Thursday, 29 November 2018
A great adventure, good friends, hospitality, inspiration and ideas - the feedback from this years Recyclers Road Trip to the ARA Convention included all of these comments
This year 19 recyclers from Holland, New Zealand, Poland and the United Kingdom met in Jacksonville on their way to Orlando for the 75th Automotive Recyclers Association Annual Convention and Expo.
Marta Witkowska, Vice-President of FORS wrote “The Road Trip 2018 was a great adventure. We have spent three days visiting ATF’s with different ways of treating ELVs. We were impressed with the impetus of Central Florida Pick & Pay (CFPP) in Orlando (1000 vehicles accepted monthly!) and how perfectly All Pro Used Parts & U Pull It and Brandon Used Parts were organised. We enjoyed many ideas helping to develop sales, like the idea of separate area for VIP clients and promotional days for spare parts.
We were joining the Road Trip for the third time and we’ve noticed that the environmental obligations for Authorised Treatment Facilities in the States are becoming more demanding. In Poland oil separators and airtight surfaces are, among others, the minimal obligations for ATFs. We are not able to keep ELVs on unprotected ground, that always surprises us while visiting ATFs in different States and the way ATF’s operates in the USA, we find much more practical.”
Scott Green from Pick-A-Part in New Zealand added “We came away inspired and enthusiastic to implement some new ideas. There was something to glean from each of the yards we visited and we wish to commend everyone we visited for their willingness to share their knowledge of our industry. We highly recommend the road trip to everyone and we look forward to the next one.”
The road trip included opportunities to share food together and this year’s restaurant was The Melting Pot where everyone enjoyed three different types of Fondue and far too much food!
Go-Pull It, Greenstar Recycling, Central Florida Pick & Pay, All Pro Auto Parts, Brandon Auto Service and Cocoa Auto Salvage all welcomed the road trip and treated us like friends, proudly taking us around their facilities, sharing lots of information and answering every question put to them.
Joanna Dabrowska for the Polish group highlighted the differences between the US and Poland “From our point of view, despite the fact that each yard was somehow different from other ones, the organisational basis was similar and different from what we can see in Poland. Most yards were focused on second use of spare parts while the price of scrap was not of significant importance. Also all of the yards were organised as self-service yards (or semi self-service yards), where the ELV’s are stored for 60 to 90 days. This is different from Polish situation, where self-service yards are not popular. In most yards in Poland, full-service is practiced, maybe because of lack of free space.”
Marta Witkowska continued “We should learn from American ATFs how to effectively sell, how to manage with auctions and how to constantly raise volumes of sale. Americans are absolute masters in establishing cooperation among each other and a hub and spoke sale systems. That’s what we try to develop in Poland.”
I would like to thank every recycler that opened the gates of their facilities to the road trip, who welcomed us and shared so much with the whole team, and to the members of the road trip for their enthusiasm, fun and fellowship, and we all look forward to meeting up in 2019 on our way to Charlotte.
Friday, 16 November 2018
Our future is coloured orange. No, we are not thinking about the famous fizzy drink or the old mobile phone network, but high voltage vehicles.
A delegate arrived at a recent training course I was running on high voltage vehicles and told me as he arrived that he could sum up my course in one sentence “never cut the orange cables.”
That statement is correct, but thirty minutes into the training I asked him if that statement still summed up the training and he agreed that there is much more to these vehicles than even he had previously thought.
In short - handle a high voltage vehicle incorrectly and it WILL kill you!
100v DC is enough to give a fatal electric shock, and many of these vehicles have batteries producing between 200 and 400 volts DC with future vehicles bringing in 800v DC batteries and much greater voltages in later generations.
As I travel around the world I see many disturbing sights at vehicle recyclers, including high voltage batteries removed from vehicles with the high voltage safety plug still attached, or stored in such a manner that could create damage with subsequent fire risks. Both of the following images were recently taken in vehicle recyclers yards in the USA
The image here shows a battery, in store in a vehicle recycler, that is still connected. This means that the battery terminals are live, they could fatally electrocute any person that touches the terminals, or if a metal object (pen, spanner etc.) fell out of a staff member’s pocket and shorted the terminals, create a very serious fire.
Many may have seen videos on social media of lithium-ion batteries catching fire, and many of these can be attributed to they betters being physically damaged; safe storage of these batteries is of paramount importance, hence why I was very concerned when seeing these batteries stacked on eachother with no apparent concern for safety, minimisation of damage, or reduction of risk.
If you look closely at the picture you will see another battery (with the green case) on the floor inform of the pile. This battery was still live and was wedged between two pallets.
Examples like these indicate that there is still a very long way to go to make the vehicle recycling industry aware of the risks, to train their staff and put processes in place that protect their businesses from the risk of fatal electrocution or fire.
Tuesday, 25 September 2018
Many vehicle recyclers are handling high voltage vehicles and are completely unaware of the risks they exposing themselves, their colleagues and their businesses to.
What will it take to make these recyclers realise the danger and the risk of these vehicles; to train their staff, purchase necessary personal protective equipment and tools and set up a best management practice for the business? I hope that they see the need before one of their employees, colleagues or friends gets killed!
100v DC WILL KILL YOU!
Battery voltages are rising, with up to 400v DC now, 800v DC in the next 12 months and in excess of 1000v DC in the future - these batteries are lethal if not handled correctly.
Salvage Wire Managing Director, Andy Latham, is speaking at the International Battery Recycling Congress in Berlin and will be highlighting this issue to the assembled delegates.
Risks include electrocution, fire and physical injury caused by the weight of the batteries; basic training along with the purchase and use of appropriate Personal Protective Equipment plus a decent best management process and the use of free resources from the IDIS system will be enough to keep employees safe, minimise fire risks and protect the business.
Vehicle Recyclers and their national trade associations need to commit to training their employees and members on how to recognise these vehicles, understand the risks, and invest in the PPE and tools required to minimise or mitigate those risks before there is a fatality in the industry.
Andy will challenge the vehicle manufacturers to open up their training to technicians outside of their franchises, to first responders, recyclers and body repair centres, and will also ask them to continue to fit their vehicles with simple High Voltage disconnect devices because in an emergency situation easy access to a high voltage disconnect could be a life saver.
All vehicle recyclers can find a best management practice guide at www.salvagewire.com and can book WAMITAB accredited, high voltage training designed specifically for vehicle recyclers, by emailing email@example.com
Wednesday, 4 July 2018
“Peter, suddenly bold, said, ‘Master, if it’s really you, call me to come to you on the water.”
Many may know this quote from Matthew 14: 28 when Jesus appeared to his disciples walking on the water, and Peter decides to step out of the boat and walk on water as well.
It doesn’t go well - Peter starts to sink and needs extra help; the morale is that he tried, he stepped out of his comfort zone (he was a fisherman so boats were a large part of his life) and attempted something different.
The majority of the automotive recycling industry is also stuck ‘in the boat’; comfortable where they are and will only step out of their comfort zone to try something new or different when they absolutely have to.
This is especially true when dealing with high voltage electric and hybrid vehicles, and my major concern here is that it will take a life-changing or fatal injury to bring many to their senses and invest in training, education and protective equipment for members of their team.
It only takes 60volts and 1/2 an amp to kill - high voltage automotive batteries range from 120 to 400volts and anything up to 800amps; more than enough to cause some serious injuries or fatalities.
Salvage Wire are already on the case for the vehicle recycling industry with their WAMITAB accredited Safe Handling of Electric and Hybrid Vehicle training that has been specifically designed for vehicle recyclers.
This one-day training has been attended by over 200 delegates during the last three years; all of them leaving the day with an increased awareness of the risks, dangers and opportunities these vehicles bring, the knowledge to make these vehicles safe to transport, store and dismantle, and an accredited training qualification for their continual professional development.
Salvage Wire is bringing their training to Scotland on Wednesday 18 July and Warrington on Thursday 19 July, and there are places available on both dates for the very low price of £125 per delegate that includes all training workbooks, handouts, notes, lunch and a discount code for the purchase of high voltage tools and PPE.
Now is the time for automotive recycling professionals to step out of the boat, receive professional help and assistance to learn about the latest high voltage vehicles that will be coming into their yards now and in the future, grow, develop and seize the opportunities that these vehicles bring - book your training now or register an interest for training at another location at firstname.lastname@example.org
Salvage Wire - Helping automotive recyclers become leaders in their industry - www.salvagewire.com
Wednesday, 27 June 2018
Too many vehicle recyclers are sticking their head in the sand and not doing anything to understand high voltage technology; to understand the risks associated with electric and hybrid vehicles; to understand the opportunities that these vehicles bring them and to understand how their business needs to change and adapt to accommodate these vehicles.
Sales of Battery Electric Vehicles and Plug In Hybrid vehicles rose by 43% and 34% respectively across Europe in 2017, sales increases in the UK were 31% and 23% in both categories.
Vehicle manufacturers are predicting massive increases in sales volumes of these vehicles, with VW group expecting to annual sales of 2.5 million electric vehicles by 2025 and Bloomberg forecasting that full electric and plug in hybrid vehicles will form an ever larger percentage of vehicle sales in the coming years.
Why is this happening? Because vehicle manufacturers are being forced to reduce vehicle emissions; add in high oil prices, the decisions by many countries to ban the sale of new internal combustion engined vehicles at some stage in the future, the ever reducing cost of producing high voltage batteries, the increasing range that full electric vehicles offer, the increasing volume of charge points and the current debate around diesel vehicles and some could debate that the perfect storm has been created to condemn internal combustion engined vehicles.
These changes will have major knock-on effects to many different industries across the automotive marketplace, and the vehicle recycling industry will have to change and adapt to the new automotive landscape that will be created.
Progressive and forward thinking vehicle recyclers are already working on this, learning how the vehicles operate, looking at the opportunities this new technology brings, investigating the risks to their business, their staff and themselves, working out how to change, adapt, grow and minimise any risks, and how to provide the best service to their suppliers, customers and work providers.
You can find out more at the Salvage Wire Skills Lab at CARS on the 11 and 12 July, see https://www.cars-expo.com/show-features/skills-lab/ for more details.
Salvage Wire also have training courses scheduled for July:
- Wednesday 18 July in Edinburgh
- Thursday 19 July in Warrington
Places are limited so contact Salvage Wire now to reserve your place
Helping Automotive Recyclers Become Leaders in Their Industry
Wednesday, 20 June 2018
I don’t think that any business owner or leader would turn down any opportunity to grow their business, especially if there was an added incentive to increase their own knowledge and expertise, plus the opportunity to regularly meet fellow professionals in the industry, enjoy a meal and a few drinks with them and talk about everything that is important to them.
Well, what are you all waiting for, join fellow vehicle recyclers in the Salvage Leader Mastermind group where you can develop and grow your business, learn from each other, enjoy times of fellowship and learning, become a leader in the vehicle recycling industry and see your own business expand, become more efficient and profitable, become a business that attracts and retains talented staff and becomes the wise choice for customers.
Salvage Wire - Helping Automotive Recyclers Become Leaders in Their Industry
Monday, 11 June 2018
“Don’t need to be trained as I refuse to accept them into the yard” was one response from a recycler I was talking to recently, “but we have a Honda Insight here” was their next comment!
So you do need to be trained, you do need to be aware of the dangers, you do need to have the appropriate protective equipment for your staff, but no, they didn’t want to invest in their business or their staff - some may call this irresponsible, I call it ignorance.
60 volts and 0.5 of an amp can kill - current electric and hybrid vehicles range from 120 to 400 volts, so there is a clear focus here, handle one of these wrongly and it will kill!
Going back to my friendly recycler that made the choice not to invest in their staff or their business and refused the training; if something goes wrong and they are the subject of an investigation by the Environment Agency or the Health and Safety Executive, they may regret not making that investment and learning about these vehicles, gaining the knowledge of how they work, what the risks are, how to research the vehicle and minimise the risks to themselves, their team and their business.
So book your training now! Salvage Wire’s WAMITAB accredited training is specifically designed for the vehicle recycling community and is suitable for all members of the business.
We can come to your yard and train your team, or you can send one of your team to our regular training days around the country.
Our next scheduled training days are:
- Thursday 14 June in Lichfield where there are two spaces still available
- Wednesday 20 June in Bridgend
- Wednesday 18 July in Edinburgh
- Thursday 19 July in Warrington
For more details contact email@example.com
Salvage Wire - Helping vehicle recyclers become leaders in their industry
Thursday, 17 May 2018
Tactile, beautiful to look at, safe and very colourful; not the latest product from Apple or Tesla, but the new high voltage tool packs from the EHV Safety team at Total Lockout.
Rated to 1000 volts, these tools are specifically made to keep technicians and engineers safe whilst working on high voltage vehicle components, especially vehicle batteries.
These tools have been available individually for nearly two years but very few vehicle technicians are aware of them or using them - WHY?
Is it going to take the death of a vehicle technician to make people aware of these tools and how a small investment could save a life? I hope not!
Having spent three days at The Battery Show recently it seems that leaders, engineers and managers are aware of the risks and talking about investing in tools and equipment to keep their teams safe, but talking is one thing, doing is another!
One technician recently advised me that he winds insulation tape around his screwdriver to stop him getting electrocuted when dismantling a high voltage battery - unbelievable when a screwdriver pack that includes tools designed, tested and certified to 1000 volts is available for less than £50. How this technician (or his manager) cannot invest a small amount of money to protect his own life is beyond me!
5 Tool kits are available from stock and with prices ranging from £300 to £5,000 will fit most budgets; the best bit is that the EHV Safety team can build bespoke kits for any customer, laser etch the whole kit with the customer’s name, the engineer’s name or a serial number that identifies the tool or the kit for added security and protection - check out www.ehvsafety.com for full price lists, stock availability and options, and adding the discount code SW1018 on checkout gives each customer an added 10% discount on the order.
If a full kit is not your choice then all the tools are available individually at www.ehvsafety.com so you can build your own kit along with every bit of PPE that each technical and engineer requires, including gloves, apron, face shield, floor mats and more - so be safe, stay alive, and purchase all your high voltage tools and PPE from www.ehvsafety.com
Thursday, 3 May 2018
As a sound engineer in my spare time, I use an enormous amount of 9volt batteries in microphones and almost singlehandedly keep the local battery recycling bin full.
Fortunately the High Voltage batteries in vehicles don’t need changing as often, and at weights of anything up to 600kg that is probably a good thing!
Almost every week vehicle manufacturers are announcing new and updated vehicles with some form of electrification, from 48v mild hybrid systems to the latest technology with battery power at 800volts. Over time every single one of these vehicles will head towards a vehicle recycling yard, some after many years and others quite quickly after being involved in accident or incident, and vehicle recyclers need to know how to handle these vehicles so that they can keep themselves, their staff and their businesses safe.
An electric shock can have serious consequences - it only take 60volts and less than 1amp to kill - consequences that could also prove as devastating to the business where an electrocution occurs, because the Health and Safety Executive and the Environment Agency will start to take a serious interest in the operation before the lawyers of the injured staff member take over.
Yard owners and managers have a couple of options available to them going forward and these include:
Doing nothing - not the smart choice, because many will not be in a position to turn these vehicles away and untrained, unaware employees handling these vehicles is a recipe for disaster.
Training themselves and their staff in awareness and understanding of these vehicles would be the first good decision, then they need to follow this up by putting best management practices into place that cover the collection, storage, de-pollution and dismantling of electric and hybrid vehicles.
Salvage Wire have a WAMITAB accredited Safe Handling of Electric and Hybrid Vehicle training course available that has been specifically designed for vehicle recyclers, the course covers all aspects of these vehicles and gives all delegates the information and confidence to collect, store, de-pollute and dismantle these vehicles and the high voltage components that come out of them.
There are three training courses scheduled over the coming weeks:
- Thursday 7 June in Braintree
- Thursday 14 June in Lichfield
- Wednesday 20 June in Bridgend
Battery storage is also very important - recyclers must have separate storage areas for each type of battery, making certain that the three different types of battery (Lead Acid, Nickel Metal Hydride and Lithium-Ion) are not stored together, and also that nothing can fall onto the batteries or that they cannot fall onto anything else.
Owners and mangers also need to invest in the appropriate Personal Protective Equipment for their staff to keep them safe; this includes gloves, tools, voltage testers, signs and more; everything needed can be obtained from Total Lockout and readers of this blog can get a 10% discount by entering the code SW1018 when purchasing safety clothing, insulated tools, signs, accessories and high voltage kits at https://ehvsafety.com.
Some vehicle recyclers are reporting difficulties in disposing of their high voltage batteries as their normal battery recycler either will not take these batteries or is charging for disposal. Working with Cawleys in Luton, Salvage Wire are developing a waste collection service for high voltage batteries (find out more at https://www.cawleys.co.uk/innovations/lithium-battery-disposal/) and investigating disposal solutions. Currently there are no facilities in the UK where these batteries can be recycled and the cells are being removed from the battery and shipped to Belgium for recycling. Obviously there will still be a cost but this will be minimised as much as possible with the Cawleys proposition - for more details and to arrange a quote please contact firstname.lastname@example.org with details of the batteries you have available.
Many may consider that these vehicles are dangerous, but they are no less unsafe than conventional internal combustion engines with a tank of flammable liquid at the back of the vehicle that is piped to the front, injected into a cylinder at high pressure and then exploded multiple times a second - at the end of the day you are comfortable with what you understand!
Monday, 23 April 2018
Introducing the Salvage Wire, Safe Handling of Electric and Hybrid Vehicle Training course - this one-day training will be held in Redcar on Tuesday 1 May
This WAMITAB accredited training is specifically designed for the vehicle recycling industry, it is a mix of classroom and practical training, teaches the delegates about the vehicles, how they work, the risks and how to manage the level of risk, and highlights best practice for these vehicles - from first notification of collection to final dismantling.
Covering 70 vehicle manufacturers with region specific data for 40 countries and translated into 31 languages the International Dismantling Information System (IDIS) is an advanced and comprehensive information system for pre treatment and dismantling information for end of life vehicles.
The system contains safe handling information on High Voltage batteries, LPG vehicles and airbag technologies as well as oils, fuels, air conditioning and much more for legitimate vehicle recyclers across the world.
IDIS provides a user friendly navigation to an extensive database with practical information on pre-treatment, safety related issues like airbag deployment and handling of HV batteries, on potentially recyclable parts and other safety related elements mentioned in the EU ELV directive (e.g. lead in batteries or mercury and lead in electronic devices). The objective is to provide dismantling information for treatment operators and promote the environmentally sound treatment of ELV’s, safely and economically.
Access to IDIS is free of charge for all vehicle recyclers, and once registered recyclers gain access to dismantling information and safety information for vehicles from 1974 right through to the latest models, systems and technologies available.
To access IDIS check out www.idis2.com and become one of the over 6,000 users of the system that is helping vehicle recyclers across the world to safely dismantle vehicles and promote environmentally effective practices.
Salvage Wire - Helping Automotive Recyclers Become Leaders in Their Industry
Tuesday, 17 April 2018
All vehicles have to be repaired from time to time, using recycled parts for these repairs makes economic sense with the added benefit of saving the planet.
Repair costs can range from a few hundred to thousands of pounds and a little research can go a long way towards saving a lot of money because recycled parts cost significantly less than brand new parts.
When cars reach their end of life many parts are still in great working condition, this is even true with cars involved in collisions. After a traffic accident the vehicle may not be economical to repair and this means that all the unaffected, perfectly working parts can be re-used on another vehicle.
The cost factor is by far the number one reason to buy recycled parts. The difference in price between new and used parts can be amazing.
As an example, the brand new price for many headlamps is now into four figures, whilst purchasing a recycled part could be as little as 35 to 40% of the brand new price. There are many factors that drive the cost of used parts, including availability, condition, and scarcity. In general, you can easily save over 50% for the average car when you buy recycled.
Consumers can find their own parts if they want to save even more money. A visit to the local vehicle recycling yard if they are mechanically inclined, can increase their savings by removing needed parts themselves.
Vehicle recycling has operated alongside vehicle manufacturing for over a century, and vehicle technicians have always had access to, and utilised recycled parts.
Today, of course, the internet provides a vast resource for finding the exact parts required, and the internet can search the whole world to locate parts that may not be available locally.
Recycled parts are Original Equipment Manufacturer (OEM) units, the same brand that was original to the manufacture of the car, meaning correct fit and operation.
After-market parts are also available. For vehicles, after-market simply means that the part comes from a different brand than the one the original manufacturer used.
95% of the materials in current automobiles are recyclable in some way or another, and using recycled parts in any vehicle reduces the amount of oil and other resources that would otherwise be needed to produce new parts, supports local businesses, keeps vehicles on the road, saves the planet and reduces ownership costs.
To find out more about recycled parts, how to save money and improve the environment have a look at the Vehicle Recyclers Association pages https://www.vrauk.org where you can also find member details and start searching for your recycled parts.
Wednesday, 11 April 2018
UK Vehicle recyclers could unknowingly be selling potentially dangerous vehicle parts that should have been repaired or replaced by the vehicle manufacturer under a vehicle recall programme
Over the last few years there have been more vehicles recalled globally than in the entire history of the motor vehicle.
In the UK, vehicle recalls are for safety related issues, owners are contacted by the vehicle manufacturer to tell them why the vehicle is being recalled, what they need to do and who they should contact about the recall; the vast majority of recalls have been completed satisfactorily, but there are some vehicles that have not been captured by the recall notice and are therefore un-repaired and potentially unsafe.
In a few cases these vehicles may have arrived at an auto recycler’s premises and may well be stripped for parts, and any parts that are subject to a recall should be removed from use and destroyed - in some cases there may be a case for the vehicle manufacturers to pay the vehicle recyclers for the recalled parts they remove from these vehicles.
All automotive recyclers need to be clear and unequivocal about this situation - IF there is any possibility that the part they are selling could be subject to a recall notice then there are two options.
- Make certain the vehicle in question has been checked under the recall notice and confirm that the part being sold is of merchantable standard
- If the part is still subject to a recall then DO NOT sell the part, but return it to the local franchised dealer along with details of the vehicle it came from.
Vehicle manufacturers need to make all vehicle recall data, including relevant part numbers available to the vehicle recycling community, in a format that can be easily used by yard management systems; vehicle recyclers will then be made aware of the recall information and can physically check each part against the manufacturers data, confirm if the part is saleable, and if not, can remove the part and return it to the vehicle manufacturers via the local franchised dealer.
There can be no other alternative to this, the consequences of selling a defective part could be enormous for any business, especially if the defect results in a fatal accident.
Vehicle manufacturers also need to recognise that professional automotive recyclers are an important part of this process, and reflect that by refunding them for the time and effort they have taken to check and remove the part subject to a recall, and to cover for their loss of revenue because they are unable to sell that part onwards.
After speaking to providers of Yard Management Systems and automotive recyclers there are very few checks in place to determine if any parts sold are subject top a recall notice.
One recycler did advise that if they receive notification of a recall from a vehicle manufacturer for any vehicle they have in their possession the relevant parts are removed from sale.
Yard Management System providers have no process built in to check for recalls on any vehicle or part.
So how should the ideal process work in a vehicle recycling yard?
Upon Receipt of the vehicle
- Vehicle details entered into yard management system:
- The YMS links directly with the recalls database, cross references the vehicle registration and VIN number and advises on any active recalls and the parts involved, including the appropriate part numbers.
- In reality, yard staff will have to manually check recall databases
- The yard can then place an embargo on any recalled parts, and either scrap them, or remove that part(s) and check them to confirm if the part is safe or not.
- If the part is safe, then it can be sold as an approved green recycled part
- If the part is found to be unsafe, then it should either be scrapped, or removed, quarantined, and transferred to the local franchised dealer. The vehicle manufacturer should then be informed so they can update their own records.
- The vehicle recycler should receive a refund from the vehicle manufacturer for all recalled parts returned to the franchised dealer.
Every time the vehicle moves into another area (for example, moved from storage to dismantling, or storage to auction) another recall database check would be completed to cover for any changes in recall data - including new recalls (this would be automatic or manual as dictated by the system in place).
As every part is sold a further recall check is completed to make certain that no parts being sold are under a recall notice. (this would be automatic or manual as dictated by the system in place).
Examples of potential recalled parts found for sale
The Driver & Vehicles Standards Agency (DVSA) operate a full database of all vehicle recalls, data includes the vehicle manufacturer, model, build year, VIN’s and description of the issue. Through this two safety related parts were highlighted and potential examples of these parts were found to be on sale at high profile recyclers or recycled parts sales platforms.
Passenger airbag for a 2002-2004 Honda Jazz.
DVSA data shows an active recall for Passenger airbags on Honda Accord, Accord Tourer, CR-V, Civic, Jazz and Stream covering vehicles built between Jan 2003 and Dec 2003. This airbag COULD be one of these defective units!
Steering rack for a 2014-2018 Mercedes C-Class
Build dates and build code that correspond to a recall from Mercedes for a defect on the steering rack motor - the motor can be clearly seen in the image - Again, this part COULD be subject to a recall notice.