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NHTSA defect investigation · Preliminary Evaluation

Harley-Davidson preliminary evaluation PE16009

Sudden Brake Failure - Motorcycle. NHTSA’s Office of Defects Investigation opened this preliminary evaluation about the control unit/module on 76 model years (2008–2011). Opened Jul 6, 2016, closed Apr 23, 2018 after 22 months. It led to safety recall 18V076000. became a recall

What NHTSA says

Source: Office of Defects Investigation, as filed

The Office of Defects Investigation (ODI) opened this investigation in July 2016 based on forty-three (43) Vehicle Owner Questionnaires (VOQ).During the course of this investigation ODI received a total of 145 VOQs related to the alleged defect on the subject motorcycles. Owners allege they experience a sudden and complete loss of brakes on one or both wheels. To better understand the cause of the braking issue on the subject motorcycles, ODI requested NHTSA's Vehicle Research and Test Center (VRTC) conduct inspections and testing of affected vehicle braking systems. Through its work, VRTC determined that deposits were forming on the valves in the Hydraulic Control Unit (HCU) of the Antilock Braking System (ABS). These deposits could prevent the proper function of the HCU and render the brakes ineffective. To understand why deposits were forming in the HCU, Harley Davidson completed an analysis of the Dow 460 brake fluid used as original equipment on the subject motorcycles and determined that it had stability issues if left in the brake system for an extended period of time. Harley Davidson found that if a brake fluid flush was not conducted as outlined in the owner?s manual for the motorcycles, and was left in the system for a period of time beyond their recommendation; deposits could form in the HCU. Through further testing, Harley Davidson identified an alternate, commercially available, brake fluid that did not have the same stability issues as the original fluid and could stop the proliferation of any current brake system deposits. ODI sent Information Request (IR) letters to Harley Davidson and Dow Chemical (the supplier of the brake fluid on the subject motorcycles) to collect information about the subject bikes and the alleged defect. Harley Davidson responded in full on Sept 30, 2016 and Dow responded with a confidential submission on October 25, 2017. ODI analyzed the information contained in both IR responses and concluded that motorcycles manufactured during Model Years (MY) 2008, 2009, 2010, and 2011 were failing at a rate greater than their peers. Based on this analysis and the brake fluid study conducted by Harley Davidson, a group of motorcycles was identified that were potentially affected by the instability of the original brake fluid.2008 marked the introduction of ABS on Harley Davidson motorcycles and a change in the Dow 460 brake fluid used in the 2012 MY vehicles provided the bases for the scope of the affected population. With recall action 18V-076 taken by Harley Davidson this investigation is closed as further use of agency resources does not appear to be warranted. The ODI reports cited above can be reviewed at: https://www.nhtsa.gov/ using the complaint identification numbers attached to this resume.

Stage Preliminary Evaluation — NHTSA works to complete one within eight months Opened Jul 6, 2016 Closed Apr 23, 2018 Manufacturer Harley-Davidson Motor Company Components Service Brakes, Hydraulic › Antilock/Traction Control/Electronic Limited Slip › Control Unit/Module Resulting recall 18V076000

A Preliminary Evaluation is the first formal stage: NHTSA has decided the complaints and other information it screened are worth a closer look, and asks the manufacturer for its own data on the condition. The summary is the agency’s own text from its investigation file, unedited; the opening and closing resumes with the full reasoning are on NHTSA’s site under this number.

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 became a recall. The campaign page carries the manufacturer’s filed defect, risk and remedy, the build window and every model year covered; whether one specific vehicle is included is settled by VIN at nhtsa.gov/recalls.

Model years it names

Source: as NHTSA filed them

Also named: 2011 Harley-Davidson FLHR103; 2011 Harley-Davidson FLHRC103; 2008 Harley-Davidson FLHRSE4; 2011 Harley-Davidson FLHRX103; 2011 Harley-Davidson FLHTC103; 2011 Harley-Davidson FLHTCU103; 2008 Harley-Davidson FLHTCUSE3; 2009 Harley-Davidson FLHTCUSE4; 2010 Harley-Davidson FLHTCUSE5; 2011 Harley-Davidson FLHTCUSE6; 2011 Harley-Davidson FLHX103; 2011 Harley-Davidson FLHXSE2; 2008 Harley-Davidson Flhp; 2009 Harley-Davidson Flhp; 2010 Harley-Davidson Flhp; 2011 Harley-Davidson Flhp; 2008 Harley-Davidson Flhpe; 2009 Harley-Davidson Flhpe; 2010 Harley-Davidson Flhpe; 2011 Harley-Davidson Flhpe; 2008 Harley-Davidson Flhr; 2009 Harley-Davidson Flhr; 2010 Harley-Davidson Flhr; 2011 Harley-Davidson Flhr; 2008 Harley-Davidson Flhrc; 2009 Harley-Davidson Flhrc; 2010 Harley-Davidson Flhrc; 2011 Harley-Davidson Flhrc; 2008 Harley-Davidson Flhrs; 2011 Harley-Davidson Flhruse; 2008 Harley-Davidson Flht; 2009 Harley-Davidson Flht; 2010 Harley-Davidson Flht; 2008 Harley-Davidson Flhtc; 2009 Harley-Davidson Flhtc; 2010 Harley-Davidson Flhtc; 2011 Harley-Davidson Flhtc; 2008 Harley-Davidson Flhtcu; 2009 Harley-Davidson Flhtcu; 2010 Harley-Davidson Flhtcu; 2011 Harley-Davidson Flhtcu; 2009 Harley-Davidson Flhtcuh; 2009 Harley-Davidson Flhtcutg; 2010 Harley-Davidson Flhtcutg; 2011 Harley-Davidson Flhtcutg; 2009 Harley-Davidson Flhtk; 2010 Harley-Davidson Flhtk; 2011 Harley-Davidson Flhtk; 2008 Harley-Davidson Flhtp; 2009 Harley-Davidson Flhtp; 2010 Harley-Davidson Flhtp; 2011 Harley-Davidson Flhtp; 2009 Harley-Davidson Flhtph; 2008 Harley-Davidson Flhx; 2009 Harley-Davidson Flhx; 2010 Harley-Davidson Flhx; 2011 Harley-Davidson Flhx; 2010 Harley-Davidson Flhxse; 2008 Harley-Davidson Vrscaw; 2009 Harley-Davidson Vrscaw and 16 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 PE16009 a recall?

No — it is the investigation that led to one. Recall 18V076000 is the campaign; its page carries the remedy.

Is PE16009 still open?

No. It closed on Apr 23, 2018 and led to recall 18V076000.

Which vehicles does PE16009 cover?

NHTSA opened it on 76 model years: 2011 Harley-Davidson FLHR103, 2011 Harley-Davidson FLHRC103, 2008 Harley-Davidson FLHRSE4, 2011 Harley-Davidson FLHRX103, 2011 Harley-Davidson FLHTC103, 2011 Harley-Davidson FLHTCU103 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.