Who Are the Victims of Takata’s Fraud?

For more than a decade, airbag supplier Takata manufactured what turned out to be ticking time bombs – airbag inflators with a volatile propellant called Phased-Stabilized Ammonium Nitrate (PSAN) – that were placed in vehicles worldwide by the hundreds of millions.

Takata was churning them out at several dollars a bag less than airbags manufactured by rivals, such as Autoliv. According to an August 16 New York Times story, in the late 1990s, Autoliv engineers examined Takata airbags manufactured with PSAN, and concluded that the company could not and would not replicate them, because PSAN was too volatile and dangerous for that application. Autoliv reportedly informed General Motors, which had asked the Swedish supplier to match Takata’s price, and warned other OEMs as well. 

In fact, the dangers of PSAN were common knowledge in the industry – enumerated in patents by airbags makers, including Takata – and in the scientific literature. Later, there were the ruptures that made this knowledge manifest to at least some of the Original Equipment Manufacturers (OEMs), in real-world incidents – a BMW in 2003 and a Honda in 2004. The 2006 explosion that rocked Takata’s plant in Monclova, Mexico, was another flare fired into the industry’s consciousness about PSAN’s stability and Takata’s ability to handle it safely. By 2008, when Honda launched its first mini-recall of 4,000 vehicles, OEMs using Takata airbags learned of two more ruptures through Honda’s Notice of Defect and Noncompliance. By 2009, Honda was aware of 11 ruptures and one death. On Christmas Eve of that year, another woman died in an airbag rupture after a fender-bender. In the years to follow, the rolling recalls and changing root cause explanations provided ample warning about Takata’s systemic manufacturing and quality control issues.

What did the OEMs do with this knowledge? Nothing. They continued to buy and install Takata airbags with PSAN propelled inflators. By 2015, Takata had captured 22 percent of the global airbag market and had its biggest year since 2007, with sales topping out at 254 billion yen.

But that is not the story told by Attachment B of the $1 billion plea agreement struck by the Department of Justice and Honda – dumped out on a Friday before a holiday weekend. Takata pled guilty to one count of wire fraud and agreed to pay hefty fines and compensation, submit to the oversight of an independent monitor (who needs no airbag experience) and initiate a corporate compliance program. Other Takata entities escaped charges, including Takata Holdings, the U.S. arm, which performed the testing, investigated the ruptures, and participated in the fraud.

This plea appears to be more obviously designed to preserve Takata’s ability to enter bankruptcy without the costs of the massive recall discouraging would-be buyers of the ailing manufacturer. So far, Takata’s suitors have filed plans requiring that the company rid itself of its liabilities. But the OEMs did not want to bear the brunt of the recall costs.  The lion’s share of the $1 billion penalty – $850 million – goes to those “victims.” 

In the process, the agreement trades the whole truth for a Reader’s Digest version in which the OEMs hadn’t a clue that Takata had quality control problems until 2015 and likely continues to grapple with today. (Take out your hankies.) According to the plea agreement:

“…had the OEMs been provided with the true and accurate test information and data, the OEMs either would have: (a) insisted that any problems with the PSAN inflators be resolved prior to installation into their vehicles; or (b) refused to put the airbag systems containing the faulty or problematic PSAN inflators into their vehicles.”

To this, we can only say: Nonsense!

Fake Data

It is true that Takata falsified test data showing that inflators using PSAN were not meeting targets for effluent gas and ballistics. The plea agreement described the scheme as the work of a cabal composed of Shinichi Tanaka, 59; Hideo Nakajima, 65; and Tsuneo Chikaraishi. For 15 years, the trio and others hid failures and ruptures during production testing, using the code term “XX” in written communications, as a verb for falsifying data. This mostly involved trimming the extreme ends off the test results to make it seem like there was less variability in the data.

But was this really the missing bit of information that would have led the OEMs to insist that the problems be resolved, or to refuse to buy Takata airbags? A 2015 Takata Engineering Integrity Audit performed at Honda’s behest, by an independent team, suggests it wouldn’t have made much of a difference:

Based upon the information provided by Takata and Honda, and despite the numerous examples of data manipulation, the audit team did not identify any potential safety risks from the audited test reports and test data for three of the four inflator designs (PSDI-5, PSDI-X and PSPI-X) as installed in Honda vehicles. For the PSPI-6 inflators, however, recent information from Takata indicates that after the PV program was completed there were a number of instances of closure burn through or closure erosion in tests of production inflators. This suggests that the burn through problems identified in this audit had not been resolved in the production inflators. This audit did not find any test results with peak pressure results in either DV or PV test programs that could have caused explosive ruptures.

The OEMs – Shoulda, Coulda, Woulda 

The three executives, all Japanese citizens, were indicted separately on fraud and conspiracy counts. Bringing criminal charges against auto-manufacturing executives is a relatively new phenomenon. In 2015, some auto-parts higher-ups were indicted on price-fixing charges. Last year, the DOJ indicted six Volkswagen managers in the diesel emissions cheating scandal. Serious consequences for corporate criminality in the auto sector represents some progress. But, as long as there is a financial incentive to ignore or cover up problems, they won’t be the last to be indicted.

And this brings us around to Takata’s co-conspirators – the OEMs. Despite industry knowledge in the late 1990s that Phase-Stabilized Ammonium Nitrate was a risky choice for an airbag inflator – vulnerable to explosions when subjected to temperature changes and moisture exposure –  it sure was cheap. Ultimately, GM, Honda, Toyota, and others chose to use it as a significant cost-saving.

And in order for Takata to succeed in maintaining the fiction that PSAN posed no problems, the automakers had to look the other way as each red flag was hoisted and ignore their own supplier quality control procedures. Honda, is perhaps, the most egregious example – as we pointed out in May (Honda Finds Convenient Scapegoat in Takata)

Honda experienced its first rupture in an inflator using PSAN as a propellant in 2004, but passed it off as an anomaly, and waited a year to tell Takata. Even before that, Honda had a rupture with a Takata Unibody-style inflator, which was determined to be the result of a bad weld, indicating a manufacturing problem. By 2009, Honda was aware of 11 ruptures and at least one death – which it concealed from the National Highway Traffic Safety Administration.

A more recent report Takata was compelled to submit to NHTSA under the terms of a 2015 Consent Order, illustrates how involved Honda was in Takata’s design and manufacturing decisions going back to 2000.

Around that time, Takata and Honda were performing sled tests using modules containing PSDI inflators with propellant wafers in the shape of a shark fin and others in the batwing configuration. When a module with a shark fin wafer failed to satisfy one of the test criteria, Honda insisted that Takata use batwings, even though Takata argued that the problem could be remedied and that the shark fin design would produce more consistency in the wafer density, and therefore less variability in ballistic performance. Honda’s February 2000 decision to go with the batwing design came just four months before production was slated to begin, rushing the normal design and production validation processes and leaving Takata insufficient time to test and set up a new production line at its inflator assembly facility in LaGrange, Georgia.

This caused Takata to perform its initial production validation testing using pre-production batwing wafers pressed on a non-production press. And to meet Honda’s volume needs, Takata had to ship a Stokes 340 press – a machine intended for research and development, not mass production – to its Lake Moses, Washington plants to augment the work of its Gladiator presses. The problems with using the Stokes press were later implicated as a possible root cause for the first Honda recalls.

In 2010, Honda and Takata hired outside scientists from Pennsylvania State University and University of California Berkeley to investigate the inflator ruptures. PSU’s analysis of Takata’s PSAN propellant between 2011 and 2014, concluded that it is susceptible to dynamic burning – when it is exposed to sudden pressure increases, such as that created by low-density wafers, it may burn at a much faster rate and at higher temperatures than expected, leading to over-pressurization. Penn State believed this dynamic burning effect contributed to the ruptures and published a paper to that effect in 2012, warning that “the effect of dynamic burning behavior of the propellant needs to be accounted for when designing or analyzing systems that subject the PSAN propellant to high pressurization rates.” Honda was an active participant in all discussions.

Honda’s close relationship with suppliers is legendary – written up regularly in the business press. And even when business professors are not lauding your super-tight collaborations with suppliers, every automaker has a system in place to communicate with and check on component manufacturers, from design to post-production. OEMs, which are ultimately responsible for the end product, can and do require proof of a product’s safety. For example, Design Failure Modes and Effects Analyses (DFMEA) identify potential failures, rank them by severity, and identify fail safes to mitigate them. DFMEAs and other analyses are the bases of Production Parts Approval Process (PPAPs), packets which OEMs use to choose their suppliers. These documents would have predicted that ruptures could happen as a result of over-pressurization and given them a severity 10 – which engineers consider a red flag that the design needs to change. Significantly, according to the plea agreement, Takata had minimal internal controls and compliance systems until 2006. How did that escape the OEMs’ notice when they audited Takata before selecting it as a supplier?

Contrary to the DOJ’s fairytale predictions about what the OEMs would have done with information about bad tests, automakers’ design analyses and audits should have identified and disqualified the use of PSAN in airbag inflators before they went into any vehicle. Later, the public record of ruptures, recalls, and revolving root causes gave them enough reason to galvanize their supplier quality control processes into action. By their own policies, the OEMs should have ceased using Takata as a supplier no later than 2009, when it was clear Takata could not control its systemic issues, with deadly consequences. But none of that actually did happen – because ammonium nitrate is cheap.

The OEMs simply gambled, and their customers lost. 

How to Read the Plea Agreement

The Safety Record gets the fact that legally, the wire fraud charge necessitates that the “victim” in the transaction be the entity that paid Takata for its services, i.e, the OEMs. But, we wouldn’t want our readers to confuse the legal victims with the real victims.

Takata airbag ruptures are responsible for 16 deaths worldwide and more than 180 injuries in the U.S. The most recent U.S. death occurred in September. A 50-year-old California woman on her way to get a flu shot died of inflator shrapnel injuries after a front-end collision. The plea agreement sets aside only $125 million to compensate those who have not already resolved their claims against Takata. The payouts will be administered by attorney Kenneth Feinberg, who denied 91 percent of the claims while performing the same service for GM during the ignition switch crisis. This is a pittance, considering that the some of the injuries include serious neck and chest wounds, and facial lacerations necessitating long and costly recoveries.

This restitution fund lives for only five years – the current estimate for completing the recall. After that, any leftover monies go to the government. What happens to people injured after recalls? People are still being injured on a regular basis. And some of the airbag replacements use the same inflators, under the theory that the inflators don’t become dangerous until age six, giving the OEMs the leeway to worry about those inflators later. Even if the deterioration rate of PSAN bought the manufacturers six more years, Takata’s continuing manufacturing problems wipe that margin out. Takata airbag inflators have been subject to four recalls since 2014 for manufacturing defects that could lead to ruptures.

  • June 2014: GM recalled model year 2013 and 2014 Chevrolet Cruze vehicles after an investigation of a rupture in a 2013 Cruze showed that some SDI-X inflators were made using outer baffle components intended for the PSDI-X inflator.  Nissan also issued a U.S. recall, and Nissan and Honda issued foreign recalls.

  • July 2014: Mercedes-Benz recalled 311 model year 2014 SLK and SL class vehicles because inadequate fasteners could come apart, allowing the diffusor to detach and enter the passenger compartment.

  • September 2015: GM recalled 395 model year 2015 vehicles after the body bore seal separated from a side airbag inflator (SSI-20 inflator) during lot acceptance testing. The root cause remains unknown.

  • October 2015: Honda recalled 515 model year 2016 CR-V vehicles after a PSDI-X inflator failed during lot acceptance testing. Takata concluded there was either a stamping issue or a weak metal canister.

  • January 2016: Volkswagen recalled 734 model year 2015 vehicles after an SSI-20 side airbag ruptures in a 2015 Tiguan. Takata subsequently combined the GM and Volkswagen vehicles into one equipment recall for SSI-20 airbags in 1,129 vehicles, noting that it had not yet determined a root cause.

And what about the millions forced to drive vehicles with potentially deadly airbags while waiting years for a replacement? Will the recall really be done in five years? GM, for example, reacted to all these revelations about Takata’s fraud, the dangers of PSAN and Takata’s ongoing manufacturing issues by asking NHTSA for a one-year extension to comply with the agency order that recalls of certain model years must be completed by December 31, 2016. GM had flouted the Consent Order for months. At the time it requested the extension, its repair rate for Takata-related recalls was a dismal .17% (only 552 vehicles).

After initially informing customers that GM “strongly recommends that you have this safety recall repair performed immediately” and urging occupants not to sit in the passenger seat, GM’s later customer communications deemed its campaign a “preliminary recall,” and refused to actually repair the vehicles:

“GM continues to believe that there is no immediate danger of inflator rupture in the recalled GM vehicles and that these vehicles are presently safe to drive. You will be notified when there is a need to take action.”

The plea agreement’s section entitled “The Victims” only contains two points devoted to the OEMs who purchased the defective bags based on false data. But what made Takata’s deception truly criminal were the deaths and injuries that resulted long after the doctored validation test results were shoved in a file. And the DOJ spared not a word for those individuals who never had any hand in the decision to roll the dice on PSAN, or saw a ballistic test, but suffered the most severe consequence.

Since 2009, there have been 11 deaths in the U.S. caused by inflator ruptures – people who had their necks sliced open – some in crashes so minor, they should have walked away. Save one 13-year-old, we know their names, and since the government didn’t mention them in the official record, The Safety Record will:

Ashley Parham

Gurjit Rathore

Hai Ming Xu

Jewel Brangman

Hien Thi Tran

Carols Solis

Kylan Langlinais

Joel Knight

Huma Hanif

Delia Robles

 

GM Stiffs Takata Recall, Petitions for Delay

Safety Research & Strategies response to this request: Deny! It’s rare for an automaker to request such a change – it’s even rarer for the agency to ask for comments. But, our focus on this issue tells us that the petition is a stunning display of chutzpah, considering that the automaker is already flouting the Consent Order it signed. GM has been selling unremedied recalled vehicles while telling its customers it isn’t replacing the airbags because there’s no problem. Everything we’ve learned about the history of this defect assures us – there ain’t no such guarantees.

Read the SRS comments below.

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]

Takata Recall Tests the New and Improved NHTSA

Tomorrow October 22, the National Highway Traffic Safety Administration is scheduled to hold a public hearing ostensibly to explore coordinating a national recall of defective Takata airbag inflators. 

This auto safety crisis had been brewing internally at Takata since at least November 2001, when Honda received its first field report (noted as part of a recall for 2,900 Accord and Acura TL vehicles with passenger-side airbag inflators that had been improperly welded.) But the repeated Honda recalls for driver’s side airbag inflators that could explode with little to no provocation, spewing shrapnel at the vehicle occupants, did not really penetrate the public consciousness until 2013. By then, there were three known deaths and a spate of serious injuries associated with the defect, and the recalls widened to include other automakers and passenger-side inflators. Congress began to summon Takata and National Highway Traffic Safety Administration officials to the Hill for explanations.  

Today, 12 automakers have or are in the process of replacing defective Takata inflators in 19 million U.S. vehicles. Takata had resisted launching national recalls – insisting that it was only necessary to recall vehicles in states with hot and humid climates, even as explosions occurred in locations outside of the initial list. But, under the persuasive influence of a May Consent Order, Takata conceded that a safety defect existed and agreed to conduct national recalls.

This month’s hearing has been billed in the Federal Register as a notice of NHTSA’s resolve to publicize its intention of issuing administrative orders to coordinate the recall under its authority in several provisions of The Safety Act to ‘‘accelerate’’ remedy programs; to inspect and investigate; to ensure that defective vehicles and equipment are recalled and remedied; and to ensure that the remedy for the defect is adequate. The agency envisions its leadership in the recall effort as speeding up delivery of the repairs by prioritizing and organizing the air bag inflator remedy programs among multiple manufacturers; managing inflator sourcing, production, allocation, delivery, and installation; and ensuring adequacy of the remedy. 

Apparently, it’s already game on, because last month, the agency’s chief of Recall Management Division, Jennifer Timian, held a meeting in Ohio with representatives of BMW, Chrysler, Ford, Toyota, Honda, Subaru, GM, Mitsubishi and Nissan – all participants in the Takata Recallapalooza. And, in a subsequent email to the attendees, Timian praised the group:

“We accomplished more than we thought possible in the few short days we had. However, and as many of you lamented, a large portion of the work to be done involves consistent and clear messaging to the public.  To that end, our communications office plans to shortly reach out to your communications folks to arrange a call for later this week to get that coordination kicked off.” The email recommended that automakers send their contact information to NHTSA’s Communication Director Gordon Trowbridge, because, Timian wrote, “We certainly don’t want to leave any critical players out.”

The Safety Record Blog felt a bit left out, and contacted Mr. Trowbridge for comment about the agency’s plans to coordinate communications. He did not respond.

Automakers are definitely upping their communications strategies. One 2002 Honda Accord owner who had inflator recall repairs done in 2011 and 2015 for the driver’s side airbag received several dire robo-calls from the “Honda Customer Service Team,” requesting an immediate response to “this urgent safety recall.” The one minute, 42-second voice message explained in straightforward language how the defect manifested itself. And, unlike the usual recall communications, in which the risk to safety is presented as a hypothetical – even if the defect had caused injuries and deaths – this message dropped all pretense:

“In some Honda vehicles the driver’s side airbag could produce excessive internal pressure upon deployment. If a defective airbag deploys, the increased pressure may cause the inflator to rupture. In the event of a rupture, metal fragments could pass through the airbag cushion material and possibly hit you and others in the vehicle. Past ruptures like this have killed or injured vehicle drivers. Due to the severity of this defect, please call us immediately. Do not delay.”

Meanwhile, the story of who knew what, when has grown like Topsy. And yet, despite intense media attention, there were still pieces of the story that have been hiding in the public record, such as foreign recalls for passenger side frontal airbags that preceded the U.S. recalls by about three years, and a published technical paper lending more credence to at least one root-cause theory that the volatility of phase-stabilized ammonium nitrate that Takata exclusively uses is a key factor in inflator explosions.  

Lies, Lies and Damned Lies

A closer look at the public record shows that automakers have had more truthiness issues with the extent of their knowledge of the problem than previously suspected. To wit, the Part 573 Notices of Defect and Non-Compliance filed in 2013 by Honda, Toyota, and Nissan in their passenger side air bag inflator recalls, which claimed to have discovered the defect in 2011 or later. Honda, for example, told NHTSA that it had no inkling that this could be a problem until October 2011, when a passenger airbag inflator ruptured in Puerto Rico. Ditto for Toyota, which told the agency, that it, too, discovered a passenger-side airbag rupture in October 2011, but in a crash in Japan. Nissan reported to NHTSA that it didn’t know anything about passenger-side airbag inflator ruptures until February 2013, when Takata informed the automaker that it was investigating a “quality issue” with front passenger airbag inflators.

We suspect, however, that the trio already had gotten a big hint there was a problem with exploding passenger side airbags, because all three had launched recalls in the summer of 2010 for passenger inflators in vehicles sold in other countries. Turns out Takata operators had not put enough propellant wafers into the inflators, allowing the other wafers to break apart. 

In August 2010, Honda recalled 57,660 Programmable Smokeless Passenger Inflators (PSPIs) in 82 countries in Asia, Africa, Europe, Middle East, Australia, Mexico and South America, including MY 2001-2003 Civics, MY 2002 Fit vehicles and MY 2001-2003 Stream vehicles because:  “In certain vehicles, the single-stage passenger airbag inflator could produce excessive internal pressure. If an affected airbag deploys, the increased internal pressure may cause the inflator housing to rupture. Metal fragments could pass through the airbag cushion material possibly causing injury or death to vehicle occupants.”

Honda conceded that the U.S. 2001-2003 Civics were similar to the recalled vehicles—except for the inflator modules, which were “dual-stage inflator modules,”  rather than the single-stage modules used in U.S. vehicles, and “we have received no more similar reports for dual stage passenger airbag modules.”

On June 30, 2010, Toyota recalled more than 38,000 MY 2001 Toyota Corolla, Corolla Fielder, Corolla Runx, and Yaris vehicles sold in Japan, France, Malaysia, and “other countries, for: inflators “produced with an insufficient amount of gas generators. In this condition, gas generators in the inflator may become broken and powdered by vehicle vibration over time. This can create abnormal combustion and pressure in the inflator body during airbag activation, causing it to break and scatter. This increases the risk of personal injury during airbag inflation.”

Toyota, long known for its chatty Part 573s, simply said that the foreign vehicles had “different” inflators than those in U.S. vehicles and offered no explanation of the discovery of the defect.

On July 1, 2010, Nissan recalled 4,043 passenger inflators in its 2001 MY Cefiro and Pulsar/Sunny vehicles sold in Japan, Singapore, Australia, and Sri Lanka. The automaker also recalled passenger inflators in 46 U.S. vehicles ( never to be mentioned again). Nissan described the defect as “some air bag inflators may be missing a wafer. As a result, the remaining wafers in the inflator used for the deployment of the front passenger air bag may be broken up into powder due to vibration experienced while driving. This causes the combustion rate of the propellant to increase inside the inflator, which can lead to internal pressure rising suddenly during air bag deployment. In certain cases, the inflator housing may rupture.”

Nissan’s chronology marks its discovery of bad passenger airbags to October 2009, when the automaker learned that a passenger airbag had “deployed abnormally” while being scrapped at a recycling center in Japan. Nissan collected inflators and conducted duplication testing and found that vibration of driving could pulverize the propellant wafers, causing them to burn unnaturally and produce excessive internal pressure. Naturally, Takata records showed that it only happened one time and everything was all fixed up: “During a certain discreet production period, due to a manufacturing error, it was possible that one of the propellant wafers was missing from the inflator. Production records indicated that this manufacturing issue was promptly corrected at the supplier's plant.” 

Given all that had preceded these “discoveries” – multiple recalls, secret testing at Takata, myriad quality control issues at its plants – we think these explanations are one wafer short of an inflator. 

Transient Burning

“Transient Burning Behavior of Phase-Stabilized Ammonium Nitrate Based Airbag Propellant.” That’s a mouthful, isn’t it? Shorter version: Researchers at Pennsylvania State University have been studying the combustion behavior of Takata inflators and how rapidly the propellant burns when there are rapid pressure changes. The technical paper authored by Jonathan T. Essel, Eric Boyer, Kenneth K. Kuo, and Baoqi Zhang of Penn State’s Department of Mechanical and Nuclear Engineering was published in the latter part of 2012. 

For those of you who are not regular subscribers of the International Journal of Energetic Materials and Chemical Propulsion (Editor-in-Chief Kenneth Kuo), this paper describes an investigation into the dynamic burning behavior of an airbag propellant as a function of pressure and pressurization rate. The burn rate of airbag propellants can increase significantly under intense pressure; that’s why they are supposed to be designed to maintain a steady burn rate during the transient combustion process. This paper said:  “It is clear from the results that the PSAN propellant does exhibit dynamic burning behavior. It is also apparent that the higher the pressurization rates, the more severe the dynamic burning effect.” It also said: “The effect of dynamic burning behavior of the propellant needs to be accounted for, when designing or analyzing systems that subject the PSAN propellant to high pressurization rates.” 

This sounds like chemistry-speak for NHTSA’s explanation of the inflator defect:

“Over time, that moisture causes changes in the structure of the chemical propellant that ignites when an air bag deploys. The degraded propellant ignites too quickly, producing excess pressure that causes the inflator to rupture and sends metal shards into the passenger cabin that can lead to serious injury or death.” 

According to a story in today’s New York Times, this investigation was not mere scholarly interest – Takata, which is a sponsor of Penn State’s High Pressure Combustion Lab, paid for this study and forbade the researchers from mentioning Takata or Honda in its published paper. It disliked the results so much that it waited for two years before sharing this information with NHTSA.

Of course, despite the absence of the words “Takata,” and “Honda,” one could infer that the researchers were testing Takata inflators – perhaps at the behest of Takata itself – from several in-the-public-record facts:

  • Of the three global manufacturers of airbag inflators, Takata is the only one to use phase-stabilized ammonium nitrate (PSAN) based propellant.
  • Co-author Eric Boyer is also assistant director of Penn State’s High Pressure Combustion Lab.
  • Takata is a sponsor of Penn State’s High Pressure Combustion Lab.
  • Before a June U.S. House Energy & Commerce Committee hearing updating Congress on the Takata recalls, Kevin Kennedy, Executive Vice President of Takata North America Testifified: “Well, the studies that we have done, and the research that we have from some of the leading experts in the world, seem to indicate that ammonium nitrate is certainly a factor in the inflator ruptures.”

Attorney Ted Leopold, who represents a Duval County, Florida, woman severely injured by a Honda airbag with a Takata inflator, believes that ammonium nitrate is also a factor in over-aggressive deployments. In June 2014, Patricia Mincey, owner of a 2001 Honda Civic, was belted in a moderate frontal crash, when, she alleges, the Honda/Takata airbag “deployed late and violently exploded due to excessive pressurization,” rendering her a quadriplegic. Honda had replaced her inflator in the 2009 recall. Four days after the crash, Honda recalled her vehicle again to replace the defective airbag.

Leopold, of Cohen Milstein Sellers & Toll PLLC in Palm Beach Gardens, Florida, is scheduled to depose Kuo on November 3 about the significance of the Penn State team’s findings.

“The published PSU study confirms that Takata’s use of phase stabilized ammonium nitrate in its inflators results in an over-pressurization that leads to inflator ruptures and aggressive deployments. This often overlooked defect – aggressive deployments – can lead to severe injuries,” he says. 

In 2011 and 2012, while Takata was characterizing the defect as a discrete manufacturing problem, researchers at Penn State were examining the role of the propellant chemistry in inflator explosions and had come to the conclusion that its propellant ignites too quickly. But Takata – three years after this research is published – apparently still isn’t sure. Even as Kevin Kennedy acknowledged that ammonium nitrate is a factor in inflator ruptures, he insisted that its propellant chemistry is safe.

At that same June hearing, Rep. Joseph Kennedy of Massachusetts asked Kevin Kennedy: Can you guarantee that as long ammonium nitrate is used in those products, that the products are safe?

Kevin Kennedy answered: “Well, we believe properly manufactured and designed ammonium nitrate, phase stabilized ammonium nitrate, can be done properly.”

Well, maybe it can, but apparently, Takata didn’t.

Takata, Take Two

The big take-aways from the second round of Congressional hearings on Takata airbag inflator ruptures and recalls were:

  • No root causes have been definitively identified and may never be definitively identified.
  • Takata is going to cut back on its production of ammonium nitrate – one of several potential root causes of inflator explosions. There was a lot of focus on this aspect of the issue – maybe it’s too hard to wrap our heads around the idea that often defect issues result from a confluence of root causes? (Manufacturing, materials and design)
  • That driver’s side replacement inflator you dutifully went to the dealership to get in a previous recall has the same damn problem, so you are going back again whenever supplies are available. But don’t worry it will take another seven years for your newish inflator to go bad. Passengers, take cover. Free advice from Congress to consumer: Check weekly with your local dealership!

Beyond that, the afternoon was largely another episode of Safety Accountability Theater. We have to hand it to NHTSA’s new administrator. Mark Rosekind was smoother than a fresh jar of Skippy, thanking every committee member for asking their question, even as they murdered his last name and the name of his agency. He showed a solid command of the details, even signified that regional recalls are dead, and promised decisive action.  NHTSA will, for the first time in its history, be coordinating a massive, national 11-automaker, 34 million vehicle recall. Rosekind also made a strong pitch for more funding, given the agency’s monumental task, with too few people and an insufficient budget that, adjusted for inflation, is 23 percent lower than it was 10 years ago.

The Democrats on the committee took the occasion as an opportunity to promote Reps. Jan Schakowsky (D-ILL) and Frank Pallone’s (D-NJ) The Vehicle Safety Improvement Act, which would close the loophole that allows rental car companies and used car dealers from putting unremedied recalled vehicles back in the marketplace, kill the whole regional recall strategy of which automakers are so fond, give consumers easier access to more complete safety information and require the disclosure of serious injuries and fatalities.

Takata Executive Vice President Kevin Kennedy sustained multiple lacerations during the hearing by falling on his sword. He did, however, defend its propellant chemical and partly blamed the automakers for failing to write design specs that would have forced them to make safer inflators.

Alliance of Automobile Manufacturers President Mitch Bainwol countered with: we just specify performance. The safety part’s up to you. By the by, Takata, where are your ISO 12097-3 tests requiring failure in a controlled manner?

We also heard a little of the consumers-must-do-their-part shtick – a newly popular lament from the manufacturers and the regulators. And consumers do need to take recalls seriously.  What’s missing from the narrative is a large chunk of the reality which is very relevant to the Takata airbag inflator recalls, but certainly holds true for others. For a long time, NHTSA did next to nothing to ensure that recall remedy rates were adequate – there are no benchmarks for recall success. NHTSA did not keep very good track of how recalls were progressing – it took years for them to notice and take action against manufacturers with poor records – if at all.

The regulations do not require manufacturers to do much more than send a first-class letter informing consumers of a defect. They don’t even have to tell the consumer if the defect has caused injuries and fatalities – the safety risks are expressed as hypotheticals. In this age of social media and connectivity, manufacturers have multiple ways to reach consumers – if they want to, and they can give their customers a more straightforward accounting of the defect – if they want to.

It’s been several years since Congress first considered bills to make used car companies and rental companies get the recalled vehicles in their fleets remedied. That loophole remains open for business.  (Support for the issue appears to be gaining some momentum.)

So nobody in charge of recall policy, enforcement or practice has felt much urgency to get recalled vehicles repaired. Add in supply chain issues in which the part you supposedly desperately need isn’t available for months or a year, and if consumers have a bad case of recall apathy, we certainly know who they caught it from.

Bottom line – failure has many fathers – and consumers are not among them: NHTSA for years of lax defect and recall enforcement, and the automakers — who apparently have had no mechanism for or a desire to enforce quality control on their suppliers –and Takata for hiding the extent of problems and issuing rolling recalls.  

What Do the Takata Recalls Really Mean?

Today, the Department of Transportation announced that it will organize the multi-manufacturer recall of 34 million airbag inflators announced by supplier Takata earlier this week. Just three days earlier, the agency took a victory lap, after finally forcing Takata to launch national – not regional – recalls and to work more closely – under the terms of a consent order and the threat of civil fines – with NHTSA to ferret out the root causes.

The story has played out as a win for the agency and another coat of polish on its newly acquired iron fist. And we find little to argue with there. However, at the consumer level, it may not mean much in the short term.

We haven’t seen an episode of High Noon that pitted federal sheriffs against a black-hatted OEM supplier since 2001, when NHTSA issued an Initial Decision – a painful and public prelude to NHTSA compelling an entity to conduct a recall – in the case of Firestone Wilderness tires on Ford Explorers. On October 4 of that year, more than a year after Firestone initiated its first recall for ATX and some Wilderness tires, the agency determined that that Wilderness tires in sizes P235/75R15 and P255/70R16 on SUVs were defective. Less than two weeks later, Firestone officially threw in the towel, and announced a recall rather than contesting the decision.

Under federal regulations, even suppliers have an obligation to file Part 573 defect notices with all of the same working parts as vehicle manufacturers – including detailed chronologies of the defect’s discovery, affected vehicles, and a no-charge remedy plan. To quote the CFR: “In the case of a defect or noncompliance decided to exist in original equipment installed in the vehicles of more than one manufacturer, compliance with §573.6 is required of the equipment manufacturer as to the equipment item, and of each vehicle manufacturer as to the vehicles in which the equipment has been installed.”

Typically, it is the vehicle manufacturer that assumes these obligations. And, back in 2009, when the snowball started rolling downhill, Honda filed the Part 573s, with very sketchy chronologies, and conducted the recalls with varying degrees of success. But as the explanations for exploding inflators kept shifting and problem gathered mass in 2013, with 10 manufacturers launching recalls, Congressional hearings, new deaths and injuries, along with a steady stream of acid press, the pressure had been building on Takata to officially acknowledge the defect and provide more transparency about the causes. Takata filed recall notices in 2013 and 2014. In December, the agency threatened civil fines if Takata did not launch a nationwide recall for inflators that might explode from over-pressurization. Takata basically told NHTSA to stick it – the agency had no evidence to support its demand, and, by the way, you have no power here!

That was it for NHTSA. The safety-free, deal cuttin’ days of former DOT Secretary Ray LaHood and his sidekick NHTSA Administrator David Strickland (ever brothers, now as lobbyists) were over. You may recall the NHTSA-Chrysler showdown of June 2013, over older Jeeps with behind-the-axle, rear-mounted fuel tanks which burst into flames when struck from the rear – especially at higher speeds. NHTSA formally requested that Chrysler conduct a recall, but the automaker had no interest. To avoid a legal brawl, LaHood, Strickland and Chrysler CEO Sergio Marchionne came up with a cosmetic solution – a retro-fitted tow-hitch, which one year later the automaker hadn’t installed on one vehicle. In the meantime, the roadside incinerations continue and in April a Georgia jury awarded $150 million to the family of a 2012 death of four-year-old boy, who died in his booster seat after the 1999 Jeep Grand Cherokee was struck from behind and burst into flames. The airport conference-room recall that the trio cooked up with is still leaving a stench.

Takata has filed four separate Part 573s and here’s what they have told us:

First, after six years of offering revolving root-cause explanations – when anyone bothered at all – Takata concedes that this is a multi-root cause problem involving moisture intrusion caused by leaking seals, the design of the inflator, the airbag, the vehicle, the shape of the propellant, and manufacturing “variability”:

It appears that the inflator ruptures have a multi-factor root cause that includes the slow-acting effects of a persistent and long term exposure to climates with high temperatures and high absolute humidity. Exposure over a period of several years to persistent levels of high absolute humidity outside the inflator, combined with the effects of thermal cycling, may lead to moisture intrusion in some inflators by means of diffusion or permeation. Fraunhofer ICT has identified the possibility in these climates for moisture intrusion into the inflator over time and a process by which the moisture may slowly increase the porosity of the propellant within the inflator. Fraunhofer ICT's analysis also indicates that the design of the inflator and the grain (shape) of the propellant can affect the likelihood that the porosity change will occur, as can manufacturing variability. The results of the Fraunhofer ICT research to date are consistent with the geographic location and age of the inflators that have ruptured in the field and in Takata's testing. Takata's testing also indicates that the design of the vehicle and the design of the air bag module are associated with differences in outcomes.   

And:

Takata is also aware of a potential issue associated with the inflator body internal tape seals on some SPI inflators. During its investigation, Takata observed a small number of tape seal leaks in SPI inflators manufactured prior to 2007. These leaks were discovered during leak testing in 2014, as part of the Takata returned-inflator evaluation program.

 

Second, we got an official count of field incidents: Takata put that figure at 84, if we add the ruptures in each of the four defect notices.

Third, we learned that the recall system sucks – 77 percent (65) of the incidents occurred in vehicles that had already been recalled but not remedied.

But playing chicken with Takata differs from the NHTSA-Firestone standoff in one key respect: Takata cannot directly recall vehicles as tiremakers – which have distinct recall obligations from other OEM component manufacturers – do.

And unlike any recall to come before in the history of recalls, NHTSA will apparently be coordinating the whole enchilada. There is, however, a nifty tie to the Firestone recalls. The agency is tapping a heretofore unused power granted by the Transportation Recall Enhancement, Accountability and Documentation (TREAD) Act, passed in the wake of the Ford Explorer-Firestone tire crisis. Interesting historical irony for NHTSA scholars. For consumers, that means that the zillions of inflators will pass through three entities: Takata, the vehicle manufacturers and NHTSA. How this plays out we'll have to wait and see. But the days of filing a recall and doing your thing appear to be gone for now.  

Takata Airbag Defect Explodes into Crisis

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:
  • Propellant wafers with inadequate compaction force;
  • 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;
  • The process of processing the propellant into a wafer on a specific Stokes high-compression machines;
  • The handling of the propellant during manufacturing; 
  • Propellant wafers with lower material density; 
  • Prolonged exposure to heat and humidity over the lifecycle of the vehicle;
  • 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:
  • Confusion over one manufacturing processes that did not automatically verify all propellant as being within specification;
  • An unreliable method of sampling production meant that Takata could not absolutely assure that the inflators in the recall population met all production criteria;
  • 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;
  • 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.
 

The Continuing Case of Takata’s Exploding Airbags

Last week, four Japanese automakers – Toyota, Nissan, Honda and Mazda – announced recalls of 3.4 million vehicles for “improperly pressurized” airbags made by Takata that could rupture, igniting fires or propelling metal fragments that could travel “upward toward the windshield or downward toward the front passenger’s foot well.”

They forgot to mention that they could shoot straight out and hit you in the chest, as allegedly happened in 2009 to a Florida woman who owned a 2001 Honda Civic. And, they apparently forgot to mention that these airbags have been recalled over and over again since 2001.

In this latest campaign, Takata said that it only learned of the problem in 2011, after an alleged rupture of a passenger airbag inflator occurred in Puerto Rico. Certainly, it’s unlikely that 2011 was the first the supplier heard about this issue. There have been six recalls associated with Takata airbags that explode with too much force, spraying debris in their wake. This slow-moving rolling recall for manufacturing defects involving 13-year-old vehicles raises more questions than it answers. Why is Honda identifying a manufacturing process problem so long after these vehicles were produced?

The latest recall of 2000 to 2004 vehicles suggests an age degradation issue involving the propellant. Honda’s ever-changing explanations suggest that perhaps more than one manufacturing problem lies at the root of the inflator rupture problems.  A stroll through the recall documents also reveals Honda’s odd behavior – like recalling 830,000 vehicles to find 2,400 replacement modules. The depth of NHTSA’s involvement is also unknown. The agency began asking questions in 2009, without actually assigning the recall investigation an official Recall Query number. We suspect that the Recall Management Division has been keeping close company with Honda ever since.

Honda Inflator Ruptures Through the Years

2008: Recall 08V593

In November 2008, Honda began to recall certain 2001 Accord and Civic vehicles to replace airbags that “could produce excessive internal pressure,” causing “the inflator to rupture,” spraying metal fragments through the airbag cushion. Honda said that it learned of the problem via a June 2007 claim. In September 2008, another metal-laced deployment occurred. The limited campaign affected fewer than 4,000 vehicles.

2009: Recall 09V259

On June 30, 2009, Honda decided to expand the recall to 440,000 MY 2001 and 2002 Civic, Accord and Acura vehicles, after receiving two more claims of “unusual deployments” on May 28 and June 9.

At this point, Honda got NHTSA’s attention. In August 2009, the Recall Management Division sent Honda an information request to explain why Honda didn’t include these vehicles in the 2008 recall, and “to evaluate the timeliness of HMC’s recent defect decision.” The Recall Management Division asked for complaints, lawsuits, warranty claims and field reports, along with a lot more explanation about the “unusual deployments” and Honda investigative efforts.

In Honda’s September reply, the automaker said that its information came from Takata:

“We understood the causal factors to be related to airbag propellant due to handling of the propellant during airbag inflator module assembly.” Later, Honda and Takata pinpointed the problem to “production of the airbag propellant prior to assembly of the inflators.” Specifically, the cause was “related to the process of pressing the propellant into wafers that were later installed into the inflator modules,” and limited to “one production process” involving one high-precision compression press that was used to form the propellant into wafers, the automaker told NHTSA.

(Honda included an October 2, 2008 presentation Takata made to Honda about the causes – the substance of which was granted confidentiality.)

The automaker said that it had fielded nine complaints and one lawsuit, with the first incident reported to Honda in May of 2004. It is difficult to determine if these represented complaints apart from those mentioned in Honda’s Defect and Noncompliance reports for the 2008 and 2009 recalls, because the dates of these complaints don’t line up.

(NHTSA has fielded at least four complaints from Honda customers reporting airbag deployments that shot metal shards into an occupant. But the first such claim came in 2005. According to ODI complaint number 10152674, a driver in Wheaton, Ill. reported that during a head-on collision, “the airbag exploded and discharged metal fragments causing injury to the driver.”)

Honda said that the common thread in these complaints was over-pressurization that created “some form of separation of the metal airbag inflator shelf, resulting in metal fragments of the shell being propelled through the airbag fabric. In most cases the metal fragments were relatively small, though in one instance it appears that the second stage of the two-stage inflator became separated from the inflator module and was propelled toward the driver.”

Since NHTSA didn’t open an official Recall Query, it’s difficult to say if Honda’s submissions were sufficient to close the matter for the agency.

2010: Recall 10V041

About three months after its 2009 recall, Honda announced a third recall for 379,000 vehicles – more 2001 and 2002 Accords and Civics, and certain 2002 MY Honda CR-V, 2002 Honda Odyssey, 2003 Honda Pilot, 2002-2003 Acura 3.2TL and 2003 Acura 3.2CL vehicles. This time, Honda said that there were two different manufacturing processes used to prepare the propellant – one was verified as being within specifications, but the other was not. Honda decided to recall all of those using the second process – even though the automaker claimed that testing of some inflators from this batch found that they performed properly.

2011: Recall 11V260

In April 2011, Honda filed yet another Part 573 Defect and Noncompliance report for 2,430 replacement service part airbag modules that might have been installed in vehicles covered by previous recall expansions. Despite an analysis to determine where those 2,430 replacement modules went, Honda said they couldn’t find them – so the automaker was going to contact all owners of previously recalled models – all 833,277 of them – to capture the errant replacement modules.

The problem continued to surface. In addition to the Puerto Rico incident in 2011, in October 2012, the owner of a 2002 Civic from McKinney, Texas reported to NHTSA:

 

I was proceeding to make a left turn after stopping and looking at an all-way stop. A Ford truck coming the opposite direction ran the stop and crashed into my car in the right-front. The airbags deployed and I was stunned by the impact. My left ear and face were severely lacerated by fragments of the airbag inflator (which were found and photo-documented), resulting in 29 stitches and permanent scarring. Shortly after the accident, Honda sent me a recall notice regarding the airbag inflator: this was the first time I was made aware of the fact that the airbag inflator was known to produce shrapnel and had caused fatalities. Despite having owned the car since 2003 and having it serviced at dealerships several times over the years, I had not received any prior information regarding the lethal airbag defect. Honda has been irresponsible and apathetic regarding my situation and the problem in general. I could have easily been injured worse or killed by the fragments, yet the company seems to not take the problem seriously. I will absolutely never own another Honda, will forbid my family and loved ones from owning a Honda.

 

2013: Recall 13V132

And that brings us up to this month, when the exploding airbag recall exploded into the millions. According to Honda’s most recent Defect and Noncompliance report, the airbag that exploded in Puerto Rico in October 2011 prompted Honda to ask NHTSA if it could collect “healthy” airbag modules to see if “abnormal combustion was possible,” and guess what? It was! But Honda claims it still didn’t know why.

On February 8, NHTSA and Honda met to discuss the “ongoing investigation.” Honda said that “A recreation of propellant production using the same methods as were used during 2001-2002 production periods indicated that it was possible for propellant produced during 2001-2002 to be manufactured out of specification without the manufacturing processes correctly identifying and removing the out of specification propellant. 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.”

Well that clears it all up, then.

So, why are these Takata airbags spewing metal? Let’s review the explanations:

·        In 2008, it was excessive internal pressure caused by the handling of the propellant during airbag inflator module assembly. Then it was a manufacturing process that occurred before assembling the inflators — the process of pressing the propellant into wafers, traced to one particular compression machine.

·         In 2010, Honda/Takata revealed that there were actually two different manufacturing processes used to prepare the propellant – one was verified as being within spec, but the other wasn’t.

·         In 2013, Honda/Takata discovered that the propellant produced in 2001-2002 could be out of spec without the plant knowing it, and “another potential concern” – as yet unidentified.

Confused yet? Exactly how were these propellants out of spec? Was Takata skimping on the chemical binders that hold the material together? Is this an age degradation issue – exacerbated by heat? Time? Moisture? Publicly known complaints emanate from warm climate states like Texas, Florida and Puerto Rico. If this is a manufacturing process issue, why did it take Takata six years to suss it out? Why are some newly manufactured airbags exploding and spraying shrapnel? Same reasons?

One thing is for sure: these recalls don’t inspire much confidence that the problem has been solved.