Turn Signal Visibility – 2015-2023 Mack GU & GR

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pg. 1 November 23, 2022 Acting Administrator, Ann Carlson National Highway Traffic Safety Administration, 1200 New Jersey Ave., SE Washington, DC 20590; RE: 22V819, Petition for Inconsequential Non-compliance, MVSS 108, 6.4.3 Turn Signal Visibility Dear Ms. Carlson On behalf of Mack Trucks LLC, I respectfully submit this petition for your consideration. I appreciate yours and NHTSA’s consideration of this matter. A copy of this document has been uploaded to the recall portal under 22V819. Best regards, Emily Bishop Director, Vehicle Certification & Compliance Complete Vehicle, USA emily.bishop@volvo.com +1 301 5735972 7900 National Service Rd | Greensboro, NC, 27409 | USA | Volvo Group pg. 2 Information Required per 49CFR556 Full Name of Applicants: Mack Trucks LLC. 7825 National Service Road, Greensboro, NC 27409-9416 Nature of Business: Vehicle Manufacture, Corporation State: North Carolina Description of motor vehicles or items of motor vehicle equipment involved: • Brand: Mack • Models: Certain 2015-2023 GU/GR Class 8 trucks and truck-tractors • Manufacturing Dates: September 1, 2014-September 30, 2022 with different axle position and frame extension configurations. • Total number of vehicles involved: 27544 Description of non-compliance: This is issue is relative to the MVSS 108, 6.4.3 turn signal visibility. Based upon different axle positions and frame extension configurations, the forward turn signals on specific vehicles are not compliant with the 45 degree inboard and/or 15 degree downward angle relative to the September 2014 regulation update. S6.4.3 Visibility options. A manufacturer must certify compliance of each lamp function to one of the following visibility requirement options, and it may not thereafter choose a different option for that vehicle:(a) Lens area option. When a vehicle is equipped with any lamp listed in Table V-b each such lamp must provide not less than 1250 sq mm of unobstructed effective projected luminous lens area in any direction throughout the pattern defined by the corner points specified in Table V-b for each such lamp; or(b) Luminous intensity option. When a vehicle is equipped with any lamp listed in Table V-c each such lamp must provide a luminous intensity of not less than that specified in Table V-c in any direction throughout the pattern defined by the corner points specified in Table V-c for each such lamp when measured in accordance with the photometry test requirements of this standard. Table V-b—Visibility Requirements of Installed Lighting Devices—Lens Area Visibility Option Lighting device Corner points1 2 Required visibility pg. 3 Motorcycle All other Turn signal lamp 3 15° UP-20° IB 15° UP-45° OB 15° UP-45° IB 15° UP-45° OB Unobstructed minimum 15° DOWN-20° IB 15° DOWN-45° OB 15° DOWN-45° IB 15° DOWN-45° OB effective projected Stop lamp 15° UP-45° RIGHT 4 15° UP-45° LEFT 4 15° UP-45° IB 15° UP-45° OB luminous lens area 15° DOWN-45° RIGHT 4 15° DOWN-45° LEFT 4 15° DOWN-45° IB 15° DOWN-45° OB of 1,250 sq mm in any Taillamp 15° UP-45° RIGHT 5 15° UP-45° LEFT 5 15° UP-45° IB 15° UP-45° OB direction throughout 15° DOWN-45° RIGHT 5 15° DOWN-45° LEFT 5 15° DOWN-45° IB 15° DOWN-45° OB the pattern defined by Parking lamp No Requirement No Requirement 15° UP-45° IB 15° UP-45° OB the specified corner No Requirement No Requirement 15° DOWN-45° IB 15° DOWN-45° OB points. 1 IB indicates an inboard direction (toward the vehicle’s longitudinal centerline) and OB indicates an outboard direction. 2 Where a lamp is mounted with its axis of reference less than 750 mm above the road surface, the vertical test point angles located below the horizontal plane subject to visibility requirements may be reduced to 5° down. 3 Where more than one lamp or optical area is lighted at the front on each side of a multipurpose passenger vehicle, truck, trailer, or bus, of 2032 mm or more overall width, only one such area need comply. 4 If a multiple lamp arrangement is used for a motorcycle stop lamp, the inboard angle for each lamp shall be 10 degrees. 5 If a multiple lamp arrangement is used for a motorcycle tail lamp, the inboard angle for each lamp shall be 45 degrees. pg. 4 Description of the Non-Compliance In 2014, the MVSS regulation was updated for turn signal visibility. The updated regulation includes the requirement that the turn indicator should be visible on 45 degrees inboard and 15 degrees downwards. However, certain vehicle configurations within Volvo Group were not updated accordingly. As a result of an unrelated engineering change, Volvo Group identified that a non-compliance existed on certain vehicles where they were found to not be compliant with MVSS 108,6.4.3 turn signal visibility. The inboard and downward angle of compliance was non-compliant by 8 degrees inboard and 8 degrees downward. Please reference the below table to identify the degree per vehicle. Degrees Model Inboard Downward GU Axle Back 37 15 GR Axle Back 37 15 GU Axle Forward 45 7 GR Axle Forward 45 7 GU Axle Forward Extended Frame Rail 45 7 GR Axle Forward Extended Frame Rail 45 7 Table 1: Degree of non-compliance pg. 5 Illustration 1. GR/GU 7 (illustration 1) is the axle forward configuration of the Granite truck platform: When configured in with a bumper and extended (front) frame it is not compliant with the updated regulation. Illustration 2. GR/GU 8 illustration 2 is the axle back configuration of the Granite truck platform: pg. 6 Period of Exemption Requested: Mack is petitioning that all vehicles in the affected population be exempt from the recall requirements as the non-compliance is inconsequential to motor vehicle safety. Please feel free to contact me if you have any questions. Best regards, Emily Bishop Director, Vehicle Certification & Compliance Complete Vehicle, USA emily.bishop@volvo.com +1 301 5735972 7900 National Service Rd | Greensboro, NC, 27409 | USA | Volvo Group

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 22V-819 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Mack Trucks, Inc. Submission Date : NOV 03, 2022 NHTSA Recall No. : 22V-819 Manufacturer Recall No. : n/a Manufacturer Information : Manufacturer Name : Mack Trucks, Inc. Address : 2100 Mack Boulevard PO Box M Allentown PA 18105-5000 Company phone : 610-709-2131 Population : Number of potentially involved : 27,544 Estimated percentage with defect : 100 % Vehicle Information : Vehicle 1 : 2015-2023 Mack GU/GR Vehicle Type : BUSES, MEDIUM & HEAVY VEHICLES Body Style : OTHER Power Train : DIESEL Descriptive Information : The population was determined based on a study of front turn signal angle visibility. The different axle positions and frame extension configurations were evaluated for the 45 degree inboard and 15 degree downward angle regulation update. The population of vehicles includes trucks built from the effective change of the regulation until our production was corrected. Production Dates : SEP 01, 2014 – SEP 30, 2022 VIN Range 1 : Begin : NR End : NR Not sequential Description of Noncompliance : Description of the Noncompliance : Vehicles are non-compliant with the updates to FMVSS 108, 6.4.3, turn signal visibility. FMVSS 1 : 108 – Lamps, reflective devices, and assoc. Equipment FMVSS 2 : NR Description of the Safety Risk : There is no safety risk. Description of the Cause : Failure to incorporate the changes to FMVSS 108, 6.4.3 into some chassis extensions and hood variations. Identification of Any Warning that can Occur : N/A Involved Components : Part 573 Safety Recall Report 22V-819 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Component Name 1 : Headlamp Component Description : Headlamp assy Component Part Number : 25105806 Supplier Identification : Component Manufacturer Name : Mack Trucks Address : NR NR Country : NR Chronology : During a new project, questions were raised relative to some current hood designs August 3, 2021. Investigation opened, September 20,2021, escalated to Product Safety Working Group for evaluation October 14, 2022 with findings from investigation. Product Safety Working Group meets October 19, 2022 recommends that a non-compliance be raised to Product Safety Committee and that a request of a petition for inconsequential to safety be filed. Product Safety Committee meets October 27, 2022 and makes the decision that noncompliance exists and that a petition for in-consequential noncompliance will be filed. Description of Remedy : Description of Remedy Program : n/a Mack is submitting a request for inconsequential non-compliance petition for consideration. How Remedy Component Differs from Recalled Component : Hood and lighting re-design meets the updated regulation. Identify How/When Recall Condition was Corrected in Production : Production in our manufacturing facilities was corrected effective 22 September, 2022 Recall Schedule : Description of Recall Schedule : n/a Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : NR – NR Part 573 Safety Recall Report 22V-819 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 * NR – Not Reported

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