Hazard Warning Flashes Too Fast – 2020-2021 Freightliner Cascadia

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Amended Defect Information Report (Section 573.6) FL- 851 Date of Submission: December 23, 2021 Manufacturer: Daimler Trucks North America LLC P.O. BOX 3849 Portland, Oregon 97208 Type of Report: ⃝ Safety Defect X Non-Compliance Vehicle Information Model Yr. Start: 2020 Model Yr. End: 2021 Make: Freightliner Model: New Cascadia Production Dates: Begin: 01/16/2019 End: 03/27/2020 Descriptive Information: On the affected vehicles, during certain Advanced Brake Assist (ABA) events that have progressed to require a full emergency brake application to avoid a collision, the hazard warning lights may activate automatically in the moments immediately before the vehicle comes to a complete stop, and flashes at a rate of 140 flashes per min. Number potentially involved: 24,282 Estimated percentage of involve with defect: 100% Defect / Non-compliance Description For this Defect/Non-compliance: Describe the defect or non-compliance: On the affected vehicles, during certain Advanced Brake Assist (ABA) events that have progressed to require a full emergency brake application to avoid a collision, the hazard warning lights may activate automatically in the moments immediately before the vehicle comes to a complete stop and flashes at a rate of 140 flashes per min. FMVSS 108, requires the hazard warning signal lights to be driver controlled and flashing rate to be between 60-120 flashes per min and that the activation of the hazard warning operating unit be “driver controlled.” If a non-compliance, provide the applicable FMVSS: FMVSS 108 Describe the safety risk: DTNA intends to petition the agency pursuant to 49 CFR 556 for exemption from the notice and remedy provisions of the Safety Act on the grounds that the automatic activation portion of this non-compliance is inconsequential as it relates to motor vehicle safety. The automatic activation of the hazard lamps communicates to other motorists the potential for an impending and possibly severe crash. ABA events that progress to a full emergency braking stage are rare and only occurs after multiple warnings to the driver, which the driver has ignored or to which the driver is unable to respond. These include optical acoustic warning, haptic warning (partial braking) during which time a driver can disengage ABA before the hazard warning signal is automatically activated and begins to flash at 140 flashes per min. The automatic activation of the hazard lamps occurs within the moments (seconds or fractions of a second) before the vehicle (a Class 8 truck with a GVWR of above 50,000 lbs.) employs a significant de-rating event with a force of approximately 1G. The duration of the hazard lamp activation under these conditions lasts a matter of seconds, if the ABA system is able to avert the crash. DTNA has already submitted to NHTSA an inconsequentiality petition regarding the flash rate. Identify any warning, which can precede or occur: ABA events which progress to a full emergency braking stage occurs only after multiple warnings to the driver including auditory and visual warnings, haptic braking which involves partial braking along with auditory and visual warnings. If applicable, identify the manufacture of the defective or noncompliant component: N/A Involved Components Component Name: Detroit Assurance 5.0 Component Description: Advanced Drivers Assistance System (ADAS) Component Part Number: N/A Chronology of Defect / Non-compliance Determination Provide the chronology of events leading up to the defect decision or test data for the non- compliance decision. February 2020, DTNA began an investigation to review all its features related to ABA events as part of a study to develop systems for new trucks. During this study, it was identified that certain features may need further review to ensure the current product met the provisions of FMVSS 108. March 2020 through April 2020, Product validation conducted tests on certain vehicles to identify any potential non-compliance, and an extensive engineering investigation was undertaken to understand all the features of ABA and how they interact together. During this study, it was identified that in certain situations the hazard warning signals flash at a rate of 140 flashes per min. An in-depth review of NHTSA regulations and interpretations related to this issue indicated a potential non-compliance with the flash rate provisions. May 6, 2020, DTNA determined that a non-compliance existed as to the flash rate for the hazard warning lamps and decided to file a Part 573 non-compliance information report and petition for exemption from the notice and remedy provisions of the Safety Act for this issue. DTNA believes that this non-compliance is inconsequential as it relates to motor vehicle safety, as the occurrence will be extremely rare, for a very short duration and does not contribute to confusion or distraction for other motorists. DTNA also recognized that the hazards automatically flash in severe brake events but deemed this not a non-compliance, nor an issue that needed NHTSA approval, based upon the permission granted to GM in essentially similar situations. June 4, 2020, DTNA filed a petition for exemption from notification and remedy provisions of motor vehicle safety act for non-compliance with FMVSS no. 108, lamps, reflective devices and associated equipment. Between early June 2020 to Late July 2020, DTNA communicated with NHTSA, at the agency’s request, regarding DTNA’s non-compliance information report and inconsequentiality petition. DTNA made several verbal updates, presentations and provided evidence and data to support the inconsequentiality petition pertaining to hazard warning signals flashing at 140 flashes per min during certain ABA events that involves full braking. July 13, 2020, upon NHTSA’s request, DTNA amended the inconsequentiality petition to include FMVSS S14.9.3.9.3 – flasher performance requirements as an additional non-compliance basis. Between late August 2021 to late September 2021, DTNA again reviewed the inconsequentiality petition with NHTSA at the agency’s request. At that time, NHTSA advised DTNA to consider automatic activation of the hazard lamps as an additional aspect of the non-compliance analysis. October 4, 2021, DTNA met with NTHSA and presented the company’s basis for why it did not believe that automatic activation of the hazard warning lamps during the course of a severe automatic emergency braking event rose to the level of a non-compliance. DTNA presented, among other things, the severe and limited time frame for the automatic activation of the hazard lamps, the progressive phases of automatic braking required to trigger the hazard lamps and analysis of similar circumstances where the agency had concluded that automatic activation of the hazard lamps was appropriate to communicate a vehicular emergency. DTNA furnished the agency with additional information that it requested in the following weeks. On December 20, 2021, DTNA received a verbal report from NHTSA, which described that the agency views automatic activation of hazard warning signals during an emergency braking event in the DTNA vehicles as a non-compliance. December 22, 2021, based on this feedback from NHTSA, DTNA determined that a non-compliance existed and decided to amend Part 573 non-compliance information report and petition for exemption from the notice and remedy provisions of the Safety Act for this issue. DTNA believes that this non-compliance is inconsequential as it relates to motor vehicle safety, and will supply an inconsequentiality petition for the agency’s consideration. Identify the Remedy Describe the defect/non-compliance remedy program, including the manufacture’s plan for reimbursement. DTNA intends to petition the agency pursuant to 49 CFR 556 for exemption from the notice and remedy provisions of the safety act on the grounds this non-compliance is nonconsequential as it relates to motor vehicle safety. 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: N/A Planned Dealer Notification End Date: N/A Planned Owner Notification Begin Date: N/A Planned Owner Notification End Date: N/A Manufacture’s identification code for this recall (if applicable): FL-851 DTNA Representative; Tiffani Torgeson Manager Compliance and Regulatory Affairs

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Amended Defect Information Report (Section 573.6) FL851 Date of Submission: March 20, 2023 (December 23, 2021) Manufacturer: Daimler Truck North America LLC P.O. BOX 3849 Portland, Oregon 97208 Type of Report: X Safety Defect Non-Compliance Vehicle Information Model Yr. Start: 2020 Model Yr. End: 2021 Make: Freightliner Model: Cascadia Production Dates: Begin: 01/16/2019 End: 03/27/2020 Type: Truck/Tractor Descriptive Information: On the affected vehicles, during certain Advanced Brake Assist (ABA) events that have progressed to require a full emergency brake application to avoid a collision, the hazard warning lights may activate automatically in the moments immediately before the vehicle comes to a complete stop, and flashes at a rate of 140 flashes per min. Number potentially involved: 24,282 Estimated percentage of involve with defect: 100% Defect Description Describe the defect: On the affected vehicles, during certain Advanced Brake Assist (ABA) events that have progressed to require a full emergency brake application to avoid a collision, the hazard warning lights may activate automatically in the moments immediately before the vehicle comes to a complete stop and flashes at a rate of 140 flashes per min. FMVSS 108, requires the hazard warning signal lights to be driver controlled and flashing rate to be between 60-120 flashes per min and that the activation of the hazard warning operating unit be “driver controlled.” If a noncompliance, provide the applicable FMVSS: FMVSS 108 Describe the safety risk: Certain Freightliner Cascadias with DTNA’s ABA system will automatically activate the hazard lamps if the vehicle’s safety system engages in extreme evasive braking, which can increase the risk of a crash for other road users. NHTSA considers the automatic hazard activation in these circumstances, as well as the flash rate at which the hazard lamps’ flash rate, noncompliance under FMVSS 108 Lamps, reflective devices, and associated equipment. Identify any warning, which can precede or occur: ABA events which progress to a full emergency braking stage occurs only after multiple warnings to the driver including auditory and visual warnings, haptic braking which involves partial braking along with auditory and visual warnings. If applicable, identify the manufacture of the defective or noncompliant component: Hazard and Turn Signal Lighting parameters during Active Brake Assist (ABA) Involved Components Component Name: Detroit Assurance 5.0 Component Description: Advanced Drivers Assistance System (ADAS) Component Part Number: NA Supplier Identification: DTNA Component Manufacturer: DTNA Chronology of Noncompliance Determination Provide the chronology of events leading up to the defect decision or test data for the noncompliance decision. February 2020, DTNA began an investigation to review all its features related to ABA events as part of a study to develop systems for new trucks. During this study, it was identified that certain features may need further review to ensure the current product met the provisions of FMVSS 108. March 2020 through April 2020, Product validation conducted tests on certain vehicles to identify any potential non-compliance, and an extensive engineering investigation was undertaken to understand all the features of ABA and how they interact together. During this study, it was identified that in certain situations the hazard warning signals flash at a rate of 140 flashes per min. An in-depth review of NHTSA regulations and interpretations related to this issue indicated a potential non-compliance with the flash rate provisions. May 6, 2020, DTNA determined that a non-compliance existed as to the flash rate for the hazard warning lamps and decided to file a Part 573 non-compliance information report and petition for exemption from the notice and remedy provisions of the Safety Act for this issue. DTNA believes that this non-compliance is inconsequential as it relates to motor vehicle safety, as the occurrence will be extremely rare, for a very short duration and does not contribute to confusion or distraction for other motorists. DTNA also recognized that the hazards automatically flash in severe brake events but deemed this not a non-compliance, nor an issue that needed NHTSA approval, based upon the permission granted to GM in essentially similar situations. June 4, 2020, DTNA filed a petition for exemption from notification and remedy provisions of motor vehicle safety act for non-compliance with FMVSS no. 108, lamps, reflective devices and associated equipment. Between early June 2020 to Late July 2020, DTNA communicated with NHTSA, at the agency’s request, regarding DTNA’s non-compliance information report and inconsequentiality petition. DTNA made several verbal updates, presentations and provided evidence and data to support the inconsequentiality petition pertaining to hazard warning signals flashing at 140 flashes per min during certain ABA events that involves full braking. July 13, 2020, upon NHTSA’s request, DTNA amended the inconsequentiality petition to include FMVSS S14.9.3.9.3 – flasher performance requirements as an additional non-compliance basis. Between late August 2021 to late September 2021, DTNA again reviewed the inconsequentiality petition with NHTSA at the agency’s request. At that time, NHTSA advised DTNA to consider automatic activation of the hazard lamps as an additional aspect of the non-compliance analysis. October 4, 2021, DTNA met with NTHSA and presented the company’s basis for why it did not believe that automatic activation of the hazard warning lamps during the course of a severe automatic emergency braking event rose to the level of a non-compliance. DTNA presented, among other things, the severe and limited time frame for the automatic activation of the hazard lamps, the progressive phases of automatic braking required to trigger the hazard lamps and analysis of similar circumstances where the agency had concluded that automatic activation of the hazard lamps was appropriate to communicate a vehicular emergency. DTNA furnished the agency with additional information that it requested in the following weeks. On December 20, 2021, DTNA received a verbal report from NHTSA, which described that the agency views automatic activation of hazard warning signals during an emergency braking event in the DTNA vehicles as a non-compliance. December 22, 2021, based on this feedback from NHTSA, DTNA determined that a non-compliance existed and decided to amend Part 573 non-compliance information report and petition for exemption from the notice and remedy provisions of the Safety Act for this issue. DTNA believes that this non-compliance is inconsequential as it relates to motor vehicle safety, and will supply an inconsequentiality petition for the agency’s consideration. On March 20, 2023, DTNA received notice of denial of the inconsequentiality petition for noncompliance. Therefore, out of abundance of caution, and per the requirements of Motor Vehicle Safety Act, DTNA amended its Part 573 report in light of the agency’s response. Identify the Remedy Describe the defect/noncompliance remedy program, including the manufacture’s plan for reimbursement. On the affected vehicles, parameters controlling the enablement of hazards flashing automatically at a faster frequency during an ABA Emergency Braking Event will be disabled. Customer notification will be done by first class mail using Daimler Truck North America records to determine the customers affected. Repairs will be performed free of charge by Daimler Truck North America authorized service facilities. Details of the reimbursement plan will be included in the owner’s notification letter. Owners are directed to seek reimbursement through authorized dealers. Identify the Recall Schedule Describe the recall schedule for notifications: Customer notification will be made by first class mail using Daimler Truck North America records to determine the customers affected. Planned Dealer Notification Begin Date: 05/19/2023 Planned Dealer Notification End Date: 05/19/2023 Planned Owner Notification Begin Date: 05/19/2023 Planned Owner Notification End Date: 05/19/2023 Manufacture’s identification code for this recall (if applicable): FL851 DTNA Representative; Tiffani Torgeson Manager, Compliance and Regulatory Affairs

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Daimler Trucks North America, LLC 4747 N. Channel Avenue Portland OR 97217-7699 Phone: 503-745-8000 June 4, 2020 Administrator National Highway Traffic Safety Administration Attention: Recall Management Division 1200 New Jersey Avenue S.E. Washington D.C. 20590 Re: Petition for Exemption from Notification and Remedy Provisions of Motor Vehicle Safety Act for Noncompliance with FMVSS No. 108, Lamps, Reflective Devices and Associated Equipment Daimler Trucks North America (DTNA) has determined that certain vehicles it manufactured do not fully comply with the requirements contained in the Federal Motor Vehicle Safety Standard (FMVSS) 108, “Lamps, Reflective Devices and Associated Equipment”, and has filed a Defect Information Report on May 12, 2020 for a hazard warning signal involved in certain extreme Active Brake Assist (ABA) events. DTNA hereby petitions the National Highway Traffic Safety Administration for an exemption from the notice and remedy requirements of the Motor Vehicle Safety Act, pursuant to 49 U.S.C. §§ 30118(d) and 30120(h), and 49 C.F.R. part 556, because DTNA believes that the noncompliance is inconsequential to motor vehicle safety based upon the following factors: 1. The noncompliance occurs only in extremely rare situations, 2. It occurs only for very short duration, and 3. Even in the cases when it does happen, it helps to reduce potential for rear end collision. Attached are copies of DTNA’s Defect Information Report. In addition, DTNA provides the following information in accordance with 49 C.F.R. § 556.4(b) (3): • Full name and address of applicant: Daimler Trucks North America LLC, 4747 N. Channel Avenue, Portland, OR 97217-7699 • Nature of organization: Limited Liability Company • State or country under laws of which DTNA is organized: Delaware, USA Background Approximately 24,282 Freightliner New Cascadia vehicles (“subject vehicles”) built from Jan 16, 2019 to March 27, 2020 are configured such that, during certain very limited ABA events involving an unusually aggressive full brake application to avoid a collision, the hazard warning signals would flash at a rate of 140 flashes per min lasting less than 3 seconds until the vehicle reaches a complete stop. Hazard warning signal flash rate outside the bandwidth of the standard photometric requirements can be viewed as an impairment of the effectiveness of the hazard warning signal lights, but these on the subject vehicles are rare, short duration, and effective at showing the nature of the unusually aggressive braking. Daimler Trucks North America Andy Jones Manager Compliance and Regulatory Affairs FMVSS 108 S6.1.5.1 Hazard warning signal states that “In all passenger cars, multipurpose passenger vehicles, trucks, and buses, the activation of the vehicular hazard warning signal operating unit must cause to flash simultaneously sufficient turn signal lamps to meet, as a minimum, the turn signal photometric requirements of this standard”. The noncompliance occurs only in extremely rare situations and for very short durations Under certain rare occurrences, during an Emergency Braking (EB) stage of ABA event, if the vehicle is being operated at 20 Km/h or more, hazard warning signal lights are actuated at a flash rate of140 flashes per min. However, this occurs only if the operator fails to disengage the vehicle during the first two stages of an ABA event. With the average EB event only lasting less than 1 second and the maximum observed in millions of miles of recorded data lasting less than 3 seconds, the number of blink cycles between the maximum permissible flash rate and emergency braking flash rate on the subject vehicles is minimal. The EB feature is the most aggressive of three phases of ABA, so it will engage only rarely. This feature will go through three phases of ABA – Optic Acoustic Warning (OAW), Warn (Haptic) Braking (WB/HB), and EB. OAW warns the operator of a possible collision with a pop-up and audio alert only. If the driver does not apply sufficient deceleration by applying service brakes, then the system will intervene with the Warn Braking phase. Warn Braking applies 50% deceleration to the vehicle in order to assist the driver on mitigating a possible collision. If the system deems necessary, it will follow into the emergency braking phase applying maximum braking force to assist the driver in bringing the truck to a complete halt. Only in this maximum braking event, EB, will the warning system in question engage. During ABA development, 32 trucks ran for an aggregate of 3,244,755 Km (2.016 million miles). On the subject vehicles, DTNA has identified only four cases of EB events, with an average duration of 0.99 seconds and a maximum observed duration of 2.90 seconds, which proves that EB event is an extremely rare scenario that is visible only for a short period of time in only the rarest of extreme braking events. For the maximum observed EB scenario, the stopping distance of the subject vehicle from the reference object was 80m and during this period, there were 6-7 hazard warning signal flash cycles at a frequency of 140 flashes per min. This conveys that an EB event has an extremely short occurrence with a negligible reaction time to notice the change in hazard warning signal flash rate. DTNA has videos and data, which demonstrates how quickly these EB events are executed. The flashing warning provides other vehicles with a safe indication of the aggressiveness of the braking DTNA has developed and implemented the flashing warning of the ABA system to provide signaling to following drivers during emergency braking event. NHTSA have sponsored studies, which shows that flashing warning under certain extreme braking events may be regarded as a safer indicator for rear signaling. In Docket No. DOT HS 810 846 (published in October 2007), Analysis of Rear-End Crashes and Near- Crashes in the 100-Car Naturalistic Driving Study to Support Rear-Signaling Countermeasure Development. As per crash data and the study results, “it was determined that a rear-signaling system that extinguishes somewhat after a vehicle comes to a complete stop should provide benefit by reducing a substantial percentage of collisions with stopped lead vehicles, while reducing annoyance caused by extended signaling after a vehicle is stopped. Data suggest this type of signal would address approximately 45 percent (10 out of 22) of stopped-lead-vehicle crashes. Moreover, a rear-signaling system that Daimler Trucks North America, LLC 4747 N. Channel Avenue Portland OR 97217-7699 Phone: 503-745-8000 communicates moderate to hard lead-vehicle decelerations can potentially decrease the incidence of rear- end near-crashes and incidents. For example, a system to signal hard lead-vehicle decelerations (peak braking above 0.55g) could potentially address 56 percent (109 out of 194) of near-crash events.” During an EB event, if the vehicle is operating at a speed of 20Km/h and above, vehicle would autonomously activate the horn, hazards warning signals would be actuated at a rate of 140 flashes per min and high beams would flash for less than 3 seconds until the vehicle reaches to a complete forced stop. The following attributes have been implemented to provide hard signals to indicate sudden vehicle deceleration as mentioned in the above referred research document. Recently, FMCSA has granted an approval for implementing amber brake lights for all hazmat hauler tanker trucks following a 30-month study that ended last year. Groendyke Transportation learned that the addition of a relatively simple, pulsating amber brake light reduced rear-end collisions by roughly 34%. “The Oklahoma-based hazmat hauler had received an exemption from the Federal Motor Carrier Safety Administration (FMCSA) to mount the light on the back of 632 of its tanker trucks, and in two-and-half-years they saw a 33.7% drop in rear-end crashes along with the elimination of all railroad crossing rear-end accidents.” DTNA is not aware of any accidents, injuries, owner complaints or field reports related to this condition on the subject vehicles. DTNA notes that NHTSA has previously granted petitions for decisions of inconsequential noncompliance for lighting requirements where a technical non-compliance exists, but does not create a negative impact on safety. NHTSA has allowed similar rear-signaling noncompliance The feature of hazard warning signal flashers has been designed to provide an extra attention of caution to the nearby drivers. Previously, NHTSA has granted an inconsequentiality petition that emphasizes on momentary activation of CHMSL to provide extra caution to the nearby vehicles for a decelerating vehicle. In Docket No. NHTSA–2000–7312 (published on June 18, 2001), a Petition for Inconsequentiality by GM was granted by NHTSA. In this instance, certain models could have unintended CHMSL illumination briefly if the hazard warning lamp switch is depressed to its limit of travel. NHTSA stated: “The intended use of a hazard warning lamp and the momentary activation of a CHMSL do not provide a conflicting message. The illumination of the CHMSL is intended to signify that the vehicles brakes are being applied and that the vehicle might be decelerating. Hazard warning lamps are intended as a more general message to nearby drivers that extra attention should be given to the vehicle. A brief illumination of the CHMSL while activating the hazard warning lamps would not confuse the intended general message, nor would the brief illumination in the absence of the other brake lamps cause confusion that the brakes were unintentionally applied.” NHTSA has allowed noncompliance like the present one under extremely rare occurrences Previously, NHTSA has granted similar inconsequentiality petitions for noncompliance with low probability of occurrence, which occurs under specific and rare conditions. As described above, DTNA’s system functions extremely rarely. Daimler Trucks North America, LLC 4747 N. Channel Avenue Portland OR 97217-7699 Phone: 503-745-8000 In Docket No. NHTSA-2014-0125 (published on Feb 02, 2018), a Petition for Inconsequentiality by GM was granted by NHTSA. In this instance, under certain conditions the parking lamps on the subject vehicles fail to meet the requirement that parking lamps must be activated when headlamps are activated in a steady burning state. NHTSA stated: “…The Agency agrees with GM that in this case this situation would have a low probability of occurrence and, if it should occur, it would neither be long lasting nor likely to occur during a period when parking lamps are generally in use. Importantly, when the noncompliance does occur, other lamps remain functional. The combination of all of the factors, specific to this case, abate the risk to safety.” In Docket No. NHTSA-2012-0006 (published 06/12/2013), a Petition for Inconsequentiality by GM was granted by NHTSA. In this instance, GM explained that the noncompliance occurs on rare occasions, the front passenger air bag suppression status telltale lamp may remain illuminated during a particular ignition cycle and indicate that the passenger airbag is OFF. NHTSA stated: “ The Agency has reviewed and accepts GM’s analyses that in this case front passenger classification and air bag suppression system complies with the safety performance requirements of the standard except under a very specific and rare set of conditions that can occur during an ignition cycle and cause the front passenger air bag OFF telltale to remain illuminated. When this occurs, the telltale is the only part that is affected and occupation classification system will operate as designed.” NHTSA precedents that were granted for short duration of occurrence An average Emergency Braking event is expected to last for less than 3 seconds, until the vehicle reaches a complete forced stop. Previously, NHTSA has granted similar inconsequentiality petitions for noncompliance that would last for a very short period of time. In Docket No. NHTSA-2017-0020 (published 03/06/2019), a Petition for Inconsequentiality by Volkswagen group of America was granted by NHTSA. In this instance, Volkswagen stated that the during an electronic stability control (ESC) malfunction, the malfunction telltale illuminated as required by FMVSS 126 unless the steering angle sensor is the source of malfunction. Volkswagen stated that the condition is inconsequential as the ESC malfunction warning telltale immediately re-illuminates when the vehicle starts to move and reaches 2km/h or 1.2mph. NHTSA stated, “The agency believes that ESC malfunction telltale will illuminate for very short period of time at very low speeds, conditions under which a vehicle loss of control due to instabilities that require the ESC system to activate will not occur” In Docket No. NHTSA-2014-0034 (published 01/13/2016), a Petition for Inconsequentiality by Maserati S.p.A and Maserati North America was granted by NHTSA. In this instance, MNA explains that after the car’s ignition is switched to ON position, the Tire Pressure Monitoring System (TPMS) immediately seeks to confirm if all wheel sensors are present. If the TPMS detects a sensor is not present, an internal timer is started. If the sensor detected as missing was also detected as missing during the previous ignition cycle, the malfunction indicator will illuminate as required to indicate a fault is still active. If the engine is subsequently started again and left in its steady state idle, the warning lamp continue to illuminate. However, if the car is driven, then warning lamp will extinguish. Once the vehicle moves above 22mph for 15 seconds and the internal timer reaches 160 seconds, and then TPMS starts illuminating correctly. NHTSA stated, “The agency agrees with MNA that the malfunction indicator will not illuminate as required only during very short periods of time when the vehicle is travelling at low speeds and thus poses little risk to vehicle safety”. Daimler Trucks North America, LLC 4747 N. Channel Avenue Portland OR 97217-7699 Phone: 503-745-8000 Daimler Trucks North America, LLC 4747 N. Channel Avenue Portland OR 97217-7699 Phone: 503-745-8000 In Docket No.NHTSA-96-082 (published 11/04/1996), a Petition for Inconsequentiality by GM was granted by NHTSA. In this instance, GM discovered that turn signal self-canceling feature only works intermittently after left turns on certain 1996 Buick Skylarks because of a defective multifunction switch, however Skylarks are equipped with a reminder chime that activates if the turn signal is still on after 0.5 mile of driving. NHTSA stated, “All 1996 Skylarks have a turn signal reminder chime that will signal the driver if the turn signal indicator is on after 0.5 mile of driving. Therefore, even in those instances when the self-cancel feature fails, driver will get an additional notice.” DTNA believes that a technical non-compliance exists in our subject vehicles, but it does not create a negative impact on safety when the hazard warning signal flashes at rate of 140 flashes per min during certain rare occurrences for a very short duration of time. Therefore, we respectfully request that this noncompliance to be deemed inconsequential. Please contact me if you have any questions, or concerns. Sincerely yours, Andy Jones

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