMMI developed a new test fixture to apply lateral forces to the latch plate during the evaluation of partial engagement. IMMI found that some of the returned L9 buckles could be placed into a partial engagement condition using this test fixture, and that the latch plate would not separate when a 22N force was applied. On the basis of its investigation and testing, on November 1, 2013, IMMI determined that a noncompliance with Federal Motor Vehicle Safety Standard 209 exists in some of the seat belt assemblies identified in Section 2 above. IMMI has received no report of accidents or injuries associated with this noncompliance. IMMI Page | 3 13E-061 (30 pages) - Amended 8. Remedy Program IMMI has notified all customers that received the suspect seat belt assemblies of this noncompliance decision and IMMI will work with those customers to provide replacement buckles for all vehicles that were sold with the potentially noncompliant seat belt assemblies. Document Revision History Revision Date Description 0 11/8/2013 Initial Submission 1 11/19/2013 Section 3: Updated quantities based on new information Appendix A: Updated list based on new information IMMI Page | 4 13E-061 (30 pages) - Amended IMMI 49 CFR Part 573 Noncompliance Information Report for Original Equipment Appendix A ‐ Revision 1 Ship To State/ Ship to Ship To HQ Phone Customer Name Ship To Address1 Ship To City Province Postal Code Country Number IMMI P/N Qty ALLIANCE BUS GROUP, INC. 21537 E. QUINCY AVE AURORA CO 80013 US 770-305-0060 F118301 1 ALLIANCE BUS GROUP, INC. 5845 LEES MILL ROAD FOREST PARK GA 30297 US 770-305-0060 F118301 22 ALLIANCE BUS GROUP, INC. Total 23 AMERICAN MIDWEST FLEET SOLUTIONS 1105 E 31 ST LA GRANGE PARK IL 60526 US 816-697-1927 F111703 1 AMERICAN MIDWEST FLEET SOLUTIONS Total 1 AMERICAN SEATING 25800 CLAWITER ROAD HAYWARD CA 94545 US 616-732-6600 F114900 1 AMERICAN SEATING 801 SEWARD, NW GRAND RAPIDS MI 49504 US 616-732-6600 F105595 18 AMERICAN SEATING 801 SEWARD, NW GRAND RAPIDS MI 49504 US 616-732-6600 F114878 13 AMERICAN SEATING 801 SEWARD, NW GRAND RAPIDS MI 49504 US 616-732-6600 F114883 2 AMERICAN SEATING 801 SEWARD, NW GRAND RAPIDS MI 49504 US 616-732-6600 F114900 5 AMERICAN SEATING 801 SEWARD, NW GRAND RAPIDS MI 49504 US 616-732-6600 F114901 8 AMERICAN SEATING 801 SEWARD, NW GRAND RAPIDS MI 49504 US 616-732-6600 F116146 1 AMERICAN SEATING 801 SEWARD, NW GRAND RAPIDS MI 49504 US 616-732-6600 F116174 1 AMERICAN SEATING 801 SEWARD, NW GRAND RAPIDS MI 49504 US 616-732-6600 F123305 1 AMERICAN SEATING Total 50 AUTOBUS LION, INC. 921 CH DE LA RIVIERE-DU-NORD ST-JEROME QUEBEC J7Y 5G2 CA 450-432-5466 F114852 20 AUTOBUS LION, INC. Total 20 AUTOCAR, LLC 551 SOUTH WASHINGTON ST HAGERSTOWN IN 47346 US 765-489-5499 F115640 12 AUTOCAR, LLC Total 12 BLUE BIRD BODY CO 2338 US ST. RTE. 42 DELAWARE OH 43015 US 478-825-2021 F111224 5 BLUE BIRD BODY CO 2338 US ST. RTE. 42 DELAWARE OH 43015 US 478-825-2021 F111225 6 BLUE BIRD BODY CO 2338 US ST. RTE. 42 DELAWARE OH 43015 US 478-825-2021 F111226 1 BLUE BIRD BODY CO 2338 US ST. RTE. 42 DELAWARE OH 43015 US 478-825-2021 F111228 12 BLUE BIRD BODY CO 402 BLUE BIRD BLVD FORT VALLEY GA 31030 US 478-825-2021 F103687 1 BLUE BIRD BODY CO 402 BLUE BIRD BLVD FORT VALLEY GA 31030 US 478-825-2021 F111224 350 BLUE BIRD BODY CO 402 BLUE BIRD BLVD FORT VALLEY GA 31030 US 478-825-2021 F111225 99 BLUE BIRD BODY CO 402 BLUE BIRD BLVD FORT VALLEY GA 31030 US 478-825-2021 F111226 103 BLUE BIRD BODY CO 402 BLUE BIRD BLVD FORT VALLEY GA 31030 US 478-825-2021 F111228 80 BLUE BIRD BODY CO 402 BLUE BIRD BLVD FORT VALLEY GA 31030 US 478-825-2021 F111230 26 BLUE BIRD BODY CO 402 BLUE BIRD BLVD FORT VALLEY GA 31030 US 478-825-2021 F111232 12 BLUE BIRD BODY CO Total 695 BUS WEST 3235 UNION AVE. SAN JOSE CA 95124 US 310-984-3900 F118035 2 BUS WEST Total 2 COLLINS BUS CORP (SG MAIN) 1065 BELVOIR ROAD PLYMOUTH MEETINGPA 19462 US 620-662-9000 F115177 90 Page 1 13E-061 (30 pages) - Amended IMMI 49 CFR Part 573 Noncompliance Information Report for Original Equipment Appendix A ‐ Revision 1 Ship To State/ Ship to Ship To HQ Phone Customer Name Ship To Address1 Ship To City Province Postal Code Country Number IMMI P/N Qty COLLINS BUS CORP (SG MAIN) 1065 BELVOIR