DAIMLER Defect Information Report (Section 573.6} FL-832 Date of Submission: October 2019 Manufacturer: Daimler Trucks North America LLC P.O. BOX 3849 Portland, Oregon 97208 Type of Report: 0 Safety Defect Non-Compliance Vehicle Information Model Yr. Start: With 538 seat: 2015 and with 53C RTR seat: 2014 Model Yr. End: 2020 Make: Thomas Buiit Buses Model: Saf-T-tiner C2, Saf-T-tiner HDX, Saf-T-tiner EFX, and Minotaur Production Dates: Begin: With 538 seat: 08/18/2014 and with 53C RTR seat: 7/5/2013 End: With 538 seat: 08/15/2019 and with 536 RTR seat: 8/15/2019 Descriptive Information: Certain Thomas Built School Buses equipped with Ta: 538 and 53C seats. Number potentially involved: 53,528 Estimated percentage of involve with defect: 50% Defect I Noncompliance Description For this Defect/Noncompliance: Per SynTec 573 ?ling "in the relevant population, certain speci?c areas of the seat back mallf not meet the requirements of 55.3.2 Federal Motor Vehicle Safety Standard 222.? Describe the defect or noncompliance: Per Tec 5 23 filing ?The suspect population of seats were made with styrene blocks that have the potential to not meet the requirement of 35.3.2 Federal Motor Vehicle .fiafetjir Standard 222?. If a noncompliance, provide the applicable 222 55.3.2 Describe the safety risk: Per Tec 5.73 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 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. Tec 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 an 2 of 4 seats tested for lcnee foam impact. DTNA contacted its supplier, SynTec, and Tec 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-supplier issues and other matters potentially contributing to the reported test result. June 2919, DTNA and Tec 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, Tec 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, Tec initiates design change to styrene black 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, Tec concludes that a non-compliance could potentially exist on any 539 and 536 seat in the subject population. September 2019 DTNA with an abundance of caution, decided to conduct a voluntary recall campaign on certain school buses equipped with Tec 538 and 53C seats. October 2019, Tec ojficially notifies DTNA of their 5 73 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. DAIMLER Identify the Recall Schedule Describe the recall schedule for notifications.: Customer noti?cation will be mode by first class mail using Daimler Trucks North America records to determine the customers a?ected. Planned Dealer Noti?cation Begin Date: 12/02/2019 Planned Dealer Noti?cation End Date: 12/02/2019 Planned Owner Noti?cation Begin Date: 12/02/2019 Planned Owner Noti?cation End Date: 12/02/2019 Manufacture?s identi?cation code for this recall (if applicable): FL-832 DTNA Representative; ?aw Andy Jones Manager Compliance and Regulatory Affairs