GM Roof Crush Documents from Litigation

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Date of Document

Unprotected GM ROOF CRUSH documents admitted into evidence in trials and other key roof crush documents

Admitted into Evidence in Trial

1

This document not currently available

4/19/1966

Letter and attachment
Subject – Design Goals for Safety
To – General Technical Committee
From –  L.C. Lundstrom, Director, Automotive Safety Engineering
Attachment – GM Automotive Safety Test Engineering, , 1969 Design Goals for Safety

Page 1 – The design should prevent the vehicle occupants from being severely injured during the following conditions:   4. During a ground level roll over from an initial speed of 70 mph, or a simulation of this condition

Page 2 – III Glass: Both the windshield and back light shall be so designed that they will be retained in their openings during a 70 mph rollover test

Page 5 – X. Roof Top Strength – The roof structure of the vehicle should be strong enough to withstand a 70 mph

#1103

(Tab 9)

#46 A

Shipler

2

5/16/1966

Inter-Organization Letter
Subject – 1969 GM Safety Design Goals – Body Design – No. 1 Pillar
To – H F Barr, etc
From – L.C. Lundstrom, Director, Automotive Safety Engineering
Attachment – Report No. PG-21773
“Redesign of the upper body structure to keep the No. 1 Pillar forward of the swingline of a belted occupant should be considered”
“Retention of the windshield is advantageous in the event of a rollover due to added roof strength.” “We are presently in trouble with the “A” or Number 1 pillar.”

# 50 A

Shipler

3

12/15/1967

Safety Review Board – December 15, 1967 – Agenda and Meeting Minutes

“Roof Structure integrity – establish need for further improvements from field accident studies”

#57 A

Shipler

4

1/6/1971

National Highway Safety Bureau [Docket No. 2-6; Notice 4] Proposed Motor Vehicle Safety Standard – Roof Intrusion for Passenger Cars

“The purpose of this standard is to reduce deaths and injuries do to the intrusion of the roof into the passenger compartment in rollover accidents

PUBLIC DOCUMENT

5

2/10/1971

GMC Paper
Progress in the Areas of Public Concern

GM Proving Ground, Milford, MI

Page 42 “Many of our engineers working on passive restraints have spent a great deal of time trying to make use of the air cushion to prevent ejection from the car during rollover accidents. Field surveys show that the chief cause if death in a rollover comes from passenger ejection through broken side windows.”

PUBLIC DOCUMENT

6

6A

3/5/1971

3/23/1971

Test date – January 11, 1971 – Product Test Reports No. 111037

SUBJECT: Bodies – Static Roof Intrusion Tests – 1970 and 1971 F, H, A, X, and B styles, FORWARD: The Product Testing Laboratory was asked to conduct static roof intrusion tests in accordance with the proposed roof intrusion requirement (Docket 2-6; notice 4) issued on  December 28, 1970.  The following bodies were tested:

1. 1971 Chevrolet B-47 Production Body
2. 1971 Chevrolet H-11 Pilot Body
3. 1970 Pontiac F-87 Production Body
4. 1971 Chevrolet X-27 Production Body
5. 1970 Oldsmobile B-37 Production Body
6. 1971 Pontiac B-45 Pilot Body

Conclusions: All the bodies tested failed to meet the requirements of the proposed roof intrusion requirements (Docket 2-6; Notice 4) except the X-27 body that passed.

Reported by: D. E. Foley

Test date – March 9, 1971 – Product Test Reports No. 111037 A

SUBJECT: Body – Static Roof Intrusion Tests – 1971 Pontiac A-37 was tested in accordance with the proposed roof intrusion requirement (Docket 2-6; notice 4) issued on  December 28, 1970.

Conclusions: The 1971 Pontiac A-37 production body (without the glass) failed to meet the requirements of the proposed roof intrusion requirements (Docket 2-6; Notice 4) except the X-27 body that passed.

Reported by: D. E. Foley

#1017

Shipler

7

Static Roof Crush Test device – Drawing

UNPROTECTED

8

4/5/1971

Thirty-eight individuals and/or corporations wrote comments to Docket 2-6; Notice 4 on or before the due date of 4/5/1971.  [ANPRM Docket 2-6; Notice 4 (2 pages)].

1. Albert G. Fonda, 2. NMVS Advisory Council, 3. Macerati, SP.A., 4. Insurance Institute for Highway Safety, 5. Alfa Romero, 6. Japan Automobile Manufacturers Association, 7. Checkers  Motors Corp., 8. Citroen, USA, 9. Truck and Body Equipment Association, 10. Ford Motor Co., 11. Automobile Manufacturers Association, 12. Volkswagen of America, 13. Chrysler Corp., 14. Sports Car Club of America, 15. General Motors Corp, 16. Center for Auto Safety, 17. Volvo, inc., 18. Peugeot, Inc., 19. Chrysler UK, 20. American Motors Corp., 21. Renault, Inc. 22. R. A. Carl and G. K. Williams, 23. Memo of Meeting with Ford Motor Co., 24. Alfa Romero, 25. Alpha Romero Reply, 26. Senator J. Javets – William A. Miller, 28. Automotive Club of Southern California, 29. Fiat 30. Stanley J Klein, Engineer Consultant, 31. William A. Miller, 32. Mercedes-Benz of North America, Inc, 33. Triumph Motor Company, Inc., 34. Pininfarina, Torino, Italy, 35. Mercedes-Benz of North America, 36. Report of Marketing with Toyota Motor Company, 37. Porsche. 38. Memo of telecom with Jensen Motors.

PUBLIC DOCUMENT

9

4/5/1971

[Docket 2-6; Notice 4] Comments of Automobile Manufacturers Association, Inc.   on Proposed Motor Vehicle Safety Standard, Roof Intrusion Protection for Passenger Cars

Page 9 – AMA recommended a 12” x 72” test device oriented at 5 degrees horizontally

Page 10 – “Repeat the test on the other front corner of the vehicle” has been crossed out.

COMMENT – AMA objects to this provision on the following grounds: 1. Test and accident survey experience indicates that in most cases roof structures damage is distributed to only one side of the roof in an actual rollover situation. 2. Since the upper car structure is symmetrical, it makes no difference which side of the roof is selected for testing.

PUBLIC DOCUMENT

10

4/5/1971

Letter and Comments of General Motors Corporation on Notice of Proposed Rule Making, Docket 2-6, Notice 4 – Roof Intrusion Protection, Passenger Cars, to Douglas W. Toms from Lowell A. Kintigh, VP, Engineering Staff

Attachment A – Page 3 S6.5 – – “Repeat the test on the other front corner of the vehicle” has been crossed out.

General Motors also recommends that NHTSA change the size of the test device to 30” x 72” and change the horizontal orientation to 5 degrees.

By using a larger test device there is much less force per square inch on the A pillar.

11

12/8/1971

Federal Motor Vehicle Safety Standard No. 216, Roof Crush Resistance

“The purpose of this amendment to part 571 of Title 49, Code of Federal Regulations, is to add a new Motor Vehicle Safety Standard 216, (49 CFR 571.216) that sets minimum strength requirements for a passenger car roof to reduce the likelihood of roof collapse in a rollover accident. A few comments suggested that there is no significant causal relationship between roof deformation and occupant injuries in rollover accidents. However, available data have shown that for non-ejected front seat occupants in rollover accidents, serious injuries are more frequent when the roof collapses. It has been determined, therefore , that improved roof strength will increase occupant protection in rollover accidents.”

“The purpose of this standard is to reduce deaths and injuries due to the crushing of the roof into passenger compartment in rollover accidents.” The resistance of the roof to intrusion is determined by a static test, in which force  1 ½ times the empty weight of the vehicle, or 5000 pounds, whichever is less, is gradually applied to the roof in the vicinity of the “A” pillar. The force is applied by a flat 30” x 72” test device at a 25 degree roll angle (sideways) and a 5 degree pitch angle (forward) to simulate the direction of forces that can be encountered in a rollover. During the test, the roof may show no more than 5 inches of intrusion, as measured by the movement of the test device.  S4. Requirements…. Both the left and right portions of the vehicle’s roof structure shall be capable of meeting the requirements, but a particular vehicle need not meet further requirements after being tested at one location.

PUBLIC DOCUMENT

12

FMVSS 216 Drawing

“The purpose of this standard is to reduce deaths and injuries due to the crushing of the roof into the passenger compartment in rollover accidents”

UNPROTECTED

13

Deposition of KENNETH ORLOWSKI dated November 12, 1996 in the case Wright vs. Mazda.

“And really at that time at Fisher Body, right about ’68 or ’69 was when this, as it exists today, the 216 test method was being developed. Because some of the shortcomings in evaluating vehicle structure with respect to non-repeatability, rollover testing, drop testing, this 216 method was actually developed first at GM and presented to the government and then later adopted by the government as the test method for roof crush resistance.”

Q. You mean the 216 testing device?

A: What ended up being the 216 testing device.

UNPROTECTED

14

TIMELINE – The development of FMVSS 216 – Roof Crush Resistance –   THE CRITICAL YEAR OF 1971

UNPROTECTED

15

11/28/1980

Letter dated 11/28/1980 to E. M. Estes, President, General Motors Corp., from Joan Claybrook, Administrator, NHTSA, US DOT.

PUBLIC DOCUMENT

16

12/15/1980

Letter to Joan Claybrook, Administrator, NHTSA, US DOT, from E. M. Estes, President, General Motors Corp, dated 12/15/1980.

PUBLIC DOCUMENT

17

8/12/1981

ROLLCAGE and ROLL BAR in TEST VEHICLES Occupant Protection System Guide for Proving Ground Test Operation Dated 8/12/87.  2 Pages of document were admitted in Shipler – The cover and Attachment 2, page 9, which says vehicles with a geometric stability of less than 1.10 (such as the S10 Blazer) must 1) Use helmet and Roll Bar when conducting tests such as lane changes at 0-88 kph (55 mph). 2). Use  4-5 point belts, Helmet, Roll Bar and Side Net when conducting tests such as lane changes at 88-100 kph (55-65mph).

#1015

Shipler

18

Deposition of Earl Ray, dated 1/27/1999, and exhibits attached in the case Ford vs. General Motors.

In 1999 Earl Ray was an instructor in the advanced driver’s training course for General Motors at the Proving Grounds and also an investigator of accidents for GM. There have been at least 75 rollover accidents at the GM Proving Grounds

UNPROTECTED

19

9/4/1981

Chevrolet Engineering Final Test Report dated September 4, 1981, Report No.  001-000-082-008 – T, T. W. O. No. 62701-233, Test Date 7/29/1981, Procedure, MVSS 216, 1982 S Truck. Results – 5,384 lbs

# 256

Lambert

20

4/13/1983

Inter-Organization Memo dated 4-13-1983, Subject: C/K Truck Crashworthiness Development, From J. G. Haviland to I. Arums, R. W. Bryant, D. P. Faust, J. P. Lavella, R. K. Levernz, J. Maloney, R A McGinnis, G. Montalvo, R R Nagel, W D Nelson, W. R. Seitz, R. A. Sinke,  and R. Uthe.

“IVARS ARUMS will complete his efforts to recommend tests which could be used to evaluate: a) the amount of window frame deformation required to break tempered side glass; b)the capability of alternative side glazing materials and methods to prevent occupant ejection, and; c) passenger compartment resistance to lateral roof deformation.”

#499A

#689

Shipler

21

9/14/1983

Laboratory Test Outline L 16878, Cab Roof Crush – Rollover Simulation of C10 at 45 degrees dated September 14, 1983. Includes IVARS ARUMS hand written notes: “Three load directions will be imposed on this cab: 1) A-pillar rearward and 45 degrees to horizontal and vertical; 2) B-pillar forward and 45 degrees to horizontal and vertical; 3) Roof Edge Between A & B@ 45 degrees”.

#499

Shipler

22

11/22/1983

Laboratory Test Outline L17279, Cab Roof Crush 0 Rollover Simulation of S10 at 35 degrees dated November 33, 1983.

#120

Shipler

23

11/22/1983

VIDEO of test L17279
Video Unavailable

#121

Shipler

24

OVERLAY of FMVSS 216 Static Roof Crush Tests (25 degrees on the roof) vs. Lateral Roof Crush Test (52 – 55 degrees on the roof). The Lateral roof crush tests were performed by IVARS ARUMS

  UNPROTECTED

25

6/27/1984

Inter-Organization Memo dated 6/27/1984, Subject – Cab Roof Crush – Rollover Simulation, To J. D. Green, Safety and Crashworthiness Systems, S. Millittelo, Truck and Bus, from I Arums, Safety and Crashworthiness Systems. Produce complete memo with Ivars Arums signature page which will include his conclusions of passenger compartment resistance to lateral roof deformation, Figures 1 – 20 (which is the analysis of the data) and Figures 21 -27 (which are photographs showing the general deformation of each cab. IVARS ARUMS conclusions of the Cab Roof Crush – Rollover Simulation (with signature page) and 26 pages of data (which give the results of the tests) are missing.

#130

Shipler

26

Part 1

Part 2

Part 3

Videotaped deposition of IVARS ARUMS dated 5/5/2003 in the case Barker vs. GM.   IVARS ARUMS conclusions of the Cab Roof Crush – Rollover Simulation (with signature page) and 26 pages of data (which give the results of the tests) are missing from his Inter-Organization Memo dated 6/27/1984.

Video Unavailable

UNPROTECTED

27

COMPARISON OF LATERAL ROOF CRUSH TESTS TO 216 TESTS – DRAWING

When a vehicle is tested laterally on the roof the result is 33% than when it is tested at the angle of the 216 test.

UNPROTECTED

28

Deposition of Garry Stuart Bahling dated 6/13/2003 in the case Miragilotta v. American Isuzu Motors, Inc.

Page 152 – 153

Q. Did GM ever do any testing of lateral loads other than those of the 216 standard?
A. Yes.
Q. What were the results?
A. In what regard I’m sorry.
Q. Was there more deformation was there less?
A. I don’t think you can compare the two, they are different tests.
Q. Well was there more deformation though when the lateral loads were different than 216?
A. Well, again
The Witness: I think they are two entirely different tests. The deformation was different, there is no question the deformation is different. I don’t know that you could say.
Q. Were those tests results published?
A. Within General Motors, yes.
Q. Were they published more widely?
A. Not to my knowledge, no.
Q. Do you know why?
A. I can’t imagine why they would want to publish them and in what form you would publish them.

UNPROTECTED

29

10/9/1985 to 10/11/1985

MALIBU 1 SAE Technical Paper dated October 11, 1985, Series #851734 – Rollover Crash Tests  – The Influence of Roof Strength on Injury Mechanics by Kenneth Orlowski and Thomas Bundorf, General Motors, Corp., Edward A. Moffat,  – BioMech, Inc.

MALIBU1 Test 1 4/27/83   MALIBU 1 Test 5   8/10/84

MALIBU1 Test 2 7/21/83   MALIBU 1 Test 6   8/28/84

MALIBU1 Test 3 9/21/83   MALIBU 1 Test 7 10/18/84

MALIBU1 Test 4 8/8/84  MALIBU 1 Test 8  11/6/84

#132

Shipler

30

10/11/1985

Chart from page 192 of MALIBU 1 SAE Technical Paper dated 10/11/1985. Figure 21 – Summary of all neck loads above 2000N

#137 B

Shipler

31

11/18/1985

Memo dated November 18, 1995, Subject, Static Cab Crush Results, To M. O. Ellis, From John W. Moll.

“The cab was held in the crusher at approximately 38 degrees with the horizontal (see figure 1). This angle was consistent with Greens’ tests and was chosen based on analysis of rollover accident damage patterns.”

Note: pages of this memo are IVARS ARUMS data from his lateral roof crush tests on the Ford F-150, Ranger and Toyota Pickup. See Inter-Organization Memo dated 6/27/1984, Subject – Cab Roof Crush – Rollover Simulation written by Arums.

#265

#294

#294A

#295

Lambert

#417

#558

Styles

32

1/28/1987

Memo dated Jan, 28, 1987, Subject – GMT-400 Static Cab Roof Crush Results, To: M. O. Ellis, From John W. Moll.

“The cab was held in the crusher at approximately 38 degrees with the horizontal (see figure 1).   This angle was consistent with Greens’ tests and was chosen based on an analysis of rollover accident damage patterns.” Results of  lateral roof crush tests on PRODUCTION GMT-400, NON PRODUCTION GMT-400, CURRENT C10, FORD F150, FORD RANGER, TOYOTA are shown on graph.

#295

#143

Shipler

33

11/4/1990 to 11/7/1990

MALIBU 2 SAE Technical paper dated 11/04/1990 to 11/07/1990, Series 902314 – Rollover and Drop Tests – The Influence of Roof Strength on Injury Mechanics Using Belted Dummies. By G S Bahling, R. T. Bundorf, and G. S. Kaspzyck, General Motors Corp, E. A. Moffat – Consultant, K. F. Orlowski – Consultant, J. E. Stocke – General Motors Corp 34th Stapp Car Conference, Orlando, FL, November 4 – 7, 2000.

MALIBU2 Test 1 7/787   MALIBU 2 Test 5   10/29/87

MALIBU2 Test 2 7/8/87  MALIBU 2 Test 6   10/30/87

MALIBU2 Test 3 8/4/87  MALIBU 2 Test 7  3/9/89

MALIBU2 Test 4 8/4/87  MALIBU 2 Test 8  4/25/89

#153

Shipler

34

BAR graph which shows the difference between GM’s interpretation of MALIBU II (which validates their position that roof strength is not causally related to serious injuries) and the true interpretation of data in MALIBU II (which shows that roof strength IS causally related to serious injury)

35

1985 & 1990

MALIBU CONFIDENTIAL DOCUMENT – GM MALIBU 1, TEST 5 (All data from GM discovery

# 225C (301)

Shipler

36

1985 & 1990

MALIBU CONFIDENTIAL DOCUMENT 2 photos

# 693

Shipler

37

1985 & 1990

MALIBU CONFIDENTIAL DOCUMENT 2 photos

# 694

Shipler

38

1985 & 1990

MALIBU CONFIDENTIAL DOCUMENT Photo showing the crushing of the roof.

# 1006

Shipler

39

1985 & 1990

MALIBU CONFIDENTIAL DOCUMENT – Blow up of CHART from page 192 of MALIBU 1 SAE Technical Paper dated 10/11/85. Figure 21. Summary of all neck loads above 2000N. Same as Shipler Exhibit #137B

#1010

Shipler

40

1985 & 1990

MALIBU CONFIDENTIAL DOCUMENT – Belted Rollover Tests, Axial Neck load Analysis – Roll Cage vs. Production Roof.

#1011

Shipler

41

1985 & 1990

MALIBU CONFIDENTIAL DOCUMENT – MALIBU 2 – Trailing  Edge Neck Loads –  Neck Injury Criterion – Production vehicles vs. Vehicles with Roll Cages

#1013

Shipler

42

1985 & 1990

MALIBU CONFIDENTIAL DOCUMENT – Drawing of Vehicle rolling over.

#225C (300)

Shipler

43

8/4/1987

CLIP OF MALIBU VIDEO – MALIBU 2 SP870804, test 3, B-pillar movement marked.
Video Unavailable

#225C (302)

Shipler

44

8/10/1984

CLIP OF MALIBU VIDEO – MALIBU 1 Test 5 cg track
Video Unavailable

#265

Shipler

45

4/27/1983

CLIP OF MALIBU VIDEO – Catastrophic Injury in Non Belted MALIBU, 1, 1L3
Video Unavailable

#265

Shipler

46

8/8/1984

CLIP OF MALIBU VIDEO – Catastrophic Injury in Non Belted MALIBU 1, 4L4
Video Unavailable

#265

Shipler

47

8/4/1987

CLIP OF MALIBU VIDEO – MALIBU 2, 3L2
Video Unavailable

#265

Shipler

48

8/4/1987

CLIP OF MALIBU VIDEO – MALIBU 2, 3L3
Video Unavailable

#265

Shipler

49

3/9/1989

CLIP OF MALIBU VIDEO – MALIBU 2, 7L4
Video Unavailable

#265

Shipler

50

3/9/1989

CLIP OF MALIBU VIDEO – MALIBU 2, Test 7, SP890039 – Raw Footage, Standard Belted Dolly Rollover
Video Unavailable

#282

Shipler

51

3/9/1989

CLIP OF MALIBU VIDEO – SP82028A MALIBU 2, Rollcage Drop Test

#282

Shipler

52

CLIP OF MALIBU VIDEO – MALIBU 2 Movies, Diadem
Video Unavailable

#691

Shipler

53

2/21/2002

CLIP OF MALIBU VIDEO – EXPONENT/Failure Analysis, TEC7124 PH07124, Dolly Rollover test, 1987 Chevrolet S10 Blazer with Roll cage, Speed +50.3 mph, February 21, 2002
Video Unavailable

#695

Shipler

54

CLIP OF MALIBU VIDEO – SP88028A MALIBU DROP TEST  w/ Arrow
Video Unavailable

#1002

Shipler

55

CLIP OF MALIBU VIDEO – Reinforced MALIBU  drop test with Human Occupant
Video Unavailable

#1002

Shipler

56

Malibu 2 confidential data – ANALYSIS OF POTENTIALLY INJURIOUS IMPACT 2L1

#1138

Shipler

57

Trial testimony of Garry Bahling (one of the authors of Malibu 2) dated September 16, 2003 in Shipler vs. GM. Trial attorney Michael Piuze cross examined GM’s chief liability witness BAHLING during the Shipler   trial. When confronted with documents over 20 yrs old, he was forced to admit that widely published conclusions (MALIBU 2), which have been the basis for GM’s defense in roof crush cases, were contradicted by GM’s own test documents.  See Shipler exhibit #1138 above.

UNPROTECTED

58

12/90

Product Evaluation and Development Engineering Evaluation Report dated December 1990, T. W. O. No. 6XC02 – 04, Evaluation dates 2/15/90 – 5/30/90, Procedure – FMVSS 216.

1992 S/T Regular Cab   Results – 5,614 lbs   Results with No GLASS – 3,600 lbs
1992 S/ T Extended Cab  Results – 5,950lbs
1992 S/T 2Door Utility      Results – 6,150 lbs

FMVSS 216 test on GM vehicles without windshield reveals 36% less roof strength and would never meet the standard FMVSS 216. General Motors is counting on the windshield to hold up the roof.   Where is the roof strength when the windshield breaks during a rollover and continues to roll?

#154

#258

Shipler

59

ROOF STRENGTH of vehicle without glass and tested at 55 degrees on the roof (the angle that the vehicle really contacts the ground in a rollover)

60

Reconstruction of a Rollover Collision, by K. R. Orlowski and E. A. Moffat – Safety Analysis, Inc, and R. T. Bundorf and M. P. Holcomb – Current Product Engineering, General Motors Corporation.

# 588

Shipler