Michael D. Dulberger - Comment

NHTSA’s Rating System NHTSA's individual star ratings for frontal impact, side impact and rollover should be replaced with a fatality-weighted vehicle risk index SCORE for passenger vehicles. The SCORE [Statistical Combination Of Risk Elements] is a single, composite risk value that combines a driver’s risk of fatal injury due to impact and rollover in proportions pre-determined by actual traffic fatality experience, adjusted for measured crash test and rollover results for the subject vehicle. In addition, the frontal risk contribution to the SCORE is modified to reflect the relative risk associated with that vehicle’s weight. In summary, each fatality mode is weighted, based on actual fatality rates, (for example, 38% frontal, 33% rollover, 26% side and 3% rear), then normalized to the SCORE of the “average” passenger vehicle, thereby enabling direct comparison to the “average” vehicle. This makes a subject vehicle’s overall risk easy for the consumer to identify, and that single value is used as a safety yardstick. The frontal component of this risk SCORE includes the effect on fatality risk associated with that vehicles’ weight deviation from average weight. The frontal component is the product of the risk due to frontal crashworthiness, as determined by crash testing, times that vehicle’s weight factor. The vehicle weight factor is derived from fatality data to isolate the effect of weight alone, and is the ratio of the fatality risk for that vehicle’s weight divided by the fatality risk for the average vehicle weight. A detailed explanation and the equations used to calculate SCORE are provided on my website www.InformedForLife.org, where the correlation between vehicle SCOREs and actual fatality data are also presented, demonstrating that the SCORE is a significant predictor of vehicle fatality rates.