WASHINGTON -- The 35 million-plus Takata airbag inflators added last week to the recall rolls haven't been linked to any injuries or deaths. They haven't ruptured in the field or failed in lab tests. The National Highway Traffic Safety Administration says they do not present an "unreasonable risk to safety."
But eventually, NHTSA says, they will.
And that's why the agency took the unusual, if not unprecedented, step of ordering a phased recall that stretches over the next three and a half years. Under this approach, manufacturers of the covered vehicles will issue recall notices in five waves, with each wave hitting just before the inflators become prone to developing the same dangerous defect that has been linked to 10 deaths and more than 100 injuries in the U.S.
Consider it a just-in-time recall.
The approach is made possible by NHTSA's unique application of its legal powers to wrestle the industry's most pervasive and challenging recall into submission. It takes into account the results of several investigations into the causes of the rupture as well as the need to closely manage the supply of replacement inflators.
It also reflects NHTSA chief Mark Rosekind's determination to enforce what he calls a "proactive safety culture" -- not only at manufacturers and suppliers but within the agency itself.
A NHTSA review of three independent investigations into the root cause of the Takata inflator ruptures confirmed that the ammonium nitrate propellant, when used without a chemical additive to prevent moisture absorption, degrades after several years of exposure to humid air and temperature fluctuations. When degraded, the propellant can explode with too much force when the airbag deploys, rupturing its container and spraying vehicle occupants with metal shards.
"The science clearly shows that these inflators become unsafe over time," Rosekind said in a press conference last week.
According to Harold Blomquist, a chemistry expert hired by NHTSA to review the root-cause studies, the defect appears within six to 25 years from when the inflator was manufactured.
Under terms of Takata's consent agreement with regulators, that finding was enough for NHTSA to trigger the additional recalls. But the execution will be different from previous rounds. Takata will declare up to 40 million inflators defective on a rolling basis through the end of 2019. The riskiest inflators -- in general, the oldest ones in the hottest climates -- will be recalled first, and then the less-risky ones.
"The whole purpose of NHTSA is to prevent injuries and deaths," said Joan Claybrook, a consumer advocate and NHTSA's administrator under President Jimmy Carter. "If it can be anticipated that this defect will occur ... I think that that's an appropriate step."
The additional recalls will add strain to a supply chain already racing to ramp up replacement inflator capacity. But by phasing the expanded recalls based on risk, NHTSA officials hope to achieve two goals: Remove the risky inflators before someone gets hurt and avoid a crush of replacement demand that suppliers can't fulfill.
"Because we've now laid out the next five recalls for Takata, it allows the industry and the supply chain to anticipate needs and to let NHTSA know what's coming so we can set the deadlines," NHTSA spokes-man Bryan Thomas said.
Allan Kam, a safety consultant and former NHTSA enforcement attorney, says the consent decrees used during Rosekind's tenure at NHTSA have been "very effective" tools to direct how manufacturers handle recalls.
During NHTSA's press conference last week, Rosekind acknowledged concerns about part supplies, though they were somewhat muted.
Scott Upham, president of Valient Market Research, says Autoliv, Daicel and TRW -- which together are making 2 million replacement inflators per month -- will ramp up to 3.75 million a month by midyear. At that rate, it would take less than two years to produce enough replacements for the up to 68.8 million inflators covered under existing recalls and the new rounds.
Upham said he expects those suppliers to ramp up further as a result of the announcement.