Passenger Seat Frames May Crack – 2014-22 Thomas Built Buses HDX & EFX School Buses

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Defect / Noncompliance Information Report (Section 573.6) FL946 Date of Submission: 8/11/2022 Manufacturer: Daimler Truck North America LLC P.O. BOX 3849 Portland, Oregon 97208 Type of Report: X Safety Defect ⃝ Non-Compliance Vehicle Information Model Yr. Start: 2014 Model Yr. End: 2022 Make: Thomas Built Buses Model: HDX and EFX Production Dates: Begin: 5/24/2013 End: 10/22/2021 Descriptive Information: The subject population includes approximately 1,808 Model Year 2014-2022 Thomas Built Bus (“TBB”) HDX and EFX school bus vehicles produced within the above-specified production date range in the United States. Basis for Determination of the Recall Population: Under certain extreme operating conditions, that may include adverse road conditions, a metal fatigue-related cracking may develop on 39 inch S3C seat frames with a 3-point flex belt seat rear wall mount bracket. Over time, if the condition manifests itself, the crack may propagate and lead to fracturing of the wall mount bracket. Number potentially involved: 1,808 Estimated percentage of involved with defect: 4% Defect / Noncompliance Description For this Defect/Noncompliance: Describe the defect or noncompliance: The subject vehicles are equipped with specific passenger seats that may experience abnormal structural fatigue that may impact seat strength during a crash. Root cause has not yet been determined. Describe the safety risk: Fatigue of the seats frame structure could result in frame cracking, thus causing the seat to shift and rotate. The seat may therefore not provide adequate restraint to a belted passenger, which may increase the risk of injury to vehicle occupants in a crash. Description of the Cause: TBB continues to investigate root cause. Identify any warning which can precede or occur: A fractured seat frame mounting bracket may be noticed during daily walk through, cleaning, bus inspections and routine maintenance. If applicable, identify the manufacture of the defective or noncompliant component.: Involved Components Component Name: Passenger Seat Frame Component Description: Seat Lower Frame Component Part Number: 30628, 30630 NOTE: If a Component that contains the defect or noncompliance was manufactured by a different manufacturer from the reporting manufacturer, list the following: Component’s country of origin: Business address: Business telephone number: Chronology of Defect / Noncompliance Determination Provide the chronology of events leading up to the defect decision or test data for the noncompliance decision: In or about mid-2017, DTNA’s seat supplier informed DTNA of a fractured S3C seat frame. DTNA reviewed the matter, concluded it did not present a safety-related concern, and documented the matter. In or about September 2018, DTNA received several reports of fractured seat frames from one specific customer location. Thereafter, DTNA began an investigation, which included field inspections, engineering laboratory evaluations and field tests. Upon review, DTNA concluded that the matter did not present a safety-related concern, and again documented the matter but also monitored the situation. During this period of monitoring, in or about late 2019, DTNA concluded that the issue, if it manifested, was limited to very small numbers of seats concentrated in a specific geographic location. A root cause such as uniquely severe road use/environmental use cases was conjectured but not fully understood, given the limited information available. That said, DTNA again reaffirmed its prior analysis that the matter did not present an unreasonable risk to safety within the meaning of the Safety Act. March 08, 2022, DTNA received a report from a customer with buses containing cracked seat wall mount brackets. DTNA began an extensive investigation to reassess its prior analysis. Among other things, TBB conducted an on-site customer visit to assess the alleged condition, inspect available field units, and analyze the resultant fleet inspection information. On March 28, 2022, DTNA completed a review of warranty claims and found no claims on vehicles affected by this recall. In April 2022, DTNA analyzed its preliminary investigation findings and based on engineering judgement initiated additional evaluations including further field data assessment studies to understand why the issue appeared to arise in only certain geographic areas, with certain fleets and with vehicles that may have been subjected to more severe road use/environmental use cases. In May 2022 through late June 2022, DTNA re-investigated the additional information collected from a broader field survey and determined that 8 seats were observed from of a population of 13,037 vehicles where the rear wall mount bracket were fractured. Further data searches indicated claims for replaced seat frame mounts. No reports of any injuries or fatalities could be identified related to this defect. On July 12 2022, DTNA determined that a safety-related defect exists in HDX and EFX Thomas Built Buses equipped with 39-inch S3C seat frames and with 3-point flex seatbelts. The seat frames and seatbelts otherwise conform to all applicable Federal Motor Vehicle Safety Standards. In early August 2022, while continuing to investigate this issue, DTNA discovered an accounting error whereby some potential vehicle groups were counted multiple times, resulting in an inflated suspect population. The suspect population has been corrected with this filing. Identify the Remedy Describe the defect/noncompliance remedy program, including the manufacture’s plan for reimbursement. DTNA does not have a remedy identified at this time. DTNA will provide the appropriate information as soon as it is available. Identify the Recall Schedule Describe the recall schedule for notifications.: Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Begin Date: 9/16/2022 Planned Dealer Notification End Date: 9/16/2022 Planned Owner Notification Begin Date: 9/16/2022 Planned Owner Notification End Date: 9/16/2022 Does DTNA plan to file inconsequentiality petition? ⃝ Yes X No Manufacturer’s identification code for this recall (if applicable): FL946 DTNA Representative; Sam Canupp Manager, Compliance and Regulatory Affairs
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Defect / Noncompliance Information Report (Section 573.6) FL946 Date of Submission: ____7/19/2022____________ Manufacturer: Daimler Truck North America LLC P.O. BOX 3849 Portland, Oregon 97208 Type of Report: X Safety Defect ⃝ Non-Compliance Vehicle Information Model Yr. Start: __2014________ Model Yr. End: ___2022_______ Make: __Thomas Built Buses___ Model: _HDX and EFX_____________ Production Dates: Begin: _5/24/2013___ End: _10/22/2021_ Descriptive Information: The subject population includes approximately 4,242 Model Year 2014-2022 Thomas Built Bus (“TBB”) HDX and EFX vehicles produced within the above-specified production date range in the United States. Basis for Determination of the Recall Population: _ Under certain extreme operating conditions, that may include adverse road conditions, a metal fatigue-related cracking may develop on 39 inch S3C seat frames with a 3-point flex belt seat rear wall mount bracket. Over time, if the condition manifests itself, the crack may propagate and lead to fracturing of the wall mount bracket. _________________________________________________________________________________________________________________________________________________________________________ Number potentially involved: ___4344_____ Estimated percentage of involved with defect: _1%_______ Defect / Noncompliance Description For this Defect/Noncompliance: Describe the defect or noncompliance: The subject vehicles are equipped with specific passenger seats that may experience abnormal structural fatigue that may impact seat strength during a crash. Root cause has not yet been determined._ _________________________________________________________________________________________________________________________________________________________________________ Describe the safety risk: Fatigue of the seats frame structure could result in frame cracking, thus causing the seat to shift and rotate. The seat may therefore not provide adequate restraint to a belted passenger, which may increase the risk of injury to vehicle occupants in a crash._ _____________________________________________________________________________________ Description of the Cause: TBB continues to investigate root cause. ____________________________________________________________________________________ Identify any warning which can precede or occur: _ A fractured seat frame mounting bracket may be noticed during daily walk through, cleaning, bus inspections and routine maintenance. _______________________________________________________________________________________________________________________________________________________________ If applicable, identify the manufacture of the defective or noncompliant component.: __________________________________________________________________________________________________________________________________________________________________________ Involved Components Component Name: ____Passenger Seat Frame_____________ Component Description: __Seat Lower Frame____________ Component Part Number: _____30628, 30630__________ NOTE: If a Component that contains the defect or noncompliance was manufactured by a different manufacturer from the reporting manufacturer, list the following: Component’s country of origin: _____US_____________ Business address: _ Thomas Built Buses, Inc., 1408 Courtesy Road, High Point, NC 27260___ Business telephone number: __ 336 889 4871________________ If the reporting manufacturer does not know the identity of the manufacturer of the component, it shall identify the entity from which it was obtained. If at the time of submission of the initial report, the reporting manufacturer does not know the country of origin of the component, the manufacturer shall ascertain the country of origin and submit a supplemental report with that information once it becomes available. Chronology of Defect / Noncompliance Determination Provide the chronology of events leading up to the defect decision or test data for the noncompliance decision: In or about mid-2017, DTNA’s seat supplier informed DTNA of a fractured S3C seat frame. DTNA reviewed the matter, concluded it did not present a safety-related concern, and documented the matter. Beginning in or about September 2018, DTNA received several reports of fractured from one customer location and as part of a newly formed process briefed NHTSA on the topic. Thereafter, DTNA began an investigation, which included field inspection and engineering laboratory and field tests. Upon reoccurring review with NHTSA, DTNA concluded that the matter did not present a safety-related concern, and again documented the matter but also monitored the situation. During this period of monitoring, in or about late 2019, DTNA concluded that the issue, if it manifested, was limited to very small numbers of seats concentrated in a specific geographic location. A root cause such as uniquely severe road use/environmental use cases was conjectured but not fully understood, given the limited information then available. That said, DTNA again reaffirmed its prior analysis that the matter did not present an unreasonable risk to safety within the meaning of the Safety Act. In or about March 2022, DTNA received a report from a customer with buses containing cracked seat wall mount brackets. DTNA began an extensive investigation to reassess its prior analysis. Among other things, TBB conducted an on-site customer visit to assess the alleged condition, inspected field units, and analyzed the resultant fleet inspection information. In April 2022, DTNA analyzed its preliminary investigation findings, and ordered additional steps, including further field data assessment given that the issue preliminarily appeared to arise in only certain geographic areas with certain fleets with vehicles that may have been subjected to more severe road use/environmental use cases. In May 2022 through late June 2022, DTNA conducted the ordered field study and analysis. DTNA’s field analysis yielded the following: TBB team inspected 13037 seats and identified 8 of the inspected seats with fractured mounting bracket. On July 12 2022, DTNA determined that a safety-related defect exists in HDX and EFX Thomas Built Buses equipped with 39-inch S3C seat frames and with 3-point flex seatbelt. The relevant warranty claims, field or service reports are summarized above as required by 49 C.F.R. 573.6(c)(6). The seat frames and seatbelts otherwise conform to all applicable Federal Motor Vehicle Safety Standards. _________________________________________________________________________________________________________________________________________________________________________ Identify the Remedy Describe the defect/noncompliance remedy program, including the manufacture’s plan for reimbursement. __The remedy is to be determined at this time _______________________________________________________________________________________________________________________________________________________________________ Identify the Recall Schedule Describe the recall schedule for notifications.: Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Begin Date: _9/16/2022_ Planned Dealer Notification End Date: _9/16/2022_ Planned Owner Notification Begin Date: _9/16/2022_ Planned Owner Notification End Date: _9/16/2022_ Does DTNA plan to file inconsequentiality petition? ⃝ Yes X No Manufacturer’s identification code for this recall (if applicable): _ FL946_________ DTNA Representative; Sam Canupp Manager, Compliance and Regulatory Affairs

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Daimler Truck North America LLC September 2022 FL946 Interim Recall Notice NHTSA #22V-510 IMPORTANT SAFETY RECALL Subject: TBB Passenger Seat Frames Daimler Trucks North America LLC Warranty Campaigns Department P.O. Box 4090 Portland, OR 97208-4090 800.547.0712 Phone This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act. Daimler Truck North America LLC (DTNA), on behalf of its wholly owned subsidiary, Thomas Built Buses (TBB), has decided that a defect which relates to motor vehicle safety exists in certain Model Year 2014-2022 HDX and EFX school buses manufactured May 24, 2013, through October 22, 2021. Certain buses equipped with 39-inch S3C seat frames and 3-point flex seatbelts, have seat frames crack and rotate from fatigue. The seats may therefore not provide adequate restraint to a belted passenger, which may increase the risk of injury in a crash. This is the first of two notices you will receive regarding this subject. This letter is to inform you of an upcoming Recall to correct the issue noted above. TBB is currently securing a solution and will provide the appropriate information when available. A fractured seat frame mounting bracket may be noticed during daily walk through, cleaning, bus inspections and routine maintenance. If found, please contact your local DTNA dealer to have the seat frame replaced. The second notice will inform you when the final remedy is available. When you receive the second notice, please contact your authorized DTNA dealer to schedule the Recall for your vehicle. If you do not own the vehicle that corresponds to the identification number(s) which appears on the Recall Notification, please return the notification to the Warranty Campaigns Department with any information you can furnish that will assist us in locating the present owner. If you have leased this vehicle, Federal law requires that you forward this notice to the lessee within 10 days. If you are a subsequent stage manufacturer, Federal law requires that you forward this notice to your distributors and retail outlets within five working days. If you have questions about this Recall, please contact the Warranty Campaigns Department at (800) 547-0712, 7:00 a.m. to 4:00 p.m. Pacific Time, Monday through Friday, e-mail address DTNA.Warranty.Campaigns@Daimlertruck.com. For other concerns, you may contact the Customer Assistance Center at (800) 385-4357. If you are not able to have the defect remedied without charge and within a reasonable time, you may wish to submit a complaint to the Administrator, National Highway Traffic Safety Administration, 1200 New Jersey Avenue SE, Washington, DC 20590; or call the Vehicle Safety Hotline at (888) 327-4236 (TTY: 800-424-9153); or go to http://www.nhtsa.gov. We regret any inconvenience this action may cause but feel certain you understand our interest in motor vehicle safety. WARRANTY CAMPAIGNS DEPARTMENT Enclosure

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Daimler Truck North America LLC 8BREF #: ICI22-039 Effective: 09/15/22 Release: 09/15/22 0BSUBJECT: FL946 – Interim Recall Notice This letter is to inform you that an interim recall notice is being sent to affected customers for recall FL946 ~ TBB Passenger Set Frame. The interim notices were mailed on 09/16//2022. This notice is for your information only. There is no action for dealers to take. If customers inquire, please refer them to the US and Canadian interim notices copied below If you have questions or need further information, contact the Warranty Campaigns Department by submitting an inquiry through the WSC link on DTNAConnect. REF #: ICI22-039 En vigueur : 15/09/22 Sortie: 15/09/22 MATIERE: FL946 – Avis de rappel provisoire Cette lettre a pour but de vous informer qu’un avis de rappel provisoire est envoyé aux clients concernés pour le rappel FL946 ~ Cadre de jeu de passagers TBB. Les avis intermédiaires ont été postés le 16/09/2022. Cet avis est pour votre information seulement. Les revendeurs n’ont aucune action à entreprendre. Si les clients demandent, veuillez les renvoyer aux avis provisoires américains et canadiens copiés ci-dessous Si vous avez des questions ou avez besoin de plus amples informations, contactez le service des campagnes de garantie en soumettant une demande via le lien WSC sur DTNAConnect WARRANTY CAMPAIGNS DEPARTMENT P.O. Box 4090 800-547-0712 Portland, Oregon 97208-4090 ATTENTION: Dealer Principal, Warranty Manager, Service Manager, Parts Manager Freightliner Dealers – U.S. and Canada Western Star and Sterling Dealers – U.S. and Canada FCCC Dealers – U.S. and Canada Thomas Built Buses Dealers – U.S. and Canada Direct Warranty Customers – U.S. and Canada Detroit Diesel Distributors Export Distributors If you have questions about this Letter, please submit your inquiry on the Web using the WSC Link on DTNAConnect Daimler Truck North America LLC September 2022 FL946 Interim Recall Notice NHTSA #22V-510 IMPORTANT SAFETY RECALL Subject: TBB Passenger Seat Frames Daimler Trucks North America LLC Warranty Campaigns Department P.O. Box 4090 Portland, OR 97208-4090 800.547.0712 Phone This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act. Daimler Truck North America LLC (DTNA), on behalf of its wholly owned subsidiary, Thomas Built Buses (TBB), has decided that a defect which relates to motor vehicle safety exists in certain Model Year 2014-2022 HDX and EFX school buses manufactured May 24, 2013, through October 22, 2021. Certain buses equipped with 39-inch S3C seat frames and 3-point flex seatbelts, have seat frames crack and rotate from fatigue. The seats may therefore not provide adequate restraint to a belted passenger, which may increase the risk of injury in a crash. This is the first of two notices you will receive regarding this subject. This letter is to inform you of an upcoming Recall to correct the issue noted above. TBB is currently securing a solution and will provide the appropriate information when available. A fractured seat frame mounting bracket may be noticed during daily walk through, cleaning, bus inspections and routine maintenance. If found, please contact your local DTNA dealer to have the seat frame replaced. The second notice will inform you when the final remedy is available. When you receive the second notice, please contact your authorized DTNA dealer to schedule the Recall for your vehicle. If you do not own the vehicle that corresponds to the identification number(s) which appears on the Recall Notification, please return the notification to the Warranty Campaigns Department with any information you can furnish that will assist us in locating the present owner. If you have leased this vehicle, Federal law requires that you forward this notice to the lessee within 10 days. If you are a subsequent stage manufacturer, Federal law requires that you forward this notice to your distributors and retail outlets within five working days. If you have questions about this Recall, please contact the Warranty Campaigns Department at (800) 547-0712, 7:00 a.m. to 4:00 p.m. Pacific Time, Monday through Friday, e-mail address DTNA.Warranty.Campaigns@Daimlertruck.com. For other concerns, you may contact the Customer Assistance Center at (800) 385-4357. If you are not able to have the defect remedied without charge and within a reasonable time, you may wish to submit a complaint to the Administrator, National Highway Traffic Safety Administration, 1200 New Jersey Avenue SE, Washington, DC 20590; or call the Vehicle Safety Hotline at (888) 327-4236 (TTY: 800-424-9153); or go to http://www.nhtsa.gov. We regret any inconvenience this action may cause but feel certain you understand our interest in motor vehicle safety. WARRANTY CAMPAIGNS DEPARTMENT Enclosure Daimler Truck North America LLC September 2022 FL946 Interim Recall Notice Transport Canada #2022-515 Subject: TBB Passenger Seat Frames This notice is sent to you in accordance with the requirements of the Motor Vehicle Safety Act. This is to inform you that your vehicle may contain a defect that could affect the safety of a person. Daimler Truck North America LLC (DTNA), on behalf of its wholly owned subsidiary, Thomas Built Buses (TBB), has decided that a defect which relates to motor vehicle safety exists in certain Model Year 2014-2022 HDX and EFX school buses manufactured May 24, 2013, through October 22, 2021. Certain buses equipped with 39-inch S3C seat frames and 3-point flex seatbelts, have seat frames crack and rotate from fatigue. The seats may therefore not provide adequate restraint to a belted passenger, which may increase the risk of injury in a crash. This is the first of two notices you will receive regarding this subject. This letter is to inform you of an upcoming Recall to correct the issue noted above. TBB is currently securing a solution and will provide the appropriate information when available. A fractured seat frame mounting bracket may be noticed during daily walk through, cleaning, bus inspections and routine maintenance. If found, please contact your local DTNA dealer to have the seat frame replaced. The second notice will inform you when the final remedy is available. When you receive the second notice, please contact your authorized Daimler Truck North America dealer to schedule the Recall for your vehicle. If you do not own the vehicle that corresponds to the identification number(s) which appears on the Recall Notification, please return the notification to the Warranty Campaigns Department with any information you can furnish that will assist us in locating the present owner. If you have leased this vehicle, Federal law requires that you forward this notice to the lessee within 10 days. If you are a subsequent stage manufacturer, Federal law requires that you forward this notice to your distributors and retail outlets within five working days. If you have questions about this Recall, please contact the Warranty Campaigns Department at (800) 547-0712, 7:00 a.m. to 4:00 p.m. Pacific Time, Monday through Friday, e-mail address DTNA.Warranty.Campaigns@Daimlertruck.com. For other concerns, you may contact the Customer Assistance Center at (800) 385-4357. If you have a safety concern relating to this Recall, you may wish to contact Transport Canada – Motor Vehicle Safety at, 80 rue Noel, Gatineau, Quebec J8Z 0A1 or phone (800) 333-0510. We regret any inconvenience this action may cause but feel certain you understand our interest in motor vehicle safety. WARRANTY CAMPAIGNS DEPARTMENT Enclosure Daimler Truck North America LLC Warranty Campaigns Department P.O. Box 4090 Portland, OR 97208-4090 800.547.0712 Phone Daimler Truck North America LLC September 2022 FL946 Interim Recall Notice Transport Canada #2022-515 Objet : Châssis de siège passager TBB Cet avis vous est envoyé conformément aux exigences de la Loi sur la sécurité automobile. La présente a pour but de vous informer que votre véhicule peut contenir une défectuosité pouvant nuire à la sécurité d’une personne. Daimler Truck North America LLC (DTNA), au nom de sa filiale en propriété exclusive, Thomas Built Buses (TBB), a décidé qu’un défaut lié à la sécurité des véhicules à moteur existe dans certains autobus scolaires HDX et EFX de l’année modèle 2014-2022 fabriqués en mai Du 24 octobre 2013 au 22 octobre 2021 Certains autobus équipés de cadres de siège S3C de 39 pouces et de ceintures de sécurité flexibles à 3 points ont des cadres de siège qui se fissurent et tournent à cause de la fatigue. Les sièges peuvent donc ne pas fournir une retenue adéquate à un passager attaché, ce qui peut augmenter le risque de blessure lors d’un accident. Ceci est le premier des deux avis que vous recevrez à ce sujet. Cette lettre a pour but de vous informer d’un prochain rappel pour corriger le problème mentionné ci-dessus. TBB recherche actuellement une solution et fournira les informations appropriées lorsqu’elles seront disponibles. Un support de montage de cadre de siège fracturé peut être remarqué lors de la visite quotidienne, du nettoyage, des inspections de bus et de l’entretien de routine. Si trouvé, veuillez contacter votre revendeur DTNA local pour faire remplacer le cadre du siège. Le deuxième avis vous informera lorsque le remède final sera disponible. Lorsque vous recevez le deuxième avis, veuillez contacter votre concessionnaire autorisé Daimler Truck North America pour programmer le rappel pour votre véhicule. Si vous ne possédez pas le véhicule qui correspond au(x) numéro(s) d’identification qui apparaît sur la notification de rappel, veuillez retourner la notification au service des campagnes de garantie avec toute information que vous pouvez fournir qui nous aidera à localiser le propriétaire actuel. Si vous avez loué ce véhicule, la loi fédérale exige que vous transmettiez cet avis au locataire dans les 10 jours. Si vous êtes un fabricant de stade ultérieur, la loi fédérale exige que vous transmettiez cet avis à vos distributeurs et points de vente dans les cinq jours ouvrables. Si vous avez des questions concernant ce rappel, veuillez contacter le service des campagnes de garantie au (800) 547- 0712, de 7 h 00 à 16 h 00. Heure du Pacifique, du lundi au vendredi, adresse e-mail DTNA.Warranty.Campaigns@Daimlertruck.com. Pour d’autres préoccupations, vous pouvez contacter le Centre d’assistance à la clientèle au (800) 385-4357. Si vous avez un problème de sécurité lié à ce rappel, vous pouvez contacter Transports Canada – Sécurité des véhicules automobiles au 80, rue Noel, Gatineau, Québec J8Z 0A1 ou téléphoner au (800) 333-0510. Nous regrettons tout inconvénient que cette action pourrait causer, mais soyez certain que vous comprenez notre intérêt pour la sécurité des véhicules à moteur. SERVICE DES CAMPAGNES DE GARANTIE Enceinte Daimler Truck North America LLC Warranty Campaigns Department P.O. Box 4090 Portland, OR 97208-4090 800.547.0712 Phone

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-510 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Daimler Trucks North America, LLC Submission Date : AUG 11, 2022 NHTSA Recall No. : 22V-510 Manufacturer Recall No. : FL946 Manufacturer Information : Manufacturer Name : Daimler Trucks North America, LLC Address : 4747 N. Channel Avenue Portland OR 97217-3849 Company phone : 800-745-8000 Population : Number of potentially involved : 1,808 Estimated percentage with defect : 4 % Vehicle Information : Vehicle 1 : 2014-2022 Thomas Built Buses HDX and EFX Vehicle Type : BUSES, MEDIUM & HEAVY VEHICLES Body Style : OTHER Power Train : DIESEL Descriptive Information : The subject population includes approximately 1,808 Model Year 2014-2022 Thomas Built Bus (“TBB”) HDX and EFX school bus vehicles produced within the abovespecified production date range in the United States. Under certain extreme operating conditions, that may include adverse road conditions, a metal fatigue-related cracking may develop on 39 inch S3C seat frames with a 3-point flex belt seat rear wall mount bracket. Over time, if the condition manifests itself, the crack may propagate and lead to fracturing of the wall mount bracket. Production Dates : MAY 24, 2013 – OCT 22, 2021 VIN Range 1 : Begin : NR End : NR Not sequential Description of Defect : Description of the Defect : The subject vehicles are equipped with specific passenger seats that may experience abnormal structural fatigue that may impact seat strength during a crash. Root cause has not yet been determined. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : Fatigue of the seats frame structure could result in frame cracking, thus causing the seat to shift and rotate. The seat may therefore not provide adequate restraint to a belted passenger, which may increase the risk of injury to vehicle occupants in a crash. Description of the Cause : TBB continues to investigate root cause. Part 573 Safety Recall Report 22V-510 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Identification of Any Warning that can Occur : A fractured seat frame mounting bracket may be noticed during daily walk through, cleaning, bus inspections and routine maintenance. Involved Components : Component Name 1 : Passenger Seat Frame Component Description : Seat Lower Frame Component Part Number : 30628 Component Name 2 : Passenger Seat Frame Component Description : Seat Lower Frame Component Part Number : 30630 Supplier Identification : Component Manufacturer Name : NR Address : NR NR Country : NR Chronology : In or about mid-2017, DTNA’s seat supplier informed DTNA of a fractured S3C seat frame. DTNA reviewed the matter, concluded it did not present a safety-related concern, and documented the matter. In or about September 2018, DTNA received several reports of fractured seat frames from one specific customer location. Thereafter, DTNA began an investigation, which included field inspections, engineering laboratory evaluations and field tests. Upon review, DTNA concluded that the matter did not present a safety-related concern, and again documented the matter but also monitored the situation. During this period of monitoring, in or about late 2019, DTNA concluded that the issue, if it manifested, was limited to very small numbers of seats concentrated in a specific geographic location. A root cause such as uniquely severe road use/environmental use cases was conjectured but not fully understood, given the limited information available. That said, DTNA again reaffirmed its prior analysis that the matter did not present an unreasonable risk to safety within the meaning of the Safety Act. March 08, 2022, DTNA received a report from a customer with buses containing cracked seat wall mount Part 573 Safety Recall Report 22V-510 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 brackets. DTNA began an extensive investigation to reassess its prior analysis. Among other things, TBB conducted an on-site customer visit to assess the alleged condition, inspect available field units, and analyze the resultant fleet inspection information. See miscellaneous document for more detail Description of Remedy : Description of Remedy Program : DTNA does not have a remedy identified at this time. DTNA will provide the appropriate information as soon as it is available. How Remedy Component Differs from Recalled Component : NR Identify How/When Recall Condition was Corrected in Production : NR Recall Schedule : Description of Recall Schedule : Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Date : SEP 16, 2022 – SEP 16, 2022 Planned Owner Notification Date : SEP 16, 2022 – SEP 16, 2022 * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-510 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Daimler Trucks North America, LLC Submission Date : JUL 19, 2022 NHTSA Recall No. : 22V-510 Manufacturer Recall No. : FL946 Manufacturer Information : Manufacturer Name : Daimler Trucks North America, LLC Address : 4747 N. Channel Avenue Portland OR 97217-3849 Company phone : 800-745-8000 Population : Number of potentially involved : 4,344 Estimated percentage with defect : 1 % Vehicle Information : Vehicle 1 : 2014-2022 Thomas Built Buses HDX and EFX Vehicle Type : BUSES, MEDIUM & HEAVY VEHICLES Body Style : OTHER Power Train : DIESEL Descriptive Information : The subject population includes approximately 4,344 Model Year 2014-2022 Thomas Built Bus (“TBB”) HDX and EFX vehicles produced within the above-specified production date range in the United States. Under certain extreme operating conditions, that may include adverse road conditions, a metal fatigue-related cracking may develop on 39 inch S3C seat frames with a 3-point flex belt seat rear wall mount bracket. Over time, if the condition manifests itself, the crack may propagate and lead to fracturing of the wall mount bracket. Production Dates : MAY 24, 2013 – OCT 22, 2021 VIN Range 1 : Begin : NR End : NR Not sequential Description of Defect : Description of the Defect : The subject vehicles are equipped with specific passenger seats that may experience abnormal structural fatigue that may impact seat strength during a crash. Root cause has not yet been determined. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : Fatigue of the seats frame structure could result in frame cracking, thus causing the seat to shift and rotate. The seat may therefore not provide adequate restraint to a belted passenger, which may increase the risk of injury to vehicle occupants in a crash. Description of the Cause : TBB continues to investigate root cause. Part 573 Safety Recall Report 22V-510 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Identification of Any Warning that can Occur : A fractured seat frame mounting bracket may be noticed during daily walk through, cleaning, bus inspections and routine maintenance. Involved Components : Component Name 1 : Passenger Seat Frame Component Description : Seat Lower Frame Component Part Number : 30628, 30630 Supplier Identification : Component Manufacturer Name : NR Address : NR NR Country : NR Chronology : See miscellaneous document Description of Remedy : Description of Remedy Program : The remedy is to be determined at this time How Remedy Component Differs from Recalled Component : NR Identify How/When Recall Condition was Corrected in Production : NR Recall Schedule : Description of Recall Schedule : Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Date : SEP 16, 2022 – SEP 16, 2022 Planned Owner Notification Date : SEP 16, 2022 – SEP 16, 2022 Part 573 Safety Recall Report 22V-510 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 * NR – Not Reported

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