Introduction
There are 1.6 million rental vehicles, including car-sharing in service in the United States. Our industry has a long history of providing safe vehicles for our customers. Nowhere is this more apparant than in our timely and comprehensive procedures for dealing with recalls. Our commitment to safety has led our members to adopt far more conservative standards for recalls than what the law requires or what is recommended by the auto manufacturers, as overseen by the National Highway Traffic Safety Administration (NHTSA). Current data confirm that the manner in which our industry handles recall notices is working well. The reality is, the rental car industry addresses the repair of recalled vehicles at a rate demonstrably superior to any other class of vehicle owner.
Current Industry Practices
Prompted by the unprecedented Toyota recalls of early 2010 affecting tens of thousands of rental vehicles, the industry, through ACRA, publically stated its strict adherence to the following practices:
- When we receive a recall notice from a manufacturer, we will not re-rent that vehicle until all repairs are completed. If a member makes an exception, it would only be when they are satisfied that the vehicle is safe to operate under the circumstances presented by the particular recall and based on information and direction provided by the manufacturer. In all cases our policy is to have the recommended work done as quickly as possible.
- Further, when manufacturers direct that a recalled vehicle not be driven because of the severity of the safety issue, we stop renting such models and immediately contact customers already in those vehicles to provide them a replacement as quickly as possible.
- All decisions the car rental industry makes concerning the “roadworthiness” of any vehicle are based upon information and direction provided by the auto manufacturers. Our processes have continuously evolved to improve the timeliness of recall repairs, and consequently, an overwhelming percentage of vehicles are now repaired and returned to service within the first month.
The question of regulation
The public debate regarding the need for regulation of our industry stems from two issues:
- Almost seven years ago, two California sisters died in a terrible and tragic crash involving a rented PT Cruiser, which was subject to an open recall notice. The rental company accepted responsibility for the accident, and today that 2004 PT Cruiser would not be rented until it was repaired.
- Data recently obtained from the auto manufacturers and posted by NHTSA have painted an incomplete and outdated picture about our industry’s performance regarding recall repairs. The information contained old, inaccurate (as acknowledged by the manufacturers) and irrelevant data rather than the industry’s current repair rates.
Proponents of regulating the rental car industry’s management of safety recalls cite a need to “close a rental car loophole.” In fact, there is no such loophole. Rental car companies are not treated differently under the law vs. all other vehicle owners and fleet operators. What is different, is the industry’s focus on safety which has resulted in billions of rentals over 10’s of billion of miles since 2004 without a single recall related incident.
Still, we stand ready to work with any government agency or legislative body to achieve improved recall completion rates for all vehicles on the roadways. We believe transparency and accurate information is the key to an effective process. For this reason we have made internal data available to regulators and legislators, and have committed in every forum of debate to support legislation which would mandate our ongoing reporting of recall completion data to NHTSA, who has the expertise to evaluate such data to determine whether the need exists for further regulation.