23E033 Inadequately Reflective Conspicuity Tape – 3M Flexible Prismatic Conspicuity Tape

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 23E-033 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : 3M Transportation Safety Division Submission Date : APR 20, 2023 NHTSA Recall No. : 23E-033 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : 3M Transportation Safety Division Address : 3M Center 0235-03-A-09 Maplewood MN 55144 Company phone : 461-2637 Population : Number of potentially involved : 244 Estimated percentage with defect : 100 % Equipment Information : Brand / Trade 1 : 3M™ Model : Flexible Prismatic Conspicuity Tape Series 913-72 retroreflective sheeting Part No. : 913-72 (Red) DG23732 Size : 244 Rolls Function : NR Descriptive Information : The red product from Lot # DG23732 was determined to have not met compliance through third party testing. Only this lot was affected, all other lots of this product have passed compliance. 244 Rolls of sheeting of this product was identified under this lot number. Production Dates : DEC 01, 2022 – DEC 31, 2022 Description of Noncompliance : Description of the Noncompliance : The retroreflective sheeting in question may not comply with one of the performance requirements specified in S8.2.1 of FMVSS No. 108 and Table XVIc of that standard. When samples were tested with an entrance angle of 30 degrees and an observation angle of 0.2 degrees, the sheeting reflected less than the 60 candela/lux/square meter required by the standard. Only this entrance angle and observation angle did not comply to FMVSS 108. FMVSS 1 : 108 – Lamps, reflective devices, and assoc. Equipment FMVSS 2 : NR Description of the Safety Risk : Retroreflective sheeting is used on the side of trucks and trailers to easily identify them at night, the risk in this case is quite minimal as only one specific entrance/observation angle did not comply with the required 60 candela/lux/square meter. Part 573 Safety Recall Report 23E-033 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Additionally, only the red tape from this lot did not meet compliance, trucks will have a combination of red and white tape, the white tape has met all required standards and regulations. Where only red conspicuity tape is used there is a potential for that red to be less reflective at an entrance angle of 30 degrees and an observation angle of 0.2. may not reflect at the levels required in FMVSS 108 and could reduce vehicle visibility. Description of the Cause : NR Identification of Any Warning that can Occur : NR Involved Components : Component Name : 913-72 Red Conspicuity Tape Component Description : Red Retroreflective Tape Component Part Number : DG23732 Supplier Identification : Component Manufacturer Name : 3M Company Address : 3M Center 223-3S-33 St. Paul Minnesota 55144 Country : United States Chronology : As part of its normal quality control procedures, 3M tested a sample of sheeting from the lot in question during December 2022. The third-party lab contacted 3M by email and informed 3M that this sheeting did not pass the retroreflection requirement. Because of the lower brightness measurement on the sheeting at the 0.2/30 degree angle, 3M believes the lot of sheeting identified above may not comply with S8.2.1 of FMVSS No. 108. 3M has not received any complaints regarding this issue from the field. Part 573 Safety Recall Report 23E-033 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Description of Remedy : Description of Remedy Program : 3M has notified all distributors that received any of the sheeting covered by this report to advise them to not sell any of that sheeting still in their possession and to return any remaining sheeting to 3M for replacement. 3M is covering the costs associated with returning the items. 3M has no known end-users of the noncompliant sheeting. The normal warranty has a provision for replacement of the sheeting. In this case, the material has been discontinued and refund for defective material offered. How Remedy Component Differs from Recalled Component : Different line of our conspicuity tape that is also used for trucks and trailers and satisfies the red and white conspicuity needs. Identify How/When Recall Condition was Corrected in Production : Not applicable as the product has been discontinued. Recall Schedule : Description of Recall Schedule : Notifications to customers were issued around February 28th, 2023, of the non-compliance and given guidance on how to return/replace products. NHTSA was mailed a letter around the same time. Submitting through this portal at this date. Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : NR – NR Purchaser Information : The following manufacturers purchased this defective/noncompliant equipment for possible use or installation in new motor vehicles or new items of motor vehicle equipment: Name : NR Address : NR NR Country : NR Company Phone : NR * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 23E-033 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : 3M Transportation Safety Division Submission Date : APR 20, 2023 NHTSA Recall No. : 23E-033 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : 3M Transportation Safety Division Address : 3M Center 0235-03-A-09 Maplewood MN 55144 Company phone : 461-2637 Population : Number of potentially involved : 244 Estimated percentage with defect : 100 % Equipment Information : Brand / Trade 1 : 3M™ Model : Flexible Prismatic Conspicuity Tape Series 913-72 retroreflective sheeting Part No. : 913-72 (Red) DG23732 Size : 244 Rolls Function : NR Descriptive Information : The red product from Lot # DG23732 was determined to have not met compliance through third party testing. Only this lot was affected, all other lots of this product have passed compliance. 244 Rolls of sheeting of this product was identified under this lot number. Production Dates : DEC 01, 2022 – DEC 31, 2022 Description of Noncompliance : Description of the Noncompliance : The retroreflective sheeting in question may not comply with one of the performance requirements specified in S8.2.1 of FMVSS No. 108 and Table XVIc of that standard. When samples were tested with an entrance angle of 30 degrees and an observation angle of 0.2 degrees, the sheeting reflected less than the 60 candela/lux/square meter required by the standard. Only this entrance angle and observation angle did not comply to FMVSS 108. FMVSS 1 : 108 – Lamps, reflective devices, and assoc. Equipment FMVSS 2 : NR Description of the Safety Risk : Retroreflective sheeting is used on the side of trucks and trailers to easily identify them at night, the risk in this case is quite minimal as only one specific entrance/observation angle did not comply with the required 60 candela/lux/square meter. Part 573 Safety Recall Report 23E-033 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Additionally, only the red tape from this lot did not meet compliance, trucks will have a combination of red and white tape, the white tape has met all required standards and regulations. The risk is an increased risk of crash however trucks and trailers use both white and red conspicuity tape so that risk is reduced but still present. Description of the Cause : NR Identification of Any Warning that can Occur : NR Involved Components : Component Name : 913-72 Red Conspicuity Tape Component Description : Red Retroreflective Tape Component Part Number : DG23732 Supplier Identification : Component Manufacturer Name : 3M Company Address : 3M Center 223-3S-33 St. Paul Minnesota 55144 Country : United States Chronology : As part of its normal quality control procedures, 3M tested a sample of sheeting from the lot in question during December 2022. The third-party lab contacted 3M by email and informed 3M that this sheeting did not pass the retroreflection requirement. Because of the lower brightness measurement on the sheeting at the 0.2/30 degree angle, 3M believes the lot of sheeting identified above may not comply with S8.2.1 of FMVSS No. 108. 3M has not received any complaints regarding this issue from the field. Part 573 Safety Recall Report 23E-033 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Description of Remedy : Description of Remedy Program : 3M has notified all distributors that received any of the sheeting covered by this report to advise them to not sell any of that sheeting still in their possession and to return any remaining sheeting to 3M for replacement. 3M is covering the costs associated with returning the items. 3M has no known end-users of the noncompliant sheeting. The normal warranty has a provision for replacement of the sheeting. In this case, the material has been discontinued and refund for defective material offered. How Remedy Component Differs from Recalled Component : Different line of our conspicuity tape that is also used for trucks and trailers and satisfies the red and white conspicuity needs. Identify How/When Recall Condition was Corrected in Production : Not applicable as the product has been discontinued. Recall Schedule : Description of Recall Schedule : Notifications to customers were issued around February 28th, 2023, of the non-compliance and given guidance on how to return/replace products. NHTSA was mailed a letter around the same time. Submitting through this portal at this date. Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : NR – NR Purchaser Information : The following manufacturers purchased this defective/noncompliant equipment for possible use or installation in new motor vehicles or new items of motor vehicle equipment: Name : NR Address : NR NR Country : NR Company Phone : NR * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 23E-033 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : 3M Transportation Safety Division Submission Date : APR 17, 2023 NHTSA Recall No. : 23E-033 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : 3M Transportation Safety Division Address : 3M Center 0235-03-A-09 Maplewood MN 55144 Company phone : 461-2637 Population : Number of potentially involved : NR Estimated percentage with defect : 100 % Equipment Information : Brand / Trade 1 : 3M™ Model : Flexible Prismatic Conspicuity Tape Series 913-72 retroreflective sheeting Part No. : 913-72 (Red) DG23732 Size : NR Function : NR Descriptive Information : The red product from Lot # DG23732 was determined to have not met compliance through third party testing. Only this lot was affected, all other lots of this product have passed compliance. 244 Rolls of sheeting of this product was identified under this lot number. Production Dates : DEC 01, 2022 – DEC 31, 2022 Description of Noncompliance : Description of the Noncompliance : The retroreflective sheeting in question may not comply with one of the performance requirements specified in S8.2.1 of FMVSS No. 108 and Table XVIc of that standard. When samples were tested with an entrance angle of 30 degrees and an observation angle of 0.2 degrees, the sheeting reflected less than the 60 candela/lux/square meter required by the standard. Only this entrance angle and observation angle did not comply to FMVSS 108. FMVSS 1 : 108 – Lamps, reflective devices, and assoc. Equipment FMVSS 2 : NR Description of the Safety Risk : Retroreflective sheeting is used on the side of trucks and trailers to easily identify them at night, the risk in this case is quite minimal as only one specific entrance/observation angle did not comply with the required 60 candela/lux/square meter. Additionally, only the red tape from this lot did Part 573 Safety Recall Report 23E-033 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 not meet compliance, trucks will have a combination of red and white tape, the white tape has met all required standards and regulations. The equipment should function as intended but does not fully comply with FMVSS 108. Description of the Cause : NR Identification of Any Warning that can Occur : NR Involved Components : Component Name : NR Component Description : NR Component Part Number : NR Supplier Identification : Component Manufacturer Name : 3M Company Address : 3M Center 223-3S-33 St. Paul Minnesota 55144 Country : United States Chronology : As part of its normal quality control procedures, 3M tested a sample of sheeting from the lot in question during December 2022. The third-party lab contacted 3M by email and informed 3M that this sheeting did not pass the retroreflection requirement. Because of the lower brightness measurement on the sheeting at the 0.2/30 degree angle, 3M believes the lot of sheeting identified above may not comply with S8.2.1 of FMVSS No. 108. 3M has not received any complaints regarding this issue from the field. Part 573 Safety Recall Report 23E-033 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Description of Remedy : Description of Remedy Program : 3M has notified all distributors that received any of the sheeting covered by this report to advise them to not sell any of that sheeting still in their possession and to return any remaining sheeting to 3M for replacement. 3M is covering the costs associated with returning the items. How Remedy Component Differs from Recalled Component : NR Identify How/When Recall Condition was Corrected in Production : Not applicable as the product has been discontinued. Recall Schedule : Description of Recall Schedule : Notifications to customers were issued around February 28th, 2023, of the non-compliance and given guidance on how to return/replace products. NHTSA was mailed a letter around the same time. Submitting through this portal at this date. Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : NR – NR Purchaser Information : The following manufacturers purchased this defective/noncompliant equipment for possible use or installation in new motor vehicles or new items of motor vehicle equipment: Name : NR Address : NR NR Country : NR Company Phone : NR * NR – Not Reported

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Julie Seputis 3M Transportation Safety Division 3M Center, Building 235-3A-09 Quality and Product Integrity Manager St. Paul, MN 55144-1000 February 7, 2023 VIA EMAIL Dear 3M Transportation Safety Division Product Distributor: This letter is to notify you that 3M Transportation Safety Division (TSD) recently received testing which indicates that the 3M™ Flexible Prismatic Conspicuity Tape Series 913 products listed in the table below do not fully conform to FMVSS 108 photometry requirements in S.14.2.3 and table XVI-c for retroreflective sheeting (the “Affected Products”). Therefore, 3M TSD is discontinuing the manufacturing and distribution of 913-72 Red. In addition, 3M TSD is discontinuing the complementary product 913-10 White. We recommend customers stop using the Affected Products for Class 8 Vehicle marking applications. No other areas of concern were noted in the report. Based on the report, the products listed below should no longer be used for Class 8 Vehicle marking applications: Product Number Product Color 913-72 Red 913-10 White To address this situation, TSD is discontinuing sales of the 913-72 red and 913-10 white sheeting products. If you have inventory of 913-72 or 913-10 marked products for Class 8 vehicle marking, please remove them from your inventory. In addition, please review your website for any collateral or verbiage that relates to 3M™ Flexible Prismatic Conspicuity Tape Series 913 for Class 8 Vehicle marking applications. We ask that you remove any material or verbiage you may have on your website related to the markings. Please contact your 3M Representative to return Affected Products for full credit or call 1-800-553-1380, option 1 with any questions. The attached notice provides instructions for end users as well as contact information if customers have any questions or concerns. Thank you in advance for your support and cooperation in reaching your customers with this information. We apologize for any inconvenience this situation may have caused. We hope you can appreciate how important it is to maintain your confidence in the safety and performance of 3M conspicuity products. Kind Regards, Julie Seputis Quality and Product Integrity Manager 3M Transportation Safety Division

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