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safty rating for child restraint systerm

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safty rating for child restraint systerm

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     Federal Register / Vol. 66, No. 215 / Tuesday, November 6, 2001 / Notices

     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 invehicle 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?C401, 400 Seventh Street, SW., Washington, DC, 20590. You may call Docket Management at 202?C366?C9324. 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?C10) at 202?C 366?C6012. For issues related to a compatibility/ ease of use rating, you may call Lori Miller of the Office of Traffic Safety Programs (NTS?C12) at 202?C366?C9835. 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

     turning a corner, or parking, loss of power steering does not pose a significant risk to traffic safety. The loss of drive to the generator prevents the vehicle??s battery from being charged, but is a progressive loss of battery power and does not represent a safety concern. Loss of engine cooling could cause the vehicle to overheat, typically resulting in coolant overflow at the radiator or a burst cooling system hose, however, there have been no reports of such incidences. Air conditioning is an auxiliary function, the loss of which does not affect the safe operation of the vehicle. In view of the foregoing, it is unlikely that NHTSA would issue an order for the notification and remedy of the alleged safety-related defect as defined by the petitioner in the subject vehicles at the conclusion of the investigation requested in the petition. Therefore, in view of the need to allocate and prioritize NHTSA??s limited resources to best accomplish the agency??s safety mission, the petition is denied.

     Authority: 49 U.S.C. 30162(d); delegations of authority at CFR 1.50 and 501.8. Issued on: November 1, 2001. Kathleen C. DeMeter, Director, Office of Defects Investigation, Safety Assurance. [FR Doc. 01?C27869 Filed 11?C5?C01; 8:45 am]

     BILLING CODE 4910?C59?CP

     DEPARTMENT OF TRANSPORTATION National Highway Traffic Safety Administration

     [Docket No. NHTSA?C2001?C10053?CNotice 1]

     Safety Rating Program for Child Restraint Systems

     AGENCY: National Highway Traffic Safety Administration (NHTSA), DOT. ACTION: Notice, request for comments. 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

     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?C414, 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

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     safety rating program and providing other consumer information which the Secretary determines would be useful (to) consumers who purchase child restraint systems.

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     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 higherspeed 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?C 2000?C6628). 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?C 2000?C7938). The overall goal of NHTSA??s Child Restraint Systems Safety Plan was to reduce fatalities and reduce injuries to U.S. children aged 0?C 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 passfail), 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 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. 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 Consumers and consumer advocates almost universally expressed the opinion that any child restraint rating

     1 Robert Waller, Jr., Juvenile Products Manufacturers Association, Inc., Docket 6628. 2 Comments on Child Restraint System Ratings, Ford

    Motor Company, Docket 7938. 3 Evenflo Company, Inc., Randy Kiser, Docket 7938. 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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     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, 3year-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 sixcategory 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. The child restraints of the 2001 survey were tested both with and without the top tether. The results from

     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?C 7938, 2001.

     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. 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

     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.

     7 Identification

     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 (rearfacing) and infant seats (forward-facing or convertible). They do not plan to test bed-type-seats or booster seats. Ninemonth-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?ã 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

     11 www.nrma.com.au,

     July 23, 2001.

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     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-yearold 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 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-yearold) dummies are used to assess injury. ANCAP plans to rate the dynamic performance of child restraints in vehicle tests, however, the rating

     12 http://www.euroncap.com/results.htm, August 23, 2001.

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     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 6month-old Infant CRABI, the 12-monthold CRABI, and the 3-year-old Hybrid III. IIHS evaluated the dummy results for the 6-month-old CRABI, the 12-monthold 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 6month-old CRABI and the 12-month-old CRABI were all well below the allowable limits. The results for the 3year-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 ?Ý 3 injury.15 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 fivestar classification system. The probability of injury for the 3-year-old child is as follows: Phead = [1+exp(5.02??0.00431*HIC)]??1

     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?C01?C0123.

     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 fullscale 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 usethe 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

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