The Recall Process

imp safety recall March 2014Vehicle safety recalls can be voluntary: in these cases, the manufacturer independently initiates a recall after learning of a safety defect or noncompliance with federal safety laws. Alternatively, after an investigation, the National Highway Transportation Safety Administration determines a recall is mandatory. Internal and NHTSA investigations are usually triggered by customers complaints, dealer feedback, and lawsuits filed against the company.

In either case, “the manufacturer must file a public report describing the safety-related defect or noncompliance with a Federal motor vehicle safety standard, the involved vehicle/equipment population, the major events that resulted in the recall determination, a description of the remedy, and a schedule for the recall” (NHTSA). When the recall is voluntary, the manufacturer has only five days to notify the NHTSA of the upcoming recall.

Processes for determining voluntary recalls vary by manufacturer. In the case of General Motors, at least before the ignition switch recalls, a hierarchy of committees reviewed safety issues before considering a recall (Jenner & Block, 2014; Jolsen, 2014). First, engineers would complete a preliminary review, called an Investigation Status Review. If this ISR reveals defects or safety concerns, the multidiscipline Field Performance Execution Team convenes to discuss logistics. Next, the Recommendation Group determines if the recall is related to safety or customer convenience. Finally, the Executive Field Action Decision Committee (EFADC) must unanimously agree to the recall. Once they do, the five-day countdown to notify the NHTSA begins.

Jenner and Block (2014) determined that GM considered moving stalls a customer convenience issue rather than a safety issue. Even though outsiders had made the connection between the faulty ignition switch and nondeployment of airbags (Indiana University Transportation Research Center, 2007, April 25; Wisconsin State Patrol Academy, 2007, February 14), internally, engineers failed to see the link. Their tunnel vision was exacerbated by the silos between departments and by the failure of GM employees to share critical information.

When the GM legal department and the EFADC received conclusive evidence that the ignition switch could power off the car, thereby disabling airbags and in turn leaving drivers and passengers at risk of injury or death, GM did finally issue the first recall in January 2013. Sadly, for over ten years, GM missed opportunities to identify and correct the ignition switch. As a result over 100 people died and hundreds were injured. The GM Compensation Fund provides statistics regarding the number of claims received and settled, but the true numbers are unavailable.

Documents

From Wired.com:

How Car Recalls Work

Available from the National Highway Transportation Safety Administration:

What is a Safety Recall?

Defect Notice

Retail Acknowledgement Letter

Customer Outreach Letter

December 2014 Letter to Owners

Consent Order

References

Jenner & Block. (2014). Report to board of directors of General Motors Company regarding ignition switch recalls. Chicago, IL: Valukas, A.

Golson, J. (2014, June 11). How auto car recalls work. Wired. Retrieved from http://www.wired.com/2014/06/how-auto-car-recalls-work/

Indiana University Transportation Research Center. (2007, April 25). On-site air bag non-deployment investigation: Vehicle – 2005 Chevrolet Cobalt, Location – Wisconsin. Special Crash Investigation Team #2

Wisconsin State Patrol Academy. (2007, February 14). Collision analysis and reconstruction report. Young, K. A.

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