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NHTSA defect investigation · Preliminary Evaluation

Equipment preliminary evaluation PE15007

LCI RV Entry Step Failures. NHTSA’s Office of Defects Investigation opened this preliminary evaluation about the hinge and attachments. Opened Feb 27, 2015, closed Oct 19, 2015 after 8 months. It led to safety recall 15E078000, 15V745000, 15V798000, 15V872000, 15V880000, 16V003000, 16V007000, 16V008000, 16V039000, 16V132000. became a recall

What NHTSA says

Source: Office of Defects Investigation, as filed

The Office of Defects Investigation (ODI) opened this investigation based on four Vehicle Owner Questionnaires (VOQ).The VOQs report failures of the motorized entry steps used on some recreational vehicles. When extended the steps reach out and down from the vehicle. In the retracted position the step platforms are stacked on top of each other in a compact package under the vehicle body. The gear used to actuate the steps can separate from the actuation motor allowing the steps to unintentionally extend or retract in an uncontrolled fashion. ODI was aware of one injury event prior to opening the investigation. An additional four injuries were reported to Lippert Controls Inc. (LCI) during the investigation. An Information Request Letter (IR) was sent to LCI in order to gather detailed information about the alleged defect. ODI analyzed the IR response data, simulated the failure on an exemplar set of stairs, and inspected broken parts. Complaint and warranty data indicated that the alleged defect was occurring at a significant rate. Constructing a test stand and recreating the failure mode clearly demonstrated the safety consequence of a separated drive gear. Extended steps with a separated drive gear retract when a vertical force is applied to the step. This retraction can capture an individual's foot or ankle as they ascend or descend the steps. Such an action can cause the individual to fall more than three feet to the ground. After analyzing the failure mode, the Vehicle Research and Test Center (VRTC) suggested that the center drive gear bolt appeared to fail from a bending moment. Several conditions might contribute to this type of failure. LCI reported no design changes during the production of the subject components including the drive gear bolt. Through testing, LCI attempted to determine the root cause of the gear bolt failures, but voluntarily recalled the subject components prior to completing this testing and making this determination. This investigation is closed because recall 15E-007 addresses the alleged safety defect. The ODI reports cited above can be reviewed at: http://www-odi.nhtsa.dot.gov/owners/SearchNHTSAID under the following complaint identification numbers:10537821, 10605447, 10684011, 10684277

Stage Preliminary Evaluation — NHTSA works to complete one within eight months Opened Feb 27, 2015 Closed Oct 19, 2015 Manufacturer Lippert Components Structure › Body › Door › Hinge And Attachments Resulting recall 15E078000, 15V745000, 15V798000, 15V872000, 15V880000, 16V003000, 16V007000, 16V008000, 16V039000, 16V132000

A Preliminary Evaluation is the first formal stage: NHTSA has decided the complaints and other information it screened are worth a closer look, and asks the manufacturer for its own data on the condition. The summary is the agency’s own text from its investigation file, unedited; the opening and closing resumes with the full reasoning are on NHTSA’s site under this number.

What this means for an owner

Source: and what happens next

An investigation is not a finding that a defect exists, and it puts no duty on anyone. NHTSA opens a Preliminary Evaluation when complaints and other reports suggest a condition worth asking the manufacturer about; it upgrades to an Engineering Analysis when the answers warrant testing; it closes either when it recommends a recall, when the manufacturer recalls on its own, or when no defect trend is found. The agency’s own goals are about four months for a petition, eight for a Preliminary Evaluation or a Recall Query and eighteen for an Engineering Analysis; many run longer.

This one became a recall. The campaign page carries the manufacturer’s filed defect, risk and remedy, the build window and every model year covered; whether one specific vehicle is included is settled by VIN at nhtsa.gov/recalls.

Model years it names

Source: as NHTSA filed them

NHTSA filed this action against Lippert without naming a model year — an equipment or manufacturer-level query.

Common questions

Source: NHTSA Office of Defects Investigation

Is PE15007 a recall?

No — it is the investigation that led to one. Recall 15E078000, 15V745000, 15V798000, 15V872000, 15V880000, 16V003000, 16V007000, 16V008000, 16V039000, 16V132000 is the campaign; its page carries the remedy.

Is PE15007 still open?

No. It closed on Oct 19, 2015 and led to recall 15E078000, 15V745000, 15V798000, 15V872000, 15V880000, 16V003000, 16V007000, 16V008000, 16V039000, 16V132000.

Which vehicles does PE15007 cover?

NHTSA filed it against Lippert without naming a model year.