October 3, 2023
Late last month, Hyundai/Kia recalled nearly 3.4 million vehicles, warning owners to park their vehicles well away from structures – like a house or garage – because a leak in the ABS module can cause an electrical short and lead to a fire. Hyundai’s campaign involves 13 different MY 2011-2015 models for a total recall population of 1,642,551 vehicles. Kia is recalling more than 1.7 million vehicles encompassing 12 different models, covering model years 2010-2019.
(Korean-based manufacturers Kia Corp. and Hyundai Motor Corp. are part of Hyundai Motor Group. Both companies are involved in the joint design and development of vehicles sold globally under their respective brands. Hyundai Motor Co. owns 33.88 percent of Kia Corp., making it the largest investor in the company.)
This recall is mega-sized, but it is nothing new. These two campaigns represent the 16th and 17th recalls from Hyundai and Kia for the same problem in seven years. They involve a common component by different names: in Hyundai vehicles, it’s called the Anti-Lock Brake System (ABS) module, while in Kia vehicles, it’s called the Hydraulic Electronic Control Unit (HECU). They have been manufactured by two different suppliers: Mobis and Mando. But 14 of the recalls, including all of those launched from 2020 to the present, involve components manufactured by the latter. They all share a common design configuration in that they are Powered All the Time (PAT), meaning even when the vehicle’s engine and ignition system is off, these modules still maintain a flow of electrical current. The recalls warn owners not to park their vehicles in or near a structure, because the engine or ignition doesn’t have to be on for a fire to start.
This is reminiscent of the Ford Cruise Control Deactivation Switch (CCDS) debacle, which eventually resulted in six recalls covering 14.9 million vehicles from 1996 to 2009. Ford, and later NHTSA, studied fires and thermal events involving this switch for eight years before it determined that a number of factors set off the chain of events that resulted in underhood fires: material fatigue, the orientation of the CCDS above the brake master cylinder, and the PAT configuration. The failure of the switch seals allowed for fluid intrusion, which could, eventually, lead to an electrical short and subsequent fire, including when the ignition and engine were off because the switch was always powered. Amid seven separate NHTSA investigations, Ford shifted the blame from defective switches damaged in the manufacturing process, to a systemic problem influenced by the switch’s position and the electrical architecture of the cruise control system, to an age degradation issue. The defect has been blamed for at least 1,500 fires – many in parking lots and garages – causing hundreds of thousands of dollars in property damage, and is alleged to have caused at least three injuries and three deaths.
Similarly, Hyundai and Kia have been “investigating” and recalling defective ABS/HECU modules since November 2016, with the vast majority of campaigns launched in the last three years. These latest recalls for leaking ABS modules brings the total recall population to nearly six million vehicles. Roughly half of the recalls name moisture or brake fluid intrusion into the modules as the likely root cause, while the other half state the root causes were undetermined, even though some suggest there are signs that contaminants are leaking into the HECU. When Hyundai and Kia assigned blame, it pointed to supplier quality, including improperly sealed wire harness covers, or excess flux residue from the soldering process at the supplier, compounded by exposure to heat/humidity and deteriorating seals. But many of the recalls involving Mando modules concede outright that despite a prolonged joint investigation, they were unable to determine the cause of the short circuits.
Hyundai’s most recent Mando ABS module recall pinpoints the problem as defective O-rings:
Certain ABS motor shaft O-ring material formulations may be susceptible to physical changes over time due to varying factors, including vehicle ABS specifications and/or the presence of foreign contaminants in the brake fluid, such as moisture, dirt, and dissolved metals, which could affect sealing strength and result in brake fluid leaking onto the ABS controller PCB.
Kia’s version of the recall said that it really wasn’t certain why it was recalling so many of its vehicles. Its Part 573 submission to NHTSA said: “It is believed that a short circuit may result in excessive current within the HECU [Hydraulic Electronic Control Unit]. Exact cause of the short circuit remains unknown.”
In its mandated Defect Chronology submission to NHTSA, Hyundai asserted that its American and Korean engineers have been investigating this problem for four years, beginning with analyses of some overheated ABS modules it collected in 2019. (Hyundai did not mention the earlier investigation that led to a recall in 2018.) Then, beginning in the summer of 2020, as Hyundai and Kia were initiating several recalls into other models and model years for ABS/HECU-related fires, the lawsuits related to fires in this new subset of vehicles began to roll in. That August, Hyundai’s North American Safety Office opened a formal case investigation beginning with Elantra vehicles, and began to recover all similar ABS modules with thermal damage from American market vehicles. Throughout most of 2021, Hyundai continued investigating. In some cases, they found brake fluid in the switch but could not determine how it got there. In October 2021, Hyundai brought in Exponent and after nearly two more years testing and analysis, identified the cause as the O-ring degradation within the ABS module, which lost strength and deformed over time breaking the seals:
During this period, Exponent focused testing on the motor shaft O-ring material durability. In an update provided on May 9, 2023, Exponent reported that foreign contaminants were present in residual brake fluid found inside certain analyzed ABS modules. In an update provided on July 7, 2023, Exponent found the O-rings used in the subject ABS modules consisted of varying rubber material formulations determined through thermogravimetric (“TGA”) analysis. In an update provided on September 6, 2023, Exponent confirmed that certain material formulations used in the O-ring rubber could lose hardness over time. Additionally, the material could be affected by foreign contaminants in the brake fluid, potentially impacting sealing performance. Based on this information, HMC conducted a review of supplier manufacturing records and confirmed a material formulation change to one with increased hardness implemented by the supplier in September 2014 and February 2015 at the Korea and U.S. plants, respectively.
Based on this revelation about a materials change, Hyundai recalled vehicles from the 2015 model year and earlier.
Kia starts its Defect Chronology in 2023, claiming that in July it learned that Hyundai was investigating overheating ABS modules (HECUs in the Kia vehicles), and noticed that those modules were in many of its models. During the ensuing two and a half months, it launched its own internal investigation and found some similar overheating incidents and some leaky modules but, once again, was unable to pinpoint a root cause. But given Hyundai’s go-big recall, Kia apparently decided to do the same. Its investigation is less likely to blame pre-2015 Mando O-rings, because its recall population also includes vehicles from the 2016 to 2019 model years.
You might be thinking that they would address the enduring problems with its ABS/HECU modules by simply replacing all of the older modules with newly designed modules.
You would be wrong. Despite this obvious hardware solution, Hyundai/Kia have only offered module replacements in four of the early recalls. In three other recalls, the fix was to install a relay in the vehicle’s main junction box to prevent the risk of an ABS short-circuit while the car is turned off. Of course, that wouldn’t prevent a thermal event when the engine was running. However, in most of the recalls, including all of those from the last three years, the only remedy is the installation of lower-amp fuses, so that if there is an electrical short, it will blow the fuse rather keeping the module from overheating and igniting. While that may prevent fires, if the vehicle is in motion when this occurs, it could force the driver to stop operating the vehicle, which could create a new danger.
What all of these recalls really appear to demonstrate is that the only permanent remedy is to replace the ABS modules with a design that functions throughout the vehicle lifecycle without leaks into the electrical unit.
But Hyundai and Kia aren’t doing that.
Working the Refs
In just two months, Hyundai is expected to emerge from the shadow of a three-year Consent Order it signed with NHTSA just before Thanksgiving 2020. Back then, the agency slapped Hyundai/Kia with a combined $210 million civil penalty, the largest in the regulator’s history, for lying (more politely called “inaccuracies” and “omissions”) in its communications with the agency and failing to launch timely recalls involving more than 1.6 million Hyundai and Kia models with the company’s Theta II engines. The engines were supposed to make Hyundai/Kia the leaders of fuel economybut instead suffered from manufacturing and design defects that caused lubrication problems and premature bearing wear that could lead to loss of motive power and fires. (Read about it here: Hyundai-Kia’s Billion Dollar Engine Problem that Broke the NHTSA Civil Penalty Barrier.)
The story is instructive for its similar trajectory of multiple years of rolling recalls and satisfaction campaigns to address a problem the “fixes” didn’t correct. Hyundai alleged that the engine problem began in 2011, when its Montgomery, Alabama, assembly plant changed the way it removed machining debris from the crankshaft of the then-new Theta II Gasoline Direct Injection (GDI) engine. The warranty claims for excessive noise, an illuminated check engine light, and stalls began to rise as soon as the Theta II debuted in the field.
By 2015, the complaints accruing in NHTSA’s VOQ database began to concern the agency, which contacted the automaker, worried about the potential for high-speed stalls. And so in September, Hyundai recalled 470,000 Model Year 2011-2012 Sonata vehicles equipped with 2.4L and 2.0L Theta II GDI engines.
The defect involved the travel of metal debris generated during engine crankshaft manufacturing and left in the component’s oil passages, and travel, over time into the connecting rod oiling passages, restricting oil flow to the bearings,” which could raise engine temperatures and lead to premature wear of the connecting rod bearing, eventual failure, and a vehicle stall and a potential fire. The remedy was an engine noise inspection that required moving the vehicle to a quiet place and positioning a mobile tablet near the steering wheel to assess the engine sound, while an unexplained algorithm determined if the vehicle passed or failed the inspection. The failures got a new engine; the others got a new dip stick and an oil top-off.
During the following two years, Hyundai and Kia, which also had models with the Theta II engine, attempted to avoid a recall with extended warranties, even as Hyundai engineer and 26-year company veteran Kim Gwang-ho blew their cover. A member of Hyundai’s Quality Strategy team, Kim traveled to the U.S. in August 2016 to allege in a meeting with NHTSA that Hyundai’s recall did not cover the entire population of affected vehicles in the U.S. and South Korea, and that the problem was also related to the engine design.
In March 2017, Hyundai and Kia finally announced recalls for a combined nearly 1.2 million vehicles describing the same defect as the 2015 recall. Two months later, NHTSA responded by opening a Recall Query to determine if Hyundai and Kia met its regulatory burden of issuing these recalls within five days upon learning of a defect.
On November 23, 2020 everyone signed the Consent Order agreeing that they hadn’t.
Under its terms, Hyundai and Kia had to spend a significant portion of the fine on internal process improvements. ($40 million and $16 million respectively.) Hyundai was required to “build and develop a fully functioning United States-based outdoor test laboratory and vehicle tear down facilities. The test laboratory will focus on safety field issues, vehicle inspections, and defect investigations.” Finally, Hyundai/Kia was required to hire a third-party auditor to oversee its progress. The penalty capped a five year period in which millions of Hyundai and Kia models were scrutinized under four different investigations, and were the subject of class-action lawsuits, extended warranty programs, a product improvement campaign, and 10 recalls to deal with defects that cause stalls and non-crash fires attributed to a variety of causes.
According to the NHTSA press release on the agreement, both companies were required to “develop and implement sophisticated data analytics programs to better detect safety-related concerns.” The Safety Record wonders what these new data analytics are telling them about leaking ABS modules.
And as Hyundai/Kia enters its seventh year of placing Band-Aids on ABS modules in the apparent hope that NHTSA doesn’t notice that their recall “remedies” may be as crappy as the modules themselves, may we remind you that Hyundai/Kia still has not launched a recall to fix their theft-prone, immobilizer-free models.
According to Hyundai/Kia’s defect chronologies, the defective ABS modules, have not caused any reported deaths or injuries. In contrast, the Hyundai/Kias with insufficient theft protection have touched off a two-year nationwide epidemic of criminality that shows no signs of abating, with steep car theft numbers and a horrific trail of crashes, injuries and deaths. The last two months alone have seen Hyundai/Kia theft news stories with headlines such as: “3 dead, 2 critical after stolen car ‘cut in half’ in crash with pole at MLK, Carey” (Las Vegas); “21-Year-Old Dead, Passenger in Critical Condition After Being Hit By Teens Driving Stolen Kia in Old Brooklyn” (Cleveland); or “12-Year-Old Seriously Injured After Smashing Stolen Kia Into a Utility Pole: Police” (Bridgeport).
This is just a small sample; there have been many more since February when NHTSA announced that, after eight deaths and 14 crashes attributed to stolen unprotected Hyundai and Kia vehicles, the Korean conglomerate would launch a service campaign to apply a software fix and a decal to vehicles without immobilizers. No apparent investigation, no recall.
In June, Cem Hatipoglu, NHTSA’s acting associate director for enforcement, responded to a demand by state Attorneys General that NHTSA exercise its authority to compel meaningful action, by saying that NHTSA wasn’t inclined to take any action other than monitoring the situation. He wrote: “At this time, NHTSA has not determined that this issue constitutes either a safety defect or noncompliance requiring a recall,” noting that the compliance test “does not contemplate actions taken by criminal actors to break open or remove part of the steering column and take out the ignition lock to start a vehicle.”
This is true even though FMVSS 114 was promulgated for this precise reason: to prevent casual thieves from quickly hot-wiring a vehicle for high-speed joy rides that end in tragedy. That’s why Safety Research & Strategies has petitioned NHTSA to strengthen the anti-theft compliance test provision. (You can read about it here: The Amazing Shrinking 114 )