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NHTSA defect investigation · Preliminary Evaluation

BMW preliminary evaluation PE20002

Brake fluid leak at front brake caliper. NHTSA’s Office of Defects Investigation opened this preliminary evaluation about the service brakes on 2 model years (2019). Opened Apr 1, 2020, closed Sep 21, 2020 after 6 months. It led to safety recall 20V476000. became a recall

What NHTSA says

Source: Office of Defects Investigation, as filed

The Office of Defects Investigation (ODI) opened this Preliminary Evaluation (PE) on April 1st, 2020 to investigate six consumer complaint allegations of brake fluid leaking from the front brake calipers on their 2019-2020 model year (MY) BMW R1250 motorcycles. At the closing date of this investigation, the number of ODI complaints has risen to fourteen. During the investigation, ODI contacted several consumers to validate and confirm their complaints. ODI learned from these conversations that the subject motorcycles were leaving brake fluid puddles on or near the front tires. One consumer forwarded pictures of a subject motorcycle leaking brake fluid on a BMW dealer showroom floor. In response to an ODI Information Request (IR) letter, BMW supplied ODI with 139 dealer field reports. Many of them also described leaking brake calipers that failed at 0 to 4 miles shown on the bike odometer. ODI was also able to gather pictures from BMW related to the field reports and they too showed calipers leaking brake fluid. BMW disclosed in the IR response that they switched to a Hayes designed and manufactured front caliper starting with MY 2019 of the subject motorcycles. The previous model years used Brembo manufactured calipers. ODI analyzed warranty claims and production data provided by BMW. ODI found that 1,169 vehicles were repaired for front brake caliper leaks. A total of 838 subject vehicles were repaired before the date of first sale. The motorcycles, found to be leaking and serviced prior to the date of first sale, appeared to be in violation of Federal Motor Vehicle Safety Standard (FMVSS) 122 for ?Motorcycle Brake Systems?, under Section 5.2.3. The FMVSS requires that ?during all tests and on their completion, there shall be no friction material detachment and no leakage of brake fluid. Discussions between the NHTSA Office of Vehicle Safety Compliance and BMW resulted in the manufacturer recalling MY 2019-2020 R1250 GS, GS Adventure and R1250 RT, 2020 S1000 RR and S1000 XR motorcycles for front brake calipers leaking when parked, failing to comply with the requirements of the Federal Motor Vehicle Safety Standard number 122, Motorcycle Brake Systems. As part of the safety recall, BMW will notify owners, and dealers will inspect, and if necessary, replace the front brake calipers with an improved design free of charge. The recall is expected to begin October 6, 2020. Owners may contact BMW customer service at 1-800-525-7417. This Preliminary Evaluation has been closed with a voluntary safety recall released by the manufacturer (20V-471).The ODI reports cited above can be reviewed at: http://www-odi.nhtsa.dot.gov/owners/SearchNHTSAID using the following complaint identification numbers: 11340459, 11319970, 11320627, 11311740, 11319565, 11319858, 11311520, 11308994, 11323486, 11316146, 11319832, 11319554, 11322813, 11308930.

Stage Preliminary Evaluation — NHTSA works to complete one within eight months Opened Apr 1, 2020 Closed Sep 21, 2020 Manufacturer BMW of North America, LLC Components Service Brakes, Service Brakes, Hydraulic, Service Brakes, Hydraulic › Fluid, Service Brakes, Hydraulic › Foundation Components, Service Brakes, Hydraulic › Foundation Components › Disc Resulting recall 20V476000

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 resumeINOA2020PDF
Closing resumeINCLA2020PDF
Information request to the manufacturerINIM2020PDF
Manufacturer's response — dataINRD202014 files 1234567891011121314
Manufacturer's response — full submissionINRL20202 files 12
Memo granting a response extensionINRE2020PDF

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 1, 2020, owners had filed 7 complaints with the agency about the model years above, of which 6 named the service brakes 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 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: 2019 BMW R 1250 RT; 2019 BMW R1250 GS Adventure.

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 PE20002 a recall?

No — it is the investigation that led to one. Recall 20V476000 is the campaign; its page carries the remedy.

Is PE20002 still open?

No. It closed on Sep 21, 2020 and led to recall 20V476000.

Which vehicles does PE20002 cover?

NHTSA opened it on 2 model years: 2019 BMW R 1250 RT, 2019 BMW R1250 GS Adventure. That is the scope of the inquiry, not a list of affected vehicles; a recall, if one follows, defines its own population by VIN.