[Federal Register: November 6, 2001 (Volume 66, Number 215)]
[Notices]
[Page 56146-56191]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr06no01-113]
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
[Docket No. NHTSA-2001-10053-Notice 1]
Safety Rating Program for Child Restraint Systems
AGENCY: National Highway Traffic Safety Administration (NHTSA), DOT.
ACTION: Notice, request for comments.
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SUMMARY: Section 14(g) of the Transportation Recall Enhancement,
Accountability, and Documentation (TREAD) Act requires that, by
November 2001, a notice be issued to establish a child restraint safety
rating consumer information program to provide practicable, readily
understandable, and timely information to consumers for use in making
informed decisions in the purchase of child restraint systems (CRS).
In response to this mandate, NHTSA has reviewed existing rating
systems that other countries and organizations have developed, and
conducted its own performance testing to explore a possible rating
system for child restraints. The agency has tentatively concluded that
the most effective consumer information system is one that gives the
consumer a combination of information about child restraints' ease of
use and dynamic performance, with the dynamic performance obtained
through higher-speed sled testing and/or in-vehicle NCAP testing. The
agency is also giving consideration to conducting both higher-speed
sled tests and in-vehicle NCAP testing in conjunction with the Ease of
use rating. This document provides a review of the information and
reasoning used by the agency to reach that conclusion, describes the
rating systems planned to meet the TREAD requirements, and seeks
comment on this plan.
DATES: You should submit your comments early enough to ensure that
Docket Management receives them not later than Janaury 7, 2002.
ADDRESSES: You should mention the docket number of this document in
your comments and submit your comments in writing to: Docket
Management, Room PL-401, 400 Seventh Street, SW., Washington, DC,
20590.
You may call Docket Management at 202-366-9324. You may visit the
Docket from 10 a.m. to 5 p.m., Monday through Friday.
FOR FURTHER INFORMATION CONTACT: For issues related to a performance
rating, you may call Brian Park of the New Car Assessment Program (NPS-
10) at 202-366-6012.
For issues related to a compatibility/ease of use rating, you may
call Lori Miller of the Office of Traffic Safety Programs (NTS-12) at
202-366-9835.
You may send mail to both officials at National Highway Traffic
Safety Administration, 400 Seventh St., SW., Washington, DC, 20590.
SUPPLEMENTARY INFORMATION:
I. Overview
II. 2000 Public Meeting and Draft Child Restraint Systems Safety
Plan
A. 2000 Public Meeting
B. 2000 Child Restraint Systems Safety Plan
C. Public Comments About Child Restraint Ratings
III. CRS Dynamic Performance Rating Programs
A. Existing Programs for Rating Dynamic Performance of CRS
1. Consumer's Union
2. Japanese NCAP
3. Australian CREP
B. Existing Programs for Rating Dynamic Performance of Vehicles
Equipped with CRS
1. Euro NCAP
2. Australia
C. CRS Dynamic Testing by IIHS
D. CRS Dynamic Testing within NHTSA
1. CRS Performance in FMVSS No. 213 Sled Testing
a. Advantages
b. Disadvantages
2. CRS Performance in Higher-speed Sled Testing
a. Advantages
b. Disadvantages
3. CRS Performance in NCAP Frontal Vehicle Testing
a. Advantages
b. Disadvantages
IV. Child Restraint Ease of Use Rating
A. Child Passenger Safety Selection, Use, and Installation
Website
B. Summary of Existing Ratings for Ease of Use
1. Australia
2. Consumer's Union
3. Euro NCAP
4. ICBC.
5 Japan
C. Planned Child Restraint Ease of Use Rating System
1. Assessment of Existing CRS Ease of Use Rating Systems
2. Four Rating Categories
a. Ready to Use
b. Evaluation of Labels/Instructions
c. Securing the Child
d. Installation in Vehicle
3. Weighting the Features
4. Ease of Use Rating Protocol
5. Overall Ease of Use Rating
V. Discussion and CRS Rating System Proposal
VI. Combined Child Restraint Rating
VII. Distribution
VIII. Submission of Comments
Figures
Table
Appendices
Appendix A
Appendix B
Appendix C
Appendix D
I. Overview
Congress has directed the National Highway Traffic Safety
Administration (NHTSA) to develop a child restraint safety rating
system that is practicable and understandable (Section 14 (g) of the
Transportation Recall Enhancement, Accountability, and Documentation
(TREAD) Act, November 1, 2000, Pub.L. 106-414, 114 Stat. 1800) and that
will help consumers to make informed decisions when purchasing child
restraints. Section 14(g) reads as follows:
(g) Child restraint safety rating program. No later than 12
months after the date of the enactment of this Act, the Secretary of
Transportation shall issue a notice of proposed rulemaking to
establish a child restraint safety rating consumer information
program to provide practicable, readily understandable, and timely
information to consumers for use in making informed decisions in the
purchase of child restraints. No later than 24 months after the date
of the enactment of this Act the Secretary shall issue a final rule
establishing a child restraint
[[Page 56147]]
safety rating program and providing other consumer information which
the Secretary determines would be useful (to) consumers who purchase
child restraint systems.
In response to this mandate, the agency reviewed presentations
given at a public meeting in February 2000, and comments submitted in
response to a notice announcing a draft Child Restraint Systems Safety
Plan. The agency also examined other existing and proposed child
restraint programs. Four options that emerged were: (1) A rating based
on Federal Motor Vehicle Safety Standard (FMVSS) No. 213 compliance
tests (sled tests), (2) a rating based on higher-speed sled testing,
(3) a rating based on in-vehicle testing, and (4) a rating based on
ease of use. The agency then further explored each option to determine
if it would generate information that is practicable, repeatable, and
appropriate.
After considering the various options, NHTSA has tentatively
concluded that the most effective consumer information system is one
that gives the consumer a combination of information about child
restraints' ease of use and dynamic performance, with the dynamic
performance obtained through higher-speed sled testing and/or in-
vehicle NCAP testing. The agency is also giving consideration to
conducting both higher-speed sled tests and in-vehicle NCAP testing in
conjunction with the ease of use rating.
This notice is arranged as follows. First, the notice will discuss
the February 2000 public meeting and the draft Child Restraint Systems
Safety Plan, and the comments received from the public. Second, the
notice will discuss other existing and proposed performance ratings,
the research NHTSA has done, and NHTSA's current plan for rating child
restraint performance. Third, the notice will discuss other existing
and proposed ratings based on compatibility and/or ease of use, and
NHTSA's current plan for rating child restraint ease of use. Fourth,
the notice will discuss why NHTSA is not planning a summary rating for
child restraints. Last, the notice will briefly discuss how NHTSA plans
to distribute child restraint ratings to the public.
II. 2000 Public Meeting and Draft Child Restraint Systems Safety
Plan
A. 2000 Public Meeting
On February 9, 2000, NHTSA conducted a public meeting in
Washington, DC, to discuss the safety performance of child restraint
systems and options for giving consumers information on the safety
performance of different child restraints (65 FR 1224, January 7, 2000,
Docket No. NHTSA-2000-6628). The announced topics were voluntary
standards, strategies for enhancing compliance margins, improved
labeling, and possible ways of rating child restraint performance.
B. 2000 Child Restraint Systems Safety Plan
On November 27, 2000, NHTSA published a notice requesting comments
on a draft Child Restraint System Safety Plan (65 FR 70687, Docket No.
NHTSA-2000-7938). The overall goal of NHTSA's Child Restraint Systems
Safety Plan was to reduce fatalities and reduce injuries to U.S.
children aged 0-10 years who are involved in crashes. To realize this
goal, the plan employed three key strategies: encourage correct use of
child restraints for all children, ensure that child restraints provide
optimal protection, and give consumers useful information about
restraining their child.
C. Public Comments About Child Restraint Ratings
Several presenters at the public meeting and commenters to the plan
addressed the idea of a performance rating based on compliance margins.
The concept of compliance margins is based on Federal Motor Vehicle
Safety Standard (FMVSS) No. 213, Child Restraint Systems (49 CFR
571.213). Under this concept, child restraints would be ranked
according to how large a margin they passed the standard's performance
criteria. The larger the margin that the child restraint passed the
standard by, the higher the child restraint would be ranked. A Maryland
Child Safety Technician suggested the use of compliance tests to
develop ratings, citing sufficient differences in crash test results.
However, he voiced concerns whether such a rating system could address
the issue of vehicle compatibility.
Other commenters opposed the development of a CRS rating based on
the compliance margin. Juvenile Products Manufacturers Association,
Inc. (JPMA) stated that, ``while the current FMVSS No. 213 standard
provides an exceptional rating system (essentially an easily-understood
pass-fail), the industry would certainly consider some other type of
performance rating system.'' However, JPMA noted that with so many
variables, it is likely that a rating system may have a potentially
negative effect rather than a positive one. JPMA thought it appropriate
also to mention that ``the current dynamic standard, FMVSS No. 213, is
more severe than about 95 percent of all crashes, and the historical
performance of PROPERLY USED car seats both in testing and in the field
is exceptional, better even than seat belts.'' \1\ Ford Motor Company
and other child safety experts suggested that the agency consider
having a rating system only after revising FMVSS No. 213. They stated
that the current standard sled pulse is too severe and the test
protocol is outdated. These commenters recommended that the revised
standard should reflect the current child passenger environment.\2\
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\1\ Robert Waller, Jr., Juvenile Products Manufacturers
Association, Inc., Docket 6628.
\2\ Comments on Child Restraint System Ratings, Ford Motor
Company, Docket 7938.
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Commenters addressed the idea of including child restraints in
frontal New Car Assessment Program (NCAP) tests. Evenflo supports the
addition of child restraints to NCAP tests. The company believes that
because the performance requirements of FMVSS No. 213 are so demanding,
all child restraints passing such a standard deserve a high rating.
Evenflo believes that distinguishing safety performance between child
restraints that pass FMVSS No. 213 is difficult. The company also feels
that the addition of child restraints to NCAP tests will allow for an
evaluation of how well the child restraint system works with the
vehicles.\3\ ARCCA, Inc., favors the incorporation of child restraints
into NCAP tests. ARCCA stated that, NCAP tests more closely replicate
real world conditions than the FMVSS No. 213 compliance tests. In
addition, the incorporation of child restraints into the program would
maximize its benefits.
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\3\ Evenflo Company, Inc., Randy Kiser, Docket 7938.
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Both Partners for Child Passenger Safety \4\ and Graco Children's
Products \5\ oppose adding child restraint systems to NCAP crash tests.
These organizations believe that the performance of child restraints in
NCAP tests may be characteristic of the child restraint, the vehicle,
or the restraint/vehicle interaction. This poses questions as to the
significance of the results of such tests. Ford agrees with these
comments, adding that vehicle/CRS interface factors and various vehicle
crash pulses obscure the results of child restraint performance in NCAP
tests.\6\
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\4\ Partners for Child Passenger Safety, Flaura K. Winston, MD,
PhD, Dennis R. Durbin, MD, MSCE, Kristy Arbogast, PhD, Shannon D.
Morris, Docket 7938.
\5\ Graco Children's Products, Steve Gerhart, David E. Campbell,
Docket 7938.
\6\ Comments on Child Restraint System Ratings, Ford Motor
Company, Docket 7938.
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Consumers and consumer advocates almost universally expressed the
opinion that any child restraint rating
[[Page 56148]]
should include factors for compatibility with various vehicles and ease
of use. These commenters noted that a good performance rating would be
meaningless if the child restraint was not compatible with the
consumer's vehicle or was difficult to use properly.
The Insurance Corporation of British Columbia (ICBC) claimed that
high misuse rates of child restraints are a common finding. Children
aged 3 years and older are restrained, most often, only in adult seat
belts. To compensate for misuse, ICBC recommended that the NHTSA
establish an ease of use rating.\7\ Evenflo also feels that the most
problematic area, the area in which improvement would have the greatest
positive impact, is in the nonuse and misuse of child restraints.\8\
The Automotive Coalition for Traffic Safety (ACTS) agreed, and stated
that the dynamic performance of child restraints should not be a big
issue. ACTS further suggested, however, that the recent addition of the
top tether should reduce misuse. The University of North Carolina (UNC)
Highway Safety Research was also a proponent of an ease of use rating.
They stated that the crash test performance of child restraints is only
part of the information that should be incorporated into a rating
system. Safety Belt Safe concurred, mentioning that even top-rated
systems are difficult to use. They stated that child restraint ratings
should be based on real-world conditions and behavior, not solely on
crash tests. Graco Children's Products, Inc. also asked that a rating
system be based on more than simply crash performance. They suggested
that other factors such as labeling and instruction clarity, ease of
installation and vehicle compatibility, fit of child, and ease of use,
be included.
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\7\ Identification and Publication of Relative Performance of
Different Child Restraint Systems, Insurance Corporation British
Columbia, Betty Brown, Docket 6628.
\8\ Evenflo Company Inc., Randy Kiser, Docket Number: 7938.
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One manufacturer expressed concern about starting an ease of use
rating system. The manufacturer asked what type of person would do the
evaluating. This manufacturer believed that it would be a good idea to
have inexperienced people conduct the evaluation of child restraint
systems. The manufacturer suggested using the same people gives
consistency in test methodology. This commenter thought the agency
might have difficulty getting the same people always. The child
restraint manufacturers also believed that a rating system would drive
the child restraint manufacturers to improve their products and provide
more ease of use features.
NHTSA met with two manufacturers of child restraints, Britax and
Evenflo. These two manufacturers both stated that the seats with higher
cost are the restraints with more advanced features which are likely to
be ease of use features. Both manufacturers described how a child
restraint rating system might affect the retail market. They believed
that the retail buyers would limit their purchases of child restraints
to those with high ratings. Consequently, the agency might drive the
retail market to the seats with the higher prices.
III. CRS Dynamic Performance Rating Programs
A. Existing Programs for Rating Dynamic Performance of CRS
1. Consumer's Union
The July 2001 issue of Consumer Reports was the Consumer's Union's
most recent report on child restraints.\9\ They gave a rating for the
dynamic performance of each child restraint, which is part of the
overall rating given to child restraints. This overall rating is the
averaged score of dynamic performance, ease of use, installation, and
stroller use. The installation score is determined by how securely a
child restraint can be installed in three different cars with different
seats and safety-belt types. Ease of use evaluates how difficult it is
to adjust the straps and the harness. A stroller score is also given to
applicable child restraints. This score is based on the safety,
convenience, and the durability of the child restraint and stroller.
The dynamic score was determined from a sled test representing a 30 mph
(48 km/h) frontal crash. The seats were tested using dummies that
approximate an infant, 3-year-old toddler, and 6-year-old child. Head
Injury Criterion (HIC), chest G, head excursion, and knee excursion
were compared with the injury criteria established by NHTSA to
determine the dynamic performance rating.\10\ A six-category range was
used to rate child restraints based on the dummy measurements. The six
categories were: Not Acceptable, Poor, Fair, Good, Very Good, and
Excellent.
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\9\ Consumer Reports, Traveling With Kids, July 2001.
\10\ Pittle, Greenberg, Galeotafiore, Champion, Comments of
Consumer Union to the National Highway Traffic Safety Administration
on the Child Restraint System Plan, Docket Number: NHTSA-7938, 2001.
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The child restraints of the 2001 survey were tested both with and
without the top tether. The results from this study showed that all but
one child restraint provided better protection while using the top
tether in frontal crashes.
2. Japanese NCAP
The Ministry of Land, Infrastructure, and Transport (MLIT) in Japan
recently announced a proposal to rate child restraint systems. MLIT is
asking for comments at this time. Japanese NCAP proposes to evaluate
baby seats (rear-facing) and infant seats (forward-facing or
convertible). They do not plan to test bed-type-seats or booster seats.
Nine-month-old and three-year-old child dummies will be used for the
evaluation.
Child restraints will be tested in frontal sled tests. Child
restraints will be tested using the ECE Reg. 44 crash pulse at 35 mph
(56 km/h) in a Toyota Estima (similar to the Sienna in the U.S.) sled
buck. A rating system will comprise the dummy readings, the level of
physical damage, release of CRS anchorage, and dummy kinematics. A
four-tier rating system will be used: Excellent, Good, Acceptable, and
Not Recommended.
3. Australian CREP
The Child Restraint Evaluation Program (CREP) is a joint program
run by many of the same groups as Australian New Car Assessment Program
(ANCAP). CREP tests child restraints in dynamic sled tests with a top
tether, which is required in Australia. Two frontal crashes are
simulated at 49 and 56 km/h (30 and 35 mph). Side and rear crashes are
simulated at 32 km/h (20 mph). CREP conducts another test at the same
speed, but with the CRS positioned at a 45 deg. angle relative to the
sled. One additional dynamic test is done to rear-facing and
convertible child restraints only. This is an inverted test conducted
at 16 km/h (10 mph) to simulate a rollover.
CREP gives a rating, incorporating both the dynamic test results
and ease of correct use results. They report these ratings as either
preferred buy or standards approved. The preferred buy seats did well
in the dynamic tests and the ease of correct use tests. The standards
approved rating is given to seats that passed the 49 km/h (30 mph)
test, but had excessive head movement or broke a load-bearing component
during the 56 km/h (35 mph) test.\11\
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\11\ www.nrma.com.au, July 23, 2001.
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[[Page 56149]]
B. Existing Programs for Rating Dynamic Performance of Vehicles
Equipped With CRS
1. Euro NCAP
The European New Car Assessment Program evaluates the safety of
children in vehicle crash testing. The subject vehicle's manufacturer
provides a recommendation for which child restraints are to be used
during the tests. The Europeans install child restraints in vehicles
and subject them to offset frontal and side impact tests. In the offset
frontal testing, two child crash dummies are placed in the back of the
test vehicle. The two types of child dummies used in the test are a 3-
year-old P dummy and an 18-month-old infant P dummy. Both dummies are
placed in the appropriate CRS, either forward-facing or rear-facing,
designated for their ages. For the side impact test, the dummies are
secured in the same model child restraint used for the offset frontal
crash test.
Euro NCAP evaluates dummy kinematics. In addition, technicians
evaluate ease of use, ease of installation in the vehicle, and how
securely they can install the CRS. Currently, Euro NCAP does vehicle
tests for child restraints without using a top tether. Euro NCAP gives
points based on the dynamic performance of the child dummies during the
full-scale crash tests. These points are subject to modifiers that will
reduce the points earned. Such modifiers include penalties for
ejection, poor seat labeling, and vehicle incompatibilities. A total of
four points is possible for the child scores. These points are added to
the overall total, which is used to determine the vehicle's star
rating. However, if any anomaly leads to a dangerous event (e.g., if
the child seat breaks or if a belt becomes unlatched), Euro NCAP notes
the event to consumers in their publications and web site.\12\
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\12\ http://www.euroncap.com/results.htm, August 23, 2001.
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2. Australia
The Australian New Car Assessment Program (ANCAP) harmonized its
testing procedures with Euro NCAP in 1999. Therefore, in accordance
with the Euro NCAP procedures, ANCAP does both an offset frontal crash
at 64 km/h (40 mph) and a side impact test at 50 km/h (31 mph). Two
child restraints are placed in the rear seat of each vehicle. TNO P1.5
(18-month) and P3 (3-year-old) dummies are used to assess injury. ANCAP
plans to rate the dynamic performance of child restraints in vehicle
tests, however, the rating protocol will likely be different from that
published by Euro NCAP.
C. CRS Dynamic Testing by IIHS
The Insurance Institute for Highway Safety (IIHS) currently does
not rate child restraints. However, IIHS recently did several vehicle
frontal crash tests that included child restraints. Vehicle velocities
in these car-to-car tests were 48 km/h (30 mph), and vehicle frontal
engagement ranged from 49% to 89%. Dummies used in the testing were the
6-month-old Infant CRABI, the 12-month-old CRABI, and the 3-year-old
Hybrid III.
IIHS evaluated the dummy results for the 6-month-old CRABI, the 12-
month-old Infant CRABI, and the 3-year-old Hybrid III. They used the
corresponding reference values specified in the May 12th, 2000 Federal
Register notice for FMVSS No. 208.\13\ The results for the 6-month-old
CRABI and the 12-month-old CRABI were all well below the allowable
limits. The results for the 3-year-old Hybrid III dummy showed all
injury readings were less than the reference values except for neck
tension. IIHS suggested that these results mean the current neck
tension criterion overestimates the possibility of an AIS \14\
3 injury.\15\
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\13\ Notice for FMVSS No. 208, Federal Register, Vol. 65, No.
93, page 30680, May 12, 2000.
\14\ Association for the Advancement of Automotive Medicine, The
Abbreviated Injury Scale, Des Plaines, 1990.
\15\ Susan Meyerson & Adrian Lund, Insurance Institute for
Highway Safety, ``Child Restraint Durability in High-Speed
Crashes,'' 2001 SAE conference, SAE2001-01-0123.
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D. NHTSA CRS Dynamic Testing
In response to the TREAD Act, NHTSA examined three dynamic test
methods for rating child restraint systems. The first dynamic option
was a sled test at 30 mph (48 km/h). This option would use the results
of the FMVSS No. 213 compliance testing to determine a rating. Two
possible rating schemes could be used to rate or rank the child
restraint dynamic performance. One possible rating scheme would be
based on the compliance margins with which a dummy met the limits of
the standard on HIC, chest acceleration, head excursion, and knee
excursion. A second rating scheme would use the injury risk curves that
NCAP uses to rate adult occupant protection in a frontal crash. Scaling
these curves to represent a 3-year-old child would produce a five-star
classification system. The probability of injury for the 3-year-old
child is as follows:
Phead = [1+exp(5.02-0.00431*HIC)]-1
Pchest = [1+exp(5.55-0.0756*ChestG)]-1
A second dynamic testing option examined was a high-speed sled test
at 35 mph (56 km/h). This test method would be similar to the current
FMVSS No. 213 compliance test; however, the sled acceleration pulse
would have a greater magnitude to increase the speed to 35 mph (56 km/
h). A third dynamic testing option considered was a full-scale crash
test. This approach would add a child restraint in the rear seat of a
vehicle when it is tested for frontal NCAP, and rate the vehicle on how
well the CRS and vehicle work together to protect the child. These last
two options would also use the scaled injury risk curves for a rating.
Each of the next three sections describes the testing conducted by
the agency to assess each of the proposed options. The summaries review
the trends of child restraint system (CRS) responses in the Federal
Motor Vehicle Safety Standard (FMVSS) No. 213 sled testing, higher-
speed sled testing, and frontal NCAP in-vehicle testing.
1. CRS Performance in FMVSS No. 213 Sled Testing
As specified in Standard No. 213, 49 CFR Sec. 571.213, the agency
does compliance testing of child restraints on a sled buck at a nominal
speed of 30 mph (48 km/h). Currently, a Hybrid II dummy is used in
testing to represent a 3-year-old child.
In model year 2000, the agency tested 50 upright, forward-facing
child restraints according to FMVSS No. 213. Twenty-four seats were
tested without a top tether, and 26 seats were tested with a top
tether. We restrained all seats with only a lap belt (no lower
anchorage or shoulder belt). The pertinent test results are tabulated
in the Appendix, Table A2.
Currently, to pass the FMVSS No. 213 compliance test, a child
restraint must achieve dummy injury numbers of a Head Injury Criterion
(HIC) less than 1,000 and a resultant chest acceleration of less than
60 G's. For the compliance tests, HIC is calculated using an unlimited
period and chest acceleration uses a 3 ms clip. As shown in Figure 1,
regardless of whether we equipped the child restraints with a top
tether, all child restraints achieved dummy injury readings below the
maximum allowable values. Figures 2 & 3 illustrate the margin of
compliance for HIC and chest acceleration, respectively. The margin of
compliance is one minus the measured injury reading divided by the
injury assessment reference value (IARV) times 100. Higher percentages
are better, having less probability of injury. Regarding the HIC, all
model year 2000
[[Page 56150]]
child restraints tested easily fall within the limits specified by the
FMVSS No. 213 compliance tests. Most had a compliance margin of more
than 50%. Although the margin is not as large for chest acceleration,
all tested child restraints passed this compliance requirement as well.
FMVSS. No. 213 also has a requirement for head and knee excursion.
Head excursion is limited to 720 mm (28 in) when a top tether is used,
and 813 mm (32 in) without use of a top tether. Knee excursion is
limited to 915 mm (36 in). Figures 4 & 5 illustrate the margin of
compliance for head excursion and knee excursion, respectively. Head
and knee excursion limits are compliance limits imposed to reduce the
chances of a child striking the vehicle interior or submarining
(sliding under the belt feet first) in an automotive crash. Head and
knee excursions are much closer to the compliance limits than HIC and
chest acceleration. (This may reflect attention to occupant protection,
since increases in distance traveled by the occupant reduces the forces
experienced by the occupant.)
To further investigate the possibility of using FMVSS No. 213
compliance testing to rate child restraints, NHTSA performed additional
sled tests to gather child restraint protection data. These sled tests
were performed in accordance with the specifications outlined in FMVSS
No. 213 compliance tests, with two exceptions. The three-year-old
Hybrid III dummy was used to assess injury rather than the Hybrid II
dummy. Also, the current compliance test secures child seats in two
configurations, lap belt only and lap belt with top tether. These
additional sled tests secured the child seat with the lap/shoulder belt
and tether. One child restraint tested was secured with LATCH.\16\
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\16\ ``LATCH'' is a term used by industry and retail groups
referring to the child restraint anchorage system required by
Federal Motor Vehicle Safety Standard No. 225. LATCH stands for
``Lower Anchorages and Tethers for Children.'' The term is used to
refer to vehicles equipped with the anchorage system (e.g., ``LATCH
vehicles'') and to child restraints equipped with attachments that
connect to the anchorage system (e.g., ``restrained with LATCH,'' or
``LATCH child restraints''). For convenience, we will use the term
in this notice.
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Nine child restraints were tested. Figure 6 shows the individual
plots of chest acceleration versus HIC. Injury risk curves are also
plotted, and illustrate that eight of the nine child restraints would
receive a 5 star rating, while the other one would be borderline 5
star/4 star.
Advantages and Disadvantages of a Rating System Based on FMVSS No. 213
Compliance Testing
a. Advantages
--Ratings for most child restraint systems could be implemented quickly
and inexpensively using Hybrid II results now obtained in Standard No.
213 compliance testing.
--The compliance testing is a simple pass and fail rating system.
Carrying out a rating based on the margin of compliance is
straightforward. The performances of child restraints could be used as
a rating system.
--The rating system based on sled testing subjects all child restraints
to the same impulse loading, so child restraint performance is assessed
with little or no influence of outside variables.
b. Disadvantages
--FMVSS No. 213 is currently under revision. Ford Motor Company and
others suggest that the agency consider delaying the child restraint
safety rating until after the revision of FMVSS No. 213.
--A rating based on dynamic sled testing does not take into account the
compatibility between child restraints and vehicles. Many people
believe that a child restraint and a subject vehicle must be evaluated
as a system to effectively assess child safety protection.
--To the extent that current child restraints all exceed the standard
by a wide margin, as in the case for HIC, the compliance margin may not
meaningfully distinguish among child restraints. For example, if we use
the star rating system, nearly every child restraint would get 5 stars.
If we use the percentage of compliance margin, should we tell the
public a child restraint with a 60% margin is safer than one with a 55%
margin? Also, it would be difficult to explain to the public which
compliance margin (i.e., HIC, chest acceleration, excursions) is more
important to safety.
2. CRS Performance in Higher-speed Sled Testing
Some commenters suggested that the agency should consider having a
child restraint rating based on sled tests at a higher speed (35 mph)
than the compliance testing (30 mph). As NCAP currently tests motor
vehicles at 5 mph (8km/h) above the compliance tests, the same
reasoning could be applied to the sled testing of child restraints. (It
was also recommended that the rating system use a realistic vehicle
pulse and a vehicle seat as part of the test condition.) To determine
the viability of developing an effective rating system as a consumer
program for child restraint testing, the agency has conducted higher-
speed sled testing.
NHTSA conducted higher-speed sled tests using the same nine child
restraints as in the previous section. The same FMVSS No. 213 test
procedure was used with Hybrid III three-year-old dummies. To attain
the higher speed, a sled pulse with a similar shape and duration length
as that of the 213 pulse was used, except that the change-of-velocity
was elevated from 30 mph (48km/h) to 35 mph (56km/h).
All of the child restraints tested produced dummy injury
measurements well below the FMVSS No. 208 criteria of 570 HIC and 55g
chest acceleration. Figure 7 shows the results plotted with the NCAP
injury risk curves. Although the injury assessment values are slightly
greater for the 35 MPH (56 km/h) sled tests than the 30 mph (48 km/h)
sled test (shown in Figure 6), eight of the nine child seats fell
within the 5 star range, and one fell just below in the 4 star range.
Advantages and Disadvantages of a Rating System Based on Higher-speed
Sled Tests
a. Advantages
--Running tests at higher speeds is the same approach we have used for
front and side crashworthiness ratings in NCAP, and would be expected
to magnify performance differences among child restraint systems beyond
that obtained in compliance testing.
--A rating based on sled performance would be consistent because all
child restraints would be subjected to the same impulse loading and
would be placed on the same simulated seat.
b. Disadvantages
--A rating based on a higher sled test speed would again not take into
account compatibility between child restraints and vehicles. Many
people believe that a child restraint and a subject vehicle must be
evaluated as a system to effectively assess child safety protection.
--A higher test speed with the Standard No. 213 crash pulse may be so
severe that the information would not be a helpful indicator of
expected CRS performance in the majority of real-world crashes.
--Based on tests with nine child seats, the higher test speed may not
sufficiently ``spread out'' the performance differences to allow NHTSA
to provide meaningful information to the public.
[[Page 56151]]
3. CRS Performance in NCAP Frontal Vehicle Testing
The agency evaluates vehicle crashworthiness in frontal and side
impact under the New Car Assessment Program (NCAP). Under this program,
the agency conducts approximately 40 frontal and 40 side crash tests
each year. For the frontal crash, the agency does these tests with two
50th percentile adult male dummies in the front seat. Historically,
NCAP does not put any occupants in the rear seats of the vehicles.
However, because there is room in the rear seats of most vehicles, it
has been suggested that NHTSA add child restraints to the rear of NCAP
frontal crash tests.
NHTSA has evaluated child restraints in frontal crash tests
conducted under the New Car Assessment Program. In model year (MY) 2001
testing, NCAP used various child restraints in the rear seats of
vehicles undergoing frontal NCAP crash tests. Child restraints were
placed in a total of twenty NCAP vehicles, varying in type and size.
The agency evaluated performances of six different five-point-harness
forward-facing child restraints. The evaluation assessed (1) the
variability of CRS performance in various vehicle types and sizes, (2)
CRS/vehicle interaction, and (3) performance among different child
restraints. CRS performance in the NCAP vehicle tests is shown in Table
A1 in the Appendix.
In each vehicle tested, the subject child restraint was secured
tightly, and as prescribed by the child restraint manufacturer's
instructions. In addition, all child restraints, whether secured with
LATCH or secured with a lap/shoulder belt, used a top tether. A Hybrid
III three-year-old dummy was used to assess performance. All testing
used the full instrumentation package available for the child dummy.
The injury assessment reference values for FMVSS No. 208 were used to
evaluate the results.
Figure 8 shows the overall child dummy performance concerning the
Head Injury Criterion (HIC 15) and resultant chest acceleration,
plotted with the NCAP injury probability curves scaled for the three-
year-old. The performance is shown for child restraints with LATCH or
with a belt restrained CRS with a top tether. As shown, many (38.7%)
dummy readings exceeded the allowable injury criterion for HIC 15 (570)
or the allowable chest G criterion (55 G's). Using the star rating
system, most vehicles would be rated with 3 or 4 stars for rear seat
child occupancy protection. Five samples had injury readings low enough
for a five-star rating; only one vehicle was rated with two stars. This
is in contrast to driver and right passenger frontal NCAP test results
which result in about 88% 4 and 5 star ratings.
All seats tested in the NCAP vehicle crash tests used five-point
harnesses, while the FMVSS No. 213 tests use all types of harnesses.
Figure 9 shows the model year 2000 compliance tests results for only
seats with a five-point harness and lap belt only. This graph shows
that the tethered seats produced lower HIC responses than those seats
without a top tether. The HIC responses for both the tethered and the
non-tethered seats are clustered among their respective seat types. In
comparing the data in Figures 8 and 9, we may infer that the full-scale
crashes produce a greater range of values for the Head Injury
Criterion. One could further infer that the greater range of HIC
response shown in the NCAP data of Figure 8 is due not only to the
child restraint, but also due to crash variations, such as crash pulse,
belt geometry (important for child restraints that use a lap/shoulder
belt), seat contour, and seat cushion stiffness.
The influence of these additional factors for crash testing is
shown more clearly in Figure 10. Figure 10 shows seven vehicles that
underwent NCAP crashes with the Cosco Triad child restraint. As shown,
the Cosco Triad did not give the same performance in these seven NCAP
vehicles. HIC injury values varied from approximately 300 to 650. The
performances of the Evenflo Horizon V and the Fisher Price Safe Embrace
II show like trends in vehicle testing. This is shown in Figure A1 in
the Appendix.
The agency has conducted this testing to address whether a specific
child restraint would do the same in various NCAP vehicles. We
determined that the answer is no. The agency next examined whether
various child restraints would do equally well in a specific vehicle.
Figure 11 shows the relative performance of four different CRSs
crashed in two different minivans. Two crash tests were conducted with
each minivan, and there were two child restraints placed in the rear
seat for each test. The first Grand Caravan was tested with the Century
STE and Horizon V. The second time, it was crashed with the Safe
Embrace II and the Horizon V. For the Ford Windstar, the first test had
two Safe Embrace II child restraints in the rear seat; in the second
test, Cosco Triad child restraints were used. All child restraints in
each comparison were restrained with either LATCH (which includes a top
tether) or a lap/shoulder belt and a top tether. Although the data are
extremely limited, and there was only one CRS (Safe Embrace II) that
was used in both vehicles, CRS performance appeared to be better when
tested in the Ford Windstar, and may be an indication that the vehicle
has an influence on child safety protection.
Figures 12 & 13 show vehicle crash pulse duration and acceleration
peak versus chest acceleration. Although there is considerable scatter
in the data, there appear to be slight trends, which would indicate
that the vehicle's structural response could have an influence on the
child restraint performance. Figure 12 suggests that, as the time
duration of the crash increases, there is a reduction in chest
acceleration. Figure 13 shows that, as the peak acceleration of the
vehicle increases, there is a trend toward higher chest acceleration.
(The agency did not find similar trends for the Head Injury Criterion.)
Based upon this limited amount of data, it appears that a child
restraint tested in a vehicle with good crash pulse characteristics
(i.e., longer time duration, lower peak acceleration) could perform
better than the same child restraint tested in a vehicle that does not.
Further, good performance does not depend upon cost of the CRS. The
agency examined the cost of child restraints (MY 2000) versus the
relative performance of forward-facing child restraints tested with the
three-year-old dummy in FMVSS No. 213 sled tests. Figure 14 shows no
correlation between the cost of child restraints and their performance
in dynamic sled testing. For the low IARV's, (HIC 400 and chest G 40),
there are CRS from all price ranges. In addition, the two CRS with the
highest HIC and chest G responses were in the $100-$150 cost range
(i.e., a high cost range). Therefore, the limited available data show
that a CRS need not be expensive to provide good child protection.
Advantages and Disadvantages of Rating a Vehicle Equipped With a Child
Restraint
Unlike the rating systems proposed for the sled tests at 30 mph (48
km/h) and 35 mph (56 km/h) which rate only the child restraint, this
option would rate the vehicle equipped with a CRS as a system in
protecting the child.
The following discusses the pros and cons of basing a rating system
on in-vehicle testing of child restraints.
a. Advantages
--In-vehicle testing would address the interaction of the vehicle and
the child restraint in overall safety
[[Page 56152]]
performance, since it would encourage vehicle manufacturers to take
into account child restraint performance in designing vehicles.
--Using in-vehicle testing to evaluate a child restraint in the vehicle
would enhance world harmonization with Euro NCAP and ANCAP.
--CRS testing can be easily incorporated into the New Car Assessment
Program. The NCAP program conducts about 40 frontal crashes annually;
adding child restraints to these tests could be done at a relatively
low cost.
b. Disadvantages
--Such a system would provide a rating for the vehicle rather than the
child restraint. Also, the consumer may mistakenly think that some
child restraints may appear to have poor performance if the agency only
tests them in certain vehicles, when in actuality they may perform well
in other vehicles.
--To the extent that the agency only tests a child restraint in
vehicles that perform well, that information may mislead the public
about the protection offered by that child restraint in lesser-
performing vehicles.
--This rating system would not help consumers choose a child restraint
suitable for an older vehicle model.
--Adding the CRS and dummy to the NCAP vehicle would require the
removal of fluids and/or vehicle components to attain the test weight,
and thereby potentially influence assessment of other NCAP crash
results such as fuel leakage.
IV. Child Restraint Ease of Use Rating
A. Child Passenger Safety Selection, Use, and Installation Website
In addition to implementing a child restraint rating program, NHTSA
has also been mandated by Congress to consider how to provide consumer
information on the physical compatibility of child restraints and
vehicle seats on a model-by-model basis (Section 14(b)(4) of the TREAD
Act).
In May 1995, the Blue Ribbon Panel on Child Restraint and Vehicle
Compatibility made a series of recommendations including a suggestion
that vehicle manufacturers create a chart illustrating which hardware
and what procedures of installation were necessary to ensure proper
installation of child restraints in vehicles. In the Fall of 1995,
NHTSA considered this recommendation and at the time, determined that
the agency would try to develop a child restraint and vehicle
compatibility database and make it available on a CD-ROM to child
passenger safety advocates and others who assist the public with child
safety education and proper installation. It was believed that the
program would allow the cross-referencing of data regarding specific
child restraints considering the weight and age of the child, vehicle
make, model and year choices indicating available seating locations,
resulting in a list of compatible child restraints and vehicle seating
and installation information. The original plan was to have a database
containing child restraint installation information for 100 different
1993-1996 model year vehicles, using 35 child restraints.
Over the course of developing this database, it became apparent
that collecting data on several child restraints in hundreds of
vehicles, resulting in the combination of thousands of child
positioning possibilities was inherently subjective, prohibitively
expensive, and very labor intensive. In addition, the information that
would be available to assist consumers was limited to a certain type
vehicle and a certain type child restraint, which would serve only a
small number of consumers. Further, the LATCH rulemaking will greatly
enhance the compatibility of child restraints and vehicles, which
reduces the need for a CD-ROM database. Realizing these limitations,
NHTSA began to explore ways in which we could develop a service that
would provide accurate and up-to-date information to consumers on how
to properly select the appropriate restraint for their child, and use
and install it properly. In addition, NHTSA wanted to utilize the
infrastructure of trained and certified child passenger safety
technicians (over 19,000 to date) throughout the country.
In March 2001, NHTSA developed and made available an internet-based
service on its website, providing recommendations for the correct use
of each type of child restraint to help consumers select the most
appropriate child restraint system (http://www.nhtsa.dot.gov/people/
injury/childps/csr2001/csrhtml/safetyFeatures.html). It provides a
current listing, along with pictures, of all new child restraints
available along with a list of various features available on the child
restraints that may make them easier to use and install. It provides a
list of model year 2001 vehicles with child restraint features, as well
as vehicle owner's manual instructions for child restraint
installation. In addition, this website application includes pictures
of proper use and step-by-step instruction on installation. It also
describes and shows common compatibility problems between vehicles and
child restraints and offers solutions to obtain the best fit. This
website application allows for the continual addition of current and
accurate information, at minimum cost, and significantly expands public
access. The site has received thousands of visits per week since its
placement in March.
This application is not specific to child restraints and vehicles
on a model-by-model basis, as originally intended. However, it provides
guidelines for the selection of the appropriate restraint, tips for
proper use and installation, and points consumers in the proper
direction for installation assistance, by linking to a listing of
thousands of inspection stations located throughout the country where
consumers can go and have their child restraint inspected by a
certified child passenger safety technician. For these reasons, and
because providing the information on a model-by-model basis has proven
to be limited, impracticable, and prohibitively costly, we have decided
that the web-based approach is the appropriate method of providing the
consumer information to the public.
B. Summary of Existing Ratings for Ease of Use
1. Australia
The New South Wales Roads and Traffic Authority (RTA) joined with
the National Roads and Motorists Association (NRMA) and the Royal
Automobile Club of Victoria (RACV) to conduct a joint program to assess
the relative performance of child restraints available in Australia. In
addition to crash testing, the program covers installation, use and
compatibility with a range of vehicles. The child restraints that
performed the best were given a ``preferred buy rating.'' To be awarded
a ``preferred buy rating,'' a child restraint must perform well in
crash tests that are more severe than the Australian Standard and
perform well for ease of correct installation and ease of use.
Child restraint/vehicle compatibility is evaluated by fitting each
restraint in both the rear center and rear left seats of test vehicles.
The vehicles used to evaluate compatibility are the top-selling models
in each of the following categories: large sedan, large station wagon,
small hatchback, medium hatchback, multipurpose vehicle, and large
four-wheel drive. In addition to the determination that the restraint
and vehicle are compatible, the NRMA also evaluates restraints on how
easy they
[[Page 56153]]
were to install in vehicles and how easily children could be secured in
them.
2. Consumer's Union
Consumers Union (CU), a nonprofit membership organization, has been
evaluating child restraints for more than 25 years. Their child
restraint ratings can be found on their web site and in their
publication, Consumer Reports magazine.
Consumers Union tests child restraints for crash protection, ease
of use, and the ability to install properly the restraint with
different seatbelts.\17\ In making its judgment about ease of use the
following attributes are considered:
--Threading vehicle belt through restraint,
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\17\ If an infant restraint is sold with a stroller the stroller
is also evaluated.
---------------------------------------------------------------------------
--Adjusting harness strap position for different size children,
--Adjusting harness strap tension,
--Adjusting ``belt positioner'' on boosters,
--Placing child in the restraint and arranging the harness,
--Engaging/disengaging the harness locking mechanism,
--Ease of installation in a vehicle with and without the detachable
base,
--Ease of disengaging the restraint from a detachable base,
--Carry handle comfort with a 20 pound dummy, and
--Presence of recline angle gauges or indicators and ease of using
recline level adjustment.
All of the items are evaluated subjectively on a five-point scale
(Excellent, Very Good, Good, Fair, and Poor). The crash protection,
ease of use, and installation ratings are also combined into an overall
rating.
3. Euro NCAP
In the European New Car Assessment Program, vehicle manufacturers
recommend the make/model of a child restraint suitable for a 3-year-old
child and a second restraint suitable for an 18-month-old infant. These
restraints are then installed in the rear seat of the vehicle during
the crash tests. Technicians then provide an evaluation of the ease of
installation in the vehicle when setting up the test. NHTSA is not
aware of any defined criteria for this evaluation. The evaluation
provides information about the compatibility of some child restraint
make/models with tested vehicles. In addition, if a vehicle does not
have a device for deactivating a frontal protection air bag, a notation
is made about the quality of the vehicle's warning about the hazards of
air bags with child restraints.
4. ICBC
The Insurance Corporation of British Columbia (ICBC) is a public
agency in Canada that was established in 1973 to provide universal auto
insurance to motorists in British Columbia, Canada. In July 1999, ICBC
invited members of the child restraint usability task force of ISO/
TC22/SC12/WG1 (Child Restraints) to meet in Victoria, BC. The purpose
of the two-day meeting was to prepare a draft document of usability
criteria and objective tests for child restraint manufacturers.
Consumer and insurance representatives who evaluated the ``usability''
of child restraints sold in BC subsequently used the draft document.
The findings were subsequently published in an ICBC brochure called
``Buying a Better Child Restraint.''
Depending on features and type of restraint, the ICBC strategy
rates some or all of the following features:
--Ready to use
--Instructions for use,
--Ease of conversion,
--Labeling on the child restraint,
--Securing the child in the restraint,
--Installation of the child restraint, and
--Tether straps
Several factors are evaluated within each feature category by the
evaluators. The participants in the initial meeting rated each of these
factors A, B or C according to risk and severity of misuse. The factors
with the higher risks of injury if misused were rated ``A,'' while the
factors with the lower risks of injury were rated ``C.'' The evaluators
then rate each factor, based on agreed upon standards, either ``good,''
``acceptable,'' or ``poor.'' This rating is then combined with the A,
B, or C weighting for that factor. All of the ratings for all of the
factors for a feature are combined and an overall rating for that
feature is determined. The ICBC does not combine the ratings for each
feature to develop an overall rating.
5. Japan
The Japanese Ministry of Land, Infrastructure and Transport, in
cooperation with the National Organization for Automotive Safety &
Victims' Aid, tests and evaluates the safety of automobiles currently
on the market in Japan. The results of these tests are publicly
released under the title New Car Assessment Japan. Japan has proposed
rating child restraints as part of its New Car Assessment program in
2002.
In addition to dynamic testing, Japan has proposed rating child
restraints on ease of use. Specialists would rate the restraint in five
categories. These categories are the user manual and other information
(i.e., ease of understanding and accuracy), illustrations and
instructions on the child restraint (i.e., ease of understanding and
accuracy), the safety features of the child restraint (i.e., recline
device, cover, and attachment storage), ease of installation (i.e.,
ease of threading belts and ability to tightly install), and how well
the child restraint fits into the vehicle (i.e., ease of adjustment and
buckle release mechanism).
Japan proposes to rate each item within the five categories using a
5-level rating system. NHTSA was provided with a summary of the
proposal translated into English, which did not indicate what criteria
would be used for each category. The category rating would then be the
average level of each item within that category. A graphical
representation of the ratings would be presented on a ``radar chart''
with a spoke for each of the five categories.
C. Planned Child Restraint Ease of Use Rating System
1. Assessment of Existing Ease of Use Rating Systems
After analyzing all the comments and gathered information, NHTSA
has tentatively decided that it appears possible to have a fair and
repeatable rating for ease of use. The agency has modeled its planned
approach on that used by ICBC, because ICBC uses objective criteria for
what is ``good,'' ``acceptable,'' and ``poor'' for each factor rated.
NHTSA is also proposing to use a weighting system for the relative
importance of each feature within each ease of use category. The agency
is planning to rate ease of use features in four categories as A, B, or
C, with A being the highest rating and C the lowest. In addition, NHTSA
is also considering taking the ICBC rating system one step further by
combining these four ratings into an overall rating for ease of use
using the same scale.
Almost all of the features evaluated by the other programs NHTSA
examined are included in NHTSA's planned program. The difference
between ICBC and the other ease of use rating systems (Australian, CU,
Euro NCAP, and Japanese) was the known objective criteria for each
feature in the ICBC program and the known weighting of the features
within each category in the ICBC program. To the extent that a feature
evaluated by another program is not included in our program, NHTSA has
tentatively determined that it is not a feature related to safety when
using
[[Page 56154]]
the child restraint in a vehicle.\18\ The additional difference between
our planned approach and Euro NCAP is that Euro NCAP only evaluates
those seats that have been selected by vehicle manufacturers for
inclusion in the crash test. NHTSA hopes to be able to evaluate all or
almost all the child restraints available in the US market at the time
of the evaluation.
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\18\ NHTSA requests comments on whether we should delete any of
the features we have proposed to include, or whether we should
include features that we have not included in today's proposal. For
example, should rear-facing restraints be rated according to the leg
room they provide, which may be a feature that would make the
restraint easier to use by infants with long legs?
---------------------------------------------------------------------------
NHTSA personnel spent a day conducting a hands-on evaluation of the
ICBC rating program to determine the repeatability of the program. With
the assistance of a representative of the ICBC rating program, those
present were divided into two teams. Both teams evaluated the same six
seats. Their scores were put in a computer program that incorporates
the weighting. The personnel compared the evaluation scores. While the
teams had some minor differences in ratings for features within each
category, the agency task force team evaluation resulted in 100 percent
repeatability for each category.
While NHTSA agrees that overall, the features selected and rated in
the ICBC program are those that are most subject to misuse, analysis of
each component and review of the evaluation criteria has led NHTSA to
modify slightly the ICBC program. One of the reasons why changes were
made was an effort to simplify the information provided to consumers.
Other changes were made to reflect child restraint standards of the
United States to the extent that they are different from those in
Canada. Last, some modifications were also made based on information
learned from the repeatability exercise. All of the changes are
explained in greater detail below.\19\
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\19\ A copy of the planned evaluation form is included in the
appendices to this notice. Details of the program are discussed only
to the extent that they differ from ICBC's program.
---------------------------------------------------------------------------
2. Four Rating Categories
Depending on features and type of restraint, the ICBC strategy
rates up to seven categories:
--Ready to use,
--Instructions for use,
--Ease of conversion,
--Labeling on the child restraint,
--Securing the child in the restraint,
--Installation of the child restraint, and
--Tether straps
Based upon its assessment, NHTSA is planning to rate four
categories for each restraint:
--Assembly,
--Evaluation of Labels/Instructions,
--Securing the Child,
--Installation in Vehicle,
NHTSA combined labeling and instructions into one category. In
NHTSA's experience, most labels and instructions are stylistically
similar, and therefore any restraint is likely to have the same rating
in each of these categories. In addition, ICBC has indicated and our
experience also showed, that these categories are the least objective.
NHTSA believes that combining them into a single category would reduce
the influence they would have on a combined rating for ease of use and/
or the importance a consumer would place on the individual rating.
NHTSA also moved the criteria for ``Ease of Conversion'' to a
``Securing the Child'' category, since the ease of adjusting a child
restraint for different size children is directly related to the ease
of securing a child in the restraint. Finally, NHTSA moved ``Tether
Straps'' to the ``Installation in Vehicle'' category, because there is
only one criterion related to tether straps, and because this category
also relates to ease of installation in a vehicle.
a. Assembly
NHTSA has decided to include the following features in the
``Assembly'' category:
--All functional parts including seat pad or cover attached and ready
to use
--Tether attached to child restraint
--Owner's manual easy to find
--Obvious storage pocket for manual
NHTSA chose not to include the ICBC feature, ``any other add-ons in
box'' because it is believed that such add-ons, for example extra pads,
cup holders, sun canopy, were not related to ease of use or the safety
function of the child restraint. Any add-on that is to be used and is a
functional part of the restraint or related to correct use of the
restraint is to be included under the ``all functional parts including
seat pad or cover attached and ready to use'' category.
NHTSA has chosen to modify the criteria used to evaluate the
feature, ``obvious storage pocket for manual.'' ICBC defines ``good''
as ``easy access when CRS installed in all modes,'' an ``acceptable''
as ``easy access not accessible when CRS installed in all modes,'' and
``poor'' as ``none found or not easy access/storage (incl. Plastic
tabs).'' During NHTSA's evaluation of the ICBC criteria using several
child restraints, we found that in some cases the storage pocket for
the instructions manual was easily accessible in all modes, however it
was difficult to use. In other words, it was difficult to take the
instructions out of the storage pocket and difficult to put them back
in. With this difficulty, it is believed that if consumers take the
instructions out of the storage pocket they will not put them back.
Therefore, NHTSA's planned criteria are:
--A = Easily accessible when installed in all modes and manual can be
removed and replaced easily
--B = Easily accessible when installed in all modes but manual cannot
be removed and replaced easily (any use of plastic clips as the sole
means of storing the instructions will not be higher than ``B'')
--C = Not accessible when installed in all modes.
NHTSA has also modified the criteria used to evaluate the feature
``owner's manual easy to find.'' ICBC defines a ``good'' as ``yes,
attached to CRS,'' an ``acceptable'' as ``in box,'' and a ``poor'' as
``no.'' NHTSA regulations also require written instructions; therefore
no child restraint manufactured for sale in the United States should
receive a ``poor'' under the ICBC program. However, when evaluating the
ICBC system, both infant restraints we evaluated had the written
instructions attached between the restraint and the detachable base.
This forces the consumer to learn how to release the base from the
infant restraint without the assistance of instructions. NHTSA felt
that a rating should distinguish between written instructions attached
so that they were clearly visible as the restraint was removed from the
box (many had them in a plastic bag attached to the harness) and those
where you had to search for the written instructions. NHTSA also
believes that any form of attachment is preferable to having the
instructions loose in the box, and therefore has moved the ``in box''
criteria to ``C.'' \20\ While NHTSA did not find any restraints that
would have received a ``C,'' NHTSA is concerned that if the
instructions were loose they could be lost before purchase if the box
were damaged or opened for inspection. NHTSA's planned criteria are:
\20\ The agency is mindful that Standard No. 213 requires an
owner registration card to be attached to the child restraint, and
that too many materials attached to the restraint could dilute the
consumer's attention to the registration card. Comments are
requested on whether attaching the owner's manual to the restraint
will overwhelm the card.
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--A = attached to child restraint in a clearly visible location
--B = attached to child restraint but not clearly visible
--C = in box, not attached
[[Page 56155]]
b. Evaluation of Labels/Instructions
NHTSA has decided to evaluate the following features in the
``Evaluation of Labels/Instructions'' category:
--Clear indication of child's size range
--All mode/s of use clearly indicated e.g., rear-facing only or
forward- and rear-facing if convertible
--Air bag warning in written instructions
--Shows harness slots okay to use for occupant size
--Instructions for routing for both lap belt and lap/shoulder belt in
all modes
--Visibility of seat belt routing
--Visibility of tether use
--Information in written instructions and on labels match
--Durability of labels
Beyond combining two of ICBC's categories, NHTSA has deleted the
feature ``is airbag warning visible no matter where CRS is installed.''
NHTSA requires an air bag warning label on rear-facing child restraints
in a location that would receive a ``good'' under the ICBC program.
Therefore, NHTSA feels this feature can be deleted. NHTSA is retaining
the feature ``air bag warning in written instructions'' as NHTSA found
a great variety in written instructions with regard to the visibility
of this important information.
NHTSA has added ``information on written instructions and on labels
match'' as a separate feature. While NHTSA did not encounter any child
restraint during its exercise that had different information on the
labels than in the written instructions, the representative from ICBC
indicated that they find this commonly. For example, the height or
weight ranges may be different between the two sources of information.
While NHTSA suspects this results because written instructions are
printed in a large quantity and therefore not updated as frequently as
labels, it could be very confusing to consumers. Therefore, NHTSA felt
it deserved a separate category.
NHTSA has also added a feature ``durability of labels.'' NHTSA has
received complaints about labels fading and peeling. When evaluating
the ICBC program, NHTSA found two child restraints with one or more
labels already beginning to peel as they were removed from the box. In
a recently published Notice for Proposed Rule Making (NPRM) on child
restraint labels, NHTSA did not propose a durability requirement.\21\
However, we believe that adding this feature to the ratings will
encourage manufacturers to improve label durability. To achieve an
``A'' rating, all of the labels would have to use a technology such as
molding or heat embossing. Sticky labels would receive a ``B'' rating
unless any of the labels had already started to peel when the restraint
was removed from the box. In the later case, the restraint will receive
a ``C'' rating.
---------------------------------------------------------------------------
\21\ Docket Number: NHTSA-2001-10916.
---------------------------------------------------------------------------
Under ICBC's program, almost all labels receive a poor for many of
the features unless the label is on both sides of the restraint. NHTSA
has received comments on labeling upgrades requesting us to keep in
mind the limited space on child restraints. Providing a rating on
whether restraints have labels on both sides will encourage
manufacturers to place labels on both sides, resulting in using the
limited space on the restraint for additional labels. NHTSA is
considering modifying the ratings to allow for an ``A'' rating if the
label meets the specified criteria and is on one side of the restraint.
To this end, child restraints would not receive a ``C'' rating if the
label was only on one side of the restraint. Encouraging manufacturers
to make instructions more accessible, easier to use, and clearer,
should provide a justifiable solution instead of encouraging labels on
both sides of the child restraint.
c. Securing the Child
NHTSA has tentatively decided to evaluate the following features
found in the ICBC ``Securing the Child'' category:
--Buckle can be secured in reverse (harness strap buckle)
--Harness adjustment easy to tighten and loosen when child restraint
installed
--Number of harness slots/usable slots
--Ease of attaching/removing base
--Ease of conversion rear-facing to forward-facing or forward-facing to
booster and back again
--Visibility of harness slots
--Ease of changing harness slot position
--Ease of reassembly if pad/cover removed for cleaning
--Ease of adjusting/removing shield
In addition to combining the two categories, the agency will
slightly modify the rating criteria for two of the features. First,
under ``buckle can be secured in reverse,'' (referring to the harness
strap crotch buckle which on most child restraints has a red square
buckle release) a ``good'' rating by ICBC is a ``no,'' an
``acceptable'' rating is ``yes, but usual release works,'' and a
``poor'' rating is ``yes & difficult to release/access.'' NHTSA has
modified the rating to the following: an ``A'' rating is ``no, or yes
but usual release works with same degree of effort,'' a ``B'' rating is
``yes, but usual release requires more effort,'' a ``C'' rating is
``yes, but can't use release mechanism.'' The safety concern with being
able to reverse a buckle is that during an emergency a parent may be
unable to release the mechanism and remove the child from the seat.
NHTSA has tentatively chosen to modify this rating based on our opinion
that if reversing the buckle did not make the release more difficult to
use, there is not a safety concern. Further, NHTSA thought that
reversing the buckle might provide a benefit for children who may have
learned to unbuckle the release mechanism. With the buckle reversed,
the child would be less likely to unbuckle him or herself.
The other modification is the rating criteria for the feature
``ease of changing harness slot position.'' Under the ICBC program a
``good'' rating is ``easy to attach/remove; clear slots easy to thread;
easy to attach to hardware,'' an ``acceptable'' rating is ``possible
for one person to do; slots may be misaligned/pad in way/in slots;
hardware slot shared,'' and a ``poor'' rating is ``other, slot size too
small for easy threading; loose mandatory pieces; could misroute
through buckle.'' Under the NHTSA program an ``A'' rating is ``no need
to rethread; possible for one person to do,'' a ``B'' rating is
``possible for one person to do, easy to attach/remove; large slots
easy to thread,'' and a ``C'' rating is the same as that used by ICBC.
The reason NHTSA is proposing to make a change to the evaluation
criteria is that we've observed that no matter how easy it seems to
rethread, some people will rethread the harness wrong.
d. Installation in Vehicle
NHTSA has decided to evaluate the following features in the
``Installation in Vehicle'' category:
--Separation of vehicle belt path
--Ease of vehicle belt routing (hand clearance)
--Ease of seat belt routing (boosters)
--Ease of use of any belt-positioning hardware on CRS including lock-
off
--Tether easy to tighten and release
--Belt-positioning device allowing slack to occur
NHTSA is considering adding a feature, ``Ease of tightening belt
around CRS.'' Based on experience with installing child restraints we
have found some features on child restraints, specifically on infant
seat bases, that made tightening of the vehicle belt system difficult,
or that resulted in the tilting of the infant seat base to one side
upon tightening of the vehicle's lap and shoulder belt through the
infant seat base, resulting in an improperly secured
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child restraint. Therefore, we feel there is a need to consider this
aspect of installation. NHTSA would need to develop evaluation criteria
on what features of a child restraint would receive an ``A,'' ``B,'' or
``C'' rating under this category. NHTSA is soliciting views and
comments on this consideration.
3. Weighting the Features
The ICBC program ranks each feature within each category based upon
the level of importance. These rankings were determined by the child
restraint usability task force of ISO/TC22/SC12/WG1 (Child Restraints)
\22\ at a meeting in British Columbia. Each ease of use feature is
rated as an A, B, or C according to risk of injury and severity of
misuse. Component features that could be associated with a high risk of
injury if misused are to be rated ``A''. Each ranking is assigned a
numerical scale where A = 3 points, B = 2 points, and C = 1 point. The
ratings are similarly assigned a numerical scale where good = 3 points,
acceptable = 2 points, and poor = 1 point. To determine the rating for
a category, the numerical value of the rating for each feature is
multiplied by the numerical value of that feature's ranking. The
maximum possible score is then divided into thirds to determine the
point ranges for the category rating.
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\22\ Working group TC22/SC12/WG1, ``Child Restraint Systems,''
to the International Organization for Standardization (ISO), a
worldwide voluntary federation of ISO member bodies, is considering
developing an ease of use usability rating system for child
restraint systems. The group has based its preliminary work on the
rating system of ICBC, which is similar to NHTSA's work thus far.
---------------------------------------------------------------------------
This notice is proposing a slightly modified version of this
scheme. Whereas we agree with the ICBC relative ratings for the
component elements, we do not believe that enough is known to assign
weights to the four categories in terms of importance. The discussion
on the overall summary rating in Section 8 elaborates on this choice.
The NHTSA proposed approach is as follows:
Each component feature is assigned a numerical scale of 1-3 points,
with features having the highest relationship to safety receiving 3
points. The ratings are similarly assigned a numerical scale where A =
3 points, B = 2 points, and C = 1 point. To determine the rating for a
category, the numerical value of the rating for each feature is
multiplied by the numerical value of that feature's ranking. Point
ranges for A, B, and C are determined through a 3-part split of the
range of possible points for that factor, from the minimum (if all
scores were coded ``C'') to the maximum (if all scores were coded
``A'') number of points. Appendix B and Appendix C displays this
scheme, with a hypothetical example seat rated.
NHTSA proposes to keep the same ranking as ICBC uses for the
component features it has retained. For the four new features that we
have added, we have assigned them a 2-point ranking. While we believe
these features are important enough to add them to the rating system,
their proposed lower ranking reflects the fact that ICBC chose not to
include them.
4. Ease of Use Rating Protocol
ICBC uses two 2-person teams to evaluate each child restraint.
Prior to the evaluation, the teams have a day of training. ICBC has
found that, while the rating for some features may vary between the
teams, the overall rating for the category tends to be the same. To the
extent that the teams end up with a different rating for a category,
they jointly reexamine the child restraint before a rating is
determined. Child restraints are installed in a bench seat of a generic
minivan for purposes of the evaluation.
NHTSA found that the ratings of the two teams we used in our
evaluation also matched. Therefore, we are planning to use the same
protocol for rating child restraints for ease of use.
During the evaluation, the teams would install the child restraint
in the current FMVSS No. 213 bench. If and when the FMVSS No. 213 bench
is updated, the team will use the updated test bench. No dummy will be
used during this process.
5. Overall Ease of Use Rating
Market research in recent years has shown that most consumers
prefer summary ratings or information because they find it quicker and
easier to read and understand. At the same time, a certain significant
percentage of consumers also like detailed information that is
presented in hierarchical fashion, with the more general information
presented initially. NHTSA is planning to combine the planned child
restraint ease of use ratings into a summary ease of use rating. While
NHTSA notes that it does not have clear information about how
organizations that currently provide a summary rating determine that
rating, study of the ICBC model has led to the conclusion that it is
reasonable to apply a modified version of their model. The notable
exception is that NHTSA does not believe it is possible to weight the
importance of the four overall categories. As a result, a straight
combination numerical rating is not proposed. If all of the individual
scores were added to one overall numerical score, the factors
containing more component elements would carry more weight. Therefore,
the proposal for the combined rating is majority rule for the four
categories, with two qualifiers. The two qualifiers are that a seat
cannot receive a B rating if more than 1 out of 4 categories is a C
and, correspondingly, a seat cannot receive an A rating if more that 1
out of 4 categories is rated other than A. In the example in Appendix
C, the seat received a high number of C ratings in important
components, thereby resulting in 2 out of 4 categories being rated C.
Application of the qualifier gives it a C rating.
V. Discussion and CRS Rating System Proposal
The agency has not made a final determination on which of the four
rating systems (three dynamic plus ease of use), or combination of
those rating systems, would be most appropriate and responsive to the
Congressional mandate of TREAD. However, we have tentatively concluded
that the most effective consumer information system is one that gives
the consumer a combination of information about child restraints' ease
of use and dynamic performance, with the dynamic performance obtained
through higher-speed sled testing and/or in-vehicle NCAP testing.
Section 14(g) of TREAD set forth the requirement to establish a CRS
rating consumer information program. Other sections of TREAD mention
providing ``consumer information on the physical compatibility of child
restraints and vehicle seats on a model-by-model basis'' [14(b)(4)] and
``whether to include child restraints in each vehicle crash tested
under the New Car Assessment Program'' [14(b)(9)]. From this, the
agency has tentatively concluded that a rating program that rates the
CRS and/or the vehicle would satisfy the Congressional mandate.
Table 1 shows six factors that were felt to be of primary
importance in determining an appropriate CRS rating system. From this
table, it is clear that a single rating alternative does not achieve
all of the six objectives. Ease of use is the only option that
potentially addresses misuse, and thus the agency feels that such a
rating option could have a substantial impact on proper CRS use.
However, an Ease of Use rating would not provide information on dynamic
performance. Given the advantages and disadvantages regarding the
various dynamic performance rating options described in the preceding
sections, the agency has tentatively
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concluded that higher-speed sled tests and/or in-vehicle NCAP testing
would be preferable methods for providing dynamic performance
information. Comments on which dynamic rating option, individually or
in conjunction with the Ease of use rating, would provide the most
useful information to the consumer as well as improve overall child
safety are requested. Comments are also requested on whether or not the
agency should consider conducting both higher-speed sled tests and in-
vehicle NCAP testing in conjunction with the Ease of use rating. If, in
addition to the Ease of use rating, the agency were to provide both a
higher-speed sled test rating for the child seat, and an in-vehicle
NCAP rating of child occupant protection for the vehicle, would such
information be meaningful for the consumer and worth the costs of
administering the tests given the relative advantages and disadvantages
of each? Also, if the agency were to implement an in-vehicle NCAP
rating system, what child seat(s) should be used? Should the agency
select child seat(s) from those specified in FMVSS No. 208? If so,
should a procedure be based upon only one of these seats to standardize
the child seat for all vehicles? If only one child seat is selected,
what criteria should the agency use in selecting that seat? If not, is
the protocol provided below preferable?
Possible Assessment Protocol for Higher-speed Sled Tests
The following assessment protocol for testing and rating a child
restraint in a higher-speed sled test is proposed if this dynamic
procedure is selected.
--The agency would select child restraints for higher-speed sled tests
so that most of the forward-facing child restraint models sold in the
United States would undergo the higher-speed sled test for the
evaluation of child restraints.
--Forward-facing child restraints would be placed on the same seat used
for the compliance test. The restraint would be secured to the using
the LATCH system. Installation instructions prescribed by the
manufacturer of the child restraint would be followed.
--Hybrid III three-year-old and/or 12 month CRABI dummies would be
placed in the child restraint for assessing injury. Dummy selection
would depend upon the weight rating of the CRS. Child restraints
designed for weight classifications covering both dummies would be
tested with both and provided two rating. Head and chest accelerations
would be recorded. The injury assessment reference values developed for
child dummies in FMVSS No. 208 would be calculated.
--A five star rating would be applied to the dynamic performance using
the HIC and chest acceleration to compute probability of injury as was
illustrated in Figure 7.
--Child restraints would also be examined for structural integrity
after the test. The physical structural integrity evaluation specified
in the FMVSS No. 213 procedure would be applied.
--A rating for the CRS would be made available to the public in a
manner similar to that now employed for other NCAP vehicle results.
Possible Assessment Protocol for NCAP Frontal Vehicle Testing
The following assessment protocol for testing and rating vehicles
with child restraints for in-vehicle NCAP is proposed if this dynamic
procedure is selected.
--After the agency has selected the vehicles for frontal NCAP testing,
each vehicle manufacturer would be asked for a recommendation of at
least three forward-facing child restraints for children up to a weight
of 50 pounds for each vehicle to be tested. At least one of the vehicle
manufacturer-recommended child restraints must have a retail price of
less than $60. A different CRS manufacturer must make each of the three
restraints. An integrated child restraint may be one of the recommended
child restraints. Each of the three recommended child restraints must
be currently available in the market. If the vehicle manufacturer chose
not to make a recommendation, then the agency would choose from any
child restraint available in the market.
--One of the three vehicle manufacturer-recommended child restraints
would be selected for use in the crash test. A procedure that uses the
child restraint in the LATCH configuration would be followed. The
agency would follow both the vehicle and child restraint manufacturers'
recommendations for installing the child restraint in the passenger
vehicle. Our expectation is that the vehicle manufacturer's set-up
instructions would be consistent with the installation instructions for
the child restraint.
--A forward-facing child restraint would be placed in the seat directly
behind the right front passenger, i.e., on the right-hand side of the
second row of seats. A 3-year-old Hybrid III dummy would be placed in
the child restraint system. Head and chest accelerations would be
recorded. The injury assessment reference values developed for child
dummies in FMVSS No. 208 would be calculated. If the vehicle is
equipped with a built in child seat, testing could be conducted with
either or both the built in and add on child restraints.
--A five star rating would be applied to the dynamic performance using
the HIC and chest acceleration to compute probability of injury as was
illustrated in Figure 7.
--Child restraints would also be examined for structural integrity
after the test. The physical structural integrity evaluation specified
in the FMVSS No. 213 procedure would be applied.
--A rating for child protection would be added to the vehicle frontal
NCAP ratings. In the process of developing the proposed rating system,
the agency made several decisions.
These decisions and our rationale for making them are the
following:
1. For in-vehicle testing, only frontal NCAP tests are being
proposed. Child restraints are not currently compliance-tested under
lateral loading conditions. Although lateral test requirements for CRS
are being proposed in an upgrade to FMVSS No. 213 under a separate
TREAD rulemaking action, the agency felt that the issue of a possible
lateral rating should be considered following completion of the FMVSS
No. 213 upgrade.
2. The in-vehicle proposed protocol rates only one CRS in the rear
seat. Due to the very tight schedule available for conducting and
assessing potential CRS NCAP protocol, the agency elected to
concentrate on forward-facing child restraints rather than attempt to
also include rear-facing child restraints and/or booster seats. The
decision to concentrate on the forward-facing CRS was based on the
belief that the forward-facing CRS would provide the most meaningful
information to the consumer, given that development of procedures for
all three systems could not be accomplished in the short time frame.
Following incorporation of the forward-facing CRS, the feasibility of
incorporating a rating which included rear-facing CRS and/or booster
seats would subsequently be considered.
3. The in-vehicle proposed rating uses only the three-year-old
dummy. Again, due to the very tight schedule, the agency felt it
necessary to collect as much data as possible for one dummy and that
the three-year-old would provide the most meaningful information for
the consumer. Upon
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incorporation of a child restraint system rating with the three-year-
old dummy, consideration would subsequently be given to dummies of
other sizes.
4. Higher-speed testing which was conducted by the agency used only
Hybrid III three-year-old dummies. However, if the higher-speed dynamic
performance is selected, utilization of both twelve month CRABI and
Hybrid III three year old dummies would be proposed.
Comments on these decisions and the agency's rationale for them are
requested. Also, comments regarding possible future extension of the
CRS NCAP rating to side impact, other types of CRS, and dummy size are
also sought.
VI. Combined Child Restraint Rating
NHTSA is not currently planning to do an overall summary rating
combining ease of use and dynamic performance. To date, we have not
been able to develop an acceptable methodology for a summary rating.
However, we request comments and suggestions on this issue.
VII. Distribution
NHTSA currently produces a print brochure titled Buying a Safer Car
that provides NCAP ratings and safety feature information for new
vehicles. Because new motor vehicles are commonly introduced in the
fall, NHTSA produces the first printing for each model year in the
fall. Because NCAP testing cannot begin until the vehicles are
available from dealers, this printing only has test results for
vehicles which were tested in previous model years and which have not
changed significantly. A second printing is produced in the spring
after the completion of the NCAP testing program.
NHTSA also publishes an annual brochure titled Buying a Safer Car
for Child Passengers. This brochure provides new vehicle safety
features and other information relevant to children. The brochure
identifies vehicles that have built-in child seats, manual air bag cut-
off switches, rear center rear seat lap/shoulder belts, rear-seat
adjustable upper belts, and interior trunk releases.
If NHTSA were to elect to have a rating based solely on a vehicle
equipped with a child restraint, the existing brochures would be an
appropriate venue for the distribution of the ratings. If NHTSA chooses
another rating system, we believe new printed information about child
restraint ratings will be needed. The current brochures are a helpful
model for new print information about child restraint ratings. However,
unlike vehicles, child restraint models do not tend to change on an
annual cycle. Therefore, NHTSA would have to pick a date and only
include in a print brochure child restraints that are available in the
marketplace at that time. Representatives from ICBC have indicated that
the largest concentration of new child restraint introductions seems to
occur in Canada in the months of May and June. To assist us in timing a
print brochure, NHTSA requests comments on whether this timing is also
accurate for the United States.
NHTSA notes that a print brochure could be used in addition to our
web site. Unlike printing, this site can be updated on a continuous
basis. Therefore, NHTSA could test child restraints as they became
available and add new models to the web site when testing was complete.
VIII. Submission of Comments
How Do I Prepare and Submit Comments?
Your comments must be written and in English. To ensure that your
comments are correctly filed in the Docket, please include the docket
number of this document in your comments.
Your comments must not be more than 15 pages long. (49 CFR 553.21).
We established this limit to encourage you to write your primary
comments in a concise fashion. However, you may attach necessary
additional documents to your comments. There is no limit on the length
of the attachments.
Please submit two copies of your comments, including the
attachments, to Docket Management at the address given above under
ADDRESSES.
How Can I Be Sure That My Comments Were Received?
If you wish Docket Management to notify you upon its receipt of
your comments, enclose a self-addressed, stamped postcard in the
envelope containing your comments. Upon receiving your comments, Docket
Management will return the postcard by mail.
How Do I Submit Confidential Business Information?
If you wish to submit any information under a claim of
confidentiality, you should submit three copies of your complete
submission, including the information you claim to be confidential
business information, to the Chief Counsel, NHTSA, at the address given
above under FOR FURTHER INFORMATION CONTACT. In addition, you should
submit two copies, from which you have deleted the claimed confidential
business information, to Docket Management at the address given above
under ADDRESSES. When you send a comment containing information claimed
to be confidential business information, you should include a cover
letter setting forth the information specified in our confidential
business information regulation. (49 CFR Part 512.)
Will the Agency Consider Late Comments?
We will consider all comments that Docket Management receives
before the close of business on the comment closing date indicated
above under DATES. To the extent possible, we will also consider
comments that Docket Management receives after that date.
How Can I Read the Comments Submitted by Other People?
You may read the comments received by Docket Management at the
address given above under ADDRESSES. The hours of the Docket are
indicated above in the same location.
You may also see the comments on the Internet. To read the comments
on the Internet, take the following steps:
I. Go to the Docket Management System (DMS) Web page of the Department
of Transportation (http://dms.dot.gov/).
II. On that page, click on ``search.''
III. On the next page (http://dms.dot.gov/search/), type in the four-
digit docket number shown at the beginning of this document. Example:
If the docket number were ``NHTSA-1999-1234,'' you would type ``1234.''
After typing the docket number, click on ``search.''
IV. On the next page, which contains docket summary information for the
docket you selected, click on the desired comments.
[[Page 56159]]
You may download the comments. However, since the comments are
imaged documents, instead of word processing documents, the downloaded
comments are not word searchable.
Please note that even after the comment closing date, we will
continue to file relevant information in the Docket as it becomes
available. Further, some people may submit late comments. Accordingly,
we recommend that you periodically check the Docket for new material.
Authority: 49 U.S.C. 322, 30111, 30115, 30117, 30166, and Pub.L.
106-414, 114 Stat. 1800; delegation of authority at 49 CFR 1.50.
Issued on: October 29, 2001.
Stephen R. Kratzke,
Associate Administrator for Safety Performance Standards.
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[FR Doc. 01-27547 Filed 10-31-01; 9:55 am]
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