August 17, 2016

Mr. Jeffrey Giuseppe

Acting Associate Administrator for Enforcement

National Highway Traffic Safety Administration

1200 New Jersey Avenue, S.E.

Washington, D.C. 20590

Re.: Mazda Motor Corporation Petition for a Determination ofInconsequentiality of

Takata's Defect Information Report filing under NHTSA Campaign Number 17E-034 for

PSDI-5 Desiccated Driver Air Bag Inflators

Dear Mr. Giuseppe:

Pursuant to the requirements of 49CFR Part 556, Mazda Motor of America, Inc. dba. Mazda

North American Operations ("MNAO"), on behalf of Mazda Motor Corporation ofHiroshima,

Japan ("Mazda"), hereby requests exemption from the notification and remedy requirements of

the Safety Act 49 U.S.C. Sections 30118(d) and 30120(h) of Takata's Defect Information Report

("DIR") filing under NHTSA Campaign Number 1 7E-034. Takata's DIR affects PSDI-5 frontal

driver side air bag inflators, which Mazda notified to NHTSA in the Part 573 report dated July

20, 2017 and updated in a subsequent submission on July 21, 2017. Mazda, in conjunction with

a joint petition filing with Ford Motor Company ("Ford"), further requests that the agency

provide an extension until March 31, 2018 for Ford to complete its expanded inflator field study,

aging assessment, and testing on additional samples before making a determination on the

petition. Since MY2007 -2011 Ford Ranger and MY2007 -2009 Mazda B-Series vehicles are

built on identical platforms and use identical air bag inflators, Ranger data is representative of BSeries. Ford, which designed and manufactured the affected vehicles, does not believe that the

currently available test data and technical assessments indicate the PSDI-5 inflator design in

Ford and Mazda vehicles present a risk to safety.

L

2O: e:ru entei [i ,.

I -jInc, c:,

ww.MazdaUSA.com

IeIehon

FcriiI 94J7i.
Name of the Applicant:

Mazda Motor Corporation with Designated Agent:

David G. Robertson, Senior Manager

Environmental, Safety, and Powertrain Engineering

Mazda North American Operations

1025 Connecticut Avenue, NW

Suite 910

Washington, DC 20036

Description of the Defect:

On July 10, 2017, Takata Corporation ("Takata") submitted an equipment supplier Part 573 on

PSDI-5 phase-stabilized ammonium nitrate ("PSAN") air bag inflators with calcium sulfate as a

desiccant. Takata has conducted evaluations on PSDI-5 air bag inflators collected from Nissan

and Ford vehicles in the field. These field returned inflators demonstrated a pattern of propellant

density reduction that is understood to predict a future risk ofinflator rupture. Aging

characteristics of inflators may be influenced due to design differences between Nissan and Ford

inflators and vehicles. Though Takata has not tested PSDI-5 inflators with calcium sulfate from

Mazda vehicles, MY2007 -2011 Ford Ranger data is representative ofthe MY 2007 -2009

Mazda B-Series as both were built onidentical platforms and use identical air bag inflators.

In the event of an inflator rupture, metal fragments could pass through the air bag cushion

material, resulting in injury or death to vehicle occupants.

Table 1 -Affected vehicle model(s), model years, production volumes, and production dates.

Model Model Year(s) Population Affected Production Range

B-Series 2007 -2009 5,848 February 21, 2006 to

June 18, 2009

Supporting Information ofInconsequential Defect:

For the reasons listed below, Ford does not believe that the cunently available test data and

technical assessments indicate that the PSDI-5 inflator design in Ford vehicles presents a risk to

safety.

i&zda 1\ioith ericar Operatons

200 Spectrum Center Duve, 'Lute 00

rune . www.MazdaUSAcom

Ielep0m :-j ,.:r, ci9U

FacetiSe 049 727 6101
 ̄ The data acquired from field return parts does not show a density degradation in the Ford

PSAN tablets as occurred with the Nissan tablets;

 ̄ Primary chamber pressure measurements were within specifications on all Ford PSDI-5

inflators during ballistic testing and no reports of inflator pressure vessel ruptures in the field;

 ̄ Desiccant saturation is not an indicator of propellant degradation.

Refer to the Ford and Mazda joint petition for additional details, including Takata's analysis of

the current performance ofFord's inflators, unique design characteristics ofinflators used in

Ford vehicles, and Ford's commitment to further investigation of PSDI-5 inflators through

additional parts acquisitions as well as continued testing and engineering analysis.

Should you have any questions, please feel free to contact me at 202-467-5093.

Sincerely,

David Robertson, Senior Manager

ET&C / ESE

Research & Development

Mazda North American Operations

Enclosures:

Ford and Mazda joint petition filing

Mazda submission copy of Part 573

')I

200 ,1ciiuri Ceu Div. 2u. -

n C- 02

www.MazdaUSA.com

Fv'siie 04t:i27 0
FORD PETITION FOR A DETERMINATION OF INCONSEQUENTIALITY AND

REQUEST FOR DEFERRAL OF DETERMINATION REGARDING CERTAIN FORD

VEHICLES EQUIPPED WITH TAKATA PSDI-5 DESICCATED DRIVER AIRBAG

INFLATORS

Ford Motor Company ("Ford") petitions the National Highway Traffic Safety

Administration ("NHTSA") for exemption from the notification and remedy provisions ofthe

National Traffic and Motor Vehicle Safety Act of 1966 as amended and recodified (the "Safety

Act"), 49 U.S.C. §30101, et seq., pursuant to 49 U.S.C. § 30118(d) and 30120(h) and 49 C.F.R.

part 556, with respect to PSDI-5 driver airbag inflators containing calcium sulfate as a desiccant

that are installed as original equipment in certain Ford vehicles. Ford requests that NHTSA

allow Ford until March 31, 2018, to complete its expanded PSDI-5 inflator field study, aging

assessment, and testing on additional samples and vehicle types before making a determination

on this petition.

INTRODUCTION

On July 10, 2017, Takata Corporation ("Takata") submitted an equipment Defect

Information Report ("DIR") to NHTSA on Takata PSDI-5 phase-stabilized ammonium nitrate

("PSAN") driver airbag inflators containing calcium sulfate as a desiccant. At NHTSA's

request, Ford filed a DIR on Ford vehicles equipped with this inflator on July 18, 2017. Ford's

DIR stated its intent to file a petition for a determination of inconsequentiality. The basis for this

petition is that the data provided by Takata currently do not support a conclusion that the Takata

PSDI-5 driver airbag inflators installed as original equipment in Ford vehicles contain a defect

that presents an unreasonable risk to motor vehicle safety.

Takata's July 10, 2017 DIR is the first DIR filed for any Takata desiccated PSAN

inflator. In its DIR, Takata indicated that it is "taking this action out of an abundance of caution"

and is not aware of any field ruptures or laboratory test failures on any PSDI-5 inflator that uses

1
calcium sulfate as a desiccant. As part of a field evaluation program, Takata analyzed field

returned inflators from Nissan North America Inc. ("Nissan") vehicles and Ford vehicles.

Referring to the inflators from Nissan vehicles, Takata indicated in its DIR that "[s]ome ofthe

inflators within the population analyzed show a pattern ofpropellant density reduction over time

that is understood to predict a future risk ofinflator rupture." In contrast, however, Takata's

analysis ofFord field return PSDI-5 desiccated inflators does not show a similar pattern of

propellant density reduction over time. Takata acknowledged in its DIR that "[i]nflator design

and vehicle environment differences between the Nissan and Ford inflators/vehicles may

influence their aging characteristic."

To date, Takata has evaluated over 400 PSDI-5 inflators from Ford vehicles in the field

as part ofthe field evaluation program requested by NHTSA. Takata's evaluation ofFord

inflators included live dissections and teardowns, detailed laboratory inflator constituent

analysis, as well as ballistic testing without a single rupture or elevated deployment pressure or

other sign of abnormal deployment. These field return parts were harvested from Ford vehicles

with significant time in service -approximately eight to ten years oftime in service. Takata's

analysis currently shows that even the oldest ofthese Ford vehicles do not currently present an

unreasonable risk to safety, even in the highest heat and humidity region ofFlorida, located in

NHTSA's Zone A. Takata's available field data and engineering analysis support the conclusion

that the PSDI-5 inflators in Ford vehicles are currently performing as designed in the field.

Based on Takata's testing data, there are significant differences between the inflators

from Ford vehicles and the inflators from Nissan vehicle& The design differences between the

inflators and vehicle environments may account for the differences in risk for degradation over

time. Ford needs additional time to assess the effect ofthe design and vehicle differences ofthe

2
Ford inflators and their impacts on the inflator service life by gathering additional samples and

conducting further engineering and aging analysis. As detailed in Ford's PSDI-5 test plan

reviewed with NHTSA on July 6, 2017, Ford proposes to collect significantly more inflators

from additional vehicle lines and high absolute humidity (HAM) geographic areas. Analysis on

the returned parts will help Ford, the industry, and the Agency assess the effect ofinflator

design, vehicle type, years of exposure, and desiccant on the booster and generate system. In

addition to further analysis from Takata, parts obtained from the field will also be sent to third

party experts for additional independent testing and analysis.

Moreover, Ford is concurrently working with an alternative supplier to develop potential

remedies and intends to have non-PSAN remedy parts validated for the subject Ford vehicles,

should the remedy become necessary. The estimated availability ofthe remedy for Ford's July

2017 DIR coincides with the conclusion ofFord's test plan, and providing Ford with the

additional time it requests will not delay Ford's efforts to develop and validate a replacement

inflator as an available remedy.

Ford's DIR was filed solely in response to Takata's DIR. Ford has not determined that a

defect that presents an unreasonable risk to motor vehicle safety exists in the subject vehicles,

and the filing ofthis petition is not a concession that a defect exists in the subject vehicles.

NHTSA's regulations contemplate that a manufacturer that did not itselfmake a safety defect

determination may file a petition for a determination ofinconsequentiality without having to

concede the existence ofthe safety defect. See 49 C.F.R. §556.4(c).

3
BACKGROUND

Takata evaluates desiccated PSAN inflators for their safe service life

On November 3, 2015, NHTSA and Takata entered into a Consent Order regarding

NHTSA's investigation of Takata airbag inflator ruptures (EA15-001). Under the terms ofthe

Consent Order, Takata is required to conduct testing of desiccated Takata PSAN inflators for

their service life and safety.

Testing of Desiccated Takata PSAN Inflators. Takata shall extend its current

service life and safety testing to include testing of desiccated Takata PSAN

inflators, with the cooperation of vehicle manufacturers, to determine the service

life and safety ofsuch inflators, and to determine whether, and to what extent,

these inflator types suffer from a defect condition, regardless ofwhether it is the

same or similar to the conditions at issue in the Takata [non-desiccated] DIRs.

Takata shall provide frequent updates to NHTSA on the status ofthis effort and

test results, and shall respond fully and accurately to any request for information

by the agency.

Consent Order ¶ 28.

The Consent Order further provides that "if Takata has not otherwise been able to make a

showing to NHTSA concerning the safety andlor service life of any ofthe Takata PSAN inflators

to NHTSA's satisfaction by ...December 31, 2019 for desiccated Takata PSAN inflators, then

the Administrator may issue one or more final orders setting forth a schedule on which Takata

shall submit Defect Information Reports to the agency for the relevant Takata PSAN inflators."

Id. atlJ3o.

The Consent Order also states that the Agency may make a determination that a defect

that presents an unrasonable risk to safety exists in any Takata PSAN inflator type based upon:

(a) the occurrence of a field rupture(s) ofthat Takata PSAN inflator type, (b)

testing data and analysis relating to the propensity for rupture ofthat Takata'

PSAN inflator type, (c) Takata's ultimate determinations concerning the safety

and/or service life of any Takata PSAN inflator type, (d) the determination ofroot

4
cause of inflator ruptures by any credible source, or (e) other appropriate

evidence.

Id. at1129.

The May 4, 2016 Amendment to the November 3, 2015 Consent Order notes that: "To

date, there have been no test failures or field ruptures of desiccated Takata PSAN inflators, with

the exception oftwo ruptures of desiccated side impact Takata PSAN inflators (i.e., SSI-20),

which were caused by an identified manufacturing issue." Amendment ¶ 10 n. 5.

According to Takata, it has produced multiple generations of desiccated PSAN inflators.

The earliest generation of desiccated PSAN inflators used calcium sulfate as a desiccant. These

subject inflators were installed as original equipment in vehicles sold in the United States by

Ford Motor Company, Mazda North American Operations, and Nissan North America Inc.

Ford participates in voluntary field study ofnon-recalled inflators

In February 2016, NHTSA asked Ford to conduct a voluntary study of desiccated

inflators in the field with higher time in service, in order to support ongoing investigation of

Takata desiccated inflators. In a letter from NHTSA to Ford dated February 26, 2016, NHTSA

sought Ford's assistance in an evaluation ofthe desiccated version ofthe PSDI-5 inflator type.

As stated by NHTSA: "The primary purpose ofthis field surveillance program would be to

collect a number ... ofthe oldest PSDI-5 driver inflators from the most severe HAH area ofthe

US[.1" According to NHTSA, "[t]he results ofthe testing, which would be shared with Ford and

other interested parties, would help NHTSA, as well as Ford and others, evaluate the current

state of health and safety ofthese inflators."

Ford confirmed its agreement to support NHTSA's request to participate in a field

surveillance study of certain non-recalled Takata inflators in connection with EA15-001.

Separately, in connection with NHTSA and Takata, Nissan also initiated a project to recover and

5
evaluate certain Nissan vehicles equipped with their PSDI-5 inflator design that use calcium

sulfate as a desiccant.

In April 2016, Ford's Field Review Committee approved a field service action (Ford

16B 15) to replace Takata PSDI-5 driver airbag inflators on 2007-2008 MY Ford Ranger vehicles

located in Florida, Arizona, and Michigan as part of a field return part engineering study. Ford

identified vehicles that were only ever-registered in these three geographic areas: Florida (Zone

A -High Humidity/High Temperature); Arizona (Zone B -Low Humidity/High Temperature);

and Michigan (Zone C -High Humidity/Mild Temperatures). Ford proposed that acquiring

inflators from these distinct geographic areas would provide insight on the condition and effects

of climate on the generate.

From April 2016 to August 2016, Ford released a Takata PSDI-5 driver airbag inflator

("like-for-like" replacement) as a service part, worked with Takata to develop a service kit, and

secured production capacity for the service kits to enable the recovery offield aged parts. In

September 2016, Ford notified certainowners of 2007-2008 MY Ford Ranger vehicles located in

Florida, Arizona, and Michigan ofthe program. In its notification, Ford informed its customers

that this program is a proactive engineering study effort by Ford, in coordination with NHTSA,

to gather and evaluate certain airbag inflators manufactured by Takata. Ford indicated that it was

voluntarily conducting this program to obtain field parts from certain geographic locations for

testing and that no defect or safety concern has been identified on these airbag inflators. By

March 2017, Ford had replaced approximately 1,500 Takata PSDI-5 driver airbag inflators under

the study program.
Takata 's evaluation ofFord field return inflators show no inflator rupture, no pattern ofdensity

degradation, nor an increase in inflation pressure

On March 10, 2017, Takata met with Ford to discuss the results to date from its

engineering analysis on the parts received. These results were previously shared with NHTSA.

Takata's analysis ofthe returned parts assessed the effectiveness ofthe desiccant on the booster

and generate system. Takata conducted a more detailed follow-up review of its analysis with

Ford on March 28, 2017. Neither review supported a conclusion that tablet density is degrading

in the inflators designed for Ford after 10 years ofservice.

From March 2017 to June 2017, Takata continued to test additional inflators returned

from Ford vehicles in the field. These additional inflators were subjected to live dissections,

including propellant analysis (chemical and dimensional), as well as ballistic testing. In June

2017, Takata reviewed the additional field return data with Ford. With respect to the inflators

gathered from Ford vehicles, Takata's testing results in June 2017 remained unchanged from the

data available in March 2017. Takata did not identify any pattern of generate degradation or any

aggressive inflation pressures during deployment tests ofthese field return parts from Ford

vehicles, with the increased number ofsamples tested.

To date, Takata has analyzed over 400 Ford field return parts from 2007-2008 MY Ford

Ranger vehicles located in Florida, Arizona, and Michigan. No trend in generate density

reduction was observed in the Ford data, consistent with previous reviews. No ruptures or

excessive inflator chamber pressures have been observed during ballistic test deployments on the

Ford parts. Primary chamber pressure measurements were within specifications on all Ford

7
PSDI-5 inflators during ballistic testing. Moreover, there have been no reports of inflator

pressure vessel ruptures in the field.

On June 23, 2017, NHTSA's Office ofDefects Investigation contacted Ford and

communicated that the field data from Nissan vehicles for desiccated PSDI-5 driver airbag

inflators demonstrated a trend that NHTSA felt required action, based on an observed pattern of

propellant degradation and an over-pressurization of one inflator during testing. On June 28,

2017, Takata informed Ford that NHTSA directed Takata to issue an equipment DIR on Takata

PSDI-5 inflators equipped with calcium sulfate.

Ford reviews its test plan for expanded study ofdesiccated inflators with NHTSA

On July 6, 2017, Ford met with NHTSA to review Takata's summary data on PSDI-5

inflators to date. Ford also reviewed with NHTSA plans to expand its field engineering study to

additional vehicle platforms. As previously mentioned, the purpose ofFord's expansion

program is to gather parts from additional vehicle lines and geographic areas for analysis in

support ofFord's ongoing investigation ofthese inflators. Analysis on the returned parts will

assess the effect of vehicle type, years of exposure, and desiccant on the booster and generate

system. The goal ofthe program is to obtain approximately 1,000 additional Ranger, 2,500

FusionfMilanlMKZ, and 2,500 EdgeIMKX driver airbag inflators from the high temperature/high

humidity areas ofthe United States (Zone A Gulf Coast states ofthe U.S. such as FL, LA, MS,

AL, and TX). In addition to evaluation by Takata, Ford plans to have third party experts

evaluate parts obtained from the field to provide a detailed independent analysis.

8
Takata files DIR "out ofan abundance ofcaution"

On July 10, 2017, Takata submitted a DIR for all PSDI-5 inflators using calcium sulfate

as a desiccant. In its DIR, Takata indicated that it is not aware of any field ruptures and has not

experienced any ruptures as a result ofthe field evaluation program.

Nissan files DIR

On July 17, 2017, Nissan submitted a DIR. Nissan's DIR indicates: "As of

June 28, 2017, Takata has conducted evaluations of 895 Nissan PSDI-5 driver air bag inflators

with calcium sulfate returned from the field. The Nissan field returned inflators have had zero

ruptures in ballistic test deployments and one Nissan inflator exhibited an elevated internal

pressure during the deployment testing." Nissan's DIR also indicates that with respect to remedy

parts, "[p]arts availability is currently under study."

Ford/lies DIR in response to Takata without conceding a defect exists in Ford vehicles

On July 17, 2017, Ford's Field Review Committee reviewed the concern and determined

that Takata's test data and technical assessments do not indicate that the PSDI-5 inflator design

in Ford vehicles currently presents a risk to safety. Ford also approved an expansion of its

voluntary field study.

On July 18, 2017, Ford submitted its DIR, indicating it would file a petition for a

determination of inconsequentiality. Ford's DIR identified the following vehicles equipped with

the desiccated version ofthe PSDI-5 driver airbag inflator:

(i) 2007-2011 model year Ford Ranger vehicles;

(ii) 2006-20 12 model year Ford Fusion and Lincoln Zephyr/MKZ vehicles;

(iii) 2006-2011 model year Mercury Milan vehicles; and
(iv) 2007-20 10 model year Ford Edge and Lincoln MKX vehicles.

On July 20, 2017, Mazda Motor Corporation ("Mazda") submitted its corresponding

DIR, indicating Mazda intended to file a petition for inconsequentiality following Ford's

determination. Since 2007-2011 Ford Ranger and 2007-2009 Mazda B-Series vehicles are built

on identical platforms and use identical airbag inflators, Ranger data is representative ofBSeries.

Ford files petition for inconsequentialitv

Takata's engineering analysis and the available data indicate that the PSDI-5 inflators in

Ford vehicles have not demonstrated a pattern of degradation in density. The PSDI-5 inflators in

Ford vehicles have significant design differences discussed later in this document. Takata's

July 10, 2017 filing does not in fact determine that the PSDI-5 inflators in Ford vehicles actually

contain a defect at this time, or that they will develop one over time.

It is Ford's beliefthat once its engineering analysis is complete, Ford will be able to

supplement or amend its petition with a complete analysis, which will allow the Agency to make

a determination on all Ford vehicles equipped with the desiccated PSDI-5 driver airbag inflator

In the meantime, Ford will continue to design, develop, validate, and secure production capacity

for permanent replacement driver airbag inflators. Ford's continuing inflator study will not

impact the availability of permanent replacement parts should they be needed.

Its]
DISCUSSION

A. Unlike Nissan's data, Takata's analysis of Ford inflators does not show a

degradation in tablet density or an increase in inflation pressure.

Takata has analyzed over 1,400 PSDI-5 driver airbag inflators (approximately 1,000 parts

from the Nissan Versa program and approximately 423 parts from the Ford Ranger program).

For the Ford Ranger analysis, Takata received approximately 400 parts from Ford's part

harvesting program and acquired 20 parts from salvage yards, where the conditions used to store

the parts cannot be determined. As part of its analysis, Takata conducted live-dissections and

ballistic evaluations, which are further detailed below.

Ford also designed and manufactured an equivalent version ofthe Ranger for Mazda

known as the "B-Series." Because 2007-2011 Ford Ranger and 2007-2009 Mazda B-Series

vehicles are built on identical platforms and use identical airbag inflators, Ranger data is

representative ofB-Series. Ford's discussion of Takata's testing and analysis on 2007-2008 MY

Ford Ranger vehicles should apply with equal force to 2007-2009 MY Mazda B-Series.

1. Live dissections were used to quantify the effects of environmental exposure, and

demonstrate consistent inflator output performance.

Takata performed live-dissections of approximately 360 desiccated PSDI-5 inflators

obtained from Ford's part harvesting program and from salvage yards. Takata measured autoignition tablet discoloration, generate density, moisture content ofthe inflator constituents that

indicate exposure to elevated temperatures and moisture, and did not identify a reduction in

density trend.

11
a. Visual inspections evidence time-in-service, but not tablet density loss.

Takata visually inspected the generate tablets from the primary chamber, secondary

chamber, and the primary and secondary auto-ignition tables. Takata observed slight

discoloration ofthe propellant tablets in the primary and secondary chambers. This slight

discoloration indicates the propellant has been exposed to elevated temperatures and is not an

indicant by itselfthat the propellant has degraded.

Takata also examined primary and secondary booster auto-ignition tablets for changes in

color that indicates exposure to temperature cycling in the presence ofmoisture, but the color

change cannot be used to indicate changes in density. Takata also examined primary and

secondary booster auto-ignition tablets for changes in color. In the course of assessing the

exposure ofthe tablets, Takata compares the color ofthe auto-ignition tablet to a chart, where a

value of 1 denotes little if any discoloration indicating minimal exposure, while a value of 10

denotes a tablet that is almost black indicating severe exposure. For inflators harvested in Takata

Zone 1 (South Carolina, Georgia, Florida, Alabama, Mississippi, Louisiana, and Texas), the vast

majority ofthe auto-ignition tablets' color was within the 1-3 range after seven to eleven years of

vehicle service. Seven samples were in the 5-6 range.

b. Tablet density measurements do not show degradation of the propellant.

Takata measured the mass and dimensions ofthe propellant tablets in the primary and

secondary chambers in order to calculate average tablet density. Ford notes that a small number

ofsamples were measured with a density slightly below the minimum average tablet production

specification, while a nearly equal number ofsamples measured densities higher than the

12
maximum average tablet production specification. These data do not support a conclusion that

tablet density is degrading in the inflators designed for Ford after 10 years ofservice.

To understand these inconsistent results, it is important to understand what these

measurements represent. The reported density measurement is a calculation derived from a

model that assumes both (1) certain uniform characteristics ofthe tablets, and (2) consistent

measurement accuracy between samples. The range of density measurements reported both

above and below the average tablet density production specification showed a normal statistical

distribution with low standard deviation. This can be explained by variability in measurement

accuracy between samples. Takata's observation of no trend in density degradation is further

supported by ballistic deployment test results below.

2. Ballistic deployment tests show no increase in pressure.

Takata conducted ballistic deployment tests of 47 PSDI-5 desiccated driver airbag

inflators obtained from 2007 -2008 Ford Ranger vehicles and measured a maximum primary

chamber pressure of only 49.6 MPa. Although the age ofthese inflators can range from eight to

ten years of exposure in the field, none ofthe inflators has exceeded the production primary

chamber pressure specifications, including those harvested from salvage yards with

environmental exposure that is unknown, but potentially more severe than those harvested from

customer vehicles.

13
2007 -2008 Ford Ranger P501-5 Primary Chamber Pressure

:1r /'

/

Ow

Th.(,)

Consistent with the density measurements previously discussed, the primary chamber

pressure plot indicates the data is consistent with data obtained from newly manufactured PSDI5 inflators used in Ford vehicles. More importantly, the data show no increase in pressure.

Additionally, Takata had not observed a pressure vessel rupture on any desiccated PSDI-5

inflator nor any pressure excursions. During the approximately 500 ballistic tests conducted on

desiccated PSDI-5 field return inflators from Nissan vehicles, Takata measured one primary

chamber pressure that exceeded 60 MPa. The maximum primary chamber pressure that Takata

measured on the PSDI-5 inflators was approximately 15 MPa lower than on the Nissan inflator.

B. There are design differences between the inflators used in Ford vehicles versus the

inflators in Nissan vehicles that may account for the performance differences.

The current results from live-dissection and ballistic deployment tests conducted by

Takata on field return parts acquired from 2007-2008 MY Ford Ranger vehicles do not support

conducting a safety recall on the desiccated PSDI-5 driver airbag inflators. Ford also believes

there are significant design differences between the Nissan and the Ford variants ofthe

14
desiccated PSDI-5 inflator that may account for the difference in material properties ofthe

generate and the differences in primary chamber pressure measured during ballistic deployment

tests. The Ford variant ofthe PSDI-5 inflator has fewer potential moisture sources because they

contain only two auto ignition tablets that are foil-wrapped to prevent potential moisture

migration to other constituents within the inflator. The Ford variant also utilizes EPDM generate

cushion material which further reduces generate movement over time, maintains generate

integrity, and leads to consistent and predictable burn rates.

Takata's PSDI-5 inflator refers to a family of dual stage driver airbag inflators utilizing

similar structural architecture and generate configurations. Due to differences in vehicle crash

performance, packaging, and manufacturer specifications, Takata tailors their inflators to meet

each vehicle manufacturer's design and test requirements. Although both dual stage driver airbag

inflators use PSDI-5 designation, there are significant design differences between the Nissan and

Ford versions ofthe PSDI-5 and are summarized in the table below.

Inflator Component Nissan Ford

Secondary Cup Auto- 3 2

Ignition (Al-i) Tablets

Secondary Cup AutoIgnition No Yes

Auto-Ignition Seal

Divider Disk Foil Seal No Yes

Primary Cushion Material Ceramic EPDM

Secondary Cushion Ceramic EPDM Material

. The Nissan version contains three Auto-Ignition (Al-i) tablets compared to two in

the Ford version ofthe desiccated PSDI-5 inflator. Takata has stated that

moisture can be transmitted between the various constituents within the inflator

(Generate -2004, Booster -3110, Desiccant -CaSO4, and Auto-Ignition tablets).

15
The Ford version contains 33% less auto-ignition material that could be a

potential moisture source.

Additionally, the Ford PSDI-5 inflator Al-i tablets are sealed in foil, which

prevents the transfer ofmoisture from the Auto-Ignition tables to other

constituents (Generate -2004, Booster -3110, or Desiccant -CaSO4) within the

inflator.

 ̄ The Ford version ofthe PSDI-5 inflator uses EPDM as the primary and secondary

chamber cushioning material to reduce the likelihood ofthe generate surface to

spall due to road vibration. As a result ofthe EPDM cushion, the generate tablets

remain intact and will have a consistent and predictable burn rate.

 ̄ Another feature the Ford version ofthe PSDI-5 inflator was the addition of

divider disk foil tape. The foil tape reduces the ability ofthe inflator constituents

to transfer moisture amongst themselves due to temperature cycling in the

presence of high humidity.

C. Ford is committed to further investigation of PSDI-5 inflators.

Takata's data show a substantial difference in the condition of desiccated PSDI-5

inflators between the Nissan and Ford designs. Ford is concerned about the changes observed in

the inflators designed and used by Nissan and is committed to intensify the field sampling

program. Ford is expanding the scope ofthe sampling and is involving leading industry experts

to assess any potential risks from desiccated PSDI-5 inflators in Ford products. The details of

our plan are outlined below.

16
1. Part Acquisition Program

Ford has approved a field part acquisition program (17B23) to gather approximately

6,000 desiccated PSDI-5 driver airbag inflators from the following vehicle lines located in the

High Absolute Humidity areas ofthe country (Florida, Georgia, Alabama, Mississippi,

Louisiana, Texas, and South Carolina):

2007-2008 MY Ford Ranger

2006-2007 MY Ford

2006-2007 MY Mercury Milan

2006-2007 MY Lincoln ZephyrlMKZ

2007-2008 MY Ford Edge

2007-2008 MY Lincoln MKX

Ford has released like-for-like Takata desiccated PSDI-5 driver airbag replacement kits

for the program. Takata has committed to having the kits produced in September 2017, at which

time Ford will be able to notif' customers in the HAB area and request that they participate in

this important engineering study.

2. Continued Inflator Testing and Engineering Analysis

Takata will continue to evaluate field return desiccated PSDI-5 driver airbag inflators.

To supplement Takata's analysis and to further support Ford's ongoing investigation, Ford is

engaging third party experts to analyze field return parts from Ford's expanded inflator study and

provide independent technical assessments. The proposed analysis will consist ofthe following:

17
Engineering Analysis

1. Design Comparison- review the engineering drawings ofthe PSDI-5 ZN and ZQ family and

compare with other families ofinflators.

2. Statistical Assessment -conduct data analysis to determine ifthe inflator performance

characteristics are dependent upon platform inflator age, climate or other factors.

3. Ballistic Modeling -conduct analysis of data from tank and heavy weight testing to

investigate the sensitivity to various factors.

Testing

1. CTScanning -scan the outer diameter measurements ofrandomly oriented 2004 domed

propellant tablets.

2. Inflator Disassembly -disassemble the five highest and five lowest diameter from the

representative populations offield return inflators.

Propellant Testing

1. Moisture Content -measure the quantity and distribution ofmoisture inside of and field

return parts.

2. Closed Bomb Burn Rate -compare new and field return parts for signs of abnormal burning

3. X-Ray micro Computer Tomography -examine 2004 propellant to look for voids and high

density inclusions.

4. Thermogravimetric/Differential Scanning Calorimetry Analysis -determine the extent of

decomposition ofAl-i Propellant.

18
REQUEST FOR RELIEF

For the foregoing reasons, Ford requests that NHTSA determine that the condition

identified in Takata's July 10, 2017 filing is inconsequential as it relates to motor vehicle safety

in the subject Ford vehicles. In addition, Ford respectfully requests that NHTSA provide Ford

until March 31, 2018, to complete its intensified and expanded inflator field study, aging

assessment, and testing on additional samples and vehicle types to evaluate the performance of

the Takata desiccated PSDI-5 driver airbag inflators before making a determination on Ford's

petition.

Takata has analyzed over 400 field return PSDI-5 driver airbag inflators acquired from

2007-2008 MY Ford Ranger vehicles operated in Florida, Arizona, and Michigan. Takata's

results indicate that inflators with over a decade of exposure to extreme high temperature and

high absolute humidity environments are not showing a trend of degrading tablet density or

increasing the risk of a high pressure deployment that could rupture the inflator. While these data

are certainly good news for the safety ofpeople currently using these Ford Rangers, the results

on the Nissan design inflators are of concern to Ford. Ford is committed to expanding the scope

ofthe field study and employing the highest level ofindependent technical expertise to analyze

these samples and understand any potential future risks from these inflators.

Once the engineering analysis is complete, Ford will review its findings with the Agency

and will supplement or amend the petition to provide a full record so that NHTSA can make its

determination. Additionally, Ford will continue to design, develop, validate, and secure

production capacity for the non-desiccated PSDI-5 permanent replacement inflators, should they

be needed, concurrent with the evaluation program timing described above. Consistent with the

19
timing plan presented to the Agency on July 6, 2017, Ford estimates being able to begin

producing parts by March 2018.
81812017 Vehicle Report I Recalls Management Portal

0 Mazda North American Operations

Vehicle Report

NHTSA ID: 17V466 Transaction ID: 17-00842-19467-11 (Amendment 1)

Required fields indicated with *

Manufacturer: Mazda North American Operations

1025 Connecticut Avenue, NW Steve Limtiaco

Washington DC 20036 9498527225,

This is a Safety Defect Report. Filing a petition pursuant to 49 CFR 556

Vehicle Information

Mazda B-series 2007 - 2009

* Model Yr. Start: 2007 * Model Yr. End: 2009 Type: LIGHT VEHICLES

* Make: Mazda Body Style: PICKUP TRUCK

* Model: B-series Powertrain: GAS

Descriptive Information:

Production Dates Begin: 02/21/2006 Affected vehicles are equipped with Takata PSDI-5 driver frontal air bag

End 06118/2009 inflators that use calcium sulfate as a desiccant. Plant information; Edison

Assembly Plant of Ford Motor Company, USA

VIN Range(s):

VIN Range(s):

VIN Range(s):

VIN Range(s):

VIN Range(s):

VIN Range(s):

Number potentiall

Begin: 4F4YR12D97PM00002

Begin: 4F4ZR47E17PM00003

Begin: 4F4YR12D28PM00165

Begin: 4F4ZR47E68PM00001

Begin: 4F4YR12D59PM00002

Begin: 4F4ZR47E49PM00001

' involved: 5848 Estims

Defect I Noncompliance Description

For this Defect/Noncompliance:

End: 4F4YR12097PM07046

End: 4F4ZR47E87PM07241

End: 4F4YR12038PM06198

End: 4F4ZR47E18PM06031

End: 4F4YR16029PM02400

End: 4F4ZR47E79PM02261

ted percentage of involved with defect: %

* Describe the defect or noncompliance:

On July 10, 2017, Takata submitted a Defect Information Report (DIR) on all

PSDI-5 driver side air bag inflators which use 2004 propellant with calcium

sulfate as a desiccant. Mazda B-series is designed and manufactured by Ford.

Ford's Ranger and Mazda's B-Series are built on identical platforms and use

identical air bag inflators. Therefore, Ranger data is representative of B-Series.

Ford informed Mazda that no problem was found as a result of investigation on returned field parts of Ford Ranger and Ford had not received any incidents

in the field. Also, Mazda is not aware of any reports of accident or injury

related to this condition

If a noncompliance, provide the applicable FMVSS:

If applicable, provide any further FMVSS affected:

Describe the cause: According to the Takata filing, the propellant tablets in some of the subject

inflators may experience an alteration over time, which could potentially lead

to over-aggressive combustion in the event of an air bag deployment.

This Recall affects all vehicles.

* Describe the safety risk:

Ford, which designed and manufactured the affected vehicles, does not

believe that the currently available test data and technical assessments

indicate that the PSDI-5 inflator design in Ford and Mazda vehicles present a

risk to safety. Based on our discussions and review of the information

provided by Ford, Mazda intends to file a Petition for Inconsequentiality for

exemption from the notification and remedy requirements of the Safety Act,

with a request that the agency provide Mazda, in conjunction with Ford, until

March 2018 to complete its expanded inflator field study, aging assessment

and testing on additional samples before making a determination on the

petition. Since Ford's Ranger and Mazda's B-Series are built on identical

platforms and use identical air bag inflators, Ranger data is representative of

B-Series.

Identify any warning which can precede or occur:

If applicable, identify the manufacturer of the defective or noncompliant component. If the manufacturer of the component is unknown, provide the

information for the company that supplied the subject component.

Component manufacturer

Company Information Company Contact Information

Company Name: Takata / T K Holding First Name:

INC.. Last Name:

Country: United States Position:

Address 1: 888 16th street, NW, Suite 800, Washingt Email:

Address 2: 12-31 Akasaka 2-chome Minato-ku, in Japa

https://map.safercar.gov/mportal/rcl/ViewSubmittedReport
8/8/2017 Vehicle Report I Recalls Management Portal

Cit Phone:

State:

Zip/Postal Code: 20006

Chronology of Defect / Noncompliance Determination

Provide the chronology of events leading up to the defect decision or test data for the noncompliance decision.:

On July 10, 20017, Takata submitted a Defect Information Report (DIR) to NHTSA on all PSDI-5 driver side air bag inflators which use 2004 propellant with

calcium sulfate as a desiccant. On July 17, 2017, Ford's Field Review Committee reviewed the concern and approved a field action. On July 18, 2017, based

on Ford's decision, Mazda held a Quality Audit Committee meeting and approved a field action with intent to file a petition of inconsequentiality regarding the

driver side air bag inflator on the 2007 through 2009 MY Mazda B-series vehicles.

Identify the Remedy

Describe the defect/noncompliance remedy program, including the manufacturers plan for reimbursement.

Mazda will submit a petition for exemption from the notification and remedy requirements of the Safety Act within 30 days on the grounds of Ford's current

technical assessment that this non-compliance is inconsequential.

Describe what distinguishes the remedy component from the recalled component.

Identify and describe how and when the recall condition was corrected in production.

Identify the Recall Schedule

Describe the recall schedule for notifications.: Planned Dealer Notification Begin Date:

At this time, Mazda does not plan to submit notification letters to owners or dealers unless otherwise instructed to do so based on the outcome of the Planned Dealer Notification End Date:

petition for inconsequentiality. Planned Owner Notification Begin Date:

Planned Owner Notification End Date:

Manufacturers identification code for this recall (if applicable):

Please be reminded that owner notification letters must be mailed no more than 60 days from submission of this report.

Manufacturer Comments to NHTSA Staff

Document Upload

There are 0 documents associated with this report.

1200 New Jersey Avenue, SE, West Building Washington DC 20590 USA 1.888.327.4236 ITY 1.800.424.9153

This application works best in IE9 and above and recent versions of Firefox, Chrome and Safari

https://map.safercar.gov/mportal/rcl/ViewSubmitted Report 2/2