Today, I sent this letter to David Friedman (in photo), Acting Administrator of the National Highway Traffic Safety Administration (NHTSA):
On March 30, 2010 NHTSA’s Office of Defect Investigations opened Preliminary Investigation PE10010, into corrosion-related brake line failures in General Motors full-size pickups made between 1999 and 2003. In January 2011, that investigation was upgraded to ODI Engineering Analysis EA11001, which in part appears to determine if corrosion-related brake line failures were a General Motors-specific issue or industry-wide. The “Engineering Analysis” investigation remains open to this day after over three years, making it NHTSA’s longest-running open investigation, and the second longest investigation in its history.
In response to media coverage of our recent letter to General Motors’ CEO Mary Barra calling for the recall of full-size trucks made from 1999 until 2003 for brake line corrosion, GM spokesman Alan Adler told the Detroit News that “brake line wear is a maintenance issue that affects the entire industry.” This echoed Mr. Adler’s earlier statements to Consumer Affairs, with the exception that Mr. Adler no longer claims that the vehicles warning systems will alert drivers of imminent brake failure because NHTSA’s investigation shows at least 25% of related incidents involved no warning to the driver.
Similarly, NHTSA’s publicly available data show that this defect may be far from the “industry-wide” problem GM and Mr. Adler claim it is. According to NHTSA documents, the Office of Defect Investigation has received 519 complaints for brake line corrosion issues in several models of GM trucks. General Motors itself reports another 277 complaints for brake line corrosion issues.
On August 9, 2011, NHTSA’s Office of Defects Investigation Director Frank Borris sent a “Peer Vehicle Inquiry” letter to truck manufacturers seeking information to determine whether in fact the brake line corrosion issue may be a larger industry problem as Mr. Adler has claimed. Among other questions, NHTSA’s ODI inquiry asked Toyota, Ford, and Chrysler to report the number of ’99-’03 “peer vehicles” manufactured for sale or lease in the United States (mid-sized and full-sized trucks) as well as the number of “consumer complaints” related to brake line corrosion issues for those vehicles.
Based on our analysis of the responses of Toyota, Ford and Chrysler to Director Borris’ August 9th 2011 inquiry, it appears that the three truck manufacturers queried had far fewer brake line corrosion complaints than General Motors.
Our analysis of NHTSA filings indicates that Chrysler has received only 90 complaints that may relate to brake line corrosion failure in comparable pickup trucks; Toyota has received 11 reports; and, depending on how the NHTSA data are interpreted, Ford has received 76 reports or complaints. 
The following table shows the number of “peer vehicles” manufactured by each company for the years in question (’99-’03), the number of complaints, the complaints per vehicle, and the complaints per 100,000 vehicles.
99-’03 Peer Vehicles
Complaints/ Reports per Vehicle
Complaints per 100K Peer Vehicles
As the data indicate, it appears that General Motors has 6.5 times the number of complaints per 100,000 vehicles for brake line corrosion issues as the manufacturer with the next largest number of complaints – Chrysler.
If the responses to Director Borris’ August 9, 2011 inquiry from other vehicle manufacturers are accurate, this would appear to be yet another troubling example of GM denying responsibility for a major vehicle safety issue, in this case by falsely claiming that the brake line corrosion issue is “an industry wide” problem.
In November of 2013, GM issued a Technical Service Bulletin (#13-05-22-001, NHTSA Ref #10054261) making brake pipe replacements available for full-size trucks and SUVs made between 1999 and 2007. Not only does this demonstrate that GM recently believed it did in fact bear some responsibility for the brake line corrosion problems it now claims aren’t its problem, it also fits the pattern of GM’s abuse of Technical Service Bulletins (TSBs) instead of recalls as a response to safety issues.
Moreover, GM’s use of a regional recall in 2005 (NHTSA recall #05V-379) for truck brake component corrosion on 1999-2002 pickups reflects ODI’s assessment that “there is a general perception in ODI that GM is one of, if not the worst offender of the regional recall policy.”
GM’s pattern of concealing potentially serious safety issues from the public and circumventing the recall system is deeply troubling. From the now-infamous ignition problem, to the steering problems our earlier investigation uncovered, to this troubling brake corrosion issue, GM’s response to defect complaints has been consistent: deny, conceal, blame consumers, or claim that it’s a broader “industry-wide” problem.
In light of the evidence that seems to suggest brake line corrosion uniquely affects GM pickup trucks, we call on NHTSA to conclude its Engineering Analysis of the issue with all possible haste, and demand a recall related to this dangerous defect.END LETTER
The letter was copied to:
Eric Holder, Attorney General
Anthony Foxx, Secretary of Transportation
Sen. Jay Rockefeller, Chairman, Senate Committee on Commerce, Science and Transportation
Sen. Claire McCaskill, Chairman, Commerce Subcommittee on Consumer Protection, Product Safety and Insurance
Rep. Fred Upton, Chairman, House Energy & Commerce Committee
Rep. Darrell Issa, Chairman, House Oversight and Government Reform Committee
 Ford 9-28-2011 Appendix C1 [.MDB] (light duty trucks only) indicates 12 total reports in category “CQISTotal.” The same database shows 25 “A1 category” (“brake line leak due to corrosion”) reports from the Master Owner Relations Systems (MORS) database. Ford 9-28-2011 Appendix C2 [MDB] (heavy duty only) records 39 “A1” categorized reports from MORS and zero A1 category reports from CQIS.