Webasto Sunroof Separation

On August 10, 2010, Webasto notified the NHTSA that it had decided certain Hollandia 600/700 & Hollandia TVS 900 aftermarket sunroofs contained a safety related defect. Webasto stated that these sunroof models, manufactured between 2002 and 2010, may experience an adhesive bond failure where the sunroof glass attaches to its frame. This failure increases the risk of the glass detaching from the vehicle and causing injury to other motorists or pedestrians. This recall was assigned number 10E-038. Webasto and its counsel met with RMD on August 18, 2010 to discuss the recall's next steps. RMD learned that the majority of these products are installed by a third party, on new motor vehicles that have not yet been retailed, often at the request of a new car dealership. These installers are required to notify the NHTSA of any new vehicles they altered by way of a Part 573 Defect Report. On September 2, 2010, RMD issued an information request (IR) letter to Webasto requesting a list of companies who purchased the defective sunroof models. Webasto replied on September 9, 2010, submitting a purchaser list to NHTSA's Office of the Chief Counsel (NCC) for confidentiality consideration. NCC granted this confidentiality request as the release of Webasto's purchaser list could cause substantial competitive harm. Due to the large number of companies that purchased these sunroofs, RMD worked with Webasto to ensure notifications to Webasto's authorized installers (AIs) included instructions on how to file a Defect Report with NHTSA should one be required. For those AIs that altered new vehicles (vehicles not yet delivered to the first retail purchaser), the AI notification letter offered guidance on how to submit a Defect Report to NHTSA and instructions that a third party, Impartial Services Group, LLC (ISG), would be contacting them to obtain VIN information for vehicles they altered as new. ISG obtained VIN information from each AI and returned to them a computerized list of vehic