2024-21509. Agency Information Collection Activities; Notice and Request for Comment; Reporting of Information and Documents About Potential Defects

Table 1—Burden Estimate for § 579.5 Submissions

Average annual § 579.5 submissions	Estimated burden per submission (minutes)	Average hourly labor cost	Labor cost per submission	Total burden hours	Total labor costs
17,615	5	$53.44	$4.45	1,468	$78,386.75 or $78,387.

Requirements Under Part 579, Subpart B (Foreign Reporting)

The second component of this information collection request covers the requirements found in part 579 subpart B, “Reporting of Safety Recalls and Other Safety Campaigns in Foreign Countries.” Pursuant to § 579.11, whenever a manufacturer determines to conduct a safety recall or other safety campaign in a foreign country, or whenever a foreign government has determined that a safety recall or other safety campaign must be conducted, covering a motor vehicle, item of motor vehicle equipment, or tire that is identical or substantially similar to a vehicle, item of equipment, or tire sold or offered for sale in the United States, the manufacturer must report to NHTSA not later than 5 working days after the manufacturer makes such determination or receives written notification of the foreign government's determination. Section 579.11(e) also requires each manufacturer of motor vehicles to submit, not later than November 1 of each year, a document that identifies foreign products and their domestic counterparts.

To provide the information required for foreign safety campaigns, manufacturers must (1) determine whether vehicles or equipment that are covered by a foreign safety recall or other safety campaign are identical or substantially similar to vehicles or equipment sold in the United States, (2) prepare and submit reports of these campaigns to the agency, and (3) where a determination or notice has been made in a language other than English, translate the determination or notice into English before transmitting it to the agency.

NHTSA estimates that there is no burden associated with determining whether an individual safety recall covers a foreign motor vehicle or item of motor vehicle equipment that is identical or substantially similar to those sold in the United States because manufacturers can simply consult the list that they are required to submit each year. Therefore, the only burden associated with determining whether a foreign safety recall or other safety campaign is required to be reported to NHTSA is the burden associated with creating the annual list. NHTSA continues to estimate that it takes approximately 9 hours per manufacturer to develop and submit the list. The 9 hours are comprised of 8 attorney hours and 1 hour for IT work. NHTSA receives these lists from 99 manufacturers, on average, resulting in 891 burden hours (99 vehicle manufacturers × 8 hours for attorney support = 792 hours) + (99 vehicle manufacturers × 1 hour for IT support = 99 hours).

NHTSA estimates that preparing and submitting each foreign defect report (foreign recall campaign) requires 1 hour of clerical staff and that translation of determinations into English requires 2 hours of technical staff (note: This assumes that all foreign campaign reports require translation, which is unlikely). Between 2021 and 2023 NHTSA received a yearly average of 262 foreign campaign reports. NHTSA estimates that in each of the next three years, NHTSA will receive, on average, 262 foreign recall reports. NHTSA estimates that each report will take 3 hours (1 hour to prepare by a clerical employee and 2 hours for translation). Therefore, NHTSA estimates that the burden hours associated with submitting these reports will be 786 hours (3 hours per report × 262 reports).

Therefore, NHTSA estimates the total annual burden hours for reporting foreign campaigns and substantially similar vehicles is 1,677 hours (891 hours for submitting annual lists + 786 hours for submitting foreign recall and safety campaign reports). This is an increase of 87 burden hours from our previous estimate (1,677 hours for the current estimate—1,590 hours for the previous estimate). Table 2 provides a summary of the estimated burden hours for Part 579 Subpart B submissions. ( print page 77231)

Table 2—Burden Hour Estimates for Foreign Reporting

Submission type	Annual number of submissions	Burden hours per report	Total burden hours
Foreign Campaign Report	262	1 hour clerical + 2 hours translation = 3 hours	786
Annual List	99	8 hours attorney + 1 hour IT = 9 hours	891
Total			1,677

To calculate the labor cost associated with Part 579 foreign reporting submissions, NHTSA looked at wage estimates for the type of personnel submitting the documents. As stated above, NHTSA estimates that submitting annual lists under § 579.11(e) will involve 8 hours of attorney time and 1 hour of IT work. The average hourly wage for Lawyers (BLS Occupation code 23-1000) in the Motor Vehicle Manufacturing Industry is $112.21.^[3] After applying the 70.4 percent ECEC adjustment, NHTSA estimates the hourly labor costs for manufacturers to be $159.39 for Lawyers. The ECEC adjusted hourly cost for Computer Support Specialists (BLS Occupation code 15-1230) in the Motor Vehicle Manufacturing Industry is $53.44 as reviewed in the discussion of Table 1 data in the Subpart A reporting burden analysis. NHTSA estimates the incremental labor cost associated with submitting each annual list to be $1,328.56 or $1,329 ($159.39 per hour × 8 attorney hours + $53.44 per hour × 1 IT hour), resulting in an estimated annual labor cost of $131,527 for submitting all 99 annual lists each year.

NHTSA estimates that submitting each foreign recall or safety campaign report involves 1 hour of clerical work and 2 hours of translation work. The average hourly wage for Office Clerks (BLS Occupation code 43-9061) in the Motor Vehicle Manufacturing Industry is $26.65 ^[4] and the average hourly wage for Interpreters and Translators (BLS Occupation code 27-3091) is $30.33.^[5] Therefore, NHTSA estimates the ECEC adjusted hourly labor costs to be $37.86 for Office Clerks and $43.08 for Interpreters and Translators. NHTSA estimates the total labor cost associated with submitting one foreign recall or safety campaign report to be $124.02 or $124 ($37.86 per hour × 1 Clerical hour + $43.08 per hour × 2 Translator hours) and $32,493.24 or $32,493 for all 262 foreign recall or safety campaign reports NHTSA estimates will be submitted annually.

Table 3 provides a summary of the labor costs associated with the foreign reporting requirements in part 579, subpart B. NHTSA estimates that the total labor costs associated with the annual list requirement and the requirement to report foreign recalls and safety campaigns is $164,020.68 or $164,021 ($131,527.44 + $32,493.24).

Table 3—Annual Labor Cost Estimates for Foreign Reporting

Submission type and labor category	Hours per submission	Hourly labor cost	Labor cost per submission	Number of submissions	Total labor cost
Annual List-Lawyer	8	$159.39	$1,275.12	99	$126,236.88
Annual List-Computer Specialist	1	53.44	53.44	99	5,290.56
Totals for Annual List	9		1,328.56		131,527.44
Foreign Campaign Report-Clerical	1	37.86	37.86	262	9,919.32
Foreign Campaign Report-Translator	2	43.08	86.16	262	22,573.92
Totals for Foreign Campaign Report	3		124.02		32,493.24
Total Labor Costs for Part 579 Subpart B Requirements					164,020.68 or 164,021

Requirements Under Part 579, Subpart C, Reporting of Early Warning Information

The third component of this information collection covers the requirements found in part 579 subpart C, “Reporting of Early Warning Information.” Besides production information, there are five major categories requiring reporting of incidents or claims in Subpart C, with the specific requirements and applicability of those categories varying by vehicle and equipment type and, in some circumstances, manufacturer volume. Sections 579.21-27 require manufacturers to submit the following:

(1) Production information; (2) reports on incidents involving death or injury in the United States that are identified in claims or notices alleging that the death or injury was caused by a possible defect; (3) reports on incidents identified in a claim against a manufacturer that involve one or more deaths in a foreign country and involve ( print page 77232) a vehicle or item of equipment that is identical or substantially similar to a vehicle or item of equipment that is offered for sale in the United States; (4) separate reports on the number of property damage claims, consumer complaints, warranty claims, and field reports that involve a specified system or event; (5) copies of field reports; and, for manufacturers of tires, (6) a list of common green tires (applicable to only tire manufacturers). Section 579.28(l) allows NHTSA to request additional information to help identify a defect related to motor vehicle safety. The regulation specifies the time frame for reporting for each category. Foreign recalls of substantially similar vehicles and manufacturer communications are required to be submitted monthly, substantially similar vehicle listings are required annually, and all other report types are required to be submitted every quarter.

Quarterly Reporting

Manufacturers are required to report specific information to NHTSA every quarter. Manufacturers are required to submit production information,^[6] non-dealer field reports, aggregate submissions, and death and injury submissions every quarter. Estimates of the burden hours and reporting costs are based on:

• The number of manufacturers reporting;
• The frequency of required reports;
• The number of hours required per report; and
• The cost of personnel to report.

The number of hours for reporting ranges from 1 hour for trailer, child restraint, low volume vehicle, and equipment manufacturers to 8 hours for light vehicle manufacturers (Table 4). Quarterly reporting burden hours are calculated by multiplying hours used to report for a given category by the number of manufacturers for the category and by the four times per year quarterly reporting. Using these methods and the average number of manufacturers who report annually, we estimate the annual burden hours for quarterly reporting of production information at 4,176 hours as detailed below in Table 4.

NHTSA assumes that the hourly wage rate for each quarterly report is split evenly between technical and clerical personnel and a weighted hourly rate is developed from this assumption. Therefore, using the BLS total hourly compensation rates discussed above of $53.44 for a Computer Support Specialist and $37.86 for an Office Clerk, the weighted hourly rate is $45.65 (Technical Mean Hourly Wage of $53.44 × 0.5 + Clerical Mean Hourly Wage of $37.86 × 0.5). The estimated reporting costs are calculated as follows:

(M × T_p × $45.65) = Quarterly cost of reporting × 4 = Annual cost of reporting *

* M = Manufacturers reporting data in the category; T_p = Reporting time for the category; $45.65 = Reporting labor cost compensation rate; 4 = Quarterly reports per year

For example, the estimated reporting cost for light vehicles is $59,892.80 (41 manufacturers × 8 hours × $45.65 compensation rate × 4 quarters), and the total annual labor costs associated with quarterly reporting are estimated to be $190,634. Table 4 includes the estimated burden hours and reporting costs for production information, non-dealer field reports, aggregate submissions, and death and injury submissions, as well as the quarterly and annual labor costs associated with reporting.

Table 4—Estimated Manufacturer Annual Burden Hours and Labor Costs for Quarterly Reporting

Vehicle/equipment category	Average number of manufacturers	Quarterly hours to report per manufacturer	Blended hourly comp. rate	Quarterly labor costs per manufacturer	Annual burden hours for reporting	Annual labor costs
Light Vehicles	41	8	$45.65	$365.20	1,312	$59,892.80
Medium-Heavy Vehicles	41	5	45.65	228.25	820	37,433.00
Buses	30	5	45.65	228.25	600	27,390.00
Emergency Vehicles	9	5	45.65	228.25	180	8,217.00
Motorcycles	16	2	45.65	91.30	128	5,843.20
Trailers	91	1	45.65	45.65	364	16,616.60
Child Restraints	35	1	45.65	45.65	140	6,391.00
Tires	31	5	45.65	228.25	620	28,303.00
Low Volume & Equipment 7	3	1	45.65	45.65	12	1,095.60
Totals	297				4,176	190,634.40 or 190,634

Early Warning Reporting Field Data Submissions

Table 5 provides an average annual submission count for each category submitted per the requirements of 49 CFR part 579, subpart C: reports on incidents identified in claims or notices involving death or injury in the United States; reports on incidents involving one or more deaths in a foreign country identified in claims involving a vehicle or item of equipment that is identical or substantially similar to a vehicle or item of equipment that is offered for sale in the United States; separate reports on the number of property damage claims, consumer complaints, warranty claims, and field reports that involve a specified system or event; copies of field reports; and, for manufacturers of tires; a list of common green tires; and additional follow-up information per 579.28(l) related to injury and fatality claims. Each reporting category has specific requirements and types of reports that need to be submitted and we state “N/A” where there is no requirement for that reporting category.

( print page 77233)

Table 5—Annual Average of EWR Submissions by Manufacturers

[2021-2023]

Category of claims	Light vehicles § 579.21	Bus, emergency, heavy, & medium vehicles § 579.22	Motorcycles § 579.23	Trailers § 579.24	Child restraints § 579.25	Tires § 579.26	Low volume vehicles & equipment § 579.27	Totals
Incidents Involving Injury or Fatality in U.S	6,338	223	109	44	133	35	11	6,893
Incidents Involving Fatality in Foreign Country	38	0	2	1	0	0	0	41
Reports on Number of Claims Involving Specific System or Event	7,985	831	23	55	NA	298	NA	9,192
Mfr. Field Reports	83,360	18,650	1,456	81	2,859	NA	NA	106,406
Common Green Tire Reporting	NA	NA	NA	NA	NA	99	NA	99
Average Number of Follow-Up Sequences per 579.28(l)	1,425	91	67	14	64	44	13	1,718
Totals	99,146	19.795	1,657	195	3,056	476	24	124,349

The submission totals summarized in Table 5 represent a 10 percent increase from the currently approved information collection with two reporting categories responsible for all of the increase. Submission totals increased for manufacturer field reports and follow-up sequence inquiries conducted per § 579.28(l) but saw a net decrease of 34 percent for the other four categories combined. Average annual injury and fatality claims in the United States dropped from 11,887 to 6,893 claims per year, a 42 percent decrease; foreign death claims dropped from 330 to 41 per year, an 88 percent decrease; claims involving specific systems or events dropped from 12,212 to 9,192, a 25 percent decrease; and common green tire reports dropped from 112 to 99 per year, a 12 percent decrease. Manufacturer field reports, which accounted for the majority of submissions in both the current and prior approved information collection requests, rose from 88,409 to 106,406 per year, a 20 percent increase.^[8] Death and injury follow-up sequence inquiries conducted per § 579.28(l) saw a much larger change, rising from 190 to 1,718 average incident inquiries per year, an increase of 804 percent. The net effect of these changes was an increase from 113,140 to 124,349 submissions per year on average.

The agency estimates that an average of 5 minutes is required for a manufacturer to process each report, except for foreign death claims and follow-up responses. We estimate foreign death claims and follow-up responses per § 579.28(l) require an average of 15 minutes to process. Multiplying the total average number of minutes by the number of submissions NHTSA receives in each reporting category yields the burden hour estimates found below in Table 6. Our previous estimates of EWR associated submission burden hours totaled 9,515 hours, and we now update that total to 10,655 burden hours, a 12 percent increase, associated with the above noted claim categories.

Table 6—Annual Manufacturer Burden Hour Estimates for EWR Submissions

Category of claims	Annual average of EWR submissions	Average time to process each report	Estimated annual burden hours
Incidents Involving Injury or Fatality in U.S	6,893	5	574
Incidents Involving Fatality in Foreign Country	41	15	10
Reports on Number of Claims Involving Specific System or Event	9,192	5	766
Mfr. Field Reports	106,406	5	8,867
Common Green Tire Reporting	99	5	8
Average Number of Follow-Up Sequences per 579.28(l)	1,718	15	430
Totals	124,349		10,655

We have also calculated hourly labor costs for each claim type with an incremental reporting burden based on time to process and labor costs for employee positions required for processing each submission. Table 7 shows the employee positions required for processing submissions for each claim type, the time required for each position to process each submission, and the weighted hourly rates for each claim type. The employee positions analyzed in Table 7 include three that have been introduced in prior sections of this information collection request: Lawyers (BLS Occupation code 23-1000), Computer Support Specialists (BLS Occupation code 15-1230), and Office Clerks (BLS Occupation code 43-9061).^[9] Cost analysis for Computer Support Specialists was provided in the discussion of Table 1 data for Subpart A labor costs analysis and analyses for Lawyers and Office Clerks were provided in the discussion of Table 3 data for Subpart B labor cost burden analysis. Labor cost analysis for ( print page 77234) Engineers (BLS Occupation code 17-2000) is introduced in Table 7. The average hourly wage for Engineers in the Motor Vehicle Manufacturing Industry is $52.56.^[10] After applying the 70.4 percent ECEC adjustment, NHTSA estimates the hourly labor costs for manufacturers to be $74.66 for Engineers. Table 7 shows the weighted hourly rates for each submission claim type.

Table 7—Estimated Manufacturer Time Allocation by Claim Type and Weighted Hourly Rate

Claim type	Estimated time (in minutes) to review a claim					Weighted hourly rate
	Lawyer (rate: $159.39)	Engineer (rate: $74.66)	Technical (rate: $53.44)	Clerical (rate: $37.86)	Total time
Incidents Involving Injury or Fatality in U.S	3	0	0	2	5	$110.78
Incidents Involving Fatality in Foreign Country	3	10	0	2	15	86.70
Reports on Number of Claims Involving Specific System or Event	0	0	3	2	5	47.21
Mfr. Field Reports	0	0	3	2	5	47.21
Common Green Tire Reporting	0	0	0	5	5	37.86
Average Number of Follow-Up Sequences per 579.28(l)	3	10	0	2	15	86.70

These rates are calculated by summing the weighted employer costs for each employee position required to review each submission claim type using the formula:

The annual labor costs for submissions of claims data are shown in Table 8. Labor Cost per Submission is the product of the Average Time to Process Each Report and the Weight Hourly Rate calculated in Table 7. Annual labor cost is the product of the labor cost per submission and the average annual submissions.

Table 8—Estimated EWR Annual Labor Costs by Category

Category of claims	Annual average of EWR submissions	Average time to process each report	Weighted hourly rate	Estimated labor cost per submission	Estimated annual labor cost
Incidents Involving Injury or Fatality in U.S	6,893	5	$110.78	$9.23	$63,633.88
Incidents Involving Fatality in Foreign Country	41	15	86.70	21.68	888.68
Reports on Number of Claims Involving Specific System or Event	9,192	5	47.21	3.93	36,162.86
Mfr. Field Reports	106,406	5	47.21	3.93	418,618.94
Common Green Tire Reporting	99	5	37.86	3.16	312.35
Average Number of Follow-Up Sequences per 579.28(l)	1,718	15	86.70	21.68	37,237.65
Totals	124,349				556,854.35 or 556,854

The total annual manufacturer burden hours for subpart C reporting of EWR data (Sections 579.21-28) is calculated by summing the burden hour estimates for quarterly reporting in Table 4 (4,176 hours) and submission reporting in Table 6 (10,655 hours). This produces an EWR annual burden hour estimate of 14,831 hours. The total annual labor cost for subpart C reporting is calculated by summing the labor cost estimates in Table 4 ($190,634.40) and Table 8 ($556,854.35), producing a total annual labor cost estimate for Subpart C reporting of $747,488.75 or $747,489.

Computer Maintenance Burden

In addition to the burden associated with submitting documents under each subpart of Part 579, NHTSA also estimates that manufacturers will incur computer maintenance burden hours associated with the information collection requirements. The estimated manufacturer burden hours associated with aggregate data submissions for consumer complaints, warranty claims, and dealer field reports are included in reporting and computer maintenance hours. The burden hours for computer maintenance are calculated by multiplying the hours of computer use (for a given category) by the number of manufacturers reporting in a category. NHTSA estimates that light vehicle manufacturers will spend approximately 347 hours per year on computer maintenance and that other vehicle manufacturers will spend about 22 percent as much time as light vehicle manufacturers on computer ( print page 77235) maintenance. Therefore, NHTSA estimates that medium-heavy truck, trailer, motorcycle manufacturers, emergency vehicle, and bus manufacturers will each spend approximately 86.5 hours on computer maintenance each year. NHTSA estimates that tire manufacturers and child restraint manufacturers will also spend 86.5 hours on computer maintenance per year. Therefore, NHTSA estimates the total burden for computer maintenance to be 36,112 hours per year (based on there being an estimated 41 light vehicle manufacturers, 41 medium-heavy vehicle manufacturers, 91 trailer manufacturers, 16 motorcycle manufacturers, 9 emergency vehicle manufacturers, 30 bus manufacturers, 31 tire manufacturers, and 35 child restraint manufactures).

To calculate the labor cost associated with computer maintenance hours, NHTSA looked at wage estimates for the type of personnel submitting the documents. The ECEC adjusted average hourly wage for Computer Support Specialists (BLS Occupation code 15-1230) in the Motor Vehicle Manufacturing Industry is $53.44 as reviewed in the discussion of Table 1 data in the Subpart A reporting burden analysis. For the estimated total of 36,112 annual computer maintenance burden hours, NHTSA estimates the associated labor costs will be approximately $1,929,799. Table 9 shows the annual estimated burden hours for computer maintenance by vehicle/equipment category and the estimated labor costs associated with those burden hours.

Table 9—Estimated Manufacturer Annual Burden Hours for Computer Maintenance for Reporting

Vehicle/equipment category	Average number of manufacturers	Hours for computer maintenance per manufacturer	Average hourly labor cost	Annual labor cost per manufacturer	Total annual burden hours	Total annual labor costs
Light vehicles	41	347	$53.44	$18,543.68	14,227	$760,290.88
Medium-Heavy Vehicles	41	86.5	53.44	4,622.56	3,547	189,524.96
Buses	30	86.5	53.44	4,622.56	2,595	138,676.80
Emergency Vehicles	9	86.5	53.44	4,622.56	779	41,603.04
Motorcycles	16	86.5	53.44	4,622.56	1,384	73,960.96
Trailers	91	86.5	53.44	4,622.56	7,872	420,652.96
Child Restraints	35	86.5	53.44	4,622.56	3,028	161,789.60
Tires	31	86.5	53.44	4,622.56	2,682	143,299.36
Totals					36,112	$1,929,798.56 or $1,929,799

Based on the foregoing, we estimate the burden hours for industry to comply with the current part 579 reporting requirements (EWR requirements, foreign campaign requirements and part 579.5 requirements) to be 54,088 hours per year. The total annual burden hours, labor costs, and changes from for this information collection consisting of manufacturer communications under section 579.5 (subpart A), foreign reporting (subpart B), EWR submissions and reporting (subpart C), and computer maintenance are outlined in Table 10 below.

Table 10—Total Manufacturer Burden Hours and Labor Costs

Reporting type	Currently approved part 579 information collection request		Pending part 579 information collection request		Changes in burden hours and labor costs
	Annual burden hours	Annual labor costs	Annual burden hours	Annual labor costs	Annual burden hours	Annual labor costs
Subpart A: Manufacturer Communications § 579.5 (Table 1)	2,074	$92,817	1,468	$78,387	* (606)	* ($14,430)
Subpart B: Foreign Reporting (Tables 2 & 3)	1,590	139,464	1,677	164,021	87	24,557
Subpart C: EWR Submissions and Quarterly Reporting (Tables 4 & 6/8)	14,731	621,260	14,831	747,489	100	126,229
Computer Maintenance (Table 9)	35,415	1,585,861	36,112	1,929,799	697	343,938
Total	53,810	2,439,402	54,088	2,919,696	278	480,294
* Reduction from currently approved ICR.