Fuel Storage System Crash Related Fires

In a letter dated October 2, 2009, the Center for Auto Safety (CAS) petitioned NHTSA to open a defect investigation and recall model year 1993-2004 Jeep Grand Cherokees. CAS alleged that the subject vehicles have defective fuel tank storage systems that present a fire hazard in crashes. CAS alleged that the plastic fuel tank's placement behind the rear axle and below the rear bumper, and the lack of adequate shielding, make it more vulnerable to rupture or leakage from a rear-impact by another vehicle (including damage from other components located on the Grand Cherokee), or in the case of rollover crashes, from other external objects. CAS also alleged that the fuel filler neck tears off in crashes. In its petition, CAS cites data from NHTSA's Fatality Analysis Reporting System (FARS) showing 172 fatal fire crashes with 254 fatalities involving the subject vehicles from calendar years 1992 through 2008. CAS stated that there have been at least 44 crashes with 64 total fatalities (subject and non-subject vehicles) where fire was entered as the Most Harmful Event (MHE) in the FARS database. In response to the CAS petition, ODI made a preliminary examination of available data. FARS data showed 2,988 occupants of the subject vehicles have died in crashes since 1992. Of those, 55 died in 44 crashes where fire was listed as the Most Harmful Event. Identifying crashes most likely associated with the alleged defect as described by CAS (defined as the subject vehicle being struck at the 5, 6 or 7 o'clock positions) isolated 10 crashes with 13 occupant fatalities. ODI also reviewed the Vehicle Owner Questionnaires (VOQ) database and identified 12 reports alleging A) a post-crash fuel tank leak and/or B) a post-crash fire potentially related to a fuel tank leak. Of the 12 reports, 10 involved fires (two involved fuel leaks only) with 9 alleged injuries and 1 alleged fatality. The existence of these post-crash fires does not, by itself, establish a defect trend. Further review