Befiliel
a fal iD -E Ki l | is PO Box 1146 Winkler, Manitoba = T 204-325-4345 lodeking.com
135 Canada Street Canada R6W 4B2 F 204-325-5369 -

14 April, 2021

Mr. Jeremy Hamilton

Head of Recalls

Defect Investigations and Recalls Division
Motor Vehicles Safety

Transport Canada

80 Noel Street

Gatineau, QC J8Z 0A1

Via email: [email protected]
Re: Notice of Defect and Recall Campaign
Dear Mr. Hamilton;

Please accept this letter as our notification to Transport Canada that we are initiating a
campaign to recall and correct a defect found with the steering mechanism on the self-
steering axle of 122 semi-trailers manufactured by Lode King Industries. Details are as
follows:

a. The name of the company giving notice is:
Triple E Canada Ltd.
D.B.A. Lode King Industries
Box 1146
135 Canada Street
Winkler, MB R6W 4B2
Phone (204) 325-4345

b. The defective axle has been designed and supplied to Lode King Industries by
Dexter Axle Company. They have assigned their campaign number SBOOSR to this
effort. We have not assigned our own internal recall campaign number. Instead, we will
use your Transport Canada Recall designation as our identifier as soon as you assign
one for this campaign.

C. All of the affected trailers are the Lode King make. The individual model
designation for each in included in the accompanying Excel file — most of these trailers
are flat deck models. The individual VIN for each unit is also provided in the
accompanying Excel file.

Division of Triple E Canada Ltd.
Bie
i fal DI -E K. f | IN is PO Box 1146 Winkler, Manitoba = T 204-325-4345 lodeking.com
135 Canada Street Canada R6W 4B2 F 204-325-5369 _

d. All of the vehicles affected by this recall are semi-trailers manufactured by Lode
King Industries during the period from July, 2017 through December, 2019. The model
year information is also included in the accompanying Excel file.

e. There are 122 semi-trailers included in this recall campaign. These trailers are
built in three and four axle configurations. All of these trailers have been sold in Canada
to Canadian customers.

f. At this point we must assume that all of these trailers have the defect.

g. The nature of this defect relates to the bolts used to secure the steering arm onto
the steering knuckle of this self-steering axle. In certain circumstances it is possible to
overload these bolts, causing them to fail catastrophically. In that event, the steering
linkage may come loose from the trailer. Should this occur, the steering function for this
axle would no longer be controlled.

h. This defect affects the steering arm connected to the steering linkage on the self-
steering lift axle of these semi-trailers.

i. We would refer you to the Dexter information to understand the genesis of this
defect, as per the attached letter from Dexter.

j. Dexter first brought this issue to our attention with their Service Bulletin SBOO9,
dated 28 October, 2019. This bulletin was revised and renamed as SBOOOR, dated 4
December, 2019. To date we have had three (3) units that failed in this way, while in
service. We began performing this corrective action as soon as Dexter identified the
problem and solution. To date we have applied the initial SBOO9 corrective action to 16
of the affected 122 trailers. Following the issuance of SBOO9R we have applied that
corrective action to an additional 29 units.

k. The potential safety risk due to this non-compliance would relate to the steering
linkage coming free from the trailer while travelling on the highway. If this linkage were
to come free there is also a risk that the vehicle may go out of control with the self-
steering axle free to steer in an uncontrolled manner, potentially leading to a crash.

I. The corrective action for this non-compliance is outlined in the Dexter SBOO9R
Service Bulletin. The bolts will be inspected to ensure they are still intact and properly
torqued. Then welds are added to further secure the steering arm to the steering
knuckle. This work will be accomplished through our dealer network.

m. Other than inspecting these bolts to ensure they are intact, it seems there is little
else that can be done to minimize the risk in advance. Simply being aware of this
potential risk will, hopefully, prompt customer to address this need quickly.

n. We anticipate sending out the customer notification letters within the next two
weeks, as soon as you assign the Recall Campaign number and give the go ahead.

Division of Triple E Canada Ltd.
Beli
Z i iD -E K Z ae is PO Box 1146 Winkler, Manitoba = T 204-325-4345 lodeking.com
135 Canada Street Canada R6W4B2 = F_ 204-325-5369 _

Our point of contact here at Lode King will be the undersigned, Director of Engineering.
We look forward to working with you to swiftly address this issue and get this corrective
action in place.

Yours truly,

Lode King Industries
D LapMale Pty

D. Roy MacLean, P.Eng.
Director of Engineering

Division of Triple E Canada Ltd.