March 12, 2012
Tell us again why electronic keys are an automotive technology advance? Apparently, they’re so great that our National Highway Traffic Safety Administration has to re-write the Federal Motor Vehicle Safety Standard 114 (in a ham-handed way) to accommodate them. And so super-duper that these new electronic ignition system vehicles are introducing new hazards that are killing and injuring consumers.
The Palm Beach County Sheriff’s office is investigating last week’s carbon monoxide poisoning deaths of Adele Ridless and Mort Victor. The couple is suspected to have succumbed to a build-up of carbon monoxide emanating from their Mercedes with a keyless ignition, parked in an attached garage. The sheriff’s office declined comment pending the outcome of their investigation.
Toyota – whose clever keyless ignition system has been implicated in at least two other carbon monoxide deaths – last month issued a Technical Service Bulletin noting that two “Smart Keys” from different vehicles in close proximity can knock the system for a loop. The February 24 notice covers some 2011 and 2012 Lexus models:
“Some 2011 and 2012 Lexus models may exhibit a condition where the Smart Key system is inoperative when another vehicle’s Smart key is in or near the vehicle. The following functions may also be affected: wireless remote operation, Smart access, and Smart start. The combination meter multi-information display may show the message: “Key not detected” when attempting to start vehicle and when driving.”
What are they talking about? NHTSA and the automakers have told us that the key in an electronic system is an invisible code inside the vehicle’s ignition module. So does that mean if you park next to another Toyota or some other manufacturer with an electronic ignition, your shiny new Lexus won’t start? Wow, that’s going to make parking in public lots a whole lot tougher.
What’s that? They are talking about the fob? Two fobs in the same car? But the fob isn’t the key. We don’t understand. NHTSA said.
Which brings us to the agency’s Notice of Proposed Rulemaking. Last December, NHTSA took a stab at trying to correct the mess that so-called smart key technology has wrought. The proposal does not address the most critical element of the problem – defining the key as an electronic code – because it was trying to fix a past mistake without putting automakers out of compliance and without introducing new requirements that would be costly to implement.
In trying to strike this balance, the NPRM suggests countermeasures that have no basis in human factors research; do not do enough to mitigate the safety problems; and defy the intent of Federal Motor Vehicle Safety Standard 114. The agency has staked its solution on auditory warnings, based on those found in FMVSS 403 Platform Lifts – the mechanized lifts used by disabled motorists and passengers. It deletes the door opening alert exclusion currently in FMVSS No. 114 for a running vehicle (only for vehicles equipped with keyless ignition), and adds requirements for an internal alert to the driver when he tries to shut down the engine without first putting the gear selection control in “park;” an external alert that the driver and bystanders can hear when the vehicle is not in “park” and the driver exits the vehicle; and an external alert that sounds when the driver leaves a keyless ignition vehicle with the engine running.
NHTSA declined to propose an automatic cutoff because it was unable to decide what would be the specific time after which the engine would shut down, and because there are scenarios in which people leave a car running in the Park position for a period of time, such as leaving pets in the car with the heater or air-conditioning running, or the drivers themselves sleeping in vehicles with the climate controls running.
The agency also rejected requiring a countermeasure that would prevent the propulsion system from shutting down unless the gear selection control is in “Park.” It had no good reason to forego this measure. The agency did concede that it would solve the rollaway scenarios.
SRS has been researching this issue since 2009 and we have raised our concerns with the agency, face-to-face and submitted comments to the docket. You can read them here.
Toyota’s TSB and the tragedy in West Boca remind us: Smart Keys aren’t.
More on Smart Key hazards:
A Funny Thing Happened on the Way to My Car…