Honda Finds Convenient Scapegoat in Takata

As the Takata airbag inflator recalls top 40 million vehicles with global estimates of the eventual final tally upwards of 60 million, the OEMs have been happy to cast Takata as a rogue supplier, willing to deceive its customers – particularly Honda – by falsifying test data, and its design and parts validation processes. And lucky them – documents and testimony corroborate this meme.

If Takata were able to build inflator assemblies with a flawed propellant while battling well-known manufacturing process variability for more than a decade without its customers knowing, this would be a fraud of monumental proportions, indeed. But, in Honda’s case, it is highly unlikely. In fact, entire old-growth forests have been decimated in service to books and articles detailing Honda’s unique and super-close relationships with its suppliers. And you don’t have to look very far into the public record to conclude that the myriad management studies are based on myths or they show that Honda knew – or should have known – that Takata’s chronic inflator manufacturing problems were going to blow up in their faces.    

Take the 2015 Japan News article about Driving Honda, a book offering an inside examination of Honda’s history, business philosophy and practices by Jeffrey Rothfeder, who noted that Honda’s handling of the Takata airbag inflator defect went against decades of company quality control practices:

"The automaker has traditionally turned its suppliers into ‘carbon copies of Honda, with the same ideals, methods and objectives,’ Rothfeder says. So much so that it sends its employees to the supplier when there is a problem so that Honda can help rectify it as soon as possible."

Honda’s well-established corporate philosophy and practice, dating back to the company’s inception and celebrated in laudatory books and case management studies, belie its claims of being duped. Had Honda followed its own policies and practices, it would have detected Takata’s systemic problems long ago and taken an active role in quality control and prevention. Thus far, there is precious little evidence to suggest that Honda acted swiftly to ensure high quality after the first field explosion in a Unibody inflator in 2002 or even after the second one in 2004, which resulted in a serious injury. Although Honda began to wake up in 2007, after three additional field ruptures, it appears the company generally accepted Takata’s ever-evolving root causes.

If Honda was following its own playbook, Takata would have been subjected to Honda’s vigorous investigation, testing, root cause analysis, and process evaluations, until enough data had been generated and analyzed to ensure the problem had been correctly detected and eliminated. Because the failure effect was potentially life threatening, Honda should have required Takata to undergo new rigorous testing and thorough analyses after each recall and installed its Supplier Quality Assurance engineers at the Takata sites. Honda’s stringent quality control management system should have required the automaker to cease using Takata as a supplier when it could not stop the repeated explosions.

None of that apparently happened. Instead, Honda issued “rolling recalls” for 14 years (adding additional years and models), and allowed Takata to identify a different root cause each time. And when the shrapnel hit the fan, Honda was asked to explain to NHTSA and Congress why the airbag inflators in its vehicles were exploding, Honda shrugged and pointed to Takata.  

Best Damned Supplier System in Automotive Manufacturing

With 80 percent of any Honda vehicle produced by suppliers, Honda long ago realized that suppliers’ quality practices were tied to its own success. The automaker is involved with suppliers at a granular level on every aspect of the transaction: costs, design, problem-solving, manufacturing, and quality management. Its intimate marriage with suppliers has long been held up as a shining example to other manufacturers. One engineer who has worked with supplier companies interviewed by SRS put it this way: “when you work with Honda they know what’s in your shorts before you know what’s in your shorts.” 

In a 2013 Industry Week article, Dave Nelson, former senior vice president of purchasing and corporate affairs at American Honda Motor Co. and co-author of Powered by Honda: Developing Excellence in the Global Enterprise, noted that Honda’s corporate culture empowers all employees and “the inclusive relationships with their strategic suppliers, in which these suppliers are literally considered extensions of Honda.” At the core of this relationship are two competing values: “BP” which stands for Best Practice, Best Process, and Best Performance, and competitive pricing.

Honda also developed the concept of sangen shugi, which means that decisions are based on “going to the three realities: 

“Gen-ba. The real spot: go to the factory floor, the showroom, the backyard, the parking lot, the driver's seat, the back row, the truck cab and bed – wherever you must – to get firsthand knowledge.

Gen-butsu. The real part: use the firsthand knowledge to focus on the actual situation and begin to formulate a decision or recommendation.

Gen-jitsu. The real facts: support your decisions with actual data and information that you have collected at the real spot.”


According to Driving Honda, Honda considers gen-ba to be the most critical:

“It is relied upon daily at Honda to assess everything from a small glitch on the assembly line to the features in a new vehicle or upgraded model to the company’s globalization strategy. No decision is made at Honda without firsthand information, and no Honda manager or employee would dare try to offer a point of view, make a recommendation, or challenge an existing process or system unless he or she had “gone to the gen-ba,” a term that is heard at Honda factories and offices everywhere in the world, no matter what language is spoken locally.”

Like every aspect of Honda’s corporate identity, BP is discussed by employees with a fervor that is almost religious. For example, in a 1997 article about Honda’s application of lean manufacturing techniques, Honda Engineer Rick Mayo characterized BP as “a mission not a job”:

“We’ve learned that we’ve got to get BP in their company so it’s not seen as a radical change. We used to meet with the top guy and say ‘do this project.’ Now we realize that the supplier needs to have their own way of doing BP. So we ask ‘what will fit best with your overall plans?’ They don’t even need to call it BP. The improvement activities need to be part of their culture, their vision. BP is one club in the golf bag – it’s probably the driver, and we hit it hard-but it’s not meant to be everything to everyone.”

In practice, Honda’s corporate ideology translates into layers of quality control divisions and processes.  Honda’s production departments establish manufacturing control items and standards for each part, process, and work task based on designers’ intentions. The automaker uses a monthly report card to monitor its core suppliers, according to a 2004 Harvard Business Review article, with sections grading the supplier on quality, delivery, quantity, performance and incidents.

Honda is also certified under ISO 9001.2008, which defines the quality management system requirements for automotive suppliers — in theory delivering continuous improvement and preventing defects — and ISO/TS 16949, a companion standard. In 2005, Honda established the Global Honda Quality Standard, Honda’s book of knowledge based on its experiences producing quality products and preventing previous issues from recurring.

A Legend in Its Own Mind

So where were these Best Practices, international quality standards, and realities when Honda decided to install Takata-made airbag inflators featuring Phase-Stabilized Ammonium Nitrate (PSAN)? Engineers – including those at Takata – had recognized PSAN was an unacceptable gas generant for airbags at least two decades ago. According to a 1996 Takata patent application “the burning characteristics would be altered in such that the inflator would not operate property or might even blow up because of the excess pressure generated.” Takata engineers also noted that PSAN is volatile when exposed to moisture:

“It is also required that airbag inflators be subjected to environmental conditioning, such as high temperature heat aging, thermal aging, thermal cycling, thermal shock, humidity cycling, and so forth. These extreme tests can cause many problems, ranging from failure to inflate the airbag to over-pressurization of the inflator leading to rupture.”

All automotive manufacturers and suppliers use Design Failure Modes and Effects Analysis (DFMEA), to identify the potential failures of a particular component, with the aim of including fail safes that mitigate them. DFMEAs rank the severity of each failure mode — with10 being the most severe — the rate of occurrence, and the ease with which the plant can detect the failure. Any design with severity levels of 10 must be redesigned or addressed through a fail safe to prevent keep the failure mode from causing serious harm.

Given the long-recognized danger that PSAN destabilized by moisture can lead to rupture, any decent DFMEA would have included rupture caused by moisture exposure, humidity, and low density propellant. And given that rupture of a metal canister can obviously lead to injury and death, the severity ranking should have been a 10 for each of those. Honda has claimed Takata lied about the propensity for rupture, but the DFMEA should have predicted the dangers – and if it didn’t, it was on Honda to ask Takata to explain why.

More telling, suppliers bundle these DFMEAs and many other analyses into packets called Production Parts Approval Process (PPAPs), which OEMs use to choose their suppliers. The system was designed to ensure that the OEMs are ultimately responsible for the end product. OEMs require different levels of proof that a product is safe, depending on how much they trust the supplier. For example, Level 1 suppliers might only have to submit basic data on the product, while Level 5 suppliers will have to submit all supporting data and submit to an engineering review in-house. According to a PPAP manual from the Automotive Industry Action Group, “if there are signs of instability, corrective action should be taken. If stability cannot be achieved, contact the customer and determine appropriate action.”

The first energetic disassembly in a Honda vehicle in the field was in November 2001 when the Unibody inflator in a MY 2000 Accord ruptured at a dealership after a crash, resulting in a recall in 2002. Based on interviews with engineering experts, industry custom and standard practices demanded that Honda designate Takata a Level 5 under the PPAP system, requiring that Takata perform a new PPAP with Honda present at the facility.

Perhaps that occurred. Then again, three years later, when another rupture in a different type of inflator caused injuries, Honda decided that, this, too, was an “anomaly.” Honda did not part with Takata until November 2015 – 14 years after mounting evidence demonstrated what the DFMEA should have predicted from the outset.

Breakdown of a Marriage

During the years of second, third, fourth, fifth, to infinity and beyond chances, Honda repeatedly violated its own rigorous standards. Rather than take the blame and admit that it failed in its promise to “go to the gen-ba” to correct even minor glitches on a line, to meet its vaunted “goal of zero defects,” to keep its customers from getting killed by its inattention, Honda has consistently blamed Takata. Its communications to NHTSA from 2009 show the pattern of supplier abuse that continues to this day.

In 2009, when NHTSA opened a Recall Query to find out why Honda’s first 2008, teeny-tiny, 3,000-vehicle airbag inflator recall suddenly mushroomed by more than 100 times to 440,000 vehicles seven months later, Honda pointed the finger at Takata. From the Closing Resume:

“Honda indicated that it had relied on its supplier of the air bag inflators, Takata, Inc. (Takata), in studying the possible sources of the inflator ruptures and identifying the recall populations.  Accordingly, RMD issued a request for information to Takata on November 20, 2009, and Takata provided a partial response on December 23, 2009.  Takata then provided its complete response on February 19, 2010.”

In 2011, when Honda expanded its airbag inflator recalls by another 272,779 vehicles, the automaker told NHTSA that it had discovered an inflator explosion for a vehicle “outside of the VIN range of previous recalls, and the inflator module installed in the vehicle was outside of the suspect range previously identified by the supplier. Additional recent analysis of the supplier's manufacturing records for the period in which this recently ruptured inflator was manufactured revealed a small degree of uncertainty regarding which driver's airbag inflator modules may have been produced utilizing propellant from the suspect processing equipment.” Again, Takata.

In in its 2013 recall of passenger bag inflators in 561,422 Civic, CR-V and Odyssey vehicles, Honda blamed the slow drip of information coming from Takata. From Honda’s Part 573 Notice of Defect and Noncompliance: “Separately, Honda was informed by the supplier of another potential concern related to airbag inflator production that could affect the performance of these airbag modules.”

In 2014, when NHTSA opened a Preliminary Evaluation into the airbag inflator ruptures, Honda’s I-know-nothing-I-see-nothing stance got more explicit:

“In addition to Honda's field action decision-making being informed by Takata’s above-described testing, analyses and expertise, each of Honda's prior recalls of its vehicles with Takata driver and front passenger airbag inflators was based on Takata’s identification of production process failures during its manufacture of inflators. To date, Takata has not identified any design defect either in the propellant or the inflator designs. As a result, many of the countermeasures for the identified manufacturing failures were manufacturing process and control improvements. The ongoing quality control processes, including Takata’s line acceptance testing of airbag inflator propellant and other components, is used to validate manufacturing process changes, which were applied to the production of replacement parts. Honda is aware that Takata conducts quality control testing on its inflators; however, the details of the methodology, timing, and results of those tests are generated and maintained by Takata. Honda and Takata have been working closely together for the last seven years to investigate these issues.”

At the December 2014 Congressional hearing on the exploding inflator crisis, Congressman Bill Johnson (R – Ohio) asked Honda at the hearing, “What analysis did Honda undergo, if any, and have you done any independent analysis to date to determine if a recall of the airbags are necessary — or the inflators, rather?” Rick Schostek, HAM’s Executive Vice President, replied:

“I think we need to separate the recall decision versus testing.  So the recall decision that we make is based on information that we receive, for example, from Takata with regard to manufacturing defects, they told us what those manufacturing defects were.  We did not simply blindly accept their analysis, but our engineers looked at it and was it reasonable, and therefore, based on that, we have effected recalls over time.”  

There are none so blind as though who will not see, eh, Honda?

[Safety Research & Strategies has been reporting on Honda and Takata airbag ruptures since Apr. 17th, 2013., starting with The Continuing Case of Takatas Exploding Airbags]

Honda May Set the Record for the Longest Running Rolling Recall

Seven years after Honda issued the first Takata airbag recall, it continues to add more vehicles to the tally. Its never-ending rolling recall – a scheme automakers use to quietly keep adding more makes and models as deaths and injuries keep occurring – has gone from 3,940 model year 2001 Accords and Civics to up to at least 8 million vehicles, spanning a giant chunk of its fleet. And that number is soft because it is impossible to break down Honda’s web of overlapping recalls, varying explanations, and numerous recall extensions to determine an actual number.

Despite Honda’s public statement that it is “committed to addressing the needs and concerns of our customers and making clear that we stand behind the safety and quality of our products,” the beleaguered automaker continues the secrecy that led to the massive Takata airbag recall.

Honda just announced that it is recalling another 104,871 driver’s side airbags with Takata inflators. This latest recall (15V153) is an extension of the earlier nationwide recall (14V351) of 5.4 million vehicles. Honda’s March 16 Part 573 recall and noncompliance report explains how it discovered earlier this month:

“Through a process of matching Takata airbag inflator part numbers to individual VINs based on factory production records, as a method of data confirmation, Honda discovered that a total of 88,549 units of the 2008 Honda Pilot should have been included in 14V351. Additionally, Honda identified certain 2001 Accord (5,454 vehicles) and 2004 Civic (10,868 vehicles) that had not been properly identified by VIN as being produced for the US market, and is adding those vehicles to 14V351.”

Honda’s explanation of a small data collection error sounds straightforward: During our effort to conduct a thorough investigation, we learned that a smallish number of specific vehicles were left out of the list. But this isn’t exactly the story of a quick turnaround. After Honda discovered this error, but before it reported it to NHTSA, the automaker launched a “multi-million dollar print, digital and radio advertising campaign” which urged owners “to take immediate action to check for open recalls to replace Takata airbag inflators.” The list of affected models in this blitz never mentions the vehicles in this newest recall.

 In a March 12 press release, John Mendel, Executive Vice President of the Automobile Division of American Honda Motor Co., Inc., proclaimed:

“The goals of this campaign are to save lives and prevent injuries. Honda hopes that this new consumer information campaign will bolster our existing and continuing efforts to reach our customers and maximize the vehicle repair completion rates associated with recalls to replace Takata airbag inflators. These ads are a strong call to action from our company designed to break through the clutter, grab the attention of customers driving affected vehicles, and urge that they get required repairs as soon as possible.”

Left off the press release’s summary of affected models? The 2008 Pilot that Honda already knew it was going to recall. Also missing was any indication that Honda would be adding more VIN numbers to the 2001 Accord and 2004 Civic recalls – which might have “urged” customers who had already checked their VINs and thought they were safe, to check again. There’s no mention of the latest recall on Honda’s website.

Vehicle owners using Honda’s VIN-look-up database, are almost always informed that their vehicles are part of one of the 2014 recalls. But often, a specific vehicle has also been among those recalled in one of the previous campaigns between 2009 and 2013, before the cover-up of the widespread danger blew wide open. And there is overlap in many of those recall populations, confusing the situation even more. So, customers who had never received a notice have no way of knowing that their vehicle has been under recall for years. They can’t know their own vehicle’s recall history unless they check the VINs and build dates included in all 10 Honda recalls.

And The Safety Record has another bone to pick: In touting December’s Recall 14V351 as a nationwide campaign of 5.4 million vehicles, Honda has encouraged the misperception that this represents the sum total of the U.S. recall population. But this month the automaker added more. And by the way, Recall 14V351 replaced driver’s side airbags. Several recalls of passenger side airbags are still in effect, covering about 2.7 million vehicles.

We’ll believe Honda’s claims of transparency when they start giving the public accurate numbers of how many vehicles and when they were actually recalled.

Behind the Honda $70 Million Fine

Honda had its turn on the ducking stool yesterday. The Japanese automaker, which had previously disclosed that a data entry glitch led to a failure to report some 1,729 death and injury claims to the National Highway Traffic Safety Administration’s Early Warning Reporting system, got held underwater until it agreed to pay $70 million in fines.  

NHTSA’s press release blamed Honda “for failing to comply with laws that safeguard the public.” But it’s far more important to examine the longstanding systemic problems behind the headline. In an audit prepared by the defense litigation firm Bowman & Brooke, Honda explained it as an institutional failure to populate or correctly code certain fields on a form that ultimately went to the Product Regulatory Office, which was responsible for submitting EWR data.  Honda learned about the problem from NHTSA’s Office of Defects Investigation (ODI) in late 2011. Yet, the automaker did not correct this administrative error and the regulator did not impose a penalty until three years later — when both were in the teeth of a Category 5 sh-tstorm over exploding Takata-supplied airbags.

Indeed, the EWR system, a key component of the 2000 Transportation Recall Enhancement, Accountability, Enforcement and Documentation (TREAD) Act, was intended to sharpen the agency’s defect detection capabilities and “safeguard the public.” But it hasn’t always worked out that way. NHTSA and the industry regard EWR as little more than a bureaucratic pain-in-the-neck: The first thing the industry did during the EWR rulemaking process was fight to keep the data secret, and the agency’s first order of business was to pare down the amount of information coming to it.

Instead of giving investigators a heads-up on emerging defects, it has functioned as an identifier of failed recalls. Manufacturers report – or not. There’s no robust process for auditing participation. There are no benchmarks for sanctions. In addition to Honda, Congress caught Ferrari failing to report a single claim in a decade. In 2013, Safety Research & Strategies caught a tire maker and two child seat manufacturers that did not report injuries and death claims to EWR; The Safety Record reported that Mercedes is likely severely under-reporting physical damage claims. Honda and Ferrari were fined, because the Hill has taken an interest. But it’s clear that they aren’t the only offenders. 

In official publications, NHTSA touts EWR’s role in identifying defects or supporting defect investigations. But in more intimate settings, NHTSA has taken a less sanguine view. To the National Academies of Science committee on electronic throttle controls, representatives of the ODI said EWR was too vague to be really useful:

“In briefings to the committee, ODI analysts noted that the EWR data lack the detail needed to be the primary source for monitoring the fleet for safety defects and that the main use of these data (especially the field reports) has been to support defect monitoring and investigations by supplementing traditional ODI data,” according to the Safety Promise and Challenge of Automotive Electronics: Insights from Unintended Acceleration.

At a recent legal conference for the defense bar, NHTSA’s Chief Counsel O. Kevin Vincent conceded: “Frankly [EWR]’s not early and it’s sometimes really not a great warning, because you have to dig down into the data.”

What Honda’s Fine Tells Us about NHTSA: No Follow-Up

Once a defect reaches the public crisis stage, and everyone starts ripping at the veils of secrecy that have draped a particular problem heretofore from widespread notice, one key factor in the run-up pops up regularly: NHTSA knew pretty early on and did not respond appropriately. The last five years has seen three whoppers: Toyota Unintended Acceleration, loose GM ignition switches and Takata airbags. In each case, the release of documents from entities outside of the agency shows that NHTSA saw the iceberg coming but, for various reasons, did not adjust its course.

  • Toyota Unintended Acceleration – In December 2003, Steve Chan, a NHTSA ODI staffer, wrote an Issue Evaluation documenting the spike in acceleration complaints in Camrys equipped with a drive-by-wire throttle. The memo noted that Toyota had already issued two technical service bulletins that related to the problem. In doing his peer analysis, Chan showed that the total complaints for Camry and Lexus vehicles far exceeded those for Honda, Nissan and Dodge models, but that the Camry and Lexus complaint rate was comparable to that of the Nissan Maxima. Nonetheless, Chan found that “the complaints do not show a geographic or seasonal trend but do show a strong recent trend of UA incidents.” Chan’s risk assessment concluded: “Although most of the alleged UA incidents had occurred at very low speed (5 to 15 mph), the percentage of incidents that resulted in a crash is high (27/40 or about 68%). Estimation from some of the complainants on engine surging duration ranged from a low of 2 seconds to as high as 20 seconds. These incidents, thought generally at low speeds, are of high risk to pedestrians because they represent situations that could occur in parking lots, at intersections, and at school lots.” NHTSA declined to open an investigation.


  • GM Ignition Switches — In March 2007, a group of GM employees met with NHTSA representatives in Washington, D.C., to discuss occupant restraint systems. During this meeting, a NHTSA representative informed the GM employees of a fatal crash that occurred on July 29, 2005, in which a 2005 Cobalt was involved in a frontal collision, the airbags did not deploy, and data retrieved from the car’s sensing and diagnostic module (SDM) indicated that the car’s power mode status was “accessory.” In May 2007, NHTSA sent GM a Death Investigation information request regarding an October 2006 fatal Wisconsin crash. In September of that year, ODI’s Department of Defect Assessment advised opening a formal investigation into the problem. According to a memo written by DAD head Greg Magno, the pattern was noted in 2005 and was investigated by the Special Crash Investigation (SCI) team (which suggested the connection between the non-deployment and the loose ignition switch Technical Service Bulletin): “Notwithstanding GM’s indications that they see no specific problem pattern, DAD perceives a pattern of non-deployments in these vehicles that does not exist in their peers and that their circumstances are such that, in our engineering judgment, merited a deployment, and that such a deployment would have reduced injury levels or saved lives.” NHTSA declined to open an investigation.


  • Takata Airbags – According to a review of Honda’s EWR failures by Bowman & Brooke, in late 2011 or early 2012, two employees of NHTSA’s ODI informed Jay Joseph, of American Honda Manufacturing’s Product Regulatory Office, that airbag injury and  death claims were missing from the automaker’s EWR reports: “In looking over separate reports provided by Honda pertaining to the Takata airbag recall, they had noticed that there were half a dozen or so injury or death incidents listed on the detailed spreadsheet that was provided to NHTSA by Mr. Joseph in connection with NHTSA’s review of Takata airbag performance that they could not find having been previously reported as EWRs in the TREAD reporting system.” Joseph explained that two of the incidents were not reportable because the vehicles were more than a decade old, and he would get back them about the others. According to the audit, he did not, and NHTSA apparently did not ask again.


In the case of Toyota, NHTSA was hampered by its failure to keep up with the technological changes in automotive safety-critical systems. It didn’t know much about automotive electronics because it had never regulated them and had not laid an institutional foundation of knowledge. If you don’t know how something works, how can you investigate it? Instead, it cowered in its comfort-zone of mechanical defects and driver error, and every ounce of agency energy has been expended in preserving that view to this day.

In the other two defects, ignorance is a little harder to claim. In the case of GM, NHTSA defended its decision by saying that it didn’t understand that the airbags were turned off when the ignition was in the accessory position. But, the connection had already been made by a Wisconsin State Trooper who investigated the October 2006 crash involving a 2005 Cobalt, which  killed the 15-year-old driver, Megan Phillips, and passenger Amy Rademaker – and by NHTSA’s own SCI team, which also investigated that crash.

In the Takata airbag saga, we learn several things from that single sentence in Honda’s audit report. In 2011, NHTSA caught Honda under-reporting death and injury claims and took no action. NHTSA had a detailed spreadsheet of injuries and deaths caused by “unusual” and “energetic” airbag deployments. Yet, the Recall Management Division allowed Honda to make Part 573 Defect and Noncompliance reports without ever mentioning deaths or injuries from this defect – so the public was largely unaware. NHTSA, which had no formal open investigation into Honda’s rolling recalls since 2009, did not open a new formal investigation, despite this knowledge of injuries and deaths.

A Brief History of EWR

In 2000, Congress passed the TREAD Act in the wake of the Ford Explorer/Firestone tire fiasco. The EWR system required manufacturers to submit reams of death, injury, property damage, warranty claims and other information to the government on a quarterly basis. The information was supposed to help government investigators identify defect trends.

EWR data consists of aggregates of broad defect categories, such as “powertrain” and “airbags” but no sub-categories. So it is impossible to determine from EWR data even some of the common defect trends, such as non-deploying airbags, or inadvertently deploying airbags, or ignition switch failures. (If NHTSA investigators want information beyond the general categories code they request the underlying documents for review.)  Any incident involving a vehicle older than 10 years or a tire older than five years does not have to be reported. 

The TREAD Act presumed that most of the EWR data would be public, but after a court battle between the Rubber Manufacturers Association and Public Citizen over the accessibility of tire claims data, NHTSA responded by keeping warranty claims, consumer complaints to the manufacturer, field reports, common green tire information, production data for all except light vehicles, and the last six digits of the vehicle identification number in death and injury claims confidential. Only death, injury and property damage information was included in the public dataset.

In the 2007 Final Rule, NHTSA amended the definition of “fire” to more accurately capture fire related events, eliminated the requirement to produce hard copies of product evaluation reports, and required automakers to update missing vehicle identification number (VIN)/ tire identification number (TIN) or components on incidents of death or injury to a period of no more than one year after NHTSA received the initial report.

In August 2013, the agency added new reporting categories related to emerging technologies.  The Final Rule mandated that automakers specify the vehicle type and the fuel and/or propulsion system type in their quarterly EWR submissions, and added new component categories of electronic stability control, forward collision avoidance, lane departure prevention, backover prevention systems for light vehicles and stability control systems for buses, emergency vehicles, and medium-heavy vehicle  manufacturers.


How Significant are EWR Failures?

Early Warning Reports offer no laser-like precision, but they are not useless. In a 2012 Preliminary Regulatory Evaluation, NHTSA said: “Since 2004, EWR data have played a role in the opening of 150 Preliminary Evaluations (PEs). Among those 150 PEs, 31 PEs have been opened based on EWR data, with the remaining 119 PEs supported—but not initiated—by EWR data.”

In an undated document entitled Public Release of EWR Data, the agency said:

As of October 1, 2011, NHTSA has used the EWR data in 225 investigations; 68 were launched because of EWR data alone; 157 were prompted by other information but supported by the EWR data.

The Safety Institute, a non-profit organization founded by SRS president Sean Kane, has also demonstrated the use of EWR data through its Vehicle Safety Watch List.  “The watch list is the culmination of years of hearing that NHTSA simply didn’t have the data to spot problems sooner” said Kane.

And yet, NHTSA, proudly “data-driven,” remains unwilling to make its peace with this unwanted tool. If the agency caught Honda under-reporting EWR data in 2011, it’s fair to assume this wasn’t the first time it found missing claims from a manufacturer. Honda was in no hurry to fix it. There’s no question that it is Honda’s obligation to make these reports, and it deserves to be sanctioned for breaking the law. But, we submit that but for the agency’s laissez-faire attitude toward EWR, Honda might have corrected it much sooner.

NHTSA’s new administrator, Mark Rosekind, has correctly identified some of NHTSA’s most serious gaps – a need for a formal, structured approach to vehicle defect analysis and recalls. He has vowed to seek more resources and authority from Congress.

Where is EWR in this mix? In a recent Automotive News article, Rosekind recounted a conversation with “a senior employee from NHTSA’s Office of Defect Investigations who suggested using less data could be more effective in spotting defects, rather than more.” At best, it’s a curious stance for any investigator to take. But, when you consider the record, perhaps it’s not entirely crazy. Not knowing doesn’t seem to be NHTSA’s problem so much as not doing, caused by a long history and complex combination of a lack of resources, technical knowledge, process, procedures and priorities.