August 10, 2020 NHTSA CAMPAIGN NUMBER: 20E054000
Seat Belt ELR/ALR functionality issue/FMVSS 210
An improperly operating seat belt lock system increases chance of injury in the event of a crash.
NHTSA Campaign Number: 20E054
Manufacturer Kiel N.A., L.L.C
Components SEAT BELTS, SEATS
Potential Number of Units Affected 437
Summary
Kiel N.A., L.L.C (Kiel) is recalling certain Avance 2025, 2050 and 1030 passenger seats for motorcoaches. The mounting point of the seat belt retractor for the last row of seats may cause the seat belts retractors to not function properly. This applies to rear cross seat chassis part number 171731, 171732, 158777, and 158778 in combination with 3-point automatic belt Emergency Locking Retractor/Automatic Locking Retractor part number 513862. As such, these passenger seats fail to comply with the requirements of Federal Motor Vehicle Safety Standard number 210, “Seat Belt Assembly Anchorages.”
Remedy
Kiel will notify owners, and dealers will install modifications to all of the affected last row seats, free of charge. The manufacturer has not provided a schedule for recall notification. Owners may contact Kiel customer service at 1-574-293-3600.
Notes
Owners may also contact the National Highway Traffic Safety Administration Vehicle Safety Hotline at 1-888-327-4236 (TTY 1-800-424-9153), or go to www.safercar.gov.
Kiel NA
Procedure: Addition of Rear Cross Belt Extension Bracket
Rev. 0
Procedure: Addition of Rear Cross Belt Extension Bracket
1. SUMMARY
1.1. Purpose of this procedure is to provide instruction for addition of the belt extension bracket to rear cross seat chassis.
1.2. Engineering is responsible for implementation and management of this procedure.
2. REVISION AND APPROVAL
| Rev. | Date | Nature of Changes | Approved By |
| 0 | 08/18/2020 | Original issue. | J Rebman |
3. PROCEDURE:
3.1 Remove seat cushion by lifting at front.
3.2 Visually inspect 3-point belt webbing to ensure it is not frayed, torn, or damaged.
3.3 While pulling webbing completely out of the retractor look at the webbing for fraying, tearing, and or damage.
3.4 Remove belt retractor from chassis and dispose of hardware.
3.5 Install bracket (part number: N263110) as pictured below with “dog leg” facing rear of seat.
3.5.5 S980200013 Bolt 7/16” -20 UNF.
3.5.6 3008067 Nut 7/16”-20.
3.6 Reinstall belt retractor as pictured below using new hardware provided by Kiel.
3.7 Use Loctite number 242 on bolt threads.
3.8 Special notes:
3.8.1 Make sure webbing angle is in line with the webbing slot and ring on chassis frame. Webbing should not touch sides of slot.
3.8.2 Do not roll or twist
3.9 Torque all 3 hardware sets to 28Nm or 21 ft. lbs.
3.10 Torque mark the nuts.
3.11 Replace seat cushion.
3.12 Test as per: Procedure: 3-Point Lap and Shoulder Belt Function
4. MAINTENANCE INFORMATION AND RECOMMENDATIONS
4.1. Important: Never disassemble retractor housing. This constitutes a safety hazard and should only be performed by belt manufacturer.
4.2. Service and maintenance should be performed by qualified personnel only.
4.3. Use of safety equipment and personal protective according to relevant guidelines.
4.4. Procedure document: Addition of Rear Cross Belt Extension Bracket is designed as a training document. If applicable, training videos are available upon request. Training is supported by Kiel NA. Please call 574-327-2050 or email [email protected] to request additional materials.
1475 Clarence Avenue
Winnipeg, Manitoba R3T 1T5
Canada
Attn: John-Paul Pelletier
Michaela Oberbauer, GM
Sharon Bachtel, QA Mgr
Kiel N.A., LLC
2009 Middlebury Street
Elkhart, IN 46516, USA
+1-574-293-3600
[email protected]
[email protected]
www.kielna.com
August 19, 2020
RE: Recall of Non-Compliant Kiel Rear Cross Seats
NHTSA ID: 20E054
Dear Mr. Pelletier,
Following is an update related to Rear Cross ELR/ALR issue. Retrofit brackets have been designed, tested, manufactured and are in the process of being shipped to Kiel N.A. L.L.C.
Immediate Corrective Action:
As previously communicated, all rear cross seats containing impacted chassis will have a modification installed. This modification will relocate the belt retractor on rear cross chassis allowing the additional webbing needed for switching back to ELR mode. Supplier Request for Engineering Approval (SREA) has been prepared and submitted to MCI
Engineering (Please see Attchment #1).
Plan to repair these coaches is as follows:
Valley Metro
-Solution will be sent to Red River Freight for installation. Timing is anticipated to be week of 08/17/2020. Pending arrival of parts, the two sets already in process at MCI
will be outfitted on site. The two remaining sets will have the update installed at Red River prior to being relocated to MCI
.
-(60) Coaches in service – Kiel NA Representative(s) will travel to these locations to perform the repair as soon as COVID-19 travel restrictions allow.
-(5) Coaches at Hayward facility – Kiel NA will supply parts and work instruction to facilitate installation by MCI
during COVID-19 travel restriction.
-(12) Coaches not yet in service – Repair will be performed at Kiel NA during 2nd inspection.
-(1) Demo Coach – Please provide current location as soon as available.
UMA Demo Coach – We have not yet been provided with the location of this coach. Please provide current location as soon as available.
Impact:
Coaches impacted remains unchanged and is as follows:
| Unit # | Sets | Project | PO# |
| Demo | |||
| 81004 | 1/77 | P392317 | |
| 81005 | 2/77 | P392317 | |
| 81006 | 3/77 | P392317 | |
| 81007 | 4/77 | P392317 | |
| 81008 | 5/77 | P392326/1 | |
| 81009 | 6/77 | P392326/2 | |
| 81010 | 7/77 | P392326/3 | |
| 81011 | 8/77 | P392326/4 | |
| 81012 | 9/77 | P700916/1 | |
| 81013 | 10/77 | P700916/2 | |
| 81014 | 11/77 | P700916/3 | |
| 81017 | 12/77 | P700916/4 | |
| 81018 | 13/77 | P700917/1 | |
| 81019 | 14/77 | P700917/2 | |
| 81020 | 15/77 | P700917/3 | |
| 81021 | 16/77 | P700917/4 | |
| 81022 | 17/77 | P700918/1 | |
| 81023 | 18/77 | P700918/2 | |
| 81024 | 19/77 | P700918/3 | |
| 81025 | 20/77 | P700918/4 | |
| 81026 | 21/77 | P700919/1 | |
| 81027 | 22/77 | P700919/2 | |
| 81028 | 23/77 | P700919/3 | |
| 81029 | 24/77 | P700919/4 |
| 81030 | 25/77 | P700920/1 | |
| 81031 | 26/77 | P700920/2 | |
| 81032 | 27/77 | P700920/3 | |
| 81033 | 28/77 | P700920/4 | |
| 81034 | 29/77 | P700920/5 | |
| 81035 | 30/77 | P700921/1 | |
| 81036 | 31/77 | P700921/2 | |
| 81037 | 32/77 | P700921/3 | |
| 81039 | 33/77 | P700921/4 | |
| 81040 | 34/77 | P700921/5 | |
| 81041 | 35/77 | P393319/1 | |
| 81042 | 36/77 | P393319/2 | |
| 81043 | 37/77 | P393319/3 | |
| 81044 | 38/77 | P393319/4 | |
| 81045 | 39/77 | P393319/5 | |
| 81046 | 40/77 | P393320/1 | |
| 81047 | 41/77 | P393320/2 | |
| 81048 | 42/77 | P393320/3 | |
| 81049 | 43/77 | P393320/4 | |
| 81050 | 44/77 | P393320/5 | |
| 81051 | 45/77 | P393321/1 | |
| 81052 | 46/77 | P393321/2 | |
| 81053 | 47/77 | P393321/3 | |
| 81054 | 48/77 | P393321/4 | |
| 81055 | 49/77 | P393321/5 | |
| 81056 | 50/77 | P393322/1 | |
| 81057 | 51/77 | P393322/2 | |
| 81058 | 52/77 | P393322/3 | |
| 81059 | 53/77 | P393322/4 | |
| 81060 | 54/77 | P393322/5 | |
| 81061 | 55/77 | P393323/1 | |
| 81062 | 56/77 | P393323/2 | |
| 81063 | 57/77 | P393323/3 | |
| 81064 | 58/77 | P393323/4 | |
| 81065 | 59/77 | P393323/5 | |
| 81066 | 60/77 | P393324/1 | |
| 81067 | 61/77 | P393324/2 | |
| 81068 | 62/77 | P393324/3 | |
| 61069 | 63/77 | P393324/4 | |
| 81070 | 64/77 | P393324/5 | |
| 81071 | 65/77 | P393325/1 | |
| 81072 | 66/77 | P393325/2 | |
| 81073 | 67/77 | P393325/3 | |
| 81074 | 68/77 | P393325/4 | |
| 81075 | 69/77 | P393325/5 | |
| 81076 | 70/77 | P393326/1 | |
| 81077 | 71/77 | P393326/2 | |
| 81078 | 72/77 | P393326/3 | |
| 81079 | 73/77 | P393326/4 | |
| 81080 | 74/77 | P393326/5 | |
| 81081 | 75/77 | P393327/1 | |
| 81082 | 76/77 | P393327/2 | |
| 81083 | 77/77 | P393327/3 | |
| 69727 | 1/1 | UMA DEMO J20-01 | F028883 |
| 81086 | 1/4 | VALLEY METRO | P394218 |
| 81087 | 2/4 | VALLEY METRO | P394218 |
| 81088 | 3/4 | VALLEY METRO | P394218 |
| 81089 | 4/4 | VALLEY METRO | P394218 |
Long Term Corrective Action:
As previously stated, modified rear cross chassis mounting location for belt retractor will be implemented prior to any further production.
Please contact us if you have any questions or need further information.
With best regards, Kiel N.A., L.L.C.
Michaela Oberbauer
General Manager
Sharon Bachtel
QA Manager
Attachment 1: SREA
BYD
Coach & Bus
46147 7th Street W
Lancaster, CA 93534
Attn: Xin Li (Eva)
Michaela Oberbauer, GM
Sharon Bachtel, QA Mgr
Kiel N.A., LLC
2009 Middlebury Street
Elkhart, IN 46516, USA
+1-574-293-3600
[email protected]
[email protected]
www.kielna.com
August 11, 2020
RE: Recall of Non-Compliant Kiel Rear Cross Seats
NHTSA ID: 20E054
Dear Ms. Li,
Following is information about an issue with Kiel Rear Cross coach seats. At this time, there is no action necessary on the part of BYD
. This recall is expected to be closed within the next two months. Updates will be sent as information becomes available.
Description of issue:
Mounting location of belt retractor on rear cross chassis is reducing length of webbing required for switching back from ALR (Automatic Locking Retractor – used for securing a child seat
) to ELR (Emergency Locking Retractor – allows the seat belt to freely extend and retract with occupant movement, yet locks the belt during a sudden stop or upon impact) mode on Schnierle belt after activation. ALR is activated by pulling the belt all the way out. ALR is deactivated by unbuckling the belt and allowing it to retract fully. Amount of webbing necessary for deactivation is very close to the switching tolerance of belt.
History:
07/15/2020 Kiel NA was notified that a seat belt on a rear cross seat was not functioning properly.
07/28/2020 Seat was inspected at Kiel NA.
07/28/20-07/31/20 Root cause analysis identified design issue. Mounting location of belt retractor on rear cross chassis is reducing length of webbing required for switching back from ALR to ELR mode on Schnierle belt after activation.
07/31/2020 – Current – Development of retrofit and long-term solution for relocating mounting location of belt retractor.
NHTSA Reporting:
A NHTSA Equipment Report has been filed on this topic effective 08/10/2020. Please see attachment #1.
Root Cause:
Mounting location of belt retractor on rear cross chassis is reducing length of webbing required for switching back from ALR to ELR mode on Schnierle belt after activation. Amount of webbing necessary for deactivation is very close to the switching tolerance of belt.
Immediate Corrective Action:
All rear cross seats containing impacted chassis will have a modification installed. This modification will relocate the belt retractor on rear cross chassis allowing the additional webbing needed for switching back to ELR mode.
This modification will be completed at Kiel expense. Please provide locations for the coaches impacted so that a schedule for completion can be organized.
Impact:
Following BYD
coaches are impacted:
Long Term Corrective Action:
Modified rear cross chassis mounting location for belt retractor will be implemented prior to any further production.
Please contact us if you have any questions or need further information.
With best regards, Kiel N.A., L.L.C.
Michaela Oberbauer
General Manager
Sharon Bachtel
QA Manager
Attachment 1: NHTSA Equipment Report
Motor Coach Industries![]()
1475 Clarence Avenue
Winnipeg, Manitoba R3T 1T5
Canada
Attn: John-Paul Pelletier
Michaela Oberbauer, GM
Sharon Bachtel, QA Mgr
Kiel N.A., LLC
2009 Middlebury Street
Elkhart, IN 46516, USA
+1-574-293-3600
[email protected]
[email protected]
www.kielna.com
August 10, 2020
RE: Recall of Non-Compliant Kiel Rear Cross Seats
NHTSA ID: 20E054
Dear Mr. Pelletier,
Following is information about the Rear Cross ELR/ALR issue. At this time, there is no action necessary on the part of MCI
. This recall is expected to be closed within the next two months. Updates will be sent as information becomes available.
Description of issue:
Mounting location of belt retractor on rear cross chassis is reducing length of webbing required for switching back from ALR (Automatic Locking Retractor – used for securing a child seat
) to ELR (Emergency Locking Retractor – allows the seat belt to freely extend and retract with occupant movement, yet locks the belt during a sudden stop or upon impact) mode on Schnierle belt after activation. ALR is activated by pulling the belt all the way out. ALR is deactivated by unbuckling the belt and allowing it to retract fully. Amount of webbing necessary for deactivation is very close to the switching tolerance of belt.
History:
07/15/2020 Kiel NA was notified by Motor Coach Industries
that a seat belt on a rear cross seat was not functioning properly.
07/28/2020 Seat was inspected at Kiel NA.
07/28/20-07/31/20 Root cause analysis identified design issue. Mounting location of belt retractor on rear cross chassis is reducing length of webbing required for switching back from ALR to ELR mode on Schnierle belt after activation.
07/31/2020 – Current – Development of retrofit and long-term solution for relocating mounting location of belt retractor.
NHTSA Reporting:
A NHTSA Equipment Report has been filed on this topic effective 08/10/2020. Please see attachment #1.
Root Cause:
Mounting location of belt retractor on rear cross chassis is reducing length of webbing required for switching back from ALR to ELR mode on Schnierle belt after activation. Amount of webbing necessary for deactivation is very close to the switching tolerance of belt.
Immediate Corrective Action:
All rear cross seats containing impacted chassis will have a modification installed. This modification will relocate the belt retractor on rear cross chassis allowing the additional webbing needed for switching back to ELR mode. Plan to repair these coaches is as follows:
| Valley Metro | -Solution will be sent to Red River Freight who will repair on site at MCI |
| -Coaches in service and at Hayward Facility – Kiel NA Representative(s) will travel to these locations to perform the repair as soon as Covid travel restrictions allow.
-Coaches not yet in service – Repair will be performed at Kiel NA during 2nd inspection. |
UMA Demo Coach – Please provide current location of coach.
Impact:
Following coaches are impacted:
| Unit # | Sets | Project | PO# |
| Demo | |||
| 81004 | 1/77 | P392317 | |
| 81005 | 2/77 | P392317 | |
| 81006 | 3/77 | P392317 | |
| 81007 | 4/77 | P392317 | |
| 81008 | 5/77 | P392326/1 | |
| 81009 | 6/77 | P392326/2 | |
| 81010 | 7/77 | P392326/3 | |
| 81011 | 8/77 | P392326/4 | |
| 81012 | 9/77 | P700916/1 | |
| 81013 | 10/77 | P700916/2 | |
| 81014 | 11/77 | P700916/3 | |
| 81017 | 12/77 | P700916/4 | |
| 81018 | 13/77 | P700917/1 | |
| 81019 | 14/77 | P700917/2 | |
| 81020 | 15/77 | P700917/3 | |
| 81021 | 16/77 | P700917/4 | |
| 81022 | 17/77 | P700918/1 | |
| 81023 | 18/77 | P700918/2 | |
| 81024 | 19/77 | P700918/3 | |
| 81025 | 20/77 | P700918/4 | |
| 81026 | 21/77 | P700919/1 | |
| 81027 | 22/77 | P700919/2 | |
| 81028 | 23/77 | P700919/3 | |
| 81029 | 24/77 | P700919/4 | |
| 81030 | 25/77 | P700920/1 | |
| 81031 | 26/77 | P700920/2 | |
| 81032 | 27/77 | P700920/3 | |
| 81033 | 28/77 | P700920/4 | |
| 81034 | 29/77 | P700920/5 | |
| 81035 | 30/77 | P700921/1 | |
| 81036 | 31/77 | P700921/2 | |
| 81037 | 32/77 | P700921/3 | |
| 81039 | 33/77 | P700921/4 | |
| 81040 | 34/77 | P700921/5 | |
| 81041 | 35/77 | P393319/1 | |
| 81042 | 36/77 | P393319/2 | |
| 81043 | 37/77 | P393319/3 | |
| 81044 | 38/77 | P393319/4 | |
| 81045 | 39/77 | P393319/5 | |
| 81046 | 40/77 | P393320/1 | |
| 81047 | 41/77 | P393320/2 | |
| 81048 | 42/77 | P393320/3 | |
| 81049 | 43/77 | P393320/4 | |
| 81050 | 44/77 | P393320/5 | |
| 81051 | 45/77 | P393321/1 | |
| 81052 | 46/77 | P393321/2 | |
| 81053 | 47/77 | P393321/3 | |
| 81054 | 48/77 | P393321/4 | |
| 81055 | 49/77 | P393321/5 | |
| 81056 | 50/77 | P393322/1 | |
| 81057 | 51/77 | P393322/2 | |
| 81058 | 52/77 | P393322/3 | |
| 81059 | 53/77 | P393322/4 | |
| 81060 | 54/77 | P393322/5 | |
| 81061 | 55/77 | P393323/1 | |
| 81062 | 56/77 | P393323/2 | |
| 81063 | 57/77 | P393323/3 | |
| 81064 | 58/77 | P393323/4 | |
| 81065 | 59/77 | P393323/5 | |
| 81066 | 60/77 | P393324/1 | |
| 81067 | 61/77 | P393324/2 | |
| 81068 | 62/77 | P393324/3 | |
| 61069 | 63/77 | P393324/4 | |
| 81070 | 64/77 | P393324/5 | |
| 81071 | 65/77 | P393325/1 | |
| 81072 | 66/77 | P393325/2 | |
| 81073 | 67/77 | P393325/3 | |
| 81074 | 68/77 | P393325/4 | |
| 81075 | 69/77 | P393325/5 | |
| 81076 | 70/77 | P393326/1 | |
| 81077 | 71/77 | P393326/2 | |
| 81078 | 72/77 | P393326/3 | |
| 81079 | 73/77 | P393326/4 | |
| 81080 | 74/77 | P393326/5 | |
| 81081 | 75/77 | P393327/1 | |
| 81082 | 76/77 | P393327/2 | |
| 81083 | 77/77 | P393327/3 | |
| 69727 | 1/1 | UMA DEMO J20-01 | F028883 |
| 81086 | 1/4 | VALLEY METRO | P394218 |
| 81087 | 2/4 | VALLEY METRO | P394218 |
| 81088 | 3/4 | VALLEY METRO | P394218 |
| 81089 | 4/4 | VALLEY METRO | P394218 |
Long Term Corrective Action:
Modified rear cross chassis mounting location for belt retractor will be implemented prior to any further production.
Please contact us if you have any questions or need further information.
With best regards, Kiel N.A., L.L.C.
Michaela Oberbauer
General Manager
Sharon Bachtel
QA Manager
Attachment 1: NHTSA Equipment Report
1 Affected Product
Equipment
| BRAND | PART NO. | PRODUCTION DATES |
| KIEL | AVANCE | |
6 Associated Documents
Recall Quarterly Report #2, 2020-4
RCLQRT-20E054-7204.PDF 211.217KB
Recall 573 Report – Amendment 1
RCLRPT-20E054-6741.PDF 214.242KB
Recall Quarterly Report #1, 2020-3
RCLQRT-20E054-2868.pdf 210.831KB
Noncompliance Notice 573 Report
RCLRPT-20E054-6471.PDF 214.042KB
Recall Acknowledgement
RCAK-20E054-7567.pdf 246.046KB
Miscellaneous Document-Procedure – Addition of Rear Cross Belt Extension Bracket
RMISC-20E054-6903.pdf 742.669KB
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- 【Live Datastream&4-in-1 Graph】 Easily view live sensor data such as RPM, fuel trims, ATF temperature, wheel speed sensor, battery voltage and so on. OM970 scan tool also supports 4-in-1 trend graphing. Spend just 3 minutes to check – and you'll know exactly what's going wrong, helping you avoid hundreds in dealership diagnostic fees.
- 【One-Click I/M Readiness&Full OBD2 Functions】 Press F1 to get an intuitive corloured form about whether your vehicle's emissions-related systems are operating properly. Help you get smog-check ready quickly. OM970 obd2 diagnostic tool supports all essential OBD2 functions you need. Plus, it features battery voltage test and DLC 16-PIN test.
- 【Straightforward Menus with Easy Navigation】 All functions are easy to understand without obscure decriptions. 3.5" Large screen delivers clear readings while keeping one-hand operation. The car diagnostic tool comes with a silicone protective case and a hard-shell carrying case, ensuring long-lived durability and drop resistance.
- 【Budget-Friendly, No Subscriptions, Free Software Updates】 Plug and play: no bluetooth pairing, monthly fees, Wi-Fi connection, or any other troublesome initial settings. OM970 obd2 scanner works out of the box with the latest software. Lifetime free upgrade.
- [All System Diagnostics, Professional-Level Scanner] - BLCKTEC 460T is the ultimate OBD2 diagnostic tool for home mechanics and professionals. It supports all 10 OBD2 modes, reads and clears Engine/Transmission/ABS/SRS codes, performs All-System Diagnostics, offers workshop reset tools, and provides real-time live data. It helps you pinpoint issues, assess your car's condition, and prepare for SMOG checks with ease. NOTE: Function availability depends on your vehicle. Before you buy, be sure to use the Compatibility Checker on BLCKTEC website or contact our customer support to verify that the features you need are supported for your vehicle’s specific year, make, and model.
- [12+ Most Popular Reset Functions] - BLCKTEC 460T OBD2 scanner offers 12+ dealer-level service functions, including Oil Maintenance Reset, ABS Bleeding, EPB Reset, SAS(Steering Angle Sensor) Recalibration, DPF(Diesel Particulate Filter) Reset, Throttle Body Relearn, Battery Reset/Initialization, TPMS Relearn, Transmission Reset, Fluid Change Reset, Maintenance Reset and more, enabling you to perform workshop services like a pro. NOTE: Function availability depends on your vehicle. Be sure to use the Compatibility Checker on BLCKTEC website to verify that the features you need are supported for your vehicle.
- [Real-Time OBD2 and OEM Live Data, Freeze Frame Data] - BLCKTEC 460T helps diagnose vehicle issues when warning lights like Check Engine Light or ABS/SRS Light appear. It offers detailed DTC info, ECU Freeze Frame Data, and real-time OBD2 and advanced OEM live data, including Engine, Transmission, ABS, SRS, and more, making it easy to diagnose and resolve vehicle problems. You can view, graph, record, replay, and overlay up to four live data streams in a single graph for better analysis.
- [AutoVIN, AutoReLink, AutoScan, 3X Faster] - Equipped with AutoVIN technology, 460T automatically retrieves the VIN to save you time. Its AutoScan and AutoReLink features scan all of the vehicle's ECUs and detect any fault codes immediately after you plug the scanner into the vehicle's OBD2 port - no button presses required. Additionally, it regathers DTC and I/M readiness information every 30 seconds, simplifying monitor tests. 460T's advanced technology makes it 3X faster than other products.
- [Get RepairSolutions2, the #1 Auto Repair App for Free] - When paired with RepairSolutions2(RS2) App, 460T becomes even more powerful. RS2's Verified Fix Database built by master technicians, provides the parts needed for the repair. Additionally, RS2 gives you access to OEM warranty info, maintenance schedules, TSB, and dealership recall info, making car care easier than ever. RS2 is free with no subscription fees and it stores your car scan reports in the cloud, allowing you to access, share, or print them anytime and anywhere.
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