GAO Report

United States Government Accountability Office

GAO

Report to Congressional Requesters

June 2011

AUTO SAFETY
NHTSA Has Options
to Improve the Safety
Defect Recall Process

GAO-11-603

June 2011

AUTO SAFETY
Accountability • Integrity • Reliability

NHTSA Has Options to Improve the Safety Defect
Recall Process
Highlights of GAO-11-603, a report to
congressional requesters

Why GAO Did This Study

What GAO Found

In 2010, auto manufacturers recalled
more vehicles than any other year,
according to the National Highway
Traffic Safety Administration
(NHTSA), the federal oversight
authority for vehicle recalls.
However, many recalled vehicles are
never fixed, posing a risk to vehicle
operators, other drivers, and
pedestrians. After the recent recalls
of Toyota vehicles, Congress raised
questions about the auto safety
defect recall process, including the
sufficiency of NHTSA’s oversight
authorities and whether vehicle
owners are being effectively
motivated to comply with recalls.

NHTSA monitors manufacturers’ recall campaigns and completion rates (the
number of defective vehicles that are fixed) and provides information and
guidance to the public. NHTSA is responsible for reviewing the planning and
implementation of recall campaigns to ensure compliance with legal
requirements. To this end, the agency is responsible for reviewing, among
other things, the manufacturer’s description of vehicles affected by a safety
defect, actions the manufacturer plans to take to remedy those vehicles
through a recall, and notification letters the manufacturer plans to send to the
vehicles’ owners. NHTSA also monitors the effectiveness of manufacturers’
recall campaigns, based in large part on the data manufacturers are required
to submit on completion rates. In addition, the agency provides information
and guidance to the public on recalls, primarily through its Web site. NHTSA
generally has similar authorities to those of selected federal and foreign
agencies GAO reviewed that oversee recalls—the Consumer Product Safety
Commission, the Food and Drug Administration, the U.S. Department of
Agriculture, and agencies in Canada, Germany, Japan and the United
Kingdom—although some differences exist in how they can implement their
authorities.

In response, GAO reviewed laws and
documents and interviewed NHTSA
and stakeholders about the (1) extent
of NHTSA’s role in the recall process,
and how its authorities compare to
selected federal and foreign agencies
that oversee recalls; (2) benefits and
challenges of the recall process for
NHTSA and manufacturers; and (3)
options for improving the recall
process. GAO also conducted focus
groups with vehicle owners to better
understand their perspectives.

What GAO Recommends
GAO recommends that NHTSA (1)
modify requirements for notification
letters; (2) enhance and publicize its
Web site (3) better use
manufacturers’ data; and (4) seek
legislative authority to notify
potential used car buyers of recalls.
NHTSA agreed to consider GAO’s
recommendations.
View GAO-11-603 or key components.
For more information, contact Susan A.
Fleming at (202) 512-2834 or
[email protected].

Auto industry stakeholders are generally satisfied with the recall process, but
several challenges may affect recall completion rates, and thus, the number of
defective vehicles that are removed from the road. Manufacturers cited
NHTSA’s role in the process as a key benefit, reporting clear requirements and
open communication. Although franchised dealerships had some concerns
related to manufacturers’ communication and availability of repair parts, they
were also generally satisfied with how manufacturers reimbursed them.
Nevertheless, NHTSA faces challenges that may affect recall completion rates;
for example, focus group participants reported that 1) they preferred
notification letters with certain elements and may be more likely to comply if
the letters included the VIN number and clarified the severity of the defect
and 2) they were unfamiliar with NHTSA’s primary means of communicating
defect information to the public—its Web site. Furthermore, according to
GAO’s review, although recall completion rates vary considerably by certain
factors, NHTSA has not consistently used the data it collects to identify which
factors make some recalls more successful than others. Finally, NHTSA does
not have authority to notify potential used car buyers of a defect.
Based on these challenges, NHTSA has the following and other options for
improving the recall process and, more importantly, recall completion rates.
First, NHTSA could modify the way manufacturers must present information
in safety defect notification letters and publicize information resources, like
NHTSA’s Web site, so that vehicle owners are better motivated and informed.
Second, NHTSA may be able to use manufacturers’ data to identify what
factors make some recalls more or less successful than others to better target
monitoring of recall campaigns and identify best practices. Finally, expanding
NHTSA’s recall authorities may help identify more defective vehicles and
improve recall completion rates.
United States Government Accountability Office

Contents

Letter

1
Background
NHTSA Conducts Oversight of Safety Defect Recalls, and Other
Selected Agencies Generally Share Similar Authorities
Auto Industry Stakeholders Are Generally Satisfied with the Recall
Process for Safety Defects, but Several Challenges May Affect
Recall Completion Rates
Options Exist to Improve NHTSA’s Safety Defect Recall Process
Conclusions
Recommendations for Executive Action
Agency Comments

18
30
35
36
37

Appendix I

Scope and Methodology

39

Appendix II

Defect Notification Letters and Envelopes Used in
Focus Groups

49

GAO Contact and Staff Acknowledgments

58

Appendix III

3
9

Tables
Table 1: Minimum Completion Rate for Possible NHTSA Follow-up
Notification Request or Requirement
Table 2: Federal Agencies’ Authorities to Order Recalls and Impose
Penalties for Selected Products
Table 3: NHTSA and Selected Foreign Agencies’ Auto Safety Recall
Authorities
Table 4: Foreign Agencies with Safety Recall Authority That GAO
Interviewed
Table 5: Auto Manufacturers GAO Interviewed
Table 6: Franchised Dealerships and Used Dealerships GAO
Interviewed
Table 7: Comparison of All NHTSA Recall Data for Safety Defects
from 2000 through 2008 to Data Analyzed by GAO
Table 8: Component Categories Used in GAO Analysis of NHTSA’s
Artemis Database

Page i

12
14
17
40
41
42
44
45

GAO-11-603 Auto Safety

Figures
Figure 1: The Role of Stakeholders in the Auto Safety Defect Recall
Process
Figure 2: Total Voluntary and Influenced Safety Defect Recalls for
Motor Vehicles, 2000-2009
Figure 3: Average Recall Completion Rates by Manufacturer, 2000
through 2008
Figure 4: Variation in Recall Completion Rates, by Component
Recalled

7
8
25
26

Abbreviations
ACRA
CPSC
EU
FDA
MLIT
NHTSA
ODI
OVSC
RSS
TREAD
UK
USDA
VIN

American Car Rental Association
U.S. Consumer Product Safety Commission
European Union
U.S. Food and Drug Administration
Ministry of Land, Infrastructure, Transport and Tourism
(Japan)
National Highway Traffic Safety Administration
Office of Defects Investigation
Office of Vehicle Safety Compliance
Really Simple Syndication
Transportation Recall Enhancement, Accountability and
Documentation
United Kingdom
U.S. Department of Agriculture
vehicle identification number

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GAO-11-603 Auto Safety

United States Government Accountability Office
Washington, DC 20548

June 15, 2011
The Honorable Elijah Cummings
Ranking Member
Committee on Oversight and Government Reform
House of Representatives
The Honorable Edolphus Towns
House of Representatives
From 2000 to 2009, manufacturers of motor vehicles and vehicle
equipment conducted almost 6,300 recalls to address safety issues ranging
from malfunctioning airbags to defective child safety seats. The vast
majority of products affected by these recalls were vehicles, such as cars,
sport utility vehicles, and pickup trucks. In 2010, a record 14.9 million
vehicles were recalled by manufacturers, according to the National
Highway Traffic Safety Administration (NHTSA), the federal agency that
oversees vehicle recalls. However, owners of vehicles subject to a recall
do not always get them fixed, posing a risk to owners, as well as to vehicle
passengers, other drivers, and pedestrians. According to NHTSA, on
average only about 70 percent of vehicles subject to a recall are fixed
within the 18-month period during which manufacturers provide recall
completion data to the agency. After the highly publicized recalls
regarding the sudden unintended acceleration of Toyota vehicles in 2009
and 2010, Congress expressed concerns about the auto recall process,
including whether NHTSA has the authorities it needs and whether vehicle
owners are being effectively motivated to get their vehicles remedied.
Congress has also expressed concern about federal oversight of recall
processes for other products. For example, in 2008, the Consumer Product
Safety Improvement Act was enacted, which gave the Consumer Product
Safety Commission (CPSC) enhanced authorities regarding safety
standards and recalls. 1 Similarly, the Food and Drug Administration (FDA)
Food Safety Modernization Act 2 was signed into law in January 2011 to
give FDA enhanced recall authority, allowing it to mandate a manufacturer

1

Pub. L. No.110-314, 122 Stat. 3016 (Aug. 14, 2008).

2

Pub. L. No.111-353, 124 Stat. 3885 (Jan. 4, 2011).

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GAO-11-603 Auto Safety

to recall an unsafe food product. 3 In addition, Congress has raised
questions regarding how NHTSA’s authorities to regulate motor vehicle
safety compare with other countries, such as Canada and Japan.
In this context, this report addresses the following questions: (1) What is
the extent of NHTSA’s role in the auto safety defect recall process, and
how do its authorities compare with those of other selected federal and
foreign agencies with safety recall authority? (2) What are the benefits and
challenges of the auto safety defect recall process for NHTSA and the
manufacturers? (3) What options exist for improving NHTSA’s auto safety
defect recall process?
To describe the extent of NHTSA’s role and authorities in the auto safety
defect recall process, we reviewed applicable legislation, including the
National Traffic and Motor Vehicle Safety Act, as amended, relevant
federal regulations, and NHTSA’s guidance on the safety defect recall
process. In addition, we conducted interviews with NHTSA officials about
the agency’s role in the defect recall process and its recall authority. To
compare NHTSA’s authorities with those of other federal agencies, we
reviewed legislation and interviewed officials at selected federal agencies
that, similar to NHTSA, have product safety oversight responsibilities,
including CPSC, FDA, and the U.S. Department of Agriculture (USDA), to
determine what differences and similarities exist between the agencies’
recall authorities and those of NHTSA. To compare NHTSA’s authorities
with selected foreign agencies with safety recall authority, we interviewed
officials from agencies in four countries (Canada, Germany, Japan, and the
United Kingdom) about their authorities and involvement in the auto
safety recall processes of their countries. We selected these agencies
based on recommendations from NHTSA and industry officials with whom
we spoke and to reflect a range of safety recall processes and authorities.
We also interviewed auto industry organizations in the selected countries
to get their perspectives on the authorities of the selected foreign
agencies, as well as officials from the European Union (EU) to understand
how EU legislation may impact two countries in our review, Germany and
the United Kingdom (UK).
To examine the benefits and challenges in the auto safety defect recall
process, as well as potential options for improving the process, we

3

For the purposes of this report, a recall includes the repair, removal, replacement, or
refund for a defective or unsafe product.

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GAO-11-603 Auto Safety

conducted and analyzed interviews with stakeholders in the auto safety
defect recall process, including NHTSA, auto manufacturers, third-party
data providers, franchised and used-car dealerships, rental car companies,
consumer groups, and industry organizations. In addition, to determine
vehicle owners’ awareness of recalls, their understanding of defect
notification letters, and their willingness to comply with defect notices, we
convened 10 focus groups in five cities—Chicago; Dallas; Richmond,
Virginia; Salina, Kansas; and Seattle, Washington. These cities were
selected to provide geographic variation and both rural and urban
environments. We also analyzed NHTSA data to determine the average
completion rate—that is, the number of defective vehicles that are
remedied—of auto safety defect recalls from 2000 through 2008 (the last
year for which a full six quarters of recall completion rate data is
available) and to examine what variations exist across completion rates.
See appendix I for more information about our scope and methodology.
We conducted this performance audit from June 2010 through June 2011 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.

Background

The National Traffic and Motor Vehicle Safety Act of 1966 established
safety standards for motor vehicles. 4 NHTSA was established by the
Highway Safety Act of 1970 to carry out safety activities, which range from
setting vehicle safety standards to working with states and local
communities to reduce drunken driving. 5 In 2000, in response to the highly
publicized recall of Firestone tires due to serious safety defects, Members
of Congress expressed concern about NHTSA’s oversight of vehicle and
equipment safety. Subsequently, the Transportation Recall Enhancement,
Accountability and Documentation—TREAD—Act was signed into law,
which enhanced NHTSA’s authority to ensure that manufacturers provide
the agency with early notification of potential safety defects in motor

4

Pub. L. No. 89-563, 80 Stat. 718 (Sept. 9, 1966).

5

Pub. L. No. 91-605, 84 Stat 1713 (Dec. 31, 1970).

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vehicles and equipment and that manufacturers quickly take actions to
remedy them. 6
NHTSA has two primary missions in its oversight of vehicle safety: 7
•

Oversight of auto and equipment manufacturers’ compliance with safety
standards established by the agency. NHTSA’s Office of Vehicle Safety
Compliance (OVSC) is responsible for ensuring that new vehicles or
equipment comply with Federal Motor Vehicle Safety Standards. 8 By law,
manufacturers must provide certification indicating that their vehicles and
equipment meet these standards, a process also known as selfcertification. OVSC also tests and inspects new vehicles to ensure that
they meet these standards. Auto manufacturers are also expected to
periodically inspect and test vehicles throughout their production period
to ensure they comply with safety standards.

•

Oversight of the identification and remedy of vehicle and equipment
defects that could pose an unreasonable safety risk—safety defects. The
agency’s Office of Defects Investigation (ODI) conducts investigations and
identifies possible safety defects in vehicles or equipment that create an
unreasonable safety risk and oversees manufacturer actions to remedy
them. ODI identifies and reviews a variety of information for trends that
could indicate the presence of a safety defect in a motor vehicle or piece
of equipment. These information sources include consumer complaints
submitted to the agency and information on fatalities, injuries, property
damage claims, and consumer complaints collected by manufacturer and
provided to the agency. Auto manufacturers also conduct their own
investigations of potential safety defects in their motor vehicles.
As part of its mission, NHTSA is responsible for overseeing two types of
recalls. Compliance recalls are initiated when vehicles or vehicle
equipment is determined to be noncompliant with applicable federal

6

Pub. L. No. 106-414, 114 Stat. 1800 (Nov. 1, 2000).

7

NHTSA also engages in activities targeted at behavioral aspects of traffic safety—for
example, through public information campaigns supporting seat belt use and against
drunken driving or distracted driving.

8

According to NHTSA, these federal safety standards are written in terms of minimum
safety performance requirements for motor vehicles or items of motor vehicle equipment.
These requirements are specified, according to the agency, in such a manner "that the
public is protected against unreasonable risk of crashes occurring as a result of the design,
construction, or performance of motor vehicles and is also protected against unreasonable
risk of death or injury in the event crashes do occur."

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vehicle safety standards, as identified by NHTSA or a manufacturer.
Compliance recalls have ranged from design issues with vehicle safety
belts to improper placement of warning labels for airbags. From 2000
through 2009, compliance recalls accounted for about 18 percent of
vehicle recalls. Safety defect recalls, which accounted for the remaining,
majority share of vehicle recalls, are initiated when a defect in a vehicle or
vehicle equipment creates an unreasonable safety risk, as determined by
NHTSA or a manufacturer. For example, the potential for a steering
column to break and suddenly cause partial or complete loss of vehicle
control could represent a safety defect and warrant a safety defect recall.
Although NHTSA also oversees compliance recalls, this report focuses on
NHTSA’s oversight of safety defect recalls, which as previously discussed
represent the majority of recalls overseen by the agency and are initiated
when a defect poses an unreasonable risk to safety. In addition, we have
limited our scope to safety defect recalls that have been initiated for
passenger vehicles, including cars, pickup trucks, sport utility vehicles,
large passenger vans, and minivans (NHTSA also oversees recalls for other
vehicles, such as motorcycles, recreational vehicles, and commercial
trucks). Finally, because the U.S. Department of Transportation Office of
Inspector General is examining NHTSA’s activities related to the
investigation of potential safety defects in motor vehicles and equipment,
we did not include safety defect investigations in our review. 9
The auto safety defect recall process for motor vehicles is a concerted
effort involving five stakeholders:
•

auto manufacturers—businesses that manufacturer, assemble, or import
motor vehicles;

•

NHTSA—the federal agency that oversees vehicle safety;

•

franchised dealerships—businesses that sell or lease an auto
manufacturer’s new vehicles;

9
The Department of Transportation’s Office of Inspector General plans to issue this report
in the summer of 2011. For more information on the Office of Inspector General, see
www.oig.dot.gov.

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GAO-11-603 Auto Safety

•

third-party data providers—businesses that collect and interpret data for
clients and assist manufacturers in identifying postal addresses of vehicle
owners with a vehicle affected by a recall; and

•

vehicle owners—purchasers or lessors of a vehicle. 10
As depicted in figure 1, these stakeholders, in particular NHTSA and auto
manufacturers, engage in a number of steps during the safety defect recall
process.

10
Lessor means a person or entity that is the owner, as reflected on the vehicle's title, of any
five or more leased vehicles, as of the date of the safety defect notification. Unless a
manufacturer notifies lessees—the persons who lease motor vehicles—directly through
agreement with a lessor, then the lessor is required to forward the initial follow-up
notifications of a recall to lessees within 10 days of receiving them.

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Figure 1: The Role of Stakeholders in the Auto Safety Defect Recall Process

Auto manufacturers

NHTSA

Investigates potential safety defects
based on data related to fatalities, injuries,
warranty claims, property damage claims,
consumer complaints, and other sources

Investigates potential safety defects
based on manufacturer data, complaints
to the agency, and reports of recalls in
foreign countries, among other sources

Sharing information

Requests that manufacturer conduct
recall or, if necessary, orders recall

Determines defect creates
unreasonable safety risk; plans
recall campaign to remedy it

Sends repair guidance to franchised
dealerships; drafts recall notification
letters for vehicle owners

Provides notification of
defect and recall plan

Provides copies of notices for franchised
dealerships and vehicle owners

Determines defect creates
unreasonable safety risk
Reviews defect information and recall plan
to remedy it

Reviews recall notices for owners for
compliance with regulations

Approves or requests changes
to recall notification letters

Third-party data provider
identifies owner addresses or
manufacturer uses internal data

Sends notices to vehicle
owners via first-class mail

Franchised dealerships perform recall
remedy; submit claims to manufacturer for
reimbursement of recall remedy work

Provide data on status of
recall campaign

Monitors effectiveness of recall
campaign; responsible for sending
follow-up notifications

Can require manufacturer to
send follow-up notifications

Monitors effectiveness
of recall campaign

Source: GAO analysis of NHTSA documents and interviews with agency officials, auto manufacturers, and industry organizations.

According to NHTSA officials, since 2000 all safety defect recalls for
passenger vehicles have been conducted voluntarily by manufacturers.
Although some of these recalls were conducted based on NHTSA’s
investigations of safety defects—known as influenced recalls—most were
initiated by manufacturers without influence from agency investigations—
known as voluntary, or “uninfluenced,” recalls (see fig. 2). For example, in
April 2011, a manufacturer expanded the scope of vehicles included in one
of the company’s safety defect recalls based, in part, on NHTSA’s own

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investigation of the defect. Moreover, NHTSA also has the authority to
order a vehicle manufacturer to conduct a recall. 11 According to NHTSA
officials, the agency has not ordered any vehicle recalls since prior to
2000, and since the agency was established, it has ordered seven recalls for
motor vehicles or equipment.
Figure 2: Total Voluntary and Influenced Safety Defect Recalls for Motor Vehicles,
2000-2009
Number of recalls
600

500

400

300

200

100

0
2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

Year
Voluntary recalls
Influenced recalls
Source: GAO analysis of NHTSA data.

Note: According to NHTSA officials, the agency did not order any vehicle recalls during this time
frame.

11

49 U.S.C. § 30118(b)(2).

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NHTSA Conducts
Oversight of Safety
Defect Recalls, and
Other Selected
Agencies Generally
Share Similar
Authorities

As part of its oversight role, NHTSA is responsible for reviewing auto
manufacturers’ planning and implementation of safety defect recalls to
ensure compliance with legal requirements. To this end, the agency is
responsible for reviewing, among other things, the manufacturer’s
description of vehicles affected by a safety defect, actions the
manufacturer plans take to remedy those vehicles through a recall, and
notification letters the manufacturer plans to send to owners of affected
vehicles. NHTSA also monitors the effectiveness of recall campaigns being
conducted by manufacturers based, in large part, on a manufacturer’s
quarterly reports showing the completion rate of a campaign. In addition,
the agency provides information and guidance to the public on recalls,
primarily through its Web site, www.safercar.gov. NHTSA and most other
selected federal agencies we reviewed generally share similar authorities
in recall processes, but the agencies’ authorities differ with regard to
penalizing manufacturers and ordering recalls. For example, in contrast to
NHTSA’s recall authority over motor vehicles, FDA’s recall authority over
some products includes a mandatory requirement for manufacturers to
recall a product regardless of any challenges a manufacturer may have to
the order. 12 Foreign agencies we reviewed also generally had similar
authorities to NHTSA, with a few exceptions. For example, unlike NHTSA,
officials from the Federal Motor Transport Authority—Germany’s agency
that oversees vehicle safety—told us they can revoke the registration of
vehicles with an outstanding safety recall.

NHTSA Oversees the
Planning and
Implementation of Safety
Defect Recalls

First, NHTSA is responsible for oversight of planning efforts by auto
manufacturers for safety defect recalls. Specifically, NHTSA reviews an
auto manufacturer’s required notification to the agency that describes a
safety defect and the manufacturer’s plan to remedy it through a recall.
The agency reviews several pieces of information that manufacturers must
include in these notifications, including the following:
•

a description of vehicles containing the safety defect, including the make,
model year, and date the vehicles were manufactured;

•

the number of vehicles potentially containing the defect and an estimate of
what percentage actually have the defect;

12

Pub. L. No. 111-353, § 206.

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•

a chronology of principal events leading up to the manufacturer’s decision
that there is a safety defect in the vehicle; and

•

a description of the manufacturer’s plan to remedy the defect through a
recall campaign.
As stated earlier, though all recalls since 2000 have been either voluntary
recalls or influenced recalls, NHTSA can also order a manufacturer to
conduct a recall. Before NHTSA can order a recall, the agency must
provide the manufacturer with an opportunity to respond to NHTSA’s
initial decision. Prior to completion of the administrative process, the
manufacturer may conduct the recall voluntarily. According to NHTSA
officials, the agency tries to convince manufacturers to conduct influenced
recalls based on NHTSA’s investigations rather attempt to prove the case
for an ordered recall through court, which the officials said can take a long
time and require substantial agency resources. NHTSA officials also told
us that manufacturers generally conduct a recall voluntarily if the agency
informs the manufacturer that it has decided that one is necessary
because, according to the officials, a manufacturer does not want to risk
receiving negative publicity in an argument against the agency’s decision.
Similarly, some manufacturers told us that if NHTSA decides that a recall
to remedy a safety defect is necessary, it is usually in a manufacturer’s
best interest to conduct one even if the manufacturer believes it is not
necessary due to the risk of negative publicity and consumer opinion.
Second, NHTSA oversees a manufacturer’s implementation of a safety
defect recall. Among other things, this includes reviewing the
manufacturer’s letter to vehicle owners notifying them of the safety defect
and the manufacturer’s recall to remedy it. In particular, NHTSA reviews
each manufacturer’s draft recall notification letter and envelope to ensure
that it includes several pieces of required information about the safety
defect, meets the legal requirement to mail the initial notification via first
class postage, and adequately motivates owners to make their vehicles
available for remedy work. 13 Among other information, a recall notification
letter must include the following items:

13
Manufacturers are required to submit draft recall notification letters to the agency at least
5 business days prior to the date that the manufacturer plans to mail them to vehicle
owners. 49 C.F.R. § 577.5(a).

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•

an opening statement that states “This notice was sent to you in
accordance with the requirements of the National Traffic and Motor
Vehicle Safety Act”;

•

a clear description of the safety defect and the malfunction that may result
from it;

•

an evaluation of the risk to vehicle safety related to the defect;

•

a description of what a vehicle owner can do to get the defect remedied;

•

a statement of precautions, if any, a vehicle owner should take to reduce
the risk that the malfunction will occur before the defect is remedied;

•

a statement indicating that remedy work is free of any cost to the vehicle
owners, unless the manufacturer is exempt from providing it free of cost; 14
and

•

on the envelope of the notification letter, inclusion of the words
“SAFETY,” “RECALL,” and “NOTICE” in all capital letters and in a font size
that is larger than that used in the address information.
NHTSA is also responsible for receiving manufacturer notifications to
franchised dealers that perform recall remedy work, which must include
information about the safety defect involved in the recall, how to remedy
it, and an estimate of when they can expect to be able to conduct the
remedy work. According to NHTSA officials, the agency may review these
notifications and provide feedback to manufacturers.

NHTSA Monitors Recall
Campaign Completion
Rates

NHTSA evaluates the effectiveness of safety defect recalls based on
several considerations, including a recall campaign’s completion rate,
which, is calculated by dividing the total population of affected vehicles by
the number of vehicles that have been remedied. To determine the
completion rate for a recall campaign, NHTSA uses data submitted by the
manufacturers. Specifically, manufacturers are required to submit
completion rate data to NHTSA through reports to the agency every

14

Manufacturers are required to provide the remedy free of cost to vehicle owners who
purchased the vehicle within 10 years of the identification of the defect. 49 U.S.C. §
30120(g). However, NHTSA officials told us auto manufacturers generally provide the
defect remedy work free of cost to all vehicle owners in all cases.

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quarter for six consecutive quarters (18 months) after the start of a recall
campaign. 15 These reports must show the total number of vehicles
recalled, the number of vehicles inspected and remedied, and the number
of vehicles determined by the manufacturer to be unreachable for
inspection due to reasons such as theft, scrapping, or export to foreign
countries. NHTSA assesses these reports against agency guidelines, or
thresholds (see table 1) and considers other factors such as the severity of
the defect and the amount of time since and the effectiveness of the
manufacturer’s last notification to vehicle owners. According to NHTSA,
the agency generally uses an internal guideline on completion rates to
assess whether renotification is warranted. When the completion rate is
considered low, the agency may require a follow-up notification. NHTSA
officials could not tell us how frequently they required follow-up
notifications.
Table 1: Minimum Completion Rate for Possible NHTSA Follow-up Notification
Request or Requirement
Quarter of recall campaign

Minimum completion rate (percent)

1

10

2

20

3

30

4

45

5

55

6

65

Source: GAO analysis of NHTSA document.

According to NHTSA officials we spoke with, after the 18-month period in
which these quarterly reports are generally required, the agency can
require the manufacturer to continue sending reports on the completion
rate. Several manufacturers also told us that they often continue to
monitor recall campaigns and send follow-up notifications beyond the first
18 months of a recall campaign whether NHTSA requires it or not.
While the factors just described provide some guidance to the agency
regarding a campaign’s effectiveness, agency officials told us that a variety
of factors can also impact a campaign and are taken into account during
the agency’s review of recall campaigns. For example, agency officials told

15

The first quarter of reporting is required to begin with the date on which a manufacturer
first sends recall notices to vehicle owners.

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us that vehicle owners’ perception of the severity of a safety defect may
impact the completion rate of a campaign. In addition, the officials said
that factors such as the age and type of vehicles in a campaign could
impact completion. NHTSA officials also told us that the completion rate
of recalls with older vehicles tends to be lower because owners of older
vehicles are less likely to make their vehicles available for recall remedy
work. Though factors such as these can impact the completion rate of a
recall campaign, agency officials told us that they do not analyze trends in
completion rate data of recall campaigns.

NHTSA Provides Guidance
and Information to Public

NHTSA also provides the public with guidance and information on safety
recalls, primarily through its Web site, www.safercar.gov. On the Web site,
NHTSA maintains a database in which the public can search for safety
recalls by entering year, make, and model of a vehicle. The agency’s Web
site also provides basic guidance on what to do in the event of a safety
recall. For example, the Web site offers guidance to vehicle owners about
what to do if they do not receive a recall notification letter but believe that
their vehicle may be affected by a recall. In addition, NHTSA officials told
us they occasionally issue press releases and consumer advisories on
safety recalls; in one case, they issued consumer advisories for a recall on
faulty cruise control systems in one manufacturer’s vehicles that could
cause vehicles to catch fire.

NHTSA and Other Federal
and Foreign Agencies
Share Similar Recall
Authorities, but a Few
Differences Exist

As table 2 shows, NHTSA and most other selected federal agencies we
reviewed are generally authorized to order a recall, but differences exist in
their ability to implement this authority, which we will describe in this
section.

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GAO-11-603 Auto Safety

Table 2: Federal Agencies’ Authorities to Order Recalls and Impose Penalties for Selected Products
Agency

Selected products reviewed

Can issue recall
order?

Recall order is
mandatory?

Can impose civil money
penalties?

NHTSA

Motor vehicles

Yes

No

Yesb

CPSC

Consumer products

Yes

No

Yes

FDA

Foods not exclusively regulated Yes
by USDA

Yes

Yes

USDA

Medical devices

Yes

Yes

Yes

Human drugs

No

No

No

Meat, poultry, egg products

Noa

N/A

Yesc

Source: GAO analysis of applicable laws and regulations.
a

USDA officials told us that although they cannot order a recall, they can request manufacturers to
conduct one voluntarily. In addition, agency officials told us that USDA’s authority to seize and detain
products was sufficient and that, therefore, authority to order a recall was not necessary.
b

In certain cases, where NHTSA does not have authority to impose civil penalties, it can refer the
matter to the U.S. Department of Justice for civil proceedings where civil penalties may be imposed.

c

USDA can impose civil monetary penalties of up to $7,500 for egg products. Criminal penalties can
be imposed for meat and poultry.

All of the agencies can impose penalties for some or all of the selected
products 16; however, there is some variation in the penalties. For example,
NHTSA can currently impose fines on manufacturers up to $17.350 million
for violations of requirements relating to the recall process for safety
defects. 17 In 2010, the agency twice imposed the maximum penalty of
$16.375 million each from Toyota for failing to timely notify the agency of
defects involving accelerator pedals. CPSC can impose a similar maximum
fine of $15 million, while FDA can impose maximum fines that range from

16

In certain cases, where NHTSA does not have authority to impose civil penalties, it can
refer the matter to the U.S. Department of Justice for civil proceedings where civil
penalties can be imposed.

17

NHTSA is authorized to impose a fine of not more than $5,000 for each violation and a
maximum of $15 million for a related series of violations. 49 U.S.C. § 30165(a). At least
every 4 years NHTSA reviews the amount of the fines and, if appropriate, is authorized to
adjust the fines. Currently, NHTSA has adjusted the fines to not more than $6,000 for each
violation and to a maximum of $17.350 million for a related series of violations.

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GAO-11-603 Auto Safety

$500,000 for food products to $1 million for medical devices; 18 however,
the agency does not have authority to impose monetary fines for violations
related to the recall process for human drugs. USDA can impose a
maximum fine of $7,500 for egg products; USDA officials told us they can
also impose administrative penalties. 19 For example, the officials told us
that USDA can withhold the “USDA Inspected and Passed” mark of
inspection, effectively shutting down a manufacturer’s operations. Once a
product is in commerce, USDA may detain the product and petition a U.S.
court to seize it.
In addition, we found that while three of the four agencies have the
authority to order a recall, only one—FDA—has mandatory recall
authority, which sets a mandatory requirement for a manufacturer to
conduct a recall based on an agency’s determination of a safety defect
regardless of any challenge the manufacturer may have to the recall order.
Specifically, though NHTSA and CPSC have authority to order
manufacturers of selected products that they regulate to conduct a recall,
manufacturers can challenge either agency’s order in court and during this
challenge can refrain from conducting a recall campaign and continue to
sell the potentially unsafe product pending the outcome of the challenge. 20
Unlike NHTSA and CPSC, FDA has mandatory recall authority, meaning
manufacturers whose products are subject to this authority face a
mandatory requirement to conduct a recall and refrain from distributing
their product to retailers, regardless of any challenge the manufacturer
may make to the order. In addition, CPSC’s authority applies to retailers of
products affected by a recall order, which includes a requirement for
retailers to refrain from selling the affected product. Moreover, CPSC has
authority to issue public health and safety findings in order to warn the

18

CPSC can impose a fine of not more than $100,000 for each individual violation and a
maximum of $15 million for a related series of violations. 15 U.S.C. § 2069(a)(1). For food
products under FDA’s authority, any person who introduces into interstate commerce or
delivers for introduction into interstate commerce an article of food that is adulterated or
any person who does not comply with a recall order shall be subject to a civil money
penalty of not more than $50,000 in the case of an individual and $250,000 in the case of any
other person for such introduction or delivery, not to exceed $500,000 for all such
violations adjudicated in a single proceeding. 21 U.S.C. § 333(f)(2)(A). For medical devices
under FDA's authority, fines are $15,000 for each violation and a maximum of $1 million for
all violations adjudicated in a single proceeding. 21 U.S.C. § 333(f)(1)(A).

19

21 U.S.C. § 1041.

20

49 U.S.C. § 30118(b)(2); 15 U.S.C. § 2064(d)(1).

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GAO-11-603 Auto Safety

public about products that the agency determines pose a safety risk. 21
CPSC officials added that in some cases this authority has proven
sufficient in convincing manufacturers to conduct recalls voluntarily.
FDA’s mandatory recall authority applies to some, but not all, products
regulated by the agency and included in our review. Specifically, although
FDA has mandatory recall authority over food products and medical
devices, it does not have mandatory recall authority over human drugs.
USDA is the only agency we reviewed that does not have the authority to
order a manufacturer to conduct a recall, or require the manufacturer to
replace or refund the cost of an unsafe product. USDA officials told us,
however, that they do not consider this a challenge in addressing unsafe
products regulated by the agency because the agency has the authority to
detain products deemed unsafe by the agency for 20 days if a
manufacturer does not do so voluntarily. FDA and CPSC also have
authority to detain some of the products that they regulate.
NHTSA’s authorities in the auto safety recall process are also generally
similar to those of agencies with auto safety recall authority in Canada,
Germany, Japan, and the UK (see table 3), with some exceptions. 22 For
example, officials from all of the agencies we reviewed told us their
agency can establish requirements for safety recall campaigns. Moreover,
officials from all but one of the selected foreign agencies we reviewed told
us manufacturers must notify them of safety defects. Similarly, officials
from all but one of the foreign agencies we spoke with told us they have
authority to impose penalties, such as fines, if manufacturers do not
comply with laws or regulations.
However, the authorities of the foreign agencies we spoke with differed to
some extent. For example, unlike NHTSA or the other foreign agencies,
Germany’s Federal Motor Transport Authority has the authority to revoke

21

15 U.S.C. §. 2055(b)(5)(d).

22

The auto safety recall authorities of Germany and the UK are based, in part, on European
Union (EU) directives. Officials from Germany and the UK told us that their national laws
pertaining to the recall process are based on laws that apply to safety standards for all
consumer products, which, in turn, are based on the EU’s law pertaining to general product
safety. EU officials told us that the EU requires that all of its member states conduct risk
assessments of potential safety defects in products, such as motor vehicles, and ensure that
manufacturers take actions to remedy these risks. According to the officials, member
states must also report safety defects to the EU so that they can be posted to a Web-based
system accessible to the public.

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GAO-11-603 Auto Safety

the registration of a vehicle for owners who have not complied with an auto
safety recall notice. Specifically, the officials we spoke with from the
Federal Motor Transport Authority said that if the risk of the safety defect is
determined to pose a threat to persons other than the vehicle owner, then
they can revoke the registration on that vehicle until the recall remedy is
completed, unlike in the United States, where NHTSA has no such authority.
According to the officials, in 2010, Germany revoked owners’ registration
due to outstanding safety recalls more than 1,000 times, and in general the
agency regularly uses this authority. In addition, among the agencies we
reviewed, only Transport Canada, Canada’s agency that oversees auto
safety, does not have the authority to order a manufacturer to conduct a
recall. Officials from Transport Canada we spoke with added, however, that
the agency can prosecute a manufacturer on criminal charges if the
manufacturer does not notify vehicle owners after identifying a safety
defect. Moreover, officials from the Ministry of Land, Infrastructure,
Transport and Tourism (MLIT)—Japan’s agency that oversees auto safety—
told us that while auto manufacturers are required to notify the agency
about safety recalls, they are not required to notify it about safety defects.
Table 3: NHTSA and Selected Foreign Agencies’ Auto Safety Recall Authorities
Can order auto
manufacturer
to conduct a
recall

Can establish
requirements for
auto manufacturer
recalls

Can revoke
registration of
vehicles with an
outstanding safety
recall

Country

Agency

Requires auto
manufacturers to
notify agency about
safety defects

Can impose
penalties on
auto
manufacturers

United States

NHTSA

Yes

Yes

Yes

No

Yes

Canada

Transport
Canada

Yes

No

Yes

No

Yes

Germany

Federal Motor Yes
Transport
Authority

Yes

Yes

Yes

Yes

Japan

MLIT

No

Yes

Yes

Noa

Nob

United
Kingdom

Vehicle
Operator and
Services
Agency

Yes

Yes

Yes

No

Yes

Source: GAO analysis of U.S. laws and regulations and foreign agencies’ authorities based on comments of officials representing the
foreign agencies.
a

According to MLIT officials, the agency can order users to repair their vehicles if the defects of the
recalled vehicles are serious and should be removed immediately.

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GAO-11-603 Auto Safety

b

According to MLIT officials, both criminal and administrative penalties are determined by the court
according to the provisions in laws. In the case of criminal penalties, including fines and
imprisonment, MLIT can report violations to the prosecutor’s office. Based on MLIT’s report, the
prosecutors will indict auto manufacturers or employees of the companies for the violation of the law.
Then based on the judgment of the court, auto manufacturers may face such penalties. In the case of
administrative penalties including fines, MLIT can report the violation to the court. Then, based on the
decision of the court, auto manufacturers pay fines to the government coffer.

Auto Industry
Stakeholders Are
Generally Satisfied
with the Recall
Process for Safety
Defects, but Several
Challenges May Affect
Recall Completion
Rates

Manufacturers Reported
Clear Requirements and
Open Communication as
Benefits of NHTSA’s Role
in the Recall Process for
Safety Defects

Although industry stakeholders were generally satisfied with the recall
process for safety defects, certain challenges may affect the completion
rate of recalls. For example, about half of the auto manufacturers we
spoke with told us that NHTSA’s regulatory requirements were clear in
conveying what was expected of them in the recall process. Likewise,
many manufacturers said NHTSA fostered open communication, allowing
for two-way interaction that aided in prompt resolution of problems when
they arose. Franchised dealerships were generally pleased with how
manufacturers reimbursed them during the recall process for safety
defects, although some expressed concerns, such as sometimes learning
about safety defect recalls at the same time as the public and not always
having the parts available for repair when recalls are announced. In
addition, we found five challenges that may affect the completion rate of
safety recalls:

•

identifying and notifying vehicle owners of auto safety defects,

•

motivating vehicle owners to comply with notification letters,

•

providing better information to vehicle owners and the public,

•

using existing data to improve completion rates of recall campaigns, and

•

lacking the authority to require manufacturers to notify used-car
dealerships of recalls and to require used-car dealerships to notify
potential buyers of the existing defect.

Manufacturers we spoke with were generally satisfied with the recall
process for safety defects and stated that NHTSA’s role in this process is a
key benefit. Many manufacturers reported that the process is working well
because the regulatory requirements are clear and, as a result, they know
exactly what is expected of them in the process and by when. For
example, some manufacturers stated that requirements for the auto safety
defect recall process were well-defined and, because of this, there is little
confusion about what manufacturers needed to do after a recall decision is

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GAO-11-603 Auto Safety

made. Some manufacturers also reported that a benefit of the safety defect
recall process is the open and cooperative communications between
NHTSA and the manufacturers. For example, some manufacturers pointed
out that they and NHTSA have established clear points of contact for
addressing issues during recall campaigns. These channels of
communication made it easier and less time consuming to resolve issues
when they arose. Likewise, manufacturers told us they were generally
pleased with how promptly NHTSA approved their defect notification
letters—sometimes within 1 to 2 days—which facilitates their ability to
implement recalls for safety defects in a timely manner.
Other benefits were cited, as well. Most manufacturers we spoke with
stated that the requirement to use first-class mail to notify vehicle owners
of safety defects was appropriate and effective because, for example,
postal mail is a recognizable form of communication to most vehicle
owners, allows uniform delivery of the same message to all affected
vehicle owners, and allows the manufacturer to track the receipt of
notification letters. Additionally, one manufacturer we spoke with noted
that the National Traffic and Motor Vehicle Safety Act had been around for
decades, and questions and concerns had already been litigated—resulting
in a well-understood law.

Franchised Dealerships
Reported Reimbursement
for Recall Remedy Work as
a Benefit of the Recall
Process for Safety Defects
but Expressed a Few
Concerns

Franchised dealerships we spoke with generally told us they were satisfied
with how manufacturers reimburse them for remedying vehicles with
safety defect recalls. Moreover, several franchised dealerships told us that
service work related to recalls is profitable for dealerships. One of these
dealerships added that this served as an incentive to the dealer to seek out
and repair used vehicles in their inventory that may have an outstanding
recall.
However, the franchised dealerships we interviewed also expressed a few
concerns. First, some dealerships told us that manufacturers do not notify
them as promptly as they would like about recalls; as a result, they learn
about some recalls at the same time as the general public through the
media. Consequently, the dealership may have inquiries from customers
about bringing their cars in for repair before the dealer knows about the
recall. Second, dealerships expressed concern that parts are not always
readily available when recalls are announced, which they said can be an
inconvenience to customers who come to the dealership expecting to
immediately have the remedy work completed. Two manufacturers told us
that the delay in supplying dealerships with parts has, in part, resulted

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GAO-11-603 Auto Safety

from many parts suppliers going bankrupt or out of business during the
recent economic crisis and that they are working to address the problem. 23

Five Key Challenges May
Affect Recall Completion
Rates
Identifying and Notifying
Vehicle Owners of Auto Safety
Defects

Some manufacturers told us that notifying vehicle owners about safety
defects can be difficult for a few reasons. For example, one manufacturer
said the process was challenging because not all vehicle owners keep their
address information up-to-date with state motor vehicle registration
offices. In addition, several other manufacturers told us that identifying
the current mailing addresses for older vehicles is especially difficult
because these vehicles often have multiple changes of ownership and,
thus, mailing addresses, which compounds the problem. NHTSA and
several manufacturers told us that the completion rates for recall
campaigns with older vehicles were generally lower than the rates for
campaigns with newer model vehicles, although NHTSA officials stated
they have not conducted any formal analyses to confirm this. Third-party
data providers that manufacturers use to collect owner information
confirmed the challenges associated with identifying current vehicle
owner addresses. For example, one of the third-party data providers we
spoke with stated that mailing addresses for owners of newer vehicles are
more current and become less reliable as vehicle ownership changes
hands. In addition, they highlighted several other challenges to obtaining
up-to-date information, including state privacy laws—some of which
require the signature of the vehicle owner before a state motor vehicle
agency can release contact information.
Focus group participants and some manufacturers we spoke with also
indicated that new or additional methods of communicating recall
information to consumers—in addition to the postal mail notifications

23

In November 2009, a survey by the Original Equipment Suppliers Association—a leading
auto supply industry group—reported that at least 43 U.S.-based auto suppliers had filed
for Chapter 11 bankruptcy protection in 2009. Also in 2009, a consultant group estimated
that as many as 30 percent of North American suppliers were at high risk of failure.

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GAO-11-603 Auto Safety

currently in use—could help increase recall completion rates. 24 For
example, some focus group participants indicated that they would be more
likely to respond to defect notices if they received notice of the defect by
phone or through e-mail, in addition to the standard first-class mailing, and
some focus group participants recommended the use of multiple contact
methods.
Our focus groups with vehicle owners demonstrated that NHTSA and
manufacturers may face difficulties in motivating vehicle owners to
comply with recall notification letters. Although manufacturers are
responsible for drafting notification letters and notifying vehicle owners of
a defect, NHTSA is responsible for approving the letters’ contents. As
stated earlier, NHTSA is responsible for ensuring that the letters contain
certain items that (1) inform owners of defects in a clear and
understandable manner and (2) effectively motivate owners to have their
vehicles remedied. However, our focus group participants revealed that
though some of them would comply with a recall notice in any
circumstance, the willingness of others to comply depends on vehicle
owners’ perceptions of three primary factors:

Motivating Vehicle Owners to
Comply with Notification
Letters

•

the severity of the defect—how urgent vehicle owners perceive the recall
to be;

•

the convenience of the defect remedy—the time projected to fix the
defect, as well as whether the dealership provides an alternate mode of
transportation during service; and

•

the cost of the recall remedy—the perception of how much it will cost the
vehicle owner to have the defect remedied (by law, a recall remedy is free
of cost to vehicle owners who purchased the vehicle within 10 years of the
defect being identified and, according to NHTSA, is generally provided
free in all cases).
Moreover, while NHTSA has no ability to control many aspects of a recall
campaign, such as the severity of the defect, the agency can control how
these and other issues are presented in the defect notification letters,

24

We convened 10 focus groups of vehicle owners in five cities—Chicago; Dallas;
Richmond, Virginia; Salina, Kansas; and Seattle—to determine vehicle owners’ awareness
of auto safety recalls, their willingness to comply with defect notification letters, and
potential options for improving safety defect notification letters. For more information, see
appendix I.

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GAO-11-603 Auto Safety

which may affect whether vehicle owners are motivated to comply. Focus
group participants responded that they preferred letters that included
certain elements. As a result, including these elements in a defect letter
may positively affect whether and how quickly they respond to a recall.
The focus groups we convened reviewed three defect notification letters
from three separate manufacturers and indicated they would prefer the
following elements in a defect letter, which may lead to higher rates of
responding to a defect notice: 25
•

a clear explanation of the severity of the defect, including an explanation
that does not use jargon, which can be confusing. For example, instead of
using the acronym “ABS,” focus group participants would prefer the words
“anti-lock brake system.”

•

the word “urgent” to indicate the seriousness of the defect.

•

a question-answer format because, as one participant described, it spells
out the issue, provides an immediate answer, and allows recipients to pick
and choose the parts that are most necessary to read.

•

an apology from the manufacturer.

•

the owner’s vehicle identification number (VIN) information. As one
participant explained, including a VIN in the body of the defect
notification letter clarifies whether this recall applies to the owner’s
vehicle.

•

readable font size.

•

an indication of whether there is any cost involved with the recall remedy.
In addition, we asked focus group participants to review three defect
notification envelopes to gauge their perceptions of the envelope style and
format and the likelihood that they would be willing to open each
envelope. Though the focus groups reached less consensus on what style
and format of envelope they would be most likely to open, participants did
reveal that they preferred envelopes that included the word “urgent,” and
some preferred envelopes that did not have technical or confusing
language. For example, one participant stated that she liked the envelope

25

See appendix II for copies of the three defect notification letters and three envelopes
reviewed by the focus group participants.

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GAO-11-603 Auto Safety

that said “urgent air bag safety” because it described the issue in concise
terms. In addition, several focus group participants liked the use of
color—red shadowing, for example—to indicate the envelope’s
importance, and were more in favor of envelopes without VIN information
on the envelope itself.

Providing Better Information to
Vehicle Owners and the Public

Our focus groups revealed that many vehicle owners may not be familiar
with the Web site www.safercar.gov—NHTSA’s primary means of
communicating defect information to the public. While the Web site is
meant to provide vehicle owners and the public with valuable safety defect
information, discussions with focus group participants revealed that few
knew that the Web site existed or ever used the Web site to learn of
recalls. For example, none of the almost 90 participants said they were
familiar with www.safercar.gov and more noted that they use Google
when they search for information related to safety defects. 26
Among other things, www.safercar.gov allows vehicle owners and the
public:

•

to set up an RSS—Really Simple Syndication—feed that provides recall
information via a computer or mobile device, updated daily, on safetyrelated recalls for vehicles, among other things. 27

•

to subscribe to NHTSA’s Recall Notification E-mail System and elect to
receive a weekly e-mail that summarizes the vehicle recalls for the past 7
days or to select up to five vehicles by make, model, and year about which
to receive recall notifications.

•

to search a recall database for vehicle recalls by make, model, year, and
component, among other things.
However, the information NHTSA provides on its Web site could be more
useful. In particular, a centralized database (developed by NHTSA or
another party) that allows consumers to search for recall information by

26

CPSC sponsors www.recalls.gov, which provides information on, among other things,
consumer product recalls and auto safety recalls. Six federal regulatory agencies,
including NHTSA, participate in recalls.gov. In addition to searching for safety recalls,
consumers may access a list of recent recalls issued by each of the six agencies.
Consumers may also subscribe to e-mail alerts from four of the six agencies, including
NHTSA.

27

Each new recall will remain available on the RSS feed for 7 days.

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GAO-11-603 Auto Safety

VIN would allow vehicle owners to determine if their specific vehicle is
affected by a recall. Several used and franchised car dealerships we spoke
with noted that having a database to search for recalls by VIN would allow
those who may not have been informed of recalls through a notification
letter to determine whether the vehicles they possess have outstanding
safety recalls. Although NHTSA has not developed a centralized VIN
database, most of the manufacturers we interviewed allow their customers
to access VIN-specific recall information for their vehicles in a few ways.
Some manufacturers, for example, provided their customers and the
public with online access to VIN-specific recall information, but only if
their customers registered on the manufacturer’s Web site first. Other
manufacturers, however, allowed their customers access to this
information online without requiring customer registration. Seven of the
manufacturers that provide online VIN-specific recall information told us it
would be beneficial to have a centralized NHTSA Web page that provides
links to online VIN information. Manufacturers that did not provide online
access to VIN recall information allowed their customers to call the
manufacturers’ toll-free customer service number or sign up for e-mail
notifications to obtain VIN recall information on their vehicles.
NHTSA officials we spoke with agreed that additional efforts could be
made to improve the awareness of www.safercar.gov and told us that the
agency is currently redesigning its Web site to consolidate information so
that consumers can more easily find information on vehicle 5-Star Safety
Ratings and auto safety recall information. 28 According to agency officials,
upgrading the Web site to include VIN information would be helpful for
vehicle owners but would require significant resources to implement.
However, the agency is in the process of purchasing software to facilitate
a VIN-based search engine on its Web site.

Using Data to Improve
Completion Rates of Recall
Campaigns

NHTSA is not consistently using the data it collects from manufacturers to
improve the completion rates of recall campaigns. As previously
discussed, according to NHTSA officials, on average about 70 percent of
all vehicles subject to a recall are fixed within the 18-month period during
which manufacturers provide recall completion data to the agency.
However, our analysis of NHTSA’s completion rate data for passenger
vehicle recalls from 2000 through 2008 found considerable underlying
variation in completion rates in several areas. Overall, we found that

28

NHTSA’s 5-Star Safety Ratings measure the crash worthiness and rollover safety of
vehicles. Five stars indicate the highest rating, one star indicates the lowest.

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GAO-11-603 Auto Safety

annual recall completion rates varied substantially by year—from about 55
percent to 75 percent—for all passenger vehicles with safety defect
recalls, with an average across all years of about 65 percent. 29 In addition,
our analysis revealed that within any given year, some manufacturers have
safety defect recall completion rates as low as 23 percent to 53 percent per
year, whereas other manufacturers have completion rates between 90
percent and 96 percent (see fig. 3). Furthermore, some manufacturers
have consistently higher or lower rates across the 9 years we included in
our analysis.
Figure 3: Average Recall Completion Rates by Manufacturer, 2000 through 2008
Year
2008
2007
2006
2005
2004
2003
2002
2001
2000
0

10

20

30

40

50

60

70

80

90

100

Percent

Lowest manufacturer completion rate
Average manufacturer completion rate
Highest manufacturer completion rate
Source: GAO analysis of NHTSA data.

29
NHTSA does not have a separate category in their data for “passenger vehicles.” For our
analysis we excluded motorcycles, commercial vehicles, trailers, recreational vehicles, and
car seats. Furthermore, we included only safety defect recalls for vehicles from the top 21
manufacturers in terms of U.S. market share according to Ward’s Automotive Group from
2000 through 2008. All data for 2009 or 2010 was excluded because recall completion data
for recalls initiated during late 2009 or 2010 would not have matured a full 18 months (6
quarters) at the time of our analysis. After these exclusions, our analysis included 1,028
safety defect recall campaigns representing about 88 percent of all affected vehicles
recalled by manufacturers from 2000 through 2008.

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GAO-11-603 Auto Safety

Note: The figure includes the automobile manufacturer completion rates for the 1,028 passenger
vehicle recalls that were initiated from 2000 through 2008. The completion rate is calculated after the
6th quarter following the initiation of the recall.

Similarly, completion rates for safety defect recalls involving
components—items such as brakes and fuel systems—varied from 46
percent to as high as about 80 percent (see fig. 4). In particular, recall
completion rates involving air bags and vehicle speed control (e.g., cruise
control) systems resulted in some of the lowest completion rates across all
components at 60 percent and 46 percent, respectively.
Figure 4: Variation in Recall Completion Rates, by Component Recalled
Defective component

Average

Parking Brakes

(14)

Tires

(16)

Equipment

(21)

Wheels

(22)

Latches/Locks/Linkages

(25)

Structure

(25)

Seats

(27)

Vehicle Speed Control

(44)

Visibility

(44)

Exterior / Interior Lighting

(47)

Engine and Engine Cooling

(58)

Seat Belts

(65)

Suspension

(68)

Steering

(70)

Power Train

(75)

Electrical System

(84)

Air Bags

(85)

Service Brakes

(90)

Fuel System

(145)
0
10
20
Completion rate

30

40

50

60

70

80

90

Source: GAO analysis of NHTSA data.

Notes: The figure includes recall completion rates, averaged across all years, for component
categories as defined by NHTSA. The completion rates are associated with passenger vehicle recalls
initiated from 2000 through 2008.
Components in the “visibility” category refer to items that affect vehicle lighting such as headlamps,
side marker lamps, reflectors, and tail lamps. Components in the “equipment” category include
vehicle accessories and after-market equipment, including lighting, trailer hitches, bike racks, and
heated car seat covers, among other things.

We found less variation across vehicle types; from 2000 through 2008, the
average recall completion rate was 67 percent for passenger cars, 72

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GAO-11-603 Auto Safety

percent for sport utility vehicles and passenger vans, and 65 percent for
pickup trucks.
Using the data that NHTSA collects to conduct a broader aggregate-level
analysis across all campaigns may help NHTSA determine some of the
factors that are associated with higher or lower rates of compliance. As
mentioned previously, NHTSA monitors recall campaign completion rates
by collecting data on a quarterly basis, including the date a vehicle owner
is notified of a recall, the number of vehicles involved, the number of
vehicles remedied, and the number of vehicles that are unreachable (e.g.,
stolen, scrapped, unable to notify owner, and so forth). In particular,
NHTSA officials told us they evaluate the effectiveness of a recall
campaign by comparing a specific recall campaign’s progress to similar
campaigns based on factors such as the age of vehicles recalled and the
number of vehicles recalled. However, the agency does not currently use
the data it collects to conduct a higher-level analysis across all campaigns
to systematically look for potential factors related to higher or lower recall
completion rates that might be helpful in identifying successful recall
campaigns because conducting such analyses is resource intensive. Based
on our analysis of NHTSA data, without conducting a broader aggregatelevel analysis to look for outliers, patterns, or trends, the agency may be
missing an opportunity to identify underlying factors that affect recall
campaign completion rates.
NHTSA officials told us that although their goal for each recall campaign is
a 100 percent completion rate, there are a number of factors affecting
completion rates that are outside of NHTSA’s control—such as whether
vehicle owners read recall notices or their perception of the severity of a
defect. In addition, NHTSA officials explained that monitoring recalls on a
campaign-by-campaign basis provides them with the flexibility necessary
to capture the unique aspects of each recall campaign and that by focusing
on communication and discussion with manufacturers, the agency can
develop solutions to improve completion rates when a campaign is
achieving a completion rate that is below its expectation. While we agree
that completion rates are affected by a number of factors, including a
vehicle owner’s perception of defect severity, conducting additional
analyses could help the agency determine some of the factors that are
associated with higher or lower rates of compliance.

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Limited Authorities

Under federal law, NHTSA can order a manufacturer to give notification of
a defect or noncompliance with motor vehicle safety standards to the
owners, purchasers, and franchised dealers, as well as order the
manufacturer to remedy the defect. 30 However, NHTSA cannot require
used-car dealers (or franchised dealerships that sell used vehicles) to
notify potential buyers of an outstanding safety defect or require that they
get the defect remedied prior to sale. 31 Used-car dealerships we spoke with
told us that when they become aware of a vehicle defect, they either
remedy the defect before the sale of the vehicle or notify potential buyers
of the safety defect because it is a good business practice. Nevertheless, in
some instances, a used-car dealer may not be aware that an outstanding
safety defect exists in a vehicle. In particular, a used-vehicle dealer
association with over 20,000 members told us that because used dealers do
not have a franchise agreement with the manufacturers, they do not
receive the defect notices that manufacturers send to franchised dealers.
Moreover, used-car dealers we spoke with told us that generally they do
not receive defect notices from manufacturers, except in certain cases,
such as when a used dealer purchases previously leased vehicles directly
from a manufacturer.
The rental car companies we spoke with each told us that, unlike used-car
dealerships, they generally receive defect notification letters regarding
affected vehicles in their fleets, and although they are not required to
remedy a defect, they have developed a system for dealing with recalls.
One company described a two-tiered system to address safety defects in
which vehicles are placed on a “soft-hold”—meaning that the cars can still
be rented but will be put in the queue for service—if the defect is not a
safety issue. If the defect is a safety issue, these vehicles will be placed on
a “hard-hold”—meaning that the cars will be taken out of service
immediately and will not be rented until the repair has been made. Each of
the rental car companies described a similar system that they used to
address recall safety issues.

30

49 U.S.C. § 30118(b)(2). While NHTSA can order the manufacturer to remedy the defect,
according to NHTSA officials, the process of remedying vehicles is overseen by the
manufacturer with minimal involvement from NHTSA. The process of remedying defects
primarily involves the manufacturer and franchised dealers.

31
Franchised dealers that sell new motor vehicles may sell or lease the motor vehicle only if
the defect has been remedied before delivery of the motor vehicle under the sale or lease.
49 U.S.C. § 30120.

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The stakeholders we interviewed had mixed views on whether usedvehicle dealerships and rental car companies should be required to notify
potential buyers of outstanding safety recalls prior to sale. Several
manufacturers we spoke with indicated that it was reasonable to require
used-car dealerships to notify the potential buyer of a defect prior to sale.
A number of the manufacturers also supported requiring dealerships to get
used vehicles with safety defects remedied before selling them to the
public. However, the used-vehicle dealer industry association and usedvehicle dealerships we spoke with cited a few difficulties in doing so.
First, as previously discussed, used-vehicle dealers do not receive the
defect notification letters that manufacturers send to franchised dealers,
and as a result, they are generally not notified of a safety defect. Second,
there is no single source of information on safety recalls—such as a
centralized VIN database—that can be accessed to determine if a car in a
dealership’s possession has an outstanding recall. Instead, according to
the used-car dealerships we spoke with, they must go through ad-hoc
channels to find out about a defect—often by purchasing vehicle history
reports such as CarFax (which may not always have up-to-date and
accurate information, according to the dealerships) to determine, vehicle
by vehicle, whether cars on their lots are subject to outstanding recalls. 32
Since NHTSA cannot require that used-car dealers receive notification of
defects, in some cases the used-car dealers may be unable to notify
potential buyers of outstanding defects. With over 35 million used cars
sold by used and franchised dealerships in the United States in 2009 alone,
this could pose a significant risk to the safety of millions of vehicle drivers
and may have a negative impact on recall completion rates. 33
In addition, although NHTSA has the authority to order a recall, the agency
does not have “imminent hazard” authority. As initially proposed in the
111th Congress, imminent hazard authority would permit NHTSA to order
manufacturers to stop further production, sale, or distribution of vehicles
containing a defect found to present an imminent hazard to public safety
that may result in death or serious bodily harm. 34 According to NHTSA,

32

CarFax reports are available on all used cars and light trucks model year 1981 or later
using the unique 17-character VIN. These reports check for information on a vehicle’s
history such as title information; accident indicators, including air bag deployment; and
recall information.

33

National Independent Automobile Dealers Association, Used Car Industry Report
(2010).

34

Motor Vehicle Safety Act of 2010, S. 3302, 111th Cong. (2010). This bill was not enacted in
the 111th Congress.

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imminent hazard authority would allow the agency to bypass the lengthy,
resource-intensive court process currently needed to prove that a safety
defect exists before ordering a recall. NHTSA officials told us that if they
were to obtain imminent hazard authority, they could more expeditiously
enforce a recall when severe safety defects are present.

Options Exist to
Improve NHTSA’s
Safety Defect Recall
Process

Based on our interviews with industry stakeholders, our interviews with
focus group participants, foreign agencies, and NHTSA, and legislation
proposed in the 111th Congress, we have identified several recurring
options or changes that could address some of the challenges to the safety
recall process. Most of the options have both advantages and
disadvantages that will require careful consideration before they are
adopted.

Adopting Additional
Defect Notification
Methods

Notifying vehicle owners of a recall through other methods in addition to
postal mail may increase recall completion rates. As we previously
described, participants in the focus groups indicated that they might be
more encouraged to respond to a recall notice if they were notified of a
recall by methods other than postal mail. In fact, other federal agencies
and some manufacturers use other notification techniques to notify
consumers of a defect:
•

FDA and USDA issue press releases about recalls since the owners of
many products they regulate are not identifiable through a registration
process. However, the level of publicity that press releases receive in the
media (for example, on television and in newspapers) is subject to
discretion of the media outlets, which one manufacturer noted can be
inconsistent and unpredictable.

•

A few manufacturers we spoke with encourage dealerships to
communicate with vehicle owners through phone calls and e-mails to
notify the vehicle owner of a recall and encourage them to bring the
vehicle in for service.

•

Finally, a few manufacturers have begun or are currently pursuing the use
of telematic systems (such as GM’s OnStar technology) to alert vehicle
owners to recalls in real time by calling or sending messages directly to
vehicles notifying owners of outstanding recalls.

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However, according to some manufacturers we interviewed, there are
disadvantages to using e-mail and phone calls as ways of communicating
recall information to consumers. First, several manufacturers noted that
vehicle owners change e-mail addresses and phone numbers frequently. In
addition, they noted that there is no requirement that a vehicle owner must
register a phone number or an e-mail address with a state motor vehicle
agency, unlike postal mailing addresses—which are tied to vehicle
registration.

Modifying Safety Defect
Notification Letters

NHTSA may have opportunities to improve recall completion rates by
modifying the requirements for manufacturers’ safety defect notification
letters. Responses from our focus group participants indicated they would
prefer defect notices to include additional information, which would likely
lead to higher rates of consumer responses to these notices. Specifically,
as we previously noted, focus group participants reported that notification
letters they reviewed did not always convey a clear description of the
defect or the severity of the defect. Such confusion could affect their
willingness to take their vehicles in for service and, ultimately, reduce the
recall completion rates for certain recall campaigns. In addition, focus
group participants indicated they may be more likely to respond to a
notification letter identifying that the defect affected their vehicle
specifically and that explained that vehicle owners could have their
vehicles repaired at no charge.
Though some information is already required by law and regulations,
NHTSA has the ability to add requirements to the defect notification
letters, as previously described. 35 Rental car companies we spoke with also
stated that a better indication of the severity of the recall would help them
determine how to treat recalled vehicles in their fleets and reduce
confusion. For example, the rental car companies told us that
understanding the urgency of a safety recall is especially important
because rental car companies must use the defect notification letters they
receive to make decisions about whether to continue to rent vehicles to
consumers before the car is repaired or ground an entire fleet of vehicles,
which could result in a significant loss in revenue. NHTSA officials told us

35

NHTSA requires defect notification letters to have (1) a notation on the envelope that
include the words “SAFETY,” “RECALL,” and “NOTICE” in all capital letters and in a font
different from the address information; (2) a clear description of the defect; (3) an
evaluation of the risk to vehicle safety related to the defect; and (4) a statement of
measures to be taken to remedy the defect. 49 C.F.R. § 577.5.

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that the agency has recommended to the rental car companies that they
should not rent recalled vehicles until the defect has been repaired.
In addition, NHTSA officials we spoke with told us that they review and
approve each defect owner notification letter to make sure it meets the
current requirements but have not developed a standard template for
notification letters because each recall is different. In addition, NHTSA
officials told us that although they are working toward increasing recall
campaign completion rates, they believe that adding content to the
notification letters could be distracting and that the fundamental
information needed to convey the defect, the actions the owner should
take, and the remedy program is covered by the current requirements.
While we agree that adding lengthy and complex information to the
notification letters is unnecessary, our focus groups have shown that a
more clear description of the severity of a defect without the use of jargon
and the addition of content such as the owner’s VIN may encourage
vehicle owners to comply with defect notifications.

Publicizing Existing
Resources and Making
VINs Available to Vehicle
Owners and the Public

As previously described, our focus groups with vehicle owners indicated
that the public may not be aware of NHTSA’s Web site, the primary
method of communicating information on recalls to consumers. In
addition, a few industry associations told us that it would be useful to
provide vehicle owners with the ability to search more easily for recall
information using their VINs. As such, NHTSA has an opportunity to make
vehicle owners and the public more aware of its Web site and to include
more useful information. In order to so, NHTSA could develop public
service announcements and additional press releases or collaborate with
auto manufacturers to develop methods of informing vehicle owners about
available resources. NHTSA officials we spoke with agreed that additional
efforts could be made to improve the awareness of www.safercar.gov and
told us that the agency is currently redesigning its Web site to consolidate
information so that consumers can more easily find information on vehicle
5-Star Safety Ratings and auto safety recall information. In addition,
legislation from the 111th Congress contained provisions that would have
required NHTSA to improve public accessibility to information on its
vehicle safety websites. 36

36

S. 3302; Motor Vehicle Safety Act of 2010, H.R.5381, 111th Cong. (2010).

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NHTSA officials told us they are interested in finding additional ways to
improve vehicle owners’ access to specific information about recalls, and
to that end, they are in the process of purchasing software to facilitate a
VIN-based search engine on its Web site. However, the agency noted that
developing a centralized VIN database would require significant additional
resources to fully implement. In addition, agency officials told us that VIN
searches can present problems because vehicle owners may not enter VIN
information correctly into a Web site. NHTSA officials are currently
exploring ways to address this issue.

Developing National
Standards and Guidance
for Vehicle Owners and
Operators

Representatives of the rental car industry stated that developing guidance
for vehicle owners on how to categorize the severity of a recall and
whether to operate a vehicle once that determination has been made could
help ensure that recalls are handled consistently and remove confusion
from the process. Currently all vehicle owners, including rental
companies, must decide whether to continue to operate vehicles subject to
a recall based on the information provided by the manufacturer in the
recall notice. The law does not require the manufacturer to advise whether
the vehicle should continue to be operated until the defect or
noncompliance is remedied. All of the rental car companies we spoke
with, as well as some of the focus group participants we interviewed,
stated that some defect notification letters are confusing and do not
provide a clear description of the severity of the defect. In addition, the
rental car companies noted that notification letters rarely provide
guidance as to whether the vehicle can continue to be operated. Rental car
company and industry representatives suggested that clear national
standards—as determined by NHTSA and the manufacturers—for how to
categorize the nature of a defect (including the potential for harm) and
whether the vehicle can continue to be operated would be helpful to
consumers and rental car companies. In particular, the American Car
Rental Association (ACRA) has proposed that NHTSA issue separate
bulletins for when a vehicle can be operated pending completion of a
recall or when a vehicle needs to be grounded until the vehicle can be
serviced. NHTSA officials stated that while they had not reviewed ACRA’s
proposal, they are opposed to publishing classifications of defects, ranking
them, or otherwise suggesting to vehicle owners that certain safety defects
are more serious than others. Moreover, NHTSA officials told us that
suggesting that some defects are more risky may have dangerous
consequences—namely, that many safety defects, all of which involve an
unreasonable risk, will be ignored. This could result in fewer consumers
remedying their vehicles due to the fact that NHTSA has categorized the

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recall as “less serious,” and therefore, consumers may perceive the safety
risk to be decreased.

Using Data More
Effectively

Although NHTSA uses manufacturer data to track the average annual
recall completion rate for all vehicle recall campaigns, NHTSA does not
currently use its data to conduct aggregate analyses of completion rates
across factors such as manufacturer, component, and vehicle type or by
analyzing completion rates based on the characteristics of the defect
notification letters, such as the format of the letter mailed to vehicle
owners. Conducting these types of trend analyses could help NHTSA
identify risk factors that might be associated with lower recall completion
rates. As discussed earlier in this report, our analysis has shown that
completion rates vary considerably across manufacturers and components
and, to some extent, vehicle types. Additionally, NHTSA officials told us
that other factors may also affect completion rates, including the
perception of the severity of the defect and the age of a vehicle at the time
of the recall. NHTSA has the opportunity to analyze its data in ways that
capture the underlying complexities and variation in the risk factors
associated with lower completion rates. With that information NHTSA
could target new recall campaigns that include such risk factors and take
additional steps to monitor those campaigns.
NHTSA officials told us they are interested in improving the completion
rates of their recalls. For example, NHTSA officials explained that they
contacted a child safety seat manufacturer that had experienced higher
rates of recall completion compared with other child safety seat
manufacturers, in order to learn how that manufacturer was achieving a
relatively higher completion rate. While this method—isolating outliers in
the data, then following up with a particular manufacturer to investigate—
is not a routine monitoring activity that NHTSA performs, such an
approach could be used more systematically when noticing differences in
recall rates in other areas identified in the data. NHTSA officials told us
they were currently re-evaluating how they used their data and would
consider ways that additional data analysis could help increase recall
completion rates.

Enhancing NHTSA’s Recall
Authorities

Legislation proposed in the 111th Congress, if enacted, would have
modified the authority NHTSA has to recall vehicles. The proposed bills
would have addressed some of the challenges in the recall process
discussed previously in this report, such as NHTSA’s authority over usedcar sales and the possibility of allowing NHTSA to declare a vehicle an

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“imminent hazard.” S. 3302 proposed a provision that would have
protected potential buyers of used cars by requiring that a used-car dealer
not sell or lease a used passenger vehicle until (1) the dealer clearly and
conspicuously notified the purchaser or lessee, in writing, of any
notifications of a defect or noncompliance that have not been remedied;
and (2) the purchaser or lessee acknowledged, in writing, the receipt of
such notifications. Requiring manufacturers to notify all dealerships that
sell used cars about recalls and requiring such dealerships to notify
potential buyers of a defect could result in increased awareness of recalls,
particularly among the group of vehicle owners that, according to
manufacturers and third-party vendors, are the hardest to identify through
postal mail—namely second and third owners of a vehicle. However, an
industry association and the used-car dealerships we spoke to noted that it
is challenging to identify vehicles with outstanding recalls due to the lack
of VIN data available to the public and because used-car dealerships are
not required to be notified of a safety defect through the use of first-class
mail. NHTSA officials agreed that notifying used-car dealers of recalls is a
challenge, but the agency has not sought this authority. NHTSA officials
indicated that in May 2011, however, the agency identified several policy
proposals to Congress on vehicle safety issues. One of these proposals is
to prohibit, with certain exceptions, used-car dealers and rental companies
from selling or leasing a vehicle subject to a recall prior to the repair
having been made.
S. 3302 also included a provision to enhance NHTSA’s authorities to
include an “imminent hazard” provision, which would have provided
NHTSA with the authority to ensure that vehicles with safety defects
posing a substantial likelihood of death or serious injury are recalled faster
than they currently can be by giving NHTSA authority to forbid further
sales of a vehicle model until the defect has been addressed. However, a
number of manufacturers we interviewed stated that NHTSA’s current
authority is adequate; they feel the current system is generally cooperative
and most passenger vehicle recalls are initiated voluntarily by
manufacturers. NHTSA officials stated that imminent hazard authority
would give them an additional tool to remove unsafe vehicles from the
road by significantly decreasing the time and resources needed currently
to order a recall through the judicial system.

Conclusions

NHTSA’s oversight of the passenger vehicle recall process—one of the
most important safety missions it performs—is generally considered to be
balanced and effective by the auto manufacturers and other auto industry
stakeholders we interviewed. However, our work has shown that NHTSA

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could do more to monitor the completion rates of recall campaigns and
encourage vehicle owners to remedy their vehicles, which could result in
removing more unsafe cars from the road. Most of these opportunities are
within the scope of NHTSA’s current authorities and would require
minimal investment of staff and other resources. For example, our focus
groups indicated that clearer communication about the severity of the
defect, as well as the addition of an owner’s VIN in the defect notification
letter, may reduce confusion about the defect and encourage more owners
to comply with the recalls. In addition, even though our analysis of NHTSA
data on recall completion rates revealed considerable underlying variation
in completion rates by manufacturers and defective components, NHTSA
does not currently use the data it collects to conduct analyses of
completion rates across recall campaigns. By doing so, the agency has an
opportunity to determine the trends that may be associated with lower
rates of completion and target such campaigns for additional monitoring
or other actions.
NHTSA also currently lacks the authority to require manufacturers to
notify used-car dealerships—which sold 11 million cars in 2009—of recalls
or require these dealerships to notify potential buyers of an outstanding
recall. As a result, many consumers may be unknowingly putting their lives
at risk by purchasing a defective vehicle. Used-car dealerships we
interviewed indicated that they may be willing to notify potential buyers of
outstanding recalls; however, the lack of a public VIN database for
identifying the specific cars that have been recalled makes such
notifications difficult. Although additional resources may be necessary for
NHTSA to implement such a database, working with manufacturers, many
of whom have already developed VIN search functions, could reduce
NHTSA’s burden. An expansion of the information provided on NHTSA’s
Web site to include a VIN search capability, as well as publicizing existing
and new resources, may help vehicle owners and other vehicle purveyors,
such as used-car dealerships, identify outstanding recalls, improve recall
completion rates, and increase safety for pedestrians and the motoring
public.

Recommendations for
Executive Action

In order to encourage vehicle owners to comply with safety recalls,
provide vehicle owners with specific information about whether their
vehicle is involved in a recall, and identify factors that affect recall
completion rates, among other things, we recommend that the Secretary of
Transportation direct the Administrator of NHTSA to take the following
four actions:

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Agency Comments

•

Modify the requirements for defect notification letters to include
additional information such as (1) the word “urgent” in large type to obtain
readers’ attention, and (2) the VIN of the recalled vehicle so it is clear that
the letter pertains to the owner’s current vehicle.

•

Create a VIN search function on www.safercar.gov and publicize the Web
site to vehicle owners and the public.

•

Develop a plan to use the data it collects on recall campaigns to analyze
particular patterns or trends that may characterize successful recalls and
determine whether these represent best practices that could be used in
other recall campaigns.

•

Seek legislative authority to ensure that potential buyers of used cars are
notified of any outstanding recalls prior to sale.
We provided a draft of this report to the Department of Transportation
(DOT), as well as CPSC, the Department of Health and Human Services
(HHS), and USDA for review and comment. DOT agreed to consider our
recommendations and both DOT and USDA provided technical comments,
which we have incorporated, as appropriate. CPSC and HHS did not
provide comments on this report.

We are sending copies of this report to the Departments of Transportation,
Agriculture, Health and Human Services, the Consumer Product Safety
Commission, and other interested parties. In addition, the report is
available at no charge on the GAO Web site at http://www.gao.gov.

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If you or your staff have any questions about this report, please contact me
at (202) 512-2834 or [email protected]. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made key contributions to this report are
listed in appendix III.

Susan A. Fleming
Director, Physical Infrastructure Issues

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Appendix I: Scope and Methodology

Appendix I: Scope and Methodology

This report focuses on the National Highway Traffic Safety
Administration’s (NHTSA) oversight of safety defect recalls, which
represent the majority of recalls overseen by the agency and are initiated
when a defect poses an unreasonable risk to safety. In addition, we have
limited our scope to safety defect recalls that have been initiated for
passenger vehicles, such as cars, pickup trucks, sport utility vehicles, and
minivans (NHTSA also oversees recalls for other vehicles, such as
motorcycles, buses, recreational vehicles, and commercial trucks).
Moreover, because the U.S. Department of Transportation Office of
Inspector General is examining NHTSA’s activities related to the
investigation of potential safety defects in motor vehicles and equipment,
we did not include safety defect investigations in our review. Our report
addresses the following questions: (1) What is the extent of NHTSA’s role
in the auto safety defect recall process, and how do its authorities
compare with those of other selected federal and foreign agencies with
safety recall authority? (2) What are the benefits and challenges of the
auto safety defect recall process for NHTSA and the manufacturers? (3)
What options exist for improving NHTSA’s auto safety defect recall
process?
To describe the extent of NHTSA’s role and authorities in the auto safety
defect recall process, we reviewed applicable legislation, including the
National Traffic and Motor Vehicle Safety Act, as amended; relevant
federal regulations; and NHTSA’s guidance on the safety defect recall
process. In addition, we conducted interviews with NHTSA officials about
the agency’s role in the defect recall process and its recall authority. To
compare NHTSA’s authorities with those of other federal agencies, we
reviewed legislation and interviewed officials at selected federal agencies
that, similar to NHTSA, have product safety oversight responsibilities,
including the Consumer Product Safety Commission (CPSC), U.S. Food
and Drug Administration (FDA), and U.S. Department of Agriculture
(USDA) to determine what differences and similarities exist between the
agencies’ recall authorities and those of NHTSA. We selected these
agencies based on discussions with NHTSA and previous GAO reviews of
federal agencies with safety recall authority. 1 To compare NHTSA’s
authorities with selected foreign agencies with safety recall authority, we
interviewed officials from agencies in four countries (Canada, Germany,

1

GAO, Food Safety: USDA and FDA Need to Better Ensure Prompt and Complete Recalls
of Potentially Unsafe Food, GAO-05-51 (Washington, D.C.: Oct. 6, 2004); and Consumer
Safety: Better Information and Planning Would Strengthen CPSC’s Oversight of Imported
Products, GAO-09-803 (Washington, D.C.: Aug. 14, 2009).

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Appendix I: Scope and Methodology

Japan, and the United Kingdom) about their authorities and involvement in
the auto safety recall processes of their countries (see table 4). We
selected these agencies based on recommendations from NHTSA and
industry officials with whom we spoke and to reflect a range of safety
recall processes and authorities. We also interviewed representatives of
auto industry organizations from the selected countries to get their
perspectives on the authorities of the selected foreign agencies, including
the Canadian Vehicle Manufacturers’ Association, the European
Automobile Manufacturers Associations, the German Association of the
Automotive Industry, the Society of Motor Manufacturers and Traders
Limited (a United Kingdom-based auto industry organization), and the
Japan Automobile Manufacturers Association. To gain a further
understanding of the authorities of the agencies we reviewed in the
European Union (EU)—specifically, those in Germany and the United
Kingdom—we interviewed officials from the European Commission
regarding the impact on member states of EU directives related to the
vehicle recall process.
Table 4: Foreign Agencies with Safety Recall Authority That GAO Interviewed
Foreign agency location

Foreign agency name

Canada

Transport Canada

Germany

Federal Motor Transport Authority

Japan

Ministry of Land, Infrastructure, Transport, and
Tourism

United Kingdom

Vehicle Operator and Services Agency

Source: GAO.

To examine the benefits and challenges in the auto safety defect recall
process, as well as potential options for improving the process, we
conducted and analyzed interviews with stakeholders in the auto safety
defect recall process, including NHTSA, auto manufacturers, third-party
data providers (Experian and R.L. Polk and Company), franchised and
used-car dealerships, rental car companies, consumer groups (Consumers
Union, Public Citizen, and the Center for Auto Safety), and industry
organizations. We identified stakeholders based on our review of pertinent
legislation, regulations, and NHTSA’s guidance documents on the recall
process for safety defects, as well as from interviews with officials and
stakeholders in the recall process. We interviewed 14 auto manufacturers
(see table 5) that together accounted for the majority of U.S. car and light

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Appendix I: Scope and Methodology

truck sales in 2009, including those that each had greater than 10 percent
market share (e.g., Ford, GM, Honda, and Toyota) and those with smaller
market share (e.g., BMW, Daimler, and Hyundai). 2 We also interviewed
two organizations representing auto manufacturers that operate in the
United States—the Auto Alliance and the Association of Global
Automakers (Global Automakers), formerly known as the Association of
International Automobile Manufacturers (AIAM)—to get their perspective
on the safety defect recalls.
Table 5: Auto Manufacturers GAO Interviewed
Auto Manufacturer

Manufacturers’ makes included in review

BMW

BMW
Mini

Chrysler

Chrysler
Dodge
Jeep
Ram

Daimler

Maybach
Mercedes
Smart

Ford

Ford
Lincoln

GM

Buick
Cadillac
Chevrolet
GMC

Honda

Acura
Honda

Hyundai

Hyundai

Isuzu

Isuzu

Jaguar Land Rover

Jaguar
Land Rover

Nissan

Nissan

Subaru

Subaru

Toyota

Lexus
Scion
Toyota

2

Congressional Research Service, “The U.S. Motor Vehicle Industry: Confronting a New
Dynamic in the Global Economy,” R41154 (Mar. 26, 2010).

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Appendix I: Scope and Methodology

Auto Manufacturer

Manufacturers’ makes included in review

VW

Audi
Bentley
Bugatti
Lamborghini
VW

Volvo

Volvo

Source: GAO.

To understand the perspective of franchised dealerships and used-car
dealerships, we interviewed seven franchised dealerships and two usedcar dealerships (see table 6), as well as an industry organization
representing franchised dealerships, the National Automobile Dealers
Association, and an industry organization representing used vehicle
dealerships, the National Independent Automobile Dealers Association.
The six franchised dealerships were selected to ensure coverage of
multiple vehicle makes. The two used-car dealers we interviewed were
selected based on recommendations from the National Independent
Automobile Dealers Association.
Table 6: Franchised Dealerships and Used Dealerships GAO Interviewed
Franchised dealerships

Location

AutoNation

Fort Lauderdale, FL

Conklin Motors

Salina, KS

DARCARS Automotive Group

Rockville, MD

Fitzgerald Auto Mall

North Bethesda, MD

Honda of Seattle

Seattle

Royal Chevrolet

Richmond, VA

Sewell Automotive Companies

Dallas

Used vehicle dealerships
Auto Buying Service

Fairfax, VA

Nelson Automotive

Mount Prospect, IL

Source: GAO.

In addition, we interviewed three rental car companies—Avis Budget
Group, Incorporated, The Hertz Corporation, and Enterprise Holdings—
that had nationwide operations in the United States, and an industry
organization representing rental car companies, the American Car Rental
Association.

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Appendix I: Scope and Methodology

To calculate recall completion rates—that is, the percentage of defective
vehicles that are remedied—of safety defect recalls for passenger vehicles
and to examine what variations exist across completion rates, we obtained
data on vehicle recalls from NHTSA’s Artemis system. 3 The Artemis
system is a central repository of data on motor vehicles and motor vehicle
equipment defects. NHTSA provided us with data for recalls that were
initiated from January 2000 through December 2010. We limited our
analysis to safety defect recalls currently being conducted. In addition, we
limited our analysis to recalls initiated through 2008 because final
completion rates are typically measured at 18 months, or 6 quarters, after a
recall campaign begins. Including recall data from 2009 or 2010 would
have biased the completion rates for those years downward; that is, they
would have had lower rates of completion than earlier year recalls
because the data do not extend over a full 18-month period.
Because many of the recalls conducted from 2000 through 2008 were for
nonpassenger vehicles—commercial vehicles, recreational vehicles,
watercraft, and trailers, among others—we eliminated all recalls that were
not passenger vehicles. 4 We examined each vehicle make and model
combination and coded them into three categories consisting of (1)
passenger cars, (2) pickups, and (3) SUVs and vans. For example, a
Chrysler 300 was coded as a passenger car, a Dodge 1500 as a pickup, and
a Land Rover Discovery as an SUV. In addition, because there were
hundreds of manufacturers (including those for nonpassenger vehicles) in
the database—each with their own set of makes and models—we
excluded all but the top 21 automobile manufacturers by market share.
However, the top 21 manufacturers represent about 99 percent of all
automobiles sold in the United States. Therefore, the data set we used to
calculate the recall completion rates from 2000 through 2008 included a
total of about 1,028 vehicle safety defect recalls after excluding
nonpassenger vehicles from the database and some recall records that
contained missing or anomalous data affecting nearly 125 million vehicles.
In order to make sure that our universe of passenger vehicle recalls was
reasonable, we compared the number of affected vehicles associated with
the 1,028 recalls we retained with the total number of affected vehicles

3

NHTSA officials told us that they do not have a definition of passenger vehicles. Therefore,
we defined passenger vehicles as noncommercial cars, sport utility vehicles, large vans,
minivans, and pickup trucks.
4

We also excluded motorcycles from our analyses.

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Appendix I: Scope and Methodology

from a report provided to us by NHTSA. Table 7 shows that, while we
analyzed only about 25 percent of the recalls reported by NHTSA from
2000 through 2008, the 1,028 recalls we did analyze include 88 percent of
all affected vehicles recalled for safety defects from 2000 through 2008.
Table 7: Comparison of All NHTSA Recall Data for Safety Defects from 2000 through 2008 to Data Analyzed by GAO

Year

NHTSA NHTSA number of
Number of
number of affected vehicles recalls analyzed
recalls†
(in millions)a
by GAOb

Number of affected
Percentage of
Percentage of
vehicles (in millions)
NHTSA recalls affected vehicles
analyzed by GAOb analyzed by GAO analyzed by GAO

2000

432

20

163

16.6

38

83

2001

379

11.8

120

10.5

32

89

2002

385

17.6

106

15.3

28

87

2003

429

15.3

112

13.5

26

88

2004

493

28.3

151

24.7

31

87

2005

472

18.2

104

16.3

22

90

2006

415

8.7

96

8

23

92

2007

502

14.2

83

13.7

17

96

2008

527

8.6

93

6.3

18

73

Total

4,034

142.7

1,028

124.9

25

88

Source: NHTSA and GAO analysis of NHTSA data.
a

The number or recalls and the number of affected vehicles were obtained from a report NHTSA
provided us listing all recalls by year from 1966 through 2009. That report also contained information
on safety defect recalls and compliance recalls. The numbers above are for safety defect recalls.

b

These values were obtained from our analysis of safety defect recalls for noncommercial passenger
vehicles obtained from NHTSA’s Artemis database.

To analyze completion rates for defective components by year, NHTSA
provided us with a list of 387 components used by NHTSA to classify the
defective component associated with each recall. We recoded these
components into 19 main categories. (See table 8.). For the most part, this
was a straightforward process, as the component names were grouped
into similar hierarchical items such as “Suspension: Front,” “Suspension:
Front: Shock Absorber,” “Suspension: Front: Control Arm,” and so forth.
All but a few of the components fit into logical, clear categories like
steering, suspension, or engine and cooling. However, we had to use our
judgment in a few cases, including “traction control”—which we placed in
the “steering” category.

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Appendix I: Scope and Methodology

Table 8: Component Categories Used in GAO Analysis of NHTSA’s Artemis
Database
Parking brake

Tires

Wheels

Equipment

Structure

Latches/locks

Seat belts

Visibility

Speed control

Exterior/interior lighting

Engine and cooling

Seats

Suspension

Steering

Power train

Air bags

Electrical system

Service brakes

Fuel system

Othera

Source: GAO analysis of component categories in NHTSA’s Artemis database.
a

The “Other” category was associated with only three recalls. Those recalls were not included in the
component completion rate analysis presented in the report because there were so few of them.

In order to calculate the completion rate across manufacturers, vehicle
types, and components, we adopted the formula used by NHTSA. That is,
for each recall, we divided the number of involved vehicles reported by the
manufacturer (minus those exported, stolen, scrapped, or “other”) by the
sum of number of vehicles corrected, the number of vehicles inspected
only and not needing correction, and the number of vehicles returned to
inventory.
In order to assess the reliability of the data we analyzed, we reviewed
NHTSA’s documentation of the Artemis system, interviewed NHTSA
officials familiar with the data, and conducted electronic tests of the data,
looking for missing values, outliers, or other anomalies. We did find some
recall campaign records that contained missing, duplicative, or incomplete
data. We had to delete 22 records from the data before we performed our
analysis because there were no reported quarterly values for recall
completion. Because three additional records contained duplicate
reporting quarters, we deleted those duplicate quarters and were able to
retain them for our analysis. We deleted a fourth recall record that had
anomalous data that could not be explained. Because another recall
record had an anomalous first quarter value for affected vehicles that was
clearly a data entry error, we deleted that quarter’s value. One final record
showed a completion record of slightly more than 100 percent. We capped
that record at 100 percent and retained it for our analysis. We determined
by the number of affected vehicles for these questionable records that our
changes and deletions have no material effect on our analysis and that the
data, as analyzed and corrected, were sufficiently reliable for our
purposes.

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Appendix I: Scope and Methodology

To determine vehicle owners’ perspectives about safety defect recalls, we
conducted 10 focus group sessions with a total of 89 vehicle owners at five
locations. These sessions involved structured small-group discussions
designed to gain more in-depth information about specific issues that
cannot easily be obtained from another method, such as a survey or
individual interviews. Consistent with typical focus group methodologies,
our design included multiple groups with varying characteristics but some
similarity on one or two homogeneous characteristics. Each group
involved 7 to 10 participants. Our overall objective in using a focus group
approach was to obtain views, insights, and feelings of vehicle owners
regarding their awareness of recalls, understanding of defect notification
letters, and willingness to comply with defect notices. By including vehicle
owners with recent recall experience and those without recent recall
experience, we intended to gather a range of perspectives regarding
vehicle owners’ awareness of recalls, their understanding of defect
notification letters, and their willingness to comply with defect notices.
We conducted 10 separate focus group sessions—5 sessions with vehicle
owners that had experienced a recall in the past 3 years and 5 sessions
with vehicle owners that had not experienced a recall within the past 3
years. We selected five cities in which to conduct focus groups to provide
population and geographic dispersion—Chicago; Dallas; Richmond,
Virginia; Salina, Kansas; and Seattle. In addition, we used the USDA’s
Economic Research Service Rural-Urban Continuum Codes to select a
city—Salina, Kansas—that represented a smaller, more isolated
community in order to ensure we included the perspectives of vehicle
owners in geographically distant or isolated communities. 5 Additionally,
we used criteria in selecting participants that ensured a mix of income,
gender, and educational level, and that accounted for the race and
ethnicity of the area in which the focus groups were located.
Discussions were structured, guided by a moderator who used a
standardized list of questions to encourage participants to share their
thoughts and experiences, as well as to react to various pieces of
communications. Specifically, question topics included perceived
responsibility for communicating the recall, expectations for how they
should be communicated with during a recall, factors that would affect
their decision to bring their recalled vehicle in for service, and suggestions

5

See USDA Economic Research Service at
http://www.ers.usda.gov/Briefing/Rurality/RuralUrbCon/.

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Appendix I: Scope and Methodology

for improving communications of auto safety recalls. During the sessions,
we assured participants of the anonymity of their responses, promising
that their names would not be used. We also conducted two pretest focus
groups at GAO and made some revisions to the focus group guide prior to
beginning our travel for the sessions.
Each of the 10 focus groups was recorded and transcriptions were
created, which served as the record for each group. Those transcripts
were then evaluated using content analysis to develop our findings. The
analysis was conducted in two steps. In the first step, two analysts
independently developed a code book and then worked together to resolve
any discrepancies. In the second step, each transcript was coded by an
analyst and then those codes were verified by a second analyst. Any
coding discrepancies were resolved by both analysts agreeing on what the
codes should be. Because we found no differences between the recall and
nonrecall groups, a document was created that compiled totals for each
question, which was used for the findings that were reported.
Methodologically, focus groups are not designed to (1) demonstrate the
extent of a problem or to generalize results to a larger population, (2)
develop a consensus to arrive at an agreed-upon plan or make decisions
about what actions to take, or (3) provide statistically representative
samples or reliable quantitative estimates. Instead, they are intended to
generate in-depth information about the reasons for the focus group
participants’ attitudes on specific topics and to offer insights into their
concerns about and support for an issue. The projectability of the
information produced by our focus groups is limited for several reasons.
First, the information includes only the responses from the vehicle owners
from the 10 selected groups. Second, while the composition of the groups
was designed to ensure a range of age and education levels, the groups
were not randomly sampled. Third, participants were asked questions
about their experiences or expectations, and other vehicle owners not in
the focus groups may have had other experiences or expectations.
Because of these limitations, we did not rely entirely on focus groups, but
rather used several different methods to corroborate and support our
conclusions.
We conducted this performance audit from June 2010 through June 2011 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence

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Appendix I: Scope and Methodology

obtained provides a reasonable basis for our findings and conclusions
based on our audit objectives.

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GAO-11-603 Auto Safety

Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups

Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups
For the purposes of the focus groups, identifying information such as
manufacturer names, owner addresses, and vehicle identification numbers
were redacted. We distributed copies of three defect notification letters
and three envelopes, as shown in the following pages:

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Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups

Defect Notification Letter, Sample A (Original Included Three
Pages)
(Page 1 of 3)

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Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups

(Page 2 of 3)

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Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups

(Page 3 of 3)

Source: Defect notification letter used in focus groups.

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Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups

Defect Notification Letter, Sample B (Original Included One Page)

Source: Defect notification letter used in focus groups.

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Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups

Defect Notification Letter, Sample C (Original Included One Page
in Landscape Format) 1

Manufacturer name

Source: Defect notification letter used in focus groups.

1

This defect notification letter was two-sided, with one side in English and the other in
Spanish. The Spanish letter (not shown) was not discussed in our focus groups.

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Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups

Defect Notification Letter Envelope, Sample D

Manufacturer name
Vehicle make

Owner name and address

Source: Defect notification envelope used in focus groups.

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GAO-11-603 Auto Safety

Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups

Defect Notification Letter Envelope, Sample E

Manufacturer name and address

Red bar

Perforated edging on
three sides; tear to open

Source: Defect notification envelope used in focus groups.

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Appendix II: Defect Notification Letters and
Envelopes Used in Focus Groups

Defect Notification Letter Envelope, Sample F

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GAO-11-603 Auto Safety

Appendix III: GAO Contact and Staff
Acknowledgments

Appendix III: GAO Contact and Staff
Acknowledgments
GAO Contact

Susan A Fleming, (202) 512-2834 or [email protected]

Staff
Acknowledgments

In addition to the contact named above, Ray Sendejas (Assistant Director),
Jennifer Clayborne, H. Brandon Haller, Terence Lam, James Leonard,
Grant Mallie, Josh Ormond, Steve Rabinowitz, Amy Rosewarne, Kelly
Rubin, Tina Won Sherman, Susan Michal-Smith, Andrew Stavisky, Crystal
Wesco, Chad Williams, and Susan Zimmerman made key contributions to
this report.

(541074)

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