Letter to NHTSA Administrator Runge Re: Recall Remedy

September 26, 2002

Dr. Jeffrey Runge, Administrator
National Highway Traffic Safety Administration (NHTSA)
400 7th Street SW
Washington DC 20590

Dear Dr. Runge:

It is our understanding that Ford Motor Company intends to announce tomorrow
that it will recall its Crown Victoria Police Interceptors (CVPI) for
defective fuel systems which explode on impact.1 We strongly urge
the National Highway Traffic Safety Administration (NHTSA) to crash test
these fixes to confirm they will protect police officers in the 80+ mph
rear impacts in which occupants survive the crash forces only to burn
to death. When Ford agreed to recall the Pinto in 1978, NHTSA conducted
its own crash tests at DySci in Phoenix that showed Ford’s proposed remedy
was inadequate and required substantial changes to upgrade the fix before
NHTSA would approve the recall. As shown in the attached
chronology, Ford first came up with a plastic shield, longer filler
neck and better gas cap that proved inadequate in NHTSA crash tests. All
further Ford crash tests had NHTSA personnel on the scene. Ultimately,
the recall remedy was substantially upgraded after more stringent car
to car crash tests were conducted.

The need to do independent testing of any fix Ford proposes is all the
more imperative because private companies have crash tested fixes available
today that demonstrate these Ford CVPI can take an 82 mph rear impact
from a full-size pickup without a fire. The independent crash test was
performed last month by Goodrich Aerospace at its Hurricane Mesa Test
Track, a military testing center in Hurricane, Utah. Using a pusher/rocket
sled, engineers crashed a 1970 Ford F-100 pick-up truck weighing more
than 4,000 pounds into the rear of a 1999 Crown Victoria Police Interceptor
(CVPI) equipped with both a Fuel Safe bladder and a Fire Retardant Panel
(FIRE Panel). The pick-up impacted the rear of the Crown Victoria at 81.9
mph. Even though the CVPI contained real gasoline instead of non-flammable
Stoddard fluid, there was no fire.2 Neither technology is radical
or new. The bladder has been used in Ford’s own race cars while the fire
retardant has been used for years in military planes and has been tested
by the Bureau of Standards in passenger motor vehicles.

Although Ford has tried to mislead the public into believing the fire
crashes in Crown Victorias are unsurvivable due to high speed, they are
generally survivable because the Crown Victoria has so much crush space
and strong seats to absorb the energy of the crash.3 By placing
the fuel tank in the energy absorbing crush zone, Ford converts a survivable
80 mph trauma crash into a fatal fire crash.4 The location of the
fuel tank in the crush zone makes it vulnerable to side and angled impacts
such as the ones that killed Officers Jefferson Davis
in Florida and Robert
Neilson in Arizona. Such non-direct rear impacts makes it all the
more imperative that there be independent crash tests with Ford’s proposed
fix that replicate real world crashes to determine if the fix is adequate
at high speeds.

With police officers and consumers dying across America in Crown Victoria,
Grand Marquis and Town Car fire crashes, it’s time for Ford to do the
right thing and recall all these vehicles just as Ford did with the Pinto
in 1978. And just as NHTSA did in 1978, any recall proposed by Ford must
be independently tested to confirm that it is a real recall that saves
lives and not a sham recall that saves Ford dollars.

We would appreciate the opportunity to talk with you about this before
you take a position on Ford’s proposed recall.

Sincerely,

Clarence M. Ditlow
Executive Director
Center for Auto Safety

Joan Claybrook
President
Public Citizen

1 We are also concerned about the civilian versions of
the 1992-2001 Crown Victoria and its twins, the Grand Marquis and Town
Cars (hereinafter Crown Victoria), which together have been involved in
at least 83 fatal fire crashes with 102 occupant
deaths.

2 The Fuel Safe bladder lines the fuel tank and enhances
its structural integrity, limiting the possibility of fuel spraying if
the tank is damaged. The FIRE Panel creates a plume of fire retardant
powder around the tank on impact to "inert" the environment
and prevent any fuel that does leak from igniting. The FIRE Panel has
its origins in advanced military technology that is used to protect the
fuel tanks on sophisticated helicopters and aircraft.

3 The fundamental principle of crash fire safety is that
if you survive the trauma of a crash, you should not die by fire. In its
Research Safety Vehicle (RSV) Program of the late 1970’s, NHTSA demonstrated
that 50 mph rear barrier impacts, well over 80 mph impacts into parked
vehicles, were survivable crashes with good crash management and fuel
system integrity to prevent injury and fire respectively.

4 NHTSA crashes vehicles at 35 mph into fixed barriers
in frontal collision which is equivalent to striking a parked car of similar
mass at 70 mph. Most vehicles including the Crown Victoria do very well
in these crashes even though the front structure of a vehicle is much
more difficult to design to collapse and absorb energy than is the rear
of a large vehicle.