Steering Gear Assembled Incorrectly – 2021-2022 ENC Axess

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9670 Galena Street. Riverside, CA 92509 Date: 12/22/2022 To: NHTSA From: Mike Gonzales – ENC Quality Manager Subject: Motor Vehicle Safety Recall 22V551 Sheppard Steering Gear As requested per our phone call on 12/14/2022, I have created this letter to share events and status of the Sheppard recall. Due to internal communication errors, I was ill-informed of the requirement of a formal Owner Letter that needs to be sent out to customers on every recall. This being my first recall, I will ensure that measures are set in place to prevent something like this from happening on any future recalls. We filed recall 22V551 on 08/01/2022 and I reached out to our dealers and customers and notified them of the recall (these email communications have been uploaded to our recall portal). Shortly after, we completed the recall and repaired all the suspect units that were at dealer lots and at the customers’ possession – we have reached a 100% remedy rate for the recall. Audit report can be found on page 2 of this letter. The only thing that was omitted was a formal Owner Letter being sent out. Please let me know if you have any questions or requests, hopefully this letter will clear up any concerns in order to activate Quarterly Reports that I can address formally. Sincerely, Eldorado National Co. By: Michael Gonzales Quality Manager (909) 591-9557 cc: Jason Moore – VP/GM Daniel Lewis – Dir. of Service ENC Sheppard Gear status audit findings

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-551 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Eldorado National- California, Inc. Submission Date : JUL 28, 2022 NHTSA Recall No. : 22V-551 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : Eldorado National- California, Inc. Address : 9670 GALENA STREET RIVERSIDE CA 92509 Company phone : 909-591-9557 Population : Number of potentially involved : 14 Estimated percentage with defect : 100 % Vehicle Information : Vehicle 1 : 2021-2022 ENC Axess Vehicle Type : BUSES, MEDIUM & HEAVY VEHICLES Body Style : OTHER Power Train : CNG/LPG Descriptive Information : A small number of steering gears were assembled without the required number of recirculating balls. The recall population was determined by identifying the oldest production lot associated with a gear failure, and including all production from that lot to the date in February 2022 when the improvements in the assembly processes were instituted. Total buses affected are 14. Production Dates : NOV 01, 2021 – JUN 30, 2022 VIN Range 1 : Begin : NR End : NR Not sequential Description of Defect : Description of the Defect : Steering gear was assembled with fewer than the required number of recirculating balls which can lead to a fracture in the steering gear worm-shaft and loss of vehicle steering FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : A steering gear with fewer than the required number of recirculating balls may bind when loads are applied. In some cases, the balls may align on the same side of the gear’s worm-shaft and concentrated loads may cause the gear’s internal parts to fracture resulting in loss of vehicle steering. Loss of steering increases the likelihood of a crash. Description of the Cause : An anomaly in the steering gear recirculating ball insertion operation occurred during assembly. Subsequent rework processes and inspections did not detect Part 573 Safety Recall Report 22V-551 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 the missing recirculating balls. Identification of Any Warning that can Occur : Preceding the internal fracture, the steering may be perceived as strained by the driver. No audible or visual warning is available. Involved Components : Component Name 1 : Sheppard Steering Gear Component Description : Steering Gear Component Part Number : 19202601 Component Name 2 : Sheppard Steering Gear Component Description : Steering Gear Component Part Number : 12005901 Supplier Identification : Component Manufacturer Name : R.H. Sheppard Co., Inc. Address : 101 Philadelphia Street P.O. Box 877 Hanover Pennsylvania 17331-0877 Country : United States Chronology : 2/8/22-Sheppard warranty lab receives a gear built 8/20/2021 with failed worm-shaft. 2/9/22 – warranty lab inspection/disassembly indicates fracture of the worm-shaft and less than the required number of recirculating balls 2/10/22-plant stops production. Additional inspections and process verifications put in place. Clean point is established. Material on hand is inspected and confirmed defect free. Production resumes. (2/10/22 – 5/13/22): review of all warranty from 2015-present indicated no similar failure ever received. engineering tests are performed to understand and to reproduce failure mode. 3/10/2022 – Sheppard contacted vehicle driver for description of event and confirmed no accident or injury, low speed and while backing up. 4/12/22 – Sheppard receives a second gear at incoming shipping facility 5/5/22- Sheppard warranty lab receives/inspects/disassembles the second gear built on 6/26/21 with failed worm-shaft and less than the required number of recirculating balls 5/6/22- The Product Integrity Committee meets for update Part 573 Safety Recall Report 22V-551 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 on the product investigation. 5/13/22 – The Product Integrity Committee meets and recommends submission of a defect report 573. 7/18/22 – REV Group was notified on Sheppard’s recall 22E-047 and began gathering the necessary information and approval to conduct a pass-through recall. Description of Remedy : Description of Remedy Program : Purchasers will identify the unique serial number imprinted on the recalled equipment. A web-based tool is available after August 1, 2022, to vehicle manufactures and their service networks to classify the serial number. Serial numbers will be classified as either suspect and must be replaced or as not suspect and may remain in service. Sheppard assumes cost burden for the remedy being performed. How Remedy Component Differs from Recalled Component : The remedy component was assembled after the recall condition was corrected in production when additional controls were put in place. The remedy component has been verified to have the correct number of recirculating balls. Each remedy component is identifiable by an imprinted unique serial number. Identify How/When Recall Condition was Corrected in Production : On Feb 10, 2022, the recirculating ball insertion process control was enhanced. Additional process controls and inspectors were added to the process to verify that the correct number of recirculating balls in each steering gear. Recall Schedule : Description of Recall Schedule : On Feb 10, 2022, the recirculating ball insertion process control was enhanced. Additional process controls and inspectors were added to the process to verify that the correct number of recirculating balls in each steering gear. Planned Dealer Notification Date : JUL 28, 2022 – AUG 01, 2022 Planned Owner Notification Date : JUL 28, 2022 – AUG 01, 2022 * NR – Not Reported

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