2007 Lexus ES350 Recalls

From 2000 through 2017, Takata produced millions of air bag inflators using two types of phase-stabilized ammonium nitrate ("PSAN") propellant -- propellant 2004 and propellant 2004L. After prolonged exposure to high temperature cycles and humidity, inflators using propellant 2004 can degrade, causing the propellant to burn too quickly when ignited. The rapid burning can cause the inflator to rupture during deployment, potentially causing serious or even fatal injury to vehicle occupants. See 2016 Blomquist Report at www.nhtsa.gov/sites/nhtsa.gov/files/documents/expert_report-hrblomquist.pdf.Consequently, all frontal inflators using propellant 2004 that do not contain a "desiccant" (a substance that traps and holds moisture) in US vehicles are under recall. These "non-desiccated" inflators either have been or are required to be replaced.In some cases, the remedy part for these recalled inflators was, or will be, an inflator using either propellant 2004 or 2004L that does contain a desiccant. None of these "desiccated" remedy parts (which were installed in older model year vehicles) are currently under recall for a degradation concern. Certain subsets of desiccated PSAN inflators using propellant 2004 for use as original equipment, however, have been recalled for a degradation concern. All Takata inflators produced with propellant 2004L contain desiccant, and none of these desiccated inflators using propellant 2004L are under recall for a degradation concern. There have been no reported field ruptures in any non-recalled desiccated PSAN inflators.It is understood that desiccants fully saturate at some threshold, at which point any additional moisture will not be captured. This means the degradation process observed in non-desiccated inflators using propellant 2004 may also occur in non-recalled desiccated inflators using propellant 2004, assuming additional moisture enters the inflator and high temperature cycling occurs. Based on available information, desiccant saturation can occur within the first five years in the worst environments, and the time required for full saturation is affected by multiple factors. While no present safety risk has been identified, further work is needed to evaluate the future risk of non-recalled desiccated inflators using propellant 2004.Three entities -- Takata (now known as TK Global), the Independent Testing Coalition, and Exponent -- have been studying the long-term behavior of Takata desiccated PSAN inflators using propellant 2004L (as well as 2004) in the presence of moisture and temperature cycling. The research efforts, which include development of predictive modeling techniques and field sample analysis, are ongoing. To date, none of the researchers have identified field evidence showing that propellant 2004L is undergoing a degradation process that leads to aggressive deployment and potential rupture. However, the time in service of such inflators remains short compared to that of the inflators using propellant 2004. Further study is needed to assess the long-term safety of desiccated inflators using propellant 2004L.The Office of Defects Investigation is opening this investigation to examine whether a safety defect related to propellant degradation exists in non-recalled desiccated PSAN frontal inflators manufactured by Takata. This investigation will require extensive information on Takata production processes and surveys of inflators in the field. Lists of recall actions that may have used desiccated PSAN inflators as remedy parts, as well as the makes and models originally manufactured with them, is available with the downloadable version of this document (see nhtsa.gov/recalls?nhtsaId=EA21002 -- note this information is subject to change/revision as the investigation proceeds). This investigation does not supersede EA15-001, which remains open.

THE OFFICE OF DEFECTS INVESTIGATION (ODI) OPENED DP09-001 ON APRIL 8, 2009, TO EVALUATE A DEFECT PETITION REQUESTING ADDITIONAL INVESTIGATION OF POTENTIAL THROTTLE CONTROL SYSTEM DEFECTS UNRELATED TO FLOOR MAT INTERFERENCE WITH ACCELERATOR PEDALS IN MODEL YEAR (MY) 2007 LEXUS ES 350 VEHICLES.THE PETITIONER REFERENCED AN EARLIER ODI INVESTIGATION CONCERNING FLOOR MAT INTERFERENCE WITH ACCELERATOR PEDAL RETURN (PE07-016/EA07-010), WHICH HE STATED WAS TOO NARROW IN SCOPE AS IT DID NOT INCLUDE ALL INCIDENTS OF UNWANTED ACCELERATION AND CONSIDER ALL POTENTIAL CAUSES OF VEHICLE SPEED CONTROL CONCERNS.THE PETITION ALSO REQUESTED AN INVESTIGATION OF MY 2002-2003 LEXUS ES300 FOR THOSE 'LONGER DURATION INCIDENTS INVOLVING UNCONTROLLABLE ACCELERATION WHERE BRAKE PEDAL APPLICATION ALLEGEDLY HAD NO EFFECT' THAT WERE DETERMINED NOT TO BE WITHIN THE SCOPE OF INVESTIGATION PE04-021. AS BACKGROUND, THE PETITIONER OWNS A MY 2007 LEXUS ES350 THAT ALLEGEDLY EXPERIENCED AN UNWANTED AND UNCONTROLLED ACCELERATION EVENT (ODI COMPLAINT NUMBER 10261660).TOYOTA CONCLUDED THAT THE INCIDENT WAS CAUSED BY AN UNSECURED FLOOR MAT. TO ASSESS THE PETITIONER'S REQUEST, ODI INTERVIEWED THE PETITIONER, INSPECTED HIS VEHICLE, REVIEWED INFORMATION SUBMITTED BY TOYOTA, REVIEWED OWNER COMPLAINTS ALLEGING INCIDENTS OF UNWANTED ACCELERATION IN THE SUBJECT VEHICLES AND MATERIAL RELATED TO THE INVESTIGATIONS CITED BY THE PETITIONER.ODI IDENTIFIED 64 COMPLAINTS ALLEGING INCIDENTS OF UNWANTED ACCELERATION IN MY 2007 LEXUS VEHICLES, RESULTING IN 8 CRASHES AND 15 INJURIES.ODI'S ANALYSIS OF THESE COMPLAINTS DETERMINED THAT 50 (78%) INVOLVED INCIDENTS OF FLOOR MAT INTERFERENCE, INCLUDING 7 (88%) OF THE CRASHES AND ALL 15 INJURIES.THEREFORE, ODI'S ANALYSIS FOUND THAT THE ONLY DEFECT TREND RELATED TO VEHICLE SPEED CONTROL IN THE SUBJECT VEHICLES INVOLVED THE POTENTIAL FOR ACCELERATOR PEDALS TO BECOME TRAPPED NEAR THE FLOOR BY OUT-OF-POSITION OR INAPPROPRIATE FLOOR MAT INSTALLATIONS. ON OCTOBER 5, 2009, TOYOTA INITIATED A SAFETY RECALL (RECALL 09V-388) TO ADDRESS CONCERNS WITH POTENTIAL ACCELERATOR PEDAL ENTRAPMENT BY FLOOR MATS IN APPROXIMATELY 3.8 MILLION VEHICLES, INCLUDING THE SUBJECT VEHICLES.EXCEPT INSOFAR AS THE PETITIONER'S CONTENTIONS RELATE TO THAT RECALL, THE FACTUAL BASES OF THE PETITIONER'S CONTENTIONS THAT ANY FURTHER INVESTIGATION IS NECESSARY ARE UNSUPPORTED. IN OUR VIEW, ADDITIONAL INVESTIGATION IS UNLIKELY TO RESULT IN A FINDING THAT A DEFECT RELATED TO MOTOR VEHICLE SAFETY EXISTS OR A NHTSA ORDER FOR THE NOTIFICATION AND REMEDY OF A SAFETY-RELATED DEFECT, AS ALLEGED BY THE PETITIONER, AT THE CONCLUSION OF THE REQUESTED INVESTIGATION.THEREFORE, IN VIEW OF THE NEED TO ALLOCATE AND PRIORITIZE NHTSA'S LIMITED RESOURCES TO BEST ACCOMPLISH THE AGENCY'S SAFETY MISSION, THE PETITION IS DENIED.THIS ACTION DOES NOT CONSTITUTE A FINDING BY NHTSA THAT A SAFETY-RELATED DEFECT DOES NOT EXIST.THE AGENCY WILL TAKE FURTHER ACTION IF WARRANTED BY FUTURE CIRCUMSTANCES.PLEASE SEE THEFEDERAL REGISTER NOTICE FOR FURTHER DETAILS.

THE DRIVER SIDE FLOOR MAT WILL NOT INTERFERE WITH THE THROTTLE PEDAL IF PROPERLY SECURED USING THE RETAINING HOOKS PROVIDED BY TOYOTA.HOWEVER, IF THE ALL WEATHER MAT IS UNSECURED AND MOVES FORWARD FROM ITS INTENDED POSITION IT CAN ENTRAP THE THROTTLE PEDAL AT THE FULLY OPEN POSITION AFTER IT HAS BEEN DEPRESSED.THIS CAN HAPPEN REGARDLESS OF WHETHER OR NOT ANOTHER MAT (CARPET) IS UNDERNEATH.WHEN THIS OCCURS, SOME OPERATORS REACT BY APPLYING THE BRAKE PEDAL MULTIPLE TIMES, DEPLETING THE BRAKING SYSTEM'S (VACUUM BASED) POWER ASSIST.STOPPING THE VEHICLE WITH UNASSISTED BRAKING WHILE THE THROTTLE IS FULLY OPEN REQUIRES SIGNIFICANT PEDAL FORCE, WHICH SOME OPERATORS DID NOT, OR WERE UNABLE TO, APPLY FOR THE REQUIRED DURATION.CONTINUED DRIVING IN THIS CONDITION RESULTS IN OVERHEATED BRAKES, WHICH FURTHER DIMINISHES THE BRAKING EFFECTIVENESS.SOME OPERATORS ATTEMPTED TO TURN THE VEHICLE OFF BY DEPRESSING THE ENGINE CONTROL BUTTON, HOWEVER THEY WERE UNAWARE THE BUTTON HAD TO BE DEPRESSED FOR THREE SECONDS TO STOP THE ENGINE WHEN THE VEHICLE IS IN MOTION; THIS FUNCTIONALITY WAS NOT EXPLAINED ADEQUATELY IN THE OWNER'S MANUAL.IN ODI INTERVIEWS, OWNER'S REPORTED THEY WERE UNAWARE THE ALL WEATHER MAT HAD THE POTENTIAL TO INTERFERE WITH THE THROTTLE PEDAL, ADVISING THAT THIS WAS NEVER PROPERLY EXPLAINED GIVEN THE SIGNIFICANT HAZARD IT REPRESENTED.OWNERS REPORTED SEVERAL EXPLANATIONS FOR WHY THE MAT WAS UNSECURED, INCLUDING THAT THE VEHICLE WAS DELIVERED IN THIS CONDITION (MOST COMMON REASON), OR THAT THEY HAD (UNWITTINGLY) INSTALLED THE MAT THEMSELVES, OR THAT ANOTHER PARTY, SUCH AS A CAR WASH ATTENDANT, HAD DISTURBED THE MAT WITHOUT THE OWNER'S KNOWLEDGE.ONE CONSUMER REPORTED THAT THEIR VEHICLE WAS DELIVERED WITHOUT THE RETAINING DEVICES INSTALLED.IN A SEPTEMBER 26, 2007 LETTER TO NHTSA, TOYOTA INDICATED THAT THEY WOULD CONDUCT A SAFETY RECALL TO REPLACE THE ALL WEATHER MAT WITH A REDESIGNED MAT.ACCORDING TO TOYOTA, THE NEW MAT DESIGN WILL REDUCE THE POTENTIAL FOR MAT INTERFERENCE WITH THE THROTTLE PEDAL.THE POPULATION NOTED ABOVE REPRESENTS THE NUMBER OF SUBJECT MATSTHAT HAVE BEEN SOLD IN THE UNITED STATES.SINCE TOYOTA CANNOT IDENTIFY WHICH VEHICLES MAY HAVE THE SUBJECT MATS, THEY WILL SEND A LETTER TO ALL REGISTERED OWNERS OF THE SUBJECT VEHICLES (ESTIMATED 750K) ADVISING THEM OF THE CONCERN AND REMEDY.A COPY OF THAT LETTER WILL BE POSTED TO NHTSA'S WEB SITE UNDER RECALL 07E-082; IT CONTAINS A DESCRIPTION OF THE CONDITION AND THE ACTIONS AN OPERATOR SHOULD TAKE IN THE EVENT THROTTLE ENTRAPMENT OCCURS WHILE DRIVING.THE FATALITY INCIDENT NOTED ABOVE OCCURRED IN JULY 2007 AND WAS INVESTIGATED BY NHTSA'S SPECIAL CRASH INVESTIGATIONS OFFICE.IT HAS NOT BEEN REPORTED ON A VEHICLE OWNER QUESTIONNAIRE.THE OPERATOR REPORTEDLY TRAVELLED AT SPEEDS IN EXCESS OF 100 MPH FOR AN ESTIMATED EIGHT MILES ON AN INTERSTATE IN CALIFORNIA BEFORE IT STRUCK TWO OTHER VEHICLES.ONE OF THE STRUCK VEHICLES AND THE SUBJECT VEHICLE CAUGHT FIRE.THE OCCUPANT OF THE STRUCK VEHICLE DID NOT EVACULATE AND DIED AT THE SCENE.THE SUBJECT VEHICLE DRIVER SUFFERED A BROKEN BONE.THE CALIFORNIA HIGHWAY PATROL IS INVESTIGATING THE INCIDENT ALSO.ODI DID NOT ISSUE AN INFORMATION REQUEST LETTER DURING THIS INVESTIGATION.THE TOYOTA REPORTS NOTED ABOVE WERE REPORTED DURING PRELIMINARY EVALUATION PE07-016 AND ARE CURRENT THROUGH APRIL 2007 FOR MY 2007 LEXUS ES350 ONLY.ODI DOES NOT HAVE FIELD EXPERIENCE DATA FROM TOYOTA FOR CAMRY VEHICLES.THROTTLE ENTRAPMENT DUE TO IMPROPERLY INSTALLED FLOOR MATS COULD BE A CONCERN IN ALL VEHICLES.THEREFORE, DRIVERS SHOULD ALWAYS ENSURE THEIR FLOOR MATS ARE PROPERLY AND SAFELY INSTALLED.THIS INCL

COMPLAINANTS INTERVIEWED BY ODI STATED THAT THEY APPLIED THE THROTTLE PEDAL TO ACCELERATE THE VEHICLE THEN EXPERIENCED UNWANTED ACCELERATION AFTER RELEASE.SUBSEQUENT (AND SOMETIMES REPEATED) APPLICATIONS OF THE BRAKE PEDAL REDUCED ACCELERATION BUT DID NOT STOP THE VEHICLE.IN SOME INCIDENTS DRIVERS TRAVELED SIGNIFICANT DISTANCES (MILES) AT HIGH VEHICLE SPEEDS (GREATER THAN 90 MPH) BEFORE THE VEHICLE STOPPED (ODI NOTES THAT MULTIPLE BRAKE APPLICATIONS WITH THE THROTTLE IN AN OPEN POSITION CAN DEPLETE THE BRAKE SYSTEM'S POWER (VACUUM) ASSIST RESERVE RESULTING IN DIMINISHED BRAKING).THE SUBJECT VEHICLES HAVE AN ENGINE CONTROL BUTTON INSTEAD OF A TRADITIONAL IGNITION KEY. SOME DRIVERS REPORTED THAT THEIR ATTEMPTS TO TURN THE ENGINE OFF BY PRESSING THE CONTROL BUTTON WERE UNSUCCESSFUL.IN THESE CASES IT APPEARS THE DRIVERS WERE UNAWARE THAT THE BUTTON'S FUNCTIONALITY CHANGES WHEN THE VEHICLE IS IN MOTION REQUIRING THAT IT BE DEPRESSED FOR 3 SECONDS (INSTEAD OF MOMENTARILY) TO STOP THE ENGINE.ODI HAS OBSERVED THAT AN UNSECURED LEXUS ACCESSORY ALL WEATHER FLOOR MAT CAN TRAP THE THROTTLE PEDAL IN AN OPEN POSITION RESULTING IN SIGNIFICANT UNWANTED ACCELERATION.UNSECURED FLOOR MATS HAVE BEEN FOUND IN THE MAJORITY OF INCIDENT VEHICLES.IN ADDITION, ODI HAS INSPECTED TWO INCIDENT VEHICLES DOCUMENTING BRAKE DAMAGE DUE TO OVERHEATING. IN THE FIVE ODI CRASH INCIDENTS THE OPERATORS ALLEGE THEY EXPERIENCED UNWANTED ACCELERATION AND WERE UNABLE TO STOP THE VEHICLE TO AVOID THE COLLISION.FOUR OF THE FIVE CRASHES ARE MULTI-VEHICLE (ONE INVOLVING 7 VEHICLES) AND TWO RESULTED IN TOTAL LOSS DAMAGES (ONE INVOLVING A FIRE).ONE INJURY, WHICH RESULTED FROM A ROLL-OVER CRASH, WAS SIGNIFICANT AND THE INJURED PERSON CONTINUES TO SHOW SYMPTOMS.ONE INJURY INCIDENT IS NOT CRASH RELATED (COMPLAINANT ALLEGES A KNEE INJURY DUE TO OVEREXERTION DURING BRAKE APPLICATION). IN THEIR RESPONSE TO ODI'S APRIL 5, 2007 INFORMATION REQUEST LETTER, TOYOTA ACKNOWLEDGES THAT SOME OF THE ALLEGED INCIDENTS ARE LIKELY RELATED TO IMPROPER INSTALLATION OF THE DRIVER SIDE ALL WEATHER FLOOR MAT RESULTING IN INTERFERENCE WITH ACCELERATOR PEDAL MOVEMENT.TOYOTA DESCRIBES VARIOUS CHANGES TO THE LABELING OF THE ALL WEATHER MAT (INCLUDING A STICKER FOR THE BOTTOM OF THE MAT AND ENLARGING THE STATEMENT ON THE VISIBLE SURFACE) AND THE PACKAGING USED FOR SALES OF THE MATS, AND HAS NOTIFIED ODI OF AN OWNER MAILING TO SUBJECT VEHICLE OWNERS WARNING OF THE DANGERS OF IMPROPER MAT INSTALLATION.TOYOTA BELIEVES THE SUBJECT VEHICLES AND THE ALL WEATHER MAT DO NOT CONTAIN A SAFETY RELATED DEFECT AND THAT THE ACTIONS THEY HAVE TAKEN ARE SUFFICIENT TO ADDRESS ANY FUTURE CONCERNS. THIS INVESTIGATION HAS BEEN UPGRADED TO AN ENGINEERING ANALYSIS TO FURTHER INVESTIGATE THIS ISSUE AND TO ASSESS THE ACTIONS TAKEN BY TOYOTA.