Recalls

Recalls & Communicating Sensitive Issues – 2 CEU’s

Recalls & Communicating Sensitive Issues – 2 CEU’s

May 14, 2010

PartnersPartnersThis 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

ObjectivesObjectives• 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 RoleNHTSA’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 BasisCR 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)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)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 VehicleSafety Compliance (OVSC)About the Office of VehicleSafety 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 ActThe 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 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 manufacturerEarly 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 processDefects 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 NHTSAWays 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 is paying attention?

Who may initiate a recall?

Manufacturer or NHTSAManufacturer 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 ProcessOffice 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?Fact or fiction?

• Registration cards have always been an important component of FMVSS 213.A. Fact

B. Fiction

Correct answer is fictionCorrect 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 timeMany 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 ResourceVehicle 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 RegistrationChild Restraint Registration

Registration and RecallCompliance RatesRegistration and RecallCompliance 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. NHTSAPublication DOT HS 809 518 (10/2002)

How Child Restraint Was AcquiredHow Child Restraint Was Acquired


Type of Store Where Seat PurchasedType of Store Where Seat Purchased

Who Consumers Spoke with About Registration When Acquiring SeatWho Consumers Spoke with About Registration When Acquiring Seat

Importance of Registering Child Safety Seats by Action taken with Registration CardImportance of Registering Child Safety Seats by Action taken with Registration Card

Registration Information provided by Retail StoresRegistration 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 importantSource: Evaluation of Child Safety Seat Registration. NHTSAPublication DOT HS 809 518 (10/2002)

Community Based ProgramsCommunity 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

monitorSource: Evaluation of Child Safety Seat Registration. NHTSAPublication DOT HS 809 518 (10/2002)

Reasons for Registering SeatsReasons for Registering Seats

• 91% notification of recall

• 15% warranty protection

• 2% because someone else told them to return it

• 3% other reasons


Reasons for Not Registering SeatsReasons for Not Registering Seats

• 85% Too busy

• 6% Lost card

• 3% Consider unimportant

• 2% Concerned about use of information

• 4% OtherSource: Evaluation of Child Safety Seat Registration. NHTSAPublication DOT HS 809 518 (10/2002)

The demographic groups with the lowest registration ratesThe 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


Child Seat Recall NotificationChild Seat Recall Notification

Fact or FictionFact or Fiction

• In most cases, a CR recall indicates a danger or potential danger for the child occupantA. Fact

B. Fiction

Correct: FictionCorrect: 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 ProgramCurriculum HS 366 R5/04, E-5

Example of Recall Error in instructionsExample 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 instructionsExample of Recall Error in instructions

Team Tex Babyride

Recall 4 24 09

NHTSA Campaign ID number 09C003000

Example of recall that is NOT crashworthyExample 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 RecallHow Registered Owners Found Out About a Recall



• A car seat should not be used while waiting for the repair kit.A. Fact

B. Fiction

Correct: FictionCorrect: 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 not 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 ExampleChild 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.: 08C003000Photo source: NHTSA

What Consumers RememberedWhat 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


Retail Store Experience with Recall of Seats Still in StockRetail 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


Retail Stores-How Recall ofChild Seat Was ResolvedRetail Stores-How Recall ofChild 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


Example of seat: No recallExample of seat: No recall• Dorel Juvenile Group

• Component: Headrest/Harness Adjustment Bar

• Screws detached from adjuster bar to headrest

2003 Cosco Summit High Back BoosterPE06034Photo source: NHTSA

Example of Recall:CR is crashworthyExample 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 BenefitsCosts 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


Register Now!Register Now!

Register Child Restraints onlinewww.safercar.gov

Register Child Restraints onlinewww.safercar.gov

Two Options to Register: NHTSA and ManufacturerTwo Options to Register: NHTSA and Manufacturer

Register the restraint at www.safercar.gov and with the child restraint manufacturer of the seat

Online RegistrationOnline 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 notificationSubscribe to email notification

Really Simple Syndication (RSS)Feed OptionReally Simple Syndication (RSS)Feed Option

RSS Feed Option InstructionsRSS Feed Option Instructions

Manufacturer’s Provide OnlineGuidanceManufacturer’s Provide OnlineGuidance

Photo sources: Mfg. websites


• Are recall kits always available to consumers whose CR is older than 6 years from date of manufacture?A. Fact

B. Fiction

Correct: FictionCorrect: Fiction

• A recall campaign is considered open for 6 quarters (18 months) after the initiation of the recall

Resources & ContactsResources & Contacts

• National Highway Traffic Safety Administration (NHTSA)• ODI Defects Assessment Division• [email protected]

• Consumer Product Safety Commission https:/www.cpsc.gov/cpsclist.aspx

Role of the TechnicianRole of the Technician

Photo courtesy of Safe Kids Worldwide

Example of a Technician Reportto ODI – No RecallExample of a Technician Reportto ODI – No Recall

• Britax Roundabout• A lower LATCH

connector was easily released

• Seat was sent to ODI

PE03045

Photo courtesy of Britaxinstruction Manual

Tech Resource: ExampleBritax Advocates ExtranetTech Resource: ExampleBritax Advocates Extranet

Photos courtesy of Britax website

Child Restraint Recall ListsChild 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 QuestionResearch 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 QuestionResearch QuestionRecall One: The component, issue, and remedy for this recall is:

A. This CR is not one that has been recalled

B. The lower anchor connector adjuster assembly may interfere with the connection to the restraint base when installed using LATCH; seat belt is not affected

C. 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

D. None of the above

The answer is CThe answer is CRecall One: The component, issue, and remedy for this recall is:

A. This CR is not one that has been recalled

B. The lower anchor connector adjuster assembly may interfere with the connection to the restraint base when installed using LATCH; seat belt is not affected

C. 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

D. None of the above

Follow up QuestionFollow up QuestionIs this CR crashworthy; what would you say to the parent?

A. This CR is crashworthy; be sure to follow the instructions for repair, contact the manufacturer for any questions you may have

B. This CR is not crashworthy the seat should not be used and the family needs to buy a replacement CR

C. 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

D. Both A and C

The correct answer is DThe correct answer is DIs this CR crashworthy; what would you say to the parent?

A.This CR is crashworthy; be sure to follow the instructions for repair, contact the manufacturer for any questions you may have

B.This CR is not crashworthy the seat should not be used and the family needs to buy a replacement CR

C.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

D.Both A and C

Research QuestionResearch QuestionRecall 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 QuestionResearch QuestionRecall Two:

The component, issue, and remedy for this recall is:A. The tether webbing could be cut and separate in a

crash allowing excessive movement of the child, a free repair kit is available

B. The tether webbing could be cut and separate in a crash, the seat is not crashworthy and should not be used

C. 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

D. This CR is not one that has been recalled

The correct answer is AThe correct answer is ARecall Two:

The component, issue, and remedy for this recall is:A. The tether webbing could be cut and separate in a crash

allowing excessive movement of the child, a free repair kit is available

B. The tether webbing could be cut and separate in a crash, the seat is not crashworthy and should not be used

C. 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

D. This CR is not one that has been recalled

Follow up questionFollow up questionIs this CR crashworthy; what would you say to the parent?A. 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.

B. The CR is not crashworthy and should not be usedC. The CR is crashworthy, contact and follow the

manufacture instructionsD. Both A and C

The answer is DThe answer is DIs this CR crashworthy; what would you say to the

parent?A. 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.

B. The CR is not crashworthy and should not be usedC. The CR is crashworthy, contact and follow the

manufacture instructionsD. Both A and C

Provide Resources, Be a ResourceProvide 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 ResourceProvide 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,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 facingRear facing vs. forward facing

• http://www.youtube.com/watch?v=kRP7ynNI8mI

http://www.youtube.com/watch?v=kRP7ynNI8mI

http://www.youtube.com/watch?v=kRP7ynNI8mI

Recalls

Documents

Transcript of Recalls