Jennifer Timian on Improving NHTSA Recall Completion Rates

Rick and Neal interview Jennifer Timian on ways that companies can improve recall management and recall effectiveness rates.  Jennifer spent 9 years as Chief of Recall Management Division at NHTSA and 4 years as the Director of Office of Compliance and Regulatory Enforcement at CPSC.

Transcript

Jennifer Timian Podcast Transcript

Rick Brenner: [00:00:01] I'm Rick Brenner, and I'm here with my colleague, product safety attorney Neil Cohen, to present another episode in our podcast series on product recalls, how to avoid them through quality management, how to be prepared if your company should need to initiate a recall. And today's topic, how to improve recall effectiveness, finding the owners of defective products and in sending them to stop using the product, get it repaired or replaced or refunded, or whatever the applicable remedy. All too often we hear of injuries or deaths from defective products that were recalled but still in use, either because the owner didn't know the product was recalled or didn't follow through for some reason. We're extremely fortunate to have as our guest today, Jennifer Timmerman, an attorney who spent most of her career overseeing recalls at two federal agencies, first at NHTSA, the National Highway Traffic Safety Administration, and later at CPSC, the US Consumer Product Safety Administration. Jennifer spent 18 years at NHTSA, ten years as a trial attorney and safety recall specialist and eight years as the chief of the Recall Management division. Then in February 2019, Jennifer moved over to CPSC, where she spent nearly four years as the director of the Office of Compliance and Regulatory Enforcement. Jennifer, it's an honor to have you with us today to share your insights.

Jennifer Timian: [00:01:24] Thank you so much. Thank you for having me.

Rick Brenner: [00:01:27] Can you begin by telling our listeners a little about your work at NHTSA and later at CPSC?

Jennifer Timian: [00:01:32] Well, I started my career as a lawyer in private practice at a law firm specializing in mass tort product liability defense, as well as other insurance defense type matters. After a number of years, I moved over to federal service, joining the NHTSA in their Office of Chief Counsel in the Litigation Enforcement Group. I spent approximately six or seven years there handling all kinds of different, very interesting litigation and enforcement matters, including supporting the engineers in the Defects Investigation Group and the engineers in the compliance office. With regard to compliance matters concerning the mandatory federal motor vehicle safety standards, as well as defending the agency in federal court alongside the Justice Department. One of the matters that I handled involved advanced airbags and defending the agency's decision making there. After a tremendous experience in the counsel's office, I was given an opportunity to join one of my client offices and assist as a senior safety defects specialist specializing in focusing on compliance to all of the requirements related to motor vehicle and motor vehicle equipment recalls. So, I spent a number of years doing that, and then I was graciously given the opportunity to head up that group after my former supervisor retired. And so, I did that for almost nine years running the RMD, that's the recall management division at NHTSA and did some incredible things with my team there. We were the ones that developed and launched the VIN lookup tool on the NHTSA website, which is huge project and tremendously impactful as well as setting up their recalls portal where manufacturers are able to go in and file reports, file representative copies of all their communications and really have an interactive experience with the agency. Then as you mentioned, I moved along to CPSC, had the tremendous opportunity to lead the Office of Compliance and Regulatory Enforcement there. That's the office that monitors and then enforces where necessary the mandatory standards applicable to consumer products. And then I've most recently left CPSC and started my own new adventure as a consultant and advisor.

Rick Brenner: [00:03:40] Well, thank you. The first topic that we'd like to talk about are our improving recall effectiveness efforts to reach owners. CPSC has suggested in its recall handbook several ways to reach consumers who may have purchased a defective product in store posters, social media posts, radio and television ads, website notices, press releases, email, or US mail notification to registered owners. Similarly, NHTSA has a lengthy list on its website entitled Tips for Increasing Recall Completion Rates, and it lists literally dozens of best practices and notification methods. To what degree does either agency mandate these techniques, and how do you suggest that companies make these decisions?

Jennifer Timian: [00:04:24] Great question. Well, I think it's fair to say that both agencies expect manufacturers, and with CPSC, it's more than manufacturers that are under their jurisdiction. They expect the recalling party, the responsible party, to notify the owners and the purchasers of those recalled vehicles and products. That's what they expect and that's what they demand. And this requires this through requirements for manufacturers to notify owners and purchasers via US mail. And to do that within 60 days for vehicles they must at least use. State DMV registration records to identify who those current vehicle owners and what their addresses are in explicit targeted communication to the owner of the product. Where that person can be identified is unquestionably the gold standard to which both regulators are going to be holding the responsible recalling firm. And this, of course, makes common sense. It is the owner or purchaser of the vehicle or product that has possession or at least knows where the product is and is best positioned to take the steps to have the safety hazard addressed. NHTSA has very prescriptive regulations that dictate what every recall notification must say to the owner and for some elements in what order they have to appear in that letter. In fact, every notification letter that goes out, no matter what the vehicle or equipment involved or what the safety hazard is or what the noncompliance to a mandatory standard is, it has to begin exactly the same way using the exact same words. There's also a requirement to use a specific branding on the envelopes in which the letters are mailed. Beyond direct notice to owners. Both agencies recognize and push the regulated communities to proactively identify additional measures to both notify and motivate their products owners to take advantage of the no cost remedies, to be creative, to recognize that not every recall nor every demographic of consumer is going to look the same.

Jennifer Timian: [00:06:27] And so different approaches must be considered. That is why the CPSC recall handbook and the NHTSA's website contains so many ideas. Manufacturers of the products can know and do know their purchasers and product users the best. They made the sale after all. Personally, I recommend manufacturers and other recalling firms use the data they have on their purchasers to help them decide which notification tactics and channels will resonate. For example, they should be studying the demographics of their purchasers and they should be engaging in in so called market segmentation that they look at the data they might have, whether it be from sales data or service records that informs on what communication channels those different segments prefer and what communication channels or online platforms brought them onto the sales floor or into that service bay. In addition, I might recommend examining how to make the recall remedy more convenient or less difficult to acquire, especially when a firm has done all that it can with traditional methods like re noticing. And that needle just isn't moving. Is there an option to tow the vehicle? Does the local dealer have a mobile mechanic? Is there a rental car that can be made available to that customer? Convenience is a huge factor in recalls completion. People are busy, they're distracted. So, when you get to the point in your recall campaign where you're just not moving and there's only so much communication you can be doing, you need to be looking at sort of guerrilla tactics. And that's sort of expected, I think, from both regulators. If you're dealing with a with a severe hazard where there's likelihood of injury or death.

Rick Brenner: [00:08:11] So to what extent does the agency demand those kinds of creative solutions or are you relying on the good intentions of the manufacturer?

Jennifer Timian: [00:08:21] Great question. You know, I'll let I'll let the lawyers at the different regulators answer what's mandatory or not mandatory.   But certainly, under NHTSA's requirements, as I've specified, there is a requirement to notify in a certain way, using certain language, using a specific envelope, and to do so within a certain prescribed time frame of when the defect or failure to comply decision is made at CPSC. Certainly, when a company is working on their corrective action plan with CPSC, it's going to be questions raised and going to be the expectation that a recalling firm is going to be conduct eating what is called direct notice to the owners and purchasers where the company has that information or is able to get.

Rick Brenner: [00:09:03] It in 2015 and again in 2018, NHTSA conducted all day retooling recalls workshops where all stakeholders were invited to explore ways to improve recall effectiveness. In 2015. Dr. Rosekind opened the meeting by saying, quote, “We need to achieve 100% recall completion rates on vehicles determined to have safety related defects.” What do you recall that are some of the more impressive ideas or techniques that came out of these workshops? And what are some of the most impressive methods that you've seen companies use?

Jennifer Timian: [00:09:40] Well, whether it be in 2015 or 2018, some of the more impressive methods I've seen really at bottom are a reflection of what was said in both those summits and what I've said earlier, a tailored approach that considers the target audience that's key. I've seen manufacturers do some really good research into who their owners are and what motivates them. Right place and right time is an expression. I remember one lead on a company, one lead at a specific motor vehicle manufacturer on recalls completion, them telling me this over and over again, right place and right time. One resounding theme I remember coming out of many of the owner studies surveys. Et cetera. During the earlier stages of the Takata coordinated recall was that owners were most motivated by an almost altruistic statement or messaging that the risk is expressed as a risk to their children, to their mothers, to their friends, to their neighbors, was far more compelling in moving them to get the recall work done on their cars than describing a risk to the owner themselves. I can remember another learning in another major recall where the manufacturer learned from its studies of its owners that its impressions of what communication channels work best, which age demographics was not entirely as expected.

Jennifer Timian: [00:11:07] It learned, for example, that its youngest owners reported they were more likely to be influenced by the US mail recall notice than a text or an email. They reported that they don't check emails and that texting conveyed a less serious, less formal communication, whereas a hard mailing with the required branding on the envelope and the manufacturer's name on the return address conveyed more seriousness and formality to those younger owners. If there was a silver lining to the massive Takata recalls, it was the shared commitment of the manufacturers involved and the competitive streaks between them. I can remember strategies that involved approaching Hispanic communities with known elevated numbers of remedied cars through their pastors at mass, issuing reminders with a mobile repair van in the church parking lot awaiting takers after mass and, of course, the door-to-door canvassing That happened as well with the highest risk vehicles pushing folks at their doorsteps to make appointments via the canvassers iPad or having a tow truck on speed dial to flatbed the car to the dealer. Those are some examples of some of the impressive work that's been done.

Rick Brenner: [00:12:21] In your presentation at the 2015, you spoke about the effectiveness of what you call the nag factor. Can you speak about that?

Jennifer Timian: [00:12:30] Sure. Essentially what I was talking about and speaking about was the power of notices and the power of multichannel coupled with multi touch approaches. In other words, while a second or third letter issued to an owner is by all means going to give you some bump to completion figures. In my experience with vehicle recalls, it's usually around 10%. Several manufacturers had graciously shared with me data that demonstrated that a targeted effort from multiple communication directions within a specific time frame had a profound impact. For example, a three or four week concentrated period in which the owner would be receiving US mail, but they might also be getting a FedEx or a UPS mailer, or they might also be getting a postcard reminder, or they may be getting all three coupled with pre calls or post calls to their phones or a call from their dealer, all sending the same message about the recall in the same terms, talking about the safety risk in the same ways that the remedy was at no cost, and giving the owner information on how to easily schedule an appointment. Basically, an approach that mothers around the world have taken for centuries to ensure a barrage of reminders that continually place the desired action front and center in the brain of the recipient.

Rick Brenner: [00:13:54] And this is particularly important. You mentioned the challenge of older vehicles, particularly or even with CPC older products that the recall completion rate drops into the low fifties compared to more recent vehicles. Any ideas, any particular thoughts specifically related to older products?

Jennifer Timian: [00:14:16] Yeah, that's a real older products or low dollar value products where you don't have registration, which is a lot many most consumer products. It's hard it's hard trying to leverage if you have addressing information being creative about how you can get addressing information is critical to developing messaging platforms for consumer products. Very much looking at where were these products sold? Was there social media used and involved with the sales or pushing for the sales using the same channels that were used to make the sale in trying to connect with those consumers? Obviously, these are the platforms where they communicate or get their information. So, leveraging again to sell the recall, as I like to say, because that's really what you're doing I think is critical.

Rick Brenner: [00:15:05] Let's segue to how the agencies are alike and how they differ. NHTSA and CPSC both have mandatory reporting requirements. When a company learns of a safety incident with one of its products and both rely on companies to voluntarily recall unsafe products. From your experience as Jennifer, how are the agency similar and how do they differ in how they approach recalls?

Jennifer Timian: [00:15:28] From my perspective, they really aren't that different. While NESA has a more prescriptive approach, thanks to its statutory authorities that are that are helpfully prescriptive, both agencies are focused on maximizing recalls completion. In the first instance, her use of direct notifications to those owners and then on challenging the recalling manufacturers, distributors, etc., to use their data and their experience to develop those supplemental approaches that make sense for getting at their consumers and their and their purchasers. CPSC has a bit more of what I'd call a broader front-end approach through the use of the corrective action plan model or cap through which a manufacturer or distributor would share with the CPSC its plans and that CPSC would be reviewing ahead of the recall release and working with that recalling firm to custom tailor its plan. NHTSA's regulated parties, on the other hand, have the advantage of state registration records, at least for vehicle recalls. They do. And so, a multichannel re notice strategy may not necessarily be effective or even necessary with respect to some of those vehicle recalls, especially for those vehicles that are newer, and the owners are already bringing the vehicles in for free maintenance during which any recalls would be identified and then performed or scheduled.

Neal Cohen: [00:16:46] Jennifer That's a really interesting point because recalls that happened with the FDA, for example, are ranked by level of severity, level one, two, three. The CPSC doesn't engage in anything like that. Does NHTSA rank there the severity of a recall or all recalls treated alike?

Jennifer Timian: [00:17:04] Great question. Neal Nyssa does not rank severity of recalls for a number of different reasons, which would mirror why CPSC wouldn't do that. There is definitely the thought that's validated and data that if you start ranking recalls as people are going to, they're not going to react. They're going to they're going to put the third or fourth tier recall into the get to it when I can, you know, been and that's the last thing you want. So, no, neither organization is going to be publicly ranking recalls. And to my experience they don't internally rank them either although certainly as with a recalling firm or recalling manufacturer, there's going to be the expectation that the most severe recalls are going to require an all-hands-on deck kind of approach, whether it's mandated through regulation or not, that that's the expectation. And from my experience, most recalling firms and manufacturers, they will do that. The product liability exposure is just too big for them not to do that. So, there's sort of the selfish reason for them to be doing that. But they also are concerned with brand image. The last thing they need are anybody getting hurt or injured or even killed and what that would do to their reputation as a company and how people at the company, because these companies are all comprised of people which would feel about that. So, in my experience, the recalling firms are very much motivated to accept and acknowledge once they've made that defect decision. In my experience, they're all in now. The goal is to maximize the recall completion.

Neal Cohen: [00:18:40] When comparing different agencies who conduct recalls, such as the CPSC, the Food and Drug Administration, their procedures are quite different. The CPSC generally requires preapproval of all outgoing messages and requires sort of a lengthy process to make sure that everyone is aligned before the press release and other communications goes out. Sometimes those rank take from 4 to 8 weeks to align on those expectations. The FDA, by contrast, allows manufacturers to pretty much design. And put out their own recalls contemporaneously within a day or two, or even announcing recalls before they tell the FDA. Where does NHTSA fall in that spectrum?

Jennifer Timian: [00:19:29] Great question. I'm certainly not an authority on FDA recalls practice because I haven't worked at the FDA or been involved, although I've certainly intersected with them. I think that all of the regulators are zeroed in on what works best for their particular audience and their particular type of products with NHTSA. There's very much an emphasis on speed. However, it's a little more constrained than what you observed with the FDA, with NHTSA. They are very focused on getting that recall report into their systems and then posting it up for the public as soon as they can. But there is a process by which they would share with the manufacturer what it is that they're going to say. And usually what they say is largely based on what the manufacturer said to them. So, there's definitely this emphasis on speed for certain. I hope that answers the question, Is there something I feel like there's something I missed with that question.

Neal Cohen: [00:20:24] You did answer it. It seems like NHTSA requires the submission of materials to it. When a manufacturer is going to conduct a recall at any level and for any type of product, automotive product. And it seems as though there are clear criteria as to what the agency expects a manufacturer to communicate and how to communicate it. Like you said earlier, it's quite prescriptive. The CPSC is also prescriptive, but it's more done by their practice than by the regulations and the statute. So, the only piece that I'm really trying to narrow in on is from the time a manufacturer contacts the NHTSA and informs them that they have a defective product that needs to be taken back. In your experience, generally, how long would it take to actually alert the public to that?

Jennifer Timian: [00:21:14] Sure. Good question. It's definitely an ebb and flow and it depends on what is in the queue before NHTSA at any one time. Obviously, if NHTSA has 40 different communications from manufacturers or defect information reports coming in simultaneously, they're not going to be able to put every single one of those out within a matter of days. So, they are going to be engaging internally in a sort of prioritization process that takes into account what is the risk that's being communicated here and what is the size of this recall. On average, I would say they can process a manufacturer's recall report within a single day and have done that. That's the rarity. And usually there's some kind of communication with the manufacturer ahead of time that they have something coming in that is very, very serious that they really need to get a jump on. And in fact, they have those VINS loaded into their warranty systems so that the instant that NHTSA posts up the recall message, the owners are able to get onto the either the NHTSA vin lookup tool or the manufacturers or call their dealers and those VINS are already loaded into the manufacturer's warranty systems such that the owners will know whether or not their vehicles are impacted that very day or could be available that very day. So, it can go from any anywhere from a same day service to several weeks. I would say on average, without holding me to these numbers, I would say that NHTSA fairly effectively posts up recalls within about a business week of when they arrive.

Rick Brenner: [00:22:48] Jennifer Is there a difference between NHTSA's authority to demand a recall versus CPSC's? In CPSC's case, we know that most, most recalls are voluntary. Does NESA have the ability to demand a recall differently than CPSC?

Jennifer Timian: [00:23:06] Well, they have different statutory authorities under which they're working, but essentially, they're very similar in that there's heavy reliance on the regulated community to identify their problems and bring them to the attention of the regulator and then move as quickly as possible to develop the remedy campaign, get it launched and get the risk out of here. Both the ASA and the CPSC do, if necessary, have the authorities to so called order a recall to be conducted by the manufacturer. And they both have extensive administrative litigation procedures where manufacturers can object to and follow a process to be able to effectively litigate with the agency about the necessity or about the decision that there is, in fact, a defect or a failure to comply.

Rick Brenner: [00:23:57] Are there similar, for example, failure to report can result in a civil penalty at CPSC? Are there similar procedures in NHTSA?

Jennifer Timian: [00:24:06] Oh, yes. And there's if anybody's interested on the NHTSA's website, they post, as I believe CPSC does as well. NHTSA posts up an area where you can look in all the civil penalty cases, and many to most of those civil penalty cases are going to involve situations where manufacturers did not make a defect decision when they should have or more likely were judged to have not made a timely decision.

Rick Brenner: [00:24:31] And does NHTSA have its own investigation where it will get a complaint, for example, from a consumer of something and then investigate it on its own and then notify the company? Or is it 100% reliant on the company's notifying NHTSA?

Jennifer Timian: [00:24:45] Oh, no, no, no. And NHTSA has an entire arm both in the Office of Defects Investigation and in the Office of Vehicle Safety Compliance. NHTSA has a very robust they've invested a lot of resources and a lot of thought into what they call their owner complaint process. It's called a vehicle owner questionnaire or a VOQ But effectively, you can go online or call a hotline and report an issue, and they have a very internally robust process by which they are reviewing every single complaint and they have a very quick turnaround demand time for how quickly they review every complaint. But basically, they get what when I left NHTSA three or four years ago, they were getting over 80,000 complaints a year and they look at every single one. Now, what they do with it is another question, because not everything that gets complained about is necessarily safety related. And there needs to be judgment there. But yes, effectively, both organizations have resourced and invested in robust investigation teams that will be taking complaints from owners. And they also have mechanisms by which they can take information even confidentially from whistleblowers or from competitor manufacturers related to issues that are being seen in the field and then follow up and investigate appropriate.

Rick Brenner: [00:26:14] And as we've seen with CPSC, where CPSC has gotten much more aggressive in proactively issuing press releases to the public, where companies have been hesitant to recall a product telling the public not to use a product, that it's dangerous. Is there is there a similar story at NHTSA on this?

Jennifer Timian: [00:26:35] And it's a has followed that approach? I think it's fair to say, at least in my experience, it's a little more rare. But certainly, if a manufacturer digs their heels in and feels very strongly that they should not be digging their heels in. Then, of course, in addition to the sort of litigation enforcement procedures, there is the opportunity for them to be able to use their communications department to where they feel like the safety hazard is very high to be able to perform a public notification that basically says we're going to go ahead and warn the public, since you won't, we're going to go ahead and discharge our obligation as the safety regulator to make sure that people are aware that we think that this is bad.

Rick Brenner: [00:27:19] In recall avoidance. In your career of reviewing product defects that have led to recalls. Are there any recalling themes that have come up, lessons learned, if you will, where you've said to yourself, if the company only did X, this wouldn't have happened?

Jennifer Timian: [00:27:33] Really good question. Data integration is really important. Having separate silos of data and different data systems is just as bad as having a siloed organization where one hand has no idea what the other is doing or the left hand is not talking to the right hand, so to speak. Data integration is really important. Not having clear delegations of who is responsible for what is another example not to pick on General Motors because they did a tremendous job during the course of the ignition switch recall. But there was the Valukas report that came out that talks about this in length. A lot of well-intentioned folks all sharing responsibility for safety. But without those clear delegations and those roles, things fall by the wayside or dots are not connected. Having many offices, departments, and people responsible for the grandiose theme of safety, but not specifying who has which responsibilities or for which pieces is dangerous. Shared ownership is fine, but you need to be able to identify who is accountable and have the management controls in place to support and promote individuals taking that ownership, the ownership that they really want to take. If you cannot identify who owns it, then no one does. And it doesn't get done or it won't get cross-checked.

Rick Brenner: [00:28:56] Is there a story there with component manufacturers, for example, where it isn't exactly clear where the problem is or who's responsible? Do you have any experience where that has delayed a company initiating recall? Just trying to figure out what's wrong or who's responsible?

Jennifer Timian: [00:29:15] Yeah, I think that that's a. For every responsible party and manufacturer, whether it be at the vehicle level or the component level or the finished product level or the subcomponent level, there's this continuous cycle where we see something, but we're not sure what it is or where it came from. And there's this constant cycle of needing to understand more because the common refrain would be, and it's not incorrect that, well, if I can't figure out what the problem is, then I can't figure out what's impacted and how in the world am I supposed to conduct a safety campaign if I can't figure out what's impact? So, it becomes this vicious cycle. Both organizations have both regulators, I should say, have the view that lack of a root cause, lack of an ability to figure out exactly what the bookends are is never ultimately a reason for not declaring a safety defect or a failure to comply. The struggles to root cause, the struggles to identify the corresponding remedy and the scope of what's impacted is never an excuse for not reporting and acting. NHTSA had CPSC to it, to a lesser extent, has practices and procedures for those cases where you don't have a remedy available because you don't quite understand yet what it's going to take to fix the vehicle because you don't have the root cause that involves interim notification to owners, which is very frustrating to owners, very frustrating to get a notice that basically says there's this problem with your car, but there's nothing we can do about it right now. That's very frustrating to everybody involved. However, the idea is that people are entitled to know. They are entitled to know the risks that are at play to themselves, to their friends, to their neighbors, to their children, to empower them to be able to at least have that information and make a decision about whether or not they continue to use that product.

Rick Brenner: [00:31:11] We're so appreciative of your insights. Is there anything that we didn't ask you that would help companies be better prepared for product recalls or to work more effectively with the government to get unsafe products off the market quickly?

Jennifer Timian: [00:31:23] I think developing what I call a recall playbook coming up with a set of procedures written down for what levers you will pull, at what stages or in consideration of which levels of severity, or in light of what completion metrics companies need to have a set of plays they have ready and that everyone understands and everyone understands who is doing what and under what conditions and have become or will become second nature to the staff within those companies. A playbook should include some plan for what happens in preparation for the absolute worst-case scenario that hopefully never happens. A high risk, high occurrence rate, not detectable, no warning situation. No company should be winging it or reimagining its place in the middle of a crisis. So that would be the one thing is developing if it doesn't exist already, some kind of playbook where you've identified what levers you can pull at what points. And of course, it's something it's a live document. It's something that you experience things through different recalls, and you adjust up your playbook. But needing to have that sort of foundational document that identifies what you're doing and who's doing it and what timeframes, I think is critical so that when a situation arises, there's a go to place that provides some immediate direction that can be taken, and the tools and the resources necessary are already in place. So, you're not futzing around with a lot of administrative red tape or a lot of sort of, wait a minute, we need to study this more. We need to study that more before we invest in it. Just having a playbook provides that level of comfort, if you will, and then can be built upon as companies learn their owners and purchasers more as their products continue to evolve and those risks continue to evolve and look different and are reshaped, that's what I would encourage.

Rick Brenner: [00:33:13] Well, that is outstanding advice and we appreciated very, very much. Neil any closing comments?

Neal Cohen: [00:33:20] Jennifer I think we all share a real focus on the data and one of the answers you provided really struck a chord with me, which is making sure that companies do not silo their data and it's something that I have constantly counseled our clients on, which is so many of these issues could be avoided or mitigated had the issue been identified and the trends been identified sooner. And one of the key pieces of advice that I believe in is fixing those legacy data systems to let all the key stakeholders understand and see the data is probably the most important step a company can take to improving their safety processes. And you noted that. I just wanted to see if you had anything else to expand upon that or if you have any particular war stories on that front.

Jennifer Timian: [00:34:08] I don't want to share the war stories because I just want to be sensitive to some of the manufacturers I've worked with who have lived through this. But for example. And this doesn't just apply to multinational companies, but multinational companies in particular. You can only imagine there's language differences, there's cultural differences. And then we're going to throw on top of it having a bunch of different data systems. It's incredibly hard and there's so many opportunities for mistranslation, whether that be literal mistranslation or whether that be an engineering group in one country communicating one way with an engineering group in another country and them not really seeing eye to eye on something. And the appreciation of risk is different globally. In some countries, a vehicle stalling. The attitude is what's the big deal? Our owners know what to do in other countries. It's a much bigger deal here in the United States, and even stalling itself just to pick on stalling as a defect has had different, different attitudes over the decades, even within Mesa and the attitude of it. But it comes down to, “what are the circumstances of that stalling event?” Are we talking about the Washington Beltway? I would argue with you that a stalling on the capital Beltway, I don't care what speed, what lane you're in, what the weather's like, it's just going to be bad. On the other hand, maybe a stalling, making a right turn in a rural community and wherever ain't that big of a deal.

Neal Cohen: [00:35:26] Jennifer, you've really provided us with some really interesting insights today. I mean, whether it be from the cross cultural, multicultural language differences and how issues are perceived and addressed also to some of the insights about how messaging, including altruism, has an impact on recall effectiveness. These are concepts that I don't think we knew before, and we're really grateful. So, I want to thank you for sharing those and making your time available to us today.