CAS letter to NHTSA regarding a General Motors’ Fourth Takata Inconsequentiality petition

December 19, 2019

Docket Management Facility, M-30 U.S. Department of Transportation

1200 New Jersey Avenue SE
West Building, Room W12-140

Washington, DC 20590

Submitted electronically via www.regulations.gov
RE: Docket No. NHTSA 2016-0124-0305: General Motors LLC Fourth GM Petition
for Inconsequentiality re: GMT9001

The Center for Auto Safety (“Center”) once again is submitting a letter to the National Highway Traffic Safety Administration (“NHTSA”) regarding a General Motors’ (“GM”) Takata Inconsequentiality petition. This letter is specifically regarding the October 24, 2019, submission titled “General Motors LLC’s Petition for Inconsequentiality regarding certain GMT900 vehicles equipped with Takata “SPI YP” and “PSPI-L YD” passenger inflators subject to January 2019 Takata Equipment DIR filings.” (Fourth Petition).2 The Center, founded in 1970, is an independent non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy on behalf of all drivers, passengers, and pedestrians. We appreciate the opportunity to comment on this important safety issue potentially impacting millions of Americans.

On May 9, 2018, the Center submitted a comment objecting to GM’s Petition for Inconsequentiality regarding the automaker’s Takata airbag inflators.3 Today, the Center continues to urge NHTSA to deny GM’s Third and Fourth Petitions for Inconsequentiality4 and demands that GM address serious concerns with both the findings within the GMT900 Investigation submitted previously, the information missing from that document, and additional defects in the Fourth Petition.