FL843 – Insufficient Passenger Protection – 2011-2021 Thomas Built Saf-T Liner HDX School Buses

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Defect / Noncompliance Information Report (Section 573.6) FL-843 Date of Submission: 08/10/2022 Manufacturer: Daimler Truck North America LLC P.O. BOX 3849 Portland, Oregon 97208 Type of Report: ⃝ Safety Defect X Non-Compliance Vehicle Information Model Yr. Start: 2011 Model Yr. End: 2021 Make: Thomas Built Buses Model: Saf-T-Liner HDX Production Dates: Begin: 10/21/2009 End: 12/16/2019 Descriptive Information: Certain Saf-T-Liner HDX School Buses built with a wall mounted barrier at the 1st rafter on the passenger side manufactured within the above dates. Basis for Determination of the Recall Population: All HDX school buses built with wall mounted barrier at the first rafter on passenger side after -10/21/2009, when FMVSS 571.222 changed school bus barrier requirements. Number potentially involved: 7601 Estimated percentage of involved with defect: 100% Defect / Noncompliance Description For this Defect/Noncompliance: Describe the defect or noncompliance: On the affected school buses, the forward barrier was determined not to meet the requirements of Federal Motor Vehicle Safety Standard (FMVSS) 222, S5.2.3: Barrier performance forward. Describe the safety risk: In the affected population, the forward barrier was determined not to meet the requirements of S5.2.3 of Federal Motor Vehicle Safety Standard (FMVSS) 222. In the event of a crash, if the occupant contacts the barrier they may experience higher impact than intended, which may result in injury to the occupant. There have been no reported injuries or accidents related to this defect. Identify any warning which can precede or occur: If applicable, identify the manufacture of the defective or noncompliant component.: Involved Components Component Name: Wall Mounted Barrier Component Description: Wall Mount Barrier High Back Foam Component Part Number: 159527, 159528, 159529 NOTE: If a Component that contains the defect or noncompliance was manufactured by a different manufacturer from the reporting manufacturer, list the following: Component’s country of origin: __________________ Business address: __________________ Business telephone number: __________________ Chronology of Defect / Noncompliance Determination Provide the chronology of events leading up to the defect decision or test data for the noncompliance decision: October 30, 2019, NHTSA notified DTNA of potential noncompliance with FMVSS 222, S5.2.3: Barrier performance forward relating to certain barriers equipped on the Saf-T-Liner HDX School Buses. Based on the information provided by NHTSA’s testing, DTNA began to investigate the issue to evaluate the potential noncompliance and to determine the scope and establish the potentially affected population. November 2019 DTNA requested a visit to NHTSA’s test facility to review findings. On December 11, 2019, DTNA visited the NHTSA test facility to review test procedure and findings with NHTSA. On December 17, 2019, DTNA determined that a non-compliance exists on certain vehicles built with the suspect barrier mounted at the 1st rafter on the passenger side. The issue was that a purely aesthetic piece of foam changed the technicalities of how structural testing is performed, resulting in barrier with the foam not passing the amended FMVSS 222, S5.2.3 requirement. On January 16, 2020, DTNA submitted a petition seeking exemption from the notification and remedy requirements of 49 U.S.C. 30118 (d) and 49 C.F.R. Part 556 on the basis that a noncompliance with FMVSS 222 is inconsequential as it relates to motor vehicle safety. On or about August 4, 2022, DTNA received notice from NHTSA that petition was not approved. On August 10 2022, DTNA filed the amended DIR to begin the process of recalling those Barriers upon receiving the notification of NHTSA’s determination regarding the petition. I mid-August 2022, DTNA refiled this recall at the request of the agency. Identify the Remedy Describe the defect/noncompliance remedy program, including the manufacture’s plan for reimbursement. Daimler Trucks North America is currently working on a plan for repairs. Repairs will be performed by Daimler Trucks North America authorized service facilities. Details of the reimbursement plan will be included in the owner’s notification letter. Identify the Recall Schedule Describe the recall schedule for notifications.: Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Begin Date: 10/04/2022 Planned Dealer Notification End Date: 10/04/2022 Planned Owner Notification Begin Date: 10/04/2022 Planned Owner Notification End Date: 10/04/2022 Does DTNA plan to file inconsequentiality petition? ⃝ Yes X No Manufacturer’s identification code for this recall (if applicable): FL-843 DTNA Representative; Sam Geser Manager, Compliance and Regulatory Affairs

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Defect / Noncompliance Information Report (Section 573.6) FL-843 Date of Submission: 08/10/2022 Manufacturer: Daimler Truck North America LLC P.O. BOX 3849 Portland, Oregon 97208 Type of Report: ⃝ Safety Defect X Non-Compliance Vehicle Information Model Yr. Start: 2011 Model Yr. End: 2021 Make: Thomas Built Buses Model: Saf-T-Liner HDX Production Dates: Begin: 10/21/2009 End: 12/16/2019 Descriptive Information: Certain Saf-T-Liner HDX School Buses built with a wall mounted barrier at the 1st rafter on the passenger side manufactured within the above dates. Basis for Determination of the Recall Population: All HDX school buses built with wall mounted barrier at the first rafter on passenger side after -10/21/2009, when FMVSS 571.222 changed school bus barrier requirements. Number potentially involved: 7601 Estimated percentage of involved with defect: 100% Defect / Noncompliance Description For this Defect/Noncompliance: Describe the defect or noncompliance: On the affected school buses, the forward barrier was determined not to meet the requirements of Federal Motor Vehicle Safety Standard (FMVSS) 222, S5.2.3: Barrier performance forward. Describe the safety risk: In the affected population, the forward barrier was determined not to meet the requirements of S5.2.3 of Federal Motor Vehicle Safety Standard (FMVSS) 222. In the event of a crash, if the occupant contacts the barrier they may experience higher impact than intended, which may result in injury to the occupant. There have been no reported injuries or accidents related to this defect. Identify any warning which can precede or occur: If applicable, identify the manufacture of the defective or noncompliant component.: Thomas Built Bus manufactured parts Involved Components Component Name: Wall Mounted Barrier Component Description: Wall Mount Barrier High Back Foam Component Part Number: 159527, 159528, 159529 NOTE: If a Component that contains the defect or noncompliance was manufactured by a different manufacturer from the reporting manufacturer, list the following: Component’s country of origin: US Business address: Business telephone number: Chronology of Defect / Noncompliance Determination Provide the chronology of events leading up to the defect decision or test data for the noncompliance decision: October 30, 2019, NHTSA notified DTNA of potential noncompliance with FMVSS 222, S5.2.3: Barrier performance forward relating to certain barriers equipped on the Saf-T-Liner HDX School Buses. Based on the information provided by NHTSA’s testing, DTNA began to investigate the issue to evaluate the potential noncompliance and to determine the scope and establish the potentially affected population. November 2019 DTNA requested a visit to NHTSA’s test facility to review findings. On December 11, 2019, DTNA visited the NHTSA test facility to review test procedure and findings with NHTSA. On December 17, 2019, DTNA determined that a non-compliance exists on certain vehicles built with the suspect barrier mounted at the 1st rafter on the passenger side. The issue was that a purely aesthetic piece of foam changed the technicalities of how structural testing is performed, resulting in barrier with the foam not passing the amended FMVSS 222, S5.2.3 requirement. On January 16, 2020, DTNA submitted a petition seeking exemption from the notification and remedy requirements of 49 U.S.C. 30118 (d) and 49 C.F.R. Part 556 on the basis that a noncompliance with FMVSS 222 is inconsequential as it relates to motor vehicle safety. On or about August 4, 2022, DTNA received notice from NHTSA that petition was not approved. On August 10 2022, DTNA filed the amended DIR to begin the process of recalling those Barriers upon receiving the notification of NHTSA’s determination regarding the petition. I mid-August 2022, DTNA refiled this recall at the request of the agency to supersede 19V899. Identify the Remedy Describe the defect/noncompliance remedy program, including the manufacture’s plan for reimbursement. Daimler Trucks North America is currently working on a plan for repairs. Repairs will be performed by Daimler Trucks North America authorized service facilities. Details of the reimbursement plan will be included in the owner’s notification letter. Identify the Recall Schedule Describe the recall schedule for notifications.: Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Begin Date: 10/04/2022 Planned Dealer Notification End Date: 10/04/2022 Planned Owner Notification Begin Date: 10/04/2022 Planned Owner Notification End Date: 10/04/2022 Does DTNA plan to file inconsequentiality petition? ⃝ Yes X No Manufacturer’s identification code for this recall (if applicable): FL-843 DTNA Representative; Sam Geser Manager, Compliance and Regulatory Affairs

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Defect / Noncompliance Information Report (Section 573.6) FL-843 Date of Submission: 08/10/2022 Manufacturer: Daimler Truck North America LLC P.O. BOX 3849 Portland, Oregon 97208 Type of Report: x Safety Defect X Non-Compliance Vehicle Information Model Yr. Start: 2011 Model Yr. End: 2021 Make: Thomas Built Buses Model: Saf-T-Liner HDX Production Dates: Begin: 10/21/2009 End: 12/16/2019 Descriptive Information: Certain Saf-T-Liner HDX School Buses built with a wall mounted barrier at the 1st rafter on the passenger side manufactured within the above dates. Basis for Determination of the Recall Population: All HDX school buses built with wall mounted barrier at the first rafter on passenger side after -10/21/2009, when FMVSS 571.222 changed school bus barrier requirements. Number potentially involved: 7601 Estimated percentage of involved with defect: 100% Defect / Noncompliance Description For this Defect/Noncompliance: Describe the defect or noncompliance: On the affected school buses, the forward barrier was determined not to meet the requirements of Federal Motor Vehicle Safety Standard (FMVSS) 222, S5.2.3: Barrier performance forward. When 5/8 inch of aesthetic foam was added to seat barriers for styling purposes, FMVSS 222 changed the conditions of the seat barrier test with which the prior seat complied. The amount of energy absorbed by the seat barrier under the revised test did not meet the specification standard 5.2 of 452 joules / person within the first 356 mm of deflection. Describe the safety risk: In the affected population, the forward barrier was determined not to meet the requirements of S5.2.3 of Federal Motor Vehicle Safety Standard (FMVSS) 222. In the event of a crash, if the occupant contacts the barrier they may experience higher impact than intended, which may result in injury to the occupant. There have been no reported injuries or accidents related to this defect. Identify any warning which can precede or occur: If applicable, identify the manufacture of the defective or noncompliant component.: Thomas Built Bus manufactured parts Involved Components Component Name: Wall Mounted Barrier Component Description: Wall Mount Barrier High Back Foam Component Part Number: 159527, 159528, 159529 NOTE: If a Component that contains the defect or noncompliance was manufactured by a different manufacturer from the reporting manufacturer, list the following: Component’s country of origin: US Business address: Business telephone number: Chronology of Defect / Noncompliance Determination Provide the chronology of events leading up to the defect decision or test data for the noncompliance decision: October 30, 2019, NHTSA notified DTNA of potential noncompliance with FMVSS 222, S5.2.3: Barrier performance forward relating to certain barriers equipped on the Saf-T-Liner HDX School Buses. Based on the information provided by NHTSA’s testing, DTNA began to investigate the issue to evaluate the potential noncompliance and to determine the scope and establish the potentially affected population. November 2019 DTNA requested a visit to NHTSA’s test facility to review findings. On December 11, 2019, DTNA visited the NHTSA test facility to review test procedure and findings with NHTSA. On December 17, 2019, DTNA determined that a non-compliance exists on certain vehicles built with the suspect barrier mounted at the 1st rafter on the passenger side. The issue was that a purely aesthetic piece of foam changed the technicalities of how structural testing is performed, resulting in barrier with the foam not passing the amended FMVSS 222, S5.2.3 requirement. On January 16, 2020, DTNA submitted a petition seeking exemption from the notification and remedy requirements of 49 U.S.C. 30118 (d) and 49 C.F.R. Part 556 on the basis that a noncompliance with FMVSS 222 is inconsequential as it relates to motor vehicle safety. On or about August 4, 2022, DTNA received notice from NHTSA that petition was not approved. On August 10 2022, DTNA filed the amended DIR to begin the process of recalling those Barriers upon receiving the notification of NHTSA’s determination regarding the petition. I mid-August 2022, DTNA refiled this recall at the request of the agency to supersede 19V899. Identify the Remedy Describe the defect/noncompliance remedy program, including the manufacture’s plan for reimbursement. Daimler Trucks North America is currently working on a plan for repairs. Repairs will be performed by Daimler Trucks North America authorized service facilities. Details of the reimbursement plan will be included in the owner’s notification letter. Identify the Recall Schedule Describe the recall schedule for notifications.: Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Begin Date: 10/04/2022 Planned Dealer Notification End Date: 10/04/2022 Planned Owner Notification Begin Date: 10/04/2022 Planned Owner Notification End Date: 10/04/2022 Does DTNA plan to file inconsequentiality petition? ⃝ Yes X No Manufacturer’s identification code for this recall (if applicable): FL-843 DTNA Representative; Sam Geser Manager, Compliance and Regulatory Affairs

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Daimler Truck North America LLC November 2022 FL843 Interim Recall Notice NHTSA #22V-634 IMPORTANT SAFETY RECALL See enclosed VIN list Subject: TBB Front Seat Barriers This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act. Daimler Truck North America LLC, on behalf of its wholly owned subsidiary, Thomas Built Buses, Inc., has decided that certain Model Year 2011-2021 Thomas Built Buses Saf-T-Liner HDX model vehicles manufactured October 21, 2009, through November 12, 2019, fail to conform to Federal Motor Vehicle Safety Standard No. 222, “School Bus Passenger Seating and Crash Protection.” In the event of a crash, occupants may collide with the front seat barriers with more force than intended, increasing the risk of injury. 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. You may continue to operate your vehicle. The second notice will inform you when the final, free 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. If you have 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, e-mail address [email protected]. For other concerns, you may contact the Customer Assistance Center at (800) 385-4357. 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 go to http://www.nhtsa.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 Truck North America LLC Thomas Built Buses, Inc. 1408 Courtesy Road High Point, NC 27260 800.547.0712 Phone

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Daimler Truck North America LLC 5BREF #: 1BICI22-046 6BEffective: 2B11/04/22 7BRelease: 3B11/04/22 0BSUBJECT: 4BFL843 – Interim Recall Notice This letter is to inform you that an interim recall notice is being sent to affected customers for recall FL843 ~ TBB Front Seat Barriers. The interim notices will be mailed on 11/08/2022. A copy follows for your reference. This notice is for your information only. There is no action for dealers to take. If customers inquire, please refer them to the interim notice. 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 Thomas Built Buses Dealers – U.S. and Canada Direct Warranty Customers – U.S. and Canada Detroit Diesel Distributors Export Distributors If you have questions about this Letter, please submit your inquiry on the Web using the WSC Link on DTNAConnect Daimler Truck North America LLC November 2022 FL843 Interim Recall Notice NHTSA #22V-634 IMPORTANT SAFETY RECALL See enclosed VIN list Subject: TBB Front Seat Barriers This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act. Daimler Truck North America LLC, on behalf of its wholly owned subsidiary, Thomas Built Buses, Inc., has decided that certain Model Year 2011-2021 Thomas Built Buses Saf-T-Liner HDX model vehicles manufactured October 21, 2009, through December 16, 2019, fail to conform to Federal Motor Vehicle Safety Standard No. 222, “School Bus Passenger Seating and Crash Protection.” In the event of a crash, occupants may collide with the front seat barriers with more force than intended, increasing the risk of injury. 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. You may continue to operate your vehicle. The second notice will inform you when the final, free 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. If you have 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, e-mail address [email protected]. For other concerns, you may contact the Customer Assistance Center at (800) 385-4357. 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 go to http://www.nhtsa.gov. We regret any inconvenience this action may cause but feel certain you understand our interest in motor vehicle safety. WARRANTY CAMPAIGNS DEPARTMENT Enclosure

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-634 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Daimler Trucks North America, LLC Submission Date : SEP 12, 2022 NHTSA Recall No. : 22V-634 Manufacturer Recall No. : FL843 Manufacturer Information : Manufacturer Name : Daimler Trucks North America, LLC Address : 4747 N. Channel Avenue Portland OR 97217-3849 Company phone : 800-745-8000 Population : Number of potentially involved : 7,601 Estimated percentage with defect : 100 % Vehicle Information : Vehicle 1 : 2011-2021 Thomas Built Buses Saf-T-Liner HDX Vehicle Type : BUSES, MEDIUM & HEAVY VEHICLES Body Style : Power Train : NR Descriptive Information : Certain Saf-T-Liner HDX School Buses built with a wall mounted barrier at the 1st rafter on the passenger side manufactured within the above dates. All HDX school buses built with wall mounted barrier at the first rafter on passenger side after -10/21/2009, when FMVSS 571.222 changed school bus barrier requirements. Production Dates : OCT 21, 2009 – DEC 16, 2019 VIN Range 1 : Begin : NR End : NR Not sequential Description of Defect : Description of the Defect : On the affected school buses, the forward barrier was determined not to meet the requirements of Federal Motor Vehicle Safety Standard (FMVSS) 222, S5.2.3: Barrier performance forward. When 5/8 inch of aesthetic foam was added to seat barriers for styling purposes, FMVSS 222 changed the conditions of the seat barrier test with which the prior seat complied. The amount of energy absorbed by the seat barrier under the revised test did not meet the specification standard 5.2 of 452 joules / person within the first 356 mm of deflection. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : In the affected population, the forward barrier was determined not to meet the requirements of S5.2.3 of Federal Motor Vehicle Safety Standard (FMVSS) 222. In the event of a crash, if the occupant contacts the barrier they may experience higher impact than intended, which may result in injury to the occupant. There have been no reported injuries or accidents related to this Part 573 Safety Recall Report 22V-634 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 defect. Description of the Cause : NR Identification of Any Warning that can Occur : NR Involved Components : Component Name 1 : Wall Mounted Barrier Component Description : Wall Mount Barrier High Back Foam Component Part Number : 159527 Component Name 2 : Wall Mounted Barrier Component Description : Wall Mount Barrier High Back Foam Component Part Number : 159528 Component Name 3 : Wall Mounted Barrier Component Description : Wall Mount Barrier High Back Foam Component Part Number : 159529 Supplier Identification : Component Manufacturer Name : Thomas Built Bus Address : NR NR Country : United States Chronology : October 30, 2019, NHTSA notified DTNA of potential noncompliance with FMVSS 222, S5.2.3: Barrier performance forward relating to certain barriers equipped on the Saf-T-Liner HDX School Buses. Based on the information provided by NHTSA’s testing, DTNA began to investigate the issue to evaluate the potential noncompliance and to determine the scope and establish the potentially affected population. November 2019 Part 573 Safety Recall Report 22V-634 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 DTNA requested a visit to NHTSA’s test facility to review findings. On December 11, 2019, DTNA visited the NHTSA test facility to review test procedure and findings with NHTSA. On December 17, 2019, DTNA determined that a non-compliance exists on certain vehicles built with the suspect barrier mounted at the 1st rafter on the passenger side. The issue was that a purely aesthetic piece of foam changed the technicalities of how structural testing is performed, resulting in barrier with the foam not passing the amended FMVSS 222, S5.2.3 requirement. On January 16, 2020, DTNA submitted a petition seeking exemption from the notification and remedy requirements of 49 U.S.C. 30118 (d) and 49 C.F.R. Part 556 on the basis that a noncompliance with FMVSS 222 is inconsequential as it relates to motor vehicle safety. On or about August 4, 2022, DTNA received notice from NHTSA that petition was not approved. On August 10 2022, DTNA filed the amended DIR to begin the process of recalling those Barriers upon receiving the notification of NHTSA’s determination regarding the petition. I mid-August 2022, DTNA refiled this recall at the request of the agency. It will supersede 19V899. Description of Remedy : Description of Remedy Program : Daimler Trucks North America is currently working on a plan for repairs. Repairs will be performed by Daimler Trucks North America authorized service facilities. Details of the reimbursement plan will be included in the owner’s notification letter. How Remedy Component Differs from Recalled Component : NR Identify How/When Recall Condition was Corrected in Production : NR Recall Schedule : Description of Recall Schedule : Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Date : OCT 04, 2022 – OCT 04, 2022 Planned Owner Notification Date : OCT 04, 2022 – OCT 04, 2022 * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-634 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Daimler Trucks North America, LLC Submission Date : AUG 19, 2022 NHTSA Recall No. : 22V-634 Manufacturer Recall No. : FL843 Manufacturer Information : Manufacturer Name : Daimler Trucks North America, LLC Address : 4747 N. Channel Avenue Portland OR 97217-3849 Company phone : 800-745-8000 Population : Number of potentially involved : 7,601 Estimated percentage with defect : 100 % Vehicle Information : Vehicle 1 : 2011-2021 Thomas Built Buses Saf-T-Liner HDX Vehicle Type : BUSES, MEDIUM & HEAVY VEHICLES Body Style : Power Train : NR Descriptive Information : Certain Saf-T-Liner HDX School Buses built with a wall mounted barrier at the 1st rafter on the passenger side manufactured within the above dates. All HDX school buses built with wall mounted barrier at the first rafter on passenger side after -10/21/2009, when FMVSS 571.222 changed school bus barrier requirements. Production Dates : OCT 21, 2009 – DEC 16, 2019 VIN Range 1 : Begin : NR End : NR Not sequential Description of Defect : Description of the Defect : On the affected school buses, the forward barrier was determined not to meet the requirements of Federal Motor Vehicle Safety Standard (FMVSS) 222, S5.2.3: Barrier performance forward. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : In the affected population, the forward barrier was determined not to meet the requirements of S5.2.3 of Federal Motor Vehicle Safety Standard (FMVSS) 222. In the event of a crash, if the occupant contacts the barrier they may experience higher impact than intended, which may result in injury to the occupant. There have been no reported injuries or accidents related to this defect. Description of the Cause : NR Identification of Any Warning that can Occur : NR Part 573 Safety Recall Report 22V-634 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Involved Components : Component Name 1 : Wall Mounted Barrier Component Description : Wall Mount Barrier High Back Foam Component Part Number : 159527 Component Name 2 : Wall Mounted Barrier Component Description : Wall Mount Barrier High Back Foam Component Part Number : 159528 Component Name 3 : Wall Mounted Barrier Component Description : Wall Mount Barrier High Back Foam Component Part Number : 159529 Supplier Identification : Component Manufacturer Name : NR Address : NR NR Country : NR Chronology : October 30, 2019, NHTSA notified DTNA of potential noncompliance with FMVSS 222, S5.2.3: Barrier performance forward relating to certain barriers equipped on the Saf-T-Liner HDX School Buses. Based on the information provided by NHTSA’s testing, DTNA began to investigate the issue to evaluate the potential noncompliance and to determine the scope and establish the potentially affected population. November 2019 DTNA requested a visit to NHTSA’s test facility to review findings. On December 11, 2019, DTNA visited the NHTSA test facility to review test procedure and findings with NHTSA. On December 17, 2019, DTNA determined that a non-compliance exists on certain vehicles built with the suspect barrier mounted at the 1st rafter on the passenger side. The issue was that a purely aesthetic piece of foam changed the technicalities of how structural testing is performed, resulting in barrier with the foam not passing the amended FMVSS 222, S5.2.3 requirement. On January 16, 2020, DTNA submitted a petition seeking exemption from the notification and remedy requirements of 49 U.S.C. 30118 (d) and 49 C.F.R. Part 556 on the basis that a noncompliance with Part 573 Safety Recall Report 22V-634 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 FMVSS 222 is inconsequential as it relates to motor vehicle safety. On or about August 4, 2022, DTNA received notice from NHTSA that petition was not approved. On August 10 2022, DTNA filed the amended DIR to begin the process of recalling those Barriers upon receiving the notification of NHTSA’s determination regarding the petition. I mid-August 2022, DTNA refiled this recall at the request of the agency. It will supersede 18V899 Description of Remedy : Description of Remedy Program : Daimler Trucks North America is currently working on a plan for repairs. Repairs will be performed by Daimler Trucks North America authorized service facilities. Details of the reimbursement plan will be included in the owner’s notification letter. How Remedy Component Differs from Recalled Component : NR Identify How/When Recall Condition was Corrected in Production : NR Recall Schedule : Description of Recall Schedule : Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Date : OCT 04, 2022 – OCT 04, 2022 Planned Owner Notification Date : OCT 04, 2022 – OCT 04, 2022 * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-634 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Daimler Trucks North America, LLC Submission Date : SEP 06, 2022 NHTSA Recall No. : 22V-634 Manufacturer Recall No. : FL843 Manufacturer Information : Manufacturer Name : Daimler Trucks North America, LLC Address : 4747 N. Channel Avenue Portland OR 97217-3849 Company phone : 800-745-8000 Population : Number of potentially involved : 7,601 Estimated percentage with defect : 100 % Vehicle Information : Vehicle 1 : 2011-2021 Thomas Built Buses Saf-T-Liner HDX Vehicle Type : BUSES, MEDIUM & HEAVY VEHICLES Body Style : Power Train : NR Descriptive Information : Certain Saf-T-Liner HDX School Buses built with a wall mounted barrier at the 1st rafter on the passenger side manufactured within the above dates. All HDX school buses built with wall mounted barrier at the first rafter on passenger side after -10/21/2009, when FMVSS 571.222 changed school bus barrier requirements. Production Dates : OCT 21, 2009 – DEC 16, 2019 VIN Range 1 : Begin : NR End : NR Not sequential Description of Defect : Description of the Defect : On the affected school buses, the forward barrier was determined not to meet the requirements of Federal Motor Vehicle Safety Standard (FMVSS) 222, S5.2.3: Barrier performance forward. FMVSS 1 : NR FMVSS 2 : NR Description of the Safety Risk : In the affected population, the forward barrier was determined not to meet the requirements of S5.2.3 of Federal Motor Vehicle Safety Standard (FMVSS) 222. In the event of a crash, if the occupant contacts the barrier they may experience higher impact than intended, which may result in injury to the occupant. There have been no reported injuries or accidents related to this defect. Description of the Cause : NR Identification of Any Warning that can Occur : NR Part 573 Safety Recall Report 22V-634 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Involved Components : Component Name 1 : Wall Mounted Barrier Component Description : Wall Mount Barrier High Back Foam Component Part Number : 159527 Component Name 2 : Wall Mounted Barrier Component Description : Wall Mount Barrier High Back Foam Component Part Number : 159528 Component Name 3 : Wall Mounted Barrier Component Description : Wall Mount Barrier High Back Foam Component Part Number : 159529 Supplier Identification : Component Manufacturer Name : Thomas Built Bus Address : NR NR Country : United States Chronology : October 30, 2019, NHTSA notified DTNA of potential noncompliance with FMVSS 222, S5.2.3: Barrier performance forward relating to certain barriers equipped on the Saf-T-Liner HDX School Buses. Based on the information provided by NHTSA’s testing, DTNA began to investigate the issue to evaluate the potential noncompliance and to determine the scope and establish the potentially affected population. November 2019 DTNA requested a visit to NHTSA’s test facility to review findings. On December 11, 2019, DTNA visited the NHTSA test facility to review test procedure and findings with NHTSA. On December 17, 2019, DTNA determined that a non-compliance exists on certain vehicles built with the suspect barrier mounted at the 1st rafter on the passenger side. The issue was that a purely aesthetic piece of foam changed the technicalities of how structural testing is performed, resulting in barrier with the foam not passing the amended FMVSS 222, S5.2.3 requirement. On January 16, 2020, DTNA submitted a petition seeking exemption from the notification and remedy requirements of 49 U.S.C. 30118 (d) and 49 C.F.R. Part 556 on the basis that a noncompliance with Part 573 Safety Recall Report 22V-634 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 FMVSS 222 is inconsequential as it relates to motor vehicle safety. On or about August 4, 2022, DTNA received notice from NHTSA that petition was not approved. On August 10 2022, DTNA filed the amended DIR to begin the process of recalling those Barriers upon receiving the notification of NHTSA’s determination regarding the petition. I mid-August 2022, DTNA refiled this recall at the request of the agency. It will supersede 18V899 Description of Remedy : Description of Remedy Program : Daimler Trucks North America is currently working on a plan for repairs. Repairs will be performed by Daimler Trucks North America authorized service facilities. Details of the reimbursement plan will be included in the owner’s notification letter. How Remedy Component Differs from Recalled Component : NR Identify How/When Recall Condition was Corrected in Production : NR Recall Schedule : Description of Recall Schedule : Customer notification will be made by first class mail using Daimler Trucks North America records to determine the customers affected. Planned Dealer Notification Date : OCT 04, 2022 – OCT 04, 2022 Planned Owner Notification Date : OCT 04, 2022 – OCT 04, 2022 * NR – Not Reported

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