A PETITION TO

THE NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

U.S. DEPARTMENT OF TRANSPORTATION

400 Seventh Street, S.W.

Washington, D.C. 20590

Subject:

Investigation of Defects Present in 1989 - 2000 Volvo Trucks

March 21, 2001

TABLE OF CONTENTS

Introduction

II. Background

III. Summary of Volvo Truck Complaints

IV. Shaking and Vibration in the Front of Volvo Trucks

V.  Steering Problems With Volvo Trucks

VI. Premature Tire Wear on Volvo Trucks

VII. Problems Keeping Volvo Trucks in Alignment

VIII. Problems With Volvo Axles

A. Problems with the axle and the parts surrounding the axle

B. Overweight Steering Axle

IX. Problems With Volvo Truck Suspension

X. Malfunctioning of the Volvo Truck Transmission

A. General Transmission Problems

B. Clutch Problems

XI. Problem with the Engine Racing and Shutting Down

XII. Problem with the Volvo Truck Electrical System

XIII. Conclusion

I. INTRODUCTION

The Owner-Operator Independent Drivers Association, Inc. hereby petitions the Department of Transportation (DOT'') and the National Highway Traffic Safety Administration (''NHTSA'') to commence a proceeding, pursuant to 49 U.S.C. § 30162, 49 C.F.R. § 552 and 49 C.F.R. § 554, to investigate defects related to motor vehicle safety. Additionally, this petition requests that DOT and NHTSA issue an order, pursuant to 49 U.S.C. § 30118(b), requiring the manufacturer of the vehicle subject to the investigation to give notice of any defect to owners, purchasers, and dealers of the vehicles (pursuant to 49 U.S.C. § 30119) and to remedy the defect (pursuant to 49 U.S.C. § 30120). The petition sets forth evidence that Volvo heavy duty trucks manufactured between 1989 and 2000 may contain defects that pose the potential for loss of life and serious injury.

II. BACKGROUND

The Owner-Operator Independent Drivers Association, Inc. (''OOIDA'' ) is a business association of persons and entities, commonly known as ''owner-operators'', who own and operate their own motor carrier equipment. OOIDA is a not-for-profit corporation incorporated in the State of Missouri, with its headquarters located at 311 R.D. Mize Road, P.O. Box 1000 Grain Valley, Missouri 64029.

OOIDA was founded in 1973 and now has over 60,000 members residing in all fifty (50) states and in Canada. Owner-operators are typically small business men and women who own and operate Class 7 and 8 trucks (large tractor- trailers) in interstate commerce. Owner-operators typically lease their equipment, with drivers, to private carriers and/or regulated motor carriers operating under the authority granted by the DOT and formerly by the Interstate Commerce Commission (''ICC''). Owner-operators comprise one of the primary sectors of the interstate motor carrier industry, accounting for the transportation of an estimated forty percent (40%) of all inter-city truck traffic in the United States.

OOIDA serves as an advocate for owner-operators on a number of issues. It has a member services department which receives information and complaints from members on a variety of issues, including safety. In mid-1999, OOIDA received a telephone call from a member, Douglas Fabish of Eugene, Oregon, complaining of serious problems with his 1997 Volvo WIA664TTES truck. Mr. Fabish detailed problems with front-end vibration, premature steer tire wear and shearing suspension bolts.

Within a few weeks, OOIDA received four more complaints from owner-operators regarding Volvo trucks. OOIDA decided to query Volvo owners in the OOIDA member database. OOIDA received more than fifty written complaints concerning Volvo trucks. These complaints included front-end vibration and premature wear on steer tires.

OOIDA publishes a monthly magazine, Land Line, which highlights safety issues for owner-operators. In its March 2000 issue, Land Line published an article regarding Volvo- related complaints and asked readers experiencing problems with Volvo trucks to advise OOIDA by letter. Upon receipt of a written complaint, OOIDA sent to each complainant a form questionnaire seeking additional and more detailed information.

By the end of this inquiry, OOIDA received a total of one hundred and eighty five (185) written complaints regarding problems involving two hundred and sixty (260) Volvo trucks. The written complaints and returned questionnaires were collected and the evidence evaluated. The substance of these complaints comprise the evidentiary support for the petition's request that NHTSA commence an investigation for safety-related defects in Volvo trucks manufactured from 1989 to the present.

III. SUMMARY OF VOLVO TRUCK COMPLAINTS

The vast majority of complaints received by OOIDA from Volvo truck owners concerned the front end of the truck. Sixty-seven complaints reported the incidence of severe vibration, shaking, and noise centered in the front of the truck. Seventeen complaints reported trouble steering and controlling the truck. Several Volvo owners have discovered that their truck is overweight on the steering axle, even when not hitched to a loaded trailer.

Many other problems were reported that may be caused by the truck's shaking and vibration. These include various parts wearing down prematurely, various parts failing and falling off the truck, and the electrical system malfunctioning. With regard to the truck's body, windows have blown out and doors and hoods have failed to shut properly. These truck components may be defective themselves, or their failure may be a result of a chain reaction derived from a larger problem. This is one of the questions that OOIDA asks NHTSA to investigate.

The following is an outline of problems that have been reported by Volvo truck owners. Some Volvo truck owners reported only on their mechanical problems. Others described incidents in the operation of their truck that created hazardous conditions on the road or highway.

Finally, we have excerpted comments made by Volvo mechanics and dealers to Volvo owners, regarding the reputation of Volvo trucks. These comments demonstrate that the problems reported are not isolated incidents but have been experienced by other Volvo owners with some level of frequency.

OOIDA believes that these reports of serious problems with Volvo trucks form a sufficient basis for the initiation of a NHTSA safety defect investigation. The vehicle involved is a widely purchased commercial motor vehicle in use by thousands of drivers each day. The hazardous situations reported by its owners demonstrate a serious risk of injury and death to truck drivers, other members of the motoring public, and pedestrians.

IV. SHAKING AND VIBRATION IN THE FRONT OF VOLVO TRUCKS

The most frequently mentioned problem with Volvo trucks is a violent vibration and shaking coming from the front of the vehicle. Vibration and shaking, no matter the cause, can seriously affect a driver's ability to operate a truck safety.

Mr. & Mrs. Ben Lowell (VOL000256), of Shelton, Washington, were forced to stop driving as a team because of the vibration and shaking. Mrs. Lowell now stays home instead of driving with her husband. ''My husband and I pull munitions and the truck must roll or be watched 24 hours a day. You can imagine the safety hazards of a team in a truck that it is almost impossible to sleep in while moving.'' Sleep and rest is an important factor in the safe operation of a truck. Any team driver in a Volvo truck who cannot sleep is a danger on the highway.

Mr. David Wilmot (VOL000187), of Jackson, Tennessee reports that the shaking affects his ability to use his mirrors. ''[I] [d]idn't think anything could vibrate and distort the images worse than my Harley...'' Any condition that prevents drivers from being able to use their mirrors impairs their ability to see the road, safely change lanes, and enter or exit the highway. Internal truck parts are also affected by shaking and vibration. Mr. & Mrs. Tim Margis  (VOL000242), reported that ''the alternator fell off while going down to the road ... I was lucky it didn't fall on the road ... it was laying on the wheel well...'' Other internal parts that may have been affected by shaking and vibration are outlined in the following section.

Shaking and vibration may also be the cause of problems experienced with the truck's body and cab. For example, Mr. Gary Wallace (VOL00086), of Columbia City, Oregon, reports that the windows on the passenger side of his truck ''blew out. '' A window blowing out in a truck traveling down the road creates a difficult driving condition for the driver and is a potential hazard to others. When Mr. Wallace reported the incident to Volvo, they told him that they "were aware of this problem and had issued new parts to facilitate the repairs of the faulty parts.'' Mr. Wallace points out, however, that Volvo did not contact him to make the repair before his incident.

Another problem is that of the truck's hood not shutting properly. In a complaint made to both OOIDA and NHTSA, Ms. Christine Edmondson (VOL000404) described the problem of the truck's hood popping open while she was driving her truck. This is another situation where a problem with the truck impaired the driver's view of the road and other vehicles.

Vibration and shaking are typically reported as the first signs to Volvo owners that there is a problem with their truck. This behavior, however, appears to be related to other serious problems.

V. STEERING PROBLEMS WITH VOLVO TRUCKS

Forty-five drivers reported problems steering the truck. This is sometimes referred to as ''road walk'' or as the truck pulling to one side. Properly functioning vehicles should not have a steering problem. In the experience of Volvo owners, repeated realignments of Volvo trucks rarely fix this problem permanently.

Others reported more serious steering problems.

Mr. & Mrs. Harold Hains (VOL 188-206), of Cassville, Missouri, reported that among other problems, ''Our steering wheel locked up on us at an off-ramp, my husband has to use all of his strength to brake it free. And our horn didn't work. '' This incident had the potential to cause a serious accident, without the driver being able to warn surrounding vehicles.

Mr. & Mrs. Ray Kasicki (VOL000219-0200), of Cleveland, Ohio, reported that when they were in Boston and backing into a dock, ''the steering column fell into our lap. The steering wheel bracket that holds the tilt and telescoping wheel to the dash board broke. '' The Kasickis continued, ''We then complained to the [Volvo] service reps at the Louisville truck show and told them this was a very serious safety problem. What would have happened if this would have broken if we were driving down the road?''

Mr. & Mrs. Douglas Grattafiori (VOL000070-071), of Brighton, Michigan, reported that while pulling forward in a line at a container port, the gear box of their Volvo truck ''popped'' out onto the ground, along with all of the power steering fluid. The truck lost its steering, and, "[t]hank God it didn't happen coming down Jelico M[ountain].'' If the truck had fallen apart on a winding mountain road, the loss of steering would have caused a catastrophic accident with likely fatalities.

These problems may be related to the truck's shaking and vibration. Whether or not they are related to a larger problem in the truck, these problems by themselves are defects which justify a NHTSA investigation.

VI. PREMATURE TIRE WEAR ON VOLVO TRUCKS

By far, the most frequently cited problem, reported in one-hundred and sixty (160) complaints, is the premature tire wear. Volvo owners report that the life of their tires is one-third to one-half that of tires on other trucks. Thirty-five complaints of premature tire wear specified that such wear occurred on their truck's steering tires. Twelve complaints described the tire wear as "cupping'' and one complaint reported an incident of tire blowout.

A typical account of premature tire wear is that of Russ Heroux (VOL 000074-075), of Cypress, California. He reported, ''When I bought the truck I got 28,000 miles on my front steer tires ... The second set of steers last[ed] 84,000 ... I should be able to get 120,000 [miles] out of a set of steer tires.]'' Each time Mr. Heroux bought new steer tires he was given a different reason for their wear.

Although the economic burden of replacing steer tires frequently is a significant problem for Volvo owners, that is not the only problem presented by prematurely wearing tires. Tires that endure unusual pressure and wear from the truck can fail and create a very dangerous situation. From the time Mr. & Mrs. Marvin Phillips (VOL000307), of Jamestown, Indiana, bought their truck, they heard and felt a popping sound from under the truck. Volvo told the Phillips that ''all trucks do that. One day while driving, they ''...blew the right steer tire without apparent reason. It also ripped part of the fender and steps off (we never found any part of the blown tire.)'' Since that event, they have not felt safe in their truck.

Volvo told other drivers that premature tire wear was normal. Mr. & Mrs. Larry Gills, of Mercer, Pennsylvania, (VOL000068) complained to Volvo after replacing several parts, including the steer tires after only 50,000 miles. They were told by Volvo that ''it was the nature
of the vehicle.''

Ms. Sarah Cilley (VOL000319-322), of Fredonia, Wisconsin, received a similar response from Volvo. In a letter, Volvo first blames premature tire wear on a lack of maintenance by the truck owner. Then Volvo, stated ''I can assure you we have many customers that are experiencing tire wear that is equal or greater to vehicles of other manufacturers.''

Premature tire wear is a major economic burden on small business truckers, and it is a problem that has manifested itself frequently in Volvo trucks. Tire failure, especially on steer tires, creates a hazardous condition on the roadway. The only line of defense against premature tire wear turning into tire failure on the highway is the conscientious truck owner who constantly monitors the operating condition of his or her vehicle. It appears, though, that this is a symptom of a larger problem with Volvo trucks. The safety implications of these problems are significant, and warrant being a part of a NHTSA investigation.

VII. PROBLEMS KEEPING VOLVO TRUCKS IN ALIGNMENT

Volvo owners frequently blame premature tire wear and the shaking and vibration on their truck's inability to maintain an alignment.

Fifty-five Volvo owners described problems with their truck's alignment. As Mr. Robert Hudgins, from Clyde, Texas, (VOL 000079-81, 000290) reported, improper alignment was the primary suspect for excessive tire wear. The truck refused to maintain proper alignment and repeated attempts at realignment failed to solve the excessive tire wear problem.

Mr. Hudgins bought his truck in March, 1998, with 228,202 miles on the odometer and ten new tires. He reported, ''In June '98, 1 had a complete three axle alignment done because all tires were wearing excessively ([at] 274,120 miles). At 284,829 miles I replaced the steer tires (July '98). At 318,799 miles (Sept. 98) 1 replaced the drive tires, all eight because of uneven wear and had another three axle alignment. At 347,860 miles, I replaced all bushing[s] and pins in the front suspension. Replaced the steer tires and [a]nother three axle alignment (Jan. '99).'' None of these efforts solved Mr, Hudgins problems.

After reporting premature tire wear on his steer tires, Charles Honeycutt (VOL000112) of Greenwood, Indiana, was told by Volvo ''that the truck may or may not have been aligned correctly at the factory when it was shipped.''

Although many Volvo owners, and apparently Volvo itself, believe that excessive tire wear is due to poor alignment, complaint after complaint reported that realignments do not last on Volvo trucks, and therefore do not reduce premature tire wear.

VIII. PROBLEMS WITH VOLVO AXLES

A. Problems with the axle and the parts surrounding the axle

Thirty-five Volvo owners complained of unusual wear of an axle and the parts surrounding the axle. The steering axle is identified most frequently with problems. Dennis Young (VOL000210) reported both of his Volvo trucks have the same problems: '' 1) Rear axle center bolts breaking, 2) king pins and spring housing wearing out, 3) front tires prematurely wearing, 4) Aprox[imately] 50,000 miles as average rear axle wearing.'' Mr. Fred Huffman (VOL000215) reported that he ''had lots of trouble keeping the front end in alignment as the [tie] rod ends, spring hangers, bushings and pins have had to be replaced more than usual. After about 25-30 thousand miles the front tires would beat out and have to be replaced.''

John Wallace (VOL000083) reported that ''all U-bolts on front axle broke. Volvo admitted to Mr. Wallace that the ''...bolts came loose all the time, needed to be checked at service intervals.'' Mr. Wallace wrote that the ''Book'' recommends that the bolts must be checked at 15,000 miles intervals, and that this is ''Not a part of normal PM service at truck stops. Volvo claims they do it.''

The failure of an axle and parts associated with the axle have created several dangerous situations on the road. Mr. William Kessel (VOL000247), of Buffalo, New York, reported that he has been ''shut down for rear spring bolts breaking several times.... In fact once all four bolts broke on me while I was pulling a ... load, and the front rear axle came forward and almost killed me.'' Mr. Kessel continued on to report innumerable repairs he has made, the corresponding loss of his business' reliability since his truck is always in the shop, and the fact that these problems have ''ruined my life'' and put him into Chapter 13 bankruptcy.

Other axle failures have resulted in Volvos losing a wheel during operation. Mr. Thomas Pitts (VOL000099) reported that, after complaining of a shimmy in the front end of his truck, the dealer paid for the front end work. ''(2) tie rod ends, front end alignment, rear axle alignment, plus 2 tires. '' Just over two months later, ''the left side steering, rim and hub came off without warning at 70 mph.''

Mr. Andy Bergman (VOL000265), of West Olive, Michigan, experienced the same problem. He wrote that his ''right front hub sheared right off the axle so that one minute I was driving along and the next minute I saw my tire roll off towards the shoulder with the lug nuts still securely fastened and the right side of my axle slammed down on the roadway.''

A truck that instantly loses a wheel and a truck wheel that rolls free into traffic can put the truck driver, other drivers, and pedestrians at risk of death or injury. The safety implications of losing a tire on the highway are extremely serious.

Volvo's axle problems seem well known in the industry. Mr. & Mrs. Terry Foust (VOL000064-067, 289, 291), of Marysville, Kansas, reported that ''numerous mechanics and service technicians with various companies and businesses ... have all had negative output and information on [V]olvo axles. '' Two of them told the Fousts that Volvo axles were ''JUNK.''

When a trucker buys a new truck, he or she expects that the truck is roadworthy. Mr. Mark Wister (VOL000286), of Schontz, Oklahoma, reported that upon investigating his premature tire wear, he discovered that the wheels ''had never been balanced from the factory nor from the dealership.'' In fact, when Mr. Wister asked his salesman about the wheels, ''I was told that balancing was never done at the factory nor at the dealership unless the customer requested it.''

Problems with vibration, alignment, tires, wheels. axles, and surrounding axle components appear to be interrelated. A NHTSA investigation should determine whether the defect in Volvo trucks is in the parts described by these complaints, or whether the problems lie elsewhere else in the truck.

B. Overweight Steering Axle

One of the most curious and disturbing reports concerning Volvo trucks is that they are overweight on the steer axle. This could be a possible source of the axle problems. Mr. Paul Bruinix (VOL000136), of Archbold, Ohio, wrote that Volvo acknowledged the problem with his overloaded steering axle. A scale ticket on his truck showed that his steering axle weighed 11,980 pounds with no trailer attached. Mr. Bruinix further reported that ''The people at Volvo wish to correct the error by removing both fuel tanks and reattaching them further back towards the drive tires. Volvo is also considering changing the brake hubs from steel to aluminum. However, even though the engineering department is admitting error, there is still no word of any kind of settlement for the many dollars spent on prematurely worn tires, etc. or downtime!''

Mr. Dave Johnson (VOL000185, 000234-0235), of Mission Viejo, California, complained to Volvo about his front axle weighing 12,640 pounds ''without any trailer or [back] end weight.'' The engineering department at Volvo admitted to Mr. Johnson that ''it was a flaw and it is known to VOLVO.''

For states that have any maximum steering axle weight limitations, these trucks, with the additional weight of a full trailer, are illegal to drive on the road. Additionally, a truck that is overweight on its steer axle can be the cause of many other mechanical problems. If the axle is not rated for the weight of the truck, the truck can be difficult to handle and steer, and may even fail. Other parts that could strain and fail under the stress of an overweight truck include the suspension, king pins, spindles, hubs, bearings, wheels, and tires. The wear reported on these parts, and the tire blowouts reported by Volvo owners could be a result of the overweight axle. These are important issues that should be included in the scope of a NHTSA investigation.

IX. PROBLEMS WITH THE VOLVO TRUCK SUSPENSION

Eighty complaints described the frequent need to replace loose and worn suspension and suspension-related parts.

The most common suspension problem (detailed in twenty-five complaints) concerns the U-Bolts that hold the suspension to the axle. In many cases Volvo owners found their U-bolts to be either loose or sheared off and missing. James Fountaine (VOL000162), of Janesville, Wisconsin, reported that after finding his rear suspension bolts sheared many times, he was told by a Volvo dealer ''that it is a common replacement item [and] my final cure was to go to [C]aterpillar an[d] get their industrial bolts an[d] put them in an[d] it finally solved the problem.'' Continuing to get tire wear following the replacement of two lower shock mounts, Volvo told Mr. Fountaine, ''that this was a design flaw but not covered by them'' under the warranty. (VOL000163)

Jose Tafurt (VOL000058-60), of Chicago, Illinois, complained that suspension defects had resulted in ''the front end making noises when making turns.'' In Mr. Tafurt's case, his Volvo dealer adjusted the suspension, but the dealer told him that the suspension ''pins were defective metal and they wear out, '' and that ''Volvo knew about the premature wear on the front suspension (rear shocks, pins and bushings).'' (VOL000059-60).

The problems described by Volvo owners are consistent with the theory that these parts face excessive stress consistent with the violent shaking and vibration of the truck.

X. MALFUNCTIONING OF THE VOLVO TRUCK TRANSMISSION

A. General Transmission Problems

Over twenty Volvo owners complained of transmission problems. A frequent transmission problem mentioned was the repeated failure of the clutch. Other problems reported involved incidents where the transmission shifted and acted independently of the driver's actions.

Gary Williams Carr, Ph.D. (VOL000084-085), of Wayne, Maine, reports a problem with his transmission sticking in gear. ''So far the transmission has stuck in 2nd once, 3rd twice, 8^th three times, and 9th once. This is where the safety to the motoring public is gravely impaired.''

Dr. Williams continues:

''Three of the times this has happen[ed], I was in heavy traffic and nobody wants to give a large truck the chance to move over. Have you ever tried to move 78,000 pounds in 8th gear on an incline slipping the clutch on the Atlanta beltway[?] It is not a good move for the drive train. Or when you['re] approaching the Woodrow Wilson Bridge and you['re] in 8th gear again but you have to go over the bridge in heavy traffic to get off the road. Or when it is in the middle of winter with snow banks on both sides of the road and you have to travel 4 miles in 3rd gear before you can get off the road. Or when you are on an off ramp and you want to accelerate and you can not because the transmission is [c]lashing the gear and will not engage. Putting the transmission in the hold position and/or using the up or down buttons does nothing. If this happens only once, one can ignore it but this happen[ed] too many times and the motoring public safety is impaired!''

Mr. Don Scattergood (VOL000255), of Algona, Iowa, also reported that his transmission shifts itself upwards. When he brought it in to be repaired, ''I get the same answer every time. It's characteristic with this model truck.''

When Mr. James Harless (VOL00041 1) of Seaford, Virginia, reported to Volvo the transmission problems he was having with his brand new truck, Volvo informed him that his truck had actually broken down while being driven from the factory to the dealership. Volvo also told Mr. Harless that ''there is some history of problems with this particular shifter.''

B. Clutch Problems

Ms. Sarah Cilley (VOL000319-0320) of Fredonia, Wisconsin, reported the need for fourteen clutch adjustments in one year and the need to replace the clutch at 100,000 miles. Mr. Christopher Wysoki of New Britain, Connecticut, (VOL000180) reported that after driving 10,000 miles he had to repair his clutch. ''Next day in Phoenix AZ VOLVO service I was told that this is the specific problem with that clutch. That all VOLVOS have to be serviced at least every 10,000 miles with the clutch problem.'' Within the next year Mr Wysoki had the clutch repaired four times and then the warranty ran out without a resolution to the problem. Finally, ''in August of [2000] on the highway 1-80 bordering between UT & WY [the] whole clutch system died.''

When Mr. & Mrs. Marvin Phillips (VOL000307-0312), of Jamestown, Tennessee, complained about the clutch not working after it was supposedly fixed, Volvo's reply was ''Learn to shift without the clutch.''

No complaints reported that Volvo was able to fix the clutch problem. A malfunctioning clutch takes control of the truck away from the driver and creates a hazardous condition on the road. As with any problem in which the driver is unable to control a truck, there is the serious risk of a truck accident. This evidence further supports the initiation of a NHTSA investigation.

XI. PROBLEMS WITH THE ENGINE RACING AND SHUTTING DOWN

Volvo owners reported losing control of their vehicle when the engine raced at times and cuts itself off without warning at other times. Mr. & Mrs. Peggy Middleton (VOL000278) reported that their 1998 truck would just quit while going down the road.

Mr. Ira Doss (VOL000239), of Ormond Beach, Florida, reported problems with the truck "running away, getting ''stuck at a specific speed,'' and failing to ''stop accelerating.'' Mr. Doss reported extensively on ''just how dangerous [the truck had] become:''

''On Thursday January 27th our Volvo shut off on us two times while driving down the road. On Friday January 28th of (2000) it shutdown 5 more times on us. [Then on January 29''], [t]he truck began dying at irregular intervals and we became very concerned that the problem was escalating. At approximately 10:00 a.m. the truck died again. We [were] driving on a fairly slick road with some snow and ice on the road's surface. The highway was not dangerous for a normal truck. The Volvo died on us and stayed off for what I would guess to be about five seconds. When it turned itself back on it came back at full power. We broke traction and began to jackknife. We first turned toward the left and I was able to correct to some extent. The tractor maintained its loss of traction and continued through the recovery and then began to jackknife to the right. We were sliding sideways at about 50 mph. We were at or just above a 90 degree angle to the trailer as we began to slide off the road surface onto the shoulder where the snow was deeper.''

Fortunately Mr. Doss was able to straighten out his truck and avoid a highway catastrophe, but, ''This experience scared by wife and I more than anything we have ever had happen to us during our professional driving careers. Janet, my wife, refused to get back in the truck after we got home. I'm not willing to risk either of our lives because of a mistake at Volvo ... The (psychological) and physical implications of owning and operating this truck have been expansive. It's really not a truck as much as it is a liability and unpredictable stress generator.''

Mr. Michael E. Wootan (VOL000548-055 1), of Glendive, Montana, reported that his truck died while he was driving through two lanes of construction. Fortunately, he was able to get it to the side of the road. On an another occasion, Mr. Wootan was driving through Sherman Pass near Cheyenne, Wyoming when his truck died again. He had to back the truck down the hill in order to pull off to the side of the highway. The mechanics told Mr. Wooten that the transmission had malfunctioned and had not allowed the engine to start. Any time a truck stalls on the highway, especially in the middle of a construction zone or a mountain pass, a very hazardous situation is created.

The unpredictability of engine behavior is a serious mechanical problem that should also be within the scope of a NHTSA investigation.

XII. PROBLEMS WITH THE VOLVO TRUCK ELECTRICAL SYSTEM

Twenty problems have been reported regarding Volvo's electrical system in the
dashboard and in the truck's cab.

As Mr. & Mrs. Marvin Phillips (VOL000307) described,

''Another problem of this truck are its ''black outs.'' About every 4-6 months the electrical system goes crazy. One time we were cruising along 1-40 in Tennessee and all the gauges just quit, no more dash lights, the side light switch all of a sudden operated the interior lights, but the headlights worked, the speedometer stuck somewhere around 65 mph, no matter of the truck's actual speed. All other gauges (oil pressure, air etc) went dead. It also lost I 000 miles on the odometer that day. The blinker gets sometimes ''stuck'', i.e. it just lights up but doesn't blink. All symptoms disappear if the truck gets shut off a while. The computer at the Volvo dealership cannot find any problem.''

Mr. Kevin Hollaway (VOL000113), of Chillicothe, Illinois reported problems with the power outlets inside the cab. While one of Mr. Hollaway's drivers was operating the truck, one of the outlets started to smoke, ''and self destructed before my driver could stop and unplug the refrigerator. This plug to the best of my knowledge was not on a circuit by itself and could have caused a potential problem for all involved.''

Mr. Mike Norton (VOL00243-0244), of Phoenix, Arizona, reported ''...that these trucks had an even WORSE problem. They shorted out, caught fire and burned. We had 4 of them catch fire while idling at fuel islands or, in one instance, at the scale in St. George, Utah. '' Even after repair and rewiring of the trucks at Volvo shops, ''the trucks continued to short out, eat alternators, blow sensors, and catch fire.'' Defects that cause fires at fuel pumps are certainly a major public safety hazard that requires study and attention by NHTSA investigators.

Mr. Gerald Pizzini (VOL000258-0259), of Sequin, Texas, reports the common litany of problems associated with Volvo trucks, including a variety of problems with malfunctioning gauges and electronics in the dashboard. He was told by the service writer ''that it is such a common problem that Volvo had to redesign the connections. But that did not stop them from charging me nearly $600.00 to fix it.''

Mr. & Mrs. Harold Hains (VOL000188) of Cassville, Missouri, reported that during the operation of their vehicle, ''Our dash instrument would just go off. No gages for air, oil or anything else. (We are on our 4th dash cluster ... )'' The Hains continue ''There is a burning smell and popping noise coming from under the dash. Lights have flickered.'' Not being able to read instruments presents a very hazardous condition during the operation of a truck, and to those sharing the road with the truck.

Electrical problems such as these could also be attributed to the vibration and shaking of the truck. Mr. J.R. Johnson (VOL000251) attributed such problems to ''the bounce and vibration [which] has knocked the instrument panel out of wack.''

The dramatic stories told by Volvo owners with electrical problems in their trucks should further support a NHTSA investigation.

XIII. CONCLUSION

Perhaps the best way to summarize the problems which have been experienced with Volvo trucks is found in the words spoken by a mechanic who told Mr. & Mrs. Harold Hains that their Volvo truck ''is a piece of crap. Make them buy it back, and get a new one. '' The Hains explained, however, that ''[n]o one will put [it] ... in writing, since they work for Volvo.... Volvo kept saying There isn't anything wrong with your truck, - So why do they keep trying to fix it, without really fixing it? They also told us to get a lawyer.''

Any malfunction in a truck that compromises the driver's control (acceleration, braking, steering) of a vehicle presents a dangerous situation. Any situation that introduces an obstacle to the free flow of traffic (a truck that has broken down or its parts that have fallen in the middle of the road) presents the potential for accidents, injury and loss of life. The reported degradation and malfunction of so many Volvo truck parts that are integral to the safe operation of a truck demonstrate the potential for serious injury or loss of life unless remedied.

The Federal Motor Carrier Safety Administration (''FMCSA'') oversees numerous safety regulations that prohibit the operation of trucks in an unsafe condition. (See 49 C.F.R. § § 3 92.7, 394.1 et al., and 396.7). Volvo trucks constantly put their owners at risk of violating these regulations. OOIDA encourages NHTSA to borrow from the expertise at FMCSA to gain the truck enforcement perspective of determining the danger of a defective vehicle.

The breakdown of individual truck parts and the malfunctioning of the truck's systems as reported by these Volvo truck owners is evidence of serious problems with Volvo trucks. Several incidents have been reported that could have easily resulted in a crash, injury and loss of life of the truck's driver and other vehicle drivers, passengers, and pedestrians.

It is some combination of luck, the skill of the driver, and the small business truck owner's usual keen awareness of their truck's condition that has prevented these from turning into tragic highway accidents. NHTSA should not rely on luck to prevent future accidents. OOIDA encourages NHTSA to head off potential injuries and deaths by granting this petition, investigating these problems, and demanding Volvo remedy the situation in the most appropriate way.

Attached is a copy of all complaints to OOIDA regarding Volvo trucks. OOIDA stands ready to help NHTSA in any way we can to address these serious problems. Thank you very much for your consideration of this petition.