[Federal Register Volume 62, Number 34 (Thursday, February 20, 1997)]
[Proposed Rules]
[Pages 7858-7897]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 97-4084]
[[Page 7857]]
_______________________________________________________________________
Part IV
Department of Transportation
_______________________________________________________________________
National Highway Traffic Safety Administration
_______________________________________________________________________
49 CFR Part 571
Federal Motor Vehicle Safety Standards; Child Restraint Systems; Tether
Anchorages and Anchorage Systems; Proposed Rule
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 /
Proposed Rules
[[Page 7858]]
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
49 CFR Part 571
[Docket No. 96-095; Notice 3]
RIN 2127-AG50
Federal Motor Vehicle Safety Standards; Child Restraint Systems;
Tether Anchorages for Child Restraint Systems; Child Restraint
Anchorage System
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation.
ACTION: Notice of proposed rulemaking (NPRM); request for comment.
-----------------------------------------------------------------------
SUMMARY: This document proposes to require that motor vehicles and add-
on child restraints be equipped with a means independent of vehicle
safety belts for securing the child restraints to vehicle seats. The
adoption of the proposal would avoid problems of incompatibility
between child restraints and vehicle safety belts and increase the
correct installation of child restraints. This proposal would reduce
allowable head excursion, which would have the effect of requiring
child restraints to be equipped with an upper tether strap, and would
require vehicles to have two factory-installed, user-ready anchor
points for attaching the tether. It would also require vehicles to have
two rear vehicle seating positions equipped with a specialized lower
anchorage system, and require child restraints to be equipped with
means of attaching to that system.
The proposal for the lower anchorages is based on two of the
systems discussed at an October 1996 NHTSA public workshop concerning
alternative systems for providing dedicated means for attaching child
restraints to vehicle seats. Almost all of the different systems
evaluated and discussed at the workshop appeared comparable in terms of
demonstrated safety and public acceptance. However, one system appeared
to be less expensive and have the advantage of using hardware familiar
to consumers. This system is the ``uniform child restraint anchorages
(UCRA) system,'' referred to as such by a consortium of manufacturing
groups in a June 28, 1996 petition for rulemaking to the agency. The
International Standards Organization (ISO) Working Group on child
restraint systems recognized in a November 1996 meeting the need for
this system to permit improvements in the short term.
The other notable dedicated system is one supported by European
members of the ISO Working Group. This alternative, which is completing
development, uses a two-prong nonflexible item of hardware on the child
restraint to mate with two fixed anchorages at the bottom of the back
of the vehicle seat without the use of any belt webbing. Under today's
proposal, either of these systems could meet the proposed requirement
for a dedicated lower anchorage system, but manufacturers installing
the fixed anchorage system would also have to ensure that the system is
compatible with the UCRA system, so that UCRA-type child restraints can
be used in all vehicles equipped with either anchorage system.
To the extent possible, this proposal also harmonizes with the
actions of other regulatory agencies around the world. This proposal
seeks to harmonize with Canadian and Australian regulations by
requiring an upper tether anchorage and with prospective European
regulations by allowing a non-UCRA anchorage system.
This proposal pertains to the compatibility of child restraints
with motor vehicle seats, and not that of child restraints with
aircraft seats. The Federal Aviation Administration and NHTSA are
developing possible requirements and procedures for improving the
compatibility of child restraints in aircraft. If the agencies decide
that rulemaking is warranted on that issue, such rulemaking will be
commenced as a separate action.
DATES: Comments on this notice must be received by the agency no later
than May 21, 1997.
ADDRESSES: Comments should refer to the docket number and notice number
and be submitted in writing to NHTSA's Docket Section at the following
address: Until March 10, 1997: Room 6130, After March 10, 1997: Room
5109, 400 Seventh Street, S.W., Washington, D.C., 20590. Telephone:
(202) 366-5267. Docket hours are 9:30 a.m. to 4:00 p.m. Monday through
Friday.
FOR FURTHER INFORMATION CONTACT: At NHTSA, for nonlegal issues: Dr.
George Mouchahoir, Office of Vehicle Safety Standards (telephone 202-
366-4919). For legal issues: Deirdre Fujita, Office of the Chief
Counsel (202-366-2992). Both can be reached at the National Highway
Traffic Safety Administration, 400 Seventh St., S.W., Washington, D.C.,
20590.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Statement of the Problem
II. Improved Anchorage System
a. Standardized System
b. Competing Concepts
III. Public Workshop
a. Summary of Presentations
1. ISOFIX 4-point Rigid System
2. CANFIX 2-Point Rigid System
3. UCRA Soft Anchor System
4. European Industry Hybrid System
5. Car Seat Only System
b. Clinics
c. Cost
d. Tether
e. Agreement on Differences
f. Future Work
IV. Subsequent Developments
a. Albuquerque, N.M.
b. Additional Information
c. Petition on Scheme D (Hybrid System)
V. Evaluation of Concepts
a. Top Tether
b. Lower Anchorage Points
1. Improve Compatibility
2. Safety Performance
3. Consumer Acceptability
4. Costs and Burdens
5. Harmonization
6. Leadtime and Availability
7. Proposed System
c. Discussion of Alternatives
1. SAE Recommended Practice J1819
2. Lockability
3. Car Seat Only System
VI. Proposal for New Vehicle Standard
a. Highlights of Proposal
b. Applicability
c. Seating Positions
d. Construction
1. Lower anchorages
2. Upper anchorages
e. Performance
f. Instructions
VII. Proposal for Amendments to Child Seat Standard
a. Applicability
b. Required Components
c. Dynamic Performance
d. Instructions and Labeling
VIII. Proposed Effective Date
IX. Rulemaking Analyses and Notices
a. Executive Order 12866 (Regulatory Planning and Review) and
DOT Regulatory Policies and Procedures
b. Regulatory Flexibility Act
c. Executive Order 12612 (Federalism)
d. Unfunded Mandates Reform Act
e. National Environmental Policy Act
f. Executive Order 12778 (Civil Justice Reform)
X. Comments
I. Statement of the Problem
The effective use of child restraints is important because of the
number of children killed and injured in vehicle accidents. Annually,
about 600 children less than five years of age are killed and over
70,000 are injured as occupants in motor vehicle crashes. Data from the
National Center for Health Statistics (for 1991) indicates that motor
vehicle
[[Page 7859]]
occupant fatalities were the third leading cause of death for this age
group (NCHS, 1993).
While child seats are highly effective in reducing the likelihood
of death or serious injury in motor vehicle crashes, the degree of
their effectiveness depends on how they are installed. NHTSA estimates
that the potential effectiveness of child seats, when correctly used,
is 71 percent. However, it is estimated that imperfect securing of
children in the child seats and/or of the child seats in vehicles
reduce that effectiveness from the potential 71 percent to an actual 59
percent. That is, as a group, child seats (those that were used
correctly together with those that were misused) have an actual
effectiveness of 59 percent.
Child restraint effectiveness is reduced by limitations imposed by
vehicle belt design, and by belt anchorage locations. Child seats are
generally designed to attach to a vehicle by means of the vehicle's lap
belt system. While child seats provide high levels of safety when
correctly attached to a standard vehicle seat assembly with only a lap
belt, in most vehicles different types of seat belt systems exist in
addition to or in lieu of a lap belt. Among the different types are
belt systems with a locking latchplate, a non-locking (sliding)
latchplate, a reversible lockable retractor, an emergency-locking
retractor, or an automatic seat belt. Some of these belt systems, such
as those equipped with a locking retractor, are able to hold a child
seat without use of attachment accessories, but a parent must correctly
manipulate the system, such as by pulling the belt completely out of
the retractor and then feeding excess slack back into it after buckling
in the child seat. Some belt systems can be used to secure a child seat
only when used with an accessory item that impedes movement of the belt
or child seat in a crash, such as a locking clip or supplemental strap.
Some belt systems, such as an automatic seat belt, may not be
compatible with a child seat at all.
The agency recognizes the difficulty of designing vehicle seat
belts to restrain both child restraint systems and a wide range of
weights and sizes of individuals. Some vehicle seats have the seat belt
anchorage positioned far forward of the vehicle ``seat bight'' (the
intersection of the seat cushion and the seat back). Forward-mounted
anchor points may better protect an adult using the vehicle seat belt
system by drawing the vehicle belt low across the pelvis where the body
can best tolerate the forces in a crash. However, when used with a
child seat, the belt anchor is so far forward of the seat bight that
the vehicle belts cannot initially provide any resistance to the
forward, longitudinal motion of a child seat reacting to a decelerating
crash pulse. The child restraint moves forward until it is sufficiently
far forward of the belt anchorages that the belt finally can resist the
forward, longitudinal motion of the child seat. This forward movement
of the child restraint can result in excessive forward movement of the
child's head, and a greater likelihood of head impact.
Child restraint effectiveness is also reduced by incorrect securing
of children and child restraints due to the complexities of adapting
vehicle belts to those purposes and due to failure to follow
instructions. To properly install child restraints, devices such as
lockable retractors, locking clips, and supplemental belts must be used
in many cases. Unfortunately, it appears that many people installing a
child seat are either unfamiliar with the use of these devices (which
generally are not used or needed except in conjunction with a child
restraint), not able to understand or unwilling to read instructions
concerning their proper use, or unable to surmise from their design how
to use them correctly. People generally are frustrated about the
difficulty in installing child seats correctly in vehicle seats. Recent
user trials conducted in the U.S.1 and Canada 2 found that
virtually all the people surveyed in the studies expressed high levels
of dissatisfaction with conventional means of attaching child
restraints in vehicles. NHTSA receives an average of about 50 calls a
day to its Consumer Complaint Hotline from people asking for step-by-
step guidance in installing their child seats. When an article appears
in the media about incompatibility problems between child restraints
and vehicle seats, those calls typically increase to over 500 a day.
All of these callers express frustration at the difficulty of
installing a child seat securely, and all urge NHTSA to make the
installation easier. NHTSA understands that child restraint
manufacturers also receive a large number of similar calls and asks
that commenters verify this.
---------------------------------------------------------------------------
\1\ ``An Evaluation of the Usability of Two Types of Universal
Child Restraint Seat Attachment Systems,'' General Motors
Corporation, 1996.
\2\ ``The ICBC Child Restraint User Trials,'' Rona Kinetics and
Associates Ltd. Report R96-04, prepared for the Insurance
Corporation of British Columbia, December 1996.
---------------------------------------------------------------------------
A four-state study done for NHTSA in 1996 examined people who use
child restraint systems and found that approximately 80 percent of the
persons made at least one significant error in using the systems.
(``Patterns of Misuse of Child Safety Seats,'' DOT HS 808 440, January
1996.) Observed misuse due to a locking clip being incorrectly used or
not used when necessary was 72 percent, and misuse due to the vehicle
safety belt incorrectly used with a child seat (unbuckled,
disconnected, misrouted, or untightened) or used with a child too small
to fit the belts was 17 percent.
II. Improved Anchorage System
a. Standardized System
The difficulty with using vehicle safety belts to attach child
restraints arises from the fact that those belts are primarily designed
to restrain and protect larger and older vehicle occupants. Given the
inability to change vehicle belt design and anchorage location because
of this purpose, the agency is seeking a means of securing a child
restraint that is independent of the safety belt. For a number of
years, industry groups and governmental bodies have explored improving
the securement of a child seat on a vehicle seat. The child seat and
motor vehicle industry is unanimous that the means of attaching child
restraints to the vehicle interior should be easier, more efficient and
without incompatibility problems. Further, all agree that there should
be a universal and independent means of attaching child restraints.
That is, there should be means that are either identical or at least
compatible, regardless of vehicle make or model, and that are dedicated
solely for use in securing child restraints. The importance of
universality across vehicle make or model also compels a universal
requirement for the anchorage system, and would mitigate against having
the system be available on an optional basis.
The concept of a universal and independent anchorage system was
embraced by the ``Blue Ribbon Panel on Child Restraint and Vehicle
Compatibility,'' which NHTSA Administrator Ricardo Martinez, M.D.,
formed in February 1995 to improve the use and attachment of child
safety seats.3 In its May 30, 1995 report recommending ways to
improve the compatibility between child restraints
[[Page 7860]]
and vehicle seating positions, the panel recommended that there be an
entirely separate anchorage system for child restraint installation,
given the complex variables affecting the proper installation of child
restraints using existing vehicle safety belts.
---------------------------------------------------------------------------
\3\ The Blue Ribbon Panel included child safety advocates and
representatives of the motor vehicle, child safety seat and seat
belt industries, including representatives from Ford, Chrysler,
General Motors, Mercedes Benz, Volkswagen, BMW, Volvo, Nissan,
Toyota, Honda, Century, Gerry, Fisher-Price, Cosco, Evenflo,
Kolcraft, Riley Hospital, DANA Foundation, American Academy of
Pediatrics, University of Michigan, TRW, and Takata, and advocates
Stephanie Tombrello and Annemarie Shelness.
---------------------------------------------------------------------------
While there is universal agreement on the need to improve the ease
with which child seats can be properly secured to vehicle seats and
concurrence with the merits of a separate anchorage system, there is
disagreement on which system is best. It is assumed that a
``universal'' anchorage system must standardize the means of
attachment, so that it and it alone would be required for all affected
vehicles, and it alone would be the system with which child seats would
be required to be compatible. This is needed to ensure universal
compatibility between child seats and vehicles.
b. Competing Concepts
In 1990, the ISO began work on a universal child seat anchorage
system (``ISOFIX''). The ISOFIX concept originated as a 4-point rigid
system, where four sturdy braces are mounted on the bottom of a child
restraint. Each brace has a latch at its end. Two of the latches
connect, through holes at the vehicle seat bight, to a metal bar in the
seat frame. The other two latches, at the bottom braces, connect to a
bar below the vehicle seat cushion. The ISOFIX system is supported by
Volvo, as well as others.
Other concepts for universal anchorage systems have developed as
alternatives to the 4-point ISO system, many in response to perceived
problems with the ISOFIX system, such as ISOFIX being too rigid, too
susceptible to false latching, too bulky, unreasonably expensive, and
too heavy.
Transport Canada developed the CANFIX system, which consists of two
rigid rear anchorages at the seat bight (rather than the four points of
ISOFIX), plus an upper tether. This system envisions all vehicles to be
equipped with upper tether anchorage locations. CANFIX is supported by
Australia, which refers to the system as CAUSFIX. At this time, neither
Canada nor Australia requires the CANFIX or CAUSFIX but both are
interested in pursuing such a requirement in the near-term. It is
noted, however, that Transport Canada has stated that in lieu of rigid
lower anchorage points, it could support soft anchorages such as those
of the ``UCRA'' system described below, in addition to an upper tether.
General Motors (GM) helped develop a ``uniform child restraint
anchorage (UCRA)'' system consisting of two lower anchorages near the
bight line and an upper tether anchorage. The lower anchorages have
small latches that are compatible with easy-to-use buckles (as well as
tether hooks) that would be installed on the child seat. The top tether
anchorage would have a buckle or tether hook that is compatible with a
tether and latch or hook on the child seat.
GM joined with thirteen other vehicle and child restraint
manufacturers in petitioning NHTSA to require the UCRA system on
vehicles and componentry compatible with the anchor system on child
seats. The joint petitioners are: the American Automobile Manufacturers
Association (AAMA), which includes General Motors, Chrysler, and Ford;
five companies of the Association of International Automobile
Manufacturers (AIAM) (Honda, Isuzu, Nissan, Subaru, and Toyota); the
Juvenile Products Manufacturer's Association (JPMA), which includes
child restraint manufacturers Century, Evenflo, Fisher-Price, Gerry and
Kolcraft; and Indiana Mills and Manufacturing, a supplier of belt
systems and hardware.
As another alternative to the ISOFIX 4-point rigid system, several
European ISO manufacturer members are currently developing a hybrid
system. The system consists of two lower anchorage points located in
the seat bight and an upper tether anchorage point located behind the
vehicle seat back. A child restraint system could be attached to the
two lower anchorage points by means of either a buckle (such as the
UCRA buckle) or the ISOFIX connector. The object of this option is to
achieve worldwide compatibility between the UCRA and ISOFIX types of
connectors.
The four systems described above are the four options, known as
``Schemes'' A through D, that the ISO has been considering for the past
year. The four-point rigid anchor system (ISOFIX) is known as Scheme A;
the two-point rigid anchor and rigid attachment, plus tether, is Scheme
B; the two-point flexible anchor and flexible attachment, plus tether,
is Scheme C; and the two-point rigid or semi-rigid anchor and flexible
attachment is Scheme D.
Another approach for a universal anchorage system was advanced by
Cosco, a child restraint manufacturer. Cosco suggested in a July 1,
1996 petition for rulemaking to NHTSA that vehicle manufacturers alone
should be responsible for improving compatibility between child seats
and vehicle seats and the ease of installation of child seats. Cosco
believed that vehicles should provide a dedicated Type I lap belt for
child seats, at or rear of the vehicle seat bight. Cosco calls its
system the ``Car Seat Only (CSO)'' system. Cosco envisions that the CSO
system would require no changes in the design and manufacture of child
restraints.
III. Public Workshop
The relative merit of each of the systems was discussed at a public
workshop NHTSA held on October 16 and 17, 1996 in Washington, D.C.
Attending were about 100 persons from the U.S., Canada, Europe, Japan
and Australia, representing governments and manufacturers of motor
vehicles and child restraints, as well child safety advocates.4
---------------------------------------------------------------------------
4 A transcript of the meeting has been placed in NHTSA Docket
No. 96-095, Notice 01, and is available from Neal R. Gross, Court
Reporters and Transcribers, 1323 Rhode Island Avenue, N.W.,
Washington, D.C., 20005 (telephone 202-234-4433).
---------------------------------------------------------------------------
NHTSA held this two-day meeting to discuss the various alternatives
of universal child restraint anchorage systems that are being
considered by the agency, safety advocates, and automotive and child
safety organizations, such as the Society of Automotive Engineers (SAE)
and the ISO. The five options described above were presented and
discussed as to design characteristics, safety performance, public
acceptance and economic considerations. The meeting focused on bringing
to discussion the characteristics of the various alternatives and not
necessarily on reaching a consensus on a system. Participants had the
opportunity to experiment with the UCRA and hybrid systems in actual
vehicles that were provided by their respective manufacturers.
a. Summary of Presentations
The following discussion summarizes the remarks of each presenter.
1. ISOFIX 4-point Rigid Systems
Thomas Turbell (Sweden), presenting on Scheme A (ISOFIX), reviewed
the ISO work of the last six years on the 4-point system. He said that
the first ideas on an anchorage system envisioned a fixation point in
the vehicle where forward-facing child seats and rear-facing seats
could be installed. The ISOFIX type 1 system (two rigid points), the
ISOFIX Type 2 system (``DELTAFIX,'' two rigid points and one point in
the front) were compared in an early user trial with the conventional
Swedish child restraint system (installation by the seatbelt and by two
lower tethers attached to the seat frame). Eighty percent of the users
installed the
[[Page 7861]]
ISOFIX type 1 system correctly the first time, 60 percent the DELTAFIX,
and only 30 percent the conventional system. Eighty-nine percent of the
subjects indicated that they wanted the new ISOFIX type 1 system.
Ninety percent were willing to pay a 50 percent increase over a normal
price of a child seat at that time.
Work on the system continued in subsequent meetings of the ISO
group in Stockholm in 1993, and Munich, where a list of features
considered essential for the system was developed. For example,
``misuse should be almost impossible, the cushion of the car seat
should have no influence on the system, and * * * the performance
should be better than the present systems.'' A ``UNIFIX'' proposed by
the UK was later changed to the UNIFIX-2 four-point, and in 1993 in San
Antonio, the ISO group decided that this was the system to develop. In
1993, the group had its first draft ISO standard on the system, and in
1994 it had a sixth draft completed.
In London in 1995, the ISO group split the draft standard into
three parts because there were problems with certain aspects of it. The
Blue Ribbon Panel indicated a positive regard for the ISOFIX system,
and the group received a resolution from the European Parliament
pushing them to introduce the ISOFIX as soon as possible.
In San Diego in 1995, General Motors presented its ideas on the
UCRA and the Blue Ribbon Panel modified its earlier support for ISOFIX.
In subsequent meetings in Cologne and London in 1996, GM presented its
findings on its user clinic, and the Hybrid system was presented. Since
then, a consumer clinic has been conducted on the different ISO schemes
and a working group meeting has been held in Albuquerque.
After reviewing the history of the development of the ISOFIX, Mr.
Turbell noted concerns to consider. He believed that the anchorage
system should be unrestricted by design patents. ``[Patents] will
probably stop [an internationally] standardized system.'' He noted a
concern about small cars being able to fit anchorage systems in a small
rear seat, stating ``[W]e can't let the available space in the smallest
rear seat decide the size of the child restraints.'' He also stated his
belief that rigid systems might have an advantage over other systems
with regard to the ease with which an air bag switch-off device can be
incorporated.
2. CANFIX 2-Point Rigid System
France Legault (Transport Canada), presenting Scheme B (CANFIX)
(the system is also known as CAUSFIX in Australia), explained that
Canada varied from the four-point ISOFIX system because of Canada's
high regard for tethers on child seats and tether anchorages in
vehicles. Canada requires anchorages in passenger cars, and will soon
introduce a regulation extending the requirement to trucks,
multipurpose passenger vehicles, and sport utility vehicles.
Ms. Legault stated that CANFIX has one flexible top tether anchored
to the body of the vehicle, and two lower rigid points based on the
ISOFIX system. CANFIX has the possibility to include improved tether
installation with better adjustability, e.g., in a reel or ratchet
mechanism. It also has the possibility of a tether interlock, which
would prevent the entire system from being installed if one of the
points is not attached, and the possibility of an air bag switch-off.
She said that before CANFIX was presented to the ISO group in 1995,
Canada conducted sled testing and found that performance of the system
was slightly improved over a conventional type of child restraint
system. In that work, Canada also was able to design and build a device
to test anchorages in a vehicle by pulling on them.
Canada's position on a universal child restraint anchorage system
is that while it has sponsored the two-point rigid system, Canada is
also open to the idea of soft anchors at the bottom ``depending on
usability and cost. * * *'' However, Canada definitely supports a
tether. Ms. Legault indicated that Canada will retain its head
excursion and chest acceleration criteria, which have the effect of
requiring a tether, because of the perceived safety benefits of a
tether. Canada will be improving its tether regulation to require
factory installation of the actual hardware for the anchorage.
Currently, Canada requires only a hole or a threaded hole, and the
consumer has to obtain and install the bolt and latchplate.
Canada believes harmonization is an important consideration in
developing a universal child restraint anchorage system. Cost is
important, and well as useability. Ms. Legault said that a positive
engagement feature (e.g., a click or other indication on an engaged
attachment) would be important for usability. She is concerned about a
``transition period,'' where new and old vehicles and child seats could
be intermixed. New child restraints equipped with components for an
anchorage system must be capable of use with older vehicles lacking a
system. Ms. Legault said that testing with a CANFIX prototype showed
that, in about 85 percent of its vehicles (lacking receptors for the
rigid points), the prongs would go in between the seat cushion and seat
back, so that the seat belt could still be used to attach the child
seat.
Canada is in the process of testing the CANFIX and several
conventional restraints to make sure that the tether will provide
additional protection, not just when it is properly used but also when
it is used with varying amounts of slack. Canada will be testing high-
mounted tethers and low-mounted tethers. Early test results show that a
tether improves performance in head and chest acceleration and head
excursion, even if the tether is loose. A tether also reduces neck
forces and moments.
Canada conducted surveys to determine the use rate of tethers. In a
1992 survey of owners of vehicles that provided no tether anchorage,
about 25 percent installed the anchorage and used it. Of vehicles that
had standard anchorages, tether use doubled. In addition, new data from
the Province of Quebec show that its tether use increased from 47
percent to 65 percent after vehicles became equipped with a tether
anchor, even when motorists had to take the extra step of installing
the tether anchorage hardware.
3. UCRA Soft Anchor System
David Campbell (Century Products), Kazuhiko Miyadara (Toyota), and
Jack Havelin (GM), presented Scheme C (UCRA) and the petition for
rulemaking on the UCRA. Mr. Campbell stated that the key objectives of
its work on a uniform child restraint anchorage system are ``to find a
single world-wide system, to address the issue of compatibility and
misuse, while improving dynamic performance of current restraints.'' He
stated that the system should be independent of the adult seat belt
system so that manufacturers can have the flexibility to optimize the
performance of the anchorage system for child restraints and allow the
adult seat belt system to be optimized for the other occupants in the
vehicle. Mr. Campbell stated that child restraint manufacturers believe
that the UCRA system is the best system because the buckle and latch
plate system is intuitive:
They are the type of systems that are currently available in
vehicles * * *. Secondly, it will minimize misuse. You won't have
the routing issues that we have through current child restraints
today with the vehicle lap belts because they are attached and you
know how to use it.
The UCRA also is designed so that current child restraints can be
easily adapted to use it. This could be done by
[[Page 7862]]
means of a special belt provided by restraint manufacturers. The belt
would have buckles on both ends to use with the UCRA latchplates, and
would route through the current belt path used today.
Mr. Campbell said that the manufacturing costs of the UCRA are
lower than those for some of the other systems. There also is less
added weight. He agreed with most of NHTSA's estimates about the weight
increases of the various systems, but believed the UCRA would add only
about 1 to 1.6 pounds (lb), rather than NHTSA's estimate of 4.5 lb. He
stated that it would take less leadtime to begin implementing a UCRA
requirement as opposed to the alternative systems, because the UCRA
uses ``existing technology--known systems, known belts, known buckles,
known latch plates.'' Expanding on the cost issue, the presenter stated
that current child restraints cost and sell at retail between $35.00
and $90.00 in the U.S.:
Our market price is very sensitive, and one of the objectives we
have is to increase the usage rate and not have a negative effect on
the current usage rate. Soft anchors are predicted to add something
in the order of magnitude of $20.00 to the cost of a child
restraint. The Canadian CANFIX, the estimates were about $55.00 at
retail, and for the ISOFIX it was $95.00. * * * Car seat loaner
programs could be affected by this.
Mr. Campbell also stated that the UCRA systems meets Standard 213's
performance criteria without attaching the tether. Tethered, it meets
Canada's requirements. He stated that use of the tether does
significantly reduce head and knee excursions, but there is some trade
off in chest accelerations and HIC values, and the use of the tether in
a higher position can help reduce that HIC.
Mr. Miyadara discussed past and current work evaluating usability,
safety and cost issues for a two-point rigid system, a two-point soft
system and current child restraint systems.
A past study evaluated usability in a customer preference clinic of
current, past and future users. No significant difference was found
between the two-point hard and the two-point soft system. Safety was
assessed in dynamic testing. Some differences in HIC and chest G values
were found, but the actual effect that those differences could have on
a child occupant were unknown. The presenter expected, though, that
safety could be somewhat improved with regard to chest Gs. The
presenter said that one of Toyota's biggest concerns with both a two-
point rigid and a two-point soft system is with potential ``loose fit''
of a child restraint on a vehicle anchorage system.
A study of vehicle and child seat cost impacts indicated that a
two-point soft system should be much more acceptable to the customer.
Mr. Miyadara discussed current work on addressing the ``loose fit''
issue. Toyota has been jointly developing a device that could be used
with a soft system to avoid the problem of consumers installing a child
seat so that its fit is too loose. Toyota is evaluating a strap type
device with belt adjuster, strap type with A-lock, lever-type and
ratchet type. Toyota believes that it can work out the loose fit issue
for a soft system in the near future.
Toyota's future work includes a customer preference clinic on the
Schemes A through C systems, and dynamic testing.
Mr. Miyadara concluded by stating that Toyota's goals in joining in
the AAMA et al. petition is to achieve international harmonization and
provide increased safety to children by eliminating or decreasing
misuse and improving crash performance, at a cost acceptable to the
consumer. Further, to address the problems of incompatibility as soon
as possible, the system should be implemented quickly. Mr. Miyadara
said Toyota does not believe there is any reason to select the two-
point rigid system over the two-point soft system. He also suggested
that NHTSA consider conducting a customer preference clinic of its own.
Mr. Havelin addressed what he believed to be confusion about GM's
position on a universal anchorage system. He said that GM supports an
internationally harmonized requirement. Mr. Havelin stated that GM
believes that an anchorage system should, foremost, increase child
restraint use rates (citing the statistic that three out of four of the
fatally injured children in the U.S. under the age of five are not
using a child restraint), and secondly, reduce the potential for misuse
and improve crash protection. GM suggested that NHTSA ``establish the
template'' for international harmonization by issuing an NPRM based on
three principles. ``First, what does our common customer want, that is,
the child seat manufacturer's customer as well as the vehicle
manufacturer's customer. We think the results of customer clinics need
to be tempered to some degree by sound benefit/cost analysis * * * And
finally, that template should be based on valid science. * * * [S]ome
[consumer clinics and cost analyses] are better than others and we need
to be focused on which ones are valid and which ones are not.''
Mr. Havelin said that GM believes consumers prefer the UCRA system
because the dual straps on the child seats use familiar anchorage
hardware, and provide an intuitive, secure installation. Also, the
tether is obvious and provides a secure anchorage. All three of the
strap anchors give a positive indication when correctly attached. He
said that other reasons the UCRA is preferred is that the child seat
would be light and compact, and without any threatening surfaces (e.g.,
rigid prongs) associated with it. GM believes that the UCRA is within
the acceptable cost range for consumers.
The presenter also highlighted other perceived benefits of the
UCRA, such as that it need not be tethered to meet Standard 213's
performance requirements, can be retrofitted into existing vehicles,
incorporates what GM considers to be ``fully developed and field-proven
hardware, and can be implemented faster than the other attachment
systems.''
4. European Industry Hybrid System
Klaus Werkmeister (Germany), presenting Scheme D, provided some
historical background on the development of a universal child restraint
anchorage system. He believed that interest in a worldwide universal
system started in the late 1980's to address a high rate of severe
accidents where children were killed or injured. Experts determined
that the real problem with those accidents was not the severity of the
crash, but the considerable misuse rate of child seats due to the wrong
adaptation of seat belts.
In preparing for an April 1996 meeting in Cologne of the ISO
Working Group of Child Restraint Systems, German vehicle manufacturers
met to identify criteria they believed were important for an anchorage
system. They developed a list of 12 properties. First, there should be
no top tether, due to concerns about its non-use. Second, the system
must have two lower symmetrical anchorage points, because unacceptable
performance may result from an unsymmetrical configuration. Third, due
to the configuration and dimensions of interior vehicle compartments,
especially of smaller cars, there must be a 250 mm to 280 mm lateral
spacing between the latch points. Fourth, the latch points must have a
degree of stability to ensure that excursion limits are not exceeded.
Fifth, the child restraint must be able to attach through a one-hand
operation, to ensure that the restraint can be easily installed.
[[Page 7863]]
Sixth, there must be a means to prevent attaching the child restraint
on one side only. Seventh, the user must be able to tension the child
restraint with one hand. Eighth, there must be no reduction of seat
comfort for adult passengers. Ninth, the locking device that attaches
the child seat to the vehicle system must be attached to the child
restraint, not the vehicle, to limit overall cost impacts. Tenth, to
avoid design restrictions, the locking device need not be required to
be a pushpad buckle. Eleventh, to ensure that a child restraint does
not have excessive webbing or ratcheting devices, the length of the
adjustment system used to tension the system should not exceed 200 mm.
Lastly, the dimensions of the latch points on the vehicle should be as
specified in Scheme A.
The presenter said that dynamic testing of the four-point rigid and
the soft anchor system showed a reduction in safety performance when
the systems are not properly tightened. Also, a non-symmetrical
configuration resulted in very high head acceleration.
Mr. Werkmeister said that the Scheme D system incorporates ideas
from both rigid and soft anchor systems. The system calls for defining
a field around the ISOFIX fixture, which might include an area behind
the seat bight (where hard anchors could be located), or an area in
front of the seat bight (where semi-rigid anchors could be). A
connector would be used to attach the child seat to the anchorage on
the vehicle. At the option of the child restraint manufacturer, the
connector could be attached to a piece of webbing (such as in the UCRA
system), or could be built into the child seat (as in the ISOFIX rigid
systems). The presenter estimates that the cost of the connector system
would be about $12 for the vehicle and $9 to $15 for the child seat.
The presenter expressed concerns about use rates for a top tether,
believing that use rates will be far less than Canada's 65 percent. He
also discussed concerns about the width between anchorage points and a
symmetrical configuration of the child restraint. He emphasized the
need for design flexibility in an anchorage system. He believed
manufacturers should be provided maximum design flexibility to meet
performance requirements and market demands, and believed that Scheme D
best provides this.
5. Car Seat Only System
John Reynolds and Carol Dingledy (Cosco), presented the ``Car Seat
Only (CSO)'' system. Mr. Reynolds stated that Cosco looked at three
critical issues when evaluating universal anchorage systems. First,
Cosco looked at performance and determined that a system must not
reduce the safety performance of existing child restraints. Second,
Cosco looked at ``implementation,'' or the transition phase between the
existing and new systems, the primary problem being the mix of new car
seats with old cars, and old car seats with new cars. Third, Cosco
looked at how the systems could affect the cost of child restraints,
and in turn, overall use rates. Mr. Reynolds stated that after
evaluating the systems under these criteria, Cosco decided to develop
its CSO system. Cosco believed that because the system is a simple lap
belt, it would have the least negative impact in terms of
implementation and transition. Further, the CSO system would have the
lowest cost to the car seat user, since the cost to the restraint
manufacturer is virtually none.
Ms. Dingledy elaborated on Cosco's concerns with implementation
time and cost. She said that adopting a system other than the CSO will
require considerable research on the part of child seat manufacturers
to determine if seats comply. She said that, given the variety of car
seats that must be tested (e.g., infant-only, convertible, forward- and
rear-facing) and the different types of vehicle seats, just researching
a new system prior to rulemaking will take at least many months, if not
a year or so. She also indicated that research is needed to determine
whether a rigid system might place excessive forces on a child's neck,
particularly a young child who has less developed neck muscles. She was
also concerned that the actual implementation of competing systems
would require long leadtimes to implement (possibly two to five years
development time, plus 10 years production time), as well as a great
deal of public education. The presenter stated that this is in contrast
to the CSO, which can be implemented much more quickly and which
requires little education. Ms. Dingledy said that international
harmonization of an anchorage system does not appear to be realistic in
the near term.
The presenter discussed cost concerns at length. She said that a
system that significantly increases the price of car seats will
decrease the number of new seats purchased at retail, possibly
resulting in (1) more used child seats being purchased or (2) more
children being incorrectly restrained in seats they have outgrown or by
adult belts when they are too small for the belts. She believes
consumers in the U.S. will resist purchasing car seats that retail
between $100 and $200, and that even a $20 increase would slash sales
dramatically. She indicated that the average price of a convertible
restraint is $63, but about one quarter of the car seats purchased cost
$50 or less; less than 5 percent cost $100 or more. She believes that
perhaps 10 percent of persons purchasing car seats would be unable to
purchase a seat if prices increase dramatically. She emphasized a
concern about the impacts of cost increases on loaner programs.
Ms. Dingledy estimated that a 10 percent decrease in child seat use
rates would result in approximately 40 additional child fatalities
annually. She also said that about three million car seats are sold
each year to retail stores and loan programs. The presenter cautioned
that a 10 percent reduction in the number of seats sold means 300,000
children per year riding without a new car seat, which translates into
1.2 million additional children riding unrestrained.
Ms. Dingledy stated that questions arising about the CSO system
concerning the possibility that adults may mistakenly use the CSO belts
are unwarranted. She said that an adult would prefer a lap/shoulder
belt to a lap only belt due to the superior performance and comfort of
a Type II belt. She also said that the CSO belt could be installed at a
location that makes it inaccessible for use with an adult, and could be
prominently labeled or color contrasted to distinguish it from an adult
belt system.
At the conclusion of her remarks, Ms. Dingledy introduced Frank
Rumpleton (appearing on behalf of the Juvenile Products Manufacturers
Association) (``JPMA''), who presented the views of the North American
car seat manufacturers. He said that the number one priority of these
manufacturers is to increase the usage and more importantly the proper
use of child restraint systems. In addition, they wish to ensure that
the changes made to child seats are simple, intuitive and easy for the
caregivers to use. They also support worldwide harmonization.
Underlying all these priorities, however, is the belief that
initiatives must be cost effective, because of a direct correlation
between cost and use rates. He said that every dollar of cost at least
doubles at the retail shelf. He suggested that the cost of an anchorage
system could be better absorbed on the vehicle side than on the child
restraint side.
The presenter said that JPMA categorically rejects the four-point
ISOFIX system and the two-point CANFIX or CAUSFIX rigid system, because
of cost. He said that JPMA supports soft anchor systems, which includes
the UCRA, CSO and Scheme D.
[[Page 7864]]
JPMA hoped that all parties attending the workshop would focus on the
soft systems as a starting point and focus on the similarities and the
positive aspects of each of these proposals, to develop a solution that
maximizes the potential use of child restraints and minimizes the cost
to the ultimate consumer.
b. Clinics
Separate presentations were made on the public acceptance and
support of the development of a universal anchorage system. The
Insurance Corporation of British Columbia (ICBC) along with Rona
Kinetics reported on the findings of its clinic on usability of various
alternatives. The study surveyed 76 subjects in Vancouver, Canada
representing a cross section of age, sex, and experienced/unexperienced
groups. General Motors presented the findings of a February 1996,
clinic that was conducted in Troy, Michigan with a sample of about 400
subjects. Toyota also presented a customer preference study on various
types of soft and rigid anchor systems that was conducted in Japan on
rigid and soft systems. Finally, a study was recently initiated in the
UK and a progress report on its findings of an initial small number of
subjects surveyed was presented.
Generally, the findings of these clinics were in agreement on two
major issues: 1) all subjects surveyed seem to prefer a universal
anchorage system over the current child restraints and 2) no
significant difference in consumer acceptance was detectable when
comparing between a rigid and soft anchorage system.
c. Cost
The participants agreed that the cost of the rigid options is much
higher than the soft anchorage system, with added costs to the child
restraint system of about $100 for the 4-point ISOFIX, $60 for the
CANFIX and $20 for the UCRA soft anchorage system. Cosco, whose
alternative does not incur additional costs to current child
restraints, raised important concerns regarding the potential negative
effects of high increases to the retail price of current child
restraints. Concerns over families not being able to afford the
increase and over loaner programs with fixed budgets for purchasing and
providing free child seats to low income families were discussed. The
issue of cost increases was in conflict with European countries
expectations, according to the attendants from Sweden who indicated
that these added costs do not have such implications as expected in the
U.S. market.
d. Tether
Other discussions addressed specific issues pertinent to the
development of universal child restraint anchorage systems. One major
issue that was discussed pertained to the upper tether. A
representative from the Insurance Institute for Highway Safety
presented an overview of the experiences and possible reasons for non-
use of the upper tether in the US during the 1980s. On the other hand,
a participant from Australia reported that the use of the upper tether
in Australia is about 98%. Transport Canada also reported substantial
increases in use of the tether in Canada. These experiences seem to
indicate that the high usage of upper tether stems from the fact that
the tether anchor points are provided on the vehicle and are visible to
and easily accessible for use by consumers. There appeared to be an
agreement among participants that a child restraint with an upper
tether provides better protection to the child during a crash.
e. Agreement on Differences
In the interactive exchange among attendees during the course of
the workshop, several important points relating to development of a
universal child seat anchorage system emerged. The following key views
were expressed:
User clinics indicate that consumers are overwhelmingly
unhappy with the manner with which current child seats are attached to
vehicle seats and wish to see improvement.
The various systems evaluated in consumer trials (ISOFIX,
schemes A through C) do not differ much in terms of safety performance
(assuming proper installation) and public acceptance.
Schemes B, C and D (CANFIX, UCRA and the Hybrid) are
virtually variations of the same system, except for the hardware used
to connect the child seat to the vehicle. CANFIX has specified a rigid
anchor and rigid connectors on the child seat. UCRA specifies a buckle
and latchplate system; the buckle would be on a piece of webbing
attached to the child restraint and the latchplate would be on a semi-
rigid stalk at the vehicle seat bight. The Hybrid system would specify
a 6 mm bar (e.g., a D ring) that could connect to a child seat either
in front of or behind the vehicle seat bight. The UCRA system differs
from the Hybrid system only with regard to the connector piece that
fastens the child restraint to the vehicle.
Purchasers of child restraints in the U.S. are very
sensitive to price. Sixty-four percent of the car seats sold in the
U.S. sell for less than $60. Consumers in this country are unwilling to
pay the $300 it costs on average for a child seat in Sweden.
The European manufacturers generally still prefer a rigid
system, while U.S. manufacturers oppose it. Canada has indicated a
willingness to move from a rigid two-point plus tether (Scheme B) to a
soft two-point plus tether system.
Scheme D (the Hybrid system) has potential in
accommodating both rigid and soft systems. It would provide the
greatest design flexibility, in that it would specify minimum elements
of the vehicle anchor (e.g., a 6 mm bar) and a location that could
connect to a child seat either in front of or behind the vehicle seat
bight. It would provide vehicle manufacturers the option of supporting
the anchor rigidly or semi-rigidly. Child restraint manufacturers could
choose any means to attach to the anchor. A child seat could have a
telescopic or a rigid device, or a soft attachment (piece of webbing),
so long as the child seat can attach to the anchor.
Each system has strengths but also possible weaknesses.
Questions were raised about the cost, weight and development time
needed for a rigid system, the slack that could be introduced into the
belts of a soft system and the suitability of a soft system with fold-
over seats, the need for anchors to be visible to consumers in a Hybrid
system, the possibility of slack and misrouted belts with the CSO
system, and the actual use of a top tether in tethered systems.
The various systems under consideration are unencumbered
by patents of any kind. Britax (a European child restraint
manufacturer), when asked about a certain patent application, expressly
declared that it holds no patents or applications for patent or other
claims that would hinder third parties from making ISOFIX equipped
vehicles or child restraints using rigid or semi-rigid anchorages.
f. Future Work
Manufacturers of motor vehicles and child restraints extensively
explored the differences between the UCRA and European hybrid systems
with an agreement to further develop this option to harmonize between
the European vehicle manufacturers and Britax and the US and Japanese
child restraint/vehicle manufacturers. These participants expressed
that future efforts would be made to elaborate on progress of this
development at a November 7 and 8, 1996, ISO Working Group on child
safety meeting in Albuquerque,
[[Page 7865]]
New Mexico and future meetings of the Group.
IV. Subsequent Developments
a. Albuquerque, New Mexico
During the November 7 and 8, 1996 meeting of the ISO Working Group
on Child Restraint Systems (ISO/TC 22/SC 12/WG 1), the Group voted on a
proposition containing two resolutions on the specifications for the
anchorage of a universal child restraint anchorage system. The first
resolution recognized the need to allow two anchorage systems: one
based on two-prong nonflexible hardware (a system that is under
development), and another based on flexible UCRA-type hardware (a
system that is available today). A second resolution opposed an upper
tether anchor in motor vehicles.
Following the Albuquerque meeting, the Secretariat of the ISO
Working Group opposed the proposition--which was intended to advise
different governments on how to treat the use of ISOFIX with and
without a top tether--on the basis that it goes beyond the mandate of
the Working Group. A re-voting of an amended resolution was conducted
by correspondence with the delegations of country members, and was due
back to the Secretariat on December 6, 1996. The voting on this
resolution was to select between: i) specifying a top tether anchorage
in vehicles; ii) not specifying the tether; or, iii) either of these
options. It was also agreed that two reports--one for the rigid and one
for the rigid/semi rigid options--will be prepared by members of the
Working Group to describe and specify these systems.
The result of the re-voting was a resolution to produce two draft
standards for universal child restraint attachment interfaces. One
draft standard would cover an attachment system comprising the UCRA-
type attachments on the lower points. The other standard would cover
the rigid anchorage system. The standards would not include
specifications for an upper tether anchorage. (The results of the re-
voting and copies of the rough drafts of the two reports were placed on
December 13, 1996 in Docket No. 96-095, Notice 01 for the readers'
review.)
b. Additional Information
On November 21, 1996, some of the UCRA petitioners provided the
agency with additional information supporting their petition. NHTSA
representatives met with representatives from General Motors, Century
Products, Indiana Mills and the Lear Corporation, at the request of the
latter, to discuss the resolutions of the ISO Working Group meeting in
Albuquerque. (A December 13, 1996 memorandum describing this meeting
and attaching the handouts is entry number 16 in Docket 96-95, Notice
1.) The petitioners emphasized that the North American child restraint
manufacturers strongly favor the UCRA system with an upper tether and
have doubts that a determination can be made at this time that the
rigid system would be a long term solution. They also presented the
findings of an evaluation that Indiana Mills performed in response to a
NHTSA call for harmonization during the public workshop. (The agency
had requested that hardware manufacturers explore the feasibility of an
anchorage system that would accommodate buckles, snap hooks and ISO-
type connectors with a flat latch or round link, for consideration at
the Albuquerque ISO meeting.) Indiana Mills described the advantages
and disadvantages of the various types of hardware and its reasons for
supporting the existing technology of a flat latch plate/buckle system.
Lear Corporation presented cost data for rigid and soft attachments to
various types of vehicle seating systems. It stated that the vehicle
added cost data should be considered as a complement to the NHTSA study
cost figures. Specifically, it included cost figures on items, such as
covers and trim of rigid anchors, that were not included in the costing
of the NHTSA study. The data showed that the costs of the soft
anchorage system per seat on the vehicle range from about $4 to $10, as
compared to about $13 to $30 for the rigid anchorage points system.
c. Petition on Scheme D (Hybrid System)
On December 18, 1996, BMW, Chrysler, Ford, Land Rover, Mercedes-
Benz, Volkswagen, and the University of Michigan Child Passenger
Protection Research Program, petitioned NHTSA to consider an approach
based on Scheme D and modify the suggestions made in the UCRA petition.
These petitioners supported a system incorporating two ``latch plates''
formed of 6 mm diameter elements for the vehicle, ``coupled with the
alternatives for the [child restraint system], namely, tether hooks or
buckles on belts with tilt-lock adjusters for tension release, or the
rigid ISOFIX connectors on a sliding element.'' The petitioners believe
that this system will offer vehicle and child restraint manufacturers
the greatest design flexibility, and will further international
harmonization at an early date.
V. Evaluation of Concepts
During the course of the agency's deliberations on a universal
child restraint anchorage system and as a result of the discussions at
the October 1996 workshop and other information, the agency has
tentatively determined that child seats can be better secured to a
vehicle (thereby reducing incompatibility problems and increasing
safety) by providing three anchorage points between the restraint and a
vehicle seat. One point is at the top center of the restraint
(attachment of a child restraint to a vehicle would be accomplished at
that point through a top tether), and the other two are at the vehicle
seat bight.
a. Top Tether
ISO Schemes B and C (CANFIX/CAUSFIX and UCRA) include provisions
for a top tether. Cosco indicated it would support a tether
requirement, although the manufacturer is concerned whether tethers
will be used in this country. The European systems do not call for
tethers.
As a result of the agency's deliberations on this rulemaking,5
the agency reevaluated its view of a top tether on child restraints.
NHTSA currently does not require a tether or a tether anchorage on
vehicles. The agency does not prohibit a tether, but generally requires
child restraints to meet Standard 213's 30 mph dynamic testing
requirements without attaching a tether to reflect the historically low
use rate of tethers in this country.
---------------------------------------------------------------------------
\5\ On November 15, 1996, the American Academy of Pediatrics
(AAP) petitioned NHTSA to amend Standard 213 to require child
restraint manufacturers to supply tether straps on all child seats
and require vehicle manufacturers to provide tether anchors at all
rear seating positions. AAP also requested that child restraint
manufacturers be required to make tether straps for existing car
seats available to consumers by mail order and at retail outlets.
NHTSA granted this petition on January 14, 1997.
---------------------------------------------------------------------------
NHTSA tentatively concludes that a top tether should be provided to
better secure a child restraint. By restraining the top portion of a
child seat, a tether would supplement the vehicle belt system in
limiting forward movement of the child restraint in a crash. With less
forward movement, head excursion can be reduced.
This document proposes a performance requirement that would have
the practical effect of requiring a tether on child seats. A new head
excursion requirement for forward-facing seats would be added to limit
excursion to 720 mm (28.35 inches) forward of the Z-point on the test
seat assembly when a child seat is attached
[[Page 7866]]
to the standard seat assembly in accordance with the manufacturer's
instructions. To meet this requirement, manufacturers will likely have
to provide a top tether, which would be attached in the test for this
new requirement. NHTSA believes that the head excursion limit of 720 mm
is practicable with a tether because it is the same as the Canadian
requirement and because most, if not all, child restraint manufacturers
currently produce child restraints for sale in Canada and thus already
meet the requirement for those products. The 720 mm requirement would
promote harmonization with Canadian requirements. Further, the European
child restraint manufacturers believe that a 720 mm limit could be
achieved with the rigid anchorage system with two lower anchorages and
no upper tether.
Test data strongly support the safety value of a tether. AAMA et
al. submitted test results in support of a requirement for a tether
anchorage, stating:
Test results clearly demonstrate that a fastened tether can
significantly reduce dummy head excursion measurements which most
developers and evaluators use as the primary predicator [sic] of a
CRS's performance in field accidents * * * .
An Australian report cites forward-facing CRS test results,
indicating that ``as well as reducing head excursion, a top tether,
with the right high mounted geometry, significantly reduces head
acceleration and neck loads in frontal impacts'' [footnote excluded]
* * * . Recent computer simulations and tests of the recommended
UCRA concept suggest that * * * a fastened tether significantly
reduces dummy head excursion during high severity frontal impacts.
Computer simulations conducted by petitioners AAMA et al. showed a
reduction in force levels experienced by a restrained dummy's head,
neck and chest when a tether was used as compared to no tether, and a
reduction in head and knee excursions. Actual testing of child
restraint systems with and without a tether showed that with the tether
attached, there generally were reductions in head injury criterion
(HIC) values and chest g's, and in head and knee excursions.
These findings are consistent with NHTSA's limited testing of
tethers. In two tests of an Evenflo Scout forward-facing convertible
seat with the inboard anchor of the lap belt restraining the child
restraint to the test seat assembly positioned four inches forward of
the seat bight, the HIC and 3 ms chest acceleration clip were 631 and
59.6 g's respectively. When the child restraint was tethered on its
top, these HIC and chest clip measurements were reduced to 503 and 42.2
g's, respectively.
In her comments at the October public workshop, Ms. Legault of
Transport Canada reported that on-going testing of tethered, untethered
and loosely-tethered restraints indicate improved head acceleration,
head excursion and chest acceleration with a tether strap, even when
the strap is loose. Additionally, upper neck forces and moments were
also improved with a tether. (Transcript of October 17, 1996, pp. 32-
34.) (However, Indiana Mills tests showed increased HIC and chest g's
for a child seat with a dual strap anchorage with a tether, compared to
one without a tether. Comments are requested explaining these
increases.)
However, nonuse of the tether has been a problem in the U.S. In an
effort to boost use rates, NHTSA once proposed requiring all vehicles
under 10,000 lb GVWR to have tether anchorages at all rearmost seating
positions, to make it possible for motorists to easily attach the
tether straps on their child restraints to the vehicle. 45 FR 81625;
December 11, 1980. At the time of the proposal, tether use was about 50
percent. NHTSA terminated rulemaking on this proposal after determining
that (a) since the proposal, there was a continual shift toward
untethered seats, so that most seats did not need a tether to meet
Standard 213's requirements; (b) motor vehicle manufacturers had
increasingly been voluntarily providing provisions, such as
indentations to identify anchorage points and pre-drilled or threaded
holes, in their vehicles to facilitate the attachment of tether straps;
and (c) the most effective way to promote child safety would be to
amend Standard 213 to require all child restraints to meet Standard
213's requirements without attachment of the tether. July 5, 1985; 50
FR 27632.
Petitioners AAMA et al. believe that a tether will be used. GM's
consumer focus group testing indicates a positive response toward a
tether, particularly if the tether anchorage is equipped with all the
components needed for use with the child restraint. The petitioners
state, ``Australian field experience shows very high tether use rates
are obtainable when factory installed tether anchorages are provided.''
(Emphasis in text.) Indeed, top tether use is reported in excess of 95
percent in Australia, primarily due to requirements for installation of
the anchorages and to early and continuous public education on the use
of tethers. ``Options for a Universal Child Restraint Attachment
System,'' M. Lumley, June 14, 1996, revised October 10, 1996.
Petitioners are also encouraged by information from the Canadian
Province of Quebec indicating a 65 percent tether use rate in vehicles
required to have just a tether anchorage, and not the tether hardware.
``This in spite of the fact, that vehicle owners must install the
tether anchorage hardware themselves or return to their dealer to have
it installed.''
In an effort to increase tether use in Canada, Transport Canada is
proposing to require vehicles to have a factory-installed, user-ready
tether anchorage, with hardware included. Transport Canada believes
that tether use will increase if an anchorage equipped with all needed
parts for consumer use is provided at the factory. NHTSA tentatively
believes that this information from petitioners AAMA et al. and from
Transport Canada provides a basis for concluding that tethers would be
used if child seats are equipped with a tether and vehicles are
equipped with a factory-installed, easy- and ready-to-use tether
anchorage. Accordingly, in view of the potential added safety value of
a tether, the agency proposes requiring installation of a ready-to-use
tether anchorage at the two seating positions that would be required to
have the lower anchorages dedicated for attaching a child restraint
system. (See infra, section VI.c.) For purposes of harmonization, the
proposed requirements for the tether anchorages are essentially
identical to those proposed by Transport Canada.
However, because NHTSA does not know the extent to which tethers
will be used in this country, the agency believes the standard should
also retain the present head excursion requirement, which limits
excursion to 813 mm (32 inches) without use of a tether strap.
Retaining the requirement would ensure a minimum level of safety
performance when the tether strap is not used. Further, NHTSA proposes
that child restraints dynamically tested on a child restraint anchorage
system with UCRA anchorages should be subject to the 813 mm (32 inches)
head excursion requirement without attaching the tether. This accords
with the AAMA et al. petition, which suggests not attaching the tether.
Comments are requested on this issue. Comments are also requested on
the potential of using tethers in aircraft.
b. Lower Anchorage Points
Improving the lower anchorage points of a child seat to the vehicle
would make it easier for parents to correctly attach a child seat to
the vehicle.
NHTSA stated in the Federal Register notice announcing the workshop
that an
[[Page 7867]]
anchorage system should accomplish the following:
Improve the compatibility between child restraint systems
and vehicle seats and belt systems, thereby decreasing the potential
that a child restraint was improperly installed;
Ensure an adequate level of protection during crashes;
Ensure correct child restraint system use by ensuring that
the child restraint systems are convenient to install and use;
Ensure that the child restraint systems and anchorages are
cost effective; and
Achieve international compatibility of child restraint
performance requirements for uniform anchorage points.
In remarking on the various ISO schemes and in other presentations,
participants in NHTSA's workshop concurred with and elaborated on these
considerations.
1. Improve Compatibility
All of the anchorage systems appear to improve compatibility
between child restraint systems and vehicle belt systems. Consumers
comparing ISO Schemes A, B and C systems against conventional child
restraints indicated that the new methods of attachment are easier than
current methods. Cosco's CSO system was not evaluated in these studies,
but to the extent that the CSO does not depend on a locking clip or
other means to adapt the belt to a child restraint, an improvement over
existing belt systems, at least concerning that aspect of design, can
be assumed. The CSO belt would still have to be routed correctly
through the child restraint. All anchorage systems would improve
compatibility between child restraint systems and forward-mounted
anchors. Views were expressed at the October 1996 workshop that Schemes
A, B and C systems would improve compatibility between child restraints
and contoured vehicle seats. A rigid anchor system may suspend the
child restraint above the contoured seat, and a UCRA would provide some
resistance to the side-to-side motion of a child seat on a humped
contoured seat. The CSO might not be as effective on humped seats in
limiting side-to-side motion of a child restraint.
2. Safety Performance
ISO Schemes A, B and C systems have performed satisfactorily in
dynamic tests. The CSO system has not been tested, but it simulates the
standard seat assembly used in Standard 213 compliance tests.
Consumer clinics indicate that ISO Scheme A, B and C systems are
comparable in terms of a user's ability to correctly install them.
Users are able to install child restraints correctly in those systems.
Scheme D and the CSO were not evaluated.
The degree to which an anchorage system will be correctly used
outside the context of a clinic is unknown at this time, but design
differences between the systems could affect such use. Attendees at the
public workshop expressed concern with potential misuse problems that
could arise by virtue of the design of each system. A type of misuse
that could occur with a rigid system (ISOFIX four-point or CANFIX) is
if the user does not fully attach all points of the system. Test data
indicate that performance of the child restraint is severely degraded
if one or more points are not attached. Some attendees believed that
users must be able to see clearly where to insert the child seat
connector to the vehicle system, and that a guide of some sort is
needed if the attachment point is behind the seat bight. Some believed
that an education campaign is needed to teach people how to use the
system since a rigid bar anchorage is unfamiliar in this country.
Proponents of the UCRA system believe that the soft anchor system
is superior to a rigid system in that the connectors are buckles and
latches that are consumer-familiar in design to the seat belt hardware
on vehicles. Proponents believe that users will know ``intuitively''
how to use the connector and will recognize the sound and feel of the
click that indicates a positive attachment. Several participants
expressed concern about a possible misuse problem arising due to the
presence of webbing on the connectors, i.e., that slack in the webbing
will negate a tight fit of a child seat on the system. Toyota indicated
it is developing a means of addressing this potential problem.
Cosco believes the CSO system ``is the most intuitive system
suggested because people have been using this type of system for
years.'' NHTSA believes that while users might be familiar with the
system, the CSO system poses some of the same problems as the lap belt
currently used to attach child restraints. The belt would have to be
correctly routed through the child restraint, which is a problem
occurring with present seats. Slack in the belt would negate a secure
fit of the child seat, so an adjuster of some sort would be needed, and
it would have to be positioned on the belt where a user could maneuver
around the child seat to tighten the belt. The seat belt would have to
be long enough to permit it to be fastened around all types of child
restraints, including restraints for children with special needs. A
common complaint with current child seats is the difficulty of routing
the belts through the system and pulling the belt tight. It appears
that the CSO system might not alleviate those problems in all
restraints. Further, there is the potential that the CSO belt would be
inadvertently used by an adult occupant as a restraint, particularly in
a seating position equipped with a lap belt, even if the CSO belt were
labeled.
It may be possible to attach child seats with either a rigid anchor
(ISOFIX four-point rigid, CANFIX) or a soft anchor (UCRA) system design
to a vehicle seat in the same way that current child seats are
attached, using the occupant belt system (and meet minimum performance
criteria). Thus, it may be possible to use them in a vehicle that lacks
an anchorage system. The ability to attach a child seat in a
conventional manner, i.e., using the vehicle belt, is an essential
feature addressing the use of new child seats with old vehicles, and
vice versa (old child seats with new vehicles). Ms. Legault of
Transport Canada said that testing with a CANFIX prototype showed that,
in about 85 percent of its vehicles (lacking receptors for the rigid
points), the prongs could be inserted between the seat cushion and seat
back, so the seat belt could still be used to attach the child seat.
All child seats with UCRA-designed anchorages can be attached to a
vehicle by use of the existing vehicle safety belt, because the UCRA
design is based on a simple addition of buckles to current models of
child seats. The CSO design would also result in all child seats being
able to be attached in a conventional manner. It is unknown whether the
four-point ISOFIX seat could be attached with an existing vehicle belt
and perform satisfactorily.
The various systems differ in their ability to allow child seats
and vehicles to be retrofitted with features of the anchorage system.
The ability to retrofit is desirable, since it would increase the
number of seats that provide improved protection. Retrofitting seats
and vehicles would provide all children the benefits of the improved
technology. It does not appear that the four-point ISOFIX or the two-
point CANFIX allows for retrofitting either the child restraint or the
vehicle. These rigid anchorage systems necessitate an elaborate
redesign of existing child seats. The anchorage pins on the vehicle
seat would have to be precisely aligned with the prongs on the child
seat to ensure that the system performs properly. Alignments of this
nature are generally
[[Page 7868]]
not believed to be feasible in the aftermarket.
Proponents of the UCRA system state that existing seats can be
installed using the UCRA system if the system is supplemented by a
special belt with buckles at each end that are compatible with the UCRA
latchplates on the vehicle. The belt would be provided to the owner of
the old (pre-standard) child seat to route through the existing belt
route path on the child seat. Further, proponents of the UCRA system
believe that vehicles can be retrofitted with the UCRA system. The CSO
system calls for no change in the design of a child seat, so old child
seats could be used with a CSO system in a vehicle. Cosco did not
indicate whether vehicles can readily be retrofitted with the CSO belt
system, although it appears as feasible as retrofitting them with the
UCRA system.
3. Consumer Acceptability
Consumer clinics indicate that ISO Scheme A (rigid four-point), B
(CANFIX) and C (UCRA) systems are comparable in terms of consumer
acceptance. Participants in GM's clinic indicated a preference for
UCRA. Scheme D and the CSO were not evaluated in the clinics.
Participants in all the clinics indicated a desire to see an
improvement in the way child restraints are attached to vehicles. With
regard to bulk and added weight to a child restraint, the CSO adds no
weight, and the UCRA appears to have an advantage over a rigid system
and the CANFIX. The rigid prongs and supporting structure on a rigid
system add much more weight than the buckles of a UCRA and also
protrude from the child restraint.
4. Costs and Burdens
Cost is an area where the systems differ greatly. The cost of the
rigid options is much higher than the soft anchorage system, with added
costs to the child restraint system of about $100 for the four-point
ISOFIX, $60 for the CANFIX and $14 for the UCRA soft anchorage system.
The agency is concerned that the $60 to $100 added costs of the rigid
systems could engender public dissatisfaction with child restraints,
reduce child restraint use rates and significantly reduce the number of
seats available through car seat loaner programs. The CSO system does
not incur additional costs to current child restraints.
Schemes A, B and C systems are fairly design restrictive, in
specifying the geometry and location of assorted components on the
vehicle and child seat. Scheme D (Hybrid) and the CSO specify only the
features of the vehicle system, and not of the child seat. Design
flexibility allows manufacturers latitude in meeting market demands and
developing new technology, yet would be a trade-off in standardization
of the anchorage system.
5. Harmonization
Harmonization was one of the major goals of the agency's October
1996 public workshop. NHTSA stressed the importance of international
harmonization during the workshop and urged ISO member country member
delegates to agree on a unique child restraint anchorage system.
The UCRA system would harmonize with Canada, Australia, New Zealand
and Japan in specifying a top tether. With the top tether proposal, the
proposed rule would harmonize with Transport Canada's current head
excursion threshold and with its planned new regulation proposing to
require manufacturers to provide anchors for tethers in motor vehicles.
The rigid anchor system is endorsed by European members of the ISO
Working Group.
6. Leadtime and Availability
The different systems are at varying stages of development in
design concept. Final design of the four-point ISOFIX system and the
two-point rigid CANFIX have not been completed, although proponents of
those systems believe that completion is imminent. Design of the UCRA
system is completed.
The view was expressed at the October 1996 workshop that the
leadtime needed to implement a requirement for a rigid system would be
much longer than that needed to implement the UCRA system. This is
because the UCRA uses ``existing technology--known systems, known
belts, known buckles, known latch plates'' (quoting David Campbell).
Cosco argues that its CSO system would be the fastest to implement.
7. Proposed System
The agency has decided to base a proposal for a universal child
restraint anchorage system primarily on the UCRA system. The four-point
and two-point rigid and the UCRA appear comparable in terms of safety
performance and public acceptance, but the UCRA appears to have
advantages over the others with respect to its cost impact, near-term
availability and ability to address intermix and retrofit issues.
Further, the UCRA system has advantages in terms of its usability. The
agency believes the familiarity of its components (particularly the
crucial connector pieces--buckles and latchplates--that attach a child
seat to the vehicle system) is a definite advantage over the other
systems. Also, the UCRA system is not as bulky or heavy as the other
systems, which increases its usability.
In addition, NHTSA believes that the soft anchor system has a
potential for use in restraining child seats in aircraft. The Federal
Aviation Administration (FAA) stated in a submission to NHTSA's docket
for the October 1996 public workshop on a universal anchor system that
``preliminary review and evaluation of the proposed ISOFIX systems
under consideration by [NHTSA] suggest that the UCRA concept presents
the best solution in the aircraft environment.'' 96-95-N01-008. FAA is
concerned that the rigid prongs of an ISOFIX-type child seat may not be
compatible with aircraft seat cushions or suited for narrow aircraft
seats.
While NHTSA has decided to propose the UCRA system due to its
advantages in cost, usability, potential for use in aircraft, and the
fact that it is proven technology available today, the agency is still
interested in the possibility of achieving harmonization on a universal
anchorage system. To that end, NHTSA is proposing to permit vehicle
manufacturers to substitute the two lower rigid points of ISO Scheme D
(the Hybrid system) in place of the UCRA anchors, provided that the
vehicle is also equipped with adapters that enable the lower rigid
points to accommodate UCRA-type child restraint systems.
The European manufacturer members of the ISO Working Group on Child
Restraints Systems believe that their countries will require the two
rigid anchorage points in the future.6 Accommodating both hardware
systems would be consistent with the agency's goal of solving the
problem of incompatibility between child restraints and motor vehicles
as expeditiously as possible, while promoting harmonization. The UCRA
system, being a well developed and familiar current technology, is
currently available. The non-flexible system would be given the
opportunity to be developed, tested and evaluated in the market place
to prove what its proponents believe to be its superiority as the child
restraint anchorage technology of the future.
---------------------------------------------------------------------------
\6\ It should be noted that the work thus far by the ISO has
been at the Working Group level. Any ISO standard on this matter has
still to go to higher committee before it becomes a standard.
---------------------------------------------------------------------------
NHTSA tentatively concludes that the two proposed systems can
coexist in the
[[Page 7869]]
short term. The UCRA system will not hinder any development of the non-
flexible hardware system. The proposed rule allows vehicle
manufacturers to install a 6 mm pin to attach a child restraint that is
equipped with jaw-type non-flexible hardware. The proposed rule would
not prevent manufacturers of child restraints from developing a
restraint with non-flexible hardware, and would facilitate a transition
to future technology. However, in the interest of eradicating
incompatibility problems henceforth, child restraints with non-flexible
hardware would be required to have components (e.g., buckles),
permanently attached to the child restraints, that are compatible with
the UCRA anchorages. This proposal considers the UCRA system to be
paramount, and a rigid system would be allowed as long as the UCRA
system is universal for all vehicles and child restraint systems.
c. Discussion of Alternatives
A number of other approaches have been suggested to minimize or
eliminate incompatibility between child seats and vehicle seats. This
section addresses these alternatives to the approach proposed today.
1. SAE Recommended Practice J1819
In 1994, the Society of Automotive Engineers (SAE) published its
Recommended Practice SAE J1819, ``Securing Child Restraint Systems in
Motor Vehicle Rear Seats,'' to promote compatibility between child
seats and vehicle rear seats and seat belts. J1819 provides voluntary
design guidelines to vehicle manufacturers for certain characteristics
of rear seats and seat belts, such as seat cushion shape and stiffness,
and seat belt anchorage location, belt length, buckle and latchplate
size, and lockability. In addition, J1819 provides design guidelines to
child seat manufacturers for child seat features that correspond to the
vehicle features.
J1819 specifies a ``Child Restraint System Accommodation Fixture''
to represent a child seat, so that designers of both the vehicle and
child seat can evaluate each product for compatibility.
NHTSA tentatively concludes that J1819 alone does not fully solve
incompatibility problems. It is a tool for evaluating incompatibility,
not a requirement that vehicle seats and child restraints must be
compatible.
In the October 1996 workshop, Mr. Howard Willson (who chairs the
Children's Restraint Systems Standards Committee of the SAE) stated
that J1819 might be amended to add ``a test for seat contour.'' The
test would enable vehicle manufacturers to ``identify seating positions
where it's probable that child restraints will not work well because of
seat contour.'' He also stated
I doubt that we will agree to simply design our seating positions so
that they're all as flat as the seats in a pick-up truck used to be,
for example. There is an appeal to a shaped seat, an appeal to the
users. (Transcript of October 18, pp. 8-9.)
At the same workshop, Mr. David Campbell said that a child
restraint anchorage system--
should be independent of the adult seat belt system so that
manufacturers can have the flexibility to optimize the performance
of the anchorage system for child restraints and allow the adult
seat belt system to be optimized for the other occupants in the
vehicle. (Transcript of October 12, p. 40.)
NHTSA tentatively agrees with this statement. Further, NHTSA
recognizes that it is very difficult for a single system to optimize
the safety protection for adults of all ranges and child restraints of
different types. Nonetheless, the agency requests comments discussing
possible design alternatives to a universal child restraint anchorage
system.
2. Lockability
In 1993, NHTSA amended its occupant crash protection standard
(Standard 208) to adopt a ``lockability'' requirement effective
September 1, 1995. The rule requires vehicle lap belts or the lap belt
portion of lap/shoulder belts to be capable of being used to tightly
secure child safety seats, without the need to attach a locking clip or
any other device to the vehicle's seat belt webbing, retractor or any
other part of the vehicle. 58 FR 52922, October 13, 1993. The
requirement applies to seating positions other than the driver's
position on vehicles with a gross vehicle weight rating of 10,000
pounds or less.
The rule requires the lap belt to be lockable and specifies test
procedures demonstrating compliance with the lockability requirement.
The rule does not specify how the vehicle belt is to be locked, except
to prohibit locking by ``inverting, twisting or otherwise deforming''
the belt webbing. An example of a permitted means of locking a belt is
extending the belt all the way, then feeding in the slack.
NHTSA tentatively concludes that the lockability requirement is
insufficient alone in addressing incompatibility problems. While the
requirement ostensibly makes a locking clip obsolete, it still depends
on the user knowing enough and making the effort to manipulate the belt
system. Also, the vehicle belt must be routed correctly through the
child restraint, which may not be an easy task in all cases. Further,
the lockability requirement does not address incompatibility problems
arising from forward-mounted seat belt anchors. Excessive forward
movement of a child seat can still occur, even if the feature is
engaged and the belt is ``locked.'' Comments are requested on this
issue. NHTSA is considering deleting the lockability requirement as
unnecessary if requirements for a child restraint anchorage system are
adopted. A lockability requirement may not be needed for a seating
system with a universal anchorage system since the vehicle's belt would
no longer be used for attaching a child restraint. However, lockability
might be needed to attach child seats that are not equipped for a
universal anchorage system, even if the vehicle seat has such a system.
3. Cosco's CSO system
Cosco's CSO system is appealing in its simplicity and low cost, but
the CSO system is essentially no different from the current lap belt
means of attaching child restraints to vehicle seats. NHTSA is
concerned that the CSO system might not make attaching a child seat
significantly easier than it is today. As noted previously, the CSO
belt would have to be correctly routed through the child restraint,
which manufacturers believe many consumers find difficult to do. In
addition, from photographs of the CSO system, it might be difficult to
tighten the belt. Consumers have expressed concern about their child
seat not being secure on the vehicle seat because of the lateral side-
to-side motion of the child restraint that occurs no matter how tightly
the lap belt is adjusted. On a contoured, humped, seat, there is even
more lateral ``play.'' The CSO system might not be able to address
these concerns. Cosco provided no data on these issues assessing the
viability of this approach. Another concern relates to the potential
that the CSO belt would be inadvertently used by an adult occupant as a
restraint, even if the CSO belt were labeled. It is also unknown how
consumers will accept the addition of more seat belt systems in the
rear seat, in addition to the Type I and II belts already provided in
the rear seat. The agency requests data or comment on any research that
has been done on the CSO system evaluating its acceptability by
consumers, its performance with child restraints, the potential for
correct use with child restraints and for misuse by adult passengers.
Focus group testing comparing the CSO system to the UCRA and other
standardized systems would be especially helpful.
[[Page 7870]]
VI. Proposal for New Vehicle Standard
a. Highlights of Proposal
The most significant requirements proposed by this document are
highlighted below.
(1) A new safety standard would require all passenger cars and
light trucks and vans to be equipped with a child seat anchorage
system, defined in the standard, at two rear seating positions. If an
air bag cutoff switch is provided that deactivates the air bag for the
front passenger position, one system would have to be provided in that
position, and another in a rear seating position. If there is no rear
seat and no air bag cutoff switch, an anchorage system would be
disallowed in the front passenger seat. A built-in child seat may be
substituted for one of the systems, but not both, since rear-facing
built-in systems are currently unavailable.
(2) The system would consist of two lower anchorages at the vehicle
seat bight (the intersection of the seat cushion and the seat back) and
a top tether anchorage. The lower anchorages could consist of either
UCRA-type latchplates or rigid anchorages (ISO Scheme D), provided that
connectors are provided with the Scheme D anchorages that enables a
child seat with UCRA buckles to be used with the rigid anchorages. The
child restraint system standard (Standard 213) would be amended, in
effect, to require child seats to be equipped with a top tether, and
with attachment components (e.g., buckles) that are compatible with the
UCRA latchplates on the vehicle.
(3) The proposed requirements would specify the construction of the
child restraint anchorage system, the location of the anchorages, and
the geometry of related components, such as the hardware that attaches
to a child seat.
(4) A new safety standard would specify performance and location
requirements for the tether anchorages. The standard would apply to all
tether anchorages installed in a vehicle, regardless of whether the
anchorage is required by a safety standard or voluntarily installed by
the manufacturer. The agency tentatively believes that all anchorages
should be subject to the proposed performance and location requirements
to ensure that any anchorage used in the vehicle performs properly.
(5) To prevent the anchorages from failing in a crash, the vehicle
anchorages, including structural components of the assembly, would have
to withstand specified loads in a static pull test.
(6) Child restraint systems would be dynamically tested under
Standard 213 when attached to the vehicle system. The standard seat
assembly specified in the standard to test add-on child seats would be
revised to incorporate the upper and lower anchorages of a child
restraint anchorage system. It would have both UCRA anchorages (Scheme
C) and rigid anchors (Scheme D). A head excursion limit of 813 mm (32
inches) would have to be met without attaching the top tether.
(7) A child seat equipped with features enabling it to be attached
to an anchorage system would also have to meet the present 813 mm head
excursion requirement of Standard 213 when tested with just a lap belt.
This is to ensure a minimum level of safety performance when the child
seat is used in a vehicle that does not have an anchorage system.
(8) In addition, each child restraint would have to meet a 720 mm
(28 inches) head excursion requirement when tested according to the
manufacturer's instructions. A tether provided with the child restraint
may be attached in this test.
(9) Instructions for using the anchorage system would have to be
provided with each child restraint and in the vehicle owner's manual.
As discussed above, this proposal is based on the premise that a
child restraint anchorage system would make child seats compatible with
motor vehicles, and thus increase the safety value of restraints. The
approach taken by this proposal would be to rectify the vehicle-to-
child restraint incompatibility problem along two lines: vehicles would
be required to have a child restraint anchorage system with components
``ready'' to attach a child seat, and child restraints would be
required to have components ``ready'' to attach to the vehicle system.
By having a dedicated anchorage system for child restraint systems,
manufacturers can optimize the designs of their vehicle belt and child
restraint systems to provide higher safety protection to both adults
and children.
A potential but seemingly necessary limitation in the proposed
compliance tests is that the vehicle system is statically tested by
devices that replicate the loads imposed by a child seat, and a child
restraint is dynamically tested on a seat assembly simulating a vehicle
seat. That is, an actual vehicle anchorage system would not be tested
with an actual child restraint, and vice versa. This is to avoid
possibly complicating enforcement efforts if an apparent failure arises
in a compliance test. If vehicles were tested with actual child seats,
and vice versa, and if a vehicle anchorage system, for example, were
found to fail the proposed requirements, an issue could arise as to
whether the failure was with the vehicle system, or with the child seat
attached to the vehicle system. To avoid this complication, the
compliance tests must be as controlled as possible to remove unknown
influences on the performance of regulated parts.
While the actual vehicle-to-child seat attachment would not be
tested, NHTSA believes that the performance obtained in the compliance
test will reflect the real-world performance of the anchorage system
and the child restraint. This is because the geometry of the belts and
latchplates primarily responsible for the vehicle-to-child seat
interface would be precisely specified by this proposal. These
components would have to be provided on vehicles and child seats
precisely as specified in the standards. In turn, these components, in
the same geometry as that specified in the standards, would be used in
the compliance tests. Thus, the vehicle-to-child seat interface should
be adequately tested.
b. Applicability
The requirement for a child restraint anchorage system would apply
to passenger cars and trucks and multipurpose passenger vehicles (MPVs)
under 10,000 pounds (lb) gross vehicle weight rating (GVWR) (hereafter
referred to as ``LTVs''), except as noted below.
Petitioners AAMA et al. suggested, with respect to trucks and MPVs,
that the requirement be limited to those with a GVWR of 8,500 lb or
less and an unloaded vehicle weight of 5,500 lb or less. AAMA stated:
The GVWR range suggested was incorporated using the identical
GVWR range currently required to meet the dynamic performance
requirements of FMVSS 208 for occupant protection. The relatively
small number of vehicles larger than those within this range, the
physical dynamics of these size vehicles and the unexpected use of
CRSs [child restraint systems] in them, support maintaining this
GVWR range for this proposal.
NHTSA agrees that vehicles with GVWRs of more than 10,000 lb are
much less frequently used to carry young children (as compared to
vehicles with GVWRs of less than 10,000 lb) and thus should be excluded
from a requirement to provide a child restraint anchorage system.
However, child restraint systems could be used in vehicles with a GVWR
between 8,500 and 10,000 lb, such as in vehicles used for
transportation to child care programs. In the interest of best ensuring
that a child restraint anchorage
[[Page 7871]]
system would be available when needed and to minimize incompatibility
problems between child restraints and vehicle seats to the extent
possible, NHTSA proposes to apply this rule to trucks, buses and
multipurpose passenger vehicles with a GVWR of 10,000 lb or less.
Comments are requested on this issue.
AAMA et al. suggested excluding walk-in van-type vehicles and
vehicles manufactured to be sold exclusively to the U.S. Postal
Service. The agency agrees that these vehicles are unlikely to be used
for transporting children in child safety seats. NHTSA made the
determination in the rulemaking adopting the lockability requirement,
supra, that these vehicles are not likely to be used to carry children
in child seats. Accordingly, NHTSA proposes to exclude these vehicles
from today's proposed vehicle standard.
The AAMA petitioners suggested that the standard should not apply
to a vehicle that ``the manufacturer designates as not intended for CRS
use.'' The petitioner further suggested that ``[v]ehicles not intended
for CRS use shall include this information in the vehicle's owner's
manual'' and on a label in the vehicle. The agency has tentatively
decided against this approach. NHTSA does not know, and petitioners did
not explain, why manufacturers should be permitted to exclude a vehicle
from the proposed requirements, given that such a provision could
substantially reduce the number of vehicles that are equipped with an
anchorage system. Reducing the universe of vehicles equipped with the
anchorage system would eviscerate the ``universality'' of the system,
which could result in many consumers not having an improved means of
attaching a child restraint in their vehicle.
c. Seating Positions
This proposal would require the child seat anchorage system (i.e.,
a top tether anchorage and lower anchorages) in two rear seating
positions. NHTSA proposes requiring the system to be placed in a rear
seating position because available data indicate that the rear seating
positions are the safest positions in which to install a child
restraint system. Vehicles that lack a rear seating position capable of
fitting a rear-facing child seat would be required to provide a system
in the front seat if the vehicle has a cutoff switch that deactivates
the air bag installed at the right front passenger position in the
vehicle. However, a child restraint anchorage system would also have to
be installed in the rear seat of these vehicles, because a rear seat
that is too small to fit a rear-facing child restraint can nonetheless
probably fit a forward-facing seat. If the vehicle lacks a rear seat
and does not have an air bag cutoff switch, an anchorage system would
be disallowed in the front passenger seat. A built-in child seat may be
substituted for one of the anchorage systems, but not both, since
built-in seats currently cannot accommodate a rear-facing restraint.
There was no consensus among the petitioners as to the number of
child restraint anchorage systems that should be required and where in
the rear they should be. Many believe that the system should be
installed at each of the outermost designated seating positions of the
second row (and a tether anchorage in the rear lap-belt center
position). The Japanese vehicle manufacturers believe that only one
rear seat position should be required to have the system. Fisher-Price,
a child restraint manufacturer, believes that the rear center seating
position is recognized as the safest and that the system should
therefore be required there.
NHTSA has tentatively determined that each vehicle with a rear seat
should have at least two rear seating positions that can properly hold
a child restraint system. The agency is concerned whether there is a
need for an anchorage system at more than two seating positions. NHTSA
requests information on this issue, such as demographic data on the
number of children in child restraints typically transported in a
family vehicle. It is noted that nothing in the proposed standard would
prohibit a vehicle manufacturer from voluntarily providing child
restraint anchorage systems in rear seats at more than the required
seating positions, if a purchaser wants additional systems.
This proposal does not specify that both anchorage systems would
have to be provided at an outboard position. In some vehicles with
large interiors, it may be possible to install one of the required
systems in a center seating position.
d. Construction
Requirements are proposed for the construction of the child
restraint anchorage system. The system would consist of two child
restraint anchorages at the vehicle seat bight and a tether anchorage.
1. Lower anchorages
The proposed rule would permit manufacturers to conform lower
anchorages to either option A, consisting of requirements based on the
UCRA system (ISO Scheme C), or option B, based on the Hybrid system
(Scheme D).
Option A (UCRA System)
For vehicles incorporating the UCRA system, the standard would
specify that lower anchorages are located 280 mm apart, measured to the
centerline of each latchplate when fully extended in a plane parallel
to the vehicle's longitudinal axis. When fully extended, the tip of
each latchplate must not extend more than 50 mm forward of the seat
bight. The 50 mm value was suggested to ensure accessibility of the
lower anchorages. The petitioners and the ISO ad hoc group specified
this figure in a November 15, 1996 draft ISO/WD13216-1i report. 7
NHTSA tentatively believes the value is reasonable to ensure that the
lower latchplates are not so rearward that they may be buried in the
seat bight, yet are not so forward that excessive forward movement of a
child seat could result.
---------------------------------------------------------------------------
\7\ This figure is consistent with the ISO/WD 13216-1i report
that are in the December 13, 1996 submittal to Docket No. 96-095,
Notice 1.
---------------------------------------------------------------------------
The standard would also specify the geometry of related components,
such as webbing and latchplates (tongues) of the lower anchorage
points. NHTSA is proposing the latchplate geometry that was suggested
in the petition by AAMA et al. The agency is proposing to specify the
geometry of these components as necessary to ensure the universality of
the anchorage system. 8 It negates the likelihood that a used
child restraint with particular attachment components would be ``handed
down'' or sold to a person owning a vehicle with an incompatible
anchorage system. Further, since a simple, effective way of testing
anchorage systems with varying components has not been devised,
specifying the geometry is the best means of ensuring that anchorage
systems will securely attach a child restraint, and provide an adequate
level of child protection.
---------------------------------------------------------------------------
\8\ While the geometry of the vehicle latchplates would be
mandated, child restraint systems would not have designs specified,
other than that to have ``components permanently attached to the
system that securely fasten to the [vehicle's] latchplates''
(proposed S5.9(a)). However, the agency anticipates the use of UCRA
buckles.
---------------------------------------------------------------------------
The lower anchorages would be equipped with specialized latchplates
that would attach to buckles on a child seat. The geometry of the
components is such that the webbing, buckles and latchplates are
similar in design to components found on current adult occupant belt
systems. This is to ensure that the components and their operation are
familiar to persons installing a child seat. The geometry of the
components is such that they are smaller in size than
[[Page 7872]]
like components on the adult occupant belt systems. This is to reduce
the likelihood that the person installing a child restraint might
confuse the belts and buckles of the child seat anchorage system with
the adult occupant belt systems.
Several participants at the October 1996 workshop expressed
concerns or suggestions about aspects of the UCRA's belt systems. Klaus
Werkmeister expressed concern that the UCRA system's lower anchorages
could be lost in the seat bight of a foldover seat after the seat is
flattened to make room for cargo and then reinstalled as a seat. On the
other hand, John Gane said that the ICBC clinic had folding rear seats
and that these didn't interfere with either the hard or soft anchor
systems. Transcript, October 17, 1996, page 228-230. Comments are
requested on this issue.
Mr. Gane also suggested that the ICBC clinic indicated that the
side straps for the UCRA should be distinguished from the straps
comprising the harness for the child. He said that when the straps were
not distinguished, ``we had a huge failure rate of people to understand
how the seat was intended to work.'' Id., p. 220. (Some clinic
participants attached the vehicle anchor belt to the child restraint's
internal harness.) ICBC later modified the UCRA child restraint to
color code the belts. Comments are requested on whether the straps of
the UCRA should be distinguished, and if so, what measures should be
required to distinguish them (e.g., color coding and/or labeling).
Howard Willson stated that the webbing-supported anchorages of the
UCRA should be required to have a specific stiffness so that users can
use one hand to attach the child seat connector to the anchorage. The
AAMA et al. petitioners also suggested that the latchplates should not
displace rearward more than 25 mm under a 50 N rearward load. Comments
are requested on the need for such a requirement, the level at which a
requirement should be set, the means of testing a requirement, and
limiting side-to-side deflection of the latchplates which may degrade
the ability to attach the child seat with just one hand. Comments are
also requested on any other performance that should be required of the
UCRA system to ensure that it will be effective.
Option B (Scheme D)
For vehicles incorporating the ISO Scheme D system, the standard
would specify anchorage dimensional and marking requirements developed
in draft by the ISO in ``ISO/WD 13216-1i Road Vehicles-Child Restraint
Systems-Standardized Universal Attachment to Vehicle (ISOFIX)--Part 1:
Dimensions and General Requirements,'' (November 15, 1996). The rule
would require the lower anchorages to be 6 mm diameter transverse
horizontal round bars with a minimum effective length of 25 mm. The
spacing between the bars would be 280 mm apart, center-to-center. This
value is harmonized with ISO to be agreeable with manufacturers of
European, Japanese and U.S. motor vehicles. 9 Other specifications
for the location of the lower anchorage bars would also be set forth in
the standard. The anchorage location zone would be determined using a
child restraint apparatus (see Figures 1, 2 and 3 of the proposed
standard).
---------------------------------------------------------------------------
\9\ This figure is consistent with the ISO/WD 13216-1i report
that are in the December 13, 1996 submittal to Docket No. 96-095,
Notice 1.
---------------------------------------------------------------------------
Vehicle manufacturers incorporating the Scheme D system would also
be required to provide connectors that would enable the system to be
used with a UCRA-type child seat. The connector would have a component
on one end that latches onto the 6 mm bar, and a UCRA latchplate on the
other for attaching a UCRA child seat to the anchorage system. Comments
are requested on the degree to which the geometry of the connector
should be specified. A connector would have to be provided for each
Scheme D lower anchorage point. NHTSA believes that a connector should
be provided to ensure that parents having a UCRA-type child restraint
can use the restraint in any vehicle. This aspect of the proposal was
not included in the petition from BMW et al. Those petitioners
suggested that a connector from a child restraint to the vehicle
anchorages should be provided on the child restraint, by the child
restraint manufacturer. Comments are requested on this issue.
2. Upper Anchorage
The tether anchorage would be harmonized with Canadian and
Australian requirements. Canada is preparing to require vehicles to
have a factory-installed, user-ready tether anchorage. While AAMA et
al. originally petitioned to require a specialized buckle that would be
compatible with a latchplate on a child seat tether, petitioners have
indicated a desire to harmonize with Canada and Australia. Thus, a
simple anchor (such as a ring) on the vehicle would be sufficient,
although a more sophisticated anchor could be provided if it is
compatible with the tether hook that today's NPRM proposes to require
on child restraints.
e. Performance
The main performance requirement for the anchorage system would
specify strength criteria for the lower and upper anchorages and
related hardware. In addition, the standard would require the system to
meet Standard 209's belt and buckle requirements, such as those
relating to abrasion, resistance to light, corrosion resistance and
temperature resistance. Comments are requested on whether Standard
213's buckle release requirements (S5.4.3.5) should also be met. Among
other things, those requirements specify that a buckle must not release
when subjected to a force of less than 40 N, and shall release when a
force of not more than 62 N is applied.
The proposed strength criteria are to prevent the anchorages from
failing in a crash. The anchorages, including structural components of
the assembly, would have to withstand specified loads in a static pull
test.
The performance criteria for the lower anchorages would require
that, in a static test of the anchorages: (a) no portion of the
latchplate for each anchorage shall move more than 125 mm forward of
the seat bight when subjected to a forward force of 5,300 N and, (b)
there shall be no complete separation of any anchorage component of the
assembly (including webbing, straps, latchplates, adjustment and
anchorage hardware and retractors).
The static pull test would specify that each lower anchorage is
tested to withstand the application of a 5,300 N forward load. In the
test, a force of 5,300 N would be applied to each anchorage in the
forward direction parallel to the vehicle's longitudinal vertical
plane. The force would be applied by means of a belt strap that is of
sufficient length to extend not less than 250 mm forward from the
vertical plane intersecting the seat bight. The belt would be fitted at
one end with hardware for applying the force, and at the other end with
hardware for attachment to the anchorage latchplate. The 5,300 N force
is attained within 30 seconds, with an onset force rate not exceeding
135,000 N per second, and is maintained at the 5,300 N level for ten
seconds. The test procedure and force level were selected to harmonize
with the proposed Canadian regulations on the upper tether, as well as
with the suggested force level of the UCRA petition. The same test is
proposed for the rigid anchor system with the adapter attached to each
anchor point.
[[Page 7873]]
A static pull test would also be specified in a new standard
10 for the upper tether anchorage, in accordance with Canada's
proposed tether anchorage requirement. The force level and application
rate would harmonize with the proposed Canadian regulations on the
upper tether. The standard would specify that each structural component
of the anchorage shall withstand a force of not less than 5,300 N, and
that there shall be no complete separation or failure of any anchorage
component. Comments are requested on whether more specificity is needed
for these strength requirements, and on whether other performance
requirements should be included in the standard.
---------------------------------------------------------------------------
\10\ Assuming a final rule on this subject is issued, the
requirements set forth in the proposed tether standard could be
incorporated into the standard on the child restraint system
anchorage system, rather than in a separate standard.
---------------------------------------------------------------------------
Each tether anchorage would be tested separately. However, more
than one tether anchorage installed on a row of seats would be tested
simultaneously.
f. Instructions
The standard would require that instructions about attaching a
child restraint to the vehicle anchorage system be provided in the
vehicle owner's manual. The instructions would have to indicate the
seating positions equipped with a child restraint anchorage system, and
include instructions that provide a step-by-step procedure, including
diagrams, for properly attaching a child restraint system to a vehicle
anchorage system equipped with UCRA-type anchorages. In addition, for a
vehicle equipped with a rigid anchorage system, instructions would also
have to be provided for properly attaching a child restraint to the
rigid system.
VII. Proposal for Amendments to Child Seat Standard
a. Applicability
Standard 213 would be amended to require all child seats, other
than belt positioning seats, to be equipped with components that are
compatible with the UCRA anchorages on the vehicle system. Belt-
positioning seats, which are a type of booster seat designed for older
children, are designed to use a vehicle's lap and shoulder (Type II)
belt system to restrain the child occupant. Because a vehicle's belt
system is not necessarily directly routed around or through a belt-
positioning seat to secure it to a vehicle, and because upper torso
protection is provided by the shoulder portion of the Type II belt,
there does not appear to be any incompatibility between a vehicle seat
or its seat belts and belt-positioning seats. Also, because a Type II
belt system is placed around the child occupant who is seated on a
belt-positioning seat, there would be a minimal amount of forward
movement of the child and child seat before forward movement is
restrained by the Type II belts.
b. Required Components
Requirements would be established for the components of the child
seat that attach to the vehicle system. A child restraint would be
permitted to have components that attach to rigid or semi-rigid Scheme
D anchorages (Hybrid system), but the restraint must nonetheless have
the UCRA attachments permanently attached to it. This would ensure that
persons owning any type of child seat can use the restraint in any
vehicle (i.e., all vehicles would be able to attach a UCRA-type seat,
either attached to a UCRA system, or by way of UCRA connectors to
Hybrid anchorages). The agency requests comments on whether child
restraints intended to be used with systems that have Hybrid anchorages
should be required to provide an adapter, rather than the UCRA
components.
By way of reduced allowances on head excursion, each child seat
would be required to have a tether that attaches to the vehicle. To
minimize the chances of incompatibility between the seat and the
vehicle, the standard would specify the exact geometry of the tether
hook.
The regulatory text for this proposal does not include a provision
that the child seat components attaching to the lower anchorages of the
vehicle system have retractors to take up excessive slack in the belts.
NHTSA requests comments on whether a retractor is needed or is manual
adjustment enough to ensure that the child seat will be snug against
the vehicle seat back. Excessive slack in the connecting belts could
result in excessive head and knee excursions for the child occupant,
and a greater likelihood of head impact.
In the October 1996 workshop, Kazuhiko Miyadara, Jocelyn Pedder of
Transport Canada, and others indicated that a soft anchor system should
have a means of taking up slack in the belts. Comments are requested on
what type of retractor, if any, should be specified for the UCRA.
c. Dynamic Performance
The dynamic test specified in Standard 213 would be used to
evaluate the performance of the child seat when attached to the
universal vehicle anchorage system. The standard seat assembly
specified in the standard to test add-on child seats would be revised
to incorporate a child restraint anchorage system meeting the proposed
specifications. A child restraint would be attached to the system using
the appropriate buckles and other components of the child restraint.
Injury criteria and other performance requirements specified in
Standard 213 would have to be met when the child seat is attached to
the anchorage system.
Forward-facing restraints would be required to meet a head
excursion limit of 720 mm (28.35 inches) when tested in accordance with
its manufacturer's instructions. To meet this requirement, most
manufacturers would likely have to provide a top tether, which would be
attached in the test for this new requirement. Restraints would also be
required to meet a head excursion limit of 813 mm (32 inches) when the
tether is not attached, to ensure that a minimum level of safety is
provided in a misuse situation. Each child seat would also have to meet
the 720 mm (tethered) and 813 mm (untethered) head excursion limits
when attached by a lap belt. This test would be to ensure a minimum
level of safety performance when the child seat is used in a vehicle
that does not have a UCRA or rigid anchor system.
NHTSA believes that Standard 209's belt and buckle requirements
relating to abrasion, resistance to light, corrosion resistance and
temperature resistance, should apply to the webbing and hardware
installed on a child seat to connect to a vehicle system as required by
the existing provisions of S5.4 of Standard 213. The agency tentatively
concludes that these belt and buckle requirements of Standard 209
should apply to ensure the safe performance of the belts and associated
hardware.
d. Instructions and Labeling
Standard 213 would be amended to require that instructions about
attaching a child restraint to the vehicle anchorage system be provided
in the printed instructions accompanying each restraint. The
instructions would have to provide a step-by-step procedure, including
diagrams, for properly attaching a child restraint system to a vehicle
anchorage system equipped with UCRA-type anchorages, and if the child
restraint is intended for a vehicle equipped with a rigid or Hybrid
anchorage system, instructions for properly attaching to such a system.
NHTSA also proposes amending Standard 213's labeling requirements, to
either add a new provision or amend an existing one such as S5.5.2(g),
to instruct owners to secure the child restraint system with either a
vehicle
[[Page 7874]]
belt or components attaching to a vehicle's child restraint anchorage
system.
S5.5.2(j) of Standard 213 would already require a label instructing
owners to secure the top tether strap of the child restraint. That
section states that in the case of each child restraint system equipped
with an anchorage strap, the following must be permanently labeled:
SECURE THE TOP ANCHORAGE STRAP PROVIDED WITH THIS CHILD RESTRAINT AS
SPECIFIED IN THE MANUFACTURER'S INSTRUCTIONS.
Comments are requested on what changes, if any, should be made to this
labeling requirement to increase the likelihood that parents will
attach the top tether strap.
VIII. Proposed Effective Date
In their petition, AAMA et al recommended a schedule for phasing in
the suggested requirements, should those requirements be adopted. The
petitioners requested different schedules for vehicle manufacturers,
child restraint manufacturers, and final-stage vehicle manufacturers
and alterers. The latter group of manufacturers are typically small
businesses. (See table 2, below.) The schedules suggested by AAMA et
al. are based on the assumptions that (a) the attaching system
envisioned by the petitioners is adopted, and (b) a final rule is
issued by January 1, 1997.
The petitioners suggest that vehicle manufacturers be permitted two
alternatives in phasing in complying vehicles, beginning September 1,
1998. Under the first alternative, 10 percent of the vehicles
manufactured in the first model year after September 1, 1998, would be
required to have the child restraint anchorage system (manufactured on
or after September 1, 1998, through August 31, 1999), 30 percent of the
vehicles manufactured in the second model year (ending August 31,
2000), 50 percent in the third model year (ending August 31, 2001), and
100 percent in the fourth year (ending August 31, 2002). Under the
second alternative, no vehicle need comply with the proposed standard
before September 1, 2000, but 75 percent of a manufacturer's vehicles
produced on or after September 1, 2000 through August 31, 2001 (model
year 2001) would have to comply with the requirements, and 100 percent
of its vehicles manufactured on or after September 1, 2001 would have
to comply.
The requested schedule for child seat manufacturers also includes
two alternatives for phasing in complying child seats, beginning
September 1, 1998. The petition refers to child restraints manufactured
in a particular ``model year,'' which apparently assumes the September
1 to August 31 cycle traditionally used to designate vehicle model
years. Under the first alternative, 5 percent of the child seats
manufactured in the first ``model year'' after September 1, 1998 would
be required to have the components enabling the child restraint to
attach to the universal vehicle system (model year ending August 31,
1999), 15 percent of the child restraints manufactured in the second
model year (ending August 31, 2000), 25 percent in the third model year
(ending August 31, 2001), and 100 percent in the fourth year (ending
August 31, 2002). Under the second alternative, no child restraint need
comply with the proposed amendments to Standard 213 before September 1,
2000, but 50 percent of a manufacturer's restraints produced on or
after September 1, 2000 through August 31, 2001 (model year 2001) would
have to comply with the requirements, and 100 percent of its child
seats manufactured on or after September 1, 2001 would have to comply.
The petitioners provided the following table showing the requested
phase-in schedules for vehicle and child seat manufacturers:
Petitioners Requested Phase-In Alternatives (Percent of Products Required to Comply)
----------------------------------------------------------------------------------------------------------------
Vehicle Child seat
manufacturers Vehicle manufacturers Child seat
Model year alternative #1 manufacturers alternative #1 manufacturers
(percent) alternative #2 (percent) alternative #2
----------------------------------------------------------------------------------------------------------------
1999........................................ 10 0 5 0
2000........................................ 30 0 15 0
2001........................................ 50 75 25 50
2002........................................ 100 100 100 100
----------------------------------------------------------------------------------------------------------------
The requested schedule for final-stage manufacturers and alterers
would provide these manufacturers the option of using the phase-in
schedule for vehicle manufacturers, described above, or the alternative
of having the requirements become mandatory on September 1, 2001 for
100 percent of a manufacturer's vehicles, and not before.
NHTSA has made the following tentative decisions about leadtime.
The agency believes that the proposed requirement that vehicles provide
a user-ready tether anchorage and that child seats provide a tether can
be made effective at a much earlier date than a requirement for the
lower anchorages of a child restraint anchorage system. Passenger cars,
in particular, generally are already equipped with a tether anchor
(Canada has required a tether anchorage in passenger cars since 1989),
so it appears that a user-ready anchorage can be provided in the near
future. Canada is proposing an effective date of September 1, 1999 for
its tether hardware requirement for passenger cars. NHTSA proposes that
its tether anchorage requirement for passenger cars be the same as the
Canadian proposal.
For LTVs, Canada has also proposed that its tether anchor (hole)
requirement be effective September 1, 1999, and its tether hardware
requirement effective a year later. In view of these dates and that
anchorages (holes) are apparently not as currently available on LTVs as
on passenger cars, NHTSA proposes a September 1, 2000 effective date
for its tether hardware requirement for LTVs.
With regard to child restraints, restraints manufactured in the
U.S. and sold in Canada already are equipped with a tether to meet
Canadian requirements. NHTSA believes that most U.S. manufacturers
produce child restraints for sale in Canada. NHTSA is considering an
effective date of September 1, 1999 for its proposal to effectively
require tethers by way of reducing Standard 213's head excursion
requirement.
As to a requirement for the lower anchorages, the petitioners did
not explain why a phase-in is needed, or why more than four years would
be needed to implement the requirement. The agency is determined to
remedy the
[[Page 7875]]
problem of incompatibility of child restraints and motor vehicles as
promptly as possible and requests comments on the feasibility of having
full implementation (100 percent of affected vehicles) in a shorter
period, e.g., two years after the publication of a final rule. GM
indicated in the UCRA petition that if allowed, it would begin
installing the UCRA system on vehicles before completion of this
rulemaking on UCRAs. (NHTSA replied in an August 27, 1996 letter that
manufacturers are permitted to voluntarily install the system before
completion of a final rule.) Given that the UCRA technology is
developed and available, and capable of being installed in today's
vehicles, the agency believes the system could be implemented within
two years. The same issue arises with regard to the effective date for
requiring child restraints to be equipped with buckles and other
components compatible with the UCRA system. Comments are requested on
why a phase-in is needed, and on whether a shorter compliance date is
possible.11
---------------------------------------------------------------------------
\11\ A phase-in of an amendment to an equipment standard is
uncommon. It should be noted that to implement a phase-in
requirement, the agency would require manufacturers to provide
information on the total annual sales of their seats, so that the
agency can determine whether the requisite number of seats complied
with the new requirements.
---------------------------------------------------------------------------
NHTSA recognizes that the rigid attachment system may need longer
time to implement, especially on vehicles that may need to redesign
their vehicle seats and/or floor pans. This was acknowledged by the
international safety community in the December 6, 1996 ISO resolution
that the rigid system is a hardware alternative that needs some time
for development, as compared to the flexible hardware option. (See
section IV.a., supra.) The agency's proposal would allow the long term
rigid anchors solution to coexist with the UCRA approach that is
available today. Even though the proposed lead time of 24 months may
not be sufficient for the rigid anchorage hardware technology, the
proposed rule provides vehicle manufacturers with the option of
implementing the rigid system (with connectors) once it is developed,
while providing a UCRA-type system in the short term.
IX. Rulemaking Analyses and Notices
a. Executive Order 12866 (Federal Regulation) and DOT Regulatory
Policies and Procedures
NHTSA has examined the impact of this rulemaking action and
determined that it is economically significant within the meaning of
Executive Order 12866 and significant within the meaning of the
Department of Transportation's regulatory policies and procedures.
NHTSA has prepared a Preliminary Economic Assessment (PEA) for this
notice which discusses issues relating to the potential costs, benefits
and other impacts of this regulatory action.
A copy of this analysis has been placed in the docket for this
rulemaking action. Interested persons may obtain copies of this
document by writing to the docket section at the address provided at
the beginning of this notice.
To briefly summarize the analysis, NHTSA estimates that the cost of
a rule requiring the UCRA system would be approximately $160 million.
The cost of the rule related to the vehicle would range, per vehicle,
from $3.88 (one UCRA in front seat only) to $7.76 (for one UCRA in
front seat and one in back seat or two UCRAs in rear seats). NHTSA
estimates that 15 million vehicles would be affected: 9 million
passenger cars and light trucks with ``adequate'' rear seats, 3 million
vehicles with no rear seat, and 3 million vehicles that can only
accommodate a forward-facing child seat in the rear seat (not a rear-
facing infant seat). The cost of the rule for vehicles is estimated to
be about $105 million. The cost of the UCRA attachments on the child
seat is estimated to be about $55 million (3.9 million child restraints
(excluding belt-positioning boosters) at $14 per seat).
The benefits of the rule are estimated to be 24 to 32 lives saved
per year, and 2,187 to 3,615 injuries prevented.
As discussed in the PEA for this proposal, in view of the cost of
the UCRA attachments on a child restraint, estimated to be about $14
per restraint, NHTSA requests information on the price elasticity of
child restraints. NHTSA is concerned about the potential effects of
this rule on the purchase behavior of consumers. As one participant in
the October 1996 workshop pointed out, if consumer demand is
sufficiently sensitive to new car seat prices, the resulting changes in
car seat usage could partially or totally offset the benefits of the
proposed rule. NHTSA has estimated that the proposed rule will raise
the price of the average car seat by $14. For a $50 car seat, this
represents a 28 percent increase in price. On the other hand, each of
the States and the District of Columbia require the use of child
restraints in motor vehicles. To what extent, if at all, would an
increase in the price of a child restraint lead to a decrease in demand
for the product, notwithstanding child restraint use laws mandated by
each State? Also, NHTSA and child restraint manufacturers have been
inundated with calls from parents asking for help in installing seats
correctly. Would this interest in child safety motivate a sufficiently
large number of people to pay $14 for changes to a child restraint that
would make a restraint easier to install and more secure on a vehicle
seat? NHTSA is especially interested in comments from consumers on
these questions.
Consumers have essentially four choices: buy a car seat despite the
higher price, buy a used seat, seek a giveaway or loaner program, or
forego the seat altogether. If a 28 percent price increase were to
result in a 10 percent decrease in new sales and thus a corresponding
decline in usage (assuming options two and three are not available),
then the estimated benefits of the rule (24 to 32 fatalities prevented
per year) could be offset by an estimated 24 fatalities from reductions
in the number of seats in use. Consumers turning to the used car seat
market would receive no benefit from the proposed rule. The offsetting
effects would be reduced if there is a corresponding increase in
giveaway and loaner programs, but by virtue of the price increase these
programs would have to find new or additional funding.
The agency does not know how many programs exist and requests
information on this issue. A cost increase could result in fewer seats
being purchased by the program for loan or giveaway. On the other hand,
persons responsible for some State loaner/giveaway programs informed
the agency that if the new seats cost more, they would be able to find
the funding to keep up with demand. They also said that the time saved
installing child seats in each vehicle and making adjustments would be
worth the difference in price.
Unfortunately, NHTSA has not located any data or estimates of the
actual sensitivity of new child restraint sales to price changes. For
the sake of comparison, a large proportion of consumer goods exhibit
greater sensitivity to price than that described in the hypothetical
example above, even in the short run. If new child restraint purchases
in fact exhibit the same magnitude of price sensitivity as many other
consumer goods, the proposed rule could increase rather than reduce the
overall risks to the Nation's children.
For these reasons, NHTSA strongly encourages data, analyses, and
comment on this issue. The agency also requests comments on ways to
mitigate these effects, such as ways to minimize effects on price. For
example, the $14 cost increase includes the cost of two buckles that
attach to latchplates of the
[[Page 7876]]
UCRA system on the vehicle. Would costs be reduced if the latchplates
were part of the child restraint and the buckles part of the vehicle
system? This assumes that the buckle hardware is of higher cost than
the latchplates. Should NHTSA conclude that both (1) the combination of
expected child restraint price changes and consumer sensitivity to
those price changes is sufficiently large and (2) there are no cost-
effective ways to mitigate these effects such that the final rule will
result in a net increase in child safety, NHTSA would need to
reconsider the proposal.
b. Regulatory Flexibility Act
The Regulatory Flexibility Act of 1980 (Public Law 96-354), as
amended, requires agencies to evaluate the potential effects of their
proposed and final rules on small businesses, small organizations and
small governmental jurisdictions. Section 603 of the Act requires
agencies to prepare and make available for public comment an initial
regulatory flexibility analysis (IRFA) describing the impact of
proposed rules on small entities. NHTSA has included an IRFA in the PEA
for this proposal.
NHTSA tentatively believes that the proposed rule could have a
significant impact on a substantial number of small entities. The
proposed rule would affect motor vehicle manufacturers, almost all of
which would not qualify as small businesses, and portable child
restraint manufacturers. NHTSA estimates there to be about 10
manufacturers of portable child restraints, four or five of which could
be small businesses.
Business entities are generally defined as small businesses by
Standard Industrial Classification (SIC) code, for the purposes of
receiving Small Business Administration assistance. One of the criteria
for determining size, as stated in 13 CFR 121.601, is the number of
employees in the firm. There is no separate SIC code for child
restraints, or even a category that they fit into well. However, there
are categories that could be appropriate. To qualify as a small
business in the Motor Vehicle Parts and Accessories category (SIC
3714), the firm must have fewer than 750 employees. The agency has
considered the small business impacts of this proposed rule based on
this criterion. On the other hand, to qualify as a small business in
the category including manufacturers of baby furniture, the firm must
have fewer than 500 employees. Comments are requested on which Standard
Industrial Classification code would best represent child restraint
manufacturers.
The IRFA discusses the possible impacts on small entities and
requests information that would assist NHTSA in further analyzing those
impacts. As discussed in the IRFA, the incremental cost increase of $14
to the current price of a child restraint would significantly raise the
price of child restraints, which could have a significant economic
impact on a substantial number of small businesses. NHTSA does not know
the elasticity of demand for child restraints. While child restraint
use is mandated by each State, there is significant nonuse of
restraints. An increase in the price of a child restraint could lead to
a decrease in demand for the product, notwithstanding the restraint use
laws.
According to information from Cosco (see summary, above, of NHTSA's
October 1996 public workshop), the average purchase price of a
convertible car seat today is $63. About 25 percent of the car seats
purchased cost $50 or less; less than five percent cost $100 or more.
Cosco estimated that at least 10 percent of the people would not be
able to purchase a car seat if prices increased significantly.
Comments are requested on the effect that raising child restraint
prices by $14 (UCRA attachments) to possibly $100 (hard anchor system)
would have on small businesses that manufacture child restraints. Would
an across-the-board increase in price reduce small business sales? What
is the magnitude of the impact?
As discussed above in section IX.a., a loaner program could have
fewer seats available. Assuming that would be the case, NHTSA seeks
information on the extent to which the number of seats a program makes
available impacts on the organization itself. For example, do proceeds
from loaner or giveaway programs (where a nominal fee might be charged)
support the not-for-profit organization's activities?
NHTSA tentatively believes that there are no alternatives to the
proposal which would accomplish the stated objectives of 49 U.S.C.
Sec. 30101 et seq. and which would minimize any significant economic
impact of the proposed rule on small entities. As discussed above in
section V.c., ``Discussion of Alternatives,'' NHTSA considered a number
of other approaches to minimize or eliminate incompatibility between
child seats and vehicle seats. SAE Recommended Practice J1819,
``Securing Child Restraint Systems in Motor Vehicle Rear Seats,'' does
not appear sufficient alone to solve incompatibility problems. It is a
tool for evaluating incompatibility, not a requirement that vehicle
seats and child restraints must be compatible. Further, it is very
difficult for a single system to optimize the safety protection for
adults of all ranges and child restraints of different types. The
current ``lockability'' requirement does not appear sufficient alone in
addressing incompatibility, because it still depends on the user
knowing enough and making the effort to manipulate and correctly route
the belt system. Also, the lockability requirement does not address
incompatibility problems arising from forward-mounted seat belt
anchors. The ``Car Seat Only (CSO)'' system suggested by Cosco probably
would not make attaching a child seat significantly easier than it is
today. The CSO belt would have to be correctly routed through the child
restraint, which is a problem occurring with present seats, and appears
hard to tighten. Also, Cosco provided no information showing that the
CSO belt would improve the securement of a child restraint on contoured
(especially humped) seats. Another concern relates to the potential for
inadvertent use by an adult occupant.
Comments are requested on possible alternatives to the proposal
which mitigate any significant economic impact of the proposed rule on
small entities, while accomplishing the objectives of 49 U.S.C.
Sec. 30101 et seq.
c. Executive Order 12612
This proposed rule has been analyzed in accordance with the
principles and criteria contained in Executive Order 12612, and the
agency has determined that this proposal does not have sufficient
federalism implications to warrant the preparation of a Federalism
Assessment.
d. Unfunded Mandates Reform Act
The Unfunded Mandates Reform Act of 1995 (Pub. L. 104-4) requires
agencies to prepare a written assessment of the costs, benefits and
other effects of proposed or final rules that include a Federal mandate
likely to result in the expenditure by State, local or tribal
governments, in the aggregate, or by the private sector, of more than
$100 million annually. NHTSA has included an evaluation in the PEA for
this proposal. The costs and benefits of the proposal are discussed
above and throughout the PEA. (As explained above, the cost would be
approximately $105 million for vehicles, and $55 million for child
restraints. The benefits would be saving approximately 24 to 32
children's lives per year, and preventing 2,187 to 3,615 injuries. An
independent means of attaching child restraints would also enable
vehicle manufacturers to optimize the design of vehicle belt systems
for adult occupants.)
[[Page 7877]]
Participants in a NHTSA public meeting held in March 1995 at the
Lifesavers National Conference on Highway Safety Priorities, who
typically work in State highway traffic safety agencies, community
traffic safety programs and State or local law enforcement agencies,
expressed strong support for a requirement for a universal child
restraint anchorage system, such as that proposed in this NPRM. Support
for a universal child restraint anchorage system, such as that proposed
in the NPRM, was also expressed at NHTSA's October 1996 public workshop
on various types of anchorage systems. As discussed above in sections
V.c. and IX.b., and in the PEA, the agency does not believe that there
are feasible alternatives to the proposal, including SAE Recommended
Practice J1819, the lockability requirement or Cosco's CSO system.
e. National Environmental Policy Act
NHTSA has analyzed this rulemaking action for the purposes of the
National Environmental Policy Act. The agency has determined that
implementation of this action would not have any significant impact on
the quality of the human environment.
f. Executive Order 12778 (Civil Justice Reform)
This proposed rule does not have any retroactive effect. Under
section 49 U.S.C. 30103, whenever a Federal motor vehicle safety
standard is in effect, a state may not adopt or maintain a safety
standard applicable to the same aspect of performance which is not
identical to the Federal standard, except to the extent that the state
requirement imposes a higher level of performance and applies only to
vehicles procured for the State's use. 49 U.S.C. 30161 sets forth a
procedure for judicial review of final rules establishing, amending or
revoking Federal motor vehicle safety standards. That section does not
require submission of a petition for reconsideration or other
administrative proceedings before parties may file suit in court.
X. Comments on the Proposal
Interested persons are invited to submit comments on the proposal.
It is requested, but not required, that 10 copies be submitted.
All comments must not exceed 15 pages in length. (49 CFR 553.21).
Necessary attachments may be appended to these submissions without
regard to the 15-page limit. This limitation is intended to encourage
commenters to detail their primary arguments in a concise fashion.
If a commenter wishes to submit certain information under a claim
of confidentiality, three copies of the complete submission, including
purportedly confidential business information, should be submitted to
the Chief Counsel, NHTSA, at the street address given above, and seven
copies from which the purportedly confidential information has been
deleted should be submitted to the Docket Section. A request for
confidentiality should be accompanied by a cover letter setting forth
the information specified in the agency's confidential business
information regulation. 49 CFR Part 512.
All comments received before the close of business on the comment
closing date indicated above for the proposal will be considered, and
will be available for examination in the docket at the above address
both before and after that date. To the extent possible, comments filed
after the closing date will also be considered. Comments received too
late for consideration in regard to the final rule will be considered
as suggestions for further rulemaking action. Comments on the proposal
will be available for inspection in the docket. The NHTSA will continue
to file relevant information as it becomes available in the docket
after the closing date, and it is recommended that interested persons
continue to examine the docket for new material.
Those persons desiring to be notified upon receipt of their
comments in the rules docket should enclose a self-addressed, stamped
postcard in the envelope with their comments. Upon receiving the
comments, the docket supervisor will return the postcard by mail.
List of Subjects 49 CFR Part 571
Imports, Motor vehicle safety, Motor vehicles.
PART 571--[AMENDED]
In consideration of the foregoing, NHTSA proposes to amend 49 CFR
Part 571 as set forth below.
1. The authority citation for Part 571 would continue to read as
follows:
Authority: 49 U.S.C. 322, 30111, 30115, 30117 and 30166;
delegation of authority at 49 CFR 1.50.
2. Section 571.210a would be added to read as follows:
Sec. 571.210a Standard No. 210a; Child restraint anchorage system.
S1. Purpose and scope. This standard establishes requirements for a
system for anchoring child restraint systems to increase the likelihood
that child restraints are properly secured in motor vehicles.
S2. Application. This standard applies to passenger cars, and to
multipurpose passenger vehicles, trucks and buses with a GVWR of 10,000
pounds or less, except walk-in van-type vehicles and vehicles
manufactured to be sold exclusively to the U.S. Postal Service.
S3. Definitions.
Child restraint anchorage means any component involved in
transferring child restraint loads to the vehicle structure, including
but not limited to, the attachment hardware on the vehicle structure,
webbing and straps attached to the vehicle and hardware attached
thereto, the seat frames, seat pedestals, and the vehicle structure
itself.
Child restraint anchorage system means a system that is designed
for attaching a child restraint to a vehicle at a particular designated
seating position and for transferring child restraint loads to the
vehicle structure and that consists of--
(1) Two lower child restraint anchorages at the seat bight; and
(2) A tether anchorage for attaching a top tether strap of a child
restraint system.
Child restraint apparatus means the fixture depicted in Figures 1,
2 and 3 of this standard which simulates the dimensions of a child
restraint, and which is used to determine the space required by the
child restraint and the location and access to the lower anchorages.
Seat bight means the intersection of the vertical plane tangent to
the forward most point of the seat back and the horizontal plane
tangent to the uppermost point of the seat cushion.
Tether anchorage is defined in 49 CFR 571.210b, ``Tether anchorages
for child restraint systems.''
S4. Requirements. Each motor vehicle shall meet the requirements in
this section when, as specified, tested in accordance with S5 and this
paragraph.
S4.1 Type.
(a) Except as provided in S4.1(b) through (d) of this section, each
vehicle shall be equipped with a child restraint anchorage system for
at least two rear designated seating positions.
(b) A vehicle may be equipped with a built-in child restraint
system conforming to the requirements of Standard No. 213 (49 CFR
571.213) in lieu of one of the child restraint anchorage systems
required by S4.1(a) of this section.
(c) A vehicle that meets the conditions concerning rear seats in
either S4.5.4.1(a) or S4.5.4.1(b) of Standard No. 208 (49 CFR 571.208)
and
[[Page 7878]]
that has an air bag cutoff switch meeting the requirements of S4.5.4 of
Standard 208 shall have a child restraint anchorage system installed
for a designated seating position in the front seat, and for a position
in the rear seat if the vehicle has a rear seat.
(d) A vehicle that has no forward-facing designated seating
positions to the rear of the front seating positions and no air bag
cutoff switch meeting the requirements of S4.5.4 of Standard 208, shall
not have a child restraint anchorage system installed for a designated
seating position in the front seat.
S4.2 Lower anchorages.
The child restraint anchorage system shall have two lower
anchorages and shall conform to either S4.2.1, or S4.2.2 and S4.2.3, at
the manufacturer's option.
S4.2.1 Flexible anchorages.
S4.2.1.1 Configuration and Geometry.
A child restraint anchorage system shall incorporate two lower
anchorages with latchplates conforming to the configuration and
geometry specified in Figure 4 of this standard.
S4.2.1.2 Location.
(a) When fully extended in a plane parallel to the vehicle's
longitudinal axis, the centerlines of the two latchplates are 280 mm
apart.
(b) When fully extended in a plane parallel to the vehicle's
longitudinal axis, the tip of each latchplate must not extend more than
50 mm forward of the seat bight.
S4.2.1.3 Strength.
When tested in accordance with S5 of this standard, a child
restraint anchorage system shall meet the following requirements:
(a) No portion of the latchplate for each lower anchorage shall
pass through a vertical, transverse plane that is 125 mm forward of the
seat bight; and
(b) There shall be no complete separation of any anchorage
component component (including webbing, straps, hooks and buckles,
latchplates, adjustment and attachment hardware and retractors).
S4.2.2 Rigid or semi-rigid anchorages.
S4.2.2.1 Configuration and geometry.
A child seat anchorage system shall incorporate two lower
anchorages that are 6 mm diameter transverse horizontal round bars with
a minimum length of 25 mm.
S4.2.2.2 Location.
(a) The transverse spacing of the bars shall be 280 mm, center-to-
center.
(b) The lower anchorage bars are located with respect to the child
restraint apparatus rearward extensions as shown in Figures 2 and 3 of
this standard, with the child restraint apparatus placed on the vehicle
seat cushion and against the vehicle seat back. Anchorage bars that are
rigidly supported are to be 50 mm rearward of the rearmost surface of
the fixture, while semi-rigidly supported bars may be located from 50
mm rearward to 10 mm forward of that surface. The center of rigidly
supported lower anchorage bars shall be at least 120 mm behind the
vehicle seating reference point.
(c) Rigidly supported lower anchorage bars must be in a zone from
10 to 20 mm above the bottom surface of the child restraint apparatus,
while semi-rigidly supported bars must be in a zone from 0 to 20 mm
above that surface.
S4.2.2.3 Strength.
When tested in accordance with S5 of this standard, a child
restraint anchorage shall meet the following requirements:
(a) No portion of any component attaching to the lower anchorage
bars shall move forward more than 125 mm.
(b) There shall be no complete separation of any anchorage
component.
S4.2.3 Connectors.
Each vehicle equipped with lower anchorages conforming to S4.2.2 of
this standard shall be equipped with connectors that permit the
attachment of a child restraint that is equipped with components which
attach to lower anchorages conforming to S4.2.1. Each connector shall
be equipped with a latchplate conforming to the configuration and
geometry specified in Figure 4 of this standard. When attached to a
lower anchorage, the tip of each latchplate must not extend more than
50 mm forward of the seat bight when the connector is fully extended.
S4.3 Tether anchorage.
The child restraint anchorage system shall incorporate a tether
anchorage conforming to 49 CFR 571.210b, ``Tether anchorages for child
restraint systems.''
S4.4 Webbing, buckles and belt adjustment hardware.
S4.4.1 Webbing.
The webbing provided with a child restraint anchorage system
shall--
(a) After being subjected to abrasion as specified in S5.1(d) or
S5.3(c) of FMVSS No. 209 (49 CFR 571.209), have a breaking strength of
not less than 75 percent of the strength of the unabraded webbing when
tested in accordance with S5.1(b) of FMVSS 209; and
(b) Meet the requirements of S4.2(e) through (h) of FMVSS No. 209
(49 CFR 571.209).
S4.4.2 Buckles and belt adjustment hardware.
Each belt buckle and item of belt adjustment hardware used in a
child restraint anchorage system shall conform to the requirements of
S4.3(a) and S4.3(b) of FMVSS No. 209 (49 CFR 571.209).
S4.5 Marking and Guidance.
For lower anchorages conforming to S4.2.2, at least one lower
anchorage bar is to be readily visible to the person installing a child
restraint. The vehicle seat cushion or seat back shall include markings
or features to assist in the correct lateral positioning of the child
restraint system as it is moved rearward to engage the lower
anchorages.
S4.6 Instructions.
The vehicle owner's manual shall:
(a) Indicate the seating positions equipped with a child restraint
anchorage system;
(b) Include instructions that provide a step-by-step procedure,
including diagrams, for properly attaching a child restraint system to
a vehicle anchorage system equipped with lower anchorages conforming to
the requirements of S4.2.1 (with or without use of a connector); and,
(c) Include instructions for properly installing a child restraint
system in a vehicle anchorage system equipped with lower anchorages
conforming to the requirements of S4.2.2, if the vehicle is equipped
with such anchorages.
S5 Test procedures.
S5.1 Lower anchorages.
Test each lower anchorage separately, with or without connectors
provided with the vehicle. Apply a force of 5,300 N to each anchorage
in the forward horizontal direction parallel to the vehicle's
longitudinal axis. Apply the force by means of a belt strap that
extends at least 250 mm forward of the seat bight. The belt is fitted
at one end with hardware for applying the force, and at the other end
with hardware that attaches to an anchorage or connector. Apply force
to the belt strap so that the 5,300 N force is attained within 30
seconds, with an onset force rate not exceeding 135,000 N per second,
and is maintained at the 5,300 N level for at least 10 seconds.
S5.2 Tether anchorage.
Tether anchorages are tested according to the procedures specified
in 49 CFR 571.210b, ``Tether anchorages for child restraint systems.'
BILLING CODE 4910-59-P
[[Page 7879]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.012
Figure 1--Child Restraint Apparatus-Isometric
[[Page 7880]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.013
Figure 2a--Child Restraint Apparatus Anchorages Front View
[[Page 7881]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.014
Figure 2b--Child Restraint Apparatus Anchorages Side and Plan View
[[Page 7882]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.015
[[Page 7883]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.016
[[Page 7884]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.017
BILLING CODE 4910-59-C
[[Page 7885]]
3. Section 571.210b would be added to read as follows:
Sec. 571.210b Standard No. 210b; Tether anchorages for child restraint
systems
S1. Purpose and scope. This standard establishes requirements for
the strength and location of tether anchorages to ensure proper
anchoring of child restraint systems.
S2. Application. This standard applies to tether anchorages
installed in passenger cars manufactured on or after September 1, 1999,
and in multipurpose passenger vehicles, trucks and buses manufactured
on or after September 1, 2000.
S3. Definitions.
Tether anchorage means any component that transfers loads from
tether anchorage hardware to the vehicle structure.
Tether anchorage hardware means any component that transfers tether
strap loads to a tether anchorage and is designed to accept a tether
strap hook.
Tether strap means a device that is fitted with a tether strap hook
and secured to the rigid structure of a child restraint system and that
transfers the load from that system to the anchorage hardware.
Tether strap hook means a device, illustrated in Figure 11 of
Standard No. 213 (49 CFR 571.213), used to attach a tether strap to
tether anchorage hardware.
S4. Requirements. Each tether anchorage shall meet the requirements
of this section.
S4.1 Configuration.
S4.1.1 Except as provided by S4.1.2, each tether anchorage shall--
(a) Be equipped with tether anchorage hardware that is easily
accessible and that permits the attachment of a tether hook meeting the
configuration and geometry specified in Figure 11 of Standard No. 213
(49 CFR 571.213) of this section;
(b) Be located in accordance with S4.2 of this section; and
(c) Be sealed to prevent the entry of exhaust fumes.
S4.2 Anchorage positioning requirements.
S4.2.1 Passenger cars and multipurpose passenger vehicles. The
vertical centerline of each tether anchorage and each tether anchorage
hardware component shall be located within the shaded zone shown in
Figures 2, 3, 4 and 8 of this standard, with reference to the shoulder
reference point of a template described in section 3.1 of SAE Standard
J826 (June 1992), where
(a) The H-point of the template is located at the unique Design H-
point of the seat, as defined in section 2.2.11.1 of SAE Recommended
Practice J1100 (June 1993), at the full rearward and downward position
of the seat;
(b) The torso line of the template is at the same angle from the
vertical plane as the seat back with the seat adjusted to its full
rearward and full downward position and the seat back in its most
upright position; and,
(c) The template is positioned in the vertical longitudinal plane
that contains the H-point of the template.
S4.2.2 Trucks and buses. Subject to S4.3.2.1, the vertical
centerline of each tether anchorage and each tether anchorage hardware
in a truck or bus shall be located within the shaded zone shown in
Figures 5, 6, 7, and 8 of this standard, with reference to the H-point
of a template described in section 3.1 of SAE Standard J826 (June
1992), where
(a) The H-point of the template is located at the unique Design H-
point of the seat, as defined in section 2.2.11.1 of SAE Recommended
Practice J1100 (June 1993), at the full rearward and downward position
of the seat;
(b) The torso line of the template is at the same angle from the
vertical plane as the seat back with the seat adjusted to its full
rearward and full downward position and the seat back in its most
upright position; and
(c) The template is positioned in the vertical longitudinal plane
that contains the H-point of the template.
S4.3.2.1 The centerline of a tether anchorage in a truck or bus
may be located outside the shaded zone referred to in S4.3.2 if a
routing device that is of sufficient strength to withstand the loads
referred to in S4.4 is installed within that shaded zone.
S4.4 Strength.
S4.4.1 If a tether anchorage is installed for only one designated
seating position on a seat, the tether anchorage with the tether
anchorage hardware installed shall, when tested in accordance with S5,
withstand a force of 5,300 N. There shall be no complete separation or
failure of any anchorage component.
S4.4.2 If a tether anchorage is installed for more than one
designated seating position on a bench seat, each tether anchorage with
the tether anchorage hardware installed shall, when tested in
accordance with S5, withstand the simultaneous application of a force
of 5,300 N to each assembly of tether anchorage and tether anchorage
hardware. There shall be no complete separation or failure of any
anchorage component.
S5 Test procedure.
With the seat adjusted to its full rearward and full downward
position and the seat back in its most upright position, attach a belt
strap that extends not less than 250 mm forward from the vertical plane
intersecting the seat bight (the intersection of the surfaces of the
seat cushion and the seat back). The strap is fitted at one end with
hardware for applying the force and at the other end with a bracket for
attachment to the tether anchorage hardware and passes over the top of
the vehicle seat back as shown in Figure 8 of this standard. Apply a
force of 5,300 N to each anchorage in the forward horizontal direction
parallel to the vehicle's longitudinal axis. The 5,300 N force is
attained within 30 seconds, with an onset force rate not exceeding
135,000 N per second, and is maintained at the 5,300 N level for one
second.
Figure 1--[Reserved]
BILLING CODE 4910-59-P
[[Page 7886]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.018
Figure 2--Side View, Tether Anchorage Location for Passenger Cars
and Multi-Purpose Passenger Vehicles
[[Page 7887]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.019
Figure 3--Rear View, Tether Anchorage Location for Passenger Cars
and Multi-Purpose Passenger Vehicles
[[Page 7888]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.020
Figure 4--Plan View, (R-Point Level), Tether Anchorage Location for
Passenger Cars and Multi-Purpose Passenger Vehicles
[[Page 7889]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.021
Figure 5--Side View, Tether Anchorage Location for Trucks
[[Page 7890]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.022
Figure 6--Rear View, Tether Anchorage Location for Trucks
[[Page 7891]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.023
Figure 7--Plan View, (V-Point Level), Tether Anchorage Location for
Trucks
[[Page 7892]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.024
Figure 8--Three-Dimensional Schematic View for Tether Anchorage
Location for Passenger Cars, Multi-Purpose Passenger Vehicles and
Trucks
[[Page 7893]]
4. Section 571.213 would be amended by:
a. adding to S4, in alphabetical order, a definition of ``child
restraint anchorage system,'' ``tether anchorage hardware,'' ``tether
strap,'' and ``tether strap hook'';
b. revising S5.1.3, S5.1.3.1, S5.3.1, S5.3.2 and S5.6.1;
c. adding S5.9 and S5.10;
d. revising S6.1.1(a)(1), S6.1.1(c) and S6.1.2(a)(1)(i);
e. adding S6.1.2(d)(1)(iii); and
f. revising Figure 1A and adding figures 11 and 12.
The revised and added paragraphs would read as follows:
Sec. 571.213 Standard No. 213; Child restraint systems
* * * * *
S4. Definitions.
* * * * *
Child restraint anchorage system is defined in S3 of FMVSS No. 210a
(49 CFR 571.210a).
* * * * *
Tether anchorage hardware is defined in S3 of FMVSS No. 210b (49
CFR 571.210b).
Tether strap means a device that is fitted with a tether strap hook
and secured to the rigid structure of a child restraint system and that
transfers the load from that system to the tether anchorage hardware.
Tether strap hook means a device, illustrated in Figure 11 of this
standard, used to attach a tether strap to tether anchorage hardware.
* * * * *
S5.1.3 Occupant excursion. When tested in accordance with S6.1 and
the requirements specified in this paragraph, each child restraint
system shall meet the applicable excursion limit requirements specified
in S5.1.3.1 through S5.1.3.3.
S5.1.3.1 Child restraint systems other than rear-facing ones and
car beds. Each forward-facing child restraint system shall retain the
test dummy's torso within the system.
(a) In the case of an add-on child restraint system, no portion of
the test dummy's head shall pass through a vertical, transverse plane
that is 720 mm forward of point Z on the standard seat assembly,
measured along the center SORL (as illustrated in figure 1B of this
standard), and neither knee pivot point shall pass through a vertical,
transverse plane that is 915 mm forward of point Z on the standard seat
assembly, measured along the center SORL, when attached to the seat
assembly as described in S6.1.2(a)(1)(i)(A)(1).
(b) In the case of an add-on child restraint system, no portion of
the test dummy's head shall pass through a vertical, transverse plane
that is 813 mm forward of point Z on the standard seat assembly,
measured along the center SORL (as illustrated in figure 1B of this
standard), and neither knee pivot point shall pass through a vertical,
transverse plane that is 915 mm forward of point Z on the standard seat
assembly, measured along the center SORL, when attached to the seat
assembly as described in S6.1.2(a)(1)(i)(A)(2) or S6.1.2(a)(1)(B).
(c) In the case of a built-in child restraint system, neither knee
pivot point shall, at any time during the dynamic test, pass through a
vertical, transverse plane that is 305 mm forward of the initial pre-
test position of the respective knee pivot point, measured along a
horizontal line that passes through the knee pivot point and is
parallel to the vertical plane that passes through the vehicle's
longitudinal centerline.
* * * * *
S5.3 Installation.
S5.3.1 Except for components designed to attach to a child
restraint anchorage system, each add-on child restraint system shall
have no means designed for attaching the system to a vehicle seat
cushion or vehicle seat back and no component (except belts) that is
designed to be inserted between the vehicle seat cushion and vehicle
seat back.
S5.3.2 (a) When installed on a vehicle seat, each add-on child
restraint system, other than a belt-positioning seat, shall be capable
of being restrained against forward movement solely by means of:
(1) A Type I seat belt assembly (defined in Sec. 571.209) that
meets Standard No. 208 (Sec. 571.208);
(2) A Type I seat belt assembly plus a tether anchorage; and,
(3) A child restraint anchorage system.
(b) Each belt-positioning seat shall be capable of being restrained
against forward movement by means of a Type II seat belt assembly
(defined in Sec. 571.209) that meets Standard No. 208 (Sec. 571.208).
* * * * *
S5.6.1 Add-on child restraint systems.
Each add-on child restraint system shall be accompanied by printed
installation instructions in English that provide a step-by-step
procedure, including diagrams, for installing the system in motor
vehicles, securing the system in the vehicles, positioning a child in
the system, and adjusting the system to fit the child. If the child
restraint system has components for attaching to a child restraint
anchorage system, installation instructions shall be included that
provide a step-by-step procedure, including diagrams, for properly
attaching a child restraint system to a vehicle anchorage system
equipped with lower anchorages conforming to the requirements of S4.2.1
of Standard No. 210a (49 CFR Sec. 571.210a). In addition, if the child
restraint is equipped with components that attach to a vehicle
anchorage system equipped with lower anchorages conforming to the
requirements of S4.2.2 of Standard No. 210a, instructions shall be
provided for properly installing a child restraint to such an anchorage
system.
* * * * *
S5.9 Attachment to child restraint anchorage system.
(a) Each add-on child restraint system, other than a belt-
positioning seat, shall have components permanently attached to the
system that securely fasten to the latchplates conforming to S4.2.1 of
Standard No. 210a (49 CFR Sec. 571.210a) and depicted in Drawing
Package ____ (consisting of drawings and a bill of materials) with
addendum A, revision dated January 6, 1997, (incorporated by reference;
see Sec. 571.5).
(b) In addition to the components required by S5.9(a), each child
restraint system intended for use with lower anchorages conforming to
S4.2.2 of Standard No. 210a (49 CFR Sec. 571.210a) shall have
components of a configuration depicted in Figure 12 of this standard,
in a location that enable the child restraint to securely fasten to the
anchorages.
S5.10 Each tether strap on a child restraint system must be
equipped with a tether strap hook that conforms to the configuration
and geometry specified in Figure 11 of this standard.
* * * * *
S6.1.1 Test conditions.
(a) Test devices.
(1) The test device for add-on restraint systems is a standard seat
assembly consisting of a simulated vehicle bench seat, with three
seating positions, which is described in Drawing Package SAS-100-1000
with Addendum A Revised (consisting of drawings and a bill of
materials), dated December __, 1996 (incorporated by reference; see
Sec. 571.5). The assembly is mounted on a dynamic test platform so that
the center SORL of the seat is parallel to the direction of the test
platform travel and so that movement between the base of the assembly
and the platform is prevented.
* * * * *
[[Page 7894]]
(c)(1) Attached to the seat belt anchorage points provided on the
standard seat assembly (illustrated in Figures 1A and 1B of this
standard) are Type I seat belt assemblies in the case of add-on child
restraint systems other than belt-positioning seats, or Type II seat
belt assemblies in the case of belt-positioning seats. These seat belt
assemblies meet the requirements of Standard No. 209 (Sec. 571.209) and
have webbing with a width of not more than 50 mm, and are attached to
the anchorage points without the use of retractors or reels of any
kind.
(2) Attached to the standard seat assembly is a child restraint
anchorage system conforming to Standard No. 210a (Sec. 571.210a). The
seat assembly is equipped with lower anchorages that conform to S4.2.1
and S4.2.2 of that standard.
* * * * * *
S6.1.2 Dynamic test procedure.
(a) Activate the built-in child restraint or attach the add-on
child restraint to the seat assembly as follows:
(1)(i) Test configuration I.
(A) Except for a belt-positioning seat, an add-on child restraint
system is installed at the center seating position of the standard seat
assembly using either the standard lap belt or the child seat anchorage
system--
(1) In accordance with the manufacturer's instructions provided
with the system pursuant to S5.6.1; or
(2) In accordance with the manufacturer's instructions, except that
the add-on restraint is secured to the standard vehicle seat using only
the standard vehicle lap belt (except a child harness, a backless child
restraint system with a top anchorage strap, and a restraint designed
for use by physically handicapped children are not subject to this
paragraph.
(B) A belt-positioning seat is attached to either outboard seating
position of the standard seat assembly in accordance with the
manufacturer's instructions provided with the system pursuant to S5.6.1
using only the standard vehicle lap and shoulder belt.
* * * * *
(d) * * *
(1) * * *
(iii) When attaching a child restraint system to the child
restraint anchorage system on the standard seat assembly, all belt
systems used to attach the restraint to the standard seat assembly are
tightened to a tension of not less than 53.5 N and not more than 67 N,
as measured by a load cell used on the webbing portion of the belt.
* * * * *
BILLING CODE 4910-59-P
[[Page 7895]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.025
[[Page 7896]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.026
Figure 11--Tether Strap Hook
[[Page 7897]]
[GRAPHIC] [TIFF OMITTED] TP20FE97.027
Figure 12--Rigid Connector-Side View
Issued on February 13, 1997.
L. Robert Shelton,
Associate Administrator for Safety Performance Standards.
[FR Doc. 97-4084 Filed 2-18-97; 8:45 am]
BILLING CODE 4910-59-C
