General Motors Pickup Truck Defect Investigation; Public Proceeding Scheduled

DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

[Docket No. EA92-041; Notice 1]

General Motors Pickup Truck Defect Investigation; Public

Proceeding Scheduled

AGENCY: National Highway Traffic Safety Administration (NHTSA), DOT.

ACTION: Notice of initial decision and public meeting.

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SUMMARY: NHTSA will hold a public meeting beginning at 10:00 a.m. on

December 6, 1994 regarding the initial decision by the Secretary of

Transportation that certain pickup trucks and other vehicles

manufactured by General Motors Corporation (GM) contain a defect that

relates to motor vehicle safety.

FOR FURTHER INFORMATION CONTACT:

Ellen Berlin, Director, Office of Public and Consumer Affairs, National

Highway Traffic Safety Administration, 400 Seventh Street, SW,

Washington, DC 20590; (202) 366-9550.

SUPPLEMENTARY INFORMATION: Pursuant to 49 U.S.C. 30118(a) (formerly

section 152(a) of the National Traffic and Motor Vehicle Safety Act of

1966, as amended, 15 U.S.C. 1412(a)), Secretary of Transportation

Federico Pena has made an initial decision that model year 1973-1991

full-sized GM pickup trucks and cab-chassis equipped with fuel tanks

mounted outboard of the frame rails contain a defect that relates to

motor vehicle safety.

The rationale for this initial decision is set forth in the

Engineering Analysis (EA) Report for EA92-041. The entire report, as

well as the complete record on which the initial decision is based, are

available for inspection during working hours (9:30 a.m. to 4:00 p.m.)

in NHTSA's Technical Reference Library, Room 5108, 400 Seventh Street,

SW, Washington, DC 20590. That record consists of the public files for

EA92-041 and Defect Petition (DP) 92-016. The Executive Summary of the

EA Report is set out below.

Engineering Analysis Report--Executive Summary

This Engineering Analysis was opened on December 8, 1992, as a

result of granting a petition from the Center for Auto Safety (CAS) and

Public Citizen to ``initiate a defect investigation into and recall all

Chevrolet/GMC full-sized pickups (C/K-series) with fuel tank(s) * * *

mounted outboard of frame rails.'' The objective of the investigation

was to determine whether certain model year 1970-1991 Chevrolet and GMC

full-sized pickup trucks contain a defect that poses an unreasonable

risk to safety, related to the danger of fires following crashes, with

primary focus on side-impact crashes. In the investigation, the

National Highway Traffic Safety Administration's (NHTSA) Office of

Defects Investigation (ODI) conducted analyses of real-world accident

data and performed laboratory crash tests of the subject and peer

vehicles. ODI also addressed questions related to the compliance of

these trucks with Federal Motor Vehicle Safety Standard (FMVSS) No.

301, ``Fuel System Integrity.'' Additionally, ODI examined whether the

fuel tanks and related components on the trucks were unduly affected by

corrosion that could make them more likely to be involved in a fire.

On April 9, 1993, ODI sent a recall request letter to General

Motors Corporation (GM), recommending that GM conduct a safety recall

on GM trucks with fuel tanks mounted outside the frame rails (subject

vehicles). That letter was based on two principal factors:

1. Real-world accident data in the Fatal Accident Reporting System

(FARS) indicate that there is an increased risk of fatality caused by

fire in side-impact crashes involving the subject vehicles compared to

1973-1987 Ford full-sized pickup trucks. That increased risk led to an

estimate that, in 1993, an additional 5-6 fatalities would occur in

side-impact crashes involving the subject vehicles compared to what

would occur if those trucks had the same side-impact fire performance

as full-sized Ford pickups.

2. Laboratory crash tests corroborated the findings from the real-

world accident data analysis. That is, in certain comparable side-

impact crash tests, GM fuel tanks leaked and Ford tanks did not.

Further, these tests used instrumented test dummies. Dummy measurements

indicate that humans could have survived the crash forces at the impact

speeds at which the subject vehicles leaked. While these speeds are

well in excess of the impact speed specified in FMVSS No. 301, the

results indicate the increased fire risk in the GM trucks in crashes

that are otherwise survivable.

GM provided an extensive amount of data and arguments in response

to the recall request letter. ODI has completed an exhaustive review

and analysis of the GM submissions and has conducted a variety of

additional analyses associated with issues involved in this

investigation. These include:

An assessment of the effect of corrosion on fuel tank

leakage and fire performance in the subject vehicles;

An analysis of non-fatal burn injuries in side-impact

crashes involving the subject vehicles;

An in-depth review of all available police accident

reports and other records of side-impact, fire-involved fatal crashes

involving the subject vehicles to assess the crash conditions and

severity of each;

An update of the FARS analysis that led to the April 9,

1993 recall request letter;

An analysis of the reasonableness of GM's decision to

design the subject vehicle with side-mounted fuel-tanks, given what GM

knew about the safety risks associated with that design and the

availability of feasible alternative designs; and

An analysis of the information about the risk of post-

crash fuel leaks that became available to GM during the time the

subject vehicles were being manufactured.

Principal Findings

A review of GM submissions, as well as ODI testing,

indicates that there are no data on which to conclude that the GM

trucks to which FMVSS No. 301 applied, when new, did not comply with

the standard.

There are no data to indicate a relationship between fuel

tank corrosion and increased fire risk in the subject vehicles, either

in side impacts or in non-crash incidents.

Apart from the basic decision to locate the fuel tanks of

the subject vehicles outside of the frame rails, many of the specific

features of the design of the fuel storage system and the surrounding

area have increased the likelihood of post-crash fuel fires in the

subject vehicles.

Based on a review of 1979-1993 accident data reflecting

the performance of full-sized pickups in side-impact fatal crashes

involving fire, occupants of the subject vehicles experienced 2.8 times

as many fire-related fatalities (i.e., fatalities in crashes in which a

fire occurred) per million registered vehicle-years as occupants of

Ford pickups and 2.5 times as many as occupants of Dodge pickups. Where

the FARS code indicated that the most harmful event (MHE) of the crash

was fire, the GM-to-Ford occupant fatality per million registered

vehicle-years ratio is 3.4 to 1, and the GM-to-Dodge ratio is 6.1 to 1.

Real-world accidents data do not support GM's contention

that GM and Ford pickup trucks have comparable side-impact fire

performance and that differences in driver demographics and driver

behavior explain the difference in the rates of fire-related and MHE-

fire fatalities in side-impact crashes for the GM and Ford pickups.

This is demonstrated by the tremendous reduction in the rate of MHE-

fire side-impact fatalities that occurred after GM moved the fuel tanks

for these pickups inside the frame rails in model year 1988.

Contrary to GM's contentions, the MHE coding in FARS is a

reliable indicator of the number of fatalities actually caused by fire.

FARS data indicate that, if past trends continue, there

would be approximately five additional fatalities due to fire in side-

impact crashes in 1994 compared to what would occur if the subject

vehicles had the same side-impact fire performance as Ford full-sized

pickups.

Reports of non-fatal burn injuries indicate that, if past

trends continue, there would be three to four additional non-fatal burn

injuries in 1994 in side-impact crashes involving the subject vehicles

compared to the Ford pickups.

Laboratory crash data indicate that, at certain impact

speeds and configurations, the subject vehicles will leak fuel in side

impacts, while comparable Ford pickups will not.

While the crash severities in fatal side-impact, fire-

involved crashes involving the subject vehicles are far in excess of

the severity specified in FMVSS No. 301, they are generally less than

the severities that result in fires in fatal side-impact crashes

involving the Ford pickups.

GM was aware at the time it designed the subject vehicles

in the early 1970s that side-mounted fuel tank design presented an

increased risk of post-crash fuel fed fires in side impacts, compared

to the risk associated with other feasible alternative designs.

Moreover, GM obtained additional information demonstrating the

increased risk associated with the side-mounted tanks during the 15-

year period the subject vehicles were in production.

Principal Conclusions

The increased risk of death and injury from fire in side-

impact crashes involving the subject vehicles is a result of the design

of their fuel storage system, primarily the location of the fuel tanks

outside of the frame rails, supplemented by other features of the

design.

Given the state of the art at the time and GM's awareness

of the likely consequences, it was unreasonable for GM to design the

subject vehicles with fuel tanks outside the frame rails.

The increased safety risk due to post-crash fires in the

subject vehicles is unreasonable.

Therefore, on the basis of the entire investigative record, I have

initially decided, pursuant to 49 U.S.C. 30118(a) (formerly section

152(a) of the National Traffic and Motor Vehicle Safety Act), that the

subject vehicles contain a defect that relates to motor vehicle safety.

[End of Executive Summary]

Pursuant to 49 CFR 554.10, a public meeting will be held beginning

at 10:00 a.m., on Tuesday, December 6, 1994 in Room 2230, Department of

Transportation Building, 400 Seventh Street, SW, Washington, DC, at

which time GM and all other interested persons will be afforded an

opportunity to present information, views, and arguments on the issue

of whether the vehicles covered by this initial decision contain a

safety-related defect. NHTSA's Deputy Administrator, Christopher A.

Hart, will preside at that public meeting.

Interested persons are invited to participate in this proceeding

through written and/or oral presentations. Persons wishing to make oral

presentations are requested to notify Ms. Judy Taylor, Office of

Defects Investigation, National Highway Traffic Safety Administration,

Room 5326, 400 Seventh Street, SW, Washington, DC 20590 (202) 366-2850,

before the close of business on November 28, 1994. Such persons should

indicate the approximate amount of time their presentation is expected

to take and whether they will need any audio-visual equipment. Written

comments may be submitted to the same address and must be received not

later than the beginning of the meeting on December 6, 1994.

Authority: 49 U.S.C. 30118(a).

Issued on: October 21, 1994.

Federico Pena,

Secretary of Transportation.

[FR Doc. 94-26650 Filed 10-26-94; 8:45 am]

BILLING CODE 4910-59-M