ODI DETERMINED THAT TWO SUBJECT TRAILERS EXPERIENCED COMPLETE FRAME SEPARATIONS. HEIL HAD INITIATED AN OWNER NOTIFICATION PROGRAM, WHICH PAID FOR THE COMPLETE REPAIR OF ALL SUBJECT TRAILERS.GIVEN THAT THE SUBJECT TRAILERS WERE FUEL TANKERS, ODI WAS CONCERNED ABOUT HEIL'S DECISION TO CONDUCT A FIELD ACTION IN LIEU OF A SAFETY RECALL.AFTER REVIEWING HEIL'S PRIOR RECALL HISTORY AND DISCUSSING THE FAILURES WITH INVOLVED FLEETS, ODI CONTACTED HEIL TO DISCUSS THE MATTER.DURING OUR DISCUSSION, THE SAFETY RISKS ASSOCIATED WITH A 6,000 GALLON GASOLINE TANKER SEPARATING FROM THE TOW BAR MECHANISM WERE DISCUSSED. AS A RESULT, HEIL DECIDED TO CONDUCT A SAFETY RECALL.