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NHTSA defect investigation · Preliminary Evaluation

Tesla preliminary evaluation PE20010

Loss of rearview camera. NHTSA’s Office of Defects Investigation opened this preliminary evaluation about the camera on 10 model years (2012–2018). Opened Jun 22, 2020, closed Nov 22, 2020 after 5 months without a recall. closed

What NHTSA says

Source: Office of Defects Investigation, as filed

On June 22, 2020, the Office of Defects Investigations (ODI) opened Preliminary Evaluation PE20-010 to investigate incidents of media control unit (MCU) failures resulting in loss of rearview camera in model year (MY) 2012-2015 Tesla Model S vehicles equipped with the NVIDIA Tegra 3 processor with an integrated 8GB eMMC NAND flash memory device. EMMC NAND flash devices have a finite lifespan based upon the number of program/erase (P/E) cycles. The subject MCU allegedly fails prematurely due to memory wear-out of the eMMC NAND flash. Tesla used the same MCU with the Tegra 3 processor in approximately 159 thousand 2012-2018 Model S and 2016-2018 Model X vehicles built by Tesla through early-2018. In response to ODI's Information Request (IR) for PE20-010, Tesla provided ODI with 2,399 complaints and field reports, 7,777 warranty claims, and 4,746 non-warranty claims related to MCU replacements. The data show failure rates over 30 percent in certain build months and accelerating failure trends after 3 to 4 years-in-service. According to Tesla, for subject vehicles equipped with the NVIDIA Tegra 3 processor with an integrated 8GB eMMC NAND flash memory device, the eMMC NAND cell hardware can fail when reaching lifetime wear, for which the eMMC controller has no available blocks to recover. With this failure mode, the only recovery available is a replacement of the eMMC device, achieved by physical part replacement of either the MCU assembly or visual control module subcomponent. Tesla provided the effects of MCU failure on vehicle function which result in loss of rearview/backup camera, loss of HVAC (defogging) setting controls (if the HVAC status was OFF status prior to failure.) There is also an impact on the advanced driver assistance support (ADAS) Autopilot system, and turn signal functionality due to the possible loss of audible chimes, driver sensing, and alerts associated with these vehicle functions. There are precedents for addressing defects that result in loss of either backup camera, defogging, or turn signal functions under safety recalls. Tesla has implemented certain Over-The-Air or OTA updates to subject vehicles to mitigate the effects of MCU failure. These updates include firmware changes to reduce memory usage of the subject memory card, improve eMMC error correction and storage management strategies, changing the control logic for turn signal activation, and defaulting the HVAC system to Auto (71.6F) for drives after MCU failure to address windshield defogging. Tesla indicated that the MCU failures are likely to continue to occur in subject vehicles as vehicles continue to operate and use available memory in the 8GB eMMC NAND flash memory until 100% of units have failed. This investigation has been upgraded to an Engineering Analysis (EA20-003). The VOQs associated with the upgrade of this investigation are identified in the attachment to this resume.

Stage Preliminary Evaluation — NHTSA works to complete one within eight months Opened Jun 22, 2020 Closed Nov 22, 2020 Manufacturer Tesla, Inc. Components Back Over Prevention › Sensing System › Camera, Electrical System › Instrument Cluster/Panel

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 closed without a recall. That means NHTSA found no defect trend it chose to act on at the time, or the manufacturer addressed the condition another way (a service campaign or a bulletin, which have their own pages). A closed file can be reopened if new reports arrive.

Model years it names

Source: as NHTSA filed them

Also named on model years this site has no page for: 2012 Tesla Model S; 2013 Tesla Model S; 2014 Tesla Model S; 2015 Tesla Model S.

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 PE20010 a recall?

No. A preliminary evaluation 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 PE20010 still open?

No. It closed on Nov 22, 2020 without a recall.

Which vehicles does PE20010 cover?

NHTSA opened it on 10 model years: 2018 Tesla Model S, 2017 Tesla Model S, 2016 Tesla Model S, 2018 Tesla Model X, 2017 Tesla Model X, 2016 Tesla Model X 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.