After conducting an audit of the National Highway Traffic Safety Administration’s (NHTSA) Office of Defects Investigation (ODI), the U.S. Department of Transportation’s Inspector General recently issued a report concluding that NHTSA had not fully established and applied its risk-based process for safety defect analysis.

The Inspector General found that:

• ODI did not meet its timeliness goals for the five types of investigations examined;
• ODI did not upload investigation documentation to its public website in a timely manner;
• ODI did not have an integrated information system to facilitate the safety defect investigation and recall processes;
• ODI did not consistently document information used for investigation and identifying potential defects and unsafe motor vehicles or motor vehicle equipment in the Agency’s internal and external files; and
• ODI did not consistently follow its procedures for issue escalation and lacks guidance for other pre-investigative efforts

Of the 75,267 consumer complaints the agency received in 2019, with 32,482 needing “further substantive review,” only 88 investigations were opened. However, the audit report recognized that the low number of investigations was also due to manufacturers being proactive and electing to launch their own recalls before ODI pursued an investigation.

The Inspector General made 12 recommendations to help NHTSA improve its risk-based processes for investigating and identifying potential motor vehicle and equipment safety defects, and NHTSA concurred with 10 of the 12 recommendations. These recommendations were:

1. Assessing timeliness goals by determining whether current goals are realistic and attainable;
2. Developing and implementing a plan for meeting timeliness goals;
3. Developing and implementing a system of accountability to improve ODI’s compliance with processes;
4. Developing and implementing improved procedures for ensuring investigation documentation is uploaded to the public website;
5. Revising 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;
6. Developing and implementing procedures for the planned integrated information system;
7. Completing expeditious integration of the information systems for pre-investigation and investigation processes, including data migration;
8. Developing and implementing a consistent procedure to govern ODI’s practice of negotiating a resolution of potential safety defects with manufacturers;
9. Developing and implementing 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;
10. Developing and implementing guidance for determining which issues investigators should present at Hot Issues meetings based on ODI’s risk-based analysis process;
11. Reconciling the risk matrix and issue escalation procedures and establish specific guidance on when an investigation should be opened; and
12. Developing a definition of high-interest topics and the actions needed to address these issues.