Nissan Comments

COMMENTS OF NISSAN NORTH AMERICA, INC. TO THE
NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION
Request for Public Information; 49 CFR Parts 573 and 577
Reports, Forms, and Record keeping Requirements
June 27, 2016 (Docket No. NHTSA–2016-0065)
Nissan North America, Inc. (“Nissan”) offers the following comments in response to the Request for
Public Information on Reports, Forms and Record Keeping Requirements. Under procedures
established by the Paperwork Reduction Act of 1995, NHTSA is soliciting public comment on
proposed collections of information, including extensions and reinstatement of previously approved
collections, before seeking approval from the Office of Management and Budget (OMB).
In this submission, Nissan is providing estimates regarding the potential man hours/time spent and
costs required to comply with the requirements set forth in 49 CFR Parts 573 and 577. Nissan’s
estimates include current processes necessary to produce the below information required by the
regulations.
In regards to manufacturer notification to NHTSA, the Agency states:
“We continue to estimate that it takes a manufacturer an average of 4 hours to complete
each notification report to NHTSA and that maintenance of the required owner, purchaser,
dealer, and distributors lists requires 8 hours a year per manufacturer. Accordingly, the subtotal
estimate of annual burden hours related to the reporting to NHTSA of a safety defect or
noncompliance and maintenance of owner and purchaser lists is 5,616 hours annually ((854
notices x 4 hours/report) + (275 MFRs x 8 hours)).
Nissan estimates that it spends two (2) to three (3) days (16-24 hours) to complete each Defect
Information Report (DIR), based on an eight (8) hour day. This varies based on the size and
complexity of the recall.
In regards to dealer and distributor notification, the Agency states:
In addition, we continue to estimate an additional 2 hours will be needed to add to a
manufacturer’s Part 573 Safety Recall Report details relating to the intended schedule for
notifying its dealers and distributors, and tailoring its notifications to dealers and distributors in
accordance with the requirements of 49 CFR § 577.13.
Nissan’s experience shows that the task requirement of the Dealer notification varies based on the
complexity of the recall. Nissan typically works up to five (5) business days/forty (40) hours to craft the
Dealer announcement with the appropriate repair protocol and other essential information to provide
to dealers. The announcement creation includes coordinating with multiple departments in order to
notify and instruct the dealers/retailers on how to execute the remedy.
In regards to providing the Agency copies of communications regarding defects and noncompliances,
the Agency states:
49 USC § 30166 (f) requires vehicle manufacturers to provide to the Agency copies of all
communications regarding defects and noncompliances sent to owners, purchasers, and
dealerships. Manufactures must index these communications by the year, make, and model of
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the vehicle as well as provide a concise summary of the subject of the communication. We
estimate this burden requires 30 minutes for each vehicle recall.
Nissan agrees with the Agency’s estimate.
In regards to manufacturer preparation concerning customer reimbursement, the Agency states:
As for the burden linked with a manufacturer’s preparation of and notification concerning
its reimbursement for pre-notification remedies, we continue to estimate that preparing a plan for
reimbursement takes approximately 8 hours annually, and that an additional 2 hours per year is
spent tailoring the plan to particular defect and noncompliance notifications to NHTSA and
adding tailored language about the plan to a particular safety recall’s owner notification letters.
In order to meet the Agency’s regulations and requirements, Nissan estimates the following:
•

The Consumer Affairs Department:
o

Maintains a website for customers to submit reimbursements related to campaigns. The
yearly budget for maintaining and updating the site is approximately $24,000.

o

Updates to the website take approximately four (4) hours to complete. This does not
include the development of the customer facing information (e.g. Notification and Q&A).

o

Additional time is required to disseminate internal documents to Consumer Affairs staff that
we estimate takes about one (1) hour per month.

•

The Field Quality Assurance department spends an average of four (4) hours per issue
creating the reimbursement plan.

•

The Technical Compliance department spends an average of thirty (30) minutes per campaign
to add the reimbursement specific language to the owner notification letter.

In regards to costs associated with manufacturer VIN lookup tool, the Agency states:
The estimated costs to industry for one-time infrastructure expenses to create a VIN-based recalls
lookup service consisting of 108 hours, and costing a total of $45,000, will now be removed from
this information collection.
Nissan agrees with the Agency’s cost/time estimation for this task.
In regards to the additional burden associated with database creation and setup, the Agency states:
Each manufacturer was also required to establish requirements, analysis, and designs for
their new recalls look-up tools. These additional burdens stemmed from: the creation of the VIN
search interface; database setup to host the recall information; data refresh procedures to
populate recall information; server side VIN code lookup and recall status retrieval; integration with
existing manufacturer website; and application testing. We estimated these burdens to total 1,332
hours and $130,005 and these costs will now be removed from this information collection.
Nissan estimates the burden to build and implement the interface would equate to a total threethousand (3,000) hours with an estimated cost of approximately $90,000.

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In regards to the costs associated with database administrator support and application/web server
management, the Agency states:
We estimate that 100 burden hours will be spent on system and database administrator support.
These 100 burden hours include: backup data management and monitoring; database
management, updates, and log management; and data transfer, archiving, quality assurance, and
cleanup procedures. We estimate another 100 burden hours will be incurred on web/application
developer support. These burdens include: operating system and security patch management;
application/web server management; and application server system and log files management.
We estimate these burdens will total 1,800 hours each year (9 MFRs x 200 hours). We estimate
the recurring costs of these burden hours will be $30,000 per manufacturer.
Nissan agrees with the Agency’s estimates.
In regards to the one-time startup costs that manufacturers would assume to provide recall
information to the NHTSA website, the Agency states:
The Agency previously estimated one-time startup costs that manufacturers would
assume in order to meet certain technical access requirements to provide recall information to
NHTSA’s website. We estimated that the total one-time costs to the industry from these technical
access requirements would require 1,914 burden hours (27 MFRs x 72 hours) and total $189,270
(27 MFRs x $7,010) and we are now removing these costs from this information collection.
Nissan agrees with the Agency’s estimates.
In regards to the one-time startup costs manufacturers incurred to create a VIN list for 15 years of
recall information, the Agency states:
The Agency previously estimated one-time startup costs manufacturers incurred to create
a VIN list for 15 years of recall information. We estimated that the total one-time costs to the
industry from this VIN list creation would require 1,620 hours (27 MFRs x 60 hours). We are
now removing these costs from this information collection.
Nissan agrees with the Agency’s estimates.
In regards to updating the VIN status of vehicles remedied under the remedy program, the Agency
states:
Changes to 49 CFR Part 573 in 2013 required 27 manufacturers to update each recalled
vehicle’s repair status no less than every 7 days, for 15 years from the date the VIN is known to
be included in the recall. This ongoing requirement to update the status of a VIN for 15 years
continues to add a recurring burden on top of the one-time burden to implement and operate
these online search tools. We believe it will take no more than 1 hour, and potentially much less
with automated systems, to update the VIN status of vehicles that have been remedied under the
manufacturer’s remedy program.
Nissan agrees with the Agency’s estimates.
In regards to the time it takes to create and submit the quarterly reports, the Agency states:
Our previous estimate of 3,000 quarterly reports received annually is now revised up to an
average of 3,800 reports annually. The quarterly reporting burden now totals 15,200 hours (3,800
quarterly reports x 4 hours/report).
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Nissan estimates that it takes 10 minutes per report to gather the required information. In any give
quarter, Nissan may have up to 30 recalls to report on. We estimate a total of 5 hours per quarterly
report (10 minutes per report x 30 reports), with 4 reports per year. So a total of 20 hours per year
spent on preparing the reports.
Nissan estimates that it takes an additional 1 hour to upload the completion rate information for the
entire quarterly report. This is based on searching for each recall individually and entering the
information one recall at a time. This adds another 4 hours per year to upload the information to the
NHTSA safety portal.
In regards to the burden associated with setting up the online recall portal with pertinent contact
information, the Agency states:
We continue to estimate a small burden of 2 hours annually in order to set up a manufacturer’s
online recalls portal account with the pertinent contact information and maintaining/updating their
account information as needed.
Nissan agrees with the Agency’s estimates.
In regards to the time required to amend a Part 573 report with new information, the Agency states:
We continue to estimate that 20 percent of Part 573 reports will involve a change or addition. At 30
minutes per amended report, this totals 86 burden hours per year (854 recalls x 20 = 171 recalls;
171 / 2 = 86 hours).
Nissan believes that this will vary based on the complexity and size of the recall. Nissan estimates
the Agency’s estimate is a bit conservative and an additional amount of time, with up to one (1) hour
per amended report would be required.
In regards to the amount of time it takes to draft an owner notification letter, the Agency states:
We continue to estimate that it takes manufacturers an average of 8 hours to draft their
notification letters, submit them to NHTSA for review, and then finalize them for mailing to their
affected owners and purchasers.
Nissan agrees with the Agency’s estimates.
In regards to the time it takes to draft an interim owner notification, the Agency states:
We previously calculated that about 25 percent of past recalls did not include an owner
notification mailing within 60 days of the filing of the Part 573 Safety Recall Report. However,
recent trends show that only about 10 percent of recalls require an interim owner notification
mailing. Under the regulation, manufacturers must send two letters in these cases: an interim
notification of the defect or noncompliance within 60 days and a supplemental letter notifying
owners and purchasers of the available remedy. Accordingly, we estimate that 680 burden hours
are associated with this 60-day interim notification requirement (854 recalls x .10 = 85 recalls; 85
recalls times 8 hours per recall = 680 hours).
Nissan agrees with the Agency’s estimates. However, if the interim letter is complex in nature, this
can increase to ten (10) hours.
In regards to the estimate cost for first class mail owner notification, the Agency states:
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As for costs associated with notifying owners and purchasers of recalls, we continue to estimate
this costs $1.50 per first class mail notification, on average. This cost estimate includes
the costs of printing, mailing, as well as the costs vehicle manufacturers may pay to third-party
vendors to acquire the names and addresses of the current registered owners from state and
territory departments of motor vehicles.
Nissan agrees with the Agency’s estimates.

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