NHTSA Administrator Mark Rosekind pledged the agency would achieve a 100% completion rate for recalls in the U.S.

The fairly new head of the National Highway Traffic Safety Administration, Dr. Mark Rosekind, a veteran of the highly regarded National Transportation Safety Board, announced that NHTSA will seek 100% completion of safety recalls in the U.S.

This comes in the wake of a record 51 million vehicles recalled for safety fixes in 2015 (40% of them related to Takata air bags) and an increase in highway fatalities last year after several progressive years of declining crash deaths, both statistics generating headlines in the media.

Of course, Congress, and NHTSA are feeling the heat in Washington from media and professional safety critics. And NHTSA – the only agency ordained to do something about it – is wringing its hands.

To the extent that the vast number of safety recalls have much to do with actual highway crash deaths, this is indeed a legitimate path to follow, because only about 80% of safety-recalled vehicles actually get fixed, and Rosekind appears to think closing the gap can be accomplished.

(Legislation, not technology, key obstacle to autonomous driving. For more, Click Here.)

It’s not quite that easy, though, according to recent studies released by the Society of Automotive Analysts (SAA) in Detroit. Recall numbers are generated by the automakers, who in North America must rely on registered-owner data generated by 50 US. states plus D.C. and the Canadian provinces.

Among the problems thus created is first, that there is no registry of identification numbers (VINs) for vehicles that have been scrapped. This especially applies to older vehicles which simply “age out” because the cost of repairs – including those due to crash damage – or tire and/or battery replacements exceed the economic value of the vehicle or the ability of impoverished owners to pay.

Then there is the simple human problem of owners of any vehicles beyond new-car-warranty limits, generally three years, who fear that taking their car into a new-car dealership in response to a recall notice for a free fix may subject them to costs for additional repairs urged by aggressive service department personnel, or worse yet, the wiles of new vehicle sales folks in the front of the establishment.

As to the affected cars in the hands of “independent dealers” (usually of used cars), there is no universal, reliable list of such businesses – and, so far, any incentive other than good citizenship for them to respond.

Now, some foreign countries bar periodic re-registration or re-licensing of vehicles that haven’t had their recalls completed. In America that would require new, hard-to-achieve legislation by each of the states. It would not be hard to imagine the public pushback against such even-well-intended laws, and thus politicians’ reluctance to embrace them.

In the realm of carrot-and-stick persuasion, another possible way to “stick” slow-to-respond-to-recalls owners and satisfy Rosekind, could be state legislation specifying owner liability for damages incurred because a recall was not completed. Such laws sometimes are referred to as “lawyer full employment legislation.”

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So, automakers, according to SAA, are looking for easier ways to improve recall-completion numbers, in response to Rosekind’s directive. According to NHTSA regulations, automakers have only five business days after determining there is a safety issue, to notify the agency of the details of a forthcoming recall action, in what is known as a 573 letter. The recall notice to vehicle owners comes in what is called a 577 letter. (Both numbers refer to the governing regulation.)

So some new thinking is going into the wording in these letters, especially the 577 to owners. Is the safety issue too overstated, maybe creating disbelief? Is the letter too long, say, more than one page? Are some words more effective than others in persuading skeptical owners to respond, for instance, “apology” or, alternatively, “regret.” Again we’re talking about those hard-to-reach vehicles three to five years old or older than five.

Remember, many older vehicles may not even exist any longer or be hard to trace:  the recall notice, based on registration, may come back to the auto company marked by the post office “undeliverable” or, in Elvis Presley’s words, “no such number.”

Among the dilemmas facing automakers and their suppliers from the beginning of government recall regulations is the “five-day” notification rule. The problem always has been availability at dealerships of parts needed for completion of the recall.

In the case of much older vehicles, such parts may no longer be in production by supplier factories and could even require new tooling and testing. Thus, responsible customers taking their vehicles to dealerships could become discouraged by delays, and the fix might never be made.

In a perfect world, of course, automotive safety recalls would never again be required, though it was speculated at SAA that the increased inclusion of computer-controlled devices in theory will only increase the likelihood of data-crash highway crashes. The example cited was the recently reported experimental hacking of a Jeep Cherokee’s computer-controlled automatic transmission while the vehicle was underway.

(Nissan and Renault set to launch 10 autonomous vehicles by 2020. For more, Click Here.)

One way or another, recalls aren’t going away.