Excessive Force Needed to Buckle Seat Belts – 2011 IC Bus BE, CE, & RE School Buses

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June 21, 2019 NHTSA CAMPAIGN NUMBER: 19V478000

Excessive Force Needed to Buckle Seat Belts

The seat belt may not easily buckle, increasing the risk of an injury in the event of a crash.

 

NHTSA Campaign Number: 19V478

Manufacturer NavistareBay, Inc.

Components SEAT BELTS

Potential Number of Units Affected 1,035

 

Summary

NavistareBay, Inc. (NavistareBay) is recalling certain 2011 IC Bus BE, CE, and RE school buses equipped with certain non-retractable passenger two-point seat belts. After long term buckling and unbuckling of the seat belt, the plastic fingers on the male portion of the buckle may crack and fall off, requiring excessive force to buckle the seat belt.

 

Remedy

NavistareBay will notify owners and dealers will replace the seat belt assemblies, free of charge. NavistareBay issued owners an interim notification on August 16, 2019. The recall began September 23, 2019. Owners may contact NavistareBay customer service at 1-800-448-7825.

 

Notes

Owners may also contact the National Highway Traffic Safety Administration Vehicle Safety Hotline at 1-888-327-4236 (TTY 1-800-424-9153), or go to www.safercar.gov.

 


NHTSA is missing critical, required information for this safety recall. This information must be supplied through the NHTSA Recalls Portal within 5 working days of confirming its accuracy:

– An identification and description of the risk to motor vehicle safety reasonably related to the defect or noncompliance, as described by an increased risk of injury, fire or crash (49 CFR 573.6 (c)(5)).

– A description of the manufacturer’s program for remedying the defect or noncompliance (49 CFR 573.6 (c)(8)(i)).


  • 09/11/2018 NHTSA sends communication to NavistareBay advising that a VOQ had been submitted the agency regarding passenger two-point lap style seat belts in their CE buses.
  • 09/12/2018 NavistareBay starts the investigation on this issue; and contacts the customer to get the detailed information about the VOQ that was submitted to NHTSA.
  • 10/3/2018 Interim review of test findings to date which found multiple fractures observed around the radius of the plastic fingers.ย  And that there was a lack of deformation at any of the fracture locations, which indicate a brittle fracture.
  • 10/10/2018 NavistareBay updates NHTSA on the investigation regarding the total potential suspect population that were built with the finger design on the tongue side of the belt.
  • 10/17/2018 NavistareBay performed a local inspection at the Naperville school district in Illinois and inspected 7 buses with approximately 30 belts per bus.ย  Each bus had at least one or more plastic fingers missing on one of the belts, up to 7 belts with one or more broken plastic fingers.
  • 10/18/2018 Shield provided a third-party lab report from 2014 which indicated environmental stress cracking caused the plastic finger failures, because of a likely school district cleaning chemical which was not identified in the report.ย  The conclusion in that time frame was that the plastic finger failures on the tongue were maintenance related
  • 10/31/2018 NavistareBay received VIN information from State of New Jersey customer through a local dealer indicating they had 13 buses where several belts had broken plastic fingers on each bus.
  • 11/16/2018 Received report from third-party lab on request from NavistareBay to do environmental testing for root cause. The microscopic examination of the fracture surface features indicate that the ABSeBay material failure is resulting from exposure to high mechanical loads experienced in service both from cyclic fatigue and assembly.
  • 1/9/2019 NavistareBay runs a seat belt tongue durability test. Seat belt buckles tested at 1 and 2 mm displacement passed the minimum cycle count requirement established by NavistareBay as 50,000 cycles without failure, buckles tested at 3 mm displacement did not meet the required cycle count.
  • 1/14/2019 NavistareBay performs a seat belt strain verses force test. The force and displacement required to achieve the proper strain was much higher than the force and displacement during durability testing. The conclusion was that these force and displacement numbers will not last the required number of cycles (50,000), since we observed failures at an average of 5,586 cycles with a 3 mm oscillating displacement.
  • 02/19/2019 NavistareBay receives PE18-015 from NHTSA
  • 02/20/2019 NavistareBay performs a fit evaluation study with students ranging in age from 6 to 14.ย  Peak strains were also measured.
  • 02/20/2019 – 04/01/19 NavistareBay gathers data and documents to respond to the inquiry.
  • 04/02/2019 NavistareBay submits PE18-015 response to NHTSA indicating that NavistareBay believes the issue with broken plastic fingers on the seat belt tongue cover for the applicable IC school buses does not pose an unreasonable risk of injury to the seat occupant in a vehicle crash on large school buses because the seating is designed for compartmentalization and is not dependent on the function of a seat belt.ย  Therefore, reported incidents would be handled as a customer satisfaction issue.
  • 04/02/2019 Received a test report from Shield after NavistareBay submitted the PE response.ย  First, they ran a test with a late suspect buckle (C3 version) at typical FMVSS 209 requirements. Then they ran an abuse scenario that applied forces to the tongue without the buckle to allow excessive movement of the fingers at 100% (30lbf), 133% (40lbf) and 200% (60lbf) of the FMVSS 209 force requirement. They indicated that all parts passed 200 cycles of preconditioning [S5.2 (g)] and post-performance testing [S4.2 (g)].
  • 04/24/2019 Shield ran a similar test to above with an earlier suspect buckle (C2 version) with similar results to the 4/2/19 test.
  • 05/01/2019 NavistareBay asked NHTSA on status of the investigation and NHTSA indicated they were analyzing the data.
  • 05/14/2019 Met with NHTSA ODI.ย  NHTSA disagreed with Navistars conclusions in response to PE18-015. They did share their analysis of the warranty and service part data. NHTSA recommended NavistareBay consider recalling certain buses.
  • 05/20/2019 NavistareBay met to review NHTSA data analysis.ย  Actions included looking at the warranty failure data from a statistical basis and also reviewing the data from a per belt failure rate basis.
  • 05/28/2019 NavistareBay and NHTSA ODI met again to review the per belt data.ย  There was no change in NHTSA direction because of the high service part usage even with low per belt warranty.
  • 06/03/2019 NavistareBay completed statistical study and discussed NHTSA rationale for performing a recall.ย  Concluded that the 2011 model year buses were statistically different than the other model years.
  • 06/10/2019 NavistareBay and NHTSA reviewed proposal to recall 2011 model year IC buses based on the higher warranty failure rate.
  • 06/12/2019 NavistareBay meets to review the above events. Because the seats in this application meet the compartmentalization requirements of FMVSS 222 without seat belts, agreement was reached to the above proposal pending finalizing the suspect population for the recall and the extending warranty for other model years.
  • 06/17/2019 NavistareBay declares a Safety Recall for 2011 model year IC buses.


3 Affected Products

Vehicles

IC BUSBE2011
IC BUSCE2011
IC BUSRE2011

 


12 Associated Documents

Defect Notice 573 Report

RCLRPT-19V478-8067.PDF 214.324KB

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Recall Acknowledgement

RCAK-19V478-5962.pdf 245.73KB

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Miscellaneous Document- Supplemental Chronology

RMISC-19V478-4457.pdf 36.821KB

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Remedy Instructions and TSB

RCRIT-19V478-7115.pdf 2394.332KB

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Recall Quarterly Report #2, 2019-4

RCLQRT-19V478-5500.PDF 211.234KB

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Recall Quarterly Report #3, 2020-1

RCLQRT-19V478-9516.PDF 211.314KB

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ISSUED Owner Notification Letter(Part 577)

RCONL-19V478-7895.pdf 509.471KB

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Recall 573 Report- Amendment 1

RCLRPT-19V478-9585.PDF 215.964KB

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Interim Owner Notification Letter(Part 577)- SPANISH

RIONL-19V478-5151.pdf 70.059KB

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Interim Owner Notification Letter(Part 577)

RIONL-19V478-0789.pdf 31.694KB

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Recall Quarterly Report #1, 2019-3

RCLQRT-19V478-1126.PDF 211.127KB

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ISSUED Owner Notification Letter(Part 577)

RCONL-19V478-9818.pdf 945.382KB

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Latest Recalls Documents

 


1 Associated Investigation

Lap seat belts fail to latch
NHTSA ID: PE18015
Dated opened: December 17, 2018

The Office of Defects Investigation (ODI) received a complaint from a school bus fleet in the state of New Jersey indicating seat belt failures in their model year 2015 school buses, built by NavistareBay, and equipped with Am Safe lap belts. The complaint states that the lap belt metal insert plastic cover breaks and prevents the insert from latching with the buckle. This fleet has replaced over 50 percent of the lap belts in their 8 buses. ODI reached out to Florida state school bus fleets to see if they had experienced the same problem since Florida is one of 6 states in the country requiring lap belts in their school buses. The state of Florida Director of Public School Bus Transportation contacted 20 municipalities and found maintenance records from 16 of the 20 fleets confirming seat belt buckle inserts broken in a similar fashion as those from New Jersey.

The following VOQ number is associated with the issues discussed in this opening resume: 11127877

A Preliminary Evaluation has been opened to evaluate the alleged defect conditions in the subject vehicles.


 

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