HANGZHOU REPLACEMENT REAR WINDOW GLASS

SAFELITE FULFILLMENT, INC. SUBMITTED A 573 DEFECT AND NONCOMPLIANCE INFORMATION REPORT ON 11/19/2007 REGARDING CERTAIN REPLACEMENT REAR WINDOW GLASS MANUFACTURED BY HANGZHOU SAFETY GLASS CO., LTD. SAFELITE DISCOVERED THAT THREE DOT 430 PART NUMBERS DIFFERED IN COLOR AND OTHER NON-STRUCTURAL COMPONENTS WHICH COULD CAUSE THE TEMPERED GLASS TO BREAK INTO LARGER PIECES THAN CONSIDERED ACCEPTABLE. LARGE SHARDS OF GLASS POSE A SAFETY RISK TO OCCUPANTS INSIDE A MOTOR VEHICLE. RMD RECEIVED AN ADDITIONAL DEFECT REPORT FROM POLYMER PROCESS DEVELOPMENT (PPD) ON 3/6/08 SHORTLY AFTER THIS EQ WAS OPENED. PPD STATED THEIR NONCOMPLIANT GLASS WAS ALSO RECEIVED FROM WHOLESALE AUTOMOTIVE. RMD MAILED AN INFORMATION REQUEST LETTER TO WHOLESALE AUTOMOTIVE ON 4/4/08 REQUESTING THE REASON WHOLESALE AUTOMOTIVE HAD NOT FILED A DEFECT REPORT FOR THIS NONCOMPLIANCE. WHOLESALE AUTOMOTIVE REPLIED ON 4/15/08 THAT COMPANY RERESENTATIVES WERE SENT TO CHINA TO SPEAK WITH THE MANUFACTURER AND DEMAND AN INVESTIGATION. WHOLESALE AUTOMOTIVE ALSO STATED THAT THEY WERE WORKING WITH AN INDEPENDENT LAB TO VERIFY THE NONCOMPLIANCE AND THAT THEIR CUSTOMERS WOULD BE NOTIFIED OF THE ISSUE ONCE/IF CONFIRMED. AFTER MORE THAN 30 DAYS WITH NO RESPONSE, RMD AGAIN WROTE WHOLESALE AUTOMOTIVE ON 5/28/08 REQUESTING THE LAB RESULTS. A RESPONSE WAS RECEIVED ON 6/11/08 STATING WHOLESALE AUTOMOTIVE WAS HAVING DIFFICULTY IN FINDING A REASONABLY PRICED LABORATORY TO CONDUCT THE TESTING. RMD MET WITH OVSC TO DISCUSS THE POSSIBILITY OF NHTSA CONDUCTING FURTHER NONCOMPLIANCE TESTING ON THE RECALLED REPLACEMENT GLASS. AT PRESENT, NO STANDARD PROCESS EXISTS FOR GLAZING TESTING WITHIN NHTSA. IT WAS QUESTIONED WHETHER THE COMPANIES RECALLING THE GLASS (SAFELITE & PPD) ALTERED THE GLASS IN ANYWAY THAT COULD TRANSFER RECALL RESPONSIBILITY TO THEIR BEHALF AS THE FINAL MANUFACTURER OF THE GLASS. AFTER INQUIRES TO BOTH COMPANIES IN EARLY JULY, IT WAS DISCOVERED THAT THE GLASS IS IMPORTED PRE-CUT & GLAZED FOR FINAL INSTALLATION. WITH THIS