Subaru preliminary evaluation PE19009
Occupant Detection System (ODS) Failure. NHTSA’s Office of Defects Investigation opened this preliminary evaluation about the inflator module on 3 model years (2016–2018). Opened Aug 6, 2019, closed Jan 22, 2020 after 6 months. It led to safety recall 19V701000. became a recall
What NHTSA says
Source: Office of Defects Investigation, as filedThe Office of Defects Investigation (ODI) opened PE19-009 to investigate 51 complaints and additional Early Warning Report (EWR) data related to allegations of front passenger seat Occupant Detection System (ODS) malfunctions in model year (MY) 2016 through 2018 Subaru Forester vehicles. These vehicles use a capacitive type ODS, which is intended to classify the occupant of the passenger seat as either full-sized, small stature, a child seat or other object. The complaints reported the ODS failed to operate properly, the SRS (Supplemental Restraint System) warning light illuminated, and/or the ODS incorrectly suppressed (turned off) the front passenger air bag when the seat was occupied by a full-sized passenger. In a frontal crash that is sufficient to warrant deployment, a suppressed air bag may increase the risk of injury to the occupant of the seat. On August 14, 2019 ODI sent an Information Request (IR) to Subaru requesting information on the subject vehicles and MY 2014-2015 Subaru Forester vehicles. On October 3, 2019, Subaru submitted a Defect Information Report (DIR) to NHTSA describing a safety defect in the passenger-side front airbag Occupant Detection System (ODS) harness of 366,282 MY 2015-2018 Subaru Forester vehicles equipped with seat heaters. The DIR stated that over time, due to a decrease in contact pressure between the terminals in the ODS sensor mat harness, a temporarily unstable electrical connection may be possible. If the connection is temporarily unstable, the ODS may not properly determine the status of the right front seat occupant. If the ODS is unable to correctly determine the status of the front occupant, the airbag warning light may illuminate, and the front passenger airbag may deactivate even though the seat is occupied, increasing the risk of injury to the front passenger in the event of a crash. Using vehicle production data and field occurrence frequency, Subaru determined the potentially affected vehicle production range to be between January 20, 2015 ?and August 1, 2017. In addition, Subaru indicated that over 99 percent of the related MY 2015-2018 field reports with vehicles in the production range involved vehicles with seat heaters. NHTSA's analysis of complaint and warranty claim data showed 1,440 of the complaints and 11,672 of the claims involve vehicles with seat heaters that were built within the production range covered by Subaru's recall. In addition, NHTSA's analysis showed a complaint rate of 393.1 per hundred thousand vehicles for the recalled population and 89.0 for MY 2014 through 2018 vehicles that are not included in the recall. Analysis of warranty claim data found a claim rate of 3.2 percent for the recalled population and 0.3 percent for MY 2014 through 2018 vehicles that are not included in the recall. Subaru will instruct owners with Subaru Forester vehicles produced in the affected vehicle production range, to bring their vehicles to a dealer to have the sensor mat harness, inspected and replaced with a new part, including the seat cushion assembly, if necessary. Based on ODI's analysis, the actions taken by Subaru mitigate any unreasonable risk to safety posed by ODS sensor mat failures in the subject vehicles. For subject and peer vehicles outside the recall population and those equipped without seat heaters, ODI's analysis indicates that there is currently no safety-related defect trend. Given these circumstances, further use of the agency resources in this matter does not appear to be warranted. Accordingly, this investigation is closed.
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- Opening resume — ODI’s own summary of why it opened this — the subject, what prompted it, and the vehicles in scope.
- Closing resume — ODI’s own summary of why it closed this, and what it concluded.
| Document | Code | Filed | At NHTSA |
|---|---|---|---|
| Opening resume | INOA | 2019 | |
| Closing resume | INCLA | 2019 | |
| Information request to the manufacturer | INIM | 2019 | |
| Manufacturer's response — data | INRD | 2019 | 37 files 12345678910111213141516171819202122232425262728293031323334353637 |
40 of 471 documents shown; the rest are under this number at nhtsa.gov.
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 openedWhen NHTSA opened this on Aug 6, 2019, owners had filed 465 complaints with the agency about the model years above, of which 117 named the air bags 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. 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 nextAn 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 themA 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 InvestigationIs PE19009 a recall?
No — it is the investigation that led to one. Recall 19V701000 is the campaign; its page carries the remedy.
Is PE19009 still open?
No. It closed on Jan 22, 2020 and led to recall 19V701000.
Which vehicles does PE19009 cover?
NHTSA opened it on 3 model years: 2018 Subaru Forester, 2017 Subaru Forester, 2016 Subaru Forester. That is the scope of the inquiry, not a list of affected vehicles; a recall, if one follows, defines its own population by VIN.