How OEMs manage safety recalls

Lucas Deal

February 8, 2017

Performing service on safety recalls is a way of life for dealer service centers. OEMs send out recall notices and a short time later customers’ trucks start rolling in.

Depending on the recall itself the sheer volume of service required can sometimes be overwhelming, but in the dealer channel the process itself is straightforward. OEMs provide necessary parts and information and dealers do the work they’ve been assigned.

For those who have ever wondered how OEMs make the process so seamless, the answer shouldn’t surprise you.

OEMs plan for this.

At the manufacturer level, every possible step in a recall is identified, and corresponds to an action that moves a recall closer to completion. From the second a recall is deemed necessary until the last truck rolls safely out of a service bay, OEMs are following a plan.

Any OEM plan begins with a notification alert—called a ‘Defect and Noncompliance Information Report’—sent to the National Highway Transportation Safety Administration (NHSTA) and Transport Canada, says Tim LaFon, vice president of regulatory affairs at Volvo Group North America.

NHTSA dictates that once a manufacturer “has decided that a safety defect or noncompliance exists in a motor vehicle or item of motor vehicle equipment it manufactures, it must report that decision to NHTSA within five working days.”

But NHTSA’s deadline only requires a notification of a safety defect, not a complete description of the failure or non-compliance and plans to remedy the issue. This distinction is valuable for OEMs, because it provides additional time to identify the full scope of a potential recall.

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LaFon says Volvo Group tries to pull together as much information as possible before sending its first notification to NHTSA and Transport Canada. In cases where the OEM doesn’t know everything, its sends what is available and provides additional information in future notifications.

The second step at Volvo Group, and at Navistar, says Manager of Product Integrity and Compliance Rick VanLaar, is determining the full scope of a potential recall and an action plan for providing service. VanLaar says Navistar has dedicated procedures for how to contact dealers and vehicle owners, order and stock parts, distribute service guidance and track recall status, but first it must determine exactly what needs to be fixed.

Manufacturers are given 60 days from when they first notify NHTSA to alert vehicle owners via first-class mail to a recall. VanLaar says in some cases Navistar can create an action plan and notify vehicle owners well within that period.

In situations where a recall requires additional attention, manufacturers can send an initial notification to customers (similar to the initial NHTSA notification) alerting them to the impending recall with promises of more information being released at a future date.

“We have to at least notify them and let them know we’ll be contacting them again [with more information],” VanLaar says.

Once an OEM has determined the total nature of a recall, it must submit the entirety of its findings to NHTSA.

The agency says the final submission must include the make, model and number of vehicles impacted, the reason for and risks associated with the failing or non-compliant components, a remedy development, recall schedule, manufacturer assigned recall identification codes and, when applicable, petitions for exemption from recall notice and remedy requirements.

This final report is then reviewed by NHTSA and the recall is assigned a unique safety recall identification number.

“Shortly thereafter, a written acknowledgment letter will be sent to the manufacturer summarizing the information in the report and providing the identification number for the recall. That letter will also contain additional information and instructions pertaining to quarterly reporting,” NHTSA says.

Occasionally NHTSA says this letter will request for additional information, and OEMs also have the opportunity after receiving the letter to review and make corrections if any errors are found within the document. It is then published on NHTSA’s websites www.safercar.gov and www.nhtsa.dot.gov.

OEMs are not required to pause their recall procedures during these stages, and most do not. The initial letters to vehicle owners are regularly sent during this period, as are initial alert messages to dealer groups.

LaFon says Volvo Group typically notifies its dealers via electronic and regular mail of recalls before contacting customers, and will provide intermittent updates during recall development as to its progress internally, and with NHTSA.

The time between first contact with NHTSA and a published recall also is an incredibly important period for an OEM’s supply chain. Recalls require OEMs to purchase and distribute all parts and kits that will be needed to complete a repair, and sometimes that can be a longer process, LaFon says.

“It depends on how many trucks are impacted,” he says.

Once a supply chain is filled and NHTSA provides a unique safety recall ID most OEMs kick their recalls processes into high gear.

If they haven’t already, manufacturers send a final instruction document (with directions for acquiring parts and a step-by-step service guidance) to dealers and letters to vehicle owners listing their impacted vehicles by VIN, and dates for when dealers will begin performing recall maintenance.

(Dealers are often notified as customers, too. VanLaar says occasionally trucks on a dealer’s lot will be subjected to recalls, so Navistar notifies the dealer so the service can be completed before the truck is sold.)

This is the where the baton is effectively passed.

Once dealers open their bays for a recall they are required to complete recall maintenance for any customer who requests it, and log the completed work for each vehicle by VIN in the OEM’s service portal. VanLaar says these systems also add notification tags to the VIN of each affected vehicle so service managers can alert a customer to an outstanding recall even if their truck was brought in for another reason.

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Vehicle owners are not required to accept a recall. VanLaar says some customers who don’t perceive a recall as an issue may choose to ignore notifications from an OEM. Additionally, truck dealers do not have the authority to perform recall service without a customer’s approval.

“It is their vehicle. We can’t hold it. But we do tell our dealers to encourage them that it needs to be repaired,” says LaFon.

Fortunately, the duo says this is rare. Navistar, Volvo and Mack all have success rates in the 90th percentile for their recalls. And because recall service is required to be provided free of charge (for all trucks first purchased within a decade of a recall announcement), there is little reason for a vehicle owner to reject service when offered.

OEMs have automated secondary messages—typically sent between 30 and 90 days of an initial recall rollout—to remind customers to bring their trucks in for service. NHTSA also requires OEMs to provide status updates for recall service for six quarters (18 months) after a recall announcement to ensure a recall is performing up to expectations.

Most OEMs don’t close recalls if they aren’t completed within that period. An OEM may choose to stop monitoring customer response to a recall after 18-24 months, but most still keep the recall active in its service software in case an impacted vehicles makes its way into a dealer service bay years later.

“We’ll keep a recall open indefinitely,” says VanLaar. “Even if a truck doesn’t come in until four or five years down the road, we’ll still honor an open recall.”

As for how to fit a recall into a dealer’s service workload, OEMs say that’s one decision they leave up to the dealers. Though manufacturers do note that they encourage vehicle owners in their initial mailed recall notifications to schedule service with their local dealer to avoid workload prioritization issues.

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