WESCO seeks regulatory counseling involving certain locksets used in recreational campers

Client(s) WESCO International, Inc.

Jones Day was retained by WESCO Distribution ("WESCO") in April 2013 to assist with an issue involving a product sold by its subsidiary, Fastec Industrial Corporation ("Fastec"). The product is a travel trailer lock with a keyed paddle handle and deadbolt primarily sold to manufacturers of Recreational Vehicles ("RVs") for installation in RV doors. As designed, when a person outside the RV locks the door and removes the key, a person inside the RV can unlock the door and exit the vehicle by operating a lever. Fastec determined that some of the locks it sold may not conform to design specifications, resulting in a circumstance in which the deadbolt could become jammed when a person outside the RV locks the door and removes the key.

While this issue does not pose a substantial risk of injury to the public, Fastec decided to conduct a recall to address the issue. On July 11, 2013, on behalf of WESCO, Jones Day drafted and filed a report with the National Highway Traffic Safety Administration ("NHTSA") that explained the issue and proposed a remedy through which consumers would receive replacement locks. A submission was also made to the NHTSA Chief Counsel's office requesting that NHTSA maintain the confidentiality of Fastec business information. Since filing the report, Jones Day has assisted Fastec in drafting notification materials for consumers and corresponding with NHTSA officers about the recall.