January 09, 2019

On December 21, 2018, the Independent Monitor of the Takata Recalls (the "Independent Monitor") issued a second report (the "Report") about the state of the Takata recalls.

As of October 2018, approximately 17 million vehicles, from 19 vehicle manufacturers, still had unrepaired defected Takata airbag inflators. Additional vehicles are planned to be recalled in January 2019. The defect causes metal shrapnel to explode from the airbag in the event of a crash where hundreds of injuries and 15 fatalities in the U.S have been alleged as the result of confirmed inflator explosions. The Report discusses initiatives implemented by affected vehicle manufacturers that have resulted in unprecedented increases in recall completion percentages, especially for the older and more dangerous vehicles affected. These initiatives include activities such as improved data quality for affected vehicle owners, segmented analysis, communications, overcoming owner inconvenience, dealer engagement, third party engagement and canvassing.

Improving Data Quality

The Report highlights the importance of identifying supplemental vehicle owner information. Historically, vehicle manufacturers have leveraged DMV registration data. The Report indicates that DMV registration data typically allows vehicle manufacturers to reach 50-60% recall completion percentages when used in combination with effective communications. The Independent Monitor noted that past this level of completion, traditional DMV vehicle owner registration data may not be accurate as vehicle owners may not register their vehicle and may move/change addresses frequently. The Report recommends that vehicle manufacturers supplement DMV registration data with non-DMV registration data to obtain new and/or additional vehicle owner information that can aid in reaching higher recall completion percentages and frequently refresh the data that is received to ensure the most current information is being used to contact vehicle owners.

Segmented Analysis

The Report discusses the importance of identifying different types of vehicle owners and developing communications to overcome the varying needs and barriers to recall completion of the diverse unrepaired population. The Report provides thirteen examples for different owner segments as well as a targeted outreach strategy for the vehicles that fall within each classification. For example, the report identifies language spoken as an owner segment and suggests outreach materials to be sent in non-English languages as well as call center agents and door-to-door canvassers to have the appropriate language proficiency. Distance to dealer is highlighted as another example where it is noted that vehicle owners located farther away from dealerships may face greater inconveniences and require special accommodations such as towing, mobile repair or authorized repair at an independent repair facility.

Communications

The Report presents four challenges in recall communications: awareness and understanding of the Takata recalls is lacking, vehicle owners find recall outreach confusing, many vehicle owners do not understand English and affected vehicle owners are skeptical of recall outreach. A list of thirteen communication best practices based on vehicle owner research, communications pilots and collaboration with affected vehicle manufacturers follows as solutions to the aforementioned challenges. For example, the Report recommends that vehicle manufacturers should use simple words and phrases, personalize outreach to the vehicle owner and provide information in languages other than English.

The Report also contains examples where vehicle manufacturers have successfully communicated with unresponsive vehicle owners and increased repair rates. These examples include the use of high intensity imagery, frequent and multi-channel outreach, certified mail, multi-lingual postcards and community efforts to raise awareness.

Overcoming Owner Inconveniences

The Report identifies addressing owner inconvenience as another key to further success in the Takata recalls. A survey of vehicle owners affected by the Takata recalls is cited where 40% of respondents listed inconvenience as their reason for not having the repair completed. Effective strategies that have been implemented by vehicle manufacturers to overcome vehicle owner inconvenience include mobile repair, extended service hours at franchised dealers, free towing and free rental vehicles.

Dealer Engagement

The Report states that franchised dealers are critical players in successful recall strategies and how engaged dealers tend to become more proactive in their recall outreach efforts, more likely to assist vehicle owners in overcoming barriers to recall completion, more likely to take advantage of services to overcome owner inconvenience, more likely to discuss challenges and best practices - often gleaned from interactions with their local communities - with the vehicle manufacturer and less likely to miscommunicate parts availability. Observations regarding franchised dealers include: many dealers view themselves as detached from recalls, many affected vehicle owners expect engagement from dealers, dealers do not always fully deploy or understand available recall services, dealers are sometimes uninformed as to parts availability and dealers do not always follow up with affected vehicle owners trying to schedule recall repairs.

The Report indicates that there is potential, and need, for improvement. Eight strategies of effective dealer engagement are presented focused on dealers being successful partners in Takata recall repairs through better communication between vehicle manufacturers and dealers, provision of tools for success and development of individualized dealer action plans.

Third Party Engagement

The Report indicates that vehicle manufacturers should engage with third parties, including state DMVs, independent repair facilities, automobile insurers, vehicle auction facilities and independent used car dealerships. For example, state DMV engagement has resulted in repair rates increasing by as much as 250% following recall mailings on DMV letterhead.

Canvassing

The Report indicates a significant industry shift toward canvassing where thirteen vehicle manufacturers have engaged in canvassing pilots either individually or in conjunction with other vehicle manufacturers and the Monitor. Canvassing is presented as a successful recall repair strategy for later stages of a recall campaign where repair appointments are scheduled between 70% and 85% of the time when an individual who could reasonably schedule an appointment was contacted. Repair rates were reported more than nine times higher for vehicle manufacturers that participated in canvassing as compared to a control group of manufacturers that did not participate in vehicle owner canvassing.

To learn more about the Takata Recalls, the first report was issued on November 15, 2017.

Additional information about the Takata recalls can be found at AirbagRecall.com.

To check if your vehicle is affected by the Takata recalls, enter your VIN at NHTSA.gov/recalls.

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