Ballast Hanger Failure – 2021 Silver Eagle VAST20W Trailer Converter Dollies

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MANUFACTURING COMPANY 5825 NE Skyport Way Portland, OR 97218 (503) 281-0727 (800) 547-6792 (503) 335-2171 Fax silvereaglemfg.com ***IMPORTANT SAFETY RECALL*** July 14, 2022 Name Company Address City, State Zip NHTSA Recall ID 22V472 Your VIN XXXXXXXXXXXXXXXXX through XXXXXXXXXXXXXXXXX Shipping Date: MM/DD/YYY This notice is being sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act. Silver Eagle Manufacturing Co. has decided that a defect exists in your Model Year 2021 VAST-20W Trailer Converter Dollies with the above VINs. ISSUE The galvanized ballast hanger near the rear of the frame may have a brittle failure causing part of the ballast hanger and its counterweights to fall onto the highway. RISK If the galvanized steel ballast hanger breaks in service and allows part of it and the associated ballast weights to fall onto the highway, another vehicle may hit it or swerve to miss the broken parts. Depending on the configuration of the dolly, the broken section, plus ballast weights, could range from 100 to 225 lbs. The trailer converter dolly can operate safely even without the ballast hanger. The fallen part may also affect the trailer the converter dolly is towing if the fallen part damages it, increasing the risk of a crash. WHAT WILL SILVER EAGLE MANUFACTURING CO. DO? Silver Eagle desires for this the replacement of the Ballast Hanger to be at no cost to you. It will ship the replacement parts at no charge to the location of your choice at its expense. It will also pay for the labor to inspect and replace the original hanger. It is estimated that process will take less than one hour and can be performed with common mechanic’s tools. WHAT SHOULD YOU DO? Inspect the ballast hanger for any cracking in the bends of the Ballast Hanger which is under the main frame in the rear of the Converter dolly. Look for cracks in the inside and outside radius of the corners of the hanger. If cracks are found, the dolly should either be removed from service, or the ballast hanger and its weights removed before returning to service. Note: If the ballast hanger and weights are removed, the tongue weight of the dolly will significantly increase affecting the safe manual maneuverability for coupling and uncoupling. Contact Silver Eagle Manufacturing immediately at (800) 547-6792 to place an order for replacement parts and the location(s) you would like for the replacement parts kit(s) to be sent. The kits will include the replacement hanger, mounting fasteners for the ballast plates and hanger, and installation instructions.  The original ballast hangers must be replaced. No evidence of cracking is not an assurance that a brittle failure will not occur in the future.  Do not attempt to reweld the ballast hanger. The material in the defective hangers is brittle and may fail at a later date, and welding on galvanized metal produces hazardous fumes. If parts are not immediately ready for shipment, they should be within 3-4 weeks of your order. WHAT IF YOU NO LONGER OWN OR OPERATE THE VEHICLE? Please provide Silver Eagle Manufacturing with the contact information of the new owner or operator of the Converter Dolly. Federal regulations require that any vehicle lessor receiving this recall notice must forward a copy of this notice to the lessee within ten (10) days. IF YOU HAVE FURTHER QUESTIONS, contact Silver Eagle Manufacturing at (800) 547-6792 and mention this Ballast Hanger Recall. If after attempting to have us remedy the above defective Ballast Hanger without charge to you, there is the option to submit a complaint to the Administrator, National Highway Traffic Safety Administration, 1200 New Jersey Ave., SE., Washington, DC 20590; or call the toll-free Vehicle Safety Hotline at 1-888- 327-4236 (TTY: 1-800-424-9153); or go to http://www.safercar.gov. Sincerely, Alyson Bennett Senior Commercial Sales Silver Eagle Manufacturing 5825 NE Skyport Way Portland, OR 97218 Direct: (503)335-2137 [email protected]

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-472 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Silver Eagle Manufacturing Company Submission Date : JUL 01, 2022 NHTSA Recall No. : 22V-472 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : Silver Eagle Manufacturing Company Address : 5825 NE Skyport Way Portland OR 97218-1249 Company phone : 800-547-6792 Population : Number of potentially involved : 146 Estimated percentage with defect : 100 % Vehicle Information : Vehicle 1 : 2021-2021 Silver Eagle VAST20W Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : A customer sent pictures of their galvanized trailer converter dolly with the center section of their Ballast Hanger (Counterweight) missing. Shortly afterward they found a second unit with one side broken but nothing was missing. We received the two different hangers plus an unbroken one for analysis. Through metallurgical work, and review of metal certifications, it was determined that we had received a substitute material (different from what was ordered. This metal was susceptible to hydrogen embrittlement during the picking and galvanizing process. Ungalvanized ballast hangers from this material are not embrittled and have proper mechanical strength. There are 146 galvanized ballast hangers that were produced and need to be replaced. 17 of these were for parts orders for the same customer. There are a total of 5 customers with ballast hangers that need to be replaced. All Trailer Converter Dollies are Model VAST, model year 2021. The parts orders may have been put on different model years, or still in the customers inventory. Production Dates : AUG 10, 2020 – MAR 29, 2021 VIN Range 1 : Begin : 1U3JX101XMBL21110 End : 1U3JX1013MBJ21301 ✔ Not sequential Description of Defect : Description of the Defect : The ballast hanger near the rear of the frame may have a brittle failure causing part of the ballast hanger and its counterweights to fall onto the highway. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : If the galvanized steel ballast hanger breaks in service, and allows part of it Part 573 Safety Recall Report 22V-472 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Description of the Safety Risk : and the associated ballast weights to fall onto the highway, another vehicle may hit it or swerve to miss the broken parts. Depending on the configuration of the dolly, the broken section, plus ballast weights, could range from 100 to 225 lbs. The trailer converter dolly can operate safely even without the ballast hanger. The fallen part may also affect the trailer the converter dolly is towing if the fallen part damages it. Description of the Cause : Embrittlement of AISI 1018 steel through the pickling and galvanizing process. Material was supposed to be ASTM A572-50. Identification of Any Warning that can Occur : The galvanized ballast hanger may show cracking in the bended section where failures have occurred. A visual inspection of the ballast hanger can be readily performed with the naked eye. Involved Components : Component Name 1 : Ballast Hanger Component Description : HANGER, BALLAST, 61#, UNDER TANK, VAII, GALV Component Part Number : 18781G Supplier Identification : Component Manufacturer Name : Silver Eagle Manufacturing Company Address : 5825 NE Skyport Way Portland Oregon 97218 Country : United States Chronology : April 8, 2022 Southeastern Freightlines informed us they had discovered a trailer Converter dolly with the missing section of the ballast hanger and its counterweight. Silver Eagle sent replacement parts and asked for the failed part to be sent back for analysis. April 11, 2022 Southeastern Freightlines discovered a second ballast hanger with failure on just one side. No parts were missing or had fallen onto the road. This hanger was removed and sent to Silver Eagle for inspection. Additionally, Silver Eagle asked for an unbroken ballast hanger for analysis from the same build of galvanized trailer converter dollies. April 11, 2022 Silver Eagle begins internal review of material and processes as possible causes while waiting for failed components to arrive for analysis. April 13, 2022 failed parts arrive from customer; they appear to have brittle failures. Silver Eagle performs an Part 573 Safety Recall Report 22V-472 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 internal flattening test to test galvanized ballast hangers in inventory. The part from inventory passes. April 14, 2022 consulting engineers are contacted for quotes and availability to conduct analysis of the failed parts. Lisin Metallurgical Services is chosen for analysis and metallurgy testing. June 17, 2022 final report is received by Lisin Metallurgical. Reports suggest embrittled material and fatigue failure. June 24, Silver Eagle determines this to be a safety concern from the batch of parts made form 1018 steel and begins to perform process to specifically identify ballast hangers made from this material and then galvanized. Description of Remedy : Description of Remedy Program : Silver Eagle will pay for parts, freight and labor to replace potential defective parts. How Remedy Component Differs from Recalled Component : To be determined Identify How/When Recall Condition was Corrected in Production : As of 3-29-2021 all the 1018 steel had been consumed and other production of ballast hangers had resumed using the proper material – A572-50. Recall Schedule : Description of Recall Schedule : Curtesy notifications have begun and official notification will commence after NHTSA approval of notification letter. Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : JUL 01, 2022 – JUL 22, 2022 * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-472 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Silver Eagle Manufacturing Company Submission Date : JUL 14, 2022 NHTSA Recall No. : 22V-472 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : Silver Eagle Manufacturing Company Address : 5825 NE Skyport Way Portland OR 97218-1249 Company phone : 800-547-6792 Population : Number of potentially involved : 146 Estimated percentage with defect : 100 % Vehicle Information : Vehicle 1 : 2021-2021 Silver Eagle VAST20W Vehicle Type : TRAILERS Body Style : OTHER Power Train : NR Descriptive Information : A customer sent pictures of their galvanized trailer converter dolly with the center section of their Ballast Hanger (Counterweight) missing. Shortly afterward they found a second unit with one side broken but nothing was missing. We received the two different hangers plus an unbroken one for analysis. Through metallurgical work, and review of metal certifications, it was determined that we had received a substitute material (different from what was ordered. This metal was susceptible to hydrogen embrittlement during the picking and galvanizing process. Ungalvanized ballast hangers from this material are not embrittled and have proper mechanical strength. There are 146 galvanized ballast hangers that were produced and need to be replaced. 17 of these were for parts orders for the same customer. There are a total of 5 customers with ballast hangers that need to be replaced. All Trailer Converter Dollies are Model VAST, model year 2021. The parts orders may have been put on different model years, or still in the customers inventory. Production Dates : AUG 10, 2020 – MAR 29, 2021 VIN Range 1 : Begin : 1U3JX101XMBL21110 End : 1U3JX1013MBJ21301 ✔ Not sequential Description of Defect : Description of the Defect : The ballast hanger near the rear of the frame may have a brittle failure causing part of the ballast hanger and its counterweights to fall onto the highway. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : If the galvanized steel ballast hanger breaks in service, and allows part of it Part 573 Safety Recall Report 22V-472 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Description of the Safety Risk : and the associated ballast weights to fall onto the highway, another vehicle may hit it or swerve to miss the broken parts. Depending on the configuration of the dolly, the broken section, plus ballast weights, could range from 100 to 225 lbs. The trailer converter dolly can operate safely even without the ballast hanger. The fallen part may also affect the trailer the converter dolly is towing if the fallen part damages it. Description of the Cause : Embrittlement of AISI 1018 steel through the pickling and galvanizing process. Material was supposed to be ASTM A572-50. Identification of Any Warning that can Occur : The galvanized ballast hanger may show cracking in the bended section where failures have occurred. A visual inspection of the ballast hanger can be readily performed with the naked eye. Involved Components : Component Name 1 : Ballast Hanger Component Description : HANGER, BALLAST, 61#, UNDER TANK, VAII, GALV Component Part Number : 18781G Supplier Identification : Component Manufacturer Name : Silver Eagle Manufacturing Company Address : 5825 NE Skyport Way Portland Oregon 97218 Country : United States Chronology : April 8, 2022 Southeastern Freightlines informed us they had discovered a trailer Converter dolly with the missing section of the ballast hanger and its counterweight. Silver Eagle sent replacement parts and asked for the failed part to be sent back for analysis. April 11, 2022 Southeastern Freightlines discovered a second ballast hanger with failure on just one side. No parts were missing or had fallen onto the road. This hanger was removed and sent to Silver Eagle for inspection. Additionally, Silver Eagle asked for an unbroken ballast hanger for analysis from the same build of galvanized trailer converter dollies. April 11, 2022 Silver Eagle begins internal review of material and processes as possible causes while waiting for failed components to arrive for analysis. April 13, 2022 failed parts arrive from customer; they appear to have brittle failures. Silver Eagle performs an Part 573 Safety Recall Report 22V-472 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 internal flattening test to test galvanized ballast hangers in inventory. The part from inventory passes. April 14, 2022 consulting engineers are contacted for quotes and availability to conduct analysis of the failed parts. Lisin Metallurgical Services is chosen for analysis and metallurgy testing. June 17, 2022 final report is received by Lisin Metallurgical. Reports suggest embrittled material and fatigue failure. June 24, Silver Eagle determines this to be a safety concern from the batch of parts made form 1018 steel and begins to perform process to specifically identify ballast hangers made from this material and then galvanized. Description of Remedy : Description of Remedy Program : Silver Eagle will pay for parts, freight and labor to replace potential defective parts. How Remedy Component Differs from Recalled Component : Each ballast hanger will have “CAMPAIGNED” on each side for easy visual inspection. Identify How/When Recall Condition was Corrected in Production : As of 3-29-2021 all the 1018 steel had been consumed and other production of ballast hangers had resumed using the proper material – A572-50. Recall Schedule : Description of Recall Schedule : Curtesy notifications have begun and official notification will commence after NHTSA approval of notification letter. Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : JUL 01, 2022 – JUL 22, 2022 * NR – Not Reported

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