Recalls
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  • Federal Motor Vehicle Safety Standard No. 213 specifies requirements for child restraint systems used in motor vehicles
  • • Before initiating an investigation, ODI carefully reviews the following to determine whether an alleged defect trend may exist. • Auto Safety Hotline • Vehicle Owner Questionnaires • Correspondence • Technical Service Bulletins • Dealer Communications • Other available data to determine whether an alleged defect trend may exist
  • While there are certain areas within the TREAD Act that need improvement, NHTSA has worked hard to ensure that new rules are issued in a timely manner. Major crash avoidance and consumer information rules:  Early warning information system to alert consumers on defects: F Tire pressure monitoring system to alert consumers of under-inflated tires: F Consumer reimbursement for defective vehicles or parts that are later recalled: D Rollover propensity consumer information program: C-  ( Note: Companion rule on vehicle handling as yet un-issued) New tire safety standards: D NHTSA Average for implementation of these Major Safety rules from TREAD:D Timeliness of issuance of rules: A-
  • Preliminary Evaluation (PE) • Initial phase of a NHTSA investigation • Most PEs are resolved within four months • Options: • May be upgraded to EA • Recall initiated • Investigation closed Engineering Analysis (EA) • Undertaken if data from a PE indicate further examination of a potential safety defect is warranted • Most EAs are resolved within one year • Second and final phase of a NHTSA investigation • Safety recall may be initiated or investigation closed Recall Query (RQ) • NHTSA monitors recalls to ensure that the scope, completion rate, and remedy are adequate • May be expanded or an adjustment in existing remedies is required Defect or Recall Petition (DP or RP) • NHTSA may be petitioned to investigate an alleged safety defect or whether a manufacturer has successfully carried out the requirements of a recall
  • Labeling on the child restraint itself must include both an address and phone number for the manufacturer • Manufacturers are required to maintain these registration records for a minimum of six years from the date of manufacture of the seat • Child restraints built into vehicles at the factory are exempt from these registration requirements.
  • 11% of these (in both time periods) were reported as campaigned units (those restraints that were reported remedied, removed from sale to the public, or removed from use by the public.)
  • During this time manufacturers are required to provide recall kits or a remedy to the consumer. After the 18 month period, there is no legal obligation to provide a kit or remedy although many do.

Recalls Recalls Presentation Transcript

  • Recalls & Communicating Sensitive Issues – 2 CEU’s May 14, 2010
  • Partners
    • This presentation was created with information provided by:
    • National Highway Traffic Safety Administration (NHTSA)
    • Mission is to save lives, prevent injuries, reduce vehicle–related crashes
    • Responsible for National CPS curriculum
    • Safe Kids Worldwide
    • Certifying Body for CPS program
    • Directory of nationally certified CPST’s and instructors
    • Communication with technicians (CPS Express, Tech Update)
    • Recall technical update: 3/11/10
  • Objectives
    • Explain how the offices within NHTSA are responsible for non-compliance and safety defect recalls
    • State the most important reason that a caregiver should register their car seat
    • List 3 methods of registering car seats
    • Define the role of the CPS technician in explaining a recall remedy or repair to families
    • Communicating sensitive issues with parents (rear-facing and airbags)
  • NHTSA’s Role
    • Safety recalls are conducted in accordance with (US Code 301 49 CFR parts 573 and 577)
    • Conducts investigations of alleged safety defects and tests for compliance within FMVSS
    • Works in conjunction with CR manufacturers who often identify the defect first
  • CR Recall Basis
    • A recall is required when there is:
    • A “non-compliance” of FMVSS 213
    • An identified safety defect
    • Recalls
    • May or may not effect crash worthiness
    • Owners can often continue to use their seat until remedy is received and completed
  • About the Office of Defects Investigation (ODI)
    • ODI is an Office within NHTSA
    • ODI conducts defect investigations and administers safety recalls
    • NHTSA is authorized to order manufacturers to recall and repair vehicles or items of motor vehicle equipment
  • About the Office of Defects Investigation (ODI)
    • ODI monitors the completion, scope and remedy effectiveness of manufacturers' recall campaigns
    • Recall information is posted to the ODI section of NHTSA’s website for six months
  • About the Office of Vehicle Safety Compliance (OVSC)
    • Administers programs to ensure compliance with Federal laws, standards and regulations
    • Manufacturers’ determine their own quality control programs
    • OVSC randomly selects test samples from the marketplace and test them to the minimum performance requirements of the applicable standard
    • The investigative approach is to work closely with the manufacturer, on a technical basis, to resolve the failure issue
  • The TREAD Act
    • Enacted in October of 2000, the Transportation Recall Enhancement Accountability Documentation (TREAD) Act exists to detect patterns that may be safety related.
    • Requires manufacturers of motor vehicles and equipment (CR) sold in the U.S. to submit quarterly reports to the Early Warning Reporting Division (EWR) within NHTSA that summarize claims made against them
    • Quarterly data is submitted electronically to NHTSA
  • The TREAD Act
    • Timeliness of issuance of new rules  A-
    • The Executive Summary of the TREAD Act is available at http://www.nhtsa.dot.gov/cars/rules/rulings/TPMS-FMVSS-No138-2005/executive_summary.html
  • Early Warning Reporting: Provided by the manufacturer
    • Initiated in 2003 and was confidential
    • Some data became public in late 2008
    • Report
      • Production Data
      • Numbers of Consumer Complaints
      • Numbers of Warranty Claims
      • Numbers of Field Reports
      • Claims and Notices of Death and Injury
  • Defects Assessment Division (DAD) Investigative process
    • Screening: Preliminary review of consumer complaints
    • Petition Analysis: An analysis of petitions or reviews of safety-related recalls
    • Example of consumer complaint leading to a recall. Photo courtesy of NHTSA
  • Ways to submit complaints to NHTSA
    • Source: http://www.safercar.gov/
    • www.safercar.gov
    • Contact NHTSA’s Auto Safety Hotline (888) 327-4236
    • Correspond with ODI via letter
    • Contact a DAD specialist when finding an issue in the field (a technician or instructor can email directly)
  • Who is paying attention?
    • Who may initiate a recall?
  • Manufacturer or NHTSA
    • A recall may be initiated by a manufacturer through testing, inspections of incoming components, through its engineering staff, or identifying a trend in Early Warning Report
    • An investigation may also be initiated by NHTSA during complaint screening, technical bulletins, Early Warning Report data, or compliance testing. The investigation may lead to a recall
  • Office of Defect Investigation (ODI) Investigation Process
    • Preliminary Evaluation (PE)
    • Engineering Analysis (EA)
    • Recall Query (RQ)
    • Defect or Recall Petition (DP or RP)
  • Fact or fiction?
    • Registration cards have always been an important component of FMVSS 213.
      • Fact
      • Fiction
  • Correct answer is fiction
    • Manufacturers of child safety seats have been required to provide a postage-paid registration form with each new child safety seat since 1993
  • Many recalls over time
    • During 1981 through 1989, six million child restraints were recalled
    • During 1990 and 1991, twelve million child restraints were involved in recalls
  • Vehicle Owner Resource
    • Motor Vehicle Safety Defects and Recalls Booklet
      • Includes commonly asked questions about how and why recall campaigns are initiated
      • Informs consumers of their rights and responsibilities when a vehicle or item of motor vehicle equipment is recalled
      • Learn more at http://wwwodi. nhtsa.dot.gov/recalls/recallprocess.cfm
  • Child Restraint Registration
  • Registration and Recall Compliance Rates
    • Prior to 1993
      • Fewer than 3% of child seats were registered
      • 14% of seats were repaired
    • Following 1993
      • 27% of child seats were registered
      • 22% seats were repaired
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • How Child Restraint Was Acquired Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Type of Store Where Seat Purchased
  • Who Consumers Spoke with About Registration When Acquiring Seat
  • Importance of Registering Child Safety Seats by Action taken with Registration Card
  • Registration Information provided by Retail Stores
    • 54% provide registration information
      • 19% provide general information
      • 35% provide information about reg form
    • • Type of store
      • Specialty 69%
      • Discount 42%
    • 43% provided why it was important
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Community Based Programs
    • Registration cards are completed either by the participants themselves or by program staff, and then mailed (usually by program staff) to the manufacturer
    • May get lost in the mail
    • Encourage online registration with manufacturer and www.safecar.gov
    • Recall notification and repairs are difficult to monitor
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Reasons for Registering Seats
    • 91% notification of recall
    • 15% warranty protection
    • 2% because someone else told them to return it
    • 3% other reasons
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Reasons for Not Registering Seats
    • 85% Too busy
    • 6% Lost card
    • 3% Consider unimportant
    • 2% Concerned about use of information
    • 4% Other
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • The demographic groups with the lowest registration rates
    • Under age 21
    • Those with a high school diploma or less education
    • Those making under $40,000 annually
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Child Seat Recall Notification
  • Fact or Fiction
    • In most cases, a CR recall indicates a danger or potential danger for the child occupant
      • Fact
      • Fiction
  • Correct: Fiction
    • Keep recalls in perspective.
    • The term “recall” is a generic term that is used to indicate the need for: Repair, Replacement, Refund, or a warning.
    • A CR may be recalled because of a safety defect that could reduce effectiveness in a crash, pose a noncrash- related hazard, or due to an error on the label or instructions.
    Source: National Standardized CPS Training Program Curriculum HS 366 R5/04, E-5
  • Example of Recall Error in instructions
    • Canadian Diplomat User Guide Harness positioning instruction issue
      • French version on page 45 of the User Guide, the word “audessus” or “above” was misspelled as “au-dessous” which translates to “below” the shoulder
    • The US version instruction is correct
      • It is not provided in multiple languages
  • Example of Recall Error in instructions
    • Team Tex Babyride
    • Recall 4 24 09
    • NHTSA Campaign ID number 09C003000
  • Example of recall that is NOT crashworthy
    • Evenflo Two in One
      • Seats backrest and base have separated during sled testing when used with 5 pt. harness
    • Seats were replaced
    NHTSA NO.: 98C014000 Source: Evenflo
  • How Registered Owners Found Out About a Recall Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Fact or Fiction
    • A car seat should not be used while waiting for the repair kit.
      • Fact
      • Fiction
  • Correct: Fiction
    • The caregiver may use another car seat if they have one that is appropriate for the child. If not, the recalled car seat may be used unless the recall states no t to.
    • Using the recalled seat is safer than having a child ride without any car seat. Be sure to counsel the caregiver that the seat should be repaired as soon as possible.
  • Child Seat Repair Example
    • Recaro Como and Signo
      • Harness may become disconnected from the harness connector when a child is placed in or removed from the child seat
      • Two rubber caps for installation on the harness connector and an instruction sheet
    NHTSA No.: 08C003000 Photo source: NHTSA
  • What Consumers Remembered
    • Received instructions
      • 70% said they did
      • 22% said they did not
      • 7% said they could not remember
    • Of those that remembered receiving instructions
      • 91% reported instructions were extremely clear
      • 6% fairly clear instructions
      • 4% felt the instructions were not clear at all
      • 84% of consumers said seat was repaired or replaced
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Retail Store Experience with Recall of Seats Still in Stock
    • How clear were the instructions?
      • 38% extremely clear
      • 35% very clear
      • 19% fairly clear
      • 4% somewhat clear
      • 4% not at all clear
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Retail Stores-How Recall of Child Seat Was Resolved
    • 65% Manufacturer credited store
    • 54% Manufacturer replaced CR
    • 46% Manufacturer sent parts
    • 24% Manufacturer fixed the CR
    • 6% Manufacturer had customer call
    • Respondents were permitted to select multiple responses, so they sum to more than 100 percent
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Example of seat: No recall
    • Dorel Juvenile Group
      • Component: Headrest/Harness Adjustment Bar
        • Screws detached from adjuster bar to headrest
    2003 Cosco Summit High Back Booster PE06034 Photo source: NHTSA
  • Example of Recall: CR is crashworthy
    • Graco ComfortSport Car Seat
      • Large supplemental pad, or body pillow, partially obscures the airbag warning label on the seat pad
      • Discard the supplemental body pillow, which is designed only for comfort and not for increased crash protection
  • Costs and Benefits
    • $2.6 million annually
    • 43¢ per seat sold in the United States
    • 20 to 40 thousand child seats involved in recalls are repaired each year because of the registration card requirement
    • The cost per child seat repaired is estimated to be between $66 and $132
    Source: Evaluation of Child Safety Seat Registration. NHTSA Publication DOT HS 809 518 (10/2002)
  • Register Now!
  • Register Child Restraints online www.safercar.gov
  • Two Options to Register: NHTSA and Manufacturer
    • Register the restraint at www.safercar.gov and with the child restraint manufacturer of the seat
  • Online Registration
    • 7,846 confirmed subscriptions between August and October, 2008
    • Reminder message sent to capture users who did not complete their registration
    • New email crafted that has a higher probability of getting through with instruction to users on how to modify their filters
  • Subscribe to email notification
  • Really Simple Syndication (RSS) Feed Option
  • RSS Feed Option Instructions
  • Manufacturer’s Provide Online Guidance Photo sources: Mfg. websites
  • Fact or Fiction
    • Are recall kits always available to consumers whose CR is older than 6 years from date of manufacture?
      • Fact
      • Fiction
  • Correct: Fiction
    • A recall campaign is considered open for 6 quarters (18 months) after the initiation of the recall
  • Resources & Contacts
    • National Highway Traffic Safety Administration (NHTSA)
      • ODI Defects Assessment Division
      • [email_address]
    • Consumer Product Safety Commission https:/www.cpsc.gov/cpsclist.aspx
  • Role of the Technician Photo courtesy of Safe Kids Worldwide
  • Example of a Technician Report to ODI – No Recall
    • Britax Roundabout
      • A lower LATCH connector was easily released
      • Seat was sent to ODI
    PE03045 Photo courtesy of Britax instruction Manual
  • Tech Resource: Example Britax Advocates Extranet Photos courtesy of Britax website
  • Child Restraint Recall Lists
    • NHTSA www.safercar.gov
    • Safety Restraint Coalition
    • www.800bucklup.org
    • Highway Safety Research Center www.hsrc.unc.edu/pubinfo/child_recall.htm
    • SafetyBeltSafe U.S.A. www.carseat.org
  • Research Question
    • Recall One: Using the NHTSA CR recall list: http://www.hsrc.unc.edu/safety_info/child_passenger_safety/child_restraint_recalls.cfm ; look this recall up and answer the question on the next slide
      • Mfg.: Peg Perego
      • Model name: Primo Viaggio
      • Date: 3/8/2001
  • Research Question
    • Recall One: The component, issue, and remedy for this recall is:
    • This CR is not one that has been recalled
    • The lower anchor connector adjuster assembly may interfere with the connection to the restraint base when installed using LATCH; seat belt is not affected
    • The bottom LATCH mechanism of the child seat on the left side does not completely engage the latching rod of the base that the stays in the vehicle; the car seat can detach from the base possibly causing serious injury or death to the child, the customer will be provided instructions on how to identify affected seats and perform the repair
    • None of the above
  • The answer is C
    • Recall One: The component, issue, and remedy for this recall is:
    • This CR is not one that has been recalled
    • The lower anchor connector adjuster assembly may interfere with the connection to the restraint base when installed using LATCH; seat belt is not affected
    • The bottom LATCH mechanism of the child seat on the left side does not completely engage the latching rod of the base that the stays in the vehicle; the car seat can detach from the base possibly causing serious injury or death to the child, the customer will be provided instructions on how to identify affected seats and perform the repair
    • None of the above
  • Follow up Question
    • Is this CR crashworthy; what would you say to the parent?
    • This CR is crashworthy; be sure to follow the instructions for repair, contact the manufacturer for any questions you may have
    • This CR is not crashworthy the seat should not be used and the family needs to buy a replacement CR
    • This CR is crashworthy; the lower anchor attachment on the left side doesn’t work properly, follow the instructions for identifying and repairing; you may use the seat belt system until it has been repaired
    • Both A and C
  • The correct answer is D
    • Is this CR crashworthy; what would you say to the parent?
    • This CR is crashworthy; be sure to follow the instructions for repair, contact the manufacturer for any questions you may have
    • This CR is not crashworthy the seat should not be used and the family needs to buy a replacement CR
    • This CR is crashworthy; the lower anchor attachment on the left side doesn’t work properly, follow the instructions for identifying and repairing; you may use the seat belt system until it has been repaired
    • Both A and C
  • Research Question
    • Recall Two: Using the North Carolina CR recall list:
    • http://www.hsrc.unc.edu/safety_info/child_passenger_safety/child_restraint_recalls.cfm ; look this recall up and answer the question on the next slide
      • Mfg.: Dorel Juvenile Group
      • Model name: Alpha Omega
      • Model number: 02-537
      • Date: 12/23/2000
  • Research Question
    • Recall Two:
    • The component, issue, and remedy for this recall is:
    • The tether webbing could be cut and separate in a crash allowing excessive movement of the child, a free repair kit is available
    • The tether webbing could be cut and separate in a crash, the seat is not crashworthy and should not be used
    • The tether webbing could be cut and separate in a crash, the seat should not be used until the repair kit is available and completed
    • This CR is not one that has been recalled
  • The correct answer is A
    • Recall Two:
    • The component, issue, and remedy for this recall is:
    • The tether webbing could be cut and separate in a crash allowing excessive movement of the child, a free repair kit is available
    • The tether webbing could be cut and separate in a crash, the seat is not crashworthy and should not be used
    • The tether webbing could be cut and separate in a crash, the seat should not be used until the repair kit is available and completed
    • This CR is not one that has been recalled
  • Follow up question
    • Is this CR crashworthy; what would you say to the parent?
    • The CR is crashworthy; the CR may be used until the tether repair has been completed; CR are tested with and without tethers , a tether reduces forward movement and should be used when available; contact your manufacturer, you may use another CR in the mean time if you like.
    • The CR is not crashworthy and should not be used
    • The CR is crashworthy, contact and follow the manufacture instructions
    • Both A and C
  • The answer is D
    • Is this CR crashworthy; what would you say to the parent?
    • The CR is crashworthy; the CR may be used until the tether repair has been completed; CR are tested with and without tethers , a tether reduces forward movement and should be used when available; contact your manufacturer, you may use another CR in the mean time if you like.
    • The CR is not crashworthy and should not be used
    • The CR is crashworthy, contact and follow the manufacture instructions
    • Both A and C
  • Provide Resources, Be a Resource
    • Utilize a checklist form and complete it properly
    • Encourage CR registration to NHTSA and manufacturer
    • Keep available for each inspection to provide caregiver:
      • Tips on ways to register car seat
      • Registration forms
      • Complaint forms
    • Be familiar in navigating recall lists
    • Be familiar with recent recalls
    • Consider highlighting the component, issue and remedy and review at pre-event meeting
  • Provide Resources, Be a Resource
    • Assist caregivers in understanding the recall and repair instructions
      • Do not alarm the caregiver but emphasize the importance of fixing it as soon as possible
    • Report identified issues to the manufacturer and ODI
    • Consumer/Technician may document with photos, videos, and highlighted instruction booklet; include statement “photos available” on form
  • Provide Resources, Be a Resource,
    • Technicians should rarely need to keep a recalled seat unless the manufacturer says the seat should not be used and if the child needs to transition to an appropriate CR
    • The manufacturer may want to work directly with the owner to replace the defective seat and evaluate the defect issue
      • First consult with manufacturer’s customer service to verify your understanding of the manufacturers’ remedy before checking with a senior checker or event coordinator
      • If there is a need to keep a seat, be sure the family has a replacement
  • Rear facing vs. forward facing
    • http://www.youtube.com/watch?v=kRP7ynNI8mI