The Center for Auto Safety is calling for a criminal investigation of Honda for failing to report deaths and injuries to the federal government.

In a letter to David Friedman, Deputy Administrator of the National Highway Traffic Safety Administration (NHTSA), the Center’s director, Clarence Ditlow, says that Honda “is not reporting all death and injury claims filed against it with NHTSA” as required by federal law.

The Tread Act in 2000 requires manufacturers to provide Early Warning Reports (EWRs) of “all incidents of which the manufacturer receives actual notice which involve fatalities or serious injuries which are alleged or proven to have been caused by a possible defect in such manufacturer’s motor vehicle or motor vehicle equipment.”

Ditlow writes that “examination of EWR reports filed by Honda versus GM and Toyota suggest that Honda is systematically under reporting Death and Injury claims against the company.”

“In 2013 GM and Toyota respectively reported 1,716 and 1,774 EWR Death and Injury claims to NHTSA while Honda only reported 28,” Ditlow writes. “In the first Quarter of 2014, GM reported 505, Toyota 377 and Honda 6. Even Hyundai which sells less than half as many vehicles as Honda reported 110 EWR Death and Injury claims to NHTSA from 2013 thru the first Quarter of 2014 (three times as many reports as Honda).”

Ditlow cites two specific cases relating to the Takata airbag mass defect where Honda failed to do so.

In May 2009, Ashley Parham was killed in an Oklahoma parking lot when the driver airbag exploded in a 2001 Honda Accord. KOCO TV reported: “The Parham family did sue Honda. Court documents indicate that the family settled the case for $5,000 with the money to go to Parham’s younger brother. He was in the car and witnessed his sister’s death.” Yet Honda filed no death report with NHTSA.

On August 6, 2013, the driver of a 2005 Honda Civic was severely injured when her driver airbag exploded and sent shrapnel into face. Ditlow says that Honda failed to file an EWR Injury Report with NHTSA.

“In view of the discovery that Honda has failed to comply with the EWR reporting requirements in the Tread Act and implementing NHTSA regulations on the Takata airbag mass defect, the Center calls on NHTSA to refer this matter to the Justice Department for a criminal investigation under 18 USC § 1001,” Ditlow wrote.