Coordinated Remedy Order With Annex A; Coordinated Remedy Program Proceeding |
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Topics: Takata
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Mark R. Rosekind
National Highway Traffic Safety Administration
November 16, 2015
[Federal Register Volume 80, Number 220 (Monday, November 16, 2015)]
[Notices]
[Pages 70866-70874]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-28924]
[[Page 70866]]
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
[Docket No. NHTSA-2015-0055]
Coordinated Remedy Order With Annex A; Coordinated Remedy Program
Proceeding
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Coordinated Remedy Order.
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DATES: Effective date: This Coordinated Remedy Order went into effect
on November 3, 2015.
Order: This Coordinated Remedy Order (``Order'') is issued by the
Administrator of the National Highway Traffic Safety Administration
(``NHTSA''), an operating administration of the U.S. Department of
Transportation. Pursuant to NHTSA's authority under the National
Traffic and Motor Vehicle Safety Act of 1966, as amended and recodified
(the ``Safety Act''), 49 U.S.C. 30101, et seq., and specifically, 49
U.S.C. 30118-30120, 30120(a)(1), 30120(c)(2)-(3), 30166(b), 30166(c),
30166(e), 30166(g)(1), and 49 CFR 573.6, 573.14, this Coordinated
Remedy Order establishes a Coordinated Remedy Program and sets forth
the requirements and obligations of certain motor vehicle manufacturers
\1\ and TK Holdings, Inc., (``Takata'') in connection with the recall
and remedy of certain types of Takata air bag inflators.
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\1\ Currently, BMW of North America, LLC (``BMW''), FCA US, LLC
(``FCA'') (formerly Chrysler), Daimler Trucks North America, LLC
(``Daimler Trucks''), Daimler Vans USA, LLC (``Daimler Vans''), Ford
Motor Company (``Ford''), General Motors, LLC (``GM''), American
Honda Motor Company (``Honda''), Mazda North American Operations
(``Mazda''), Mitsubishi Motors North America, Inc. (``Mitsubishi''),
Nissan North America, Inc. (``Nissan''), Subaru of America, Inc.
(``Subaru''), and Toyota Motor Engineering and Manufacturing
(``Toyota''). In accordance with Paragraphs 45, 46, and 48 below,
this list may expand at some future date to include other motor
vehicle manufacturers who have sold or otherwise made available in
the United States motor vehicles equipped with Takata air bag
inflators containing phase-stabilized ammonium nitrate.
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I. Nature of the Matter and Findings
1. On June 5, 2015, NHTSA opened the Coordinated Remedy Program
Proceeding and public Docket Number NHTSA-2015-0055 to address the
recalls of certain Takata air bag inflators, which together constitute
the largest Safety Act recall in NHTSA's history and one of the largest
consumer product recalls in United States history. See Notice of
Coordinated Remedy Program Proceeding for the Replacement of Certain
Takata Air Bag Inflators, 80 FR 32,197 (June 5, 2015). As of the date
of this Order, the number of recalled air bag inflators (currently,
approximately 23 million), impacted vehicles (currently, approximately
19 million), and affected vehicle manufacturers (currently, twelve), in
combination with the potential for expansion of existing recalls and
issuance of new recalls, and the remedy part supply challenges related
to the existing recalls, presents an unprecedented level of complexity
to the routine recall and remedy process. Given the potential severity
of the harm to vehicle occupants when an inflator rupture occurs and
the wide-spread exposure to the risk across a large vehicle population,
the risk of harm presented by the defective Takata air bag inflators
transcends the scope of the processes ordinarily followed in a recall
under the Safety Act. Accordingly, for the reasons that follow, and
upon consideration of the entire record in this proceeding, NHTSA now
issues this Order.
Factual Background
2. An air bag inflator (``inflator'') is a component inside an air
bag module that contains explosive materials \2\ which, when ignited,
rapidly release gases to inflate air bags that protect vehicle
occupants in vehicle crashes. Because inflators must fit into small and
unique spaces including vehicle steering wheels and front instrument
panels (i.e., dashboards), and because they must also satisfy specific
performance requirements, inflators must meet exacting size and
configuration requirements for each air bag module they are paired with
and each vehicle in which they are installed. When functioning
properly, air bag inflators are life-saving devices.
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\2\ More precisely, air bag inflators contain pyrotechnic
propellants, stored high pressure gases, or a combination of the
two. To aid the reader's understanding, by using more familiar
terminology, this is described herein as an ``explosive.''
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3. The first recall involving a rupturing Takata driver side
frontal air bag inflator was initiated by Honda on November 11, 2008.
At that time, the defect was thought to be the result of a specific
manufacturing issue involving a propellant press at Takata's Moses
Lake, Washington plant. Due to various purported discrepancies in
Takata's record keeping for the affected parts, and changing theories
as to the root cause of the defect, Honda expanded the scope of the
recall several times between 2009 and 2011.
4. The first recall involving a rupturing Takata passenger side
frontal air bag inflator was initiated by Takata on April 11, 2013, and
involved BMW, Honda, Mazda, Nissan, and Toyota. At that time, the
defect was thought by Takata to be the result of two specific
manufacturing issues: (1) The possibility that the auto-reject function
on a propellant press had been manually disabled, and (2) the
possibility that certain propellant lots were exposed to uncontrolled
moisture conditions at Takata's Monclova, Mexico plant. In 2013 and
2014, GM recalled vehicles to address separate manufacturing problems
specific to a limited number of inflators Takata supplied only to GM.
5. Between August 2013 and April 2014, NHTSA received three Vehicle
Owner Questionnaires (VOQs) that alleged air bag inflator ruptures in
vehicles outside the scope of the prior driver side and passenger side
frontal air bag inflator recalls. In late May 2014, Takata confirmed
the three ruptures with NHTSA's Office of Defects Investigation (ODI),
and notified ODI of an additional three ruptures (for a total of six
rupture incidents between August 2013 and May 2014). All of these
ruptures occurred in vehicles experiencing long-term exposure to hot
and humid climate conditions in Florida and Puerto Rico.
6. On June 10, 2014, at NHTSA's urging, Takata and the affected
vehicle manufacturers agreed to initiate various field actions in
Florida, Hawaii, Puerto Rico, and the U.S. Virgin Islands. The data
supporting these field actions indicated that certain Takata frontal
air bag inflators in regions prone to consistent long-term \3\ exposure
to high absolute humidity (``HAH'') and high temperatures posed a
safety risk. The field actions were designed to mitigate the
demonstrated risks in the HAH region, to make inflators available for
future testing, and to produce data to guide future actions.
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\3\ Consistent long-term exposure means multiple years of mostly
continuous exposure throughout the year. It is not seasonal
exposure.
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7. On June 11, 2014, NHTSA opened a preliminary evaluation (PE14-
016) to investigate the six identified rupture incidents involving
driver side and passenger side frontal air bag inflators manufactured
by Takata.
8. During the period of October through December 2014, at NHTSA's
direction, field actions were converted to recalls and the recalls were
expanded, though some recalls remained limited to certain regions with
higher absolute humidity. Also during this period, NHTSA urged Takata
and the affected vehicle manufacturers to, among other things, speed up
the
[[Page 70867]]
remedy programs by increasing the supply of remedy air bag inflators.
NHTSA emphasized the need to promptly and effectively remedy the
serious safety risk posed to consumers by the defective Takata air bag
inflators. Further, as part of its ongoing investigation and oversight,
NHTSA issued two Special Orders to Takata on October 30, and November
18, 2014, a Special Order to Honda on November 5, 2014, and General
Orders to BMW, FCA, Ford, GM, Honda, Mazda, Mitsubishi, Nissan, Subaru,
Toyota, and Takata on November 18, 2014. All these Special and General
Orders were designed and issued by NHTSA to obtain additional data
required to assess and mitigate the risk of harm to the motoring
public.
9. On November 18, 2014, NHTSA demanded that the five vehicle
manufacturers with affected driver side frontal air bag inflators
expand their regional field actions and conduct nationwide actions.
This decision was based on, among other things, NHTSA's evaluation of a
driver side frontal air bag failure in a vehicle outside the existing
regional recall area. In response, beginning in December 2014, BMW,
FCA, Ford, Honda and Mazda initiated national service campaigns or
safety improvement campaigns on vehicles with driver side frontal air
bag inflators.
10. On November 26, 2014, NHTSA demanded that Takata submit Defect
Information Reports (``DIRs'') of driver side frontal air bag
inflators. While Takata declined to do so in a December 2, 2014
response, NHTSA continued to insist that Takata accept responsibility
for the rupturing air bag inflators and file DIRs.
11. On February 24, 2015, NHTSA upgraded PE14-016 to an engineering
analysis (EA15-001).
12. On May 18, 2015, after NHTSA's consistent demands, and pursuant
to its legal obligations under the Safety Act, 49 U.S.C. 30118(c)(1)
and 49 CFR 573.6(c), Takata filed four DIRs with NHTSA (15E-040, 15E-
041, 15E-042, 15E-043) (``Takata DIRs''). In the Takata DIRs, Takata
admitted that certain types of air bag inflators manufactured by Takata
with a phase-stabilized ammonium nitrate-based propellant
(specifically, the PSDI, PSDI-4, PSDI-4K, SPI, PSPI and PSPI-L) contain
defects constituting an unreasonable risk to safety.
13. Between May 13, 2015 and June 24, 2015, BMW, FCA, Daimler
Trucks,\4\ Daimler Vans, Ford, GM, Honda, Mazda, Mitsubishi, Nissan,
Subaru, and Toyota (the ``Initial Vehicle Manufacturers'') each filed
DIRs with NHTSA for vehicles containing the air bag inflators covered
by the Takata DIRs (the ``Inflator Recalls'').
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\4\ Daimler Trucks' remedy program of approximately 2,500
vehicles is being conducted in cooperation with FCA.
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14. As part of the Coordinated Remedy Program Proceeding, launched
on June 5, 2015, NHTSA sought information from each of the Initial
Vehicle Manufacturers, Takata, and other major inflator suppliers \5\
(the ``Suppliers''). As an initial matter, this included gathering data
from the Initial Vehicle Manufacturers, Takata, and the other Suppliers
through correspondence, and a Special Order to Takata, sent on June 18
and 19, 2015.\6\ Thereafter, each of these companies provided answers
responsive to NHTSA's correspondence, which were available in the
public docket.
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\5\ ARC Automotive, Inc. (``ARC''), Autoliv Americas
(``Autoliv''), Key Safety Systems (``Key Safety''), Toyoda Gosei
North America Corporation (``Toyoda''), Daicel Safety Systems
America, LLC (``Daicel''), and TRW Automotive (``TRW'') which has
subsequently become ZF TRW (``ZF TRW'').
\6\ The correspondence sent to Takata and each of the Suppliers
and Initial Vehicle Manufacturers, and their responses, are
available for inspection in public Docket Number NHTSA-2015-0055.
Given NHTSA's ongoing investigation into the defective Takata air
bag inflators under EA15-001, the correspondence sent to Takata was
in the form of a Special Order, with a cover letter. As with the
other industry responses to the correspondence of June 18-19,
Takata's response to the Special Order was made publicly available
as a comment to the Docket.
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15. Among other things, NHTSA engaged in numerous teleconferences
and in-person meetings with the Suppliers to enhance NHTSA's
understanding of, among other things, each Supplier's current
production capacities, capabilities or plans for increasing production,
existing contractual obligations, and product reliability. NHTSA also
engaged in teleconferences and in-person meetings with the Initial
Vehicle Manufacturers to enhance NHTSA's understanding of, among other
things, each Vehicle Manufacturer's anticipated timelines for receipt
of replacement air bag units, anticipated timelines for remedy program
launch and completion, number of impacted vehicles, number of
replacement air bag units needed, and plans and efforts for promptly
conducting recall remedies and effectively reaching consumers.
16. On September 22, 2015, NHTSA gathered supplemental data from
additional vehicle manufacturers that NHTSA had learned were supplied
with Takata air bag inflators containing phase-stabilized ammonium
nitrate (``PSAN'') \7\ not covered by the Takata DIRs (collectively,
the ``Potential Expansion Vehicle Manufacturers''). Thereafter, each of
these companies provided public comments to the docket responsive to
the questions and issues raised in NHTSA's correspondence.
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\7\ Correspondence was sent to Jaguar Land Rover North America,
LLC (``Jaguar''); Mercedes-Benz US, LLC (``Mercedes-Benz''); Spartan
Motors, Inc. (``Spartan''); Suzuki Motor of America, Inc.
(``Suzuki''); Tesla Motors, Inc. (``Tesla''); Volkswagen Group of
America, Inc. (``Volkswagen''); and Volvo Trucks NA (``Volvo''). The
correspondence to each of these vehicle manufacturers, and their
responses, are available for public inspection in public Docket
Number NHTSA-2015-0055.
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17. On September 23 and 24, 2015, NHTSA convened problem-solving
meetings with the Initial Vehicle Manufacturers to examine aggregate
data and engage in a collaborative risk analysis to aid NHTSA in
developing a principled, rational, risk-mitigation based approach for
the prioritization and phasing of recall plans. Factors considered
included those currently associated with a higher risk of inflator
rupture, specifically: age of the inflator (with older inflators
presenting a greater risk); geographic location of vehicles with the
recalled inflators (with HAH areas presenting a greater risk); position
of the inflator in the vehicle (with the driver side frontal air bag
inflator presenting a greater risk of serious injury or death when a
rupture occurs); and the presence of recalled inflators in both the
driver and passenger side airbag modules. During the meetings, the
Initial Vehicle Manufacturers provided input on factors supporting a
technically supported risk-assessment methodology for the Inflator
Recalls. Following the meeting, each Initial Vehicle Manufacturer
submitted a vehicle prioritization list that applied these factors, and
other factors specific to their products, that prioritized vehicles
into three risk categories. NHTSA analyzed these submissions and
determined that the Initial Vehicle Manufacturers generally identified
reasonable and appropriate priority groups based on the evidence known
at this time.
18. Throughout this process, the public has been able to engage in
this dialogue through submissions to the public Docket, NHTSA-2015-
0055. In addition to the actions set forth above, NHTSA reviewed and
considered all public comments to the docket.
19. While Takata is a manufacturer of air bag inflators, other
Suppliers also manufacture inflators, some of which closely match the
performance requirements of the original Takata inflator and thus can
be modified and safely installed in Takata air bag modules for use as
remedy parts for the
[[Page 70868]]
Inflator Recalls. This is significant because Takata alone does not
have sufficient manufacturing capacity to produce remedy inflators for
the Initial Vehicle Manufacturers within an adequate timeframe.
According to Takata, it was capable of manufacturing approximately
85,000 replacement kits per week as of October 30, 2014. Takata's
production capacity increased to 91,000 replacement kits per week by
December 1, 2014, and to 122,000 replacement kits per week by January
26, 2015. By July 2015, Takata reported to NHTSA that, in May 2015, it
had produced approximately 730,000 remedy inflators and 1,167,000
remedy kits, which included inflators obtained from other Suppliers.
Takata further reported that these numbers were expected to reach
850,000 remedy inflators and 1,900,000 remedy kits produced per month,
including inflators obtained from other Suppliers, by October 2015.
Takata also reported that, as of June 2015, it had produced a total of
approximately 8,900,000 replacement inflators. However, this production
is not all directed to the U.S. market; it also serves the global
market requiring replacement air bag inflators. Even at the increased
rate of nearly 850,000 remedy inflators per month by October 2015, if
working alone it would take Takata at least twenty-seven (27) months to
produce enough remedy inflators for the Inflator Recalls, assuming all
of that production went solely to the United States market.
20. Further, some of the Takata driver inflators, sometimes
referred to as containing propellant in the shape of a ``batwing,''
have been used as interim replacement parts that will degrade if
continuously exposed to long-term to HAH conditions, and are themselves
subject to recall. These inflators will not be used as a final remedy
of driver side frontal air bags. Further, Takata's passenger side
frontal air bag inflators subject to the Inflator Recalls have not
previously been recalled for vehicles later than model year 2008.
21. The Initial Vehicle Manufacturers recognized the need to
increase the remedy parts supply in order to have sufficient remedy
parts available. To do so, they were required find alternative
suppliers to meet their demands for remedy air bag inflator parts. The
Initial Vehicle Manufacturers found that necessary alternative supply
source in other inflator suppliers, specifically, Autoliv, Daicel, and
ZF TRW (collectively, the ``Alternative Inflator Suppliers'').
22. According to Takata, in October 2015, the Alternative Inflator
Suppliers were scheduled to provide over 1.9 million remedy inflator
parts per month for installation in remedy air bag kits. This totaled
approximately seventy percent (70%) of the 2.8 million remedy inflator
kits produced by Takata that month for global demand. Nonetheless, the
sheer volume of remedy parts required across the vehicle manufacturing
industry, for both U.S. and foreign markets, has created challenges for
the Initial Vehicle Manufacturers in obtaining sufficient remedy parts
to remedy all of the recalled inflators within a reasonable time.
23. Despite the efforts of each of the Initial Vehicle
Manufacturers to procure remedy parts in a timely fashion, some vehicle
manufacturers will not be able to obtain sufficient remedy parts to
launch their remedy programs, in part or in full, until late 2015 or
early 2016, more than six (6) months after filing their initial DIRs in
regard to the Inflator Recalls.
24. Further, pursuant to a November 3, 2015 Consent Order to Takata
(``November 2015 Takata Consent Order''), additional Takata air bag
inflators not previously subject to a recall may need to be replaced.
This would cause the Potential Expansion Vehicle Manufacturers to join
the existing field of Initial Vehicle Manufacturers (collectively, the
``Vehicle Manufacturers'') in need of remedy air bag inflator parts.
25. Each time Takata air bag inflator recalls are issued under the
November 2015 Takata Consent Order, or current recalls are expanded,
similar challenges will arise for the Vehicle Manufacturers regarding
supply chain and the need for risk-assessments based on principled
rationales that utilize the most-current available science and data.
26. Throughout this sequence of events, Takata has conducted
inflator testing in an effort to determine the ``root cause'' of the
inflator ruptures and, by testing modules recovered from vehicles that
have been remedied, to determine which inflators posed the greatest
risk of rupture. While production issues at Takata manufacturing plants
in Monclova, Mexico and Moses Lake, Washington, were identified early
on as the purported root cause in some rupture incidents, those
theories (even if correct) do not account for the ongoing issues with
inflator rupture. For example, inflators installed in vehicles spending
many consecutive years of their service lives in hot and humid climates
have also ruptured even though they appear to have been manufactured
within Takata's specifications. While Takata now believes that the
ruptures are related to long-term exposure to HAH conditions, their
root cause testing has not produced any conclusive answers regarding
why the inflators rupture.
27. Moreover, Takata has been unable to provide a definitive
explanation for other inflators rupturing, including the rupture of an
SSI-20 side air bag inflator on June 7, 2015, in a Volkswagen vehicle
involved in a crash, or the rupture of a PSDI-X inflator during
Takata's testing of an air bag module on September 29, 2015 with a
resulting recall by Honda. Takata has also been unable to definitively
explain the October 2015, rupture of an SSI-20 inflator during Takata
quality control testing. It therefore appears to the agency that Takata
continues to have ongoing quality control issues with the volatile,
explosive compound it has chosen as the propellant for most of its air
bag inflators: PSAN.
28. While the ultimate responsibility for determining root cause
rests squarely with Takata, testing has also been conducted by NHTSA
and third parties in an effort to establish the root cause of the
defect and to verify the results of Takata's testing of inflators
returned from the field. NHTSA has conducted testing through Battelle
Memorial Institute, 3D Engineering Solutions, and the Transportation
Research Center of Ohio, testing organizations located in Ohio, to
verify Takata's test results and examine the root cause of the defect.
Testing has also been undertaken by the Independent Testing Coalition
(``ITC''), which is comprised of BMW, FCA, Ford, GM, Honda, Mazda,
Mitsubishi, Nissan, Subaru, and Toyota. Orbital ATK, a testing company
located in Utah, has commenced testing on behalf of the ITC, and hopes
to conclude root cause analysis in 2016. Multiple individual vehicle
manufacturers have also conducted testing in efforts to confirm
Takata's results or establish root cause for the defect. While this
multitude of independent testing efforts have largely confirmed the
observations made and patterns identified from Takata's test results,
none of these efforts has identified any specific root cause(s) for the
propellant failures and inflator ruptures. While progress is being
made, it is unknown when, or if, root cause will ever be definitively
determined.
29. Without a conclusive determination of root cause, the source of
the problems with certain Takata inflators remains unknown. What is
known, however, is that the propellant in inflators covered by the
Inflator Recalls and the recalls within the scope of this Order have,
at various rates of frequency, a propensity to ignite and/or
[[Page 70869]]
burn in an unexpected way that may cause the pressure inside the
inflator to increase too quickly, causing the inflator to rupture. That
rupture causes the metal canister of the inflator to break away in hot,
shrapnel-like fragments, which shoot out of the air bag into the
passenger cabin and towards the driver or any occupants who are nearby.
30. As of October 30, 2015, there have been 99 confirmed incidents
in the United States where a ruptured Takata air bag inflator allegedly
caused death or injury. Many of these incidents resulted in serious
injury to vehicle occupants. In seven of the incidents, the vehicle's
driver died as a result of injuries sustained from the rupture of the
air bag inflator. In other incidents, vehicle occupants suffered
injuries including cuts or lacerations to the face or neck, broken or
fractured facial bones, loss of eyesight, and broken teeth. The risk of
these tragic consequences is greatest for individuals sitting in the
driver seat, where one in ten individuals' whose air bag inflator
ruptured has died.
Findings
Based upon the agency's analysis and judgment, and upon
consideration of the entire record, NHTSA finds that:
31. (1) There is a risk of serious injury or death if the remedy
program of each of the Initial Vehicle Manufacturers is not
accelerated; (2) acceleration of each Initial Vehicle Manufacturer's
remedy program can be reasonably achieved by expanding the sources of
replacement parts; and (3) each Initial Vehicle Manufacturer's remedy
program is not likely to be capable of completion within a reasonable
time without acceleration.
32. Each air bag inflator with the capacity to rupture, as the
recalled Takata inflators do, presents an unreasonable risk of serious
injury or death. Seven individuals have already been killed in the
United States alone, with at least 92 more injured. Since the
propensity for rupture increases with the age of the inflator, and
increases even more when the vehicle has been exposed to consistent
long-term HAH conditions, the risk for injurious or lethal rupture
increases with each passing day. While each of the Initial Vehicle
Manufacturers has made efforts towards the remedy of these defective
air bag inflators, acceleration and coordination of the inflator remedy
programs is necessary to reduce this risk to public safety.
Acceleration and coordination will enable vehicle manufacturers to
establish priorities based on principled rationales for risk-
assessment, coordinate on safety-focused efforts to successfully
complete their respective remedy programs, and allow for the
organization and prioritization of remedy parts, if and as needed, with
NHTSA's oversight.
33. Acceleration of the inflator remedy programs can be reasonably
achieved by, among other things, expanding the sources of replacement
parts. This acceleration can be accomplished in part by a vehicle
manufacturer contracting with any of the Alternative Inflator Suppliers
for remedy parts as Takata cannot manufacture sufficient remedy parts
in a reasonable time for the estimated 23 million inflators in the U.S.
market alone that require remedy under the Inflator Recalls.
34. In light of all the circumstances, including the safety risk
discussed above, the Initial Vehicle Manufacturers' recall remedy
programs are not likely capable of completion within a reasonable
amount of time without acceleration of each remedy program. It is
critical to the timely completion of each remedy program that the
Initial Vehicle Manufacturers obtain remedy inflators from sources
other than Takata. Takata's inflator production for October 2015 will
make up only around thirty percent (30%) of the remedy inflators
produced that month. Further, Takata's ability to supply remedy parts
going forward may decrease, such that other Suppliers will need to fill
the resulting void.
35. Pursuant to the conditions for expansion of the recalls in the
Takata DIRs for Recall Nos. 15E-042 and 15E-043, Paragraphs 27-30 of
the November 2015 Takata Consent Order, and as otherwise agreed by
Takata, and after consultation throughout this Coordinated Remedy
Program Proceeding with Takata and all of the vehicle manufacturers
affected by said Recalls, NHTSA further finds that continued testing
and analysis of Takata air bag inflators is necessary. If circumstances
warrant the issuance of an Order expanding the production or geographic
scope of the Inflator Recalls, the agency will do so in accordance with
the November 2015 Takata Consent Order.
36. The issuance of this Coordinated Remedy Order is an appropriate
exercise of NHTSA's authority under the Safety Act, 49 U.S.C. Sec.
30101, et seq., as delegated by the Secretary of Transportation, 49 CFR
Sec. Sec. 1.95, 501.2(a)(1), to inspect and investigate, 49 U.S.C.
Sec. 30166(b)(1), to ensure that defective vehicles and equipment are
recalled and remedied and that owners are notified of a defect and how
to have the defect remedied, 49 U.S.C. Sec. Sec. 30118-30120, to
ensure the adequacy of the remedy, including through acceleration of
the remedy program, 49 U.S.C. Sec. 30120(c), to require vehicle
manufacturers and equipment manufacturers to keep records and make
reports, 49 U.S.C. Sec. 30166(e), and to require any person to file
reports or answers to specific questions, 49 U.S.C. Sec. 30166(g).
37. This Coordinated Remedy Order, developed after taking into
account the input and concerns of each of the Vehicle Manufacturers,
Suppliers, Takata, other interested parties and the public, will reduce
the risk of serious injury or death to the motoring public and enable
the Initial Vehicle Manufacturers and Takata to implement, and
complete, the necessary remedy programs on an accelerated basis.
Accordingly, it is hereby ordered by NHTSA as follows:
II. Terms of the Coordinated Remedy Order
Priority Groups and Target Recall Program Completion Deadlines for the
Coordinated Remedy Program
38. Each Initial Vehicle Manufacturer has previously submitted to
NHTSA a vehicle prioritization plan based on a risk-assessment that
takes into account the primary factors related to Takata inflator
rupture, as currently known and understood, and other factors specific
to that vehicle manufacturer's products. The primary factors utilized
by all of the Initial Vehicle Manufacturers are: (1) Age of the
inflator (with older presenting a greater risk of rupture); (2)
geographic location of the inflator (with continuous long-term exposure
to high absolute humidity [``HAH''] areas,\8\ as defined by each
vehicle manufacturer, presenting a greater risk of rupture); and (3)
location of the Takata inflator in the vehicle (with both driver side
and passenger side frontal air bag inflators in the same vehicle
presenting the greatest risk of rupture,\9\ and driver side only
[[Page 70870]]
presenting an elevated risk of rupture, resulting in serious injury or
death). In order to timely and adequately complete its remedy program,
each Initial Vehicle Manufacturer shall, pursuant to 49 U.S.C.
30120(a)(1) and (c), carry out its remedy program in accordance with
its prioritization plan as submitted to NHTSA. A complete listing of
the vehicles in each priority group (``Priority Group'') developed
using the above risk factors is attached hereto as Annex A,\10\ and is
hereby incorporated by reference as if fully set forth herein. The
Priority Groups are as follows:
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\8\ Each vehicle manufacturer has defined an HAH region for its
vehicle prioritization and recall remedy program, resulting in
slight variations as to which states and territories are included in
the HAH area. However, all of the prioritizations include in the HAH
area vehicles that were originally sold, or ever registered, in
Alabama, Florida, Georgia, Hawaii, Louisiana, Mississippi, Texas,
Puerto Rico, American Samoa, Guam, Saipan, and the U.S. Virgin
Islands. None of the slight variations impact the risk mitigation
established through this Order.
\9\ All recalled Takata inflators have previously been
determined to pose an unreasonable risk of death or serious injury
in a crash, as established in the filing of each of the many DIRs
for the recalled inflators. Comparative statements of risk in the
priority groups are provided to explain relative risk among the
inflators, all of which pose an unreasonable risk of death or
serious injury in a crash.
\10\ Because information about the risk factors may change
throughout this Coordinated Remedy Program, these prioritizations
are subject to change by a vehicle manufacturer, with NHTSA's
oversight of the recall program including vehicle prioritization.
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a. Priority Group 1
Vehicles in Priority Group 1 are equipped with Takata inflators
that pose the highest risk of rupture and thus the highest risk of
injury or death to the vehicle occupants. Generally, Priority Group 1
vehicles are currently model year 2008 and earlier, and have spent time
\11\ in the HAH region, and have either a recalled driver side inflator
or both recalled driver side and passenger side inflators in the same
vehicle.
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\11\ While continuous long-term exposure to HAH is an identified
risk factor, the Priority Groups take this into account by including
in the risk-assessment vehicles originally sold or ever registered
in the HAH region. Vehicle manufacturers are able to obtain
registration information and have used that data in formulating
their risk-assessment based Priority Groups.
---------------------------------------------------------------------------
b. Priority Group 2
Vehicles in Priority Group 2 are equipped with Takata inflators
that pose an intermediate risk of rupture; that is, a lower risk of
rupture and resulting injury or death to vehicle occupants than the
inflators and vehicles in Priority Group 1, but a higher likelihood of
rupture and injury or death than vehicles in Priority Groups 3 and 4.
Generally, Priority Group 2 includes: (1) All remaining vehicles with
recalled driver side inflators (this includes, vehicles 2009 and newer,
and/or vehicles with recalled driver inflators only that have not spent
time in the HAH region), and; (2) vehicles with certain recalled
passenger inflator types that have a higher rupture frequency and that
have also spent time in the HAH region.
c. Priority Group 3
Vehicles in Priority Group 3 are equipped with Takata inflators
that pose an unreasonable risk of serious injury or death to vehicle
occupants and should be remedied as soon as possible following the
remedy of the highest risk vehicles in Priority Groups 1 and 2. The
likelihood of these inflators rupturing is lower than Priority Groups 1
and 2. Generally, Priority Group 3 includes the remaining vehicles,
specifically, vehicles that are model year 2009 and later and either:
(1) Are outside the HAH region and contain only a passenger side
inflator, or; (2) are in the HAH region and contain a specific
passenger side inflator type with a lower rupture rate (the PSPI type)
than other passenger side inflator types.
d. Priority Group 4
Some Initial Vehicle Manufacturers are replacing recalled inflators
with newly manufactured ``like-for-like'' inflators while they work
towards an alternative, final remedy. Vehicles in Priority Group 4
include those vehicles with driver side frontal air bag inflators that
have received, or will receive, an ``interim remedy,'' meaning they
have been, or will be, remedied with a Takata inflator that has been
recalled, and will require a second remedy once the final remedy is
available.\12\ Once repaired with the interim remedy, these vehicles
are at the lowest risk of an inflator rupture because the inflator is
new and has not yet been subject to long-term continuous exposure to
HAH conditions. Unless specifically added at a later date to a higher
Priority Group for re-remedy by their vehicle manufacturer, all
remaining vehicles requiring a second, final, remedy of the inflator(s)
are included in Priority Group 4.
---------------------------------------------------------------------------
\12\ NHTSA has entered into Remedy Agreements with BMW and
Mazda, which can be found in the investigation file for EA15-001 on
www.safercar.gov.
---------------------------------------------------------------------------
39. Pursuant to their obligations to remedy a defect within a
reasonable time, as set forth in 49 U.S.C. Sec. 30120(a)(1) and Sec.
30120(c)(2), each Initial Vehicle Manufacturer shall acquire a
sufficient supply of remedy parts to enable it to provide remedy parts,
in a manner consistent with customary business practices, upon demand
to dealers within their dealer network by the timelines set forth in
this Paragraph. Each Initial Vehicle Manufacturer shall ensure that it
has a sufficient supply of remedy parts on the following schedule:
------------------------------------------------------------------------
Priority group Sufficient supply timelines
------------------------------------------------------------------------
Priority Group 1.......................... March 31, 2016.
Priority Group 2.......................... September 30, 2016.
Priority Group 3.......................... December 31, 2016.
------------------------------------------------------------------------
40. Further pursuant to their obligations to remedy a defect within
a reasonable time, as set forth in 49 U.S.C. Sec. 30120(a)(1) and
Sec. 30120(c)(2), each Initial Vehicle Manufacturer shall implement
and execute its recall remedy program pursuant to the Safety Act with
the target deadline to complete the recall remedy program for all
vehicles in Priority Groups 1 through 3 of December 31, 2017, and a
target deadline to remedy all vehicles in Priority Group 4 of December
31, 2019, as shown below:
------------------------------------------------------------------------
Remedy completion target
Priority group deadline
------------------------------------------------------------------------
Priority Group 1.......................... December 31, 2017.
Priority Group 2.......................... December 31, 2017.
Priority Group 3.......................... December 31, 2017.
Priority Group 4.......................... December 31, 2019.
------------------------------------------------------------------------
Remedy Completion Maximization Efforts
41. Pursuant to 49 U.S.C. 30166(e), within 90 days of this Order, a
vehicle manufacturer recalling inflators subject to this Order shall
provide to NHTSA and the Monitor (as set forth at Paragraph 44 below),
a written recall engagement process or plan for maximizing remedy
completion rates for all vehicles covered by the Inflator Recalls. Such
a process or plan shall, at a minimum, include but not be limited to
the methodology and techniques presented at the Retooling Recalls
Workshop \13\ held by NHTSA on April 28, 2015, at the U.S. Department
of Transportation Headquarters.
---------------------------------------------------------------------------
\13\ Each of the Initial Vehicle Manufacturers, other than
Daimler Vans, registered to attend this Workshop. Presentations from
the Workshop are available at: http://www.nhtsa.gov/nhtsa/symposiums/april2015/index.html#.
---------------------------------------------------------------------------
42. Pursuant to 49 U.S.C. 30166(e), a vehicle manufacturer
recalling inflators subject to this Order shall, upon request, provide
to NHTSA and the Monitor any and all information demonstrating the
reasonableness of the efforts made by that vehicle manufacturer to
maximize remedy completion rates.
43. The facts relating to supply, demand, and root cause may change
during this Coordinated Remedy Program. Pursuant to Paragraph 32 of the
November 2015 Takata Consent Order, Takata shall continue to cooperate
with NHTSA in all ways to coordinate and accelerate remedy programs,
and to adequately remedy the air bag inflators covered by the Inflator
Recalls.
Monitor
44. Pursuant to Paragraphs 35 through 46 of the November 2015
Takata
[[Page 70871]]
Consent Order, Takata has agreed to retain, at its sole cost and
expense, an independent monitor (the ``Monitor''). The Monitor's
authority includes, among other things, certain monitoring, review and
assessment of progress of the Coordinated Remedy Program and of
compliance with this Order. The powers, rights and responsibilities of
the Monitor are set forth more fully in the November 2015 Takata
Consent Order, which are hereby incorporated by reference as if fully
set forth herein.
a. The Monitor shall have the authority to take such reasonable
steps, in the Monitor's view, as are necessary to be fully informed
about the operations of the Coordinated Remedy Program and this Order.
b. It is expected that the Monitor will develop and implement
written procedures and may make additional recommendations aimed at
enhancing the Coordinated Remedy Program and ensuring that all
Coordinated Remedy Program deadlines, including those in this Order,
are met.
c. The Monitor is not intended to supplant NHTSA's authority over
decisions related to the Coordinated Remedy Program, this Order, motor
vehicle safety, or otherwise. If the Monitor identifies a problem or
issue, the Monitor shall make appropriate recommendations to NHTSA and
provide all supporting information, including information contrary to
the Monitor's recommendation, to enable NHTSA to make an informed
decision on that recommendation.
d. Takata and Vehicle Manufacturers, along with all of their
respective officers, directors, employees, agents, and consultants,
shall have an affirmative duty to cooperate with and assist the Monitor
in connection with the Coordinated Remedy Program and this Order.
Potential Future Recalls
45. The provisions of the November 2015 Takata Consent Order
regarding future recalls and possible future recalls, contained at
Paragraphs 29-30 of that document, are hereby incorporated by reference
into this Order. Accordingly, any future recall(s) of Takata inflators
pursuant to, or contemplated by, Paragraphs 29-30 of that Order shall
become part of the Coordinated Remedy Program established herein.
46. Upon Takata's filing of a DIR pursuant to 49 CFR Sec. 573, the
affected vehicle manufacturer(s) shall timely file a DIR. Upon the
filing of such DIRs NHTSA may, pursuant to 49 U.S.C. Sec. Sec. 30118-
30119, 49 U.S.C. Sec. 30120(c), 49 CFR Sec. 573.14, and 49 U.S.C.
Sec. 30166(b), (c), and (e), convene a meeting with the affected
vehicle manufacturers to take place within forty-five (45) days of
Takata's DIR filing, at an appropriate location within the United
States, as determined by NHTSA, to address issues related to the
Coordinated Remedy Program including, but not limited to, establishing
a risk-assessment framework for the prioritization of vehicles and/or
phasing of remedy programs, as appropriate. Any such prioritizations
shall be made publicly available, and shall be annexed to this Order,
in a format similar to the Priority Group lists in Annex A of this
Order.
Record Keeping & Reports
47. Pursuant to 49 U.S.C. Sec. 30166(b), (c), (e), and (g), in
carrying out any recall remedy program covered by this Order, each
affected vehicle manufacturer and Takata shall make any report, submit
any information, and accommodate any inspection and/or investigation,
as requested by NHTSA or the Monitor.
Miscellaneous
48. NHTSA may, after consultation with affected vehicle
manufacturers, and/or Takata, or upon a recommendation of the Monitor,
modify or amend provisions of this Order to, among other things:
account for and timely respond to newly obtained facts, scientific
data, changed circumstances, and/or other relevant information that may
become available throughout the term of the Coordinated Remedy Program.
This includes but is not limited to, changes to the Priority Groups
contained in Annex A; allowing for reasonable extensions of time for
the timelines contained in Paragraphs 39 and 40; facilitating further
recalls as contemplated by Paragraphs 45 and 46; or for any other
purpose arising under, or in connection with, the Coordinated Remedy
Program and/or this Coordinated Remedy Order.
49. This Coordinated Remedy Order shall become effective upon
issuance by the NHTSA Administrator. In the event of a breach of, or
failure to perform, any term of this Order by Takata or any vehicle
manufacturer, NHTSA may pursue any and all appropriate remedies,
including, but not limited to, actions compelling specific performance
of the terms of this Order, and/or commencing litigation to enforce
this Order in any United States District Court.
50. This Coordinated Remedy Order shall not be construed to create
rights in, or grant any cause of action to, any third party not subject
to this Order.
51. In carrying out the directives of this Coordinated Remedy
Order, vehicle manufacturers and vehicle equipment manufacturers (i.e.
suppliers) shall not engage in any conduct prohibited under the
antitrust laws, or other applicable law.
It is so ordered:
NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION, U.S. DEPARTMENT OF
TRANSPORTATION
Dated: November 3, 2015.
Mark R. Rosekind,
Administrator.
ANNEX A
Coordinated Remedy Program Priority Groups
In the Priority Groups listed below, the area of high absolute
humidity (``HAH'') is defined by each vehicle manufacturer
individually, but in all instances includes vehicles originally sold or
ever registered in Alabama, Florida, Georgia, Hawaii, Louisiana,
Mississippi, Texas, Puerto Rico, American Samoa, Guam, Saipan, and the
U.S. Virgin Islands. In limited instances, parts for some HAH recalls
are currently only available to a limited area within the HAH with the
highest risk of rupture. ``Non-HAH'' means any vehicle that has not
been identified by the vehicle manufacturer as having been originally
sold or ever registered in the HAH region, as defined by the vehicle
manufacturer.
------------------------------------------------------------------------
------------------------------------------------------------------------
PRIORITY GROUP 1
------------------------------------------------------------------------
BMW:
2002-2006................. BMW.............. 3 Series, M3 (HAH)
Daimler Vans USA:
2007-2008................. Freightliner..... Sprinter (HAH)
2007-2008................. Dodge............ Sprinter (HAH)
Daimler Truck North America-
DTNA:
[[Page 70872]]
2008-2009................. Sterling......... Bullet (HAH and non-
HAH)
FCA:
2006-2008................. Chrysler......... 300, 300C, SRT8 (HAH)
2005...................... Chrysler......... 300, 300C, SRT8 (HAH
and non-HAH)
2008...................... Dodge............ Challenger (HAH)
2006-2008................. Dodge............ Charger (HAH)
2005...................... Dodge............ Dakota (HAH)
2004-2005................. Dodge............ Durango (HAH)
2006-2008................. Dodge............ Magnum (HAH)
2005...................... Dodge............ Magnum (HAH and non-
HAH)
2004-2005................. Dodge............ Ram 1500, 2500, 3500
Pickup (HAH)
Ford:
2005-2006................. Ford............. GT (HAH)
2005-2008................. Ford............. Mustang (HAH)
2004-2005................. Ford............. Ranger (HAH)
GM:
2003-2007................. Pontiac.......... Vibe (HAH)
2005...................... GM-Saab.......... 9-2X (HAH)
------------------------------------------------------------------------
Priority Group 1 continued . . .
Priority Group 1 continued from prior page . . .
------------------------------------------------------------------------
Honda:
2003...................... Acura............ 3.2CL (HAH and non-
HAH)
2002-2003................. Acura............ 3.2TL (HAH and non-
HAH)
2001-2003................. Honda............ Accord (HAH and non-
HAH)
2001-2003................. Honda............ Civic (HAH and non-
HAH)
2004-2005................. Honda............ Civic (HAH)
2003-2005................. Honda............ Civic IMA-Hybrid
(HAH)
2003...................... Honda............ Civic IMA-Hybrid (non-
HAH)
2002...................... Honda............ CR-V (HAH and non-
HAH)
2003-2004................. Honda............ CR-V (HAH)
2003-2006................. Honda............ Element (HAH)
2002...................... Honda............ Odyssey (HAH)
2003...................... Honda............ Pilot (HAH and non-
HAH)
2004-2005................. Honda............ Pilot (HAH)
2006...................... Honda............ Ridgeline (HAH)
Mazda:
2003-2008................. Mazda............ Mazda6 (HAH)
2004-2008................. Mazda............ RX8 (HAH)
2006-2007................. Mazda............ Speed6 (HAH)
Mitsubishi:
2004-2006................. Mitsubishi....... Lancer and Lancer
Evolution (HAH)
2004...................... Mitsubishi....... Lancer Sportback
(HAH)
2006-2009................. Mitsubishi....... Raider (HAH)
Nissan:
2002-2003................. Infiniti......... QX4 (HAH)
2002-2004................. Nissan........... Pathfinder (HAH)
2002-2004................. Nissan........... Sentra (HAH)
Subaru:
2004-2005................. Subaru........... Impreza/WRX/STI (HAH)
2005...................... Subaru........... Legacy, Outback (HAH)
Toyota:
2007...................... Lexus............ SC430 (HAH)
2003-2007................. Toyota........... Corolla (HAH)
2003-2007................. Toyota........... Matrix (HAH)
2005-2007................. Toyota........... Sequoia (HAH)
2003-2004................. Toyota........... Tundra (HAH)
2005-2006................. Toyota........... Tundra (non-HAH)
------------------------------------------------------------------------
PRIORITY GROUP 2
------------------------------------------------------------------------
BMW:
2000-2001................. BMW.............. 3 Series (HAH)
2002-2006................. BMW.............. 3 Series (non-HAH)
2002-2003................. BMW.............. 5 Series (HAH and non-
HAH)
2003-2004................. BMW.............. X5 SUV (HAH and non-
HAH)
Daimler Vans USA:
2007-2008................. Freightliner..... Sprinter (non-HAH)
FCA:
2006-2008................. Chrysler......... 300, 300C, SRT8 (non-
HAH)
2009-2010................. Chrysler......... 300, 300C, SRT8 (HAH
and non-HAH)
2005...................... Chrysler......... 300, 300C, SRT8 (HAH)
2007-2008................. Dodge............ Aspen (HAH and non-
HAH)
2008...................... Dodge............ Challenger (non-HAH)
2009-2010................. Dodge............ Challenger (HAH)
[[Page 70873]]
2006-2008................. Dodge............ Charger (non-HAH)
2009-2010................. Dodge............ Charger (HAH and non-
HAH)
2005-2011................. Dodge............ Dakota (HAH and non-
HAH)
2004-2008................. Dodge............ Durango (HAH and non-
HAH)
2005...................... Dodge............ Magnum (HAH)
2006-2008................. Dodge............ Magnum (non-HAH)
2004-2005................. Dodge............ Ram 1500 Pickup (HAH)
2003...................... Dodge............ Ram 1500, 2500, 3500
Pickup (HAH and non-
HAH)
2006-2009................. Dodge............ Ram 1500, 2500, 3500
Pickup (HAH and non-
HAH)
2006...................... Dodge............ Ram 2500 (HAH)
2007-2008................. Dodge............ Ram 3500 Cab Chassis
(HAH and non-HAH)
2008-2010................. Dodge............ Ram 4500, 5500 Cab
Chassis (HAH and non-
HAH)
2007-2008................. Dodge............ Sprinter (non-HAH)
Ford:
2005-2006................. Ford............. GT (HAH)
2005-2008................. Ford............. Mustang (non-HAH)
2009-2014................. Ford............. Mustang (HAH)
2006...................... Ford............. Ranger (HAH)
GM:
2003-2007................. Pontiac.......... Vibe (non-HAH)
2007-2008................. Chev/GMC......... Silverado/Sierra
(HAH)
------------------------------------------------------------------------
Priority Group 2 continued . . .
Priority Group 2 continued from prior page . . .
------------------------------------------------------------------------
Honda:
2003-2006................. Acura............ MDX (HAH and non-HAH)
2004-2007................. Honda............ Accord (HAH and non-
HAH)
2004-2005................. Honda............ Civic (non-HAH)
2004-2005................. Honda............ Civic Hybrid (non-
HAH)
2005-2006................. Honda............ CR-V (HAH)
2003-2006................. Honda............ CR-V (non-HAH)
2007-2011................. Honda............ Element (HAH)
2003-2007................. Honda............ Element (non-HAH)
2003-2004................. Honda............ Odyssey (HAH)
2002-2004................. Honda............ Odyssey (non-HAH)
2006-2008................. Honda............ Pilot (HAH)
2004-2007................. Honda............ Pilot (non-HAH)
2006...................... Honda............ Ridgeline (non-HAH)
Mazda:
2003-2008................. Mazda............ Mazda6 (non-HAH)
2004-2006................. Mazda............ B-Series (HAH)
2004-2005................. Mazda............ MPV (HAH)
2004-2008................. Mazda............ RX8 (non-HAH)
2006-2007................. Mazda............ Speed6 (HAH)
Mitsubishi:
2004-2006................. Mitsubishi....... Lancer, Lancer
Evolution (non-HAH)
2004...................... Mitsubishi....... Lancer Sportback (non-
HAH)
2006-2009................. Mitsubishi....... Raider (non-HAH)
Nissan:
2003...................... Infiniti......... FX (HAH)
2001...................... Infiniti......... I30 (HAH)
2002-2003................. Infiniti......... I35 (HAH)
2002-2003................. Infiniti......... QX4 (non-HAH)
2001-2003................. Nissan........... Maxima (HAH)
2002-2004................. Nissan........... Pathfinder (HAH and
non-HAH)
2004-2006................. Nissan........... Sentra (HAH and non-
HAH)
Subaru:
2003-2005................. Subaru........... Legacy, Outback, Baja
(HAH)
------------------------------------------------------------------------
Priority Group 2 continued . . .
Priority Group 2 continued from prior page . . .
------------------------------------------------------------------------
Toyota:
2007...................... Lexus............ SC430 (non-HAH)
2003-2007................. Toyota........... Corolla (non-HAH)
2003-2007................. Toyota........... Matrix (non-HAH)
2004-2005................. Toyota........... RAV4 (HAH and non-
HAH)
2002-2004................. Toyota........... Sequoia (HAH)
2005-2007................. Toyota........... Sequoia (non-HAH)
2003-2004................. Toyota........... Tundra (HAH)
2005-2006................. Toyota........... Tundra (non-HAH)
------------------------------------------------------------------------
PRIORITY GROUP 3
------------------------------------------------------------------------
BMW:
2000-2001................. BMW.............. 3 Series (non-HAH)
[[Page 70874]]
Daimler Vans USA:
2007-2008................. Freightliner..... Sprinter (non-HAH)
2007-2008................. Dodge............ Sprinter (non-HAH)
Ford:
2005-2006................. Ford............. GT (non-HAH)
2009-2014................. Ford............. Mustang (non-HAH)
2004-2006................. Ford............. Ranger (non-HAH)
GM:
2007-2008................. Chev/GMC......... Silverado/Sierra (non-
HAH)
2005...................... GM-Saab.......... 9-2X (non-HAH)
Honda:
2005...................... Honda............ RL (HAH and non-HAH)
2008-2011................. Honda............ Element (non-HAH)
2008...................... Honda............ Pilot (non-HAH)
Mazda:
2004-2006................. Mazda............ B-Series (non-HAH)
Nissan:
2003...................... Infiniti......... FX (non-HAH)
2004-2005................. Infiniti......... FX (HAH and non-HAH)
2001...................... Infiniti......... I30 (non-HAH)
2002-2004................. Infiniti......... I35 (HAH and non-HAH)
2006...................... Infiniti......... M (HAH and non-HAH)
2001-2003................. Nissan........... Maxima (non-HAH)
Subaru:
2004-2005................. Subaru........... Impreza/WRX/STI (non-
HAH)
2003-2004................. Subaru........... Legacy, Outback, Baja
(non-HAH)
Toyota:
2002-2006................. Lexus............ SC430 (HAH and non-
HAH)
2002-2004................. Toyota........... Sequoia (non-HAH)
2003-2004................. Toyota........... Tundra (non-HAH)
------------------------------------------------------------------------
[FR Doc. 2015-28924 Filed 11-13-15; 8:45 am]
BILLING CODE 4910-59-P