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Category Archives: Transportation

Honda’s Early Warning Report Audit & NHTSA Special Order

Fact Sheet: “In September 2014, Honda commissioned a third-party audit of its TREAD Act reporting (also known as Early Warning Reports, or EWRs) to the National Highway Traffic Safety Administration (NHTSA) after certain discrepancies in reporting had been identified.

NHTSA Special Order

Once Honda received preliminary findings from the third-party audit, it requested a meeting with NHTSA, and on October 17, 2014 briefed NHTSA on the matter. On November 3, 2014, NHTSA issued a Special Order to Honda requesting information related to Honda’s EWRs, and Honda submitted responsive information to NHTSA on November 24, 2014.

TREAD Act Requirements

The heart of the TREAD Act is an Early Warning Reporting obligation, which requires vehicle manufacturers on a quarterly basis to report a wide variety of information that could indicate a potential safety defect. This information includes a report on any death or injury incident that is known to Honda from a written claim or a written notice containing any allegations that injury or death may have been caused by or related to a possible defect. These claims are received by manufacturers from customers, their representatives or other sources. Death and Injury EWRs to NHTSA are required to include certain specified information about the incidents. Oral claims and notices of death or injury do not carry the same reporting requirements. The TREAD Act also requires manufacturers to provide aggregate information about warranty claims it has paid, property damage claims (regardless of whether paid or denied), customer complaints (oral and written) and field reports. Certain field reports are required to be provided in hard copy, as well. For complete details on the TREAD Act, please visit the NHTSA website.

Key Findings of Honda’s Third-Party Audit

Honda’s third-party audit has identified that it did not report to NHTSA a total of 1729 written claims or notices concerning injuries or deaths over the period of July 1, 2003, through June 30, 2014. Our review to date indicates that these were inadvertent data entry and computer programming errors. Additionally, the audit found a delay between the time that Honda first became aware of possible discrepancies in its TREAD reporting and the full investigation and reporting of the issue. More detailed background regarding these issues follows:

  1. Data Entry Errors: In entering injury and death claims into the company’s database Honda often did not enter a date in the “written claim received” field. The computer program used to generate Honda’s Early Warning Reports requires completion of that field in order to distinguish reportable written claims and notices from non-reportable oral claims for relief. Therefore, those written claims and notices that were input without a “written claim received” date were automatically omitted from Honda’s Early Warning Reports.
  2. Coding Error: Early Warning Reports are required to identify the particular component involved in the injury or death claims being reported using a series of NHTSA component codes. Historically, Honda maintained a more exhaustive series of its own component/defect sub-codes to track incoming claims. However, the EWR computer program was not set up properly at the outset, and did not properly map all of Honda’s internal sub-codes to a NHTSA code. Therefore, when generating its Early Warning Reports, Honda’s computer program included only those written injury and death claims or notices that mapped to a NHTSA component code – thus underreporting claims.
  3. Narrow Regulatory Interpretation: Honda used an overly narrow interpretation of what constituted a “written notice” under the TREAD Act. Using this narrow interpretation, Honda did not consider third-party documentation that the company obtained through its associates or consultants as reportable. For example, police reports obtained by Honda or information from private investigators hired by the company, were not considered a “notice received by the manufacturer” – and thus did not trigger an EWR report.”

New GAO Reports – Health Care Transparency, Human Trafficking, Highway Projects, Public Transportation, Overseas Military Construction

HEALTH CARE TRANSPARENCY: Actions Needed to Improve Cost and Quality Information for Consumers, GAO-15-11: Published: Oct 20, 2014. Publicly Released: Nov 18, 2014. HIGHWAY PROJECTS: Many Federal and State Environmental Review Requirements Are Similar, and Little Duplication of Effort Occurs, GAO-15-71: Published: Nov 18, 2014. Publicly Released: Nov 18, 2014. HUMAN TRAFFICKING: Oversight of Contractors’ Use of Foreign Workers in High-Risk EnvironmentsContinue Reading

Automobile Industry Issues Consumer Privacy Protection Principles

“The automotive industry is developing innovative technologies and services that promise to deliver substantial benefits and enhance the driving experience. These technologies and services may assist in enhancing safety, reducing the environmental impacts of vehicles, diagnosing vehicle malfunctions, calling for emergency assistance, detecting and preventing vehicle theft, reducing traffic congestion, improving vehicle efficiency and performance, deliveringContinue Reading

EPA, DOE Release 2015 Fuel Economy Guide for Car Buyers

News release: “The U.S. Environmental Protection Agency (EPA) and the Department of Energy (DOE) …released the 2015 Fuel Economy Guide, providing consumers with a valuable resource to help them choose the most fuel-efficient and low greenhouse gas emitting vehicles that meet their needs. In comparison to previous years, the 2015 models include a greater number ofContinue Reading

UK Major Incident Procedure Manual Eighth Edition

“The London Emergency Services Liaison Panel (LESLP) was formed in 1973 and consists of representatives from the Metropolitan Police Service, City of London Police, British Transport Police, the London Fire Brigade, the London Ambulance Service and local authorities. The Port of London Authority (PLA), Marine Coastguard, RAF, Military and voluntary sector are also represented. LESLPContinue Reading

New GAO Reports – Airport and Airway Trust Fund, Food Safety, Information Sharing

FISCAL YEAR 2014 AGREED-UPON PROCEDURES: Excise Tax Distributions to the Airport and Airway Trust Fund and the Highway Trust Fund, GAO-15-152R: Published: Nov 6, 2014. Publicly Released: Nov 6, 2014. FOOD SAFETY: FDA and USDA Should Strengthen Pesticide Residue Monitoring Programs and Further Disclose Monitoring Limitations, GAO-15-38: Published: Oct 7, 2014. Publicly Released: Nov 6, 2014. INFORMATION SHARING: DHS Is Assessing FusionContinue Reading

McKinsey – A road map to the future for the auto industry

The China factor – “Fifty years of innovations in horsepower, safety, and rider amenities have helped automobile sales grow by an average annual rate of 3 percent since 1964. This is roughly double the rate of global population growth over the same period and makes for a planet with over one billion vehicles on its roads. ForContinue Reading

Largest Clean Air Act Settlement in History

Settlement with Hyundai and Kia protects consumers and ensures greenhouse gas emissions reductions “The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Justice today announced an historic settlement with the automakers Hyundai and Kia that will resolve alleged Clean Air Act violations based on their sale of close to 1.2 million vehicles thatContinue Reading

What Drives U.S. Gasoline Prices?

EIA, October 30, 2014: “U.S. oil production has grown rapidly in recent years. U.S. Energy Information Administration (EIA) data, which reflect combined production of crude oil and lease condensate, show a rise from 5.6 million barrels per day (bbl/d) in 2011 to 7.4 million bbl/d in 2013. EIA’s Short-Term Energy Outlook (STEO) projects continuing rapidContinue Reading

New GAO Reports – Disability Compensation, DOD Business Systems Modernization, DOD Space Systems, Energy Policy

DISABILITY COMPENSATION: Review of Concurrent Receipt of Department of Defense Retirement, Department of Veterans Affairs Disability Compensation, and Social Security Disability Insurance, GAO-14-854R: Published: Sep 30, 2014. Publicly Released: Oct 30, 2014. DOD BUSINESS SYSTEMS MODERNIZATION: Additional Enhancements Are Needed for Army Business System Schedule and Cost Estimates to Fully Meet Best Practices, GAO-14-470: Published: Sep 30, 2014. Publicly Released: OctContinue Reading

Report – Bicyclist Fatalities a Growing Problem for Key Groups

“The number of bicyclists killed on U.S. roadways is trending upward, particularly for certain subsets of the population, according to a report released today by the Governors Highway Safety Association (GHSA). GHSA’s Spotlight on Highway Safety: Bicyclist Safety notes that yearly bicyclist deaths increased 16 percent between 2010 and 2012, while overall motor vehicle fatalitiesContinue Reading

American Housing Survey: 2013 Detailed Tables

Release Number: CB14-TPS.78: “The first findings from the 2013 American Housing Survey are now available in the form of dozens of detailed tables and a microdata file. The American Housing Survey is conducted biennially and, as in past years, provides current national-level information on a wide range of housing subjects. Topics unique to this surveyContinue Reading