October 23, 2014
This week, the National Highway Traffic Safety Administration issued a Consumer Advisory urging “owners of certain Toyota, Honda, Mazda, BMW, Nissan, Mitsubishi, Subaru, Chrysler, Ford and General Motors vehicles to act immediately on recall notices to replace defective Takata airbags.” The announcement was accompanied by an agency web page with an incomplete list of vehicles under recall, as well as mistakenly naming 14 GM models equipped with Autoliv airbags that were once recalled in 2002. The recalls, investigations and complaints look-up functions on its website were inoperable. Toyota announced that it would disable defective airbags in some affected vehicles until replacement parts were available and Acting Administrator David Friedman told The New York Times concurred, under the logic that a vehicle with no airbag was better than one that might spray the occupants with shrapnel upon deployment.
At this point, 7.8 million vehicles in the U.S. are under recall. The inflator defect has been tied to reportedly 139 injuries and three – possibly four – deaths. Congress has come calling. Three U.S. Senators, Richard Blumenthal of Connecticut; Florida’s Bill Nelson and Massachusetts Senator Ed Markey have sent stern letters to NHTSA decrying the latest regional recalls. Rep. Fred Upton (R-Mich.), chairman of the House Committee on Energy and Commerce is threatening to hold a hearing.
Once again, the agency is in crisis mode, and despite NHTSA’s description of the inflator defect recalls as “going as far back as 18 months ago,” the recall history stretches back eight years, when Honda issued its first recall for Takata “airbag inflators that could produce excessive internal pressure.” And the defect history goes back 14 years to April 2000, when according to Recall Notice 13V136, some air bag propellant wafers manufactured between then and September 11, 2002 at Takata's Moses Lake, Washington plant may have been produced with inadequate compaction force.
Since then, there have been five more rounds of recalls in 2009, 2010, 2011, 2013 and 2014. And in the last two years, the Takata airbag defect has spread to nine other manufacturers. The defect is not an artifact of some long ago manufacturing process – the most recently recalled vehicles were 2013 Chevrolet Cruze vehicles (which GM and Takata claim is unrelated). And, it’s likely that even at these numbers, not all of the affected vehicles have been recalled, nor is it merely the result of exposure to heat and humidity. One of the most recent complaints to NHTSA involved a 2010 Honda Civic from Reisterstown, Maryland. According to the VOQ:
While driving at low speeds, the driver side air bag and ceiling air bag deployed unexpectedly. The contact suffered an injury to the face and the driver seat was fractured in half by a metal fragment. The vehicle was not diagnosed or repaired. The manufacturer stated that the vehicle was not included in NHTSA campaign number…
Ultimately, the problem appears to be rooted in Takata’s continuing quality control problems at its manufacturing facilities. The crisis, however, is rooted in manufacturers’ lax attitudes toward locating consumers when it’s recall time, and NHTSA’s lack of process and recall management. This week, Friedman was apologizing for all of the website malfunctions and misinformation, but he declared that NHTSA “had identified the problem.”
A look back at the earliest Part 573 Defect and Noncompliance reports shows that Honda supplied almost no information about the defect, what little it did supply turned out to be incorrect. The automaker neglected to mention that at least some of those “unusual deployments” resulted in injuries. For its part, NHTSA, until very recently, has displayed little curiosity as Honda and Takata offered shifting explanations for the rolling recalls. Perhaps the apologies should have started earlier.
NHTSA’s division of recall management has been breathing a little fire lately at manufacturers who submit Part 573s that don’t acknowledge that a recall is a recall and a defect is a defect. And, recently The Safety Record was shocked – and pleased – to read an eight-page chronology submitted with a GM Defect and Noncompliance Notice. But, for far too many years, the Division of Recall Management displayed a distinct “whatevs” attitude toward the documentation of defects and a manufacturer’s willingness to actually concede that filing a Defect and Noncompliance Notice meant, on its face, that there was a defect. And the agency is still far from showing competence when it comes to trolling quarterly reports for terrible repair rates and forcing manufacturers to put a little sweat into reaching out to vehicle owners.
“It’s well-known that automakers do a lousy job notifying customers – especially on cars out of warranty often relying on outdated owner information,” says SRS President Sean Kane. “It took an act of Congress to force NHTSA to have a VIN recall lookup tool which was only released months ago and the agency posted the wrong vehicles affected by the Takata recalls in its consumer advisory. Once again consumers are bearing the brunt of these failures.”
The Timeline
The Safety Record has been examining the public record on this defect since April 2013, and the information has been scant, misleading, and doled out sparingly. The bottom line: the production problems go back to 2000; Honda got its first complaint of a rupture that caused an injury in 2004, but did not report that in 2008, when it launched its first recall. If either is to be believed, Honda/Takata have been collecting and studying fractured airbag inflators for seven years. The pair, along with the more recent automakers dragged into the recalls, have supplied no fewer than eight different root cause explanations for the defect:
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Propellant wafers with inadequate compaction force;
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Propellant wafers exposed to elevated moisture during the manufacturing process, which, when coupled with thermal cycling in vehicles over time cause the propellant density to decline;
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The process of processing the propellant into a wafer on a specific Stokes high-compression machines;
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The handling of the propellant during manufacturing;
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Propellant wafers with lower material density;
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Prolonged exposure to heat and humidity over the lifecycle of the vehicle;
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Airbag inflator manufactured with “an incorrect part.”
The reasons for the ever expanding recall population are similarly confused. The information coming from the supplier and automakers has hopscotched from one instance of bad record-keeping to another. Among the explanations:
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Confusion over one manufacturing processes that did not automatically verify all propellant as being within specification;
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An unreliable method of sampling production meant that Takata could not absolutely assure that the inflators in the recall population met all production criteria;
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Some number of potentially affected replacement service part driver's airbag modules had been sold through Honda dealers, but could not be accounted for using the controlled parts system;
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Honda/Takata’ discovery that propellant produced during 2001 -2002 could have been manufactured out of specification without the manufacturing processes correctly identifying and removing it.
It is increasingly difficult to believe that Takata knows exactly which vehicles received a bad inflator manufactured within a specific time period on a specific machine, and that the root cause has been definitively identified.
Here’s a much condensed timeline:
2000 – Some air bag propellant wafers manufactured between this date and September 11, 2002 at Takata's Moses Lake, Washington plant may have been produced with inadequate compaction force.
2001 – Some propellant wafers used in air bag inflators manufactured between October 4 and October 31, 2002 at Takata's Monclova, Mexico plant may have been exposed to uncontrolled moisture.
2004 – In May Honda receives first complaint related to airbag inflator ruptures and shares information with Takata, but doesn’t report it to NHTSA until September 2009 in response to a Recall Query.
2006 – Mexican news reports that Takata’s air bag plant in Monclova Mexico was rocked by violent explosions in containers loaded with propellant, leaving at least a dozen workers injured.
2007 – Honda receives two more complaints and a lawsuit related to airbag inflator ruptures. Honda of America Manufacturing (HAM) initiates an investigation. Later claims to NHTSA that this is the first such report.
2008 – Honda starts to collect parts from suspect propellant lots and analyzes them. The “unusual airbag deployment” complaint total rises to five. In October, Takata Holdings makes a presentation to Honda about inflator issue. In November, Honda completes the investigation and launches Recall 08V259. Honda of America Manufacturing continues its investigation for returned inflators of the recall.
2009 – Honda receives more complaints about ruptured airbags. One is the death of Ashley Nicole Parham of Oklahoma on May 27 in a 2001 Honda Accord. Another death occurs on Dec. 24. Eve-Guddi Ratore allegedly dies in a minor crash in which the airbag deployed and the inflator ruptured in her 2001 Honda Accord. (This death does not appear in any of Honda’s recall submissions to NHTSA) By June, Honda decides that recall 08V-593 should be expanded, but does not explain why. In July, after the ninth complaint, Honda launches Recall 09V259, which expands the range of 2001 Honda Civic and Accord vehicles. In November, NHTSA’s Recall Management Division finally takes notice and sends Honda an information request to determine why vehicles in the 2009 recall weren’t included in 2008. Honda and Takata identified the process of pressing the propellant into a wafer on specific high-compression machines as the cause of the ruptures.
2010 – More Honda investigations and another recall. Recall 10V041 includes other vehicles because Honda is not able to rely on the method of sampling production in use at that time to absolutely assure that the inflators in the recall population meet all production criteria. In April, Kristy Williams is severely injured by ruptured airbag in a 2001 Honda Civic. Six months after opening the Recall Query, NHTSA accepts Takata and Honda’s explanations and closes RQ09-004. NHTSA Recall Management Division finds that there is insufficient evidence to determine if Honda and Takata failed to meet their recall timeliness obligations.
2011 – In March, Honda discovers that it can’t account for all of the bad inflators that got into dealers’ replacement parts inventory, and decides to notify owners of all 833, 255vehicles in which the 2,430 affected driver's airbag modules could have been installed and launches. More complaints, More internal investigations. Toyota receives field report of a rupture from a vehicle from the Japan market and asks Takata to investigate. Honda reports alleged rupture of a passenger airbag inflator occurred in Puerto Rico, and decides to expand the VIN range of suspect driver's airbag inflator modules for Recall 11V260 to include those that could have been assembled with mixed propellant lot production.
2012 – More Honda/Takata investigations; more field reports from Toyota
2013 – NHTSA and Honda meet to discuss the ongoing investigation. Takata informs Toyota that some of the propellant wafers found within the additionally recovered inflators were cracked, possibly due to lower material density. Takata informs Nissan, Mazda and BMW that it was investigating a front passenger air bag inflator quality issue affecting air bags. Separately, Takata tells Honda “of another potential concern related to airbag inflator production that could affect the performance of these airbag modules.” In April, Honda completes the investigation and launches Recall 13V132. The automaker also learns of a 13th incident – without injury. In the spring and summer, Mazda, Toyota, BMW and Nissan issue recalls as well.
2014 – In June, the Office of Defects Investigation opens a Preliminary Evaluation into airbag inflator ruptures affecting 1.09 million Takata components, based on six complaints of improper deployment or rupture that occurred in high heat and humidity climates of Florida and Puerto Rico. BMW, Chrysler, Ford, Mazda, Nissan and Honda agree to conduct field action. In June, GM adds the more than 29,000 2013-2104 Chevrolet Cruze vehicles to the list of airbag inflator recalls for being manufactured with an unidentified “incorrect part.”
What’s Next?
Takata’s responses to NHTSA’s 2009 Recall Query make for some interesting reading in 2014.
Takata told NHTSA back then that it had “not provided any air bag inflators that are the same or substantially similar to the inflators in vehicles covered by Recalls 08V-593 and 09V-259 to any customers other than Honda. The physical characteristics of the inflator housing used in the Honda vehicles subject to these recalls are unique to Honda.”
This does not seem to be the case.
Takata also claimed a “policy of continuous review and continuous improvement of its production methods to improve quality and to increase efficiency.”
This does not seem to have produced the results Takata hoped for.
Takata has used the propellant chemistry in the recalled Honda inflators in more than 100,000,000 air bag inflators sold to most major vehicle manufacturers over the past 10 years.
This suggests that more recalls are in the offing.
Congress has been gathering the torches and pitchforks. An October 21 letter from Florida Senator William Nelson takes NHTSA to task for urging consumers to act “immediately,” without providing “actual information they can use to accomplish that task.” He also pointed out that there are plenty of snowbirds with vehicles registered in cold weather states that spend substantial time in hot and humid climates. Yesterday, Sens. Markey and Blumenthal urged NHTSA to issue immediately a nationwide recall on all affected cars, regardless of where the vehicle is registered. All three called on manufacturers to provide rental cars at no cost to consumers if vehicles cannot be fixed immediately due to lack of replacement parts.
So here we are, again, with the national press fighting for scoops and Congress clamoring for action, all borne on a rising tide of injuries, deaths and recalls. When will someone seriously address NHTSA’s staffing levels, defect surveillance and recall management processes and procedures? NHTSA, a self-proclaimed public health agency could use a seasoned epidemiologist who can lead and instill the types of practices and policies that provide real consumer protection. The GM ignition debacle isn’t even concluded, and the agency is already swamped in another fiasco.
