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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!

Combi Recalls Coccoro, Zeus Turn, Zeus 360 Convertible Carseats

Combi has issued recalled on the Coccoro, Zeus Turn and Zeus 360 convertible carseats for failure to meet harness test requirements.

Affected models are:

Combi Coccoro
Model Number: 8220
Manufacture Dates: January 6, 2009-December 5, 2012

Combi Zeus Turn
Model Number: 8815
Manufacture Dates: July 15, 2007-March 25, 2009

Combi Zeus 360
Model Number 8836
Manufacture Dates: February 25, 2009-May 24, 2012

The model number and manufacture date can be found on the bottom of the carseat.

Coccoro DOM label  Zeus DOM label

When the harness webbing is tested independently of the carseat, it does not meet minimum breaking strength because of an embedded plastic button which keeps the buckle tongue from sliding down under the child’s bum. Newer models no longer have the embedded button.

According to Combi, the affected carseats are still safe to use until Combi can send replacement harnesses to registered owners because the carseats do pass motor vehicle safety standards (FMVSS 213) as a whole, but according to NHTSA, “In the event of a crash, a child may not be remain adequately secured, increasing the risk of injury.” (sic)  What does CarseatBlog advise? FMVSS 213 requires a minimum strength of 11,000N (roughly 2,473 lbf) before the harness webbing breaks on a carseat. How much force does a 33 lbs. child apply in a 30 mph crash to the webbing (33 lbs. is the uppermost rear-facing weight limit of the Coccoro and both Zeus seats)?  An estimate often used by technicians is child weight (33) times speed (30)  = roughly 990 lbs, which is a far cry from 2,473 lbs force (11,000N). We prefer to do the basic math estimate for you and let you, as the parent, decide whether you want to follow Combi’s advice or NHTSA’s.

For more information on this recall, see Combi’s recall notice for more information and how to register your Combi seat if you haven’t yet.

All About Chest Clips: Function, Purpose & Proper Positioning

Chest clips are one of the least understood and most misused features on a carseat. I’m going to attempt to set the record straight on how they function, what purpose they serve and how they’re meant to be positioned.

 

Proper Positioning:

Chest clips should be positioned anywhere in the mid to upper chest area. Aim for armpit level which is where most carseat instruction manuals tell you to place the chest clip. The truth is that even if it’s a little lower than armpit level – it will still do its job as a pre-crash positioner of the harness straps, as long as the harness straps are snug and routed correctly over the child’s shoulders. A snug and properly routed harness is essential!

 Chest Clip - too low Chest Clip - just right

 

Comparison of Current Infant Seat Chest Clip Designs:

Top to Bottom: Evenflo, Graco, Chicco, Safety 1st, Cybex

Comparison of chest clip designs

 

Federal Safety Standards and Chest Clips:

Believe it or not, chest clips are not required on U.S. carseats by FMVSS 213. That’s because they’re really not necessary for crash protection as long as the harness is snug and positioned over the child’s shoulders. Regardless, chest clips are included on all current harnessed seats sold in this country so it’s a component we’ve come to expect. Just keep in mind that it’s possible for a new seat to debut next week or next year that doesn’t come with a chest clip. I actually owned, used and loved an infant seat that didn’t have a chest clip back in 2004.

SIV closeup

My Beloved
Fisher-Price Stay-In-View
Infant Carseat
Oct 2004

 

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.

IIHS 2013 Booster Seat Ratings – Making Sense of the Best Bets, Check Fit & Not Recommended Ratings

lap and shoulder belt fitYou will see it all over the news today and tomorrow. It will be on national morning shows, local news broadcasts, in newspapers and online. There will be a lot of good information, but there will also be the usual misinformation. Is your child as safe as possible just because you bought a booster that has a 2013 IIHS ”Best Bet” rating? Should you panic if you have one that is rated “Check Fit”? Does that mean it’s dangerous or unsafe?

Here at CarseatBlog, our job is to help guide you through the wonderful but overwhelming world of child occupant protection. Here you’ll get info and straight answers from experts in the field who are also parents, just like you. We’ve been around this block a few times already so allow us to help you sort through the mountains of information.