NHTSA Preliminary Evaluation PE19008

On July 17, 2019, NHTSA's Office of Defects Investigation (ODI) opened Preliminary Evaluation (PE) 19-008 after receiving three Vehicle Owner Questionnaire (VOQ) reports alleging the driver's side seat belt buckle separated from the seat frame, rendering the seat belt non-functional. The VOQs involved model year (MY) 2015 and 2016 Jeep Wrangler (JK platform) that were configured for right-hand drive (RHD) use. On August 8, 2019, ODI issued an information request (IR) letter to FCA.The scope of the IR included all JK Wrangler produced for sale in the U.S. (both left- and right-hand drive), and amongst other things, requested any reports or allegations of driver's seat belt bracket failures on these vehicles. In its review of FCA's response, ODI determined that approximately 1.7 million JK Wrangler were produced from MY 2007 to 2018, about 16,000 of which were configured for RHD. ODI notes that the RHD Wrangler are typically used for rural postal delivery which often experience a more severe duty cycle. Also RHD JK was was not produced in MY 2007.As explained in the IR response, FCA identified three distinct populations of JK Wrangler concerning the driver's seat belt bucket bracket; specifically the MY 2007-2018 LHD (~1.7M units), the MY 2008-2010 RHD (4,563 units), and the MY 2011-2018 RHD (11,463 units) populations.FCA provided details on the designs used in each of these populations, identifying specific differences deemed pertinent to the strength and durability of each unique bracket design. FCA further reviewed its analysis of the complaint and warranty data identified under the IR, and noting that it had not identified any allegations of bracket failures on the LHD population, and only one allegation on the MY 2008-2010 RHD vehicles. By comparison, FCA identified 24 allegations of bracket failure for the MY 2011-2018 RHD JK, including two reports duplicative of the VOQs. Neither the FCA nor the VOQ reports allege an injury or fatality due to bracket failure. B