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NHTSA’s Proposed Side-Impact Testing Standard – the good, the bad and the interesting

SI Test - NTHSA  ProposedThis week many of you may have heard through mainstream media outlets that NHTSA’s long-awaited “NPRM” on a Federal Side-Impact Standard for Child Restraints was about to be unveiled. Here at CarseatBlog that was practically an excuse to break out the bubbly since we’ve been waiting for this announcement since the end of summer 2013 when they promised us it was going to ready! To be honest, we’ve actually waited over a decade for this but I’d rather not remind myself how quickly the last decade has flown by. Anyhow, we didn’t want to just regurgitate a press release or some bare-bones news article with no nitty-gritty details because we know you expect more than that from us, so we sat on our fingers for a few days until the actual NPRM was released.

The proposed test is interesting in so many ways but it can be really confusing too if you don’t understand all the technicalities and nuances of what they’re proposing. My advice is not to get too fixated on anything in particular because you have to consider the whole picture. There are always going to be pros and cons and almost every upside comes at the expense of something else. It’s just the way it is.

In writing this update I was torn over whether to keep it simple or go all out and try to help you make sense of everything. The latter seemed like an overwhelming task but I’m also not a keep-it-simple-kind-of-person. In the end I compromised by doing a bit of both. I tried to outline the main points (the stuff that most people would care about) in the beginning, and then I tossed in some stuff that only the die-hards with a serious coffee or diet-soda-induced caffeine buzz could manage to get through. I hope that pleases everyone. :)

Quick Overview for Parents and Caregivers:

What most parents need to take away from this is that the government standards, set by the National Highway Traffic Safety Administration (NHTSA), now have just a minimum pass/fail requirement for a typical frontal crash test only. This proposed rule will add a minimum pass/fail side-impact test that manufacturers must pass in order to sell a child safety seat in the USA. Side impacts are the most deadly types of crashes to properly restrained passengers, adults and children alike. So, this testing is potentially a big step forward in protecting our littlest passengers from head injury in particular.

This proposed test would simulate a small car moving through an intersection at a low speed and being “T-boned” by another car going about 30 miles per hour. A carseat with a child-sized dummy will be measured for injury in the rear seat, on the nearest side that is struck by the simulated oncoming vehicle. Please note that this will NOT be a 5-star comparative type of rating for either crash safety or fit to vehicle; those are separate mandates that have all but disappeared from public discussion. It’s also not yet in final form, so the public has 90 days to comment before the final rule is set. For example, the proposed test omits some key scenarios, including installation with a seatbelt, installation without a top tether and installation for children using a 5-point harness above 40 pounds. These are all very important issues, especially given the shift to seatbelt use because of the new 2014 labeling required on carseats that limits the use of LATCH system, due to concerns about the strength of the hardware.

Carseats required to pass the new testing are a long way from the market. Once the final rule is passed, we probably won’t see officially compliant models for up to 3 years. So, if you are in need of a new carseat now, this proposal does not affect you at all. Also, parents shopping for carseats in the mean time should know that most of them already adhere to voluntary side impact testing standards and many have incorporated side impact protection features for years. These vary from one manufacturer to another and will be different from the government testing, but it is important to know that manufacturers are already designing products with side-impact protection in mind.

More Details on the Proposed Rule for CPS Technicians and Advocates:

Notice of Proposed Rule Making: Amendment to FMVSS 213 – Side Impact Testing Standard

“SUMMARY: This NPRM proposes to amend Federal Motor Vehicle Safety Standard (FMVSS) No. 213, “Child restraint systems,” to adopt side impact performance requirements for all child restraint systems designed to seat children in a weight range that includes weights up to 18 kilograms (kg) (40 pounds (lb)). NHTSA is issuing this NPRM to ensure that child restraints provide a minimum level of protection in side impacts by effectively restraining the child, preventing harmful head contact with an intruding vehicle door or child restraint structure, and by attenuating crash forces to the child’s head and chest.

 

 

In a Nut Shell:

The proposed test procedure would simulate the full-scale vehicle-to-vehicle side impact crash replicated by FMVSS 214.

  • Dynamic sled test would simulate the MDB (Movable Deformable Barrier) test of FMVSS 214 which has the striking vehicle traveling at 30 mph (48.3 km/h) impacting the struck vehicle traveling at 15 mph (24 km/h)
  • Tests CR in near side impact
  • First test of its kind in the world for testing CRs in a sled system that simulates vehicle acceleration and intruding door of a small passenger car
  • Door intrusion known to be a factor for moderate and severe injury in side impacts
  • Proposed test based on acceleration sled system developed by Takata

 

Specifics:

  • CRs for children rated up to 22 lbs would be tested with CRABI dummy
  • CRs for children 22-40 lbs., including boosters, would be tested with Q3s dummy
  • Forward-facing CR installed with LATCH (lower anchors and tether)
  • Rear-facing CRs installed using lower anchors only
  • Belt-positioning boosters (those rated for children under 40 lbs.) installed with lap/shoulder belt
  • Center of CR positioned 300mm from edge of the sliding seat next to the intruding door – simulating a near-side seating position
  • Armrest on door located 32mm from edge of seat towards CR

 

Rational for limiting testing to under 40 lbs.:

  • No appropriate test dummy for representing kids over 40 lbs. right now
  • NHTSA determined that seated height of children over 40 lbs. is typically sufficient to take advantage of the vehicle’s side impact protection system (including curtain airbags)

 

ATDs:

  • Q3s is the side-impact version of the 3-yr-old Q Series dummy developed in Europe (weighs 32 lbs.)
  • CRABI – 12 month old dummy used in current frontal crash testing (weighs 22 lbs)

 

Most parents can stop here unless they are looking for a cure to their insomnia! Technical geeks and die-hard advocates looking for in-depth commentary are warned that it’s about to get more technical!

Chicco NextFit Convertible Updates – October 2013

All Chicco NextFit convertible carseats made during or after October 2013 have some minor updates. The harness strap covers are now entirely optional and remove easily thanks to Velcro on the sides. These new strap covers lack the grippy material that lined the back of the original strap covers. The new strap covers are also slightly shorter as you can see in the comparison picture.

 

 

The 2-position chest clip can now be used in either the more narrow or wider setting with no restrictions – use your best judgement. Newborns and younger babies with narrow shoulders will benefit from the more narrow setting which will draw the harness straps closer together and keep them positioned properly over the baby’s small shoulders. Older babies and bigger kids can use the wider setting. When you switch is entirely up to you.

DSCN5376

 

The crotch strap has also been lengthened just a little bit. The new crotch strap is almost (but not quite) 1″ longer. Replacement [longer] crotch straps will be available after March 1.

  photo (64)

 

You can order NEW style harness pads directly from Chicco here.

Chicco NextFit -new harness strap covers

If you own a Chicco NextFit made prior to October 2013 – you may remove the harness strap covers that came with your seat, if desired. Please carefully follow the removal directions provided by Chicco here:  http://www.chiccousa.com/nextfit/pdf/NextFit_Pad_Installation.PDF

The replacement directions in the link above were written prior to the update so you can ignore the language that says “Never use your NextFit car seat without shoulder pads”. Just follow the directions on how to remove them, put the chest clip and buckle tongues back on properly and reattach the harness safely. *At the end of the process, once the harness pin has been fully re-inserted, check to make sure that the plastic tab is back in its original position preventing the pin from moving forward again.

There is also a video detailing the process here: http://www.chiccousa.com/nextfit/installation.aspx  (the link to the video can be found in two places: on the left side of your screen under “Shoulder Pad Replacement Kit” or under the Rear-Facing Videos “Installing Shoulder Pad Replacement Kit”) Again, this is an existing video meant to detail the process of swapping out the original harness strap covers with identical replacement strap covers so you can ignore the language that warns you to never use this product without the harness pads.

 

Britax Update – FAA Certification for Frontier 90, Pinnacle 90 & Pioneer 70 Harness-2-Booster Combination Seats

All current Britax Harness-2-Booster Combination Seats (Frontier 90, Pinnacle 90 & Pioneer 70) will be certified for aircraft use in early February. This change will be retroactive to all current models, and an FAQ and addendum will update this on the Britax website soon. An updated manual will follow in early February.

 Britax Frontier 80 FAA Certification Label

 

The updated instructions for airplane installation will instruct you to route the aircraft’s lap-only seatbelt in front of the ClickTight compartment. This installation method will ONLY be approved for installation on an airplane. Since the Pioneer 70 lacks the ClickTight feature, you will route the plane’s lap belt the same way you normally would on this particular seat.

More details to follow soon. We’ll share ‘em when we have ‘em!

 

Chicco NextFit – Harness Strap Covers *Update*!

Update: See our most recent blog on the subject:  Chicco NextFit Convertible Updates – October 2013

 

Chicco USA has issued the following statement regarding the NextFit convertible:

 

Chicco is committed to creating state of the art products which meet the strictest safety standards and the ease-of-use features our consumers expect.  The original shoulder harness pads used on the NextFit have been used in Europe for over 10 years with great success.  However, after input from our U.S. consumers who have used the NextFit, Chicco conducted more testing without the harness pads and with a new harness pad design.  The NextFit performed very well with and without the current pads, as well as with a new removable shoulder harness pad design.   The new shoulder harness pads developed by Chicco for the NextFit are easily removable.  All NextFit car seats, regardless of harness pad style, meet or exceed not only Federal Motor Vehicle Safety Standards, but also Chicco’s internal safety standards.

All NextFit car seats manufactured after October 1, 2013, will have removable harness pads.

Consumers who wish to purchase these new harness pads, will be able to order them after January 1, 2014.  To order, go to www.chiccoshop.com/gear/replacement-parts/ or contact Chicco Customer Service at 877-424-4226.

 

We don’t have a picture of the new harness strap covers yet but as soon as we do we’ll share it here.

*UPDATE: Below is a link to Chicco’s specific instructions on how to remove the harness strap covers. If you want to remove the harness strap covers on your NextFit model made prior to Oct 2013 you MUST follow these specific instructions for removal. Removing the pads in any other way could result in messing something up and possibly making the seat unsafe for your child. I’m not going to go into the “whys” right now so just trust me on this one!

These “replacement” directions were written prior to this update announcement so you can ignore the language that says “Never use your NextFit car seat without shoulder pads”. Just follow the directions on how to remove them, put the chest clip and buckle tongues back on properly and reattach the harness safely. *At the end of the process, once the harness pin has been fully re-inserted, check to make sure that the plastic tab is back in its original position preventing the pin from moving forward again.

http://www.chiccousa.com/nextfit/pdf/NextFit_Pad_Installation.PDF

 

There is also a video detailing the process on the Chicco website. Again, this is an existing video meant to detail the process of swapping out the current harness strap covers with identical replacement strap covers so you can ignore the language that warns you to never use this product without the harness pads.

http://www.chiccousa.com/nextfit/installation.aspx (the link to this video can be found in two places: on the left side of your screen under “Shoulder Pad Replacement Kit” or under the Rear-Facing Videos “Installing Shoulder Pad Replacement Kit”). Again, at the end of the process, once the harness pin has been fully re-inserted, check to make sure that the plastic tab is back in its original position preventing the pin from moving forward again.

 

I just want to add that we really love that Chicco listened to feedback from parents and caregivers and worked quickly to provide options and alternatives to NextFit consumers! Child preferences, parental preferences and situations vary widely so having various options (something to please everyone!) is greatly appreciated. :)

 

IIHS Check Fit Booster Ratings and the Britax Frontier 90

Considering buying a Britax Frontier 90 or Pinnacle 90 Harness-2-Booster seat?  Maybe you already bought one, based on our reviews or because they appeared on our recommended seats list?  Perhaps you have recently seen or heard that the IIHS did not give your carseat a “Best Best” or “Good Bet” rating and you are now wondering if it is safe to use?  Don’t Panic!  “Check Fit” does NOT mean “Unsafe”!

So what does a “Check Fit” rating from the IIHS mean?  Quite simply, it means you have to check how well the booster fits your own child, in your own vehicle.  Install the booster in your vehicle, buckle and route the seat belt, all according to the instructions in the owner’s manual.  Ideally, the lap belt should be fairly flat on the upper thigh, not up on the tummy.  The shoulder belt should be centered on the shoulder; it should not be falling off the shoulder or rest on the child’s neck.  What if it doesn’t fit well?  Keep using it for now to keep your child safe and read on for some suggestions to improve the safety for your child!  For more on booster fit, please see CarseatBlog’s coverage of the 2013 IIHS Booster Ratings.

The first important thing to note is that the new 2013 IIHS Booster Ratings are not results of dynamic crash tests.  Second, they do not consider ease-of-use or additional safety features at all.  The evaluations are only measurements of seatbelt fit to an average 4 to 8 year-old child using these seats in booster mode in a few vehicle seating scenarios.  Finally, these ratings DO NOT apply at all if you are using these or any other combination booster seat in the 5-point harness mode.  In regard to harness use, CarseatBlog agrees with the American Academy of Pediatrics, “All children whose weight or height is above the forward-facing limit for their [5-point harness] Child Safety Seat should use a belt-positioning booster seat until the vehicle lap-and-shoulder seat belt fits properly, typically when they have reached 4 feet 9 inches in height and are between 8 and 12 years of age. There is a safety advantage for young children to remain in Child Safety Seats with a harness for as long as possible before transitioning to booster seats.”

How does the IIHS know if a booster will fit your child and vehicle?  Good question!  They evaluate booster fit on a standard dummy, representative of a typical 6-year old child, measured in four scenarios that mimic real vehicle use.   What if your child is a different size than the dummy or you have a vehicle that varies significantly from any of their test scenarios?  That could mean the booster fits somewhat better or worse than the rating suggests, but overall the ratings should still provide meaningful comparisons.  CarseatBlog recommends that parents consult the IIHS Booster Ratings, as they are a great place to start and generally reflect a range of children and vehicles.  We do caution that their evaluations do not always apply directly to every possible combination of child and vehicle.  That means that a model that earned a “Best Bet” may not fit ideally with your child and vehicle.  Similarly, a model that earned a “Check Fit” rating may provide a good fit for your child, in your particular vehicle.

So, a lower rating does not necessarily mean your child is less safe, unless you check yourself and find the belt fit to be marginal or poor in booster mode, of course.  For example, I found the seatbelt fit of a Britax Frontier 90 (“Check Fit” rating) in booster mode to be very reasonable on my 8-year old child in a couple of popular vehicles, a Toyota Highlander and Prius.

 

As mentioned in the video, it is worthwhile to note that the Britax Frontier 90 and Pinnacle 90 have among the highest seated torso height limits for the 5-point harness system of any combination harness/booster carseat.  That means most kids can use the harness until they are 8 years old or possibly even older.  That is a very safe option if you did happen to find that the seatbelt did not fit your child well in booster mode, especially on younger or less mature children who may benefit most from the extra points of restraint in a 5-point harness system.