Anonymous

Document ID: NHTSA-2012-0180-0016
Document Type: Public Submission
Agency: National Highway Traffic Safety Administration
Received Date: June 28 2013, at 12:00 AM Eastern Daylight Time
Date Posted: July 1 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: April 5 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: July 5 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-865w-tmu2
View Document:  View as format xml

This is comment on Proposed Rule

New Car Assessment Program

View Comment

Gentlemen, I have some comments/suggestions. 1. Seating position of the front passenger in head-on collision tests: Please change the seating position of the passenger to a real-life (i.e. some mid-) position. No real passenger uses this current foremost seating position, thus the benefit of the crash test result for the real occupant is more than unclear (to many people, even to safety experts). 2. In frontal crash test load cases, I kindly ask you to reconsider using chest accelleration again instead of or in addition to chest deflection. Taking a look on latest test results I see many chest deflection values of even below 10mm (P<1%), while the chest accelleration is often close to 50g (P>10%). This is because most car's restraint systems are now designed to hit every part of the dummy chest except the small place where the deflection sensor is located. This has barely anything to do with occupant safety. The chest accelleration cannot be tricked by airbag shapes or similar and is a robust and well-respected dummy injury value. Take for examlple both deflection and accelleration whichever value is worse. 3. For the rear seats any requirement would help. If I may suggest, put both a 5%ile next to a 50%ile (or maybe even 95%ile) on the rear seats. Choose the position (left or right) *randomly* for every test, in order to avoid a too specific restraint system design. Take (at least) the HIC and the chest 3ms accelleration rating of the old NCAP-test. 4. Oblique-test To have the car standing while the barrier is on the move is a brilliant idea. This will definetly improve crash sensor algorithms. But keep in mind that in 35mph-tests most cars today have a delta-v of close to 40mph rather than 35mph because of the rebound (thus a car of average mass should have a delta-v of 40mph). regards, r.s.

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