NHTSA Nixes GM Petition for Exclusion of Millions of Big Trucks and SUVs from Takata Airbag Recalls

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The biggest recall* in US history just got bigger as NHTSA has ordered GM to replace Takata airbag inflators used in its full-size trucks and SUVs. In dispute were millions GM vehicles. In the U.S., there are now ~5.8 million vehicles involved in this recall. Globally, the number is about 7 million. (GMT900 full-size pickup and SUV platform used for the 2007 to 2014 model years.***)

GM said in a statement that “although we believe a recall of these vehicles is not warranted based on the factual and scientific record, NHTSA has directed that we replace the airbag inflators in the vehicles in question. Based on data generated through independent scientific evaluation conducted over several years, we disagree with NHTSA’s position. However, we will abide by NHTSA’s decision and begin taking the necessary steps.”

The Takata recall numbers and the expenses are astronomical for GM – and Takata (which was driven into bankruptcy) as well as other automakers in this ongoing disaster. This dispute goes back to June of 2016 when NHTSA claimed that at some point in the future, all non-desiccated frontal Takata PSAN inflators will need to be replaced before they have reached a certain level of propellant degradation that creates a safety risk of inflator rupture. Under the so-called Amended Consent Order with NHTSA, Takata had to file Defect Information Reports covering all non-desiccated frontal Takata PSAN inflators.

General Motors then issued (2 June 2016) an unusual “preliminary recall” on 1.9 million 2007-2011 model full-size trucks and SUVs with passenger-side front airbag inflators from Takata. These were listed in defect information reports, aka (DIRs) submitted to NHTSA on 16 May 2016. NHTSA earlier in May of 2016 had expanded the recall by 40 million. The GM move followed an announcement one day earlier that Ford Motor was recalling another 1,896,443 vehicles with potentially deadly Takata airbag inflators that send shrapnel into the interior as they blow up.

GM had petitioned NHTSA for a decision that the Takata PSAN defect in the GMT900 vehicles is inconsequential as it relates to motor vehicle safety, and that GM should therefore be relieved of its notification and remedy obligations. GM proposed two primary arguments over the course of several technical filings for why the defect should be deemed inconsequential in GMT900 vehicles.

1. First, GM said that there are multiple “unique” design differences in the YD and YP variant inflators used in GMT900 vehicles that result in a reduced risk of rupture.
2. Second, GM argues that the physical environment in GMT900 vehicles “better protects the front-passenger inflator from the

GM’s primary arguments and supporting information are:

1. Unique Inflator Design Differences and Vehicle Features. GM claimed that the YD and YP variant inflators in GMT900 vehicles are not used by any other vehicle manufacturers and that these inflator variants have a number of unique design features that result in a reduced risk of inflator rupture^[1] GM said unique design features are “crucially” important factors that required Takata to “heavily modify the characteristics” of their inflators in order to meet GM’s standards.

GM’s petitions presented to NHTSA alleged design differences including the following:

Thinner Propellant Wafers. GM claims that the thinner (8mm) propellant wafers used in the GMT900 inflators have more predictable ballistic properties than thicker (11mm) wafers used in many other Takata PSAN inflator variants, which “create less excess surface area as they degrade.” As a result, GM contends that the thinner propellant wafers used in the GMT900 vehicles age more slowly and burn more efficiently than thicker propellant wafers, resulting in a reduced risk of inflator rupture.

Larger Vent Area. GM said that a greater vent-area-to-propellant-mass ratio provides for more efficient burning and deployment of the GMT900 inflators, resulting in a reduced risk of inflator rupture.

Steel Endcap. GM said that the steel endcap used on the GMT900 inflators creates an improved hermetic seal compared to the aluminum endcaps used on other Takata PSAN inflators, and therefore protects the propellant better from moisture. GM also claims that the use of steel endcaps improves the inflators’ “resistance to high-internal pressures.”

Other Design Differences. GM claimed several other design differences in its presentations to NHTSA, including tablets in a cup (for YP variants), the incorporation of a ceramic cushion (also for YP variants), and the incorporation of a bulkhead disk with an anvil (for YD variants). “While noted and discussed during presentations, these design differences were not explicitly referenced or otherwise significantly expounded upon in GM’s Petition documents,” NHTSA said.

GM also asserted that the physical environment in GMT900 vehicles is more protective of the front-passenger inflators from extreme temperature cycling that can cause inflator rupture. GM claims that the GMT900 vehicles have larger cabin volumes than other vehicles equipped with Takata PSAN inflators, and are all equipped with solar-absorbing glass windshields and side glass, which results in lower internal vehicle temperatures and thus a reduced risk of inflator rupture.^[2]

GM also contended that the passenger inflators at issue are currently performing as designed and will continue to function properly without risk of rupture for at least 30 to 35 years of service in the field. GM referred to ballistic testing, aging studies, predictive modeling, and other analyses that it has conducted over the last several years.

AutoInformed on Takata

• Subaru America Recalls Exploding Takata Air Bag Inflators  
• Deadly Takata Airbags – Toyota Recalls +900K Vehicles Again
• Honda Finally Begins Last Takata Airbag Inflator Recalls
• Ford Again Expands Takata Air Bag Recall to 1,000,000 Vehicles
• Carma Project, Toyota Try to Up Takata Recall Awareness
• Ford Issues Takata Safety Recall on 2006 Ranger Trucks
• Happy New Year! Another 800,000 Deadly Takata Airbags Recalled
• Mazda Recalls Takata Airbag Inflators with New Supplier As Replacement
• Ford Recalls 2017 Takata Airbag Inflators on F-Series, Mustang!
• Takata Pleads Guilty of Falsifying Data on Airbag Shrapnel
• NHTSA Hastens Replacements of Deadly Takata Air Bags
• New Takata Tests – High Risks in Older Honda, Acura Models
• FCA US Eliminates Use of Non-Desiccated Ammonium Nitrate Takata Air-bag Inflators
• More Recalls for Takata Airbag Shrapnel
• GM Stops Sale of 2013-14 Cruze Models for Defective Takata Air Bag Inflators
• More Recalls for Takata Airbag Shrapnel

*NHTSA Statement on Takata Airbag Inflator Recalls : “The Takata air bag inflator recalls (“Takata recalls”) are the largest and most complex vehicle recalls in U.S. history. These recalls currently involve 19 vehicle manufacturers and over 60 million Takata air bag inflators in tens of millions of vehicles in the United States alone. The recalls are due to a design defect, whereby the propellant used in Takata’s air bag inflators degrades after long-term exposure to high humidity and temperature cycling. During air bag deployment, this propellant degradation can cause the inflator to over-pressurize, causing sharp metal fragments (like shrapnel) to penetrate the air bag and enter the vehicle compartment. To date, these rupturing Takata inflators have resulted in the deaths of 18 people across the United States and hundreds of injuries, including lacerations and other serious consequences to occupants’ face, neck, and chest areas.”

*** GM Models

GM’s Petition involves certain “GMT900” vehicles that contain “SPI YP” and “PSPI-L YD” inflator variants. GMT900 is a GM-specific vehicle platform that forms the structural foundation for a variety of GM light- and heavy-duty pickup trucks and sport utility vehicles, including: Chevrolet Silverado 1500, GMC Sierra 1500, Chevrolet Silverado 2500/3500, GMC Sierra 2500/3500, Chevrolet Tahoe, Chevrolet Suburban, Chevrolet Avalanche, GMC Yukon, GMC Yukon XL, Cadillac Escalade, Cadillac Escalade ESV, and Cadillac Escalade EXT. The Petition involves approximately 5.9 million MY 2007-2014 GMT900 vehicles in Zones A, B, and C that categorize the weather conditions that degrade the Takata airbag inflator propellant.