General Motors GMT-900 Takata Airbag Petition of Inconsequentiality

by Kevin Fitzgerald & David Schumann on September 4, 2018

The GM petition to avoid recalling 6.8 million of their pickups and SUVs can be found here. We have addressed their arguments technically here, and in this article, we focus on the petition, the overview, and demonstrating that we are the actual experts, not GM or their outside consultants. The GMT-900 SPI-YP GEN 1 inflators are all recalled, but GM makes the argument that their GEN 2 version and its dual stage brother PSPI-YD should be spared the same fate. Let us explain why NHTSA should reject their petitions and the rest of us should be outraged.

The fascinating thing about the SPI-YP GEN 2 design improvements is that we were responsible for them. Schumann, working for Kevin, was the engineer who developed the enhancements and oversaw the running change. GM is right that the GEN 2 inflator is the better of the two, but only in terms of mechanical resistance. The changes made did nothing to improve the propellant’s ability to withstand environmental aging. We reject nearly all of GM’s petition arguments, and are quite adamant all of their GMT-900 inflators need to be replaced.

There is scandal behind the GMT-900 launch that is fully related in our book, but we will share some here. Internal to Takata’s inflator development center in Armada, Michigan, were two engineering teams. One was managed by Paresh Khandhadia and was responsible for inflator and propellant R&D. From this group came the now infamous phase-stabilized ammonium nitrate (PSAN) family of inflators. The other team was managed by Kevin, and his engineers were tasked with preparing Paresh’s designs for production and conducting their process validations (PV). This included GM’s SPI-YP GEN 1.

Paresh’s team conducted the GEN 1 design validation (DV) and published a report that showed compliance with GM’s specifications, and Kevin’s team took the program, released the final drawings, ordered production hardware, and then ran the PV in Monclova, Mexico. As the testing progressed, however, failures began to emerge after exposure to mechanical environments, specifically the USCAR drop test. Kevin asked Schumann to investigate, and his findings are what led to the GEN 2 design.

The glaring and obvious mystery was the disparity between the DV and PV performance. The inflator’s propellant wafer stack must be protected against mechanical environments. Takata traditionally accomplished this with a single wave spring opposite the igniter end, but the drop test was new, and the spring reached solid height upon impact, transferring the shock directly to the wafers, severely damaging them. This led to erratic and aggressive results, often not meeting specification limits. The DV report, however was flawless, and even more perplexing, the tear-down pictures included showed the wafers in substantially better shape than the PV. They were almost pristine. How could this be? It didn’t take long to discover that the test had been rigged by placing a cushion under the steel plate the inflators were required to impact. Paresh’s team couldn’t pass the test, so he instructed them to modify it and then threw the package over the fence.

Kevin broadcast this news to his management. This was trouble. GM’s launch date was immovable, and his team was now responsible for a subpar design, failing to meet requirements. Something had to be done quickly, and he assigned the GEN 2 redesign effort to Schumann. Ceramic cushions were tried first and although they successfully protected the wafers from drop, they were shredded by vibration. Drop tests followed by vibration were conducted over and over until David hit on the right combination, inserting a cushion inside the wave spring, and placing one at each end of the wafer stack. The nominal 2004 tablet load was reduced by 1.25 grams to accommodate the reduction in free volume from the added components, and an improved, more manufacturable propellant can was also introduced. The process validation was run again, everything met requirements and the GEN 2 was launched.

We share this detail here for two reasons. One, to make it clear to our readers that we understand these inflators better than anyone, and second, to highlight that Takata was a company with a deep-rooted culture of fraud and deceit. Our book tells so much more. This is crucial information, not vendetta, because it directly supports our arguments that so many more must be indicted, or our tragedy will not end. The GEN2 design changes were made solely to improve mechanical performance, that’s it. Nothing addressed PSAN degradation in the presence of heat and moisture, its Achilles tendon, and that means GM’s inflators will get more and more dangerous with time. All inflators leak, some more than others, weather patterns swing, the propellant degrades, and some unfortunate soul gets that much closer to a worst-case scenario. Too much remains unknown and the consequences are absolute. We know these inflators become unsafe. Let us convince you and earn your trust.

We support honest discussion and debate, but with peer-reviewed data. As it stands, GM likely has no strategy to replace these inflators once they are forced to finally acknowledge their weakness. They will be caught completely flat-footed, and another lengthy, time-phased recall will be hoisted on us. There are serious discussions to be had, and GM’s petition is just wasting precious time and resources.

GM Petition Highlights

Since we are intimate with the GMT-900 inflators, imagine our horror when we read GM’s first petition, and each one that followed. Basics are incorrect. Inflators were not tested at specification limits. ‘Simulated’ aging arguments are presented that contradict the real root-cause of moisture ingress and temperature-cycling. All post-aging deployments were conducted at ambient, or the high temperature deployment data is just not being shared.

We point this out because we are angry, and GM should be called on the carpet for their obfuscation while people’s lives hang in the balance. The title of their request says it all, a “Petition for Inconsequentiality.” Really? These are Takata PSAN inflators that have already claimed 23 lives and inflicted 350 injuries worldwide, most life-altering. Kevin has been protesting loudly since GM began inundating NHTSA with petition after petition, taking more precious time and resources away from the fight. They want to save a billion dollars and settle with the unfortunate. We want to save as many from the horrors as we can.

Highlighted below are some of the most egregious and nonsensical claims of GM’s third and latest inconsequentiality petition, Docket No. NHTSA-2016-0124. Follow this link for our detailed arguments that dismiss it entirely.

Page 2. “The GM study subjected test inflators to an estimated 30 years of aging, including moisture levels and temperatures significantly worse than real-world conditions in the GMT900 Vehicles in the highest risk ‘Zone A’ region,”

Maybe, but at levels less than their own specifications demand. The real-world experience is that not one Takata inflator has survived 30 years, and all the evidence to date points to non-desiccated inflators rupturing between 8 and 15 years. A GEN 1 SPI-YP field return has already demonstrated a near rupture after only ten years and it was deployed in a lab at ambient temperature. Furthermore, GM’s own report in support of the petition shows an aged GEN 2 nominal build inflator (no moisture added) exhibiting the same characteristic curve shape and time shift as the anomalous field return. It was on its way and simply from moderate temperature cycling absent external moisture. The near rupture inflator was returned from Texas where it experienced temperature swings in a humid environment. GM’s aged nominal inflators suggest the moisture sealed in the device during assembly and being transported back and forth between the propellants is enough on its own to become a problem over time.

Page 3. “The originally planned OATK study is now complete, and—despite three decades of extreme exposure to humidity- and temperature-related propellant degradation—all of the GMT900 Inflators in the study safely deployed without any ruptures.”

It may sound like these inflators were exposed to thirty-years of extreme humidity and temperature, but the statement is highly misleading. Let’s not forget this was ‘simulated’ aging in controlled conditions that were not ‘extreme’ in any sense of the word. The temperature cycling only went from 20C to 70C and from what we can make of the scant details, the moisture was added to the inflator all at once and not metered over time like the real-world. Orbital essentially doused the inflators in water, disarmed the booster and then deployed them at ambient where many failed to even light. And even with all this, a nominal build SPI-YP and PSPI-YD inflators with no moisture added and subjected to only moderate temperature cycling, began to run away.

Page 3. “These results demonstrate that the GMT900 Inflators, which have not ruptured in the field or in ballistic testing, will continue to operate safely for decades, even in the highest temperature and humidity regions.”

This is one of the most egregious statements advanced. GM concludes we should feel comfortable with these inflators in our faces forever, knowing an SPI-YP GEN 1 nearly ruptured after only ten years in the field and an SPI-DH with the same wafer stack configuration already ruptured in Florida. Furthermore, their artificially aged SPI-YP GEN 2 and PSPI-YD inflators are showing signs of ramping to rupture after only moderate temperature cycling with no added moisture. Their results demonstrate nothing even close. The only reason they haven’t exploded yet is because of time. Give them five more years and the picture will be very different. Nothing protects these inflators from the fate of the rest. Hope is not a strategy.

Page 6. “The GMT900 Inflators, moreover, are unique to GM vehicles, and have multiple unique design differences when compared to other Takata PSAN inflator variants—even inflators of the same Takata inflator family. These GM-unique design differences were purposeful: To meet GM’s airbag inflator sourcing requirements, which were some of the most exacting in the industry when the GMT900 vehicles were being developed, GM required Takata to heavily modify the characteristics of their standard SPI and PSPI-L inflators.”

Here GM states the SPI-YP GEN 2 inflator was specially designed to meet GM’s tough sourcing standards, but so was the GEN 1 version and it is already on the verge of exploding. Remember we made the design changes that led to GEN 2 configuration and they were solely to guard against an operator fumbling an inflator during module assembly. They had nothing to do with protecting the propellant from long term degradation. GM’s claim of their SPI-YP and PSPI-YD inflators being immune from rupture because they have thinner propellant wafers and a greater exit flow area than others is utter nonsense and is dismissed completely in the link provide earlier.

Page 6. “Many of these changes were necessitated by GM’s occupant-performance and component requirements, which included having all prospective airbag inflator suppliers satisfy the United States Council for Automotive Research, or USCAR, airbag-inflator performance specifications. Strict adherence to these specifications, which GM helped develop, resulted in inflators with increased inflator-structural integrity, better ballistic performance, and greater resistance to moisture.”

This is a head scratcher. Are we to infer that all Takata inflators that passed USCAR’s exacting standards are immune from rupture and if so, why are Ford and Chrysler’s passenger inflators being pulled back? Europe’s inflators require a higher safety factor than USCAR and they are being pulled back. Nissan and Toyota’s inflators require the same safety factor as USACR and they are being pulled back. Takata held every single inflator they made to the same moisture resistance standards. Understand why we are angry?

Page 7. As part of its initial analysis, which GM presented to the Agency in September 2016, OATK analyzed these design differences, and concluded that two in particular likely materially affect the inflator’s propensity to rupture:

• GM’s design change from thick wafers (10.8 g/11.0 mm) to medium/thin wafers (8.1 g/8.4 mm and 5.0 g/5.36 mm) in the PSPI-L YD inflator resulted in ballistic advantages. Heavy-weight test data with intentionally restricted nozzle vents indicated that the thinner wafers are less susceptible to energetic deployment as compared to the thicker 10.8 g/11.0 mm PSPI-L wafers.
• The increased primary-chamber vent area on the GMT900 PSPI-L YD inflator (36.19 mm2 on the PSPL-L YD v. 31.25 mm2 on the PSPL-L FD) results in faster flow of gas, which reduces the potential for higher peak pressures with degraded propellant.

Again, these claims are based on a flawed, ‘simulated’ aging study designed by Orbital-ATK, now Northrup Grumman, and are completely dismissed in our detailed analysis, but if we want to hang our hats on an Orbital claim, let’s look at this one from their original root cause report. They concluded there were three necessary factors that need to be present for Takata’s PSAN inflators to explode.

1. The presence of PSAN propellant without desiccant.
2. Long term exposure to repeated high temperature cycling in the presence of moisture.
3. An inflator that does not adequately prevent moisture intrusion under conditions of high humidity.

GM’s SPI-YP and PSPI-YD are the embodiment of the first two and all Takata inflators satisfy the third, especially given their horrible quality deficiencies. Orbital’s root cause report actually lays out the arguments for why the GMT-900 inflators will eventually succumb to failure.

“Further, as noted in the First and Second Petitions, the physical environment in GMT900 vehicles better protects the front-passenger inflator from the extreme temperature cycling that causes propellant degradation and has led to inflator rupture in other OEM vehicles. GMT900 vehicles, which are light trucks and SUVs, have larger interior volumes than smaller passenger cars, and are equipped with standard solar-absorbing windshields and side glass,8 all of which significantly reduce interior-vehicle temperatures.”

Orbital’s root cause report identifies vehicle platform differences as only a ‘contributor’. This means we can ignore the rest of GM’s arguments trying to convince us that their GMT platform vehicles magically protect PSAN inflators from themselves.

Pages 8-9. “To artificially age the inflators, OATK exposed groups of inflators, both GMT900 Inflators and a comparison group of recalled non-GMT900 Takata inflators, to 1680 4-hour temperature cycles at moisture levels and temperatures significantly worse than real-world conditions in the GMT900 Vehicles in the highest risk “Zone A” region. The study was designed to induce propellant degradation in the test inflators sufficient to cause inflator ruptures and energetic deployments—a true ‘test-to-failure’ experiment.”

Orbital’s study was far from a true ‘test-to-failure’ experiment. This is another shocking statement. They infer they did everything possible to fail their inflators, but couldn’t, therefore they must be good. Except the moisture wasn’t metered correctly, wasn’t in the right place, and the cycling and deployment temperatures didn’t meet specification extremes. They ‘simulated’ the aging process incorrectly, disarmed the booster, and yet still had nominal inflators – with no added moisture – exhibit characteristics of a runaway. They have no clue what they are talking about. Give them to us, we’ll make them rupture! By the time of the first death in 2009, Takata already knew the on and off switches, and which specifications did the most damage. Trust us. This was not a true ‘test-to-failure’ experiment.

Page 10. “First, the PSPI-L FD inflators are from the same Takata inflator family as the GMT900 light-duty inflator; but while they have certain similarities in design and construction, they lack the critical design elements that, in GM’s view, distinguish the GMT900 Inflators from other Takata non-desiccated PSAN inflators and make the GMT900 Inflators resistant to the risk of energetic deployment, even after the PSAN propellant has been damaged or degraded.”

We had to read this sentence twice. There is absolutely no one familiar with Takata’s inflators that would stand behind it. GM is actually claiming their configurations are so unique they can be loaded with degraded and damaged PSAN propellant and not suffer catastrophic failure. Let’s see that data! This is a ridiculous statement and another indication of how flawed the ‘simulated’ aging tests actually were. No inflator housing ever produced by Takata, or anyone for that matter, can withhold the deflagrating, near-explosive pressures resulting from degraded PSAN. If you knew ammonium-nitrate, you would know how absurd this statement is.

Page 11. “GM has not determined that a defect that poses an unreasonable risk to safety exists in the GMT900 Vehicles covered by Takata’s January 2018 DIRs or in any of the GMT900 Vehicles covered by one of the Petitions, and this Petition does not constitute a concession by GM of the existence of a defect in the any of the GMT900 Vehicles, as permitted by 49 C.F.R. § 556.4(c).”

This is lawyer speak. Let us translate: ‘We think the risks to your life are not worth $1B.’ GM knows it’s just a question of time. They even have the nerve to claim it is more dangerous to remove and replace these defective inflators, than just letting them be. They’re protecting us and their bottom line at the same time. Can you believe that? They don’t see real people, just numbers.

Page 12. “An estimated 63,000 Takata passenger airbag inflators have deployed in GMT900 vehicles without a single reported rupture.”

Doesn’t matter and not true. It’s akin to saying a million people smoked ten years and nobody has lung cancer yet. The near-rupture pulled from a 2007 Silverado, exceeded 90 MPa (>13,000 psi), and if it had still been in its vehicle on a hot day in Texas, it likely would have ruptured. Who knows how many more of those 63,000 deployments were close to rupture? Better Takata PSAN designs and vehicle improvements can affect the time it takes to degrade, but not the underlying truth. By fifteen years the picture will change. Trust us.

Page 13: “The results from the OATK study confirmed that the GMT900 Inflators will operate safely well into the future.”

We would like to get this on the record from Orbital ATK. It didn’t appear anyway in their report. A reporter should ask them if they support this statement, especially since they are now Northrup Grumman. What does ‘well into the future,’ even mean?

Page 15. “To assist GM in interpreting the results of the OATK study from a statistical perspective, GM retained Professor Arnie Barnett, the George Eastman Professor of Management Science and Professor of Statistics at the Massachusetts Institute of Technology, and a nationally recognized expert in modeling and calculating risk. Working with the assistance of other experts at Cornerstone Research, Professor Barnett had full access to GM and OATK’s test data and to the engineers that designed and ran the OATK study.”

To close their arguments, GM turns to statistics, which is the best proof their petitions are built on a sinking foundation. It’s not hard to find a statistician who will testify for a price. Credentials are meaningless if they are not backed by a deep understanding of thermochemistry and interior ballistics. Garbage in equals garbage out. GM’s statistician was handed numbers from a flawed aging study, threw some assumptions on top of them and concluded the probability someone would die from a GMT-900 inflator was 1 out of 430 trillion! Come on! We’ll take that bet.

Un-desiccated PSAN inflators have already ruptured far and wide, and GM’s designs that statistics are being used to claim will never suffer the same in a half a quadrillion events, is preposterous. Talk to us if its real numbers you want. Debate us. Equations drive the runaway pressures that lead to deaths, and millions of equations are running right now within each airbag and vehicle. It’s so annoying. Cornerstone’s calculations fly in the face of Takata’s own internal quality and manufacturing defect statistics. Takata was prone to mistakes and made many of them. An inflator that leaks more than another, or one that is loaded with lower density propellant, starts with a higher risk. Where is that in the analysis? GM wants you to believe the odds that tragedy will beset you are slim. We want you to see each inflator in the face of one of your loved ones, getting more dangerous with time, or already there, ready to take a life tomorrow. We have dedicated ourselves to this because we know they are dangerous.

The Vehicles GM Refuses to Recall

The 2007 model years have just crossed the ten year mark. Here is the list of the most popular trucks in America.

• 2007-2014 Cadillac Escalade
• 2007-2014 Cadillac Escalade ESV
• 2007-2013 Cadillac Escalade EXT
• 2007-2013 Chevrolet Avalanche
• 2007-2014 Chevrolet Silverado HD
• 2007-2013 Chevrolet Silverado LD
• 2007-2014 Chevrolet Suburban
• 2007-2014 Chevrolet Tahoe
• 2007-2014 GMC Sierra HD
• 2007-2013 GMC Sierra LD
• 2007-2014 GMC Yukon
• 2007-2014 GMC Yukon XL