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NHTSA defect investigation · Audit Query

Freightliner, Western Star and 2 others audit query AQ18002

Daimler Trucks North America Recalls. NHTSA’s Office of Defects Investigation opened this audit query about the switch on 197 model years (2002–2018). Opened Apr 23, 2018, closed Jul 11, 2024 after 6.2 years without a recall. closed

What NHTSA says

Source: Office of Defects Investigation, as filed

On April 23, 2018, the National Highway Traffic Safety Administration (“NHTSA”) opened Audit Query (AQ18002) to assess the timeliness and scope of four recalls filed by Daimler Trucks North America, LLC (“DTNA”). NHTSA subsequently expanded AQ18002 to examine the timeliness and scope of three additional DTNA recalls and compliance with early warning reporting and manufacturer communications reporting requirements. NHTSA and DTNA entered into a Consent Order on December 29, 2020, to resolve NHTSA’s assertions that certain recalls within the scope of AQ18002 were untimely, DTNA failed to timely submit certain manufacturer communications to NHTSA, and DTNA failed to submit field reports to NHTSA as required. As part of the Consent Order, DTNA agreed to a total civil penalty of thirty million dollars ($30,000,000), of which ten million dollars ($10,000,000) was paid on January 12, 2021. Also, of that total civil penalty, DTNA agreed to spend five million dollars ($5,000,000) on the specific performance obligations to develop advanced data analytics capabilities to enhance its ability to detect and study emerging safety-related defect trends on its vehicles (“Safety Data Analytics infrastructure”) and an advanced data analytics and reporting platform that integrates data on emerging safety-related defect trends on its vehicles and recall lessons learned (“Safety Communications Platform”). The Consent Order also held fifteen million dollars ($15,000,000) of the civil penalty in abeyance pending DTNA’s satisfactory completion of the requirements of the Consent Order, and its compliance with the Safety Act, and regulations thereunder. NHTSA and DTNA agreed to a two-year term for the Consent Order—with an option for NHTSA to extend the Consent Order for an additional year, if warranted. In the Consent Order, DTNA agreed to numerous performance obligations, including monthly meetings with NHTSA to discuss potential safety issues, recent manufacturer communications, and recall decision-making, among other things; quarterly meetings with NHTSA to discuss DTNA’s progress on the performance obligations under the Consent Order, including the Safety Data Analytics infrastructure and Safety Communications Platform, and any issues related to compliance with the Consent Order, Safety Act, or regulations; development of written procedures and employee training materials to help DTNA comply with its legal obligations to timely identify and report safety defects and noncompliances, submit complete and accurate recall filings, and timely submit manufacturer communications and field reports to NHTSA; and identifying and reporting previously unreported manufacturer communications and field reports. Also, via the Consent Order, DTNA acknowledged that the failure or inability to identify a specific root cause, develop an adequate remedy or repair, or confirm the affected population of vehicles are not bases for delaying filing a recall with NHTSA. On December 22, 2022, NHTSA extended the Consent Order for a term of one year due to concerns about DTNA’s compliance with its recall-related obligations. Specifically, NHTSA expressed concerns about the completeness of DTNA’s recall reports and issues identified with owner notification letters during the term of the Consent Order, as well as the length of time that DTNA took to consider a straightforward noncompliance issue before filing a recall and DTNA’s interactions with NHTSA during the term of the Consent Order. NHTSA addressed these concerns with DTNA during the third year of the Consent Order. The extended term of the Consent Order expired on December 28, 2023. Based on the Consent Order, this investigation, AQ18002, is closed. Closure of this AQ has no bearing on the terms of the Consent Order or DTNA’s ongoing legal obligations, and it does not represent a determination by NHTSA as to DTNA’s performance under the Consent Order.

Stage Audit Query Opened Apr 23, 2018 Closed Jul 11, 2024 Manufacturer Daimler Trucks North America, LLC Components Exterior Lighting › Brake Lights › Switch, Steering › Hydraulic Power Assist › Hose, Piping, And Connections

A Audit Query is an audit of whether the manufacturer met its early-warning reporting obligations — the data and reports it must send NHTSA — rather than of a vehicle condition. The summary is the agency’s own text from its investigation file, unedited; the resumes carrying the full reasoning are linked below.

The paperwork NHTSA filed

Source: every document on this action, at nhtsa.gov
DocumentCodeFiledAt NHTSA
Closing resumeINCLA2018PDF
Information request to the manufacturerINIM2018PDF
Manufacturer's response — dataINRD2018PDF
Manufacturer's response — full submissionINRL20186 files 123456
Filed documentINLM20182 files 12
Confidential business information noticeINCBC20188 files 12345678

These are NHTSA’s own files, served from the agency’s site — the resumes are what ODI wrote when it opened and closed the action, and the rest is the correspondence behind them, including what the manufacturer sent when the agency asked. They are linked, not copied: where a document names the people who wrote in, that redaction is the agency’s to make and its copy is the one you should read.

What owners had already reported

Source: complaints on file the day it opened

When NHTSA opened this on Apr 23, 2018, owners had filed 12 complaints with the agency about the model years above, of which 4 named the exterior lighting, steering NHTSA went on to investigate. Owner complaints are the agency’s main early signal: ODI screens them, and a Preliminary Evaluation is usually where a pattern in them ends up.

This is what the complaint file held on that date, not a claim about which reports prompted the investigation — NHTSA’s complaint records carry no investigation number, so nobody can make that link from the data alone. NHTSA’s opening resume names the reports it cited. Complaint records on this site begin with 2016.

What this means for an owner

Source: and what happens next

An investigation is not a finding that a defect exists, and it puts no duty on anyone. NHTSA opens a Preliminary Evaluation when complaints and other reports suggest a condition worth asking the manufacturer about; it upgrades to an Engineering Analysis when the answers warrant testing; it closes either when it recommends a recall, when the manufacturer recalls on its own, or when no defect trend is found. The agency’s own goals are about four months for a petition, eight for a Preliminary Evaluation or a Recall Query and eighteen for an Engineering Analysis; many run longer.

This one is closed. A audit query ends with NHTSA’s finding on the recall it examined — the remedy stands, is widened, or a new campaign follows; the file names the recall it concerned and NHTSA’s closing resume carries the reasoning.

Model years it names

Source: as NHTSA filed them

Also named: 2011 Fccc XBR; 2012 Fccc XBR; 2013 Fccc XBR; 2014 Fccc XBR; 2015 Fccc XBR; 2016 Fccc XBR; 2017 Fccc XBR; 2011 Fccc XCL; 2012 Fccc XCL; 2013 Fccc XCL; 2014 Fccc XCL; 2015 Fccc XCL; 2016 Fccc XCL; 2017 Fccc XCL; 2011 Fccc XCM; 2012 Fccc XCM; 2013 Fccc XCM; 2014 Fccc XCM; 2015 Fccc XCM; 2016 Fccc XCM; 2017 Fccc XCM; 2011 Fccc XCR; 2012 Fccc XCR; 2013 Fccc XCR; 2014 Fccc XCR; 2015 Fccc XCR; 2016 Fccc XCR; 2017 Fccc XCR; 2002 Freightliner Cascadia; 2003 Freightliner Cascadia; 2004 Freightliner Cascadia; 2005 Freightliner Cascadia; 2006 Freightliner Cascadia; 2007 Freightliner Cascadia; 2008 Freightliner Cascadia; 2009 Freightliner Cascadia; 2010 Freightliner Cascadia; 2011 Freightliner Cascadia; 2012 Freightliner Cascadia; 2013 Freightliner Cascadia; 2014 Freightliner Cascadia; 2015 Freightliner Cascadia; 2016 Freightliner Cascadia; 2017 Freightliner Cascadia; 2005 Freightliner Century; 2006 Freightliner Century; 2007 Freightliner Century; 2008 Freightliner Century; 2009 Freightliner Century; 2010 Freightliner Century; 2011 Freightliner Century; 2012 Freightliner Century; 2013 Freightliner Century; 2002 Freightliner Century Class; 2003 Freightliner Century Class; 2004 Freightliner Century Class; 2005 Freightliner Century Class; 2006 Freightliner Century Class; 2007 Freightliner Century Class; 2008 Freightliner Century Class and 137 more.

A vehicle page’s investigation list carries the same action; a name here is the scope NHTSA opened, not a list of affected VINs.

Common questions

Source: NHTSA Office of Defects Investigation

Is AQ18002 a recall?

No. A audit query is NHTSA asking questions, not a recall. A safety recall carries an NHTSA campaign number and a duty to repair for free; this one closed without one. Whether one particular vehicle has an open recall is a VIN question at nhtsa.gov/recalls.

Is AQ18002 still open?

No. It closed on Jul 11, 2024 without a recall.

Which vehicles does AQ18002 cover?

NHTSA opened it on 197 model years: 2011 Fccc XBR, 2012 Fccc XBR, 2013 Fccc XBR, 2014 Fccc XBR, 2015 Fccc XBR, 2016 Fccc XBR and more. That is the scope of the inquiry, not a list of affected vehicles; a recall, if one follows, defines its own population by VIN.