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NHTSA defect investigation · Preliminary Evaluation

Pierce preliminary evaluation PE18009

Unintended aerial platform movement. NHTSA’s Office of Defects Investigation opened this preliminary evaluation about the instrument cluster/panel on 20 model years (2003–2017). Opened Aug 21, 2018, closed Apr 8, 2019 after 8 months. It led to safety recall 19V022000. became a recall

What NHTSA says

Source: Office of Defects Investigation, as filed

This Preliminary Evaluation (PE) was opened August 21, 2018 based on 5 consumer complaints for unintended aerial platform movement on the subject vehicles. ODI complaint numbers 11101301, 11101303, 11101304, 11101305 and 11105134 allege there is a defect with the aerial ladder control mechanism that resulted unintended movement. ODI conducted several field inspections, meeting with local fire houses and municipalities to better understand and witness the alleged defect. In addition, ODI met with Pierce and the Fleet Operations Manager of the Montgomery County Fire and Rescue Service?s Central Fleet to discuss the known complaints, possible attributing factors and vehicles to be tested/instrumented. On November 30, 2018 Pierce met with ODI staff at DOT headquarters and agreed that a safety defect existed on their vehicle aerial devices. The subject vehicles may unintentionally rotate right when a command to extend the aerial ladder is given. This unintentional movement is the result of faulty Random Access Memory (RAM) chip configuration on the aerial ladder controller. If the aerial device is operated in this manner it may contract an obstruction, potentially causing property damage or injury. In addition, it may hinder the ability to perform emergency functions as intended. The effected population includes 886 2004?2018 model year Pierce Arrow XT, Dash, Enforcer, Impel, Quantum and Velocity fire trucks. This Preliminary Evaluation is closed with Safety Recall 19V-022.

Stage Preliminary Evaluation — NHTSA works to complete one within eight months Opened Aug 21, 2018 Closed Apr 8, 2019 Manufacturer Pierce Manufacturing Components Electrical System › Instrument Cluster/Panel, Electrical System, Electrical System › Software Resulting recall 19V022000

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 resumes carrying the full reasoning are linked below.

The paperwork NHTSA filed

Source: every document on this action, at nhtsa.gov
DocumentCodeFiledAt NHTSA
Opening resumeINOA2018PDF
Closing resumeINCLA2018PDF
Information request to the manufacturerINIM2018PDF
Manufacturer's response — full submissionINRL2018PDF

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 Aug 21, 2018, owners had filed 6 complaints with the agency about the model years above. 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. The opening resume linked above names the reports ODI itself 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 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: 2003 Pierce 75' Aluminum Ladder; 2004 Pierce 75' Aluminum Ladder; 2005 Pierce 75' Aluminum Ladder; 2006 Pierce 75' Aluminum Ladder; 2007 Pierce 75' Aluminum Ladder; 2008 Pierce 75' Aluminum Ladder; 2009 Pierce 75' Aluminum Ladder; 2005 Pierce Arrow XT; 2006 Pierce Arrow XT; 2007 Pierce Arrow XT; 2008 Pierce Arrow XT; 2009 Pierce Arrow XT; 2010 Pierce Arrow XT; 2011 Pierce Arrow XT; 2012 Pierce Arrow XT; 2013 Pierce Arrow XT; 2014 Pierce Arrow XT; 2015 Pierce Arrow XT; 2016 Pierce Arrow XT; 2017 Pierce Arrow XT.

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 PE18009 a recall?

No — it is the investigation that led to one. Recall 19V022000 is the campaign; its page carries the remedy.

Is PE18009 still open?

No. It closed on Apr 8, 2019 and led to recall 19V022000.

Which vehicles does PE18009 cover?

NHTSA opened it on 20 model years: 2003 Pierce 75' Aluminum Ladder, 2004 Pierce 75' Aluminum Ladder, 2005 Pierce 75' Aluminum Ladder, 2006 Pierce 75' Aluminum Ladder, 2007 Pierce 75' Aluminum Ladder, 2008 Pierce 75' Aluminum Ladder 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.