This 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
- 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)
- 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 will stop reading here unless they are looking for a cure to their insomnia! Curious readers and advocates looking for in-depth commentary are warned that it’s about to get more technical!