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October 4, 2019 NHTSA CAMPAIGN NUMBER: 19V712000

Insufficient Impact Absorption/FMVSS 222

The lack of impact absorption increases the risk of injury in the event of a crash.

NHTSA Campaign Number: 19V712

Manufacturer Daimler Trucks North America LLC

Components SEATS

Potential Number of Units Affected 53,528

Summary

Daimler Trucks North America LLC (DTNA) is recalling certain 2014-2020 Thomas Built Saf-T-Liner EFX, Minotour, Saf-T-Liner C2, and Saf-T-Liner HDX school buses equipped with SynTec S3B or S3C seats. The seats may have been manufactured with styrene blocks that may not provide sufficient impact absorption in certain specific areas around the steel seat frame of the back support. As such, these vehicles fail to comply with the requirements of Federal Motor Vehicle Safety Standard (FMVSS) number 222, “School Bus Passenger Seating and Crash Protection.”

Remedy

DTNA will notify owners, and dealers will install additional impact material between the re-bond back and the vinyl back cover to increase the amount of absorption, free of charge. DTNA issued owners an interim notification on November 29, 2019. The recall began June 22, 2020. Owners may contact DTNA customer service at 1-800-547-0712. DTNA’s number for this recall is FL-832.

Notes

Owners may also contact the National Highway Traffic Safety Administration Vehicle Safety Hotline at 1-888-327-4236 (TTY 1-800-424-9153), or go to www.safercar.gov.

Check for Daimler Trucks North America Recalls

Recall Campaign

Daimler Trucks
North America LLC

June 2020
FL832A
NHTSA#19V-712
Transport Canada #2019-497

Subject: TBB SynTec S3B/S3C Seat Kneeforms

Models Affected: Specific Model Year 2015-2020 Thomas Built Buses Minotour and Saf-T-Liner C2, EFX, and HDX model school buses manufactured August 18, 2014, through August 15, 2019, with certain SynTec S3B or S3C seats.

General Information

Daimler Trucks North America LLC (DTNA), on behalf of its wholly owned subsidiary, Thomas Built Buses (TBB), has decided that a defect that relates to motor vehicle safety exists on the vehicles mentioned above.

There are approximately 57,000 vehicles involved in this campaign.

On certain buses equipped with affected seats, specific areas of the seat back may not meet the requirements of FMVSS 222, part 53.3.2, School Bus Seating and Crash Protection. This may increase the risk of injury to occupants in a crash.

Seats will be augmented by installation of additional impact material between the seat back and the back cover to assure compliance with pertinent requirements.

Additional Repairs

Dealers must complete all outstanding Recall and Field Service campaigns prior to the sale or delivery of a vehicle. A Dealer will be liable for any progressive damage that results from its failure to complete campaigns before sale or delivery of a vehicle.

Owners may be liable for any progressive damage that results from failure to complete campaigns within a reasonable time after receiving notification.

Work Instructions

Please refer to the attached work instructions.

Replacement Parts

Selling dealers were proactively shipped an estimated 40 percent of the parts needed to complete the buses sold by the dealership. Parts and the optional installation tool for this repair, see Table 1, may also be ordered at no charge by following the instructions below.

Ordering Instructions

Email Address: tbbseatrecall@daimler.com

Subject line: Recall FL832 Parts Order

Include in email:

Quantity ordered
Dealer name and dealer code
Contact person and phone number
Shipping address

Table 1 –Parts for FL832

Campaign Number	Part Number	Description	Qty. Per Seat
FL832A	TBB 223749	SYNTEC POLYPROPYLENE FF INSERT (2 PER SEAT REQUIRED)	2 ea
	N/A	STAPLES	As needed
	N/A	OPTIONAL INSTALLATION TOOL (1 PER DEALERSHIP)	1 ea (use for all buses)

Table 1

Removed Parts

Please follow Warranty Failed Parts Tracking shipping instructions for the disposition of all removed parts.

Labor Allowance

Table 2 – Labor Allowance

Campaign Number	Procedure	Time Allowed (Hours)	SRT Code	Corrective Action
FL832A	Add foam insert to 1-5 seats	0.5	996-R196A	12 – Repair Recall/Campaign
	Add foam insert to 6-10 seats	0.8	996-R196B
	Add foam insert to 11-15 seats	1.4	996-R196C
	Add foam insert to 16-20 seats	2.3	996-R196D
	Add foam insert to 21-25 seats	2.7	996-R196E
	Add foam insert to 26-30 seats	2.8	996-R196F

Table 2

Claims for Credit

You will be reimbursed for your parts, labor, and handling by submitting your claim through the Warranty system within 30 days of completing this campaign. Please reference the following information in OWL:

Claim Type is Recall Campaign.
In the Campaign field, enter the campaign number (FL832-A).
In the Primary Failed Part field, enter 25-FL832-000.
In the Parts section, enter staples as miscellaneous parts as needed. The polypropylene foam inserts are not listed on the claim and are provided at no charge.
In the Labor section, enter the appropriate SRT from the Labor Allowance Table. Claim the SRT that includes the number of seats repaired.
The VMRS Component Code is F99-999-005 and the Cause Code is A1 – Campaign.
U.S. and Canada – Reimbursement for Prior Repairs. When a customer asks about reimbursement, please do the following:
Accept the documentation of the previous repair.
Make a brief check of the customer’s paperwork to see if the repair may be eligible for reimbursement.
Submit a Recall Pre-Approval request for a decision and authorized amount.
Submit a “based on” claim for the approved pre-approval.
Attach the documentation to the pre-approval request.
When your claim is paid, reimburse the customer the appropriate amount.

IMPORTANT: OWL must be viewed prior to performing the recall to ensure the vehicle is involved and the campaign has not been previously completed.

If you have any questions or need additional information, contact the Warranty Campaigns Department via Web inquiry at DTNAConnect.com / WSC.

Excess kit inventory related to this campaign is not returnable.

A sample letter notifying vehicle owners is included for your reference.

Please note that the National Traffic and Motor Vehicle Safety Act, as amended (Title 49, United States Code,

Chapter 301), requires the owner’s vehicle(s) be corrected within a reasonable time after parts are available to you. The Act states that failure to repair a vehicle within 60 days after tender for repair shall be prima facie evidence of an unreasonable time. However, circumstances of a particular situation may reduce the 60 day period. Failure to repair a vehicle within a reasonable time can result in either the obligation to (a) replace the vehicle with an identical or reasonably equivalent vehicle, without charge, or (b) refund the purchase price in full, less a reasonable allowance for depreciation. The Act further prohibits dealers from selling a vehicle unless all outstanding recalls are performed. Any lessor is required to send a copy of the recall notification to the lessee within 10 days. Any subsequent stage manufacturer is required to forward this notice to its distributors and retail outlets within five working days.

Copy of Notice to Owners

Subject: TBB SynTec S3B/S3C Seat Kneeforms

The U.S. notice is used for reference: This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

Daimler Trucks North America LLC, on behalf of its wholly owned subsidiary, Thomas Built Buses, has decided that a defect which relates to motor vehicle safety exists on specific Model Year 2015-2020 Thomas Built Buses Minotour and Saf-T-Liner C2, EFX, and HDX model school buses manufactured August 18, 2014, through August 15, 2019, with certain SynTec S3B or S3C seats.

Seats will be augmented by installation of additional impact material between the seat back and the back cover to assure compliance with pertinent requirements.

This is the second letter regarding this recall to let you know the repair is now available. To arrange for repairs, you should contact your local Thomas Built Buses dealer immediately. The repair may take up to three hours, depending on the number of seats affected, and will be performed at no charge to you.

You may be liable for any progressive damage that results from your failure to complete the Recall within a reasonable time after receiving notification.

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 paid to have this recall condition corrected prior to this notice, you may be eligible to receive reimbursement. Please see the reverse side of this notice for details.

If you have any questions about this recall, please contact the Warranty Campaigns Department at (800) 547-0712, 7:00 a.m to 4:00 p.pm, Monday through Friday. 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 to https://www.safercar.gov

We regret any inconvenience this action may cause but feel certain you understand our interest in motor vehicle safety.

THOMAS BUILT BUSES WARRANTY DEPARTMENT

Enclosure

Reimbursement to Customers for Repairs Performed Prior to Recall

If you have already paid to have this recall condition corrected you may be eligible to receive reimbursement.

Requests for reimbursement may include parts and labor. Reimbursement may be limited to the amount the repair would have cost if completed by an authorized Daimler Trucks North America LLC dealer. The following documentation must be presented to your dealer for consideration for reimbursement.

Please provide original or clear copies of all receipts, invoices, and repair orders that show:

The name and address of the person who paid for the repair.
The Vehicle Identification Number (VIN) of the vehicle that was repaired.
What problem occurred, what repair was done, when the repair was done.
Who repaired the vehicle.
The total cost of the repair expense that is being claimed.
Proof of payment for the repair (such as the front and back of a cancelled check or a credit card receipt).

Reimbursement will be made by check from your Daimler Trucks North America LLC dealer. Please speak with your Thomas Built Buses authorized dealer concerning this matter.

Work Instructions

Subject: TBB SynTec S3B/S3C Seat Kneeforms

Impact Material (Foam Insert) Installation

Park the vehicle on a level surface, turn the key completely off, put the bus in Park, and set the parking brake. Chock the tires.
Wearing safety glasses and gloves, release the finger latch on the bottom of the seat and tilt forward and out of the way. Remove the bottom seat cushion and set aside.
Using a staple remover, remove the staples from the first 3 to 6 inches on both sides of the seat (wall and aisle sides) of the seat. See Figure 1.

Figure 1: Removing the Vinyl Seat Cover

Pull the remaining vinyl out by hand, to detach the remaining staples and reveal the reverse side of the stapled vinyl.

From the front of the seat, using a staple remover or wide-nose pliers, remove the staples from the reverse side of the vinyl. See Figure 2.

Figure 2: Removing Staples from the Reverse Side of the Vinyl

Using pliers, bend all staples shown in Figure 3 to ensure there are no sharp points. This will be covered with two layers of vinyl in later steps.

Figure 3: Remove Staples from Wood Strip

IMPORTANT: In steps 9 and 10, do not pull the cover completely off the seat back.

Pull or roll the vinyl cover up on the front of the seat. See Figure 4.

Figure 4: Cushion and Vinyl Cover (Seat Front)

Pull or roll the cover up on the seat back. See Figure 5.

Figure 5: Vinyl Cover (Seat Back)

NOTE: An optional tool, provided with new impact material inserts (“insert”) shipped to dealers, may be used. It slides up with the insert between the existing foam and the vinyl cover. Once in position, slide the tool out.

Place the Insert between the vinyl and the existing foam. The narrower side of the insert is positioned toward the side of the seat and the wider side is positioned toward the back of the seat. See Figure 6, Figure 7, and Figure 8.

Figure 6: Positioning the Insert

Figure 7: Insert Installed

Figure 8: Insert During Installation

After both inserts are in place between the vinyl and foam, make sure the top edge of the foam has not folded over. Flatten the top edge of the foam by hand or slide the tool up to smooth any rolls, if required. Then, pull the vinyl down over the repair on both sides evenly. Do not pull one side down then the other, pull down both sides at the same time.
Check the bottom edge of both inserts. They should remain even with the foam chamfer, approximately 2 inches from the bottom of the foam. If either insert has shifted, adjust as necessary by sliding it up or down as needed to maintain the 2-inch distance from the bottom of the foam. See Figure 9.

Figure 9: Alignment with Seat Foam

Tuck and fold the front and back corners of the seat cover around the rear seat leg. See Figure 10.

Figure 10: Folding and Tucking the Vinyl Seat Cover

Pull the vinyl cover on the back of the seat under the seat and pull tight. Staple to the original wood strip. See Figure 3, Figure 11, and Figure 12.

Figure 11: Staple Back of Vinyl Seat Cover onto the Wood Strip

Figure 12: After Cover is Folded and Stapled

Pull the vinyl cover on the front of the seat down. Make sure it is straight and there are no wrinkles.
Fold the vinyl underneath itself to match the crease from the original installation.
Staple the front vinyl cover to the wood strip (that it was removed from earlier). Ensure no restraint belts are obstructed by the vinyl or staples. See Figure 13.

Figure 13: Front Seat Cover When Folded and Stapled

Reinstall the seat cushion removed earlier.
Remove the chocks from the tires.

Daimler Trucks
North America LLC

June 2020
FL832A
NHTSA #19V-712

IMPORTANT SAFETY RECALL

See enclosed VIN list

Subject: TBB SynTec S3B Seat Kneeforms

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

Daimler Trucks North America LLC, on behalf of its wholly owned subsidiary, Thomas Built Buses, Inc., has decided that a defect which relates to motor vehicle safety exists on specific Model Year 2015-2020 Thomas Built Buses Minotour, and Saf-T-Liner EFX/HDX model school buses manufactured August 18, 2014, through August 15, 2019, with SynTec S3B or S3C seats.

Seats will be augmented by installation of additional impact material between the seat back and the back cover to assure compliance with pertinent requirements.

If you have any 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. 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) 3274236 (TTY: (800) 424-9153); or to https://www.safercar.gov.

We regret any inconvenience this action may cause but feel certain you understand our interest in motor vehicle safety.

WARRANTY CAMPAIGNS DEPARTMENT

Enclosure

Reimbursement to Customers for Repairs Performed Prior to Recall

If you have already paid to have this recall condition corrected you may be eligible to receive reimbursement.

Please provide original or clear copies of all receipts, invoices, and repair orders that show:

The name and address of the person who paid for the repair.
The Vehicle Identification Number (VIN) of the vehicle that was repaired.
What problem occurred, what repair was done, when the repair was done.
Who repaired the vehicle.
The total cost of the repair expense that is being claimed.
Proof of payment for the repair (such as the front and back of a cancelled check or a credit card receipt).

Reimbursement will be made by check from your Daimler Trucks North America LLC dealer. Please speak with your Thomas Built Buses authorized dealer concerning this matter.

Daimler Trucks
North America LLC

November 2019
FL832
Interim Recall Notice NHTSA #19V-712

IMPORTANT SAFETY RECALL

See enclosed VIN list

Subject: TBB SynTec S3B Seat Kneeforms

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

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. The repair is being validated and parts are being procured. There is no action for you to take at this time. You may continue to operate your vehicle.

The second notice will inform you when the final remedy is available. When you receive the second notice, please contact your authorized Thomas Built Buses dealer to schedule the Recall for your vehicle.

We regret any inconvenience this action may cause but feel certain you understand our interest in motor vehicle safety.

WARRANTY CAMPAIGNS DEPARTMENT

Enclosure

Thomas Built Buses Seat Foam Recall Information Sheet

Thomas Built Buses recently reported and notified the National Highway Safety Administration (NHTSA) of a voluntary non-compliance recall on School Buses equipped with certain Syntec seats. Certain areas on the seat back may not meet the knee impact requirements of NHTSA’s Federal Motor Vehicle Safety Standard (FMVSS) 222. These areas are located at the lower outer edges of the seat back. Out of an abundance of caution Thomas Built Buses reported a voluntary non-compliance recall.

An increased risk of injury may be present during certain frontal impact events if an unrestrained passenger’s knee strikes certain portions of the seat back surface area relative to the rest of the seat back. All other areas of the seat back meet the FMVSS 222 knee impact requirements.

During testing for compliance to FMVSS 222; section S5.3.2.2 it had been determined that the resulting force at certain locations in the proximity of the seat frame exceeded the specified requirement. Following these performance requirements, this recall has been initiated to address and remedy the affected population of Syntec seats as specified in the standard.

Thomas Built Buses has filed this recall in accordance with the NHTSA rules and procedures.

FAQ

Can we say it is a voluntary recall?
- Yes, this is a voluntary recall for a potential non-compliance with an FMVSS 222 performance requirement.

Can we define the impact to be the knee, and low likelihood of severe injury?
- An increased risk of injury may be present during certain frontal impact events if an unrestrained passenger’s knee strikes certain portions of the seat back surface area, located at the lower outer edges of the seat back in the proximity of the seat frame, relative to the rest of the seat back. All other areas of the seat back meet the FMVSS 222 knee impact performance requirements.

Do we down the buses/Can we tell them we do not recommend grounding vehicles?
- According to NHTSA’s 2018 Recall Annual Report, in calendar year 2018 there were 914 vehicle recalls reported to NHTSA. Those recalls affected 29,317,530 vehicles. NHTSA has the authority to make a “do not drive” warnings on recalls. “Do not drive” warnings are rare and are reserved for recalls that represent an elevated risk of sever injury or death. At this time, NHTSA has not made a “do not drive” warning with this recall.

Can we tell customers only a small portion of the surface area is non-compliant?
- The affected area is at the lower outer edges of the seat back in the in the proximity of the seat frame. All other areas of the seat back meet the FMVSS 222 knee impact performance requirements.

Is my bus safe?
- School buses are statistically the safest means of transportation on the road. According to the American School Bus Council, students are about 70 times more likely to get to school safely if they take the school bus instead of traveling by car.

Does the seat have exposed steel?
- No, there is no exposed steel. The impact absorption material in the seat back may not provide as much impact protection as is required by FMVSS 222 in certain locations at the lower outer edges of the seat back in the proximity of the seat frame.

Is this a safety issue/How big is the safety risk?
- In certain frontal impacts, an increased risk of injury may be present if an unrestrained passenger’s knee strikes certain portions of the seat back surface area located at the lower outer edges of the seat back, relative to the rest of the seat back. All other areas of the seat back meet the FMVSS 222 knee impact performance requirements.

What is the fix?
- Additional impact absorption material will be added to the seat back.

When will my bus be fixed?
- Thomas Built Buses and Syntec Seating solutions are working as quickly as possible to develop the field repair and procure parts to release the recall repair.

Will you send me something in writing that says I am safe?
- This is a voluntary recall for a potential FMVSS non-compliance. Thomas Built Buses has filed this recall in accordance with the NHTSA rules and procedures.

How do we know if my bus is involved?
- Bus owners will be notified by mail beginning no later than December 2, 2019.
- Model year 2014 through 2020 Thomas Built Buses are potentially affected. Only certain Syntec S3B and S3C model seats are affected. No seats with 3 point seat belts or integrated child restraints are affected. The images below can be used to determine which seats are affected.

Affected

S3B

Affected

S3C- RTR

S3C seats with no seatbelts or lap belts only

Not Affected

S3C- Square Tube

S3C seats with 3 point seat belts or child restraints

Frequently Asked Questions: FL832

If performing the recall, and we find a foam has been replaced with a “new” style foam (foam with the built in L shape styrene) do we need to verify that it is the correct part, and if so, how?

If block styrene is installed in foam (picture a) the recall, (shin guards) are required. If L shaped styrene is installed (picture b) in foam shin guards are not required.

a. Needs shin guard

b. Shin guard not needed

Will there be a way to communicate to customers the foam that is approved going forward to use that will allow the removal of the shin guards?

The part is labeled to stay with original equipped foam. (See chart below)

If a customer changes the foam using OEM replacement foam (see chart below) with the L shaped styrene the shin guard does not need to remain in place.

No.

Does aftermarket replacement foam need the shin guards installed?

Yes.

Do we need to install the shin guards on the barriers?

No.

Which seats are involved in FL832?

All SynTec S3B and S3C seats except for the S3C ICS and S3C lap shoulder belts are involved.

This includes wall mount, track mount, and flip seats.

1. 1. Wall mount seats do not need the last row done
  2. Track mount seats do need the last row done due to the ability to move position in the bus if floor plan changes

Should shins guards need to be installed on both sides of seats?

Yes. Parts must be installed on aisle and wall side of the seat.

Should shin guards be installed on IMMI seats or Freeman seats?

No.

Why is there a visual difference in the rubber on the shin guard parts?

Earlier parts have a dull finish and the majority of parts have a shine finish to aid in the install by having it smoother.

How do I know the SRT to claim?

The seat count is the number of seats in the bus that require the repair.

Will staples be covered in FL832?

Yes. In the parts section, list them as “Staples” with a part type of “other” and the dollar amount (no handling since they were not purchased from a PDC).

In the event that a seat cover is damaged above the staple line while removing staples, will seat cover be replaced?

Yes. The dealer will need to contact their DM to get the seat cover covered via policy.

FOAM ASSEMBLY PART NUMBERS THAT REQUIRE SHIN GUARDS		FOAM ASSEMBLY PART NUMBERS THAT DO NOT REQUIRE SHIN GUARDS
Original OLD		Interim foam used 8/15/19 thru 5/21/20.		New starting approx: May 21st 2020
2483360	45″	29598	45″	29864	45″
2483361	39″	29599	39″	29865	39″
2483362	36″	29600	36″	29866	36″
2498827	32″	29601	32″	29867	32″
2483363	30″	29602	30″	29868	30″
2483364	26″	29602	26″	29869	26″

SynTec S3B & S3C RTR foam Recall
Key Talking Points

Introduction: The purpose of this call is to communicate an important customer service development concerning seating in Thomas school buses. Our communication will be specific and at this time we will not be able to elaborate or take any additional questions. We realize that there will be many questions but it is imperative that we follow specific NHTSA guidelines. Please keep this information confidential at this time. We do commit to further communication and will do so at the appropriate times and with the appropriate methods. Thank you for your understanding. Here are the key points of our message:

Thomas Built Buses will be issuing a recall on all S3B and S3C non 3 point seatbelt or ICS school bus seats.
This will impact approximately 58,000 school buses built prior to August 15, 2019.
The issue is an inconsistency with seat back foam in two small areas along the lower outer frame edges of the seat.
This non-compliance is not be visible or detectable.
All S3B and S3C non 3 point seatbelt or ICS seats will need to be addressed with a procedure to improve the impact area around the frame. That procedure is currently being verified and will be released at the appropriate time.
The S3C 3point belt or integrated child seat backs are excluded from any action currently.
Buses can continue to operate until the repair is completed

SynTec has filed an equipment recall with NHTSA. TBB’s recall has filed to NHTSA as well. We are making a commitment to keep you informed in case you get an inquiry, and telling you details today in case a customer approaches you.

The SRT time and repair procedure are being developed and will be made available once a final action is determined.

Please understand that dealers can’t deliver new units in their possession with “An OPEN RECALL THAT HAS NOT BEEN REPAIRED”. If you have new units impacted by this recall, please contact Mitch Miller.

To reiterate any unit built on or after August 15, 2019 is not subject to this recall and any units released from TBB after October 1, 2019 are not affected or subject to needed repair. Those units may be delivered to the customers.

We have set up a formal question and communication processes. Customers may send inquiries to TBBseatrecall@daimler.com. They may also call (336) 889-4871-option 1 then option 3. Please stay patient and remember we are committed to as much communication as possible as information becomes available.

Memorandum

To:	All Thomas Dealers
From:	Ken Hedgecock
Subject:	Thomas Built Buses Seat Foam Recall Document
Date:	October 25, 2019

We have received approval to share the attached document with the general public. Feel free to distribute to your customers as you see fit. Thank you for your continued patience and understanding as we strive to stay within NHTSA guidelines and provide as much information as possible to our dealers and our customers.

Memorandum

To:	All Thomas Dealers
From:	Ken Hedgecock
Subject:	NHTSA Recall 19V-712/FL-832
Date:	October 23, 2019

Attached you will find the NHTSA document that describes the most recent SynTec recall. I have highlighted a key statement for your review. This is a public document and can be shared as you see fit. I have also provided the NHTSA link for your use as well. Please make sure you dial in to our 2:00 pm EDST call tomorrow for additional details.

https://static.nhtsa.gov/odi/rcl/2019/RCLRPT-19V712-4126.PDF

SEOCONTENT-START

Defect Information Report
(Section 573.6)
FL-832
Date of Submission: October 4th, 2019
Manufacturer: Daimler Trucks North America LLC
P.O. BOX 3849
Portland, Oregon 97208
Type of Report: 0 Safety Defect X Non-Compliance
Vehicle Information
Model Yr. Start: With S3B seat: 2015 and with S3C RTR seat: 2014 Model Yr. End: 2020
Make: Thomas Built Buses
Model: Saf-T-Liner C2, Saf-T-Liner HDX, Saf-T-Liner EFX, and Minotaur
Production Dates: Begin: With S3B seat: 08/18/2014 and with 53C RTR seat: 7/5/2013
End: With 538 seat: 08/15/2019 and with S3C RTR seat: 8/15/2019
Descriptive Information:
Certain Thomas Built School Buses equipped with SynTec 538 and 53C seats.
Number potentially involved: 53,528
Defect/ Noncompliance Description
For this Defect/Noncompliance:
Estimated percentage of involve with defect: 50%
Per SynTec 573 filing “In the relevant population, certain specific areas of the seat back may not meet
the requirements of S5.3.2 Federal Motor Vehicle Safety Standard (FMVSS) 222.”
Describe the defect or noncompliance:
Per SynTec 573 filing “The suspect population of seats were made with styrene blocks that have the
potential to not meet the requirement of S5.3.2 Federal Motor Vehicle Safety Standard (FMVSS} 222”.
If a noncompliance, provide the applicable FMVSS:
FMVSS 222 S5.3.2
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Q Check if this recall only affects products in certain geographic regions.
Describe the safety risk:
Per Syn Tee 573 filing “The suspect population of seats were made with styrene blocks that have the
potential to not meet the requirement of 55.3.2 Federal Motor Vehicle Safety Standard (FMVSS} 222,
which may increase the risk of injury to the occupants in a crash. There have been NO reported injuries or
accidents related to this defect.”
If applicable, identify the manufacture of the defective or noncompliant component.
Syn Tee Seating Solutions, LLC
. Chronology of Defect/ Noncompliance Determination
Provide the chronology of events leading up to the defect decision or test data for the
noncompliance decision.:
March 2019, DTNA received report from Transport Canada of non-complying test results on 2 of 4 seats
tested for knee foam impact. DTNA contacted its supplier, Syn Tee, and Syn Tee launched investigation,
including review of design history, validation and conformance testing, product changes, testing history,
changes in test methodology, test equipment, manufacturing changes and variability, sub-suppl,er issues
and other matters potentially contributing to the reported test result. June 2019, DTNA and Syn Tee
representatives visited Transport Canada to review tested seats. Teardown of the seats indicated
variation of the position of the knee styrene block to the seat frame. July-August 2019, Syn Tee initiates
various impact tests in an effort to duplicate failure mode. This includes process trials, gluing methods,
styrene positioning, and density studies to recreate field issue. August 2019, Syn Tee initiates design
change to styrene block to improve resisting force as an improvement measure while investigation
continues. September 2019, as a result of internal seat and component level testing, combined with
difficulties in visually identifying manufacturing variation in the positioning of the styrene block, Syn Tee
concludes that a non-compliance could potentially exist on any 538 and S3C seat in the subject
population. September 30th
, 2019 DTNA with an abundance of caution, decided to conduct a voluntary
recall campaign on certain school buses equipped with Syn Tee 538 and S3C seats. October 2019, Syn Tee
officially notifies DTNA of their 573 filing.
Identify the Remedy
Describe the defect/noncompliance remedy program, including the manufacturer’s plan for
reimbursement.
Seats will be augmented by installation of an additional impact material between the re-bond back and
the vinyl back cover to assure compliance with pertinent requirements. The impact material can be
installed in the vehicle without taking the bus out of service. Repairs will be performed by Daimler Trucks
North America authorized service facilities. Copies of the reimbursement plan will be submitted as a
supplemental report when available.
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– ….,._~ 5_;._; – •. i:. :.–::- .,..,,,,,…. — .
Identify the Recall Schedule
Describe the recall schedule for notifications.:
Customer notification wifl be made by first class mail using Daimler Trucks North America records to
determine the customers affected.
Planned Dealer Notification Begin Date:
Planned Dealer Notification End Date:
Planned Owner Notification Begin Date:
Planned Owner Notification End Date:
12/02/2019
12/02/2019
12/02/2019
12/02/2019
Manufacture’s identification code for this recall (if applicable): FL-832
DTNA Representative;
Andy Jones
Manager
Compliance and Regulatory Affairs

*************************************************************

1
Memorandum
To: All TBB Dealers
From: Michael Stotler
Date: 3/17/2020
Re: FL832 Knee impact recall update
FL832 Knee impact recall update
We are close to releasing this recall on DTNA Connect and ahead of the release;
we are beginning to ship parts at no charge to dealerships. We will ship 20% of the
parts need to each dealership at this week and will follow that up with another
shipment of 20% at the end of the month. When a dealership requires more parts,
the parts can be ordered by emailing the quantity to tbbseatrecall@daimler.com
There is also a notice inside the shipment informing dealers of the process see
below:
Important Notice
For Recall FL832
We are shipping parts to the dealerships ahead
of the recall release.
March 17, 2020
2
You will receive 40% of the parts needed in
your AOR; we are shipping in 20% increments
After you have received this amount, you can
reorder by emailing
tbbseatrecall@daimler.com
The recall is scheduled to go live very soon for
claiming.
Grouping Seats / Bus SRT / Bus
1 1 to 5 0.5
2 6 to 10 0.8
3 11 to 15 1.4
4 16 to 20 1.8
5 21 to 25 2.2
6 26 plus 2.5
* do not need to do the last row at wall

*************************************************************

The information contained in this letter supercedes and supplements any related policies and procedures in any previously
released bulletins, the Warranty Manual, and/or previously released letters. Failure to read or distribute this letter will not
exempt addressees from compliance with the information contained herein.
Page 1 of 4
Daimler Trucks North America LLC
REF #:
ICI19-062
Effective:
11/20/2019
Release:
11/20/2019
SUBJECT:
TBB FL832 – Interim Recall Notice
This letter is to inform you that an interim recall notice will be sent to affected customers for upcoming recall FL832 ~ TBB SynTec S3B Seat Kneeforms. The interim notices will mail by the end of November. Copies of the notices follow for reference.
This notice is for informational purposes only. There is no action for customers or dealers to take at this time. If customers inquire, please refer them to the interim recall notice and let them know the recall will begin when all preparations are completed.
If you have questions or need further information, contact the Warranty Campaigns Department by submitting an inquiry through the WSC Link on 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
Direct Warranty Customers – U.S. and Canada
Export Distributors
If you have questions about this Letter, please submit your inquiry on the Web using the WSC Link on DTNAConnect
Daimler Trucks
North America LLC
November 2019
FL832
Interim Recall Notice
NHTSA #19V-712
IMPORTANT SAFETY RECALL
See enclosed VIN list
Subject: TBB SynTec S3B Seat Kneeforms
This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.
Daimler Trucks North America LLC, on behalf of its wholly owned subsidiary, Thomas Built Buses, Inc., has decided
that a defect which relates to motor vehicle safety exists on specific Model Year 2015-2020 Thomas Built Buses
Minotour, and Saf-T-Liner EFX/HDX model school buses manufactured August 18, 2014, through August 15, 2019,
with SynTec S3B or S3C seats.
On certain buses equipped with affected seats, specific areas of the seat back may not meet the requirements of
FMVSS 222, part 53.3.2, School Bus Seating and Crash Protection. This may increase the risk of injury to occupants
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. The repair is being validated and parts are being procured. There is no action for you to take at this time. You may continue to operate your vehicle.
The second notice will inform you when the final remedy is available. When you receive the second notice, please contact your authorized Thomas Built Buses dealer to schedule the Recall for your vehicle.
If you have any 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. 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) 3274236 (TTY: (800) 424-9153); or to https://www.safercar.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 Trucks North America LLC
Thomas Built Buses, Inc.
1408 Courtesy Road
High Point, NC 27260
800.547.0712 Phone
Daimler Trucks
North America LLC
November 2019
FL832
Interim Recall Notice
Transport Canada #2019-497
Subject: TBB SynTec S3B Seat Kneeforms
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 be non-compliant with the requirements of the Motor Vehicle Safety Regulations and that the
non-compliance could affect the safety of a person.
Daimler Trucks North America LLC, on behalf of its wholly owned subsidiary, Thomas Built Buses, Inc., has decided
that a defect which relates to motor vehicle safety exists on specific Model Year 2015-2020 Thomas Built Buses
Minotour, and Saf-T-Liner EFX/HDX model school buses manufactured August 18, 2014, through August 15, 2019,
with SynTec S3B or S3C seats.
On certain buses equipped with affected seats, specific areas of the seat back may not meet the requirements of
CMVSS 222, part 53.3.2, School Bus Seating and Crash Protection. This may increase the risk of injury to occupants
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. The repair is being validated and parts are being procured. There is no action for you to take at this time. You may continue to operate your vehicle.
The second notice will inform you when the final remedy is available. When you receive the second notice, please contact your authorized Thomas Built Buses 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
We apologize for any inconvenience this may have caused. If you have any 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. If you have a complaint, you may wish to submit a complaint to Transport Canada road safety, 80 rue Noel, Gatineau,
Quebec J8Z 0A1 or call (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 Trucks North America LLC
Thomas Built Buses, Inc.
1408 Courtesy Road
High Point, NC 27260
336.889.4871 Phone
Daimler Trucks
North America LLC
Novembre 2019
FL832
Avis de rappel intermédiaire
Transport Canada nº 2019-497
Objet : Genouillères de siège TBB SynTec S3B
Le présent avis vous est envoyé conformément aux exigences de la Loi sur la sécurité automobile. La présente est pour vous informer
que votre véhicule ne respecte peut-être pas les exigences de la réglementation sur la sécurité des véhicules automobiles et que ce
non-respect peut nuire à la sécurité des gens.
Au nom de sa filiale à cent pour cent Thomas Built Buses, Daimler Trucks North America LLC a déterminé
qu’une défectuosité liée à la sécurité des véhicules automobiles est présente sur certains Autobus Thomas Built 2015-2020, modèles
Minotour et certains modèles d’autobus scolaires Saf-T-Liner EFX/HDX construits entre le 18 août 2014 et le 15 août 2019
et équipés de sièges SynTec S3B ou S3C.
Sur certains autobus équipés des sièges concernés, certaines zones du dossier peuvent être non conformes aux exigences de la norme
NSVAC 222, section 53.3.2, Sièges pour passager d’autobus scolaire et protection en cas de collision. Cela peut accroître le risque de blessures occasionnées aux occupants
lors d’une collision.
Ceci est le premier de deux avis que vous recevrez à ce sujet. Le but de cette lettre est de vous informer d’un rappel à venir pour corriger le problème mentionné ci-dessus. La réparation est en cours de validation et les pièces sont en cours d’approvisionnement. Vous n’avez pas d’action à prendre pour l’instant. Vous pouvez continuer à faire utiliser le véhicule.
Le deuxième avis vous informera quand le remède final sera disponible. Lorsque vous recevrez le deuxième avis, veuillez contacter votre concessionnaire Thomas Built Buses autorisé pour programmer le rappel pour votre véhicule.
Si vous n’êtes pas le propriétaire du ou des véhicules dont les numéros d’identification apparaissent sur l’avis de rappel, veuillez retourner l’avis au Service des campagnes de garanties avec tous les renseignements dont vous disposez qui pourraient nous aider à identifier le propriétaire actuel. Le loueur est également tenu par la loi fédérale de faire parvenir cet avis au locataire dans les 10 jours. Si vous êtes un fabricant secondaire, la loi fédérale exige que vous fassiez suivre cet avis à vos distributeurs et détaillants dans les cinq ouvrables.
Nous nous excusons pour tout inconvénient que cela aurait pu causer. Si vous avez des questions au sujet de ce rappel, veuillez contacter le Département des Services de garantie au (800) 547-0712, du lundi au vendredi de 7 h à 16 h, heure du Pacifique. Si vous avez des motifs de plainte, vous pouvez soumettre cette dernière à l’adresse suivante Transport Canada – Sécurité routière, au 80 rue Noël, Gatineau,
Québec J8Z 0A1, ou composer le 1-800-333-0510.
Nous sommes désolés pour tout inconvénient pouvant résulter de cette activité, mais nous sommes certains que vous comprenez notre intérêt dans la sécurité des véhicules motorisés.
SERVICE DES CAMPAGNES DE GARANTIE
Pièce jointe
Daimler Trucks North America LLC
Thomas Built Buses, Inc.
1408 Courtesy Road
High Point, NC 27260, États-Unis
Téléphone : (336) 889-4871

28 Affected Products

Vehicles

MAKE	MODEL	YEAR

THOMAS BUILT BUSES	MINOTOUR	2014-2020
THOMAS BUILT BUSES	SAF-T-LINER C2	2014-2020
THOMAS BUILT BUSES	SAF-T-LINER EFX	2014-2020
THOMAS BUILT BUSES	SAF-T-LINER HDX	2014-2020

16 Associated Documents

Manufacturer Notices(to Dealers,etc)

RCMN-19V712-6930.pdf 111.047KB

Taking too long?

Reload document

Summary

Remedy

Notes

Recall Campaign

Daimler Trucks North America LLC

Subject: TBB SynTec S3B/S3C Seat Kneeforms

General Information

Replacement Parts

Labor Allowance

Claims for Credit

Copy of Notice to Owners

Subject: TBB SynTec S3B/S3C Seat Kneeforms

Reimbursement to Customers for Repairs Performed Prior to Recall

Work Instructions

Subject: TBB SynTec S3B/S3C Seat Kneeforms

Impact Material (Foam Insert) Installation

Daimler Trucks North America LLC

IMPORTANT SAFETY RECALL

Subject: TBB SynTec S3B Seat Kneeforms

Reimbursement to Customers for Repairs Performed Prior to Recall

Daimler Trucks North America LLC

IMPORTANT SAFETY RECALL

Subject: TBB SynTec S3B Seat Kneeforms

FAQ

Latest Recalls Documents

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Daimler Trucks
North America LLC

Daimler Trucks
North America LLC

Daimler Trucks
North America LLC