It’s Time to Make Seat Heaters Safer

Today, Safety Research & Strategies called on the National Highway Traffic Safety Administration and the industry to correct a longstanding safety problem: seat heaters that injure disabled drivers and passengers. With no government or industry-wide standards, manufacturers have installed a variety of seat heater systems – some that  reach temperatures significantly above human tolerances or have no automatic shut-off mechanism – or both. While most drivers know when to turn a hot seat off, occupants with lower body sensory deficits don’t feel the burn. The medical literature has been documenting serious and permanent burn injuries from car seat heaters to occupants with paralysis or diabetes since 2003. Disabled motorists have been complaining about the problem to NHTSA since, at least, 2002. The industry’s response has been to bury a warning in the owner’s manual. NHTSA’s approach to seat heater defects has been: no flames, no problem.  These are preventable injuries – and it’s time government and industry began preventing them.

The medical community has joined us in this campaign.  We encourage readers to do the same by sending NHTSA, The Alliance of Automobile Manufacturers, and the National Mobility Equipment Dealers Association letters supporting changes in standards and practices.

See below to read our briefing paper and our requests to NHTSA and the industry:

Feb. 22, 2011 Safety Research & Strategies, Seat Heater Injuries

Feb. 22, 2011 Letter to NHTSA Administrator David Strickland

Feb. 22, 2011 Letter to Robert Strassburger, Vice President, Vehicle Safety and Harmonization, Alliance of Automobile Manufacturers

Feb. 22, 2011 Letter to Dave Hubbard Chief Executive Officer, National Mobility Equipment Dealers Association

We Read the Report. Did Ray?

Last week, NHTSA pitched its two technical tomes on Toyota unintended acceleration at a pack of reporters, declared that the automaker’s electronics were fine, and ran away. Our esteemed Secretary of Transportation Ray LaHood then made the media rounds, grousing that the critics hadn’t read the report, which leads us to ask: Did Ray?

We’ve been reading it and re-reading it, and conferring with a wide range of technical experts – some of whom have extensive experience in engine management control design, validation and testing. And we gotta tell you, Ray, we aren’t ready to buy our kid a new Toyota.

Far from exonerating Toyota electronics, the reports by NHTSA and the NASA Engineering and Safety Center (NESC) confirm the paucity of the automaker’s safety diagnostics. The NESC team also identifies how the two signals in the accelerator pedal position sensor can be shorted in the real world – leading to an open throttle (aka, tin whiskers). Hell, NESC found the potential in three pedals – that’s a pretty significant percentage in a very small sample. Tin whiskers are such a serious issue that NASA has devoted considerable resources to studying them. They have wreaked electronic havoc on everything from medical devices to weapons systems and satellites. Yet, the NESC report treated the discovery of tin whiskers in a third of their pedal sample like a dead end, instead of a promising avenue of study. Continue reading

NHTSA Shuts the Door on Toyota Electronics in High Speed SUA – NASA, Not so Much

In his characteristically colorful way, Secretary of Transportation Ray LaHood told reporters today: “We enlisted the best and brightest engineers to study Toyota’s electronics system, and the verdict is in. There is no electronic-based cause for unintended, high-speed acceleration in Toyotas.”

LaHood issued this scientific proclamation based on the National Aeronautics and Space Administration “rigorous” examination of nine Toyotas in which the drivers complained about Sudden Unintended Acceleration.

Well, case closed.

We don’t think the story’s over – not by a long shot. First, we might argue that engaging engineers whose expertise is not automotive engine controls does not constitute “the best and brightest” minds in this particular instance. Second, no scientist worth his or her boots would make such a claim. In fact, NASA didn’t. That agency said:

“Due to system complexity which will be described and the many possible electronic software and hardware systems interactions it is not realistic to prove that the ETCSi cannot cause UAs. Today’s vehicles are sufficiently complex that no reasonable amount of analysis or testing can prove electronics and software have no errors. Therefore, absence of proof that the ETCSi caused a UA does not vindicate the system.”

We will be providing more analysis of the NHTSA-NASA report after we’ve had a chance to digest its findings. Stay tuned.

What We Know About Toyota Electronics

While NHTSA and NASA have been busy in their test labs, we’ve been busy doing some testing of our own. And, although our findings are preliminary, we’re uncovering important clues to the gaps in Toyota’s electronic safety net. We haven’t seen NHTSA’s report, but we’re hearing the sound of hands dusting themselves off and feet walking away. What’s troubling is examinations of the complaint data consistently show statistically significant increases in SUA complaints in Toyota models when equipped with its Electronic Throttle Control system. (See Quality Control Systems Corporation’s What NHTSA’s Data Can Tell Us about Unintended Acceleration and Electronic Throttle Control Systems for more information.) Toyota has replicated these incidents, as reported in field technical reports. (See Toyota Replicated Incidents for more information.)

Detailed evaluations of various Toyota models with ETC have revealed some fascinating design issues that demonstrate weaknesses in Toyota’s electronic architecture.  In short, their designs don’t have enough computing power to integrate ETC into the engine control and incorporate safety features needed to prevent unwanted events.

Because the algorithms that make up the software in Toyota’s engine controllers are overly simplistic they are incapable of providing a robust electronic safety net that is needed in these types of systems.

The simplified software strategies used in Toyotas demonstrate this lack of computing power and software.  It is important to note that none of the physical components need to change to accommodate safety features, they are software driven, yet these key software features are not there.  Following is an overview of some of the areas that we’ve examined related to design features that exemplify this problem.

Throttle learn/ Spring test:

There is a parameter in the Toyota engine controller referred to as the “Throttle Learned Value.”  Throttle learning is done to account for part-to-part variations and adjusts the sensor reading up or down by an offset based on the physical components.  The effect is that the entire pedal-to-throttle curve will shift up or down in response to this value.  This is very evident on pedal-follower type systems such as on the 2005 Camry.  What happens if the reference position is not what it was assumed to be?  In short, the entire relationship of sensor voltage to throttle angle can be skewed causing more engine output than the driver requested.  This condition has been documented to cause short duration UA events.

The spring self test is an important safety check performed by the engine controller when the key is on and before the car starts.  The controller opens the throttle very briefly and monitors the return spring closing.  This basic safety test is designed to check the response of the throttle body return spring to ensure throttle open / close response is functioning appropriately from a mechanical standpoint and gauges the dynamic response of the actuator before the engine is started.  There is no such test in the Toyota models.  This is important because it illuminates the lack of system integration between the electronic controller and the mechanical components they control

Pedal-Follower

Many Toyota vehicles with ETC use a pedal-follower system.  This system has significant limitations and doesn’t address the core concern which is engine torque output.  Nor do the subsystems in a pedal-follower system communicate in a manner that facilitates a more complete control of the engine.

Level Two Engine Diagnostics

Primary diagnostics are designed to catch faults conditions usually of an electrical nature.  Secondary, or Level-2 diagnostics, are rationality tests designed to catch unanticipated anomalies and to the monitor the basic functions of engine control system.  This is used to check the actual engine torque versus driver input, and mitigate if necessary.

Some Toyota ETC systems examined appear to have a complete absence of secondary or Level-2 engine torque diagnostics.  The lack of this safety net presents opportunities for undetected faults to create unwanted events.

Brake Override

Electronic brake override in an ETC system was originally a feature designed to address a physical stuck pedal condition.  If the pedal is stuck but sending a valid signal to the engine controller and the driver is braking, the accelerator pedal voltage signal is overridden (via an algorithm in the software) and the engine is returned to idle.  Toyota has “re-flashed” some late model vehicles with a brake override in recall 90L.  However, the company claims that a similar software re-flash cannot be accomplished on most of their vehicles because of the lack of computing power.

Cruise Control

Inputs on Toyota models appear to have no redundancy.  This is an atypical design compared to other OEMs.  This lack of redundancy creates the potential for failures and misinterpretations of the cruise control status due to potential electrical faults.

Accelerator Pedal Position Sensors (APPS)

Most manufacturers use a triple redundancy on the APPS.  The Toyota APPS design differs in the effectiveness of the second sensor.  While it is a separate sensor, it doesn’t have a different characteristic in the voltage slope which can result in “blindness” to certain external voltage influences.  There are also concerns associated with the calibration of the sensor agreement diagnostic logic.

(See Toyota Electronic Throttle Control Investigation: Preliminary Report )

Idle control:

Toyota allows a wide-range of idle deviation without setting Diagnostic Trouble Codes (DTCs).  Idle speed variations in excess of 2,000 RPMs have been documented in real-world conditions without driver input.  This level of idle generates a substantial amount of engine torque and can result in UA events.

If we take a moment to consider the big picture, we see regulators that have failed to regulate and the investigators have failed to investigate. They’ve set themselves back – and in the process – all of the motoring public.

Stupid Tricks with Smart Keys

Someone should have seen this one coming.

In November, a New York woman filed a lawsuit against Toyota, claiming that its keyless entry system resulted in the death of one man and her own debilitating injuries. How did it happen? Carbon monoxide poisoning from her Lexus, inadvertently left running in the garage under her home. Mary Rivera, of Queens, New York alleged that her so-called Smart Key, an electronic fob system, allowed her to exit the vehicle without it being turned off. The engine was so quiet Rivera didn’t notice that the motor was still running.

Just another one of those crazy lawsuits where some consumer does something really dumb and tries to blame the hapless manufacturer, right? More fodder for all those conservative blatherskites who love to dump on trial lawyers, right?

Actually, no. This preventable tragedy is the inevitable consequence of bad design and a NHTSA’s interpretation of the rules. Continue reading

Roll Me Over – One More Time

The Society of Automotive Engineers resumed its ongoing boxing match over injury causation in rollovers at last week’s SAE Government Industry meeting. In Malibu’s corner was Wayne State and University of Michigan’s Transportation Safety Institute, presenting research supporting the theory of occupant diving as the mechanism of head and neck injury in rollovers – regardless of roof crush.

(For those of you who haven’t followed this 25-year-old scrum, Malibu refers to two sets of experimental rollover tests General Motors conducted in 1983 and 1987 on Chevrolet Malibus. Known as Malibu I and II, the tests were conducted to validate the theory that occupants don’t suffer head and neck injuries because the roof collapses on them, but because the force of the crash propels them into the roof. Over the years, automakers have clung to the Malibu results, despite crash data showing that the number of deaths and injuries in rollover accidents has risen disproportionately, with more than quarter of the accidents involving a serious roof intrusion.)

On the other side was NHTSA, arguing that roof strength is related to injury. It’s refreshing – if ironic – to see NHTSA champion a relationship between intrusion and injury. The agency is a late convert to this view; after years as an adherent of the Holy Gospel of Malibu.

Meanwhile, over at the Transportation Research Board’s Annual Meeting – also last week – research from less likely suspects supported the need for stronger roofs. Continue reading

Toyota Sudden Unintended Acceleration: We’ve Got the Numbers!

Safety Research & Strategies has completed our latest review of Toyota unintended acceleration complaint data, and they confirm that Toyota owners are still reporting SUA incidents – even those who had taken their vehicles in for the recall repairs.

Our database consists of incidents from the following sources:

– Consumer complaints to NHTSA through January 5, 2011

– Toyota-submitted claims from several NHTSA investigations into unintended acceleration

– Incidents reported by media organizations

– Consumer contacts made to our organization and others that are reporting incidents that they have received.

Every effort has been made to identify duplicate records and combine them.  However, often the reports do not provide enough detail to link incidents to other reports.  There are likely some duplicates among our records – if there are, they are few. Continue reading

Bigger Bags, Better Glass

Forty years after automakers fought off regulations that would have actually tested rollover occupant protection, the National Highway Traffic Safety Administration has published a final ejection mitigation rule, which favors the installation of bigger and more longer-deploying  side airbags and takes a half-step forward on improving side glazing.

The rule establishes a new Federal Motor Vehicle Safety Standard 226 Ejection Mitigation. FMVSS 226 applies to the side windows next to the first three rows of seats in motor vehicles with a gross vehicle weight rating of 10,000 pounds or less. The performance-based standard would institute a compliance test in which an impactor would be propelled from inside a test vehicle toward the windows. The ejection mitigation system would have to prevent the impactor – based on the mass imposed by a 50th percentile male’s upper torso on the window opening – from moving more than a specified distance beyond the plane of the window.  Each side window would be impacted at up to four locations around its perimeter at two time intervals following deployment, to ensure that the airbags remain deployed for the beginning and end stages of a rollover. Continue reading

So What About the Defects?

In 2010, NHTSA levied nearly $50 million in fines against Toyota for flouting the recall regulations in three separate instances. The total represents the largest single fines in the agency’s history – and, (although we haven’t checked) quite possibly more than the agency has ever collected from any and all automakers in 40 years of existence.

This tough stance on recall timeliness is welcome – but does not resolve the larger issues raised by Toyota unintended acceleration – namely how defects are defined in the era of automotive electronics and how such defects are investigated when they are rare, multi-root-cause, and potentially deadly?

The dribble of documents released by the Multi-District Litigation and Congress so far show that UA has been duplicated by Toyota technicians and, contrary to attempts by Toyota advocates and agency investigators to pass off all incidents as driver error, sticky pedals, big shoes and floor mats, there are instances when reliable technical personnel take the vehicle for a test spin and experience UA with no pedal involvement. In fact, we have discovered that Toyota techs were able to duplicate UA in one of very public and widely debated case – but lied to the consumer about it. (We’ll feature that story in a future post.) Continue reading

Double Ding for Toyota

Toyota closes out 2010 by shelling out another $32.4 million to the government for tardiness. The two fines – for failing to recall its floor mats and defective relay rods within five days of determining a defect – were disclosed yesterday.

Three record fines in one year ain’t beanbag. In all three cases – the relay rods, the accelerator pedal and the floor mats – Toyota had recalled the affected vehicles overseas months before it got around to recalling those components here. It’s refreshing to see the agency enforce the law. But penalizing a manufacturer for failing to file a timely defect report only requires counting to five. The agency will greet 2011 with the much more complicated issue of unintended acceleration hanging in the balance. We’ll address that in a future post.

In the meantime, back to the fines. The details were MIA. NHTSA did not say when it thought Toyota had a duty to recall those components. Toyota didn’t admit it did anything wrong. Since the agency hasn’t made its case for the penalty to the public, the Safety Record Blog will do it for them. Continue reading