The Driver !

1. The Driver !

2. Office of Defects Investigation NHTSANational Highway Traffic Safety Administration Presentation

3. Sonny Murianka Richard Boyd Acting Director Office of Defects Investigation US DOT NHTSA 202-366-4933 Richard.boyd@dot.gov

4. Today’s Topics • Office of Defects Investigation (ODI) Who we are • Legal Authority • How we conduct business • ODI Investigations • Questions and Answers

5. ODIMission • Identify defects that relate to motor vehicle safety • Assure that defects are remedied effectively and promptly

7. What is a safety related defect ?

8. REMEDIES FOR SAFETY DEFECTS AND NONCOMPLIANCE • (A) VEHICLES • REPAIR THE VEHICLE FREE OF CHARGE • REPLACE THE VEHICLE WITH AN INDENTICAL OR REASONABLY EQUIVALENT VEHICLE, OR • REFUND THE PURCHASE PRICE, LESS ALLOWANCE FOR DEPRECIATION • (B) if item of EQUIPMENT--- • BY REPAIRING FREE OF CHARGE OR REPLACING

9. Defect ??

10. ENFORCEMENTOFFICE OF DEFECTS INVESTIGATION

11. U.S. Registered Vehicles: 248 Million • Complaints: 47,000 per year, Hotline VOQ, EVOQ, Letters, Internet • New Issues Screened: 200 • Investigations: 140 • ODI Influenced Vehicle Defect Recalls: 101 • ODI Influenced Vehicles Recalled: 12 Million

12. ODI Web Page Use • SaferCar.gov • SaferCar.gov (crash test info) • Complaints • Investigations • Recalls • Technical Service Bulletins (TSB) • Down Loads Search Results Defect Documents

15. ODI PROCESS • Investigation Process Three Primary Parts • Defect Assessment – Screening (constant) • Preliminary Evaluation (120 days) • Engineering Analysis (365 days)

16. Screening (Initial Evaluation) • Assemble & review complaints • Understand the safety consequence & trend • Interview & verify complaints • Conduct field inspections • Make peer vehicle comparison • Review current & past activity on similar vehicles • Early Warning Information • Initial Evaluation package prepared that summarizes all information identified • Present findings/package to a panel recommending opening an investigation

17. INVESTIGATION PROCESS Preliminary Evaluation • Send Information “Request” (IR) Letter with 6 week deadline • Evaluate Response from manufacturer • Contact other fleets in our “fleet network” • Interview owners, fleet managers, examine vehicles in field – • Compile information: number of complaints, warranty, average mileage and vehicle age at failure, time in service, maintenance related, part wear out? • Decision – Close, Voluntary Recall, or Upgrade to Engineering Analysis (120 days to complete)

18. Defect Investigations Information Request • Complaints, field reports, claims, lawsuits • Production data • Warranty claims • Mfr field communications (e.g., bulletins) • Mfr “studies, surveys, investigations” • Design/process changes • Sample parts (exemplar, warranty returns) • Part Sales • Mfr assessment – frequency & safety risk

19. Engineering Analysis • Send Information Request (IR) Letter (7 week response) • Extensive Testing of Complaint Vehicles (lease or purchase) • Conduct Fleet and State Surveys • Inspect Vehicles as new complaints come in • 2nd IR to MFR, Peer IR Letters • Evaluate and Analyze • Informal Communication and technical meetings with the Manufacturer • Decision – Close, Voluntary Recall, or recommend that we “request” the manufacturer to conduct a safety recall

20. Case # 1 Emergency Door Handles ODI was contacted by a local Maryland school bus fleet which reported they had emergency door handles suffering internal corrosion and failing when an attempt was made to open the door

21. Case # 1 Emergency door Handlefails • An Initial Evaluation was started • ODI visited the fleet and examined over a dozen buses • Handles were removed and examined for internal corrosion • Other fleets were visited and their door handles were examined and evidence of corrosion was observed • Internal briefings were quickly held and it was agreed that the problem presented an unreasonable risk given that in the event of an emergency evacuation, a door handle braking off was unacceptable • ODI opened a Preliminary Evaluation (PE07-054) on November 9, 2007

22. Emergency Door handles break off

23. Case # 1 – Emergency Door Handle Fails • Manufacturer was immediately contacted by phone and informed of our concerns; • Within a week the manufacturer flew in a field engineer and together with ODI’s engineer they visited several fleets and examined door handles. Several were taken back for metallurgical examination. • Manufacturer was asked to determine appropriate model and model year of buses using the emergency door handle of concern; • An information request was prepared for mailing; • Additional fleets were visited and more door handles examined;

24. Emergency Door handles break off • Manufacturer reported ……. • Suspect population was identified as “buses manufactured between Jan 1994 and March 10, 2008” • Fleets were examined having buses “outside” suspect population to ensure appropriate vehicles were targeted • On Feb 21, 2008, the Manufacturer announced a recall (08V-087) to replace all handles on Jan 1994 through March 2008 buses, a population of 243,435 buses; • It was determined the handles were corroding around the securing roll pin and square drive mechanism causing the finish to chip and flake. This allowed accelerated corrosion and the handle became weaker and ultimately would fail (break off during attempted door opening) • Handles will be replaced with a more robust, corrosion resistant design • ODI closed the investigation March 4, 2008.

25. Case # 2 Engine compartment fire • On January 14, 2008, ODI was contacted by a local Maryland school bus fleet which reported they had suffered a “minor” engine compartment fire. An Initial Evaluation was immediately opened. • ODI visited the fleet and examined several buses and observed alternator cables rubbing on the fuel line return hose. It was determined that some models did not have the same cable routing and therefore many more vehicles were examined in an effort to understand differences between buses. • Over several months other fleets were visited and ODI observed a “field fix” that some fleet mechanics had incorporated. ODI also observed that only certain engine combinations had the problem.

26. Case # 2Fuel hose vs. Electric cables

27. Exemplar bus

28. Hose to Cable Contact

29. Wire beading

30. Safety Recall Announced • After additional field work, a recall was conducted in July 2008 - (08V-356) • 3,240 1996-2002 MVP-ER (Rear Engine) built with a Caterpillar 3116 and 3126 engine • Remedy - Cables will be inspected and replaced if necessary • Alternator power cables will be separated from fuel return hose. • Power cables will be secured.

31. Defect Report (08V-356) • DAIMLER • Defect Information Report • (Section 573.6) • Date: July 28.2008 • (c)(1) Manufacturer: Daimler Trucks North America LLC • P.O. BOX 3849 Portland, Oregon 97208 • (503) 745-5219 • Brands: Thomas Built Buses • (c)(2) Vehicles identification: Model(s) affected: MVP-ER Model Years affected: 1996 through 2002 Manufacture Dates: June 8, 1995 through February 16, 2001 Basis for determining population: MVP-ER units built with Caterpillar 3116 and 3126 engines. Component manufacturer if other than the vehicle manufacturer: Not applicable • (c)(3) Total number of vehicles potentially affected: Approximately 3,420 • (c)(4) Percentage of vehicles estimated to contain the defect: 100% • (c){5) Description of the defect: Un-fused power cables were tie-wrapped to a wire-braid engine fuel return hose. Over time these cables may chafe, wearing through the wire loom and eventually through the cable insulation and fuel line covering in an area not easily detectable during normal maintenance without removing tie wraps and opening the wire loom. Un-fused un-switched power cables which wear through and contact the fuel line wire-braid may short circuit. • 49CFR Section 577.5(f) Evaluation of the risk to motor vehicle safety: In the event of a short circuit there is a potential for a thermal event. • (c){6) Chronology of principal events: September 2007 Thermal event reported. Investigation by TBB of potentially affected population completed July 2008. • (c)(7) Noncompliance-test or other data: Not applicable • (c)(8) (i) Remedial program: Cables will be inspected and replaced as necessary. Alternator power cable will be separated from fuel return hose. Power cables will be secured to valve cover. Repairs will be performed by Thomas Built Buses dealerships and Direct Warranty customers, i.e., customers approved by Thomas Built Buses to do their own warranty repairs Reimbursement Plan: Copies will be submitted as a supplemental report when available. • (ii) Estimated Owner and Dealer Notification Date: Customer notification will be by first class mail using Thomas Built Buses records to determine the customers affected. This will be completed approximately September 19, 2008. Dealer notification will be completed approximately September 19, 2008. • (c)(9) Information for tire recalls: Not Applicable • (c)(10) Communications sent to manufacturers, dealers and owners: Copies will be submitted as a supplemental report when available. • (c)(11) Manufacturer's campaign number: FL-534 • A

32. Case # 3 Accelerator Pedal StickingRecall 09V-462

33. Case # 3 Accelerator Pedal StickingRecall 09V-462 ODI was contacted by a fleet stating that they had a pedal stick to the floor. A few days later, ODI found another fleet with the same issue. ODI immediately opened an Investigation. Daimler/Thomas Bus was contacted and technical meetings were conducted. ODI and Thomas engineers visited the fleet and confirm the pedal could, in fact, “stick” when fully depressed. Reportedly, there was a height change made to the accelerator pedal mounting bracket and this change would allow the pedal to become “wedged” against the scuff plate during full pedal application. Thomas Bus recalled 5,080 MVP-EF buses to raise the pedal bracket .75” to remove the interference between the pedal and the scuff plate. The safety recall was announced (09V-462) on November 25, 2009.

34. Case # 4 Chafing Parking Brake Cable and Battery Cables

35. Case # 4 Chafing Parking Brake Cable and Battery Cables (10V-010) ODI was contacted by a fleet concerning a bus fire Inspection of bus revealed battery cables and parking brake cables abrading Investigation opened, others thermal events found Navistar issues Safety recall 10V-010 to inspect and repair 3,066 IC CE style buses. The battery cables and parking cables will be inspected and replaced as necessary.

36. Case # 5 Cat C7-07 Fuel Line CrackingRecall 10E-025

37. Case # 5 Cat C7-07 Fuel Line CrackingRecall 10E-025 ODI became aware of several Blue Bird school bus fires. In March, a PE (PE10-018) was opened to further study the issue. A few days later, ODI found another fleet with the same issue. During the investigation, a service bulletin produced by Caterpillar, was review and thought to be related to the subject of the investigation. ODI started a dialog with Caterpillar concerning injector lines failing. Caterpillar reported that the clamping of # 5 fuel line to #6 fuel line and assembly stresses caused the #6 fuel line to fail, resulting in a “high pressure fuel spray.” Both Caterpillar and Blue Bird was asked to re-evaluate the issue. Both Caterpillar and Blue Bird decided to issue a safety recall to subject buses.

38. Case # 5 Cat C7-07 Fuel Line CrackingRecall 10E-025 Blue Bird recalls 3,789 school buses and 103 non-school buses to replace # 5 and #6 fuel lines. Recall number for school buses is 10V-289, and 10V-290 for non-school buses. Caterpillar filed a safety recall, 10E-025, to replace #5 and #6 fuel line on the common rail high pressure fuel system on all engines manufactured between March 3, 2005 to Jan. 6, 2009.

39. School Bus • School buses remain one of the safest forms of transportation in the United States. • The success of School Bus Safety is dependent on the willingness of each of us concerned with the transportation of children to make every effort to ensure that safety problems on buses within our purview are identified and corrected as soon as an issue is discovered.

40. Hotline • DOT Auto Safety Hotline • (1-888-327-4236) • Vehicle Owner’s Questionnaire (VOQ) • Online at NHTSA’s home page • By mail using paper form • Recall Subscriptions • School Bus recall notification • http://www-odi.nhtsa.dot.gov/subscriptions/index.cfm

41. Richard Boyd Richard.boyd@NHTSA.DOT.GOV www.safercar.gov 202-366-4933