OOSC, Part II, Item 7. Frames - Corrosion Damage/Cracks

Professional opinion on perforation vs. crack I respectfully disagree with the conclusion that the observed perforation condition should be treated only as a violation not a out of service condition Summary visible perforation of load bearing structural members represents a later and more severe stage of the same structural failure process as a crack and should be considered accordingly in evaluating OOS significance. Ontario Out of Service 151 FRAME MEMBERS 1511 - Any cracked, loose, sagging or broken frame siderail permitting shifting of the body onto moving parts or other condition indicating an imminent collapse of the frame. - Any cracked, loose or broken frame member adversely affecting support of functional components such as steering gear, fifth wheel, engine, transmission, body parts and suspension.

If perforation is a failure annual/semi annual inspections using the inspection standard Canada’s National Safety Code Standard 11, it is reasonable to question why such deterioration would not also rise to OOS significance when it affects critical structural components. Basis for that perforation of a structural member should be OOS, The photos show distinct perforation (loss of base metal) in frame members supporting engine components and body parts. This is not surface rust—it is section loss, thinning, and structural degradation. • Perforation is a higher severity stage of structural failure than a crack. Cracks depending on the area, are a early sign of failure and is structural weakness and deterioration : perforation indicates advanced deterioration, missing metal, and reduced cross sectional strength. • This directly impacts the support of functional components, affecting vehicle control, drivability, and stability, particularly under load or during evasive maneuvers. Some regulations clearly state: • No chassis frame member or structural member … shall be visibly cracked or perforated by corrosion. • The underbody shall not be visibly perforated by rust… This places cracks and perforations at the same level of seriousness in determining structural integrity and vehicle fitness. Ontario Regulation 376/02 – Safety Inspections Under O. Reg. 376/02, perforation of any structural or load bearing member is an automatic fail condition during a safety inspection. Perforation = structural failure in the context of vehicle certification in Ontario. National Safety Code Standard 11 NSC 11, which governs commercial vehicle inspections across Canada, also identifies perforation of structural members as a fail criterion. Canada’s national inspection standard clearly views perforation as a serious structural defect, not a minor issue. Given both Ontario’s inspection standards and national NSC standards treat perforation as a structural failure, it is unclear why the same structural condition would not rise to OOS significance under CVSA when the functional risk is identical. This discrepancy is particularly concerning when perforation compromises: • structural support for engine components, • body mounts, or • any member involved in vehicle stability or load distribution. Practical Safety Considerations • Perforation = section of material loss. Where material thickness is reduced or missing, the load path and stiffness are compromised. • Engine-supporting members and body mounts carry dynamic loads (acceleration, braking, swerving, road impacts). • Reduced section modulus increases the risk of progressive failure, especially under commercial loading conditions. • Given the extent of deterioration visible, it is reasonable to conclude the defect likely predated the April semi annual inspection, raising additional concerns about vehicle condition and inspection validity. On the CVSA OOS Threshold • The photos show perforation in load bearing structural members. • Perforation removes material, reduces structural capacity, and compromises safety more substantially than many localized cracks. • CVSA OOS is intended to address conditions that jeopardize safe operation. • Both Ontario’s inspection regulation and NSC 11 already classify perforation of structural members as a failure, reinforcing that the condition is significant enough to warrant removal from service. If perforation is a failure in the annual/semi annual inspections in Canada using the inspection standard Canada’s National Safety Code Standard 11, it is reasonable to question why such deterioration would not also rise to OOS significance when it affects critical structural components.

.Requested Disposition (Reconsideration) 1. Reconsider OOS Where perforation affects structural members supporting engine components or body mounts, and full frame vehicles based on: • Schedule 7’s prohibition against perforation of structural members. • Ontario Reg. 376/02 treating perforation as a fail. • NSC Standard 11 treating perforation as a failure Perforation = Broken ?