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Weaknesses in ODI’s processes for analyzing vehicle safety data further
undermine ODI’s efforts to identify safety defects. Specifically, ODI does not
follow standard statistical practices when analyzing early warning reporting data,
such as establishing a base case for what statistical test results would look like in
the absence of safety defects. Consequently, ODI cannot differentiate trends and
outliers that represent random variation from those that are statistically significant.
In addition, ODI does not thoroughly screen consumer complaints. For example,
ODI’s initial screening of the roughly 330 complaints received daily is not
thorough, and about 90 percent of complaints are set aside. While screeners are
encouraged to query all complaints for similar issues in their area of concentration,
half of them told us that they do not consistently do this. Finally, ODI does not
adequately train or supervise its staff. For example, NHTSA has a training plan for
ODI staff, but it has not implemented this plan. As a result, ODI’s pre-
investigative staff told us they have received little or no training in their areas of
concentration, some of which are technologically complex. Collectively, these
weaknesses have resulted in significant safety concerns being overlooked. For
example, in June 2007, GM provided ODI with a State trooper’s report that
identified the 2005 Chevrolet Cobalt’s ignition switch as a possible cause of air
bag non-deployment during a fatal accident. However, two ODI staff who
reviewed the report in 2007 did not note this potential link when documenting
their reviews. Additionally, ODI officials told us that at the time, they were
uncertain under what conditions the air bags were supposed to deploy.
ODI’s process for determining when to investigate potential safety defects is also
insufficient to prompt needed recalls and other corrective actions. While ODI has
identified factors for deciding whether an investigation is warranted, it has not
developed sufficient guidance or reached consensus on how these factors should
be applied. ODI emphasizes investigating issues that are most likely to result in
recalls, which has led to considerable investigative duties being performed during
the pre-investigative phase, often by screeners who are not trained to carry out
these responsibilities. In addition to these shortcomings, ODI’s investigation
decisions lack transparency and accountability. Specifically, ODI does not always
document the justifications for its decisions not to investigate potential safety
issues and does not always make timely decisions on opening investigations. In
the GM case, ODI considered a proposal to investigate air bag non-deployments in
the Chevrolet Cobalt and Saturn Ion in November 2007 but did not document why
it decided not to investigate. Further, NHTSA’s Associate Administrator for
Enforcement directed ODI to gather more information on the issue after reports of
fatal accidents associated with the air bag non-deployments. However, the ODI
screener responsible for monitoring the issue left NHTSA in 2008, and the Defects
Assessment Division Chief did not reassign that responsibility. ODI also missed
other opportunities to investigate the ignition switch when new evidence came to
light in subsequent years.