November 3, 2015

FACT SHEET: NHTSA COORDINATED REMEDY ORDER 

LEGAL AUTHORITY

 The TREAD Act, passed in 2000, provides NHTSA the legal authority to order

vehicle manufacturers to accelerate their remedy of a safety defect if the agency 

determines that there is a risk of death or serious injury if the remedy is not 

accelerated; manufacturers’ remedy programs can be reasonably accelerated by 

expanding supplies of replacement parts or authorizing additional repair 

facilities; and manufacturers’ remedy programs are not likely to be complete 

within a reasonable time without acceleration.

 NHTSA has found that in the case of Takata air bag inflators, there is risk of 

serious injury or death if the remedy programs are not accelerated; that 

acceleration can be reasonably achieved by expanding the sources of 

replacement parts; and that each manufacturer’s remedy program is not likely 

to be completed in a reasonable time without acceleration.

COORDINATED REMEDY PROCEEDING

 NHTSA launched a formal administrative proceeding, the Coordinated Remedy 

Program Proceeding, on June 5, 2015, to consider whether it should use its 

accelerated remedy authority in the Takata air bag inflator recalls.

 The proceeding provided opportunity for public input.

 NHTSA issued information requests to vehicle manufacturers and inflator 

suppliers in June, and engaged in numerous meetings with the affected 

companies to gather additional information on remedy plans and challenges and 

replacement part supply. In September, the agency also requested information 

from vehicle manufacturers who have been supplied Takata inflators but not 

launched recalls.
 NHTSA convened meetings on September 23 and 24 with vehicle 

manufacturers to examine data gathered through the proceeding to aid NHTSA 

in developing a risk-based framework designed to ensure that the highest risk

vehicles are remedied first.

RISK FACTORS AND PRIORITIZATION

 NHTSA’s analysis of evidence to-date has determined the following factors 

affect the risk that a Takata inflator will rupture and will cause serious injury or 

death:

o Age (older inflators are more likely to rupture than newer inflators)

o Geography and climate (vehicles that have spent significant continuous 

time periods in areas of high absolute humidity, such as the Gulf Coast 

region and Puerto Rico, are at higher risk of rupture than vehicles that 

have been used in less hot and humid climates)

o Inflator position (driver-side inflators are more likely to cause fatal 

injuries than passenger-side inflators)

o Presence of two recalled inflators (vehicles with recalled inflators on 

both driver and passenger sides represent elevated risk and unique recall 

completion challenges)

 Based on those risk factors, each vehicle manufacturer has provided NHTSA a 

prioritization list that groups its recalled vehicles into four priority groups:

o Priority Group 1: Highest risk vehicles, generally those from model 

years 2008 or older that have spent time in the high absolute humidity 

region and that have either a recalled driver-side inflator or both driverand passenger-side inflators.

o Priority Group 2: Intermediate-high risk vehicles, generally including all 

vehicles with driver-side inflators that are not in Group 1 and vehicles 

with certain passenger-side inflators that have higher rupture frequency

and have spent time in the high absolute humidity region.

o Priority Group 3: High risk vehicles, generally including vehicles outside 

the high absolute humidity region with only passenger-side inflators, or 

those in the humid region with certain passenger inflators that have 

lower risk of rupture.

o Priority Group 4: Vehicles that will require an interim remedy (a remedy 

inflator that may contain the same defect as the recalled inflator) because 
alternate parts are not available. These vehicles are fourth priority 

because once the vehicles have been remedied with the interim part the 

risk of rupture is significantly reduced in the years just after the interim 

remedy is installed. 

ACCELERATING THE REMEDY

 NHTSA has ordered each vehicle manufacturer to ensure that it has sufficient 

remedy parts on hand on the following schedule:

o Priority Group 1: March 31, 2016

o Priority Group 2: September 30, 2016

o Priority Group 3: December 31, 2016

 NHTSA has also ordered each vehicle manufacturer to complete its remedy 

program on the following schedule:

o Priority Groups 1-3: December 31, 2017

o Priority Group 4: December 31, 2019

 In order to meet this schedule and maximize remedy completion rates, each 

vehicle manufacturer must provide to NHTSA within 90 days a written recall 

engagement plan which should, at a minimum, include methodology and 

techniques presented at an April 28 NHTSA workshop on maximizing recall 

completion.

INDEPENDENT MONITOR

 The Monitor established under NHTSA’s most recent Consent Order to Takata, 

issued today, will also assist NHTSA in monitoring and assessing compliance 

with the Coordinated Remedy Program and the Coordinated Remedy Order.

 The Monitor will assess progress in meeting the Order’s accelerated remedy 

requirements and provide NHTSA with all information required to make 

informed decisions.

CONSIDERATION OF NEW RECALLS OR ADDITIONAL DATA

 The Coordinated Remedy Order anticipates the possible expansion of Takata 

inflator recalls, including those resulting from provisions of the most recent 

NHTSA Consent Order to Takata.
 Within 45 days of any expansion of the Takata recalls, NHTSA may convene a 

meeting with affected vehicle manufacturers to address inclusion of the new 

recalls within the Coordinated Remedy Program, including principled riskassessments for the prioritization of the new recalls.

 NHTSA may, after consultation with affected vehicle manufacturers and/or 

Takata, or upon a recommendation from the Monitor, modify the existing 

Coordinated Remedy Order to respond to new information.