Bold School: What Happens During a Recall?


Jeep has been in the news recently, thanks to the fuel tank recall on its older Grand Cherokee models. A lot of players were involved in executing that recall, from the manufacturer itself to the Department of Transportation and its National Highway Traffic Safety Administration (NHTSA) to consumer protection groups. What actually goes into making a recall happen? Well, it is a graphic, sausage-making process:

The Defect


Recalls are the result of some type of defect when an automobile is originally produced.

Most of the time, that defect is caught by the manufacturer. Through their own tests, inspection procedures, and information-gathering systems, manufacturers find that a safety defect exists or that the requirements of a Federal safety standard have not been met. When that happens, the manufacturer is required to report its findings to the Government and take appropriate action to correct the problem. For example, when the vehicle was in the field for several months, Toyota techs noticed that the stop light switch bracket on the 2011 Toyota Sienna could – in certain limited circumstances – be deformed when the parking brake was fully applied.

Sometimes, though, a defect is caught by vehicle owners and then reported to the manufacturer and NHTSA as an official complaint. NHTSA’s Office of Defects Investigation (ODI) handles the entire process of determining whether a mandated recall is required.


Jeep Grand Cherokee

NHTSA has a screening process to weed out issues that it doesn’t get involved in, or issues that are limited to a small handful of vehicles. The process includes Vehicle Owner’s Questionnaires submitted through the Vehicle Safety Hotline, the Internet or U.S. Mail, anonymous reports, and manufacturer-submitted information, and goes through a review process by the Defects Assessment Division (DAD). NHTSA then presents its information to a panel for a recommendation on whether to open a safety defect investigation or solely investigate safety-related issues.

Petition Analyses

Safety complaints are reported to NHTSA either by mail, or at  Anyone can submit a petition requesting that NHTSA open an investigation. If the ODI decide to grand the petition, it opens a defect investigation. If it’s denied, NHTSA publishes the reasons for denial in the Federal Register. You can imagine that with all the hundreds of millions of cars on the road, the paperwork is tremendous.

Preliminary Investigation (PI)

If NHTSA decides to investigate, the Preliminary Investigation (PI) is the first step. During the PE phase, the ODI obtains information from the manufacturer on all aspects of the complaint, such as crashes, injuries, warranty claims, and parts sales. The manufacturer then has an opportunity to present its views regarding the alleged defect. Most of the time, these preliminary investigations are resolved within four months, and they’re either closed because the ODI determines that further investigation isn’t required, or because the manufacturer doesn’t issue a voluntary recall. In the event that ODI believes further analysis is warranted – despite the manufacturer’s decision not to issue a recall — the Preliminary Investigation upgrades to an Engineering Analysis.

Engineering Analysis (EA)


This is the down-and-dirty, hands-on, nuts-and-bolts process of a recall, and it’s something that both manufacturers and NHTSA would like to avoid, due to the time and money required. The EA builds on information collected during the PI and then starts testing, inspecting and surveying to build a more accurate picture of the defect. The ODI attempts to resolve all EAs within one year from the date they are opened.

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If NHTSA believes that the data indicates the existence of a safety-related defect, it presents its findings to a panel of experts from throughout the agency for peer review. If the agency panel concurs with the ODI’s recommendation that a recall is required, NHTSA notifies the manufacturer and often allows the manufacturer a final opportunity to present any new findings. If the manufacturer still decides not to voluntarily recall a product, then NHTSA sends a Recall Request Letter to the manufacturer.

Ford Explorer

Whether or not a recall happens is a political dance. In the case of Ford and Firestone during the recall that impacted owners of Ford Explorers in 2000, the recall came about after private meetings with the car builder and the tire manufacturer. Interestingly, that particular recall sticks in the mind of consumers as a Ford issue, when in actuality, it was a Firestone issue, and one that only impacted Wilderness AT tires made at Firestone’s Decatur, Illinois plant.

Usually, this is where the recall kicks into high gear, because at this point, the manufacturer would rather deal with the recall than the public scrutiny of the rest of the process, which includes public meetings, orders from the Federal Government and a lot of bad press.

That’s exactly what happened during the Grand Cherokee recall. NHTSA requested that the 1993-2004 Jeep Grand Cherokee and 2002-2007 Jeep Liberty be recalled to address the design defect that resulted in – at the lowest estimate – 51 deaths due to fire. Chrysler issued a press release that – for all intents and purposes – told NHTSA to pound sand.

Weeks later, after pressure and bad press, Chrysler agreed to “inspect and upgrade” all pre-2004 Grand Cherokees, and pre-2007 Liberty models. The upgrade is a MOPAR receiver trailer hitch, which presumably provides greater crash protection for the fuel tank.

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