Equipment Query EQ08-011: RICON/THRESHOLD WARNING/ANTI-STOW

ON 11/2/2007 RICON FILED TWO NONCOMPLIANCE REPORTS FOR THEIR S SERIES AND K SERIES PLATFORM STYLE WHEELCHAIR LIFTS.RICON IDENTIFIED CERTAIN WHEELCHAIR LIFTS (07E-095), MANUFACTURED BETWEEN 4/1/2005 AND 10/9/07, AS FAILING TO COMPLY WITH THE THRESHOLD WARNING SYSTEM REQUIREMENTS OF FMVSS 403 S7.4.

THESE LIFTS' THRESHOLD WARNING SYSTEM MIGHT NOT ACTIVATE IF A MOBILITY AID (SUCH AS A WHEELCHAIR) MOVES TOWARD A CERTAIN POINT IN THE THRESHOLD AREA.SHOULD THIS SYSTEM NOT OPERATE PROPERLY, THE WHEELCHAIR LIFT OCCUPANT MIGHT FALL FROM THE LIFT AND SUFFER INJURY.RICON SUBMITTED ANOTHER NONCOMPLIANCE REPORT (07E-097) FOR THE S SERIES & K SERIES WHEELCHAIR LIFTS, ENCOMPASSING SOME OF THE LIFTS FROM THE ABOVE RECALL.MANUFACTURED BETWEEN 4/1/05 AND 6/6/2006, CERTAIN LIFTS MAY FAIL TO COMPLY WITH THEIR ANTI-STOW INTERLOCK REQUIREMENTS OF FMVSS 403 S7.

THE PRESSURE SENSING SWITCH THAT DETECTS WEIGHT ON THE PLATFORM MIGHT NOT BE ADJUSTED TO THE PROPER SENSITIVITY LEVEL.THESE LIFTS MIGHT BEGIN TO TILT TOWARD THE VEHICLE AND BEGIN TO STOW WHILE AN OCCUPANT IS STILL ON THE LIFT.THIS MAY CAUSE THE OCCUPANT TO SLIDE OR FALL FROM THE LIFT AND SUFFER INJURY.ON SEPTEMBER 8, 2008 RMD MAILED LETTERS TO 183 COMPANIES, WHICH CONSTITUTED THE ENTIRETY OF RICON'S CUSTOMER LIST FOR THE RECALLED PRODUCTS, ADVISING THEM OF RICON'S RECALL AND REQUESTING THAT THEY FILE THEIR REQUIRED REPORTS.RMD FOLLOWED THAT MAILING WITH A2ND IR LETTERON 11/17/2008.

AS A RESULT OF THOSE MAILINGS, A TOTAL OF 53 COMPANIES DECIDED TO SUBMIT A NONCOMPLIANCE REPORT AND CONDUCT A SAFETY RECALL FOR THE VEHICLES THEY MANUFACTURED OR ALTERED AS NEW VEHICLES WITH THE INSTALLATION OF THESE RECALLED WHEELCHAIR LIFTS.A TOTAL OF 95 RECALLS (MANY COMPANIES FILING A REPORT FOR EACH RECALL) WERE RECEIVED AS A RESULT OF THESE INITIAL MAILINGS.IN THE COURSE OF THE EQ, IT WAS LEARNED THAT ONE OF RICON'S CUSTOMERS, VANTAGE MOBILITY INTERNATIONAL (VMI), ACTUALLY DISTRIBUTED ITS WHEELCHAIR LIFTS TO HUNDREDS OF OTHER COMPANIES.VMI HAD NOTIFIED MANY OF ITS CUSTOMERS OF THE RICON RECALLS, BUT NONE OF THOSE COMPANIES HAD NOTIFIED NHTSA OF ANY NEW VEHICLES MANUFACTURED OR ALTERED WITH THIS EQUIPMENT.ON JUNE 17-19, 2009 RMD MAILED 502 ADDIONAL IR LETTERS.THESE LETTERS CONTAINED A SET OF QUESTIONS ASKING IF THE RECALLED LIFTS WERE INSTALLED INTO NEW OR USED VEHICLES AND ALSO ASKED IF VIN INFORMATION WAS RECORDED BY THE COMPANY.IN THE EVENT THE COMPANIES WOULD NOT BE ABLE TO NOTIFY THEIR CUSTOMERS, RMD WANTED TO KNOW IF VIN INFORMATION COULD BE TRANSMITTED BACK TO RICON FOR PROPER CUSTOMER NOTIFICATIONS BASED ON STATE REGISTRATION RECORDS.A TOTAL OF 17 COMPANIES FILED 31 NONCOMPLIANCE REPORTS AS A RESULT OF THE JUNE 2009 MAILING.A TOTAL OF 126 SAFETY RECALLS WERE CONDUCTED AS A RESULT OF THIS EQUIPMENT QUERY.A TOTAL OF 258 COMPANIES FAILED TO RESPOND TO RMD'S IR LETTERS AND THEY WILL BE REFERRED TO THE OFFICE OF THE CHIEF COUNSEL FOR FURTHER ACTION.TOTALS AND THE EQ MAILING SPREADSHEET ARE ATTACHED BELOW AND AVAILABLE IN THE DOCUMENT REPOSITORY.THIS EQ IS CLOSED.