ATTENTION:
GENERAL MANAGER
PARTS MANAGER
CLAIMS PERSONNEL
SERVICE MANAGER

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IMPORTANT - All
Service Personnel
Should Read and
Initial in the boxes
provided, right.

© 2020 Subaru of America, Inc. All rights reserved.

PRODUCT CAMPAIGN BULLETIN
APPLICABILITY:

2003-14 MY Legacy
2003-14 MY Outback
2003-06 MY Baja
2009-13 MY Forester
2004-11 MY Impreza

2004-14 MY WRX and STI
SUBJECT: Takata Front Passenger Airbag Module /
Inflator “Like for Like” Recall

NUMBERS: TKA-20R

TKB-20R

TKC-20R
DATE: 01/06/20
REVISED: 01/15/20
NHTSA ID: 20V001
20V002
20V003

SUBARU OF AMERICA, INC. has determined that a defect, which relates to motor vehicle safety,
exists in certain 2003-2014 model year Legacy and Outback vehicles, 2003-2006 model year Baja
vehicles, 2009-2013 model year Forester vehicles, 2004-2011 model year Impreza vehicles, and 20042014 WRX (including STI) vehicles equipped with a non-desiccated Takata-sourced passenger-side
frontal air bag containing the propellant Phase Stabilized Ammonium Nitrate (PSAN).
As previously communicated, this phase of the Takata airbag recall includes vehicles which had an
interim repair performed under previous Takata airbag recalls.
Interim repairs, also referred to as “like-for-like” repairs, involved the installation of a non-desiccated
PSAN Takata-sourced inflator, prior to the availability of final repair parts which do not contain
PSAN. The vehicles included in this recall were identified from recall claim data indicating that a
“like-for-like” Takata-sourced non-desiccated PSAN inflator may have been installed.
DESCRIPTION OF THE SAFETY DEFECT AND SAFETY HAZARD
Despite the previous recall repair for a “like-for-like” air bag inflator replacement, vehicles containing
a Takata-sourced passenger-side frontal air bag inflator remain susceptible to propellant degradation
occurring after long-term exposure to high absolute humidity, temperature and temperature cycling.
Over time, this could cause the inflator within the air bag to explode when the passenger’s frontal air
bag deploys in a crash.
If the air bag inflator explodes, sharp metal fragments could strike vehicle occupants, potentially
resulting in serious injury or death.
Continued...
CAUTION: VEHICLE SERVICING PERFORMED BY UNTRAINED PERSONS COULD
RESULT IN SERIOUS INJURY TO THOSE PERSONS OR TO OTHERS.
Subaru Service Bulletins are intended for use by professional technicians ONLY. They
are written to inform those technicians of conditions that may occur in some vehicles,
or to provide information that could assist in the proper servicing of the vehicle. Properly
trained technicians have the equipment, tools, safety instructions, and know-how to
do the job correctly and safely. If a condition is described, DO NOT assume that this
Service Bulletin applies to your vehicle, or that your vehicle will have that condition.

SUBARU OF AMERICA, INC. IS
ISO 14001 COMPLIANT
ISO 14001 is the international standard for
excellence in Environmental Management
Systems. Please recycle or dispose of
automotive products in a manner that is friendly
to our environment and in accordance with all
local, state and federal laws and regulations.

Bulletin Number: TKA-20R / TKB-20R / TKC-20R; Revised: 01/15/19

Page 1 of 48

BACKGROUND
The National Highway Traffic Safety Administration (NHTSA) has prioritized the recalls of all nondesiccated Takata-sourced passenger side Takata airbag inflators based on the risk of injury or death
to vehicle occupants.
The combination of time, high temperature fluctuations, and humidity contribute to the degradation
of the propellant in the inflators. Therefore, NHTSA prioritized the Takata recalls by age and location
history of the vehicles. To do so, NHTSA has established three geographical Zones – A, B, and C –
based on the level of heat and humidity as listed below:
Zone A: Hot and Humid
Alabama, California, Florida, Georgia, Hawaii, Louisiana, Mississippi, South Carolina, Texas,
Puerto Rico, American Samoa, Guam, the Northern Mariana Islands (Saipan), and the U.S. Virgin
Islands.
Zone B: Less Hot and Humid
Arizona, Arkansas, Delaware, District of Columbia, Illinois, Indiana, Kansas, Kentucky,
Maryland, Missouri, Nebraska, Nevada, New Jersey, New Mexico, North Carolina, Ohio,
Oklahoma, Pennsylvania, Tennessee, Virginia, and West Virginia.
Zone C: Least Hot and Humid
Alaska, Colorado, Connecticut, Idaho, Iowa, Maine, Massachusetts, Michigan, Minnesota,
Montana, New Hampshire, New York, North Dakota, Oregon, Rhode Island, South Dakota, Utah,
Vermont, Washington, Wisconsin, and Wyoming.
AFFECTED VEHICLES
This phase of the Takata recall includes vehicles which may have had an interim (“like-for-like”)
repair performed under a previous airbag recall, to reduce the risk of injury before final remedy parts
were available:
• Previously repaired Zone A vehicles will be included in recall code TKA-20
• Previously repaired Zone B vehicles will be included in recall code TKB-20
• Previously repaired Zone C vehicles will be included in recall code TKC-20
If the previous recall claim data is unclear as to whether a PSAN “like-for-like” inflator was installed
or not, the vehicle has been included in this phase of the Takata airbag recall out of an abundance
of caution.

Examples of unclear retailer claim data are listed below:
•
•
•

Missing installed inflator/module serial numbers
Installed inflator/module serial numbers that do not correspond with the part number claimed
Returned part information that indicates that a PSAN unit may have been installed

Retailer affected vehicle counts by model year/carline were distributed to all Regional/Distributor offices
in December to assist with capacity planning purposes. Lists of the affected VINs will be distributed
when owner notification begins.
The status of TKA20, TKB20, and TKC20 coverage will display as “Open – Pending Phased Mailing”
until all official owner notification letters have been released. This status is not intended to discourage
retailers from scheduling these repairs and will not affect the retailers’ ability to file a claim for repairs
performed prior to the official owner notification.
Continued...
Bulletin Number: TKA-20R / TKB-20R / TKC-20R; Revised: 01/15/19

Page 2 of 48

REPAIR
The repair procedures for this recall include a required inspection prior to replacement, to confirm
whether a PSAN “like-for-like” inflator was previously installed or not.
•

If inspection confirms the affected vehicle DOES contain a previously-installed PSAN “like-forlike” air bag inflator, it will be replaced with a final remedy non-Takata sourced inflator/module.

•

If inspection confirms the vehicle DOES NOT contain a previously-installed PSAN “like-forlike” inflator, Subaru will reimburse retailers for the required inspection procedure.

OWNER NOTIFICATION
Owner notification will begin January 7, 2020 and will be phased in weekly mail drops through
the end of February. Listed below is the current mailing plan, based on the model year (MY) of the
affected vehicles:
•
•
•
•
•
•
•
•

January 7: affected 2003-2004 MY vehicles
January 16: affected 2005 MY vehicles
January 23: affected 2006-2007 MY vehicles
January 30: affected 2008 MY vehicles
February 6: affected 2009 MY vehicles
February 13: affected 2010 MY vehicles
February 20: affected 2011 MY vehicles
February 27: affected 2012-2014 MY vehicles

As a reminder, if a customer requests a loaner car, retailers should make every effort to comply with
that request and follow normal warranty procedures to obtain reimbursement for the loaner car. See
Section 8.4.7 (Alternate Transportation Program) of the Claims Policies and Procedures Manual on
subarunet.com under ‘Claims & Warranty Administration’ for details.
RETAILER VIN ASSIGNMENT
Each Subaru retailer will receive an affected VIN list from their Zone office when owner notification
begins. Vehicles will be assigned to retailers in the affected VIN list as follows. Please note that this
logic has recently changed:
1. If there is a preferred retailer on file, the VIN will be assigned to the preferred retailer.
2. If there is no preferred retailer on file:
a) Original vehicle owners are assigned to the original selling retailer if their current DMV
registration address is within a 50-mile radius of that retailer.
b) If the original selling retailer is inactive, the VIN is assigned to the nearest active retailer.
c) If the owner is not the original owner, the VIN is assigned to the nearest active retailer.

Continued...
Bulletin Number: TKA-20R / TKB-20R / TKC-20R; Revised: 01/15/19

Page 3 of 48

RETAILER PROGRAM RESPONSIBILITY
Any vehicles listed in a recall/campaign that are in retailer stock must be:
•

Immediately identified.

•

Tagged or otherwise marked to prevent their delivery or use prior to inspection and/or repair.

•

Repaired in accordance with the repair procedures outlined in this Product Campaign Bulletin.

Retailers are to promptly perform the applicable service procedures to correct all affected vehicles
in their inventory (used, demo & SSLP).
Additionally, whenever a vehicle subject to this recall is taken into retailer inventory, or in for
service, necessary steps should be taken to ensure the recall correction has been made before selling
or releasing the vehicle, provided that parts are available to complete this recall.
PARTS INFORMATION
The current part numbers required for this recall are the passenger airbag inflator kits or modules
listed below:
Applicability

Part Number

Type

Order Qty.

98279AE04A

Module

1

98279AG05A or B

Inflator

SOA963W110*

Non-Woven Material

2010-2014 MY Legacy
2010-2014 MY Outback

98279AJ06A

Module

1

2004-2005 MY Impreza
2004-2005 MY WRX & STI

98279FE070

Inflator

1

2006-2007 MY Impreza
2006-2007 MY WRX & STI

98279FE12A

Module

1

2008-2011 MY Impreza
2008-2014 MY WRX & STI

98279FG07B

Module

1

2009-2013 MY Forester

98279SC05B

Module

1

2003-2004 MY Legacy
2003-2004 MY Outback
2003-2006 MY Baja
2005-2009 MY Legacy
2005-2009 MY Outback

1

* Use part number SOA635079 to claim for non-woven material.

REMINDERS:
•

Always order the most up-to-date replacement parts based on the specific VIN being repaired.

•

One sheet of the SOA963W110 non-woven material is enough for approximately 8 vehicles.

Continued...
Bulletin Number: TKA-20R / TKB-20R / TKC-20R; Revised: 01/15/19

Page 4 of 48

PART RETURN PROCEDURES
Please review the ‘Inflator/Module Return’ instructions included as ‘Appendix A’ of this
bulletin carefully.
•

A company called Takata XPO will arrange pick up of the removed inflators/modules and
return them to Takata.

•

FedEx will no longer handle the return shipments as with previously issued Takata recalls.
However, if you do not have a large amount of inflators/modules to pick up, you may be
directed to use FedEx for return. Please follow the instructions given to you by Takata XPO.

•

Once a month or upon accumulating 200 kits for return (whichever comes first), please
call Takata XPO at 1-877-650-3476 for pick up. Please see step 6 (on pg. 30) of the return
instructions.

•

If you continue to receive inventory of inflators with the original FedEx documentation,
please follow the instructions in step 4b. of the new ‘Inflator Returns’ instructions. DO
NOT CALL FEDEX.

•

Upon claim approval and where applicable, Subaru of America, Inc. will generate a Part
Return Notice requesting the old and new inflator serial number information only. DO NOT
WAIT FOR TAKATA XPO TO PICK UP THE INFLATOR/MODULE TO SEND
THIS INFORMATION TO THE PARTS COLLECTION CENTER (PCC).

•

IMPORTANT: Each removed airbag inflator/module must be returned directly to the
supplier, Takata USA, in the same box in which the new one was received.

The shipping box contains a bar code label, which will be used by Takata USA to document the
replacement of the old inflator/module with the new inflator/module. Therefore, it is very important
for the removed inflator/module be returned in the exact same box which contained the newlyinstalled inflator/module for that vehicle. If the original box cannot be re-used, please refer to the
shipping instructions under “Requesting a new box/ shipping labels.”
•

IMPORTANT: When affixing the shipping label to the Shipping Box do not obstruct the bar
code label.

•

A completed SOA Warranty Parts Tag (MSA5W402A) must be attached to the returned
inflator/module. The tag must contain the following information: claim number, repair date,
full 17-digit VIN, and mileage.

Continued...
Bulletin Number: TKA-20R / TKB-20R / TKC-20R; Revised: 01/15/19

Page 5 of 48

SOA PART RETURN NOTICE INFORMATION

IMPORTANT NOTE: The following information is applicable to SOA and
Subaru Distributors Corporation (SDC) retailers ONLY. Subaru New England
(SNE) retailers will continue to follow the procedures currently in place as
supplied below.
All SOA and SDC retailers are required to enter BOTH the newly-installed
(replacement) and the removed (original) serial numbers for the airbag
inflator (or module assembly) into the supplied fields as shown in the
screen shot below. Claims will not receive an “Approved” status without
the serial number information being entered in the appropriate fields in
the Recall Claim Entry system. As a result of adding these new required
entry fields, Part Return Notices will no longer be generated.

The information below is applicable to SNE retailers only:
•

Upon claim approval and where applicable, Subaru of America, Inc. will generate a Part
Return Notice requesting information only.

•

To ensure proper claim credit where applicable, the old and new inflator/module serial
numbers must be recorded on the Part Return Notice and sent to SOA Part Collection Center
(PCC) as instructed on the return notice.

•

Where applicable, the completed Part Return Notice should then be sent using the YRC web
portal and utilizing the “Ship Small Parcel” link which will direct the user to the appropriate
UPS web page application to complete the shipment. Please keep the UPS tracking number
for your records.

•

DO NOT WAIT FOR TAKATA XPO TO PICK UP THE INFLATOR/MODULE TO
SEND THIS INFORMATION TO THE PCC.

Under no circumstances should any airbag inflators or modules be sent to Subaru of America,
Inc.

Bulletin Number: TKA-20R / TKB-20R / TKC-20R; Revised: 01/15/19

Page 6 of 48

SERVICE PROCEDURE
This safety recall involves the inspection and/or replacement of the passenger-side front air bag inflator
or module.
As previously communicated, this phase of the Takata recall will include vehicles which previously had
an interim repair performed under the current Takata recalls. Interim repairs, also referred to as likefor-like repairs, involved the installation of a non-desiccated PSAN Takata-sourced inflator, prior to the
availability of final repair parts which do not contain PSAN.
IMPORTANT: Inspection of the airbag inflator MUST be performed on ALL affected vehicles
BEFORE proceeding with any part replacements. Use the charts on pages 10 and 11 as a guide when
performing the inspection to determine if the currently installed airbag inflator is either a Takata or ZF
/ TRW manufactured part. If inspection determines the airbag inflator or module assembly requires
replacement, refer to the Table of Contents below for the applicable Service Procedure.
As previously communicated, this phase of the Takata recall will include vehicles which previously had
an interim repair performed under the current Takata recalls. Interim repairs, also referred to as likefor-like repairs, involved the installation of a non-desiccated PSAN Takata-sourced inflator, prior to the
availability of final repair parts which do not contain PSAN.
VERY IMPORTANT: Failure to follow these service procedures carefully and correctly may
result in an accidental deployment of the inflator and potentially cause serious injury. Please read
through and understand these procedures COMPLETELY before beginning repairs. In addition,
proper operation of the airbag after reassembly may be compromised if these service procedures
are not followed.
As additional service procedures are developed for the other models affected by the expansion and
implementation of this recall campaign, they will be added to this document and also made available
on STIS.

TABLE OF CONTENTS – SERVICE PROCEDURES
Description

Starting Page

Number

Airbag Inflator Inspection Guidelines

10

Service Procedure for 2010-2014MY Legacy / Outback Models, Airbag Module
Assembly, Part Number: 98279AJ06A

12

Service Procedure for 2009-2013MY Forester (Part Number: 98279SC05B) and
2008-2011MY Impreza, and 2008-2014MY WRX & STI Models
(Part Number: 98279FG07B), Airbag Module Assembly

14

Service Procedure for 2003-2004MY Legacy/Outback and 2003-2006MY Baja
Models, Airbag Module Assembly, Part Number: 98279AE04A

16

Service Procedure for 2005-2009MY Legacy / Outback Models, Inflator Type 2,
Part Number: 98279AG05A or B

20

Service Procedure for 2004-2005MY Impreza, WRX, and STI Models,
Inflator Type 2, Part Number: 98279FE070

30

Service Procedure for 2006-2007MY Impreza, WRX and STI Models, Airbag
Module Assembly, Part Number: 98279FE12A

38

Appendix B (2003MY Legacy, Outback, and Baja models ONLY)

47

Continued...
Bulletin Number: TKA-20R / TKB-20R / TKC-20R; Revised: 01/15/19

Page 7 of 48

Tools Required:
DESCRIPTION

BRAND OR TYPE

QUANTITY

Pliers

-

1

Wire Cutters

-

1

Needle-Nose Pliers

-

1

Torque Wrench

Inch-Pound

1

Safety Goggles

-

1

Flat-Blade Screwdriver

-

1

Scissors

-

1

Ratchet
8 mm and 10 mm Socket

1/4” Drive

1
1 ea.

Airbag Deployment Fixture

J-39401-B

1

Tether Clip Release Tool
*See Page 9 for more information

SOA635147

1

CAUTION: Before starting this service procedure, perform a visual inspection of both front airbags
looking for any damage or abnormality. Next, turn the ignition switch to the “ON” position and
confirm the airbag warning lamp illuminates then extinguishes normally. If it does not or if ANY
concern is noted with the airbag system, STOP and report these findings to the customer BEFORE
proceeding further. Any concerns identified with the airbag system (when no airbag deployment has
occurred), are not related to this campaign and must be addressed separately. Even if the system has
a concern, this may not preclude completion of this campaign. If you are unsure about proceeding,
document and fully diagnose the concern then contact the SOA Technical Helpline to review your
findings. It is in the best interest of the retailer to fully document any concerns found during this
preliminary inspection and review with the customer BEFORE proceeding with the campaign
service procedure.
•

Vehicles that do not contain Genuine Subaru airbags are not eligible for this recall repair.
For more information on identifying counterfeit airbags and how to address related customer
situations, please refer to STIS for the “Counterfeit Airbag Information” Dealer Advisory
Bulletin dated October 25, 2012 by going to Subarunet>Service>STIS>Online Reference choose Publication Type: ‘Other/Miscellaneous’ and search keywords: ‘Airbag’).

•

Do not proceed with this repair if your inspection reveals a non-Genuine Subaru airbag
module has been installed in the vehicle. Follow the instructions described in the “Counterfeit
Airbag Information” Dealer Advisory Bulletin.

•

IMPORTANT: Always examine airbag modules closely before and during removal. Confirm
they match the photos of the Genuine Subaru airbag components supplied throughout this
bulletin BEFORE proceeding. The photo below shows an example of an aftermarket or
counterfeit airbag inflator. This photo is being provided as an example of what may be a wide
variety of non-OEM components.

•

If an aftermarket or counterfeit passenger airbag or inflator is identified at any point during
the campaign service procedure, STOP IMMEDIATELY. NEVER attempt to remove or
otherwise disable any aftermarket or counterfeit device.

•

Document the presence of the aftermarket or counterfeit device on the repair order and with
photos. Report this information immediately on a Quality Monitoring Report (QMR).
IMPORTANT: When entering a related QMR, use failure code ULF and NOT the campaign fail