Audit Reports

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May 31, 2023

NHTSA Has Not Fully Established and Applied Its Risk-Based Process for Safety Defect Analysis

Self-initiated
Project ID: 
ST2023031
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What We Looked At
The impacts of a motor vehicle safety defect can be significant. The National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to investigate motor vehicle safety issues and requires manufacturers to notify the Agency of all safety-related defects involving unreasonable risk of accident, death, or injury. NHTSA’s Office of Defects Investigation (ODI) plays a key role by gathering and analyzing relevant information, investigating potential defects, identifying unsafe motor vehicles and items of motor vehicle equipment, and managing the recall process. Given the impact NHTSA’s efforts to adequately address safety defects have on the traveling public, we initiated this audit to assess ODI’s current processes for investigating and identifying safety defects. Specifically, we analyzed ODI’s risk-based oversight procedures for prioritizing its work, determining which issues were appropriate for investigation, and evaluating potential risks of harm posed by potential safety defects.
 
What We Found
NHTSA’s ODI has made progress promoting a safer transportation system for the traveling public by restructuring its office, modernizing its data repository and analysis systems, and enhancing its risk-based investigative processes to assess safety-related defects. However, ODI did not meet its timeliness goals for the five types of investigations we examined, and the Agency did not upload investigation documentation to its public website in a timely manner. ODI does not have an integrated information system to facilitate the safety defect investigation and recall processes. Furthermore, ODI does not consistently document information used for investigating and identifying potential defects and unsafe motor vehicles or motor vehicle equipment in the Agency’s internal and external files. In addition, ODI does not consistently follow its procedures for issue escalation and lacks guidance for other pre-investigative efforts.
 
Our Recommendations
We made 12 recommendations to help NHTSA improve its risk-based processes for investigating and identifying potential motor vehicle and equipment safety defects. NHTSA concurred with 10 of our 12 recommendations, partially concurred with 1 recommendation, and did not concur with 1 recommendation. NHTSA proposed alternate action for the recommendation with which it did not concur. We consider all 12 recommendations resolved but open pending implementation.

Recommendations

Open

Closed

No. 1 to NHTSA

Assess timeliness goals by: a. Determining whether its current timeliness goals are realistic and attainable and, if necessary, revising those goals. b. Developing and implementing a plan for meeting timeliness goals.

Closed on 09.01.2023
No. 2 to NHTSA

Develop and implement procedures for conducting audit query and
timeliness query investigations.

No. 3 to NHTSA

Develop and implement a system of accountability to improve ODI’s compliance with processes, including: a. Notifying petitioners regarding the decision to grant or deny petitions within 120 days; b. Documenting timely supervisory review of documents and related analyses during the pre-investigative and investigative processes and conducting timely reviews of manufacturer-provided data; c. Developing and following a written plan for all phases of investigations; and d. Documenting substantive pre-investigative and investigative-related communication with manufacturers.

No. 4 to NHTSA

Develop and implement improved procedures for ensuring investigation documentation is uploaded to the public website, including:
a. Establishing timelines for ensuring all required documents are posted; b. Identifying documents missing from the public website and mitigate the backlog; c. Assigning responsibilities between the Correspondence Research Division and investigators; and d. Establishing timelines for contractors to redact information.

No. 5 to NHTSA

Revise Information Request (IR) procedures to ensure consistent application by each of the divisions, and develop a system of accountability to ensure compliance with the revised procedures when: a. Issuing and approving a manufacturer-requested IR letter response extension; and b. Requesting information from manufacturers.

No. 6 to NHTSA

Develop and implement procedures for the planned integrated information system including a user guide for how to document decisions, actions taken, and communication with stakeholders, as well as where to store specific pre-investigative and investigative documentation.

No. 7 to NHTSA

Complete expeditious integration of the information systems for pre-investigation and investigation processes, including data migration.

No. 8 to NHTSA

Develop and implement a consistent procedure to govern ODI’s practice of negotiating a resolution of potential safety defects with manufacturers.

Closed on 09.01.2023
No. 9 to NHTSA

Develop and implement a requirement that all information used to support decisions made during the pre-investigative and investigative processes are documented and retained, including the supporting information for safety defect analyses and related briefings.

No. 10 to NHTSA

Develop and implement guidance for determining which issues investigators should present at Hot Issues meetings based on ODI’s risk-based analysis process.

No. 11 to NHTSA

Reconcile the risk matrix and issue escalation procedures and establish specific guidance on when an investigation should be opened.

No. 12 to NHTSA

Develop a definition of high-interest topics and the actions needed to address these issues.