Missing 4 Side Reflectors – 2019-2022 Cottrell 2-Car Carrier

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[email protected]. IMPORTANT SAFETY RECALL This notice applies to your vehicle [VIN] NHTSA Recall 21V-863 February 2, 2022 Dear Penske Leasing: This notice is sent to you in accordance with the National Traffic and Motor Vehicle Safety Act.Cottrell, Inc. (Cottrell) is recalling certain 2019-2022 2-Car Carrier vehicles. Four side-rear reflex reflectors are missing. As such, these vehicles fail to comply with the requirements of Federal Motor Vehicle Safety Standard number 108, (FMVSS) “Lamp, Reflective Devices, and Associated Equipment. Missing reflex reflectors reduce the vehicle’s visibility to other drivers, increasing the risk of a crash. Please find enclosed an Installation Guide with detailed instructions on how to install four (4) reflex reflectors on your Cottrell 2-Car Hauler. The four (4) reflex reflectors (2 Red and 2 Amber) are to be installed as follows: one (1) Amber reflector on each side of the unit near the midpoint between the front and rear reflectors (2 total Amber reflectors), and two (2) Red Reflectors on the rear cross member, all as shown in the enclosed Installation Guide. All parts needed to properly install the reflex reflectors are being provided to you free of charge. Once you have completed the installation above, please email Cottrell to report the installation is complete on the particular VIN number at issue, at: [email protected] This installation can be performed at the Cottrell Service Center in Gainesville, Georgia, at any Authorized Cottrell Warranty Repair Facility, or at a repair facility of your choice. You can access a list of Authorized Cottrell Warranty Repair Facilities at www.cottrelltrailers.com under “Find a Dealer.” If you no longer own your 2-Car Carrier vehicles, please contact Cottrell at 1-800-827-0132 Ext 103 or email us at If you are the lessor of these vehicles, please forward a copy of this notice to the lessee within ten days to comply with federal regulations. Cottrell will reimburse labor for this installation at the maximum rate of one-half (.5) of an hour. Requests for reimbursement can be submitted with receipts to the above email address or handled directly through the repair facility using normal warranty procedures. Please perform this installation as soon as possible following the instructions provided. Should you have any questions concerning this installation, please contact warranty at the email address or phone number indicated below. 2125 Candler Road, Gainesville, Georgia 30507 www.cottrelltrailers.com; 1-800-827-0132 If after having attempted to take advantage of this recall you believe you have not been able to have your 2-Car Carrier vehicle remedied without charge and within a reasonable amount of time, you may submit a complaint to the Administrator, National Highway Traffic Safety Administration, 1200 New Jersey Ave., S.E., Washington, D.C., 20590; or call 1-888-327- 4236 (TTY: 1-800-424-9153); or go to https://www.nhtsa.gov. Sincerely, Austin Peal Austin Peal / Warranty Coordinator [email protected] 1-800-827-0132 Ext. 103 February 2, 2022 Penske Leasing The following VIN’s are involved in campaign. Total Units Remaining 2 Cottrell Order# Tractor VIN G001575501 54DK6S164LS G001595701 54DK6S165MS KIT 169610 INCLUDES: 2 X REFLECTOR 98003R 2 X REFLECTOR 98003Y 1 X ALCOHOL WIPE 1 . CLEAN MOUNTING SURFACE OF ANY GREASE OR DIRT. 2 . REMOVE PROTECTIVE PAPER BACKING AND PLACE REFLECTOR (98003R/Y) IN A HORIZONTAL ORIENTATION AS SHOWN. 3 . PRESS FIRMLY TO ENSURE ADHESION. REFLECTOR INSTALLATION GUIDE 2-CAR DELIVERY UNITS MANUFACTURED BY COTTRELL, INC. REAR VIEW OF UNIT CENTER RED REFLECTOR (98003R) VERTICALLY ON THE SURFACE IMMEDIATELY ADJACENT TO STOP/TAIL/TURN LIGHTS ON EACH SIDE. ALIGN CENTER OF AMBER REFLECTOR (98003Y) WITH CENTER OF MID-TURN LIGHT AND PLACE DIRECTLY ADJACENT TO LIGHT ON EACH SIDE. REAR OF UNIT DOC04508

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 21V-863 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Cottrell, Inc. Submission Date : JAN 10, 2022 NHTSA Recall No. : 21V-863 Manufacturer Recall No. : 2021 2-Car Reflector Manufacturer Information : Manufacturer Name : Cottrell, Inc. Address : 2125 Candler Road Gainesville GA 30507 Company phone : 770-532-7251 Population : Number of potentially involved : 40 Estimated percentage with defect : 100 % Vehicle Information : Vehicle 1 : 2019-2022 Cottrell 2-Car Carrier Vehicle Type : TRAILERS Body Style : OTHER Power Train : DIESEL Descriptive Information : Forty (40) 2-Car Carriers built between 11/19/2018 and 11/01/2021 were missing four (4) side-rear reflex reflectors that are required in FMVSS 108. Production Dates : NOV 19, 2018 – NOV 01, 2021 VIN Range 1 : Begin : NR End : NR Not sequential Description of Noncompliance : Description of the Noncompliance : Forty (40) 2-Car Carriers built between 11/19/2018 and 11/01/2021 were missing four (4) side-rear reflex reflectors that are required in FMVSS 108. FMVSS 1 : 108 – Lamps, reflective devices, and assoc. Equipment FMVSS 2 : NR Description of the Safety Risk : Non-Compliance with FMVSS 108. Absence of the reflex reflectors may lessen the visibility of the 2-Car Carrier which may increase the risk of a motor vehicle crash. Description of the Cause : Forty (40) 2-Car Carriers built between 11/19/2018 and 11/01/2021 were missing four (4) side-rear reflex reflectors that are required in FMVSS 108. Identification of Any Warning that can Occur : NR Involved Components : Part 573 Safety Recall Report 21V-863 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Component Name 1 : 2-Car Reflex Reflector Kit Component Description : 2 Amber & 2 Red (4 total) Reflectors, Cleaning Wipe & Installation Instructions Component Part Number : 169610 Supplier Identification : Component Manufacturer Name : Cottrell, Inc. Address : 2125 Candler Road Gainesville Georgia 30507 Country : United States Chronology : As part of an FMVSS internal review, and following a full and thorough investigation, Cottrell determined on 11/01/2021 that forty (40) 2-Car Carriers built between 11/19/2018 and 11/01/2021 were missing four (4) side/rear reflex reflectors that are required in FMVSS 108. Description of Remedy : Description of Remedy Program : Cottrell has finalized an Installation Guide with pictures/diagrams and specific instructions on how to install the four (4) missing reflex reflectors on the 2-Car Carriers. Cottrell will provide all parts needed free of charge to the customer, along with the installation guide, and will reimburse labor costs up to one-half hour per unit. If any customer incurred costs to install the four (4) missing reflectors prior to notice of this recall (which Cottrell believes is highly unlikely considering only three (3) customers were involved and Cottrell is in direct communication with each of those three (3) customers), then Cottrell will reimburse the customer for the costs of the four (4) reflectors as well as labor costs up to one-half hour per unit for installing them. How Remedy Component Differs from Recalled Component : Once the four (4) missing reflex reflectors are installed on the 2-Car Carriers in the field, then there will not be a difference. Identify How/When Recall Condition was Corrected in Production : Beginning with units manufactured and completed on or before November 1, 2021, the four (4) reflex reflectors are being installed in production. Recall Schedule : Part 573 Safety Recall Report 21V-863 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Description of Recall Schedule : There are only three (3) customers involved in this recall. Cottrell has already prepared recall kits, an installation guide and letters to the three (3) customers, and those letters are all going out today, November 5, 2021. 1/10/22 UPDATE: Notifications went out to the 3 owners involved as scheduled back on 11/5/21 so the dates provided in the initial 573 filing are correct. there are NO dealers or distributors involved in this recall, so there are no dealer notifications. Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : NOV 05, 2021 – NOV 05, 2021 * NR – Not Reported

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 21V-863 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Cottrell, Inc. Submission Date : NOV 05, 2021 NHTSA Recall No. : 21V-863 Manufacturer Recall No. : 2021 2-Car Reflector Manufacturer Information : Manufacturer Name : Cottrell, Inc. Address : 2125 Candler Road Gainesville GA 30507 Company phone : 770-532-7251 Population : Number of potentially involved : 40 Estimated percentage with defect : 100 % Vehicle Information : Vehicle 1 : 2019-2022 Cottrell 2-Car Carrier Vehicle Type : TRAILERS Body Style : OTHER Power Train : DIESEL Descriptive Information : Forty (40) 2-Car Carriers built between 11/19/2018 and 11/01/2021 were missing four (4) side-rear reflex reflectors that are required in FMVSS 108. Production Dates : NOV 19, 2018 – NOV 01, 2021 VIN Range 1 : Begin : NR End : NR Not sequential Description of Noncompliance : Description of the Noncompliance : Forty (40) 2-Car Carriers built between 11/19/2018 and 11/01/2021 were missing four (4) side-rear reflex reflectors that are required in FMVSS 108. FMVSS 1 : 108 – Lamps, reflective devices, and assoc. Equipment FMVSS 2 : NR Description of the Safety Risk : Non-Compliance with FMVSS 108. Absence of the reflex reflectors may lessen the visibility of the 2-Car Carrier which may increase the risk of a motor vehicle crash. Description of the Cause : Forty (40) 2-Car Carriers built between 11/19/2018 and 11/01/2021 were missing four (4) side-rear reflex reflectors that are required in FMVSS 108. Identification of Any Warning that can Occur : NR Involved Components : Part 573 Safety Recall Report 21V-863 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Component Name 1 : 2-Car Reflex Reflector Kit Component Description : 2 Amber & 2 Red (4 total) Reflectors, Cleaning Wipe & Installation Instructions Component Part Number : 169610 Supplier Identification : Component Manufacturer Name : Cottrell, Inc. Address : 2125 Candler Road Gainesville Georgia 30507 Country : United States Chronology : As part of an FMVSS internal review, and following a full and thorough investigation, Cottrell determined on 11/01/2021 that forty (40) 2-Car Carriers built between 11/19/2018 and 11/01/2021 were missing four (4) side/rear reflex reflectors that are required in FMVSS 108. Description of Remedy : Description of Remedy Program : Cottrell has finalized an Installation Guide with pictures/diagrams and specific instructions on how to install the four (4) missing reflex reflectors on the 2-Car Carriers. Cottrell will provide all parts needed free of charge to the customer, along with the installation guide, and will reimburse labor costs up to one-half hour per unit. If any customer incurred costs to install the four (4) missing reflectors prior to notice of this recall (which Cottrell believes is highly unlikely considering only three (3) customers were involved and Cottrell is in direct communication with each of those three (3) customers), then Cottrell will reimburse the customer for the costs of the four (4) reflectors as well as labor costs up to one-half hour per unit for installing them. How Remedy Component Differs from Recalled Component : Once the four (4) missing reflex reflectors are installed on the 2-Car Carriers in the field, then there will not be a difference. Identify How/When Recall Condition was Corrected in Production : Beginning with units manufactured and completed on or before November 1, 2021, the four (4) reflex reflectors are being installed in production. Recall Schedule : Part 573 Safety Recall Report 21V-863 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Description of Recall Schedule : There are only three (3) customers involved in this recall. Cottrell has already prepared recall kits, an installation guide and letters to the three (3) customers, and those letters are all going out today, November 5, 2021. Planned Dealer Notification Date : NR – NR Planned Owner Notification Date : NOV 05, 2021 – NOV 05, 2021 * NR – Not Reported

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