2000 Mercedes-Benz M Class

ODI opened the investigation based on reports that the subject vehicle brake lamp switch (switch) failure caused 1) inoperative brake lamps (stay on or fail to illuminate), and/or 2) shift interlock failure (shifter locked in park), and/or 3) the cruise control to fail to cancel with brake application.Consumers also reported the illumination of a warning lamp on the instrument panel.The switch contains three sets of electrical contacts and a (normally extended) spring loaded plunger that actuates the contacts as it moves.As installed in the vehicle, the plunger contacts the brake pedal arm and is pushed into the switch; as the driver applies the pedal the plunger extends.One set of contacts (BLS) operates the stop lamps, a second set (EWM) controls the shift interlock system, and a third set (BS) is used by an on-board diagnostic (OBD) system to monitor switch operation.The cruise control monitors the BLS signal to determine when the brake is applied, the primary way the system is disabled when set.The relative timing of contact actuation in response to plunger movement allows the OBD system to detect a switch fault.When a fault is detected a malfunction indication lamp (MIL) is illuminated (driver alert), a diagnostic trouble code (DTC) is stored (for the service technician), and cruise control operation is inhibited (as a failsafe).In its response to ODI's January 2011 information request letter, MB explained its assessment of switch failures which was based primarily on evaluation of field return failures.MB identified both 1) electrical contact and 2) mechanical switch failure mechanisms.According to MB's analysis, electrical contact failure is the predominate failure type and the failure consequence depends on which contact fails.For instance MB claims that BLS contact failures are momentary in nature and do not affect brake light operation but are nonetheless detected by the OBD system, resulting in a DTC and subsequent replacement.Electrical contact failures of the BS and EWM contacts result in a DTC also, and EWM contact failures result in the shifter being stuck in the park (which can be overridden by the consumer).Accordingly MB maintains that electrical contact failures of the switch have no safety consequence since the brake lamps remain operational and the cruise control is always disabled.MB determined that mechanical failures of the switch, which are rare in their assessment, can result from internal wear and/or increased switch operating temperatures.High temperatures occur due to overheating of the BLS contacts and can cause the internal plastic components to melt.In one scenario overheated BLS contacts may melt to the extended plunger and are damaged when the brake pedal is released resulting in the brake lights staying on.In another scenario the increased temperatures and/or internal wear can cause the plunger to stick in the fully depressed position.In this case the cruise may not cancel when the brake is applied and the driver may have to use high brake pedal forces or other means (shifting to neutral or using the cruise master switch) to disengage the cruise.Additionally the vacuum assist can be depleted if the driver pumps the brakes resulting in reduced braking effectiveness and even higher pedal forces.In its March 31, 2011 defect notification, MB stated that to remediate the potential need for excessive brake force it would conduct a safety recall (11V-208) to replace the switch with a more robustly designed component.The recall includes 136,751 model year 2000 - 2002 M-Class and model year 2000 - 2004 M-Class AMG vehicles.Owner notification letters will be mailed

ANALYSIS OF COMPLAINTS TO ODI AND MERCEDES AND WARRANTY CLAIM DATA SUBMITTED BY MERCEDES INDICATES THAT THE ALLEGED DEFECT HAS OCCURRED AT A LOW RATE (36.5 COMPLAINTS PER 100,000 VEHICLES AND 0.29 PERCENT WARRANTY CLAIM RATE), WITH NO DISCERNABLE DEFECT TREND INDICATING THAT THE RATE OF CHAFING RELATED BRAKE LINE FAILURES IS INCREASING.THERE HAVE BEEN NO NEW COMPLAINTS SINCE JANUARY 2009.WHEN THE ANALYSIS IS LIMITED TO INCIDENTS OF BRAKE LINE LEAKAGE THAT RESULTED IN ALLEGATIONS OF REDUCED BRAKE EFFECTIVENESS, THE RATE DROPS EVEN FURTHER (22.3 COMPLAINTS PER 100,000 VEHICLES AND 0.04 PERCENT WARRANTY CLAIM RATE). MERCEDES PROVIDED DATA SHOWING THAT IN THE RARE INSTANCES WHEN CHAFING DID PROGRESS TO BRAKE LINE LEAKAGE THE DRIVER WOULD BE IMMEDIATELY ALERTED TO A PROBLEM BY ILLUMINATION OF THE BRIGHT YELLOW ESP/BAS WARNING LAMP AND CHANGES IN BRAKE PEDAL FEEL.CONTINUED OPERATION WITH A LEAKING BRAKE LINE WOULD RESULT IN ILLUMINATION OF THE BRIGHT RED BRAKE WARNING LAMP AND AN AUDIBLE CHIME DUE TO LOW MASTER CYLINDER RESERVOIR LEVEL. CONTINUED OPERATION WITH THE BRAKE WARNING LAMP ILLUMINATED WOULD ULTIMATELY DRAIN THE RESERVOIR FOR THE AFFECTED CIRCUIT, RESULTING IN LOSS OF THE CIRCUIT AND AN APPROXIMATELY 80% INCREASE IN STOPPING DISTANCES. SURVEYS CONDUCTED BY ODI AND VRTC INDICATE THAT ROUTING ANOMALIES MAY BE MORE COMMON THAN THE COMPLAINT AND WARRANTY DATA SUGGEST FOR THE SUBJECT LINE BUNDLE, WITH LINE CONTACT OR OTHER ROUTING ANOMALY NOTED IN 13 OF 51 VEHICLES SURVEYED BY ODI AND VRTC (25.5%).WHILE EVIDENCE OF CONTACT BETWEEN THE FUEL LINE AND SUBJECT BRAKE IN A PARTICULAR VEHICLE IS NOT NECESSARILY PREDICTIVE OF EVENTUAL LINE FAILURE/LEAKAGE, SIGNIFICANT CHAFING WEAR WAS NOTED IN TWO SURVEY VEHICLES (3.9%).TO ADDRESS CONCERNS WITH LINE ROUTING AND ENSURE THAT LINES WITH EVIDENT CHAFING DO NOT PROGRESS TO A LEAK CONDITION, MERCEDES WILL CONDUCT AN OWNER NOTIFICATION PROGRAM INSTRUCTING OWNERS TO BRING THE VEHICLES TO A DEALER FOR A FREE INSPECTION AND REPAIR.LINES THAT DO NOT HAVE A SPACER (RUBBER GROMMET OR OMEGA-CLIP) BETWEEN THE SUBJECT FUEL AND BRAKE LINES WILL HAVE AN OMEGA-CLIP SPACER INSTALLED TO ENSURE ADEQUATE CLEARANCE BETWEEN THE LINES.BRAKE LINES WITH CHAFE MARKS WILL BE REPLACED. ACCORDINGLY, THIS INVESTIGATION HAS BEEN CLOSED. THE CLOSING OF THIS INVESTIGATION DOES NOT CONSTITUTE A FINDING BY NHTSA THAT A SAFETY-RELATED DEFECT DOES NOT EXIST. THE AGENCY WILL CONTINUE TO MONITOR COMPLAINTS AND OTHER INFORMATION RELATING TO THE ALLEGED DEFECT IN THE SUBJECT VEHICLES AND TAKE FURTHER ACTION IN THE FUTURE IF WARRANTED. FOR ADDITIONAL INFORMATION REGARDING THIS ENGINEERING ANALYSIS REFER TO THE EA08-009 CLOSING REPORT.

MERCEDES-BENZ USA (MBUSA) WILL NOTIFY CERTAIN MODEL YEAR (MY) 1998 THROUGH 2003 M-CLASS OWNERS OF THE NEED TO BRING THEIR VEHICLES INTO DEALERS TO ADDRESS THE ISSUE PREVIOUSLY CAMPAIGNED UNDER MBUSA RECALL 2003-040005 (NHTSA RECALL 03V-121).THE MBUSA CAMPAIGN, WHICH ODI IS DESIGNATING RECALL 08V-465, WILL REPLACE THE POWER STEERING COOLER HOSE AND CLAMP IN ALL VEHICLES THAT RECEIVED THE ORIGINAL RECALL REMEDY FOR 03V-121 AND WHICH HAVEN'T RECEIVED A SUBSEQUENT REPAIR TO INSTALL A REVISED HOSE AND CLAMP.APPROXIMATELY ONE-THIRD OF THE VEHICLES THAT RECEIVED THE ORIGINAL REPAIR PROCEDURE AND PARTS RETURNED FOR SUBSEQUENT SERVICE FOR LEAKAGE FROM THE HOSE FITTING AND, IN APPROXIMATELY 10 PERCENT OF THESE VEHICLES, COMPLETE SEPARATION OF THE HOSE FROM THE COOLER.A REVISED SERVICE PROCEDURE FOR 03V-121, WHICH INVOLVED REPLACING THE OLD HOSE AND CLAMP WITH MODIFIED PARTS, HAD SIGNIFICANTLY LOWER RATES OF RETURN REPAIRS.MBUSA WILL APPLY THE REVISED SERVICE PROCEDURE FROM 03V-121 TO THE VEHICLES COVERED UNDER 08V-465.ACCORDINGLY THIS RECALL QUERY IS CLOSED.

ODI OPENED PE07-007 AFTER RECEIVING 4 COMPLAINTS WITHIN A 6 WEEK PERIOD ALLEGING INCIDENTS OF UNCOMMANDED BRAKE APPLICATION IN MODEL YEAR (MY) 2000 THROUGH 2001 MERCEDES M CLASS SPORT UTILITY VEHICLES.INFORMATION CONTAINED IN THE REPORTS OR GATHERED IN SUBSEQUENT CONSUMER INTERVIEWS INDICATED THAT THE INCIDENTS WERE CAUSED BY FAULTS IN THE ELECTRONIC STABILITY PROGRAM (ESP) SYSTEM WHICH WERE REPAIRED BY REPLACING THE YAW RATE SENSORS.ALTHOUGH THE SAME YAW RATE SENSOR IS USED IN APPROXIMATELY 800,000 OTHER MERCEDES M-CLASS, C-CLASS AND SLK MODELS, TO DATE THERE HAS BEEN ONLY ONE RELATED COMPLAINT TO ODI IN THOSE VEHICLES. DURING THIS INVESTIGATION MERCEDES BENZ PROVIDED ODI WITH 327 COMPLAINTS RELATED TO THE ESP SYSTEM IN THE MY 2000 THROUGH 2001 M CLASS VEHICLES.SEVEN OF THE COMPLAINTS SUBMITTED BY MERCEDES ALLEGED INCIDENTS OF UNCOMMANDED BRAKE ACTIVATION WHILE DRIVING, WITH TWO OF THESE INVOLVING VEHICLES IDENTIFIED IN THE ODI COMPLAINTS.NONE OF THE INCIDENTS RESULTED IN CRASH OR INJURY.HOWEVER, THE OWNERS DID EXPRESS SAFETY CONCERNS DUE TO THE SUDDEN, UNEXPECTED CHANGE IN VEHICLE SPEED AND DIRECTION. ON MAY 10, 2007 MERCEDES BENZ MET WITH NHTSA TO PROVIDE A TECHNICAL PRESENTATION AND CONDUCT A DRIVING DEMONSTRATION OF THE ESP SYSTEM PERFORMANCE WITH SIMULATED ELECTRICAL FAULTS IN THE YAW RATE SENSOR.MERCEDES SHOWED THAT THE ESP SYSTEM IS PROGRAMMED TO DIAGNOSE ELECTRICAL FAULTS AND THAT BRAKE APPLICATIONS RESULTING FROM YAW RATE SENSOR ELECTRICAL FAULTS ARE VERY SHORT IN DURATION (0.3 SECONDS OR LESS) AND DO NOT AFFECT VEHICLE CONTROL OR STABILITY. NINE OF THE CONSUMER COMPLAINTS TO ODI AND MERCEDES ALLEGED BRAKE ACTIVATIONS LONGER THAN 0.3 SECONDS, WITH SEVERAL ALLEGING THAT THE INCIDENT LASTED UNTIL THE VEHICLE CAME TO A STOP.A COMPLAINT VEHICLE THAT ALLEGED MULTIPLE INCIDENTS WAS EVALUATED BY ODI AT THE VEHICLE RESEARCH AND TEST CENTER (VRTC) IN EAST LIBERTY, OHIO.VRTC WAS UNABLE TO DUPLICATE THE CONDITION.DUE TO THE LOW COMPLAINT RATE AND ONLY ONE NEW COMPLAINT TO ODI OR MERCEDES SINCE JANUARY 2007, THIS INVESTIGATION HAS BEEN CLOSED.ODI WILL CONTINUE TO MONITOR COMPLAINTS IN THE SUBJECT VEHICLES AND OTHER MERCEDES PRODUCTS USING THE SAME YAW RATE SENSOR AND MERCEDES WILL PROVIDE UPDATES ON FIELD EXPERIENCE (COMPLAINTS, FIELD REPORTS AND WARRANTY CLAIMS) THROUGH THE END OF 2007.

AT HIGHWAY SPEED CAR JERKED VIOLENTLY TO THE LEFT AS OFF THE FROM RIGHT BRAKE WAS BEING APPLIED ON ITS OWN. TURNED THE ESP (ELECTRONIC STABILITY CONTROL) OFF AND PROCEEDED AND THE EVENT HAPPENED AGAIN, CAR JERKED TO LEFT AND HEADED TO DITCH BUT WAS ABLE TO OVERCOME WITH STEERING WHEEL. IT APPEARS A CAR SYSTEM FAILED CRASH RATHER THAN FAIL SAFE. *TR

NHTSA ID

10459727

Incident

May 24, 2012

Mileage

67,600 mi

TL* THE CONTACT OWNS A 2000 MERCEDES BENZ ML320. THE CONTACT WAS DRIVING APPROXIMATELY 55 MPH WITH THE CRUISE CONTROL IN ACTIVATION. WHEN PRESSURE WAS APPLIED TO THE BRAKE PEDAL, THE CRUISE CONTROL FAILED TO DISENGAGE. SUDDENLY THE BRAKES LOCKED AND THE VEHICLE CONTINUED TO ACCELERATE. THE GEAR WAS SHIFTED INTO NEUTRAL AND THEN INTO PARK, WHICH BROUGHT THE VEHICLE TO A STOP. THE CONTACT RESUMED IN OPERATION WITH CAUTION. THERE WAS A RECALL ASSOCIATED WITH THE FAILURE UNDER NHTSA CAMPAIGN ID NUMBER: 11V208000 (VEHICLE SPEED CONTROL: CRUISE CONTROL). THE RECALL PART WAS UNAVAILABLE TO PERFORM THE REMEDY REPAIR. THE MANUFACTURER WAS NOT MADE AWARE OF THE PROBLEM. THE APPROXIMATE FAILURE MILEAGE WAS 138,000.

NHTSA ID

10407062

Incident

Jun 15, 2011

Mileage

138,000 mi

WHILE DRIVING MY 2000 ML320 MERCEDES, THE CAR SUDDENLY APPLIES BRAKES WHILE TRAVELING AT VARIOUS SPEEDS. THE BAS/ESP WARNING LIGHTS COME ON. THIS IS A VERY DANGEROUS MALFUNCTION AND SOMEONE SHOULD MAKE MERCEDES ADDRESS THIS DEFECT IMMEDIATELY BEFORE SOMEONE IS KILLED! IF YOU DO A SEARCH ON THE INTERNET, IT WILL AMAZE YOU HOW MANY PEOPLE HAVE EXPERIENCED THIS HORRIFYING ORDEAL. PLEASE DO NOT IGNORE MY COMPLAINT. *TR

NHTSA ID

10380051

Incident

Jan 21, 2011

Mileage

160,000 mi

I WAS DRIVING MY 2000 MERCEDES BENZ ML 430 AT APPROXIMATELY 40 MPH, WHEN WITHOUT ANY WARNING LIGHTS BEING DISPLAYED IT ABRUPTLY STOPPED. THE BRAKE PEDAL HAD NOT BEEN DEPRESSED. THE VEHICLE THEN SKIDDED, STOPPED, SKIDDED AGAIN AND STOPPED. THIS WENT ON FOR APPROXIMATELY 45-60 SECONDS THEN THE BAS ESP MALFUNCTION LIGHT CAME ON. I WAS THEN ABLE TO DRIVE THE VEHICLE WHILE THE LIGHT WAS ILLUMINATED. I HAVE EXPERIENCED THIS ON 4 SEPARATE OCCASIONS AND HAVE ALMOST BEEN INVOLVED IN THREE ACCIDENTS WHICH ALL COULD HAVE BEEN FATAL BECAUSE THE VEHICLE STOPS COMPLETELY, IT DOES NOT SLOW DOWN THEN STOP, IT STOPS. I WAS ADVISED TO CHANGE THE TIRES AND HAVE THE BRAKE LIGHT SWITCH REPLACED. I DID BUT THE PROBLEM CONTINUED. I HAVE BEEN TOLD BY THREE CERTIFIED MECHANICS THAT THERE SEEMS TO BE A DEFECT WITH OR WITHIN MY ABS SYSTEM BECAUSE EVEN IF THERE IS A PROBLEM WITH MY ABS SYSTEM THE CAR SHOULD NOT ABRUPTLY STOP WHILE BEING DRIVEN AND IT SEEMS THAT THE ABS SYSTEM IS WORKING IN REVERSE ORDER BECAUSE THE MALFUNCTION LIGHTS ILLUMINATE AFTER THE MALFUNCTION OCCURS. THE ABRUPT STOPPING OF THE VEHICLE WHILE BEING DRIVEN IS DANGEROUS AND CAN CAUSE A FATALITY OR SERIOUS BODILY INJURY. I HAVE MY OLD BRAKE LIGHT SWITCH BUT DO NOT HAVE THE TIRES THAT WERE REPLACED. *TR

NHTSA ID

10348202

Incident

Jul 12, 2010

Mileage

116,885 mi

THE ANTILOCK BRAKING SYSTEM CAN TAKE OVER THROTTLE AND BRAKING. VEHICLE WILL AUTOMATICALLY APPLY BRAKES TO VARIOUS WHEELS. IT WILL PITCH THE CAR LEFT OR RIGHT AND REQUIRE DRIVER TO COUNTER STEER TO KEEP THE VEHICLE STRAIGHT. THERE IS NO WARNING ON WHEN THIS WILL HAPPEN. CAN CAUSE ACCIDENT OR CAUSE VEHICLE TO SPIN. MERCEDES DEALER SERVICE MANAGER ADVISE ME IT IS A FAULTY SENSOR AND IT IS REPLACE AT OWNERS EXPENSE FOR $600. I COMPLAINT THAT IT IS DANGEROUS AND SHOULD BE REPLACED. SERVICE ADVISOR SIMPLY REPLIED " YES IT IS, YOU SHOULD PAY FOR THE REPAIR. " *TR

NHTSA ID

10293268

Incident

Nov 19, 2009

Mileage

120,000 mi

2000 ML-CLASS MERCEDES ML55 LEAKING BRAKE LINE DUE TO CHAFFING AS DESCRIBED IN YOUR INVESTIGATION OF 52,000 ML-CLASS MERCEDES SUV'S. THE BRAKE LINE RUNNING FROM THE MASTER CYLINDER TO THE ABS PUMP SUFFERS EVENTUAL FAILURE DUE TO CHAFFING AGAINST A POORLY POSITIONED FUEL LINE. SUFFERED NEAR TOTAL FAILURE OF BRAKING SYSTEM THIS MORNING DUE TO THIS ISSUE. I HAVE ALL PARTS REMOVED, AND A FAILURE ASSESSMENT PROVIDED BY THE SERVICE TECHNICIAN. THE WORK WAS NOT PERFORMED AT A MERCEDES BENZ DEALER, THEREBY ENSURING OBJECTIVITY OF THE DIAGNOSIS. *TR

NHTSA ID

10290854

Incident

Nov 3, 2009

Mileage

87,000 mi

WITHOUT ANY WARNING, WHEN COMING TO A TRAFFIC STOP THE BRAKE PEDAL ON MY 2000 MERCEDES ML55 WENT TO THE FLOOR. I WAS ABLE TO STOP AFTER REAPPLYING THE BRAKE AND PUSHING VERY HARD. FORTUNATELY NO CARS WERE IN FRONT OF ME OR I WOULD HAVE HIT THEM. I PULLED TO THE SIDE OF THE STREET AND LOOKED UNDER THE HOOD, NOTICED THE BRAKE FLUID WAS LOW, PUT SOME FLUID IN AND DROVE A SHORT DISTANCE TO WORK. THE BRAKES WERE VERY SOFT. THE NEXT DAY TOOK THE VEHICLE TO MY MERCEDES DEALER WHERE THEY FOUND THAT A BRAKE LINE WAS RUBBED THROUGH AND LEAKING. NO INDICATOR LIGHTS OR WARNINGS OF ANY KIND OCCURRED BEFORE THE PROBLEM.

NHTSA ID

10270290

Incident

Feb 8, 2009

Mileage

66,335 mi

TL*THE CONTACT OWNS A 2000 MERCEDES BENZ ML. IN DECEMBER OF 2008, THE CONTACT TOOK THE VEHICLE TO THE DEALER TO HAVE IT REPAIRED ACCORDING TO NHTSA CAMPAIGN ID NUMBER 08V465000 (STEERING: HYDRAULIC POWER ASSIST: HOSE, PIPING). AFTER THE REPAIR, HE NOTICED THAT THE VEHICLE WAS STILL LEAKING FLUID. THE DEALER STATED THAT IF HE BROUGHT THE VEHICLE BACK, HE WOULD BE CHARGED FOR THE REPAIR. THE MANUFACTURER STATED THAT THEY WOULD CALL HIM BACK, BUT THEY NEVER DID. ON MARCH 26, 2009, WHILE DRIVING APPROXIMATELY 50 MPH, THE VEHICLE PULLED TO THE RIGHT AND THE CONTACT LOST CONTROL OF THE STEERING. THE VEHICLE VEERED TO THE SIDE OF THE ROAD AND WAS TOWED TO A REPAIR SHOP. THE MECHANIC FOUND THAT THE POWER STEERING FLUID WAS LEAKING ON THE BELTS AND CAUSED THE STEERING TO FAIL. THE VEHICLE HAS NOT BEEN REPAIRED. THE FAILURE MILEAGE WAS 80,000 AND CURRENT MILEAGE WAS 100,000.

NHTSA ID

10263170

Incident

Mar 26, 2009

Mileage

80,000 mi

MERCEDES: SEE DOCUMENT SEARCH BUTTON FOR OWNER LETTER. THE LOWER POWER STEERING HOSE AND CLAMP SHOULD BE REPLACE, UNDER EXTENDED WARRANTY, DUE TO POWER STEERING LEAKAGE FROM CONNECTION TO POWER STEERING COOLER. MODELS 1998-2003 163.154, (ML320, 430, 55, 500, 350). *PE

ESP LAMP ILLUMINATED. *TT

ENGINE WILL NOT START AND FAULT MESSAGE START ERROR APPEARS IN INSTRUMENT CLUSTER. *TT

SOME VEHICLES MAY EXPERIENCE POOR NAVIGATION POSITIONING IN HIGHER ALTITUDES (VEHICLES DRIFTS OFF OF ROADS ON MAP SCREEN OR POOR RE-ROUTE CALCULATION). *TT

THIRD ROW SEAT KITS. *TT

SUBJECT REGARDING PART NUMBERS AND PRICING INFORMATION FOR THE REAR SEAT VIDEO ENTERTAINMENT SYSTEM. *TT