1200 New Jersey Avenue SE.
Washington, DC 20590

BY EMAIL AND U.S. MAIL
Mr. Steve Gold
Vice President – Product Integrity
ARC Automotive, Inc.
1729 Midpark Road, Suite 100
Knoxville, TN 37921
steve.gold@arcautomotive.com

NEF101-sly
EA16-003

Dear Mr. Gold,As you are aware, on July 13, 2015, the Office of Defect Investigation (“ODI”) of the National
Highway Traffic Safety Administration (“NHTSA” or the “Agency”) opened a Preliminary
Evaluation (PE15-027) to investigate certain air bag inflators designed by ARC Automotive, Inc.
(“ARC”). NHTSA opened its defect investigation after learning of two driver air bag inflator
field ruptures involving ARC designed inflators. On August 4, 2016, NHTSA upgraded thedefect investigation to an Engineering Analysis (EA16-003) to further investigate allegations ofinflator ruptures involving ARC driver air bag inflators. ODI upgraded the investigation after
learning of an ARC inflator field rupture in Canada, which resulted in a fatality. The
investigation scope was subsequently expanded when NHTSA learned of frontal passenger airbag inflator ruptures in testing.
NHTSA is issuing this recall request letter to notify you that the Agency has tentatively
concluded that a defect related to motor vehicle safety exists in the frontal driver and passenger
air bag inflators under investigation that were produced before installation of borescopes on all
toroidal inflator manufacturing lines in January 2018 (“subject inflators”), and to demand thatARC issue a Part 573 Recall Report addressing that safety defect.
Background on NHTSA’s Investigation
The subject inflators are hybrid, toroidal inflators 1 supplied to Tier 1 air bag module suppliers forincorporation in their completed air bag modules. Through January 2018, 67 million of thesubject driver and passenger frontal air bag inflators have been supplied to approximately six
Tier 1 air bag system manufacturers. Delphi (acquired by Autoliv) manufactured approximately
11 million of the inflators under a licensing agreement with ARC, which manufactured theremainder of the subject inflators. The subject inflators have been incorporated into air bag
A hybrid inflator uses stored gas that is excited by the propellant to fill the air bag cushion. Toroidal inflators areround, non-cylindrical inflators.

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modules used in vehicles manufactured for sale or lease in the United States by at least 12
vehicle manufacturers.
NHTSA’s PE investigation focused on understanding the inflator specifications, manufacturing
process, ideal performance, potential failure modes, and usage. Based on information gathered
during that analysis, NHTSA determined that a field recovery program was required, and theAgency began to work with the relevant stakeholders.
As described above, ODI upgraded the PE to an EA after learning of an ARC inflator field
rupture in Canada, which resulted in a fatality. EA16-003 was opened to investigate thepotential for driver air bag inflators manufactured by ARC to rupture during frontal air bag
deployment resulting in the forceful propulsion of metal fragments into the vehicle compartment.
The investigation was subsequently expanded to include frontal passenger air bag inflator
following testing ruptures.
ARC is among the companies that have been required to report field ruptures of air bag inflators
under NHTSA’s Standing General Order (SGO) 2015-02 and as subsequently amended. To
further facilitate its investigation, NHTSA issued an additional Standing General Order (SGO2016-01) to ARC with additional reporting requirements, including preliminary notifications toNHTSA within 24 hours and an expanded scope of reportable incidents (including rupturesduring testing). Since the opening of EA16-003, the Agency has learned of multiple additional
ARC inflator field ruptures involving the forceful propulsion of metal fragments into thepassenger compartment, as further described below.
As has been publicly described, during the manufacturing process of the subject inflators, theinflator center support is friction welded to the upper and lower pressure vessels. A possible
byproduct of the friction welding process is known as weld slag (also known as weld flash).
Weld slag, if it is loose, along with any other debris inside the inflator center support will follow
the air flow out of the exit orifice during a triggered air bag deployment.
ARC’s inflator design is such that during a triggered deployment, the stored gas, excited by thepropellant, has a single path through the exit orifice to exit the inflator and fill the air bagcushion. Should any debris of sufficient size be in the inflator center support, the exit orificecould become blocked. Blockage of the exit orifice could cause over pressurization of the airbag inflator. Over pressurization of the inflator has the potential to cause it to rupture resulting
in metal fragments being forcefully propelled into the passenger compartment.
In January 2018, ARC completed installation of borescopes on all toroidal inflator
manufacturing lines. The borescope is used to detect excessive weld slag or other debris in theinflator center support mitigating the possibility of a field rupture due to exit orifice blockage.
To date, the Agency is not aware of a testing or field rupture, associated with this alleged defect,of any toroidal ARC air bag inflator built after the installation of the borescope on all toroidal
inflator manufacturing lines.
In April 2018, the field recovery test program for frontal driver air bag (DAB) inflators
manufactured by ARC was completed. Test samples for model year (MY) 2001-2006 vehicles
manufactured by a subset of manufacturers that used air bag modules assembled with ARC
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inflators were collected from salvage yards. Testing was conducted in compliance with anagreed upon protocol at ARC’s facilities in Knoxville. More than 900 inflators were deployed.
The selected number was chosen to give a statistical .99 reliability and .99 confidence level tothe results. The results were analyzed on a binomial scale of whether the inflator ruptured. No
anomalies were detected in any of the deployments. None of the tested inflators ruptured.
To date, manufacturers have chosen to address the pre-borescope blockage issues and Lot
Acceptance Test failures by recalling the specific lot associated with certain ruptures. SeeRecalls 17V-189, 17V-529, 19V-019, 21V-782, 22V-246, 22E-040, 22V-543.
RECALLNUMBERDATECOMPANY

MODEL YEAR / MODELS

RECALL
POPULATION

17V-189

3/17/2017BMW

2017MY X5 sDrive35i, X5 xDrive35i, X5xDrive50i, X5 xDrive35d, and X5xDrive40e36

17V-529

8/28/2017

FORD

2017MY MUSTANG AND F150 PICK-UP

650

19V-019

12/21/2018

GENERAL MOTORS

2010-2011MY CHEVROLET MALIBU

1145

21V-782

10/7/2021

GENERAL MOTORS

2008-2017MY BUICK ENCLAVE
2013-2017MY CHEVROLET TRAVERSE

555

22V-246

4/14/2022

GENERAL MOTORS

2015MY BUICK ENCLAVE, GMC
ACADIA, CHEVROLET TRAVERSE

2687

22E-040

5/19/2022

GENERAL MOTORSDRIVER AIR BAG SERVICEREPLACEMENT PARTS74

22V-543

7/27/2022

VOLKSWAGEN

2016MY VARIOUS AUDI AND VW
VEHICLES1216

In August 2022, NHTSA held a meeting with the affected manufacturers that used toroidal,
hybrid driver and frontal passenger air bag inflators designed by ARC (i.e., the inflators that are
the subject of NHTSA’s EA16-003 investigation). The purpose of the meeting was to assess
information learned to date from the investigation and discuss potential next steps. NHTSA sent
Information Request letters to the affected manufacturers to refresh the data on frontal passenger
air bag inflator usage and performance collected in 2020 and to collect data on frontal driver air
bag inflator usage and performance as a result of that meeting. ARC was sent an IR letter tocollect specific data on the operation of the borescope and any modifications to process andprocedure made since installation.
Recall Request
Despite the growing number of ruptures related to this blockage issue in the subject population
demonstrating a safety defect, ARC has not made a defect determination that would require arecall of this population. Based on currently available information, NHTSA has tentatively
concluded that a defect related to motor vehicle safety exists in the subject frontal driver and3

passenger air bag inflators and demands that ARC issue a Part 573 Recall Report addressing thatsafety defect.
The National Traffic and Motor Vehicle Safety Act defines motor vehicle safety as “theperformance of a motor vehicle or motor vehicle equipment in a way that protects the publicagainst unreasonable risk of crashes occurring because of the design, construction, orperformance of a motor vehicle, and against unreasonable risk of death or injury in an accident
and includes nonoperational safety of a motor vehicle.” 49 U.S.C. § 30102(8). A defect that
occurs in an essential component of a piece of motor vehicle equipment, such as in this matter
involving a frontal air bag inflator, presents an unreasonable risk to safety. See United States v.
General Motors Corp., 561 F.2d 923, 929 (D.C. Cir. 1977) (“Pitman Arms”).
A motor vehicle or component contains a “defect” if it is subject to a significant number offailures in normal operation. See United States v. General Motors Corp., 518 F.2d 420, 427(D.D.C. 1975) (“Wheels”). To establish that a significant number of failures exist, the Agency
need only show that the figure is more than de minimis. See id. at 438 n.84. The Agency mustalso show that the failure condition occurred under circumstances which, in the absence of adefect, would not have occurred. See United States v. General Motors Corp., 841 F.2d 400, 412(D.C. Cir. 1988) (“X-Cars”). An air bag inflator that ruptures when deploying in a vehicle isplainly defective. At a minimum, the following seven domestic field events involving subject
driver and passenger inflators are more than de minimis:•On January 29, 2009, a driver side air bag inflator ruptured in a (MY) 2002 Chrysler
Town and Country minivan in Ohio. The air bag module was produced by Key Safety
Systems and used a dual stage ARC inflator. The inflator was manufactured in
Knoxville. The driver was severely injured during the incident.

•On April 8, 2014, a driver side air bag inflator ruptured in a MY 2004 Kia Optima inNew Mexico. The air bag module was manufactured by Delphi and had a single stage
ARC inflator. The inflator was manufactured in Knoxville. The driver sustained injuries
to her face and legs.

•

On September 22, 2017, a driver side air bag inflator ruptured in a 2010 Chevrolet
Malibu in Pennsylvania. The air bag module was produced by ZF-TRW and used a dual
stage ARC inflator. The inflator was manufactured in Xian, China. The driver sustained
facial and head injuries.

•On August 15, 2021, a driver side air bag inflator in a 2015 Chevrolet Traverse rupturedin Michigan. The air bag module was produced by Toyoda Gosei and used a dual stage
ARC inflator. The inflator was manufactured in Reynosa, Mexico. The air bag module
was a replacement module. The vehicle had been in a prior frontal collision and theoriginal air bag module deployed with no issue. The original air bag module was, also,produced by Toyoda Gosei and used a dual stage ARC inflator. The driver sustained
fatal injuries.

4•On October 20, 2021, a driver side air bag inflator in a 2015 Chevrolet Traverse rupturedin Kentucky. The air bag module was produced by Toyoda Gosei and used a dual stage
ARC inflator. The inflator was manufactured in Reynosa, Mexico. The driver sustained
facial injuries.

•On December 18, 2021, a passenger side air bag inflator ruptured in a 2016 Audi A3 eTron in California. The air bag module was produced by Joyson Safety Systems andused a dual stage ARC inflator. The inflator was manufactured in Reynosa, Mexico. Thedriver and passenger were injured.

•On March 22, 2023, a driver side air bag inflator in a 2017 Chevrolet Traverse rupturedin Michigan. The air bag module was produced by Toyoda Gosei and used a dual stage
ARC inflator. The inflator was manufactured in Reynosa, Mexico. The driver sustained
facial injuries.

Based on certain of these field incidents, vehicle manufacturers conducted the recalls listedabove.
In addition, NHTSA is aware of at least two field incidents outside the United States:•On July 11, 2016, a driver side air bag inflator ruptured in a MY 2009 Hyundai Elantra inCanada. The air bag module was produced by Mobis and used single-stage ARC air baginflator. The inflator was manufactured in Xian, China. The driver sustained fatalinjuries.

•On October 16, 2017, a passenger side air bag inflator ruptured in a MY 2015
Volkswagen Golf in Turkey. The air bag module was produced by Key Safety Systems(now known as Joyson Safety Systems) and used a single stage ARC inflator. The
inflator was manufactured in Knoxville. The driver sustained no injuries. There was nopassenger in the vehicle.

The subject inflators pose an unreasonable risk of death or injury that may result from an item ofmotor vehicle equipment that, when not defective, is designed to save lives. Air bag inflatorsthat project metal fragments into vehicle occupants, rather than properly inflating the attached airbag, create an unreasonable risk of death and injury. Accordingly, the Agency makes thisdemand that ARC immediately submit to NHTSA a Part 573 Recall Report that identifies asafety defect in the subject driver and passenger air bag inflators.
NHTSA’s request that ARC conduct a safety recall does not constitute a formal conclusion byNHTSA with respect to the evidence in its investigative file. Also, this recall request does notconstitute an initial or final decision that the subject inflators contain a safety defect pursuant to49 U.S.C. § 30118, an order to recall vehicles, or a decision that ARC violated the law.
If ARC decides not to conduct the requested recall, it must provide ODI with a full explanationof its decision, including any additional analysis of the problem beyond ARC’s pastpresentations. If ARC fails to initiate a recall, the Agency may proceed to an initial decision that5this air bag inflator contains a safety defect, pursuant to 49 U.S.C. § 30118(a), and may takeother appropriate action. An initial decision will be accompanied by the publication of a Federal
Register notice describing the alleged safety defect and the ODI investigation and scheduling apublic meeting.
ARC’s written response to this letter referencing the identification codes in the upper right-handcorner on page 1 of this letter, must be submitted to this office no later than MAY 11, 2023, byemail to sharon.yukevich@dot.gov. It is important that ARC respond to this letter on time. Thisletter is being sent pursuant to 49 U.S.C. § 30166, which authorizes this Agency to conduct
investigations and require the submission of reports that may be necessary to enforce Chapter
301 of Title 49 of the U.S. Code. Failure to respond promptly and fully to this letter may beconstrued as a violation of 49 U.S.C. § 30166, which could subject ARC to civil penalties
pursuant to 49 U.S.C. § 30165.
If you have any questions about this letter, please contact Sharon Yukevich of my staff at 202366-4925. If you have any questions regarding the recall procedures, please contact Mr.
Alexander Ansley of my staff at 202-493-0481.
Sincerely,
STEPHENANTHONYRIDELLA

Digitally signed by
STEPHEN ANTHONYRIDELLA
Date: 2023.04.27 16:24:04-04'00'

Stephen A. Ridella, Ph.D.
Director
Office of Defects Investigation
cc:

Chris Grigorian, counsel for ARC Automotive, Inc.
R. Nicholas Englund, counsel for ARC Automotive, Inc.

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