Step rivets may shear

RMD opened RQ17-006 on September 8, 2017, to investigate the adequacy of the scope and remedy of safety recall 15E-013. RMD issued an Information Request (IR) to Hickory Spring Manufacturing (HSM), the recalling manufacturer, on August 22, 2017 requesting, among other things, an explanation of the how HSM determined which stair steps to recall, and information concerning the integrity and adequacy of the remedy which involved a newly designed rivet. RMD reviewed the IR response and its accompanying data which included production data, purchaser and distribution information, notification letters, rivet kit samples, testing information and field failure information. Through this examination RMD discovered HSM had incorrectly reported the recalled step manufacturing dates, and had overlooked identifying six affected models in its-recall information report. These mistakes did not impact the recall's overall population figures. RMD reviewed the design specifications, together with complaints and early warning reporting (EWR) data, to verify the remedy's adequacy. RMD also reviewed the various follow-on recall campaigns being conducted through several recreational vehicle (RVs). This work resulted in finding that KZRV, a RV manufacturer, had overlooked 312 sets of steps in its follow-on-recall 15V-173. As a result, KZRV filed an amended recall information report to recall those steps and notified the impacted RV owners in December 2017. At this time RMD is satisfied that the scope and remedy of the HSM recall is sufficient. Accordingly, this RQ is closed.