2014 Mercedes-Benz E350 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.

On April 10, 2020, NHTSA's Office of Defects Investigation (ODI) received a defect petition from Mr. Surjit Singh alleging premature corrosion of the rear brake lines in his 2013 Mercedes-Benz E350 sedan. The petitioner states that he was recently informed by a Mercedes dealer service department that his car had severely rusted brake lines that need[ed] to be replaced immediately at a cost of about $3300. He further stated that the dealer service advisor informed him that he had seen the issue on many cars like his. The petitioner requested ?that NHTSA launch an investigation into this serious issue of rusting brake lines on [his] 2013 Mercedes E350.? The brake line corrosion reported by the petitioner did not result in brake line leakage or any compromise in brake system performance before it was detected in a dealer vehicle inspection. The petitioner submitted a complaint to NHTSA documenting his experience (NHTSA ID 11319024).On April 24, 2020, ODI opened Defect Petition DP20-004 to evaluate the petitioner?s request. ODI conducted a search for all consumer complaints and Early Warning Reporting (EWR) data related to allegations of brake line corrosion or leakage in 2013 Mercedes-Benz E350 sedans and similarly equipped vehicles. The 2013 E350 is a fourth-generation Mercedes-Benz E-Class vehicle (W212 platform), which was first sold in the United States in 2009 as a 2010 model. Mercedes-Benz sold approximately 245 thousand model year 2010 through 2015 E-Class sedan and wagon vehicles in the United States with the same brake line design as the petitioner?s vehicle.ODI?s search for complaints and EWR data in 2013 Mercedes E350 vehicles found no additional records related to the alleged defect. Expanding the search to all W212 platform vehicles identified just one incident, a complaint alleging unspecified brake line corrosion and leakage in a 2011 Mercedes-Benz E550 (NHTSA ID 10902081). The complaint did not allege that the brake line leakage resulted in reduced brake performance, crash, or injury. The resulting failure rate of 0.4 failures per hundred thousand vehicles is extremely low for a population that includes vehicles that have been in service for over ten years. After reviewing the available data, ODI has not identified evidence of a defect trend in the subject E-Class vehicles that would support opening a defect investigation into premature brake line corrosion failure. NHTSA is authorized to issue an order requiring notification and remedy of a defect if the Agency?s investigation shows a defect in design, construction, or performance of a motor vehicle that presents an unreasonable risk to safety. 49 U.S.C. ?? 30102(a)(9), 30118. Since the information before the Agency is not indicative of a vehicle-based defect, it is unlikely that any investigation opened because of granting this petition would result in an order concerning the notification and remedy of a safety-related defect. Therefore, upon full consideration of the information presented in the petition and the potential risks to safety, the petition is denied. The denial of this petition does not foreclose the Agency from taking further action if warranted or the potential for a future finding that a safety-related defect exists based upon additional information the agency may receive.A Federal Register notice further detailing NHTSA?s reasons for denial of the petition will be forthcoming.