Denial of Motor Vehicle Defect Petition, DP18-002, 16823-16827 [2022-06217]
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16823
Federal Register / Vol. 87, No. 57 / Thursday, March 24, 2022 / Notices
number of invitations is based on the
need to recruit 1,500 participants, 750 of
whom are either non- or part-time seat
belt users. Based on corporate
experience with online panels, the
marketing research firm providing
access to their panel of participants
estimates a participation rate of 20%.
Furthermore, NHTSA research has
shown that while most drivers reported
wearing their seat belts every time they
drive, approximately 20% are either
non-users or part-time users.3 Finally,
NHTSA estimates that 90% who qualify
and read the consent form will provide
consent and complete the study. To
obtain a sample of 750 consenting
participants in the non/part user group,
requires a universe of 20,850 potential
respondents. Of the 20,850 invited
panelists, we expect 20% or 4,170
volunteers who are interested and
qualify. Of the 4,170 who are interested,
we expect 20% or 834 volunteers will
be non- or part-time seat belt users. Of
the 834 volunteers who are non- or part-
time seat belt users, we expect 90% or
750 to consent and complete the study.
The marketing research firm will
provide a link to the consent form to the
first 834 non- or part-time seat belt users
and to the first 834 full-time seat belt
users who are interested and qualify.
(Once the firm reaches 750 completions
from full-time users, which is expected
to occur before the 750 completions
from non- or part-time users, they will
no longer provide links to the informed
consent to qualified full-time users.)
Frequency: This study is a one-time
information collection, and there will be
no recurrence.
Estimated Total Annual Burden
Hours: 1,057.
The total estimated burden associated
with this collection is 1,057 hours. The
sample of potential participants will
receive an email invitation from
Schlesinger Group, a marketing research
firm that specializes in providing
sampling pools of panelists, with
screening questions to determine
eligibility. The 20,850 potential
participants are expected to spend 1
minute each in reading the invitation
email for an estimated 348 hours. Those
who are interested (estimated to be
20%, or 4,170 individuals) are expected
to spend 1 minute each in completing
the screener form for an estimated 70
hours. Schlesinger will provide
electronic links to the consent form to
the first 834 full-time seat belt users and
to the first 834 part-time/non-users who
qualify based on the screening
questions. The 1,668 eligible
participants are expected to spend 5
minutes each reading and completing
the consent form for an estimated 139
hours. The estimated 1,500 consenting
participants will each spend 20 minutes
completing the experiment for an
estimated 500 hours. The total burden is
the sum of the burden across the
invitation/screening, consenting, and
completing the experiment for a total
estimate of 1,057 hours. The details are
presented in Table 1 below.
TABLE 1—ESTIMATED BURDEN HOURS BY FORM
Form
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Form
Form
Form
Form
1599
1604
1600
1601
Description
Participants
Estimated
minutes per
participant
Total estimated
burden hours
per form
......................................................
......................................................
......................................................
......................................................
Invitation Email ..............................................
Screener Form ..............................................
Informed Consent Form ................................
Experiment Form ...........................................
20,850
4,170
1,668
1,500
1
1
5
20
348
70
139
500
Total ........................................................
........................................................................
........................
........................
1,057
Estimated Total Annual Burden Cost:
NHTSA estimates that there are no costs
to respondents beyond the time spent
participating in the study.
Public Comments Invited: You are
asked to comment on any aspects of this
information collection, including (a)
whether the proposed collection of
information is necessary for the proper
performance of the functions of the
agency, including whether the
information will have practical utility;
(b) the accuracy of the agency’s estimate
of the burden of the proposed collection
of information, including the validity of
the methodology and assumptions used;
(c) ways to enhance the quality, utility
and clarity of the information to be
collected; and (d) ways to minimize the
burden of the collection of information
on respondents, including the use of
appropriate automated, electronic,
mechanical, or other technological
collection techniques or other forms of
information technology, e.g., permitting
electronic submission of responses.
3 National Highway Traffic Safety Administration.
(2019, December). The 2016 motor vehicle occupant
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Authority: The Paperwork Reduction
Act of 1995; 44 U.S.C. chapter 35, as
amended; 49 CFR 1.49; and DOT Order
1351.29.
Issued in Washington, DC.
Nanda Narayanan Srinivasan,
Associate Administrator, Research and
Program Development.
[FR Doc. 2022–06260 Filed 3–23–22; 8:45 am]
BILLING CODE 4910–59–P
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety
Administration
[Docket No. NHTSA–2019–0105]
Denial of Motor Vehicle Defect Petition,
DP18–002
National Highway Traffic
Safety Administration (NHTSA),
Department of Transportation.
AGENCY:
safety survey: Seat belt report (Report No. DOT HS
PO 00000
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Denial of petition for a defect
investigation.
ACTION:
This notice sets forth the
reasons for the denial of a petition
submitted on August 7, 2018, by Mr.
Gary Weinreich (the petitioner) to
NHTSA’s Office of Defects Investigation
(ODI). The petition requests that the
Agency investigate alleged ‘‘premature
and excessive frame corrosion’’ in
model year (MY) 2002 through 2006
Toyota 4Runner vehicles. The petitioner
bases his request upon his own
experience with a MY 2005 Toyota
4Runner, a class action lawsuit
settlement involving other Toyota
products, and other complaints of
underbody corrosion in Toyota 4Runner
vehicles that he found in NHTSA’s
online complaint database. After
reviewing the information provided by
the petitioner regarding his vehicle,
facts related to the class action lawsuit
cited by the petitioner, and field data
regarding underbody corrosion in
SUMMARY:
812 798). Author. https://rosap.ntl.bts.gov/view/
dot/43608.
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Federal Register / Vol. 87, No. 57 / Thursday, March 24, 2022 / Notices
Toyota 4Runner vehicles, NHTSA has
concluded that there is insufficient
evidence to pursue further action.
Accordingly, the Agency has denied the
petition.
Mr.
Gregory Magno, Vehicle Defects
Division—D, Office of Defects
Investigation, NHTSA, 1200 New Jersey
Ave. SE, Washington, DC 20590
(telephone 202–366–5226).
FOR FURTHER INFORMATION CONTACT:
By letter
dated August 7, 2018, Mr. Gary
Weinreich (the petitioner) submitted a
petition requesting that the Agency
‘‘perform a high-priority investigation’’
of ‘‘premature and excessive frame
corrosion’’ in model year (MY) 2002
through 2006 Toyota 4Runner vehicles.
The petitioner bases his request upon a
corrosion-related front suspension
failure he experienced in his MY 2005
Toyota 4Runner, a class action lawsuit
settlement involving other Toyota
products, and other complaints of
underbody corrosion in Toyota 4Runner
vehicles that he found in NHTSA’s
online complaint database.
On August 17, 2018, the Office of
Defects Investigation (ODI) opened
Defect Petition DP18–002 to evaluate
the petitioner’s request for an
investigation. ODI has reviewed the
following information as part of its
evaluation: (1) Information provided by
the petitioner regarding his vehicle; (2)
facts related to the class action lawsuit
cited by the petitioner; (3) consumer
complaint data regarding underbody
corrosion in third- and fourthgeneration Toyota 4Runner vehicles.
Scope: The petitioner’s request for an
investigation of premature frame
corrosion in MY 2002 through 2006
Toyota 4Runner vehicles includes both
third- and fourth-generation 4Runner
vehicles that ranged from 12 to 17 years
in age when the petition was filed.
Toyota sold approximately 745,000
third-generation (MY 1996 through
2002), and approximately 603,000
fourth-generation (MY 2003 through
2009) 4Runner vehicles in the United
States.1
Petitioner’s vehicle: On May 24, 2018,
the petitioner experienced a front
suspension failure while driving on the
highway in a 2005 Toyota 4Runner
vehicle that was nearing 13 years of
service.2 He reported the incident to
NHTSA in a Vehicle Owner
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SUPPLEMENTARY INFORMATION:
1 The
analysis here will focus on the fourthgeneration vehicles, which includes the Petitioner’s
vehicle, except where otherwise indicated.
2 The front attachment bracket for the left lower
control arm detached from the frame.
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Questionnaire (VOQ) submitted on May
26, 2018 (NHTSA ID 11098055):
Yesterday, my wife and I and two friends
riding with us narrowly escaped a fatal
accident when the front suspension
separated from the frame due to the corrosion
problem. At highway speed, the vehicle
began shaking violently and the steering was
unable to properly control the vehicle. The
vehicle went off the road after coming close
to hitting an oncoming vehicle.
The petitioner alleged that this failure
resulted from premature and excessive
frame corrosion and provided service
history information and photographs as
supporting evidence.3 ODI reviewed the
information provided by the petitioner,
as well as additional details contained
in a lawsuit he filed against Toyota in
December 2018.4
ODI found that the petitioner’s
vehicle had a history of general
corrosion concerns throughout the
undercarriage that were not isolated to
the frame. The photographs showed that
the vehicle undercarriage was seriously
corroded at the time the incident
occurred. The information indicates
severe general corrosion of the vehicle
undercarriage consistent with many
years of severe use and exposure, but
ODI has not found evidence showing a
design or manufacturing defect in the
vehicle.
The vehicle service history
information that the petitioner provided
supports these observations. Concerns
with underbody corrosion on his
vehicle were first noted by a Toyota
dealer in a multi-point vehicle
inspection performed on April 28, 2011.
The invoice for that inspection noted
‘‘severe and excessive amount of rust on
the undercarriage and on the drive shaft
transmission.’’ Two years later, on
October 21, 2013, another multi-point
inspection by a Toyota dealer observed
further progression of underbody
corrosion damage, noting: ‘‘rust on
shocks/struts and other components,’’
‘‘rust on exhaust system,’’ ‘‘both splash
shields severely rusted,’’ and
‘‘undercarriage very rusty.’’ 5 On July 17,
2017, approximately 10 months prior to
experiencing the suspension failure
incident, an independent repair facility
performing a routine oil change and
brake maintenance informed the
3 Gary Weinreich letter to Stephen Ridella, Ph.D.,
Director, Office of Defects Investigation, August 28,
2018.
4 Gary Weinreich v. Toyota Motor Sales USA Inc.,
et al., Case No. 2:18–cv–03294–RMG, in the U.S.
District Court for the District of South Carolina,
Charleston Division.
5 Records provided by petitioner indicate that
Toyota did not service the vehicle after October
2013.
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petitioner of a concern with ‘‘excessive
frame corrosion’’ on his vehicle.
The service history further indicates
that corrosion concerns in the
petitioner’s vehicle were first observed
in other underbody components (e.g.,
drive shaft transmission, exhaust, splash
shields) and grew progressively worse
over several years before the observation
of ‘‘excessive frame corrosion’’ and
subsequent suspension link failure.
Photographs provided by the petitioner
show that the vehicle’s underbody was
in poor condition when the failure
occurred, with heavy corrosion
throughout the vehicle underbody and
multiple visible perforations in frame
structural members.
The petitioner lives less than a mile
from the ocean, where exposure to
marine salts may lead to increased
vehicle corrosion rates if vehicles are
not regularly cleaned. While no
information was provided regarding the
use, care, and maintenance of the
petitioner’s vehicle, ODI has not
received evidence that the vehicle
received any repairs to address the
noted corrosion concerns prior to the
May 2018 front suspension failure.
Class action lawsuit: The petitioner
cites a class action lawsuit settled by
Toyota in 2017 6 as evidence of the
defect in his vehicle and states that
4Runner vehicles ‘‘were not included in
the class-action lawsuit simply because
there were insufficient complaints
known to the counsel representing the
class at the time it was formed.’’ ODI
has reviewed the referenced lawsuit and
does not agree with the petitioner’s
claims. The vehicles covered by the
class action were equipped with frames
manufactured by a specific supplier
alleged to be using a defective
electrocoating process over a certain
manufacturing period. The subject
4Runner vehicles were not equipped
with frames manufactured by that
supplier.
Starting in 2008, Toyota conducted
multiple service campaigns and
warranty extension programs to address
concerns with premature frame
corrosion in certain vehicles equipped
with frames supplied by Dana Holding
Company (Dana).7 The combined field
actions covered MY 1995 through 2010
Toyota Tacoma, MY 2000 through 2008
Tundra, and MY 2001 through 2007
Sequoia vehicles (‘‘Dana frame
6 www.toyotaframesettlement.com.
7 In December 2009, Dana announced its
agreement to sell its Structural Products Business
to Metalsa, S.A. de C.V, https://
dana.mediaroom.com/
index.php?s=26450&item=69875.
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Federal Register / Vol. 87, No. 57 / Thursday, March 24, 2022 / Notices
vehicles’’).8 Toyota took these actions
after identifying quality concerns with
the electrocoating processes in certain
frames supplied by Dana that could lead
to premature corrosion failures. In 2011,
Dana settled a lawsuit with Toyota for
warranty claim costs related to
premature frame corrosion.9
These issues were presented in other
litigation as well. A class-action lawsuit
filed in Arkansas on October 3, 2014,
alleged that MY 2005 through 2009
Toyota Tacoma vehicles lacked
adequate rust protection on the vehicles’
frames, leading to premature corrosion
failures.10 A separate class-action
lawsuit filed in California on March 24,
2015, made similar claims.11 The
lawsuits were consolidated in a second
amended complaint filed on November
8, 2016. The consolidated complaint
covered MY 2005 through 2010 Toyota
Tacoma, MY 2007 through 2008 Toyota
Tundra, and MY 2005 through 2008
Toyota Sequoia vehicles. The second
amended complaint stated that the
vehicles that were the subject of the
lawsuit were all equipped with frames
manufactured by Dana using ‘‘the same
defective process.’’ The complaint
alleged that, ‘‘The frames on the Toyota
Vehicles are materially the same for
purposes of this lawsuit and suffer from
the same defect. All of the frames were
manufactured by the same corporation
(Dana Holding Corporation) pursuant to
the same defective process.’’
The class action was settled in May
2017. The terms of the settlement
included extending warranty coverage
to 12 years from first use for a Frame
Inspection and Replacement Program.
The settlement was widely reported by
news media.12
Both third and fourth-generation
4Runner vehicles were built in Japan
and are not equipped with frames
manufactured by Dana. Although
private litigation can be a relevant
source of information to consider in the
course of examining a potential vehicle
defect in many cases, the petitioner has
not demonstrated that the litigation he
cites here supports the grant of his
petition.
Complaint analysis: The petitioner
alleged that his analysis of NHTSA’s
complaint database revealed evidence
supporting his claim of premature and
excessive frame corrosion in MY 2002
through 2006 Toyota 4Runner vehicles,
and that differences in field experience
between third- and fourth-generation
4Runner vehicles provide further
evidence suggesting a design or
manufacturing defect in the fourthgeneration products. The petitioner
claims that third-generation Toyota
4Runners ‘‘do not appear to experience
the premature and excessive frame
corrosion.’’ 13 The petitioner stated their
belief that ‘‘Any frame specification
changes between generations may help
identify the root cause(s) of the
problem.’’ 14
ODI’s analysis of consumer complaint
data related to frame corrosion in
fourth-generation Toyota 4Runner
vehicles has not found evidence of a
failure trend indicating a potential
design or manufacturing defect leading
to premature failures. Rather, the data
Probability Distributions of Vehicle Ages
In Frame Corrosion Complaints to NHTSA, MV 1996-2002
tends to show complaint trends
occurring late in vehicle life in high
corrosion regions. Relatively few
complaints involved suspension
detachments, and those that did were
spread among multiple suspension
links, each occurring in older vehicles
operated in high corrosion regions.
Finally, ODI finds no meaningful
difference between frame corrosion
complaint trends and related
suspension detachment allegations in
third- and fourth-generation 4Runner
vehicles.
4Runner complaint trends lag trends
for the Dana frame vehicles by several
years. Through the end of 2008, the year
of Toyota’s first field action for Dana
frame vehicles, NHTSA had received
150 complaints for Dana frame vehicles
and just 3 for 4Runner vehicles (none
involving the subject fourth-generation
4Runner vehicles). By the end of 2010,
NHTSA had received 716 complaints for
the Dana frame vehicles and just 36 for
4Runner vehicles (only 5 involving the
subject fourth-generation vehicles).
Figure 1 shows the vehicle age
distributions of frame corrosion
complaints to NHTSA for Toyota
4Runner vehicles, Toyota Dana frame
vehicles, and peer body-on-frame
vehicles. The chart on the left shows the
distributions for MY 1996 through 2002
vehicles (i.e., third-generation 4Runner
compared with peers) and the chart on
the right shows the distributions for MY
2003 through 2009 vehicles (i.e., fourthgeneration 4Runner compared with
peers).
Probability Distributions of Vehicle Ages
In Frame Corrosion Complaints to NHTSA, MV 2003-2009
1:
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5
Vehide Age (Years)
6
7
8
9 roll ll llM B ~D ll
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Vehicle Age (Years)
1-Peer Body-on-Frame --II-Toyota Dana Frame -+-Toyota Genl 4Runner
....,..Peer Body-on-Frame
~Toyota
Dana Frame -+-Toyota Gen4 4Runner
8 The subject Tacoma, Tundra, and Sequoia
vehicles were all manufactured at assembly plants
located in the United States. Dana did not supply
frames for any products manufactured in Japan.
9 Dana Holding Corporation Reaches Settlement
with Toyota on Warranty Claims Related to
Divested Structural Products Business, January 12,
2011, https://dana.mediaroom.com/
index.php?s=26450&item=69927.
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10 Burns v. Toyota Motor Sales USA Inc., Case No.
CV 14–2208 (W.D. Ark.), https://www.toyotaframe
settlement.com/.
11 Brian Warner et al v. Toyota Motor Sales USA
Inc., et al., Case No. 2:18–cv–02171–FMO–FFM, in
the U.S. District Court for the Central District of
California, https://www.toyotaframesettlement.com/.
PO 00000
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Sfmt 4725
12 Reuters, Toyota to settle U.S. truck rust lawsuit
for up to $3.4 billion, November 12, 2016, https://
www.reuters.com/article/us-toyota-settlementidUSKBN1370PE.
13 Gary Weinreich letter to Stephen Ridella, Ph.D.,
Director, Office of Defects Investigation, August 28,
2018.
14 Ibid.
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Figure 1. Probability distributions of vehicle ages in frame corrosion complaints to NHTSA for
MY 1996-2002 vehicles (left) and MY 2003-2009 vehicles (right).
16826
Federal Register / Vol. 87, No. 57 / Thursday, March 24, 2022 / Notices
In both age groups, the complaint age
distributions for the Toyota 4Runner
vehicles lag the distributions of the
Toyota Dana frame and peer body-onframe vehicles by several years. The
complaints peak at 15 years-in-service
for the third-generation Toyota 4Runner
vehicles, 6 years after the peak for the
Dana frame vehicles and 4 years after
the peak for the peer body-on-frame
vehicles. The complaints also peak at 15
years-in-service for the fourthgeneration Toyota 4Runner vehicles, 6
years after the peak for the Toyota Dana
frame vehicles and 5 years after the peak
for the peer body-on-frame vehicles.
Figure 2 shows the cumulative age
distributions of frame corrosion
complaints to NHTSA for the same
vehicle sets. The 4Runner complaints
occur later in the vehicle age than the
Toyota Dana frame and peer body-onframe complaints. Only about 3 percent
of the complaints for the thirdgeneration 4Runner vehicles occurred
within 10 years-in-service, compared
Cumulative ProbabUity Distributions of Vehicle Ages
In Frame Corrosion COmplalnts to NHTSA, MY 2003-2009
Cumulative Probability Distributions of Vehicle Ages
In Frame Corrosion Complaints to NHTSA, MY 1996-2002
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with 43 percent of the Toyota Dana
frame vehicle complaints and 21
percent of the peer body-on-frame
vehicle complaints for the same model
year range. For the MY 2003 through
2009 vehicles, approximately 6 percent
of complaints for the Toyota 4Runners
occurred within 10 years, compared
with 45 percent for the Toyota Dana
frame vehicles and 47 percent for the
peer body-on-frame vehicles.
'!!
20K
10K
°"
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Vehicle/Ip (Years)
VehideAp (Years)
rovma Dana Frame -+-Tovota Gen4 4Runner
,....,_ BodV'2014
17:39 Mar 23, 2022
Jkt 256001
the greater exposure time of the thirdgeneration vehicles. Analysis of
suspension link failures by vehicle age
showed similar rates for the third- and
fourth-generation products through 15
years of service. In both generations, the
failures are concentrated in states with
the greatest use of deicing salts to treat
road surfaces in winter months. 96
PO 00000
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Sfmt 4703
percent of the failures involved vehicles
owned or previously registered in states
with the greatest use of deicing salts to
treat road surfaces in winter months
(‘‘Salt states’’).
Complaints for both generations of
4Runners appear to have been
influenced by news about Toyota’s field
actions for the Sequoia, Tacoma and
E:\FR\FM\24MRN1.SGM
24MRN1
EN24MR22.064
Average age
(yrs)
Count
Federal Register / Vol. 87, No. 57 / Thursday, March 24, 2022 / Notices
Tundra vehicles equipped with frames
supplied by Dana. Toyota’s field actions
were referenced in 203 of the fourthgeneration 4Runner complaints.
Furthermore, 699 or two thirds (68
percent) of the fourth-generation
4Runner complaints were received after
news of NHTSA opening this defect
petition evaluation on August 7, 2018.
Conclusion: After reviewing the
available data, ODI has not identified
evidence of a defect trend for premature
corrosion-related failure of frame
structural components in the vehicles
that the petitioner has identified.
Contrary to the petitioner’s primary
allegation, the vehicles are not equipped
with frames manufactured by the same
supplier as Toyota products that have
been included in previous field actions
by the company addressing frame
corrosion concerns. The frames in those
vehicles exhibited failure trends before
reaching 10 years in service, several
years prior to the current trends evident
in the subject 4Runner vehicles.
Analysis of the age distributions of
corrosion-related suspension link
failures in the subject 4Runner vehicles
shows late-life patterns after well over
10 years of exposure to severe corrosion
environments. Incidents of corrosion
damage that have resulted in failure of
underbody components while driving
appear to have developed progressively
over many years with ample
opportunity for detection and repair.
This appears to be indicative of normal
wear and tear failures, and we have not
found evidence of a defect related to
premature or excessive corrosion
failures.
ODI has not identified any serious
crashes or injuries associated with
corrosion-related failure of frame
structural components while driving in
a population of vehicles that currently
ranges from 15 to 19 years old.
Accordingly, the Agency is denying the
petition.
Authority: 49 U.S.C. 30162(d);
delegations of authority at CFR 1.50 and
501.8.
DEPARTMENT OF THE TREASURY
Anne L. Collins,
Associate Administrator for Enforcement.
Internal Revenue Service
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Internal Revenue Service (IRS),
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ACTION: Notice.
AGENCY:
This document provides
notice of the availability of the
application package for the 2023
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Application instructions are
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Application packages are available on
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FOR FURTHER INFORMATION CONTACT:
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DATES:
Authority
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SUPPLEMENTARY INFORMATION:
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SUMMARY:
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PO 00000
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DEPARTMENT OF VETERANS
AFFAIRS
[OMB Control No. 2900–0016]
Internal Revenue Service (IRS),
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ACTION: Notice.
17:39 Mar 23, 2022
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DATES: Application instructions are
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word search—‘‘TCE’’) or through
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Number 21.006. The deadline for
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email address at tce.grant.office@irs.gov.
SUPPLEMENTARY INFORMATION: Authority
for the Tax Counseling for the Elderly
(TCE) Program is contained in Section
163 of the Revenue Act of 1978, Public
Law 95–600, (92 Stat.12810), November
6, 1978. Regulations were published in
the Federal Register at 44 FR 72113 on
December 13, 1979. Section 163 gives
the IRS authority to enter into
cooperative agreements with private or
public non-profit agencies or
organizations to establish a network of
trained volunteers to provide free tax
information and return preparation
assistance to elderly individuals.
Elderly individuals are defined as
individuals aged 60 and over at the
close of their taxable year. Because
applications are being solicited before
the fiscal year budget has been
approved, cooperative agreements will
be entered into subject to the
appropriation of funds.
BILLING CODE 4830–01–P
AGENCY:
VerDate Sep<11>2014
16827
Agency Information Collection
Activity: Claim for Disability Insurance
Benefits, Government Life Insurance
Veterans Benefits
Administration, Department of Veterans
Affairs.
ACTION: Notice.
AGENCY:
Veterans Benefits
Administration, Department of Veterans
SUMMARY:
E:\FR\FM\24MRN1.SGM
24MRN1
Agencies
[Federal Register Volume 87, Number 57 (Thursday, March 24, 2022)]
[Notices]
[Pages 16823-16827]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-06217]
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
[Docket No. NHTSA-2019-0105]
Denial of Motor Vehicle Defect Petition, DP18-002
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation.
ACTION: Denial of petition for a defect investigation.
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SUMMARY: This notice sets forth the reasons for the denial of a
petition submitted on August 7, 2018, by Mr. Gary Weinreich (the
petitioner) to NHTSA's Office of Defects Investigation (ODI). The
petition requests that the Agency investigate alleged ``premature and
excessive frame corrosion'' in model year (MY) 2002 through 2006 Toyota
4Runner vehicles. The petitioner bases his request upon his own
experience with a MY 2005 Toyota 4Runner, a class action lawsuit
settlement involving other Toyota products, and other complaints of
underbody corrosion in Toyota 4Runner vehicles that he found in NHTSA's
online complaint database. After reviewing the information provided by
the petitioner regarding his vehicle, facts related to the class action
lawsuit cited by the petitioner, and field data regarding underbody
corrosion in
[[Page 16824]]
Toyota 4Runner vehicles, NHTSA has concluded that there is insufficient
evidence to pursue further action. Accordingly, the Agency has denied
the petition.
FOR FURTHER INFORMATION CONTACT: Mr. Gregory Magno, Vehicle Defects
Division--D, Office of Defects Investigation, NHTSA, 1200 New Jersey
Ave. SE, Washington, DC 20590 (telephone 202-366-5226).
SUPPLEMENTARY INFORMATION: By letter dated August 7, 2018, Mr. Gary
Weinreich (the petitioner) submitted a petition requesting that the
Agency ``perform a high-priority investigation'' of ``premature and
excessive frame corrosion'' in model year (MY) 2002 through 2006 Toyota
4Runner vehicles. The petitioner bases his request upon a corrosion-
related front suspension failure he experienced in his MY 2005 Toyota
4Runner, a class action lawsuit settlement involving other Toyota
products, and other complaints of underbody corrosion in Toyota 4Runner
vehicles that he found in NHTSA's online complaint database.
On August 17, 2018, the Office of Defects Investigation (ODI)
opened Defect Petition DP18-002 to evaluate the petitioner's request
for an investigation. ODI has reviewed the following information as
part of its evaluation: (1) Information provided by the petitioner
regarding his vehicle; (2) facts related to the class action lawsuit
cited by the petitioner; (3) consumer complaint data regarding
underbody corrosion in third- and fourth-generation Toyota 4Runner
vehicles.
Scope: The petitioner's request for an investigation of premature
frame corrosion in MY 2002 through 2006 Toyota 4Runner vehicles
includes both third- and fourth-generation 4Runner vehicles that ranged
from 12 to 17 years in age when the petition was filed. Toyota sold
approximately 745,000 third-generation (MY 1996 through 2002), and
approximately 603,000 fourth-generation (MY 2003 through 2009) 4Runner
vehicles in the United States.\1\
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\1\ The analysis here will focus on the fourth-generation
vehicles, which includes the Petitioner's vehicle, except where
otherwise indicated.
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Petitioner's vehicle: On May 24, 2018, the petitioner experienced a
front suspension failure while driving on the highway in a 2005 Toyota
4Runner vehicle that was nearing 13 years of service.\2\ He reported
the incident to NHTSA in a Vehicle Owner Questionnaire (VOQ) submitted
on May 26, 2018 (NHTSA ID 11098055):
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\2\ The front attachment bracket for the left lower control arm
detached from the frame.
Yesterday, my wife and I and two friends riding with us narrowly
escaped a fatal accident when the front suspension separated from
the frame due to the corrosion problem. At highway speed, the
vehicle began shaking violently and the steering was unable to
properly control the vehicle. The vehicle went off the road after
---------------------------------------------------------------------------
coming close to hitting an oncoming vehicle.
The petitioner alleged that this failure resulted from premature
and excessive frame corrosion and provided service history information
and photographs as supporting evidence.\3\ ODI reviewed the information
provided by the petitioner, as well as additional details contained in
a lawsuit he filed against Toyota in December 2018.\4\
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\3\ Gary Weinreich letter to Stephen Ridella, Ph.D., Director,
Office of Defects Investigation, August 28, 2018.
\4\ Gary Weinreich v. Toyota Motor Sales USA Inc., et al., Case
No. 2:18-cv-03294-RMG, in the U.S. District Court for the District
of South Carolina, Charleston Division.
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ODI found that the petitioner's vehicle had a history of general
corrosion concerns throughout the undercarriage that were not isolated
to the frame. The photographs showed that the vehicle undercarriage was
seriously corroded at the time the incident occurred. The information
indicates severe general corrosion of the vehicle undercarriage
consistent with many years of severe use and exposure, but ODI has not
found evidence showing a design or manufacturing defect in the vehicle.
The vehicle service history information that the petitioner
provided supports these observations. Concerns with underbody corrosion
on his vehicle were first noted by a Toyota dealer in a multi-point
vehicle inspection performed on April 28, 2011. The invoice for that
inspection noted ``severe and excessive amount of rust on the
undercarriage and on the drive shaft transmission.'' Two years later,
on October 21, 2013, another multi-point inspection by a Toyota dealer
observed further progression of underbody corrosion damage, noting:
``rust on shocks/struts and other components,'' ``rust on exhaust
system,'' ``both splash shields severely rusted,'' and ``undercarriage
very rusty.'' \5\ On July 17, 2017, approximately 10 months prior to
experiencing the suspension failure incident, an independent repair
facility performing a routine oil change and brake maintenance informed
the petitioner of a concern with ``excessive frame corrosion'' on his
vehicle.
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\5\ Records provided by petitioner indicate that Toyota did not
service the vehicle after October 2013.
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The service history further indicates that corrosion concerns in
the petitioner's vehicle were first observed in other underbody
components (e.g., drive shaft transmission, exhaust, splash shields)
and grew progressively worse over several years before the observation
of ``excessive frame corrosion'' and subsequent suspension link
failure. Photographs provided by the petitioner show that the vehicle's
underbody was in poor condition when the failure occurred, with heavy
corrosion throughout the vehicle underbody and multiple visible
perforations in frame structural members.
The petitioner lives less than a mile from the ocean, where
exposure to marine salts may lead to increased vehicle corrosion rates
if vehicles are not regularly cleaned. While no information was
provided regarding the use, care, and maintenance of the petitioner's
vehicle, ODI has not received evidence that the vehicle received any
repairs to address the noted corrosion concerns prior to the May 2018
front suspension failure.
Class action lawsuit: The petitioner cites a class action lawsuit
settled by Toyota in 2017 \6\ as evidence of the defect in his vehicle
and states that 4Runner vehicles ``were not included in the class-
action lawsuit simply because there were insufficient complaints known
to the counsel representing the class at the time it was formed.'' ODI
has reviewed the referenced lawsuit and does not agree with the
petitioner's claims. The vehicles covered by the class action were
equipped with frames manufactured by a specific supplier alleged to be
using a defective electrocoating process over a certain manufacturing
period. The subject 4Runner vehicles were not equipped with frames
manufactured by that supplier.
---------------------------------------------------------------------------
\6\ www.toyotaframesettlement.com.
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Starting in 2008, Toyota conducted multiple service campaigns and
warranty extension programs to address concerns with premature frame
corrosion in certain vehicles equipped with frames supplied by Dana
Holding Company (Dana).\7\ The combined field actions covered MY 1995
through 2010 Toyota Tacoma, MY 2000 through 2008 Tundra, and MY 2001
through 2007 Sequoia vehicles (``Dana frame
[[Page 16825]]
vehicles'').\8\ Toyota took these actions after identifying quality
concerns with the electrocoating processes in certain frames supplied
by Dana that could lead to premature corrosion failures. In 2011, Dana
settled a lawsuit with Toyota for warranty claim costs related to
premature frame corrosion.\9\
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\7\ In December 2009, Dana announced its agreement to sell its
Structural Products Business to Metalsa, S.A. de C.V, https://dana.mediaroom.com/index.php?s=26450&item=69875.
\8\ The subject Tacoma, Tundra, and Sequoia vehicles were all
manufactured at assembly plants located in the United States. Dana
did not supply frames for any products manufactured in Japan.
\9\ Dana Holding Corporation Reaches Settlement with Toyota on
Warranty Claims Related to Divested Structural Products Business,
January 12, 2011, https://dana.mediaroom.com/index.php?s=26450&item=69927.
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These issues were presented in other litigation as well. A class-
action lawsuit filed in Arkansas on October 3, 2014, alleged that MY
2005 through 2009 Toyota Tacoma vehicles lacked adequate rust
protection on the vehicles' frames, leading to premature corrosion
failures.\10\ A separate class-action lawsuit filed in California on
March 24, 2015, made similar claims.\11\ The lawsuits were consolidated
in a second amended complaint filed on November 8, 2016. The
consolidated complaint covered MY 2005 through 2010 Toyota Tacoma, MY
2007 through 2008 Toyota Tundra, and MY 2005 through 2008 Toyota
Sequoia vehicles. The second amended complaint stated that the vehicles
that were the subject of the lawsuit were all equipped with frames
manufactured by Dana using ``the same defective process.'' The
complaint alleged that, ``The frames on the Toyota Vehicles are
materially the same for purposes of this lawsuit and suffer from the
same defect. All of the frames were manufactured by the same
corporation (Dana Holding Corporation) pursuant to the same defective
process.''
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\10\ Burns v. Toyota Motor Sales USA Inc., Case No. CV 14-2208
(W.D. Ark.), https://www.toyotaframesettlement.com/.
\11\ Brian Warner et al v. Toyota Motor Sales USA Inc., et al.,
Case No. 2:18-cv-02171-FMO-FFM, in the U.S. District Court for the
Central District of California, https://www.toyotaframesettlement.com/.
---------------------------------------------------------------------------
The class action was settled in May 2017. The terms of the
settlement included extending warranty coverage to 12 years from first
use for a Frame Inspection and Replacement Program. The settlement was
widely reported by news media.\12\
---------------------------------------------------------------------------
\12\ Reuters, Toyota to settle U.S. truck rust lawsuit for up to
$3.4 billion, November 12, 2016, https://www.reuters.com/article/us-toyota-settlement-idUSKBN1370PE.
---------------------------------------------------------------------------
Both third and fourth-generation 4Runner vehicles were built in
Japan and are not equipped with frames manufactured by Dana. Although
private litigation can be a relevant source of information to consider
in the course of examining a potential vehicle defect in many cases,
the petitioner has not demonstrated that the litigation he cites here
supports the grant of his petition.
Complaint analysis: The petitioner alleged that his analysis of
NHTSA's complaint database revealed evidence supporting his claim of
premature and excessive frame corrosion in MY 2002 through 2006 Toyota
4Runner vehicles, and that differences in field experience between
third- and fourth-generation 4Runner vehicles provide further evidence
suggesting a design or manufacturing defect in the fourth-generation
products. The petitioner claims that third-generation Toyota 4Runners
``do not appear to experience the premature and excessive frame
corrosion.'' \13\ The petitioner stated their belief that ``Any frame
specification changes between generations may help identify the root
cause(s) of the problem.'' \14\
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\13\ Gary Weinreich letter to Stephen Ridella, Ph.D., Director,
Office of Defects Investigation, August 28, 2018.
\14\ Ibid.
---------------------------------------------------------------------------
ODI's analysis of consumer complaint data related to frame
corrosion in fourth-generation Toyota 4Runner vehicles has not found
evidence of a failure trend indicating a potential design or
manufacturing defect leading to premature failures. Rather, the data
tends to show complaint trends occurring late in vehicle life in high
corrosion regions. Relatively few complaints involved suspension
detachments, and those that did were spread among multiple suspension
links, each occurring in older vehicles operated in high corrosion
regions. Finally, ODI finds no meaningful difference between frame
corrosion complaint trends and related suspension detachment
allegations in third- and fourth-generation 4Runner vehicles.
4Runner complaint trends lag trends for the Dana frame vehicles by
several years. Through the end of 2008, the year of Toyota's first
field action for Dana frame vehicles, NHTSA had received 150 complaints
for Dana frame vehicles and just 3 for 4Runner vehicles (none involving
the subject fourth-generation 4Runner vehicles). By the end of 2010,
NHTSA had received 716 complaints for the Dana frame vehicles and just
36 for 4Runner vehicles (only 5 involving the subject fourth-generation
vehicles).
Figure 1 shows the vehicle age distributions of frame corrosion
complaints to NHTSA for Toyota 4Runner vehicles, Toyota Dana frame
vehicles, and peer body-on-frame vehicles. The chart on the left shows
the distributions for MY 1996 through 2002 vehicles (i.e., third-
generation 4Runner compared with peers) and the chart on the right
shows the distributions for MY 2003 through 2009 vehicles (i.e.,
fourth-generation 4Runner compared with peers).
[GRAPHIC] [TIFF OMITTED] TN24MR22.063
[[Page 16826]]
In both age groups, the complaint age distributions for the Toyota
4Runner vehicles lag the distributions of the Toyota Dana frame and
peer body-on-frame vehicles by several years. The complaints peak at 15
years-in-service for the third-generation Toyota 4Runner vehicles, 6
years after the peak for the Dana frame vehicles and 4 years after the
peak for the peer body-on-frame vehicles. The complaints also peak at
15 years-in-service for the fourth-generation Toyota 4Runner vehicles,
6 years after the peak for the Toyota Dana frame vehicles and 5 years
after the peak for the peer body-on-frame vehicles.
Figure 2 shows the cumulative age distributions of frame corrosion
complaints to NHTSA for the same vehicle sets. The 4Runner complaints
occur later in the vehicle age than the Toyota Dana frame and peer
body-on-frame complaints. Only about 3 percent of the complaints for
the third-generation 4Runner vehicles occurred within 10 years-in-
service, compared with 43 percent of the Toyota Dana frame vehicle
complaints and 21 percent of the peer body-on-frame vehicle complaints
for the same model year range. For the MY 2003 through 2009 vehicles,
approximately 6 percent of complaints for the Toyota 4Runners occurred
within 10 years, compared with 45 percent for the Toyota Dana frame
vehicles and 47 percent for the peer body-on-frame vehicles.
[GRAPHIC] [TIFF OMITTED] TN24MR22.064
ODI's analysis of consumer complaints received by NHTSA through
March 7, 2022, identified a total of 1,024 records that appear to be
related to frame corrosion in fourth-generation Toyota 4Runner
vehicles, including 70 involving alleged detachments of front or rear
suspension links. Both the overall complaints and those reporting
suspension link detachments primarily involve older vehicles in high-
corrosion states. No patterns or trends were identified for any
specific suspension link. The radiator support bracket was the most
common location for frame perforation damage in reports that included
sufficient information to assess damage location. This part can be
serviced separately and does not present any crash avoidance or
crashworthiness safety concerns. The complaints describe general
underbody corrosion damage indicative of normal, end-of-life wear-out
failures from long duration exposures to severe, corrosive
environments.
Table 1 provides a breakdown of the complaints reporting suspension
detachments by the suspension component. The detachment failures
include two minor crashes and no verified injury allegations.
Table 1--Detachments While Driving by Suspension Link
----------------------------------------------------------------------------------------------------------------
Average age Alleged Alleged
Count (yrs) crashes injuries
----------------------------------------------------------------------------------------------------------------
Lower Control Arm, Front........................ 15 13.1 2 0
Lower Control Arm, Rear......................... 38 14.1 0 0
Upper Control Arm, Rear......................... 6 13.3 0 0
Lateral Control Rod, Rear....................... 2 10.5 0 0
Sway Bar, Rear.................................. 2 13.5 0 0
Unknown......................................... 7 16.3 0 0
---------------------------------------------------------------
Total....................................... 70 14.1 2 0
----------------------------------------------------------------------------------------------------------------
ODI's analysis of NHTSA complaint data finds similar age-adjusted
trends in the field experience of the third and fourth-generation
4Runner vehicles. The third-generation 4Runner vehicles have more than
double the allegations of suspension link detachments than the fourth-
generation 4Runners. The difference appears to be attributable to the
greater exposure time of the third-generation vehicles. Analysis of
suspension link failures by vehicle age showed similar rates for the
third- and fourth-generation products through 15 years of service. In
both generations, the failures are concentrated in states with the
greatest use of deicing salts to treat road surfaces in winter months.
96 percent of the failures involved vehicles owned or previously
registered in states with the greatest use of deicing salts to treat
road surfaces in winter months (``Salt states'').
Complaints for both generations of 4Runners appear to have been
influenced by news about Toyota's field actions for the Sequoia, Tacoma
and
[[Page 16827]]
Tundra vehicles equipped with frames supplied by Dana. Toyota's field
actions were referenced in 203 of the fourth-generation 4Runner
complaints. Furthermore, 699 or two thirds (68 percent) of the fourth-
generation 4Runner complaints were received after news of NHTSA opening
this defect petition evaluation on August 7, 2018.
Conclusion: After reviewing the available data, ODI has not
identified evidence of a defect trend for premature corrosion-related
failure of frame structural components in the vehicles that the
petitioner has identified. Contrary to the petitioner's primary
allegation, the vehicles are not equipped with frames manufactured by
the same supplier as Toyota products that have been included in
previous field actions by the company addressing frame corrosion
concerns. The frames in those vehicles exhibited failure trends before
reaching 10 years in service, several years prior to the current trends
evident in the subject 4Runner vehicles.
Analysis of the age distributions of corrosion-related suspension
link failures in the subject 4Runner vehicles shows late-life patterns
after well over 10 years of exposure to severe corrosion environments.
Incidents of corrosion damage that have resulted in failure of
underbody components while driving appear to have developed
progressively over many years with ample opportunity for detection and
repair. This appears to be indicative of normal wear and tear failures,
and we have not found evidence of a defect related to premature or
excessive corrosion failures.
ODI has not identified any serious crashes or injuries associated
with corrosion-related failure of frame structural components while
driving in a population of vehicles that currently ranges from 15 to 19
years old. Accordingly, the Agency is denying the petition.
Authority: 49 U.S.C. 30162(d); delegations of authority at CFR 1.50
and 501.8.
Anne L. Collins,
Associate Administrator for Enforcement.
[FR Doc. 2022-06217 Filed 3-23-22; 8:45 am]
BILLING CODE 4910-59-P