Was Toyota using “technical service bulletins” to avoid issuing recalls? Some critics think so.

Two years before Toyota issued a recall of defective floor mats implicated in incidents of sudden, unintended acceleration, the automaker warned its dealers of the dangers. Unfortunately, no one in the American driving public ever got this information.

Critics of Toyota and the auto industry in general claim that the issuance of a technical service bulletin is often a recall in all but name, and they are seeking reform. Clarence Ditlow, director of the Center for Auto Safety. told Reuters that his organization supports efforts to make technical service bulletins available to consumers. An official with the Consumers Union also told Reuters that the organization would back a review of disclosure standards as part of an effort to reform the system.

According to Reuters, a technical service bulletin about faulty floor mats was issued in September 2007 to about 1,500 Toyota and Lexus dealers. “If the floor mat is NOT properly placed and secured, it could slip and interfere with the movement of the pedals during driving and may cause an accident,” the bulletin said. “NEVER install more than one floor mat at a time in the driver’s seating position.”

The National Highway Traffic Safety Administration (NHTSA) was seemingly satisfied with the 2007 bulletin approach, even though in a meeting that year, officials had concluded that consumers were warning of “extremely dangerous safety” risks from “floor mat interference” in Toyota. According to Reuters, just over two weeks after Toyota sent its first floor mat bulletin to dealers, the agency closed its investigation with only a limited public warning.

In September 2007, Reuters said, under pressure from federal regulators, Toyota did issue a recall for 55,000 all-weather floor mats on the Camry and the Camry-derived Lexus ES 350. But company staff would later boast that narrow recall had saved it $100 million.

In April 2008, a second technical bulletin was issued warning that improperly installed floor mats could cause crashes in the Camry, Corolla, Matrix, Sienna, Tundra, Sequoia and Land Cruiser.

Both of the bulletins went to the NHTSA, but according to Reuters, they were much more strongly worded than anything consumers received. For example, in September 2007, the NHTSA issued a “consumer advisory” urging Camry and the Lexus ES 350 owners to swap out recalled all-weather floor mats for new ones and to make sure that they were secured to keep from slipping forward and “causing the vehicle to accelerate uncontrollably.” The agency also “strongly urged” drivers of the popular Prius hybrid and Avalon sedan to make sure that their floor mats were set up properly.

But nothing in the advisory warned of the risk of crashes, or made mention of other Toyota and Lexus vehicles with the same issue. According to Reuters, the wording of the NHTSA advisory was negotiated with and approved by Toyota.