56146 Federal Register /Vol. 66, No. 215/Tuesday, November ...56146 Federal Register/Vol. 66, No. 215/Tuesday, November 6, 2001/Notices turning a corner, or parking, loss of power

56146 Federal Register / Vol. 66, No. 215 / Tuesday, November 6, 2001 / Notices

turning a corner, or parking, loss ofpower steering does not pose asignificant risk to traffic safety. The lossof drive to the generator prevents thevehicle’s battery from being charged, butis a progressive loss of battery powerand does not represent a safety concern.Loss of engine cooling could cause thevehicle to overheat, typically resultingin coolant overflow at the radiator or aburst cooling system hose, however,there have been no reports of suchincidences. Air conditioning is anauxiliary function, the loss of whichdoes not affect the safe operation of thevehicle.

In view of the foregoing, it is unlikelythat NHTSA would issue an order forthe notification and remedy of thealleged safety-related defect as definedby the petitioner in the subject vehiclesat the conclusion of the investigationrequested in the petition. Therefore, inview of the need to allocate andprioritize NHTSA’s limited resources tobest accomplish the agency’s safetymission, the petition is denied.

Authority: 49 U.S.C. 30162(d); delegationsof authority at CFR 1.50 and 501.8.

Issued on: November 1, 2001.Kathleen C. DeMeter,Director, Office of Defects Investigation,Safety Assurance.[FR Doc. 01–27869 Filed 11–5–01; 8:45 am]BILLING CODE 4910–59–P

DEPARTMENT OF TRANSPORTATION

National Highway Traffic SafetyAdministration

[Docket No. NHTSA–2001–10053–Notice 1]

Safety Rating Program for ChildRestraint Systems

AGENCY: National Highway TrafficSafety Administration (NHTSA), DOT.ACTION: Notice, request for comments.

SUMMARY: Section 14(g) of theTransportation Recall Enhancement,Accountability, and Documentation(TREAD) Act requires that, byNovember 2001, a notice be issued toestablish a child restraint safety ratingconsumer information program toprovide practicable, readilyunderstandable, and timely informationto consumers for use in makinginformed decisions in the purchase ofchild restraint systems (CRS).

In response to this mandate, NHTSAhas reviewed existing rating systemsthat other countries and organizationshave developed, and conducted its ownperformance testing to explore apossible rating system for child

restraints. The agency has tentativelyconcluded that the most effectiveconsumer information system is onethat gives the consumer a combinationof information about child restraints’ease of use and dynamic performance,with the dynamic performance obtainedthrough higher-speed sled testing and/orin-vehicle NCAP testing. The agency isalso giving consideration to conductingboth higher-speed sled tests and in-vehicle NCAP testing in conjunctionwith the Ease of use rating. Thisdocument provides a review of theinformation and reasoning used by theagency to reach that conclusion,describes the rating systems planned tomeet the TREAD requirements, andseeks comment on this plan.DATES: You should submit yourcomments early enough to ensure thatDocket Management receives them notlater than Janaury 7, 2002.ADDRESSES: You should mention thedocket number of this document in yourcomments and submit your commentsin writing to: Docket Management,Room PL–401, 400 Seventh Street, SW.,Washington, DC, 20590.

You may call Docket Management at202–366–9324. You may visit theDocket from 10 a.m. to 5 p.m., Mondaythrough Friday.FOR FURTHER INFORMATION CONTACT: Forissues related to a performance rating,you may call Brian Park of the New CarAssessment Program (NPS–10) at 202–366–6012.

For issues related to a compatibility/ease of use rating, you may call LoriMiller of the Office of Traffic SafetyPrograms (NTS–12) at 202–366–9835.

You may send mail to both officials atNational Highway Traffic SafetyAdministration, 400 Seventh St., SW.,Washington, DC, 20590.SUPPLEMENTARY INFORMATION:I. OverviewII. 2000 Public Meeting and Draft Child

Restraint Systems Safety PlanA. 2000 Public MeetingB. 2000 Child Restraint Systems Safety

PlanC. Public Comments About Child Restraint

RatingsIII. CRS Dynamic Performance Rating

ProgramsA. Existing Programs for Rating Dynamic

Performance of CRS1. Consumer’s Union2. Japanese NCAP3. Australian CREPB. Existing Programs for Rating Dynamic

Performance of Vehicles Equipped withCRS

1. Euro NCAP2. AustraliaC. CRS Dynamic Testing by IIHSD. CRS Dynamic Testing within NHTSA

1. CRS Performance in FMVSS No. 213Sled Testing

a. Advantagesb. Disadvantages2. CRS Performance in Higher-speed Sled

Testinga. Advantagesb. Disadvantages3. CRS Performance in NCAP Frontal

Vehicle Testinga. Advantagesb. Disadvantages

IV. Child Restraint Ease of Use RatingA. Child Passenger Safety Selection, Use,

and Installation WebsiteB. Summary of Existing Ratings for Ease of

Use1. Australia2. Consumer’s Union3. Euro NCAP4. ICBC.5 JapanC. Planned Child Restraint Ease of Use

Rating System1. Assessment of Existing CRS Ease of Use

Rating Systems2. Four Rating Categoriesa. Ready to Useb. Evaluation of Labels/Instructionsc. Securing the Childd. Installation in Vehicle3. Weighting the Features4. Ease of Use Rating Protocol5. Overall Ease of Use Rating

V. Discussion and CRS Rating SystemProposal

VI. Combined Child Restraint RatingVII. DistributionVIII. Submission of CommentsFiguresTableAppendices

Appendix AAppendix BAppendix CAppendix D

I. OverviewCongress has directed the National

Highway Traffic Safety Administration(NHTSA) to develop a child restraintsafety rating system that is practicableand understandable (Section 14 (g) ofthe Transportation Recall Enhancement,Accountability, and Documentation(TREAD) Act, November 1, 2000, Pub.L.106–414, 114 Stat. 1800) and that willhelp consumers to make informeddecisions when purchasing childrestraints. Section 14(g) reads asfollows:

(g) Child restraint safety rating program. Nolater than 12 months after the date of theenactment of this Act, the Secretary ofTransportation shall issue a notice ofproposed rulemaking to establish a childrestraint safety rating consumer informationprogram to provide practicable, readilyunderstandable, and timely information toconsumers for use in making informeddecisions in the purchase of child restraints.No later than 24 months after the date of theenactment of this Act the Secretary shallissue a final rule establishing a child restraint

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56147Federal Register / Vol. 66, No. 215 / Tuesday, November 6, 2001 / Notices

1 Robert Waller, Jr., Juvenile ProductsManufacturers Association, Inc., Docket 6628.

2 Comments on Child Restraint System Ratings,Ford Motor Company, Docket 7938.

3 Evenflo Company, Inc., Randy Kiser, Docket7938.

4 Partners for Child Passenger Safety, Flaura K.Winston, MD, PhD, Dennis R. Durbin, MD, MSCE,Kristy Arbogast, PhD, Shannon D. Morris, Docket7938.

5 Graco Children’s Products, Steve Gerhart, DavidE. Campbell, Docket 7938.

6 Comments on Child Restraint System Ratings,Ford Motor Company, Docket 7938.

safety rating program and providing otherconsumer information which the Secretarydetermines would be useful (to) consumerswho purchase child restraint systems.

In response to this mandate, theagency reviewed presentations given ata public meeting in February 2000, andcomments submitted in response to anotice announcing a draft ChildRestraint Systems Safety Plan. Theagency also examined other existing andproposed child restraint programs. Fouroptions that emerged were: (1) A ratingbased on Federal Motor Vehicle SafetyStandard (FMVSS) No. 213 compliancetests (sled tests), (2) a rating based onhigher-speed sled testing, (3) a ratingbased on in-vehicle testing, and (4) arating based on ease of use. The agencythen further explored each option todetermine if it would generateinformation that is practicable,repeatable, and appropriate.

After considering the various options,NHTSA has tentatively concluded thatthe most effective consumer informationsystem is one that gives the consumer acombination of information about childrestraints’ ease of use and dynamicperformance, with the dynamicperformance obtained through higher-speed sled testing and/or in-vehicleNCAP testing. The agency is also givingconsideration to conducting bothhigher-speed sled tests and in-vehicleNCAP testing in conjunction with theease of use rating.

This notice is arranged as follows.First, the notice will discuss theFebruary 2000 public meeting and thedraft Child Restraint Systems SafetyPlan, and the comments received fromthe public. Second, the notice willdiscuss other existing and proposedperformance ratings, the researchNHTSA has done, and NHTSA’s currentplan for rating child restraintperformance. Third, the notice willdiscuss other existing and proposedratings based on compatibility and/orease of use, and NHTSA’s current planfor rating child restraint ease of use.Fourth, the notice will discuss whyNHTSA is not planning a summaryrating for child restraints. Last, thenotice will briefly discuss how NHTSAplans to distribute child restraint ratingsto the public.

II. 2000 Public Meeting and Draft ChildRestraint Systems Safety Plan

A. 2000 Public Meeting

On February 9, 2000, NHTSAconducted a public meeting inWashington, DC, to discuss the safetyperformance of child restraint systemsand options for giving consumersinformation on the safety performance

of different child restraints (65 FR 1224,January 7, 2000, Docket No. NHTSA–2000–6628). The announced topics werevoluntary standards, strategies forenhancing compliance margins,improved labeling, and possible ways ofrating child restraint performance.

B. 2000 Child Restraint Systems SafetyPlan

On November 27, 2000, NHTSApublished a notice requesting commentson a draft Child Restraint System SafetyPlan (65 FR 70687, Docket No. NHTSA–2000–7938). The overall goal ofNHTSA’s Child Restraint SystemsSafety Plan was to reduce fatalities andreduce injuries to U.S. children aged 0–10 years who are involved in crashes.To realize this goal, the plan employedthree key strategies: encourage correctuse of child restraints for all children,ensure that child restraints provideoptimal protection, and give consumersuseful information about restrainingtheir child.

C. Public Comments About ChildRestraint Ratings

Several presenters at the publicmeeting and commenters to the planaddressed the idea of a performancerating based on compliance margins.The concept of compliance margins isbased on Federal Motor Vehicle SafetyStandard (FMVSS) No. 213, ChildRestraint Systems (49 CFR 571.213).Under this concept, child restraintswould be ranked according to how largea margin they passed the standard’sperformance criteria. The larger themargin that the child restraint passedthe standard by, the higher the childrestraint would be ranked. A MarylandChild Safety Technician suggested theuse of compliance tests to developratings, citing sufficient differences incrash test results. However, he voicedconcerns whether such a rating systemcould address the issue of vehiclecompatibility.

Other commenters opposed thedevelopment of a CRS rating based onthe compliance margin. JuvenileProducts Manufacturers Association,Inc. (JPMA) stated that, ‘‘while thecurrent FMVSS No. 213 standardprovides an exceptional rating system(essentially an easily-understood pass-fail), the industry would certainlyconsider some other type ofperformance rating system.’’ However,JPMA noted that with so manyvariables, it is likely that a rating systemmay have a potentially negative effectrather than a positive one. JPMAthought it appropriate also to mentionthat ‘‘the current dynamic standard,FMVSS No. 213, is more severe than

about 95 percent of all crashes, and thehistorical performance of PROPERLYUSED car seats both in testing and inthe field is exceptional, better even thanseat belts.’’ 1 Ford Motor Company andother child safety experts suggested thatthe agency consider having a ratingsystem only after revising FMVSS No.213. They stated that the currentstandard sled pulse is too severe and thetest protocol is outdated. Thesecommenters recommended that therevised standard should reflect thecurrent child passenger environment.2

Commenters addressed the idea ofincluding child restraints in frontal NewCar Assessment Program (NCAP) tests.Evenflo supports the addition of childrestraints to NCAP tests. The companybelieves that because the performancerequirements of FMVSS No. 213 are sodemanding, all child restraints passingsuch a standard deserve a high rating.Evenflo believes that distinguishingsafety performance between childrestraints that pass FMVSS No. 213 isdifficult. The company also feels thatthe addition of child restraints to NCAPtests will allow for an evaluation of howwell the child restraint system workswith the vehicles.3 ARCCA, Inc., favorsthe incorporation of child restraints intoNCAP tests. ARCCA stated that, NCAPtests more closely replicate real worldconditions than the FMVSS No. 213compliance tests. In addition, theincorporation of child restraints into theprogram would maximize its benefits.

Both Partners for Child PassengerSafety 4 and Graco Children’s Products 5

oppose adding child restraint systems toNCAP crash tests. These organizationsbelieve that the performance of childrestraints in NCAP tests may becharacteristic of the child restraint, thevehicle, or the restraint/vehicleinteraction. This poses questions as tothe significance of the results of suchtests. Ford agrees with these comments,adding that vehicle/CRS interfacefactors and various vehicle crash pulsesobscure the results of child restraintperformance in NCAP tests.6

Consumers and consumer advocatesalmost universally expressed theopinion that any child restraint rating



7 Identification and Publication of RelativePerformance of Different Child Restraint Systems,Insurance Corporation British Columbia, BettyBrown, Docket 6628.

8 Evenflo Company Inc., Randy Kiser, DocketNumber: 7938.

9 Consumer Reports, Traveling With Kids, July2001.

10 Pittle, Greenberg, Galeotafiore, Champion,Comments of Consumer Union to the NationalHighway Traffic Safety Administration on the ChildRestraint System Plan, Docket Number: NHTSA–7938, 2001. 11 www.nrma.com.au, July 23, 2001.

should include factors for compatibilitywith various vehicles and ease of use.These commenters noted that a goodperformance rating would bemeaningless if the child restraint wasnot compatible with the consumer’svehicle or was difficult to use properly.

The Insurance Corporation of BritishColumbia (ICBC) claimed that highmisuse rates of child restraints are acommon finding. Children aged 3 yearsand older are restrained, most often,only in adult seat belts. To compensatefor misuse, ICBC recommended that theNHTSA establish an ease of use rating.7Evenflo also feels that the mostproblematic area, the area in whichimprovement would have the greatestpositive impact, is in the nonuse andmisuse of child restraints.8 TheAutomotive Coalition for Traffic Safety(ACTS) agreed, and stated that thedynamic performance of child restraintsshould not be a big issue. ACTS furthersuggested, however, that the recentaddition of the top tether should reducemisuse. The University of NorthCarolina (UNC) Highway SafetyResearch was also a proponent of anease of use rating. They stated that thecrash test performance of childrestraints is only part of the informationthat should be incorporated into a ratingsystem. Safety Belt Safe concurred,mentioning that even top-rated systemsare difficult to use. They stated thatchild restraint ratings should be basedon real-world conditions and behavior,not solely on crash tests. GracoChildren’s Products, Inc. also asked thata rating system be based on more thansimply crash performance. Theysuggested that other factors such aslabeling and instruction clarity, ease ofinstallation and vehicle compatibility,fit of child, and ease of use, be included.

One manufacturer expressed concernabout starting an ease of use ratingsystem. The manufacturer asked whattype of person would do the evaluating.This manufacturer believed that itwould be a good idea to haveinexperienced people conduct theevaluation of child restraint systems.The manufacturer suggested using thesame people gives consistency in testmethodology. This commenter thoughtthe agency might have difficulty gettingthe same people always. The childrestraint manufacturers also believedthat a rating system would drive thechild restraint manufacturers to improve

their products and provide more ease ofuse features.

NHTSA met with two manufacturersof child restraints, Britax and Evenflo.These two manufacturers both statedthat the seats with higher cost are therestraints with more advanced featureswhich are likely to be ease of usefeatures. Both manufacturers describedhow a child restraint rating systemmight affect the retail market. Theybelieved that the retail buyers wouldlimit their purchases of child restraintsto those with high ratings.Consequently, the agency might drivethe retail market to the seats with thehigher prices.

III. CRS Dynamic Performance RatingPrograms

A. Existing Programs for RatingDynamic Performance of CRS

1. Consumer’s UnionThe July 2001 issue of Consumer

Reports was the Consumer’s Union’smost recent report on child restraints.9They gave a rating for the dynamicperformance of each child restraint,which is part of the overall rating givento child restraints. This overall rating isthe averaged score of dynamicperformance, ease of use, installation,and stroller use. The installation scoreis determined by how securely a childrestraint can be installed in threedifferent cars with different seats andsafety-belt types. Ease of use evaluateshow difficult it is to adjust the strapsand the harness. A stroller score is alsogiven to applicable child restraints. Thisscore is based on the safety,convenience, and the durability of thechild restraint and stroller. The dynamicscore was determined from a sled testrepresenting a 30 mph (48 km/h) frontalcrash. The seats were tested usingdummies that approximate an infant, 3-year-old toddler, and 6-year-old child.Head Injury Criterion (HIC), chest G,head excursion, and knee excursionwere compared with the injury criteriaestablished by NHTSA to determine thedynamic performance rating.10 A six-category range was used to rate childrestraints based on the dummymeasurements. The six categories were:Not Acceptable, Poor, Fair, Good, VeryGood, and Excellent.

The child restraints of the 2001survey were tested both with andwithout the top tether. The results from

this study showed that all but one childrestraint provided better protectionwhile using the top tether in frontalcrashes.

2. Japanese NCAP

The Ministry of Land, Infrastructure,and Transport (MLIT) in Japan recentlyannounced a proposal to rate childrestraint systems. MLIT is asking forcomments at this time. Japanese NCAPproposes to evaluate baby seats (rear-facing) and infant seats (forward-facingor convertible). They do not plan to testbed-type-seats or booster seats. Nine-month-old and three-year-old childdummies will be used for theevaluation.

Child restraints will be tested infrontal sled tests. Child restraints will betested using the ECE Reg. 44 crash pulseat 35 mph (56 km/h) in a Toyota Estima(similar to the Sienna in the U.S.) sledbuck. A rating system will comprise thedummy readings, the level of physicaldamage, release of CRS anchorage, anddummy kinematics. A four-tier ratingsystem will be used: Excellent, Good,Acceptable, and Not Recommended.

3. Australian CREP

The Child Restraint EvaluationProgram (CREP) is a joint program runby many of the same groups asAustralian New Car AssessmentProgram (ANCAP). CREP tests childrestraints in dynamic sled tests with atop tether, which is required inAustralia. Two frontal crashes aresimulated at 49 and 56 km/h (30 and 35mph). Side and rear crashes aresimulated at 32 km/h (20 mph). CREPconducts another test at the same speed,but with the CRS positioned at a 45°angle relative to the sled. One additionaldynamic test is done to rear-facing andconvertible child restraints only. This isan inverted test conducted at 16 km/h(10 mph) to simulate a rollover.

CREP gives a rating, incorporatingboth the dynamic test results and easeof correct use results. They report theseratings as either preferred buy orstandards approved. The preferred buyseats did well in the dynamic tests andthe ease of correct use tests. Thestandards approved rating is given toseats that passed the 49 km/h (30 mph)test, but had excessive head movementor broke a load-bearing componentduring the 56 km/h (35 mph) test.11



12 http://www.euroncap.com/results.htm, August23, 2001.

13 Notice for FMVSS No. 208, Federal Register,Vol. 65, No. 93, page 30680, May 12, 2000.

14 Association for the Advancement ofAutomotive Medicine, The Abbreviated InjuryScale, Des Plaines, 1990.

15 Susan Meyerson & Adrian Lund, InsuranceInstitute for Highway Safety, ‘‘Child RestraintDurability in High-Speed Crashes,’’ 2001 SAEconference, SAE2001–01–0123.

B. Existing Programs for RatingDynamic Performance of VehiclesEquipped With CRS

1. Euro NCAPThe European New Car Assessment

Program evaluates the safety of childrenin vehicle crash testing. The subjectvehicle’s manufacturer provides arecommendation for which childrestraints are to be used during the tests.The Europeans install child restraints invehicles and subject them to offsetfrontal and side impact tests. In theoffset frontal testing, two child crashdummies are placed in the back of thetest vehicle. The two types of childdummies used in the test are a 3-year-old P dummy and an 18-month-oldinfant P dummy. Both dummies areplaced in the appropriate CRS, eitherforward-facing or rear-facing, designatedfor their ages. For the side impact test,the dummies are secured in the samemodel child restraint used for the offsetfrontal crash test.

Euro NCAP evaluates dummykinematics. In addition, techniciansevaluate ease of use, ease of installationin the vehicle, and how securely theycan install the CRS. Currently, EuroNCAP does vehicle tests for childrestraints without using a top tether.Euro NCAP gives points based on thedynamic performance of the childdummies during the full-scale crashtests. These points are subject tomodifiers that will reduce the pointsearned. Such modifiers includepenalties for ejection, poor seat labeling,and vehicle incompatibilities. A total offour points is possible for the childscores. These points are added to theoverall total, which is used to determinethe vehicle’s star rating. However, if anyanomaly leads to a dangerous event(e.g., if the child seat breaks or if a beltbecomes unlatched), Euro NCAP notesthe event to consumers in theirpublications and web site.12

2. AustraliaThe Australian New Car Assessment

Program (ANCAP) harmonized itstesting procedures with Euro NCAP in1999. Therefore, in accordance with theEuro NCAP procedures, ANCAP doesboth an offset frontal crash at 64 km/h(40 mph) and a side impact test at 50km/h (31 mph). Two child restraints areplaced in the rear seat of each vehicle.TNO P1.5 (18-month) and P3 (3-year-old) dummies are used to assess injury.ANCAP plans to rate the dynamicperformance of child restraints invehicle tests, however, the rating

protocol will likely be different fromthat published by Euro NCAP.

C. CRS Dynamic Testing by IIHSThe Insurance Institute for Highway

Safety (IIHS) currently does not ratechild restraints. However, IIHS recentlydid several vehicle frontal crash teststhat included child restraints. Vehiclevelocities in these car-to-car tests were48 km/h (30 mph), and vehicle frontalengagement ranged from 49% to 89%.Dummies used in the testing were the 6-month-old Infant CRABI, the 12-month-old CRABI, and the 3-year-old HybridIII.

IIHS evaluated the dummy results forthe 6-month-old CRABI, the 12-month-old Infant CRABI, and the 3-year-oldHybrid III. They used the correspondingreference values specified in the May12th, 2000 Federal Register notice forFMVSS No. 208.13 The results for the 6-month-old CRABI and the 12-month-oldCRABI were all well below theallowable limits. The results for the 3-year-old Hybrid III dummy showed allinjury readings were less than thereference values except for neck tension.IIHS suggested that these results meanthe current neck tension criterionoverestimates the possibility of an AIS 14

≥ 3 injury.15

D. NHTSA CRS Dynamic TestingIn response to the TREAD Act,

NHTSA examined three dynamic testmethods for rating child restraintsystems. The first dynamic option wasa sled test at 30 mph (48 km/h). Thisoption would use the results of theFMVSS No. 213 compliance testing todetermine a rating. Two possible ratingschemes could be used to rate or rankthe child restraint dynamicperformance. One possible ratingscheme would be based on thecompliance margins with which adummy met the limits of the standardon HIC, chest acceleration, headexcursion, and knee excursion. Asecond rating scheme would use theinjury risk curves that NCAP uses to rateadult occupant protection in a frontalcrash. Scaling these curves to representa 3-year-old child would produce a five-star classification system. Theprobability of injury for the 3-year-oldchild is as follows:Phead = [1+exp(5.02¥0.00431*HIC)]¥1

Pchest = [1+exp(5.55¥0.0756*ChestG)]¥1

A second dynamic testing optionexamined was a high-speed sled test at35 mph (56 km/h). This test methodwould be similar to the current FMVSSNo. 213 compliance test; however, thesled acceleration pulse would have agreater magnitude to increase the speedto 35 mph (56 km/h). A third dynamictesting option considered was a full-scale crash test. This approach wouldadd a child restraint in the rear seat ofa vehicle when it is tested for frontalNCAP, and rate the vehicle on how wellthe CRS and vehicle work together toprotect the child. These last two optionswould also use the scaled injury riskcurves for a rating.

Each of the next three sectionsdescribes the testing conducted by theagency to assess each of the proposedoptions. The summaries review thetrends of child restraint system (CRS)responses in the Federal Motor VehicleSafety Standard (FMVSS) No. 213 sledtesting, higher-speed sled testing, andfrontal NCAP in-vehicle testing.

1. CRS Performance in FMVSS No. 213Sled Testing

As specified in Standard No. 213, 49CFR § 571.213, the agency doescompliance testing of child restraints ona sled buck at a nominal speed of 30mph (48 km/h). Currently, a Hybrid IIdummy is used in testing to represent a3-year-old child.

In model year 2000, the agency tested50 upright, forward-facing childrestraints according to FMVSS No. 213.Twenty-four seats were tested without atop tether, and 26 seats were tested witha top tether. We restrained all seats withonly a lap belt (no lower anchorage orshoulder belt). The pertinent test resultsare tabulated in the Appendix, TableA2.

Currently, to pass the FMVSS No. 213compliance test, a child restraint mustachieve dummy injury numbers of aHead Injury Criterion (HIC) less than1,000 and a resultant chest accelerationof less than 60 G’s. For the compliancetests, HIC is calculated using anunlimited period and chest accelerationuses a 3 ms clip. As shown in Figure 1,regardless of whether we equipped thechild restraints with a top tether, allchild restraints achieved dummy injuryreadings below the maximum allowablevalues. Figures 2 & 3 illustrate themargin of compliance for HIC and chestacceleration, respectively. The margin ofcompliance is one minus the measuredinjury reading divided by the injuryassessment reference value (IARV) times100. Higher percentages are better,having less probability of injury.Regarding the HIC, all model year 2000



16 ‘‘LATCH’’ is a term used by industry and retailgroups referring to the child restraint anchoragesystem required by Federal Motor Vehicle SafetyStandard No. 225. LATCH stands for ‘‘LowerAnchorages and Tethers for Children.’’ The term isused to refer to vehicles equipped with theanchorage system (e.g., ‘‘LATCH vehicles’’) and tochild restraints equipped with attachments thatconnect to the anchorage system (e.g., ‘‘restrainedwith LATCH,’’ or ‘‘LATCH child restraints’’). Forconvenience, we will use the term in this notice.

child restraints tested easily fall withinthe limits specified by the FMVSS No.213 compliance tests. Most had acompliance margin of more than 50%.Although the margin is not as large forchest acceleration, all tested childrestraints passed this compliancerequirement as well.

FMVSS. No. 213 also has arequirement for head and kneeexcursion. Head excursion is limited to720 mm (28 in) when a top tether isused, and 813 mm (32 in) without useof a top tether. Knee excursion islimited to 915 mm (36 in). Figures 4 &5 illustrate the margin of compliance forhead excursion and knee excursion,respectively. Head and knee excursionlimits are compliance limits imposed toreduce the chances of a child strikingthe vehicle interior or submarining(sliding under the belt feet first) in anautomotive crash. Head and kneeexcursions are much closer to thecompliance limits than HIC and chestacceleration. (This may reflect attentionto occupant protection, since increasesin distance traveled by the occupantreduces the forces experienced by theoccupant.)

To further investigate the possibilityof using FMVSS No. 213 compliancetesting to rate child restraints, NHTSAperformed additional sled tests to gatherchild restraint protection data. Thesesled tests were performed in accordancewith the specifications outlined inFMVSS No. 213 compliance tests, withtwo exceptions. The three-year-oldHybrid III dummy was used to assessinjury rather than the Hybrid II dummy.Also, the current compliance testsecures child seats in twoconfigurations, lap belt only and lap beltwith top tether. These additional sledtests secured the child seat with the lap/shoulder belt and tether. One childrestraint tested was secured withLATCH.16

Nine child restraints were tested.Figure 6 shows the individual plots ofchest acceleration versus HIC. Injuryrisk curves are also plotted, andillustrate that eight of the nine childrestraints would receive a 5 star rating,while the other one would be borderline5 star/4 star.

Advantages and Disadvantages of aRating System Based on FMVSS No. 213Compliance Testing

a. Advantages

—Ratings for most child restraintsystems could be implementedquickly and inexpensively usingHybrid II results now obtained inStandard No. 213 compliance testing.

—The compliance testing is a simplepass and fail rating system. Carryingout a rating based on the margin ofcompliance is straightforward. Theperformances of child restraints couldbe used as a rating system.

—The rating system based on sledtesting subjects all child restraints tothe same impulse loading, so childrestraint performance is assessed withlittle or no influence of outsidevariables.

b. Disadvantages

—FMVSS No. 213 is currently underrevision. Ford Motor Company andothers suggest that the agencyconsider delaying the child restraintsafety rating until after the revision ofFMVSS No. 213.

—A rating based on dynamic sledtesting does not take into account thecompatibility between child restraintsand vehicles. Many people believethat a child restraint and a subjectvehicle must be evaluated as a systemto effectively assess child safetyprotection.

—To the extent that current childrestraints all exceed the standard by awide margin, as in the case for HIC,the compliance margin may notmeaningfully distinguish among childrestraints. For example, if we use thestar rating system, nearly every childrestraint would get 5 stars. If we usethe percentage of compliance margin,should we tell the public a childrestraint with a 60% margin is saferthan one with a 55% margin? Also, itwould be difficult to explain to thepublic which compliance margin (i.e.,HIC, chest acceleration, excursions) ismore important to safety.

2. CRS Performance in Higher-speedSled Testing

Some commenters suggested that theagency should consider having a childrestraint rating based on sled tests at ahigher speed (35 mph) than thecompliance testing (30 mph). As NCAPcurrently tests motor vehicles at 5 mph(8km/h) above the compliance tests, thesame reasoning could be applied to thesled testing of child restraints. (It wasalso recommended that the ratingsystem use a realistic vehicle pulse anda vehicle seat as part of the test

condition.) To determine the viability ofdeveloping an effective rating system asa consumer program for child restrainttesting, the agency has conductedhigher-speed sled testing.

NHTSA conducted higher-speed sledtests using the same nine childrestraints as in the previous section. Thesame FMVSS No. 213 test procedurewas used with Hybrid III three-year-olddummies. To attain the higher speed, asled pulse with a similar shape andduration length as that of the 213 pulsewas used, except that the change-of-velocity was elevated from 30 mph(48km/h) to 35 mph (56km/h).

All of the child restraints testedproduced dummy injury measurementswell below the FMVSS No. 208 criteriaof 570 HIC and 55g chest acceleration.Figure 7 shows the results plotted withthe NCAP injury risk curves. Althoughthe injury assessment values are slightlygreater for the 35 MPH (56 km/h) sledtests than the 30 mph (48 km/h) sledtest (shown in Figure 6), eight of thenine child seats fell within the 5 starrange, and one fell just below in the 4star range.

Advantages and Disadvantages of aRating System Based on Higher-speedSled Tests

a. Advantages

—Running tests at higher speeds is thesame approach we have used for frontand side crashworthiness ratings inNCAP, and would be expected tomagnify performance differencesamong child restraint systems beyondthat obtained in compliance testing.

—A rating based on sled performancewould be consistent because all childrestraints would be subjected to thesame impulse loading and would beplaced on the same simulated seat.

b. Disadvantages

—A rating based on a higher sled testspeed would again not take intoaccount compatibility between childrestraints and vehicles. Many peoplebelieve that a child restraint and asubject vehicle must be evaluated asa system to effectively assess childsafety protection.

—A higher test speed with the StandardNo. 213 crash pulse may be so severethat the information would not be ahelpful indicator of expected CRSperformance in the majority of real-world crashes.

—Based on tests with nine child seats,the higher test speed may notsufficiently ‘‘spread out’’ theperformance differences to allowNHTSA to provide meaningfulinformation to the public.



3. CRS Performance in NCAP FrontalVehicle Testing

The agency evaluates vehiclecrashworthiness in frontal and sideimpact under the New Car AssessmentProgram (NCAP). Under this program,the agency conducts approximately 40frontal and 40 side crash tests each year.For the frontal crash, the agency doesthese tests with two 50th percentileadult male dummies in the front seat.Historically, NCAP does not put anyoccupants in the rear seats of thevehicles. However, because there isroom in the rear seats of most vehicles,it has been suggested that NHTSA addchild restraints to the rear of NCAPfrontal crash tests.

NHTSA has evaluated child restraintsin frontal crash tests conducted underthe New Car Assessment Program. Inmodel year (MY) 2001 testing, NCAPused various child restraints in the rearseats of vehicles undergoing frontalNCAP crash tests. Child restraints wereplaced in a total of twenty NCAPvehicles, varying in type and size. Theagency evaluated performances of sixdifferent five-point-harness forward-facing child restraints. The evaluationassessed (1) the variability of CRSperformance in various vehicle typesand sizes, (2) CRS/vehicle interaction,and (3) performance among differentchild restraints. CRS performance in theNCAP vehicle tests is shown in TableA1 in the Appendix.

In each vehicle tested, the subjectchild restraint was secured tightly, andas prescribed by the child restraintmanufacturer’s instructions. In addition,all child restraints, whether securedwith LATCH or secured with a lap/shoulder belt, used a top tether. AHybrid III three-year-old dummy wasused to assess performance. All testingused the full instrumentation packageavailable for the child dummy. Theinjury assessment reference values forFMVSS No. 208 were used to evaluatethe results.

Figure 8 shows the overall childdummy performance concerning theHead Injury Criterion (HIC 15) andresultant chest acceleration, plottedwith the NCAP injury probability curvesscaled for the three-year-old. Theperformance is shown for childrestraints with LATCH or with a beltrestrained CRS with a top tether. Asshown, many (38.7%) dummy readingsexceeded the allowable injury criterionfor HIC 15 (570) or the allowable chestG criterion (55 G’s). Using the star ratingsystem, most vehicles would be ratedwith 3 or 4 stars for rear seat childoccupancy protection. Five samples hadinjury readings low enough for a five-

star rating; only one vehicle was ratedwith two stars. This is in contrast todriver and right passenger frontal NCAPtest results which result in about 88%4 and 5 star ratings.

All seats tested in the NCAP vehiclecrash tests used five-point harnesses,while the FMVSS No. 213 tests use alltypes of harnesses. Figure 9 shows themodel year 2000 compliance testsresults for only seats with a five-pointharness and lap belt only. This graphshows that the tethered seats producedlower HIC responses than those seatswithout a top tether. The HIC responsesfor both the tethered and the non-tethered seats are clustered among theirrespective seat types. In comparing thedata in Figures 8 and 9, we may inferthat the full-scale crashes produce agreater range of values for the HeadInjury Criterion. One could further inferthat the greater range of HIC responseshown in the NCAP data of Figure 8 isdue not only to the child restraint, butalso due to crash variations, such ascrash pulse, belt geometry (importantfor child restraints that use a lap/shoulder belt), seat contour, and seatcushion stiffness.

The influence of these additionalfactors for crash testing is shown moreclearly in Figure 10. Figure 10 showsseven vehicles that underwent NCAPcrashes with the Cosco Triad childrestraint. As shown, the Cosco Triad didnot give the same performance in theseseven NCAP vehicles. HIC injury valuesvaried from approximately 300 to 650.The performances of the EvenfloHorizon V and the Fisher Price SafeEmbrace II show like trends in vehicletesting. This is shown in Figure A1 inthe Appendix.

The agency has conducted this testingto address whether a specific childrestraint would do the same in variousNCAP vehicles. We determined that theanswer is no. The agency next examinedwhether various child restraints woulddo equally well in a specific vehicle.

Figure 11 shows the relativeperformance of four different CRSscrashed in two different minivans. Twocrash tests were conducted with eachminivan, and there were two childrestraints placed in the rear seat for eachtest. The first Grand Caravan was testedwith the Century STE and Horizon V.The second time, it was crashed withthe Safe Embrace II and the Horizon V.For the Ford Windstar, the first test hadtwo Safe Embrace II child restraints inthe rear seat; in the second test, CoscoTriad child restraints were used. Allchild restraints in each comparisonwere restrained with either LATCH(which includes a top tether) or a lap/shoulder belt and a top tether. Although

the data are extremely limited, and therewas only one CRS (Safe Embrace II) thatwas used in both vehicles, CRSperformance appeared to be better whentested in the Ford Windstar, and may bean indication that the vehicle has aninfluence on child safety protection.

Figures 12 & 13 show vehicle crashpulse duration and acceleration peakversus chest acceleration. Althoughthere is considerable scatter in the data,there appear to be slight trends, whichwould indicate that the vehicle’sstructural response could have aninfluence on the child restraintperformance. Figure 12 suggests that, asthe time duration of the crash increases,there is a reduction in chestacceleration. Figure 13 shows that, asthe peak acceleration of the vehicleincreases, there is a trend toward higherchest acceleration. (The agency did notfind similar trends for the Head InjuryCriterion.)

Based upon this limited amount ofdata, it appears that a child restrainttested in a vehicle with good crashpulse characteristics (i.e., longer timeduration, lower peak acceleration) couldperform better than the same childrestraint tested in a vehicle that doesnot.

Further, good performance does notdepend upon cost of the CRS. Theagency examined the cost of childrestraints (MY 2000) versus the relativeperformance of forward-facing childrestraints tested with the three-year-olddummy in FMVSS No. 213 sled tests.Figure 14 shows no correlation betweenthe cost of child restraints and theirperformance in dynamic sled testing.For the low IARV’s, (HIC < 400 andchest G <40), there are CRS from allprice ranges. In addition, the two CRSwith the highest HIC and chest Gresponses were in the $100–$150 costrange (i.e., a high cost range). Therefore,the limited available data show that aCRS need not be expensive to providegood child protection.

Advantages and Disadvantages of Ratinga Vehicle Equipped With a ChildRestraint

Unlike the rating systems proposedfor the sled tests at 30 mph (48 km/h)and 35 mph (56 km/h) which rate onlythe child restraint, this option wouldrate the vehicle equipped with a CRS asa system in protecting the child.

The following discusses the pros andcons of basing a rating system on in-vehicle testing of child restraints.

a. Advantages—In-vehicle testing would address the

interaction of the vehicle and thechild restraint in overall safety



performance, since it wouldencourage vehicle manufacturers totake into account child restraintperformance in designing vehicles.

—Using in-vehicle testing to evaluate achild restraint in the vehicle wouldenhance world harmonization withEuro NCAP and ANCAP.

—CRS testing can be easily incorporatedinto the New Car AssessmentProgram. The NCAP programconducts about 40 frontal crashesannually; adding child restraints tothese tests could be done at arelatively low cost.

b. Disadvantages

—Such a system would provide a ratingfor the vehicle rather than the childrestraint. Also, the consumer maymistakenly think that some childrestraints may appear to have poorperformance if the agency only teststhem in certain vehicles, when inactuality they may perform well inother vehicles.

—To the extent that the agency onlytests a child restraint in vehicles thatperform well, that information maymislead the public about theprotection offered by that childrestraint in lesser-performingvehicles.

—This rating system would not helpconsumers choose a child restraintsuitable for an older vehicle model.

—Adding the CRS and dummy to theNCAP vehicle would require theremoval of fluids and/or vehiclecomponents to attain the test weight,and thereby potentially influenceassessment of other NCAP crashresults such as fuel leakage.

IV. Child Restraint Ease of Use Rating

A. Child Passenger Safety Selection,Use, and Installation Website

In addition to implementing a childrestraint rating program, NHTSA hasalso been mandated by Congress toconsider how to provide consumerinformation on the physicalcompatibility of child restraints andvehicle seats on a model-by-model basis(Section 14(b)(4) of the TREAD Act).

In May 1995, the Blue Ribbon Panelon Child Restraint and VehicleCompatibility made a series ofrecommendations including asuggestion that vehicle manufacturerscreate a chart illustrating whichhardware and what procedures ofinstallation were necessary to ensureproper installation of child restraints invehicles. In the Fall of 1995, NHTSAconsidered this recommendation and atthe time, determined that the agencywould try to develop a child restraint

and vehicle compatibility database andmake it available on a CD–ROM to childpassenger safety advocates and otherswho assist the public with child safetyeducation and proper installation. It wasbelieved that the program would allowthe cross-referencing of data regardingspecific child restraints considering theweight and age of the child, vehiclemake, model and year choicesindicating available seating locations,resulting in a list of compatible childrestraints and vehicle seating andinstallation information. The originalplan was to have a database containingchild restraint installation informationfor 100 different 1993–1996 model yearvehicles, using 35 child restraints.

Over the course of developing thisdatabase, it became apparent thatcollecting data on several childrestraints in hundreds of vehicles,resulting in the combination ofthousands of child positioningpossibilities was inherently subjective,prohibitively expensive, and very laborintensive. In addition, the informationthat would be available to assistconsumers was limited to a certain typevehicle and a certain type childrestraint, which would serve only asmall number of consumers. Further,the LATCH rulemaking will greatlyenhance the compatibility of childrestraints and vehicles, which reducesthe need for a CD–ROM database.Realizing these limitations, NHTSAbegan to explore ways in which wecould develop a service that wouldprovide accurate and up-to-dateinformation to consumers on how toproperly select the appropriate restraintfor their child, and use and install itproperly. In addition, NHTSA wanted toutilize the infrastructure of trained andcertified child passenger safetytechnicians (over 19,000 to date)throughout the country.

In March 2001, NHTSA developedand made available an internet-basedservice on its website, providingrecommendations for the correct use ofeach type of child restraint to helpconsumers select the most appropriatechild restraint system (http://www.nhtsa.dot.gov/people/injury/childps/csr2001/csrhtml/safetyFeatures.html). It provides acurrent listing, along with pictures, ofall new child restraints available alongwith a list of various features availableon the child restraints that may makethem easier to use and install. Itprovides a list of model year 2001vehicles with child restraint features, aswell as vehicle owner’s manualinstructions for child restraintinstallation. In addition, this websiteapplication includes pictures of proper

use and step-by-step instruction oninstallation. It also describes and showscommon compatibility problemsbetween vehicles and child restraintsand offers solutions to obtain the bestfit. This website application allows forthe continual addition of current andaccurate information, at minimum cost,and significantly expands public access.The site has received thousands of visitsper week since its placement in March.

This application is not specific tochild restraints and vehicles on amodel-by-model basis, as originallyintended. However, it providesguidelines for the selection of theappropriate restraint, tips for proper useand installation, and points consumersin the proper direction for installationassistance, by linking to a listing ofthousands of inspection stations locatedthroughout the country whereconsumers can go and have their childrestraint inspected by a certified childpassenger safety technician. For thesereasons, and because providing theinformation on a model-by-model basishas proven to be limited, impracticable,and prohibitively costly, we havedecided that the web-based approach isthe appropriate method of providing theconsumer information to the public.

B. Summary of Existing Ratings for Easeof Use

1. Australia

The New South Wales Roads andTraffic Authority (RTA) joined with theNational Roads and MotoristsAssociation (NRMA) and the RoyalAutomobile Club of Victoria (RACV) toconduct a joint program to assess therelative performance of child restraintsavailable in Australia. In addition tocrash testing, the program coversinstallation, use and compatibility witha range of vehicles. The child restraintsthat performed the best were given a‘‘preferred buy rating.’’ To be awardeda ‘‘preferred buy rating,’’ a childrestraint must perform well in crashtests that are more severe than theAustralian Standard and perform wellfor ease of correct installation and easeof use.

Child restraint/vehicle compatibilityis evaluated by fitting each restraint inboth the rear center and rear left seatsof test vehicles. The vehicles used toevaluate compatibility are the top-selling models in each of the followingcategories: large sedan, large stationwagon, small hatchback, mediumhatchback, multipurpose vehicle, andlarge four-wheel drive. In addition tothe determination that the restraint andvehicle are compatible, the NRMA alsoevaluates restraints on how easy they



17 If an infant restraint is sold with a stroller thestroller is also evaluated.

were to install in vehicles and howeasily children could be secured inthem.

2. Consumer’s UnionConsumers Union (CU), a nonprofit

membership organization, has beenevaluating child restraints for more than25 years. Their child restraint ratingscan be found on their web site and intheir publication, Consumer Reportsmagazine.

Consumers Union tests childrestraints for crash protection, ease ofuse, and the ability to install properlythe restraint with different seatbelts.17

In making its judgment about ease of usethe following attributes are considered:—Threading vehicle belt through

restraint,—Adjusting harness strap position for

different size children,—Adjusting harness strap tension,—Adjusting ‘‘belt positioner’’ on

boosters,—Placing child in the restraint and

arranging the harness,—Engaging/disengaging the harness

locking mechanism,—Ease of installation in a vehicle with

and without the detachable base,—Ease of disengaging the restraint from

a detachable base,—Carry handle comfort with a 20 pound

dummy, and—Presence of recline angle gauges or

indicators and ease of using reclinelevel adjustment.All of the items are evaluated

subjectively on a five-point scale(Excellent, Very Good, Good, Fair, andPoor). The crash protection, ease of use,and installation ratings are alsocombined into an overall rating.

3. Euro NCAPIn the European New Car Assessment

Program, vehicle manufacturersrecommend the make/model of a childrestraint suitable for a 3-year-old childand a second restraint suitable for an 18-month-old infant. These restraints arethen installed in the rear seat of thevehicle during the crash tests.Technicians then provide an evaluationof the ease of installation in the vehiclewhen setting up the test. NHTSA is notaware of any defined criteria for thisevaluation. The evaluation providesinformation about the compatibility ofsome child restraint make/models withtested vehicles. In addition, if a vehicledoes not have a device for deactivatinga frontal protection air bag, a notation ismade about the quality of the vehicle’swarning about the hazards of air bagswith child restraints.

4. ICBC

The Insurance Corporation of BritishColumbia (ICBC) is a public agency inCanada that was established in 1973 toprovide universal auto insurance tomotorists in British Columbia, Canada.In July 1999, ICBC invited members ofthe child restraint usability task force ofISO/TC22/SC12/WG1 (Child Restraints)to meet in Victoria, BC. The purpose ofthe two-day meeting was to prepare adraft document of usability criteria andobjective tests for child restraintmanufacturers. Consumer and insurancerepresentatives who evaluated the‘‘usability’’ of child restraints sold in BCsubsequently used the draft document.The findings were subsequentlypublished in an ICBC brochure called‘‘Buying a Better Child Restraint.’’

Depending on features and type ofrestraint, the ICBC strategy rates some orall of the following features:—Ready to use—Instructions for use,—Ease of conversion,—Labeling on the child restraint,—Securing the child in the restraint,—Installation of the child restraint, and—Tether straps

Several factors are evaluated withineach feature category by the evaluators.The participants in the initial meetingrated each of these factors A, B or Caccording to risk and severity of misuse.The factors with the higher risks ofinjury if misused were rated ‘‘A,’’ whilethe factors with the lower risks of injurywere rated ‘‘C.’’ The evaluators then rateeach factor, based on agreed uponstandards, either ‘‘good,’’ ‘‘acceptable,’’or ‘‘poor.’’ This rating is then combinedwith the A, B, or C weighting for thatfactor. All of the ratings for all of thefactors for a feature are combined andan overall rating for that feature isdetermined. The ICBC does not combinethe ratings for each feature to developan overall rating.

5. Japan

The Japanese Ministry of Land,Infrastructure and Transport, incooperation with the NationalOrganization for Automotive Safety &Victims’ Aid, tests and evaluates thesafety of automobiles currently on themarket in Japan. The results of thesetests are publicly released under thetitle New Car Assessment Japan. Japanhas proposed rating child restraints aspart of its New Car Assessment programin 2002.

In addition to dynamic testing, Japanhas proposed rating child restraints onease of use. Specialists would rate therestraint in five categories. Thesecategories are the user manual and other

information (i.e., ease of understandingand accuracy), illustrations andinstructions on the child restraint (i.e.,ease of understanding and accuracy),the safety features of the child restraint(i.e., recline device, cover, andattachment storage), ease of installation(i.e., ease of threading belts and abilityto tightly install), and how well thechild restraint fits into the vehicle (i.e.,ease of adjustment and buckle releasemechanism).

Japan proposes to rate each itemwithin the five categories using a 5-levelrating system. NHTSA was providedwith a summary of the proposaltranslated into English, which did notindicate what criteria would be used foreach category. The category ratingwould then be the average level of eachitem within that category. A graphicalrepresentation of the ratings would bepresented on a ‘‘radar chart’’ with aspoke for each of the five categories.

C. Planned Child Restraint Ease of UseRating System

1. Assessment of Existing Ease of UseRating Systems

After analyzing all the comments andgathered information, NHTSA hastentatively decided that it appearspossible to have a fair and repeatablerating for ease of use. The agency hasmodeled its planned approach on thatused by ICBC, because ICBC usesobjective criteria for what is ‘‘good,’’‘‘acceptable,’’ and ‘‘poor’’ for each factorrated. NHTSA is also proposing to usea weighting system for the relativeimportance of each feature within eachease of use category. The agency isplanning to rate ease of use features infour categories as A, B, or C, with Abeing the highest rating and C thelowest. In addition, NHTSA is alsoconsidering taking the ICBC ratingsystem one step further by combiningthese four ratings into an overall ratingfor ease of use using the same scale.

Almost all of the features evaluated bythe other programs NHTSA examinedare included in NHTSA’s plannedprogram. The difference between ICBCand the other ease of use rating systems(Australian, CU, Euro NCAP, andJapanese) was the known objectivecriteria for each feature in the ICBCprogram and the known weighting ofthe features within each category in theICBC program. To the extent that afeature evaluated by another program isnot included in our program, NHTSAhas tentatively determined that it is nota feature related to safety when using



18 NHTSA requests comments on whether weshould delete any of the features we have proposedto include, or whether we should include featuresthat we have not included in today’s proposal. Forexample, should rear-facing restraints be ratedaccording to the leg room they provide, which maybe a feature that would make the restraint easier touse by infants with long legs?

19 A copy of the planned evaluation form isincluded in the appendices to this notice. Detailsof the program are discussed only to the extent thatthey differ from ICBC’s program.

20 The agency is mindful that Standard No. 213requires an owner registration card to be attachedto the child restraint, and that too many materialsattached to the restraint could dilute the consumer’sattention to the registration card. Comments arerequested on whether attaching the owner’s manualto the restraint will overwhelm the card.

the child restraint in a vehicle.18 Theadditional difference between ourplanned approach and Euro NCAP isthat Euro NCAP only evaluates thoseseats that have been selected by vehiclemanufacturers for inclusion in the crashtest. NHTSA hopes to be able toevaluate all or almost all the childrestraints available in the US market atthe time of the evaluation.

NHTSA personnel spent a dayconducting a hands-on evaluation of theICBC rating program to determine therepeatability of the program. With theassistance of a representative of theICBC rating program, those present weredivided into two teams. Both teamsevaluated the same six seats. Theirscores were put in a computer programthat incorporates the weighting. Thepersonnel compared the evaluationscores. While the teams had some minordifferences in ratings for features withineach category, the agency task forceteam evaluation resulted in 100 percentrepeatability for each category.

While NHTSA agrees that overall, thefeatures selected and rated in the ICBCprogram are those that are most subjectto misuse, analysis of each componentand review of the evaluation criteria hasled NHTSA to modify slightly the ICBCprogram. One of the reasons whychanges were made was an effort tosimplify the information provided toconsumers. Other changes were made toreflect child restraint standards of theUnited States to the extent that they aredifferent from those in Canada. Last,some modifications were also madebased on information learned from therepeatability exercise. All of the changesare explained in greater detail below.19

2. Four Rating CategoriesDepending on features and type of

restraint, the ICBC strategy rates up toseven categories:—Ready to use,—Instructions for use,—Ease of conversion,—Labeling on the child restraint,—Securing the child in the restraint,—Installation of the child restraint, and—Tether straps

Based upon its assessment, NHTSA isplanning to rate four categories for eachrestraint:

—Assembly,—Evaluation of Labels/Instructions,—Securing the Child,—Installation in Vehicle,

NHTSA combined labeling andinstructions into one category. InNHTSA’s experience, most labels andinstructions are stylistically similar, andtherefore any restraint is likely to havethe same rating in each of thesecategories. In addition, ICBC hasindicated and our experience alsoshowed, that these categories are theleast objective. NHTSA believes thatcombining them into a single categorywould reduce the influence they wouldhave on a combined rating for ease ofuse and/or the importance a consumerwould place on the individual rating.NHTSA also moved the criteria for‘‘Ease of Conversion’’ to a ‘‘Securing theChild’’ category, since the ease ofadjusting a child restraint for differentsize children is directly related to theease of securing a child in the restraint.Finally, NHTSA moved ‘‘Tether Straps’’to the ‘‘Installation in Vehicle’’ category,because there is only one criterionrelated to tether straps, and because thiscategory also relates to ease ofinstallation in a vehicle.

a. Assembly

NHTSA has decided to include thefollowing features in the ‘‘Assembly’’category:—All functional parts including seat

pad or cover attached and ready touse

—Tether attached to child restraint—Owner’s manual easy to find—Obvious storage pocket for manual

NHTSA chose not to include the ICBCfeature, ‘‘any other add-ons in box’’because it is believed that such add-ons,for example extra pads, cup holders, suncanopy, were not related to ease of useor the safety function of the childrestraint. Any add-on that is to be usedand is a functional part of the restraintor related to correct use of the restraintis to be included under the ‘‘allfunctional parts including seat pad orcover attached and ready to use’’category.

NHTSA has chosen to modify thecriteria used to evaluate the feature,‘‘obvious storage pocket for manual.’’ICBC defines ‘‘good’’ as ‘‘easy accesswhen CRS installed in all modes,’’ an‘‘acceptable’’ as ‘‘easy access notaccessible when CRS installed in allmodes,’’ and ‘‘poor’’ as ‘‘none found ornot easy access/storage (incl. Plastictabs).’’ During NHTSA’s evaluation ofthe ICBC criteria using several childrestraints, we found that in some casesthe storage pocket for the instructions

manual was easily accessible in allmodes, however it was difficult to use.In other words, it was difficult to takethe instructions out of the storagepocket and difficult to put them back in.With this difficulty, it is believed that ifconsumers take the instructions out ofthe storage pocket they will not putthem back. Therefore, NHTSA’s plannedcriteria are:—A = Easily accessible when installed

in all modes and manual can beremoved and replaced easily

—B = Easily accessible when installedin all modes but manual cannot beremoved and replaced easily (any useof plastic clips as the sole means ofstoring the instructions will not behigher than ‘‘B’’)

—C = Not accessible when installed inall modes.NHTSA has also modified the criteria

used to evaluate the feature ‘‘owner’smanual easy to find.’’ ICBC defines a‘‘good’’ as ‘‘yes, attached to CRS,’’ an‘‘acceptable’’ as ‘‘in box,’’ and a ‘‘poor’’as ‘‘no.’’ NHTSA regulations alsorequire written instructions; thereforeno child restraint manufactured for salein the United States should receive a‘‘poor’’ under the ICBC program.However, when evaluating the ICBCsystem, both infant restraints weevaluated had the written instructionsattached between the restraint and thedetachable base. This forces theconsumer to learn how to release thebase from the infant restraint withoutthe assistance of instructions. NHTSAfelt that a rating should distinguishbetween written instructions attached sothat they were clearly visible as therestraint was removed from the box(many had them in a plastic bagattached to the harness) and thosewhere you had to search for the writteninstructions. NHTSA also believes thatany form of attachment is preferable tohaving the instructions loose in the box,and therefore has moved the ‘‘in box’’criteria to ‘‘C.’’ 20 While NHTSA did notfind any restraints that would havereceived a ‘‘C,’’ NHTSA is concernedthat if the instructions were loose theycould be lost before purchase if the boxwere damaged or opened for inspection.NHTSA’s planned criteria are:—A = attached to child restraint in a

clearly visible location—B = attached to child restraint but not

clearly visible—C = in box, not attached



21 Docket Number: NHTSA–2001–10916.

b. Evaluation of Labels/Instructions

NHTSA has decided to evaluate thefollowing features in the ‘‘Evaluation ofLabels/Instructions’’ category:—Clear indication of child’s size range—All mode/s of use clearly indicated

e.g., rear-facing only or forward- andrear-facing if convertible

—Air bag warning in writteninstructions

—Shows harness slots okay to use foroccupant size

—Instructions for routing for both lapbelt and lap/shoulder belt in allmodes

—Visibility of seat belt routing—Visibility of tether use—Information in written instructions

and on labels match—Durability of labels

Beyond combining two of ICBC’scategories, NHTSA has deleted thefeature ‘‘is airbag warning visible nomatter where CRS is installed.’’ NHTSArequires an air bag warning label onrear-facing child restraints in a locationthat would receive a ‘‘good’’ under theICBC program. Therefore, NHTSA feelsthis feature can be deleted. NHTSA isretaining the feature ‘‘air bag warning inwritten instructions’’ as NHTSA found agreat variety in written instructions withregard to the visibility of this importantinformation.

NHTSA has added ‘‘information onwritten instructions and on labelsmatch’’ as a separate feature. WhileNHTSA did not encounter any childrestraint during its exercise that haddifferent information on the labels thanin the written instructions, therepresentative from ICBC indicated thatthey find this commonly. For example,the height or weight ranges may bedifferent between the two sources ofinformation. While NHTSA suspectsthis results because written instructionsare printed in a large quantity andtherefore not updated as frequently aslabels, it could be very confusing toconsumers. Therefore, NHTSA felt itdeserved a separate category.

NHTSA has also added a feature‘‘durability of labels.’’ NHTSA hasreceived complaints about labels fadingand peeling. When evaluating the ICBCprogram, NHTSA found two childrestraints with one or more labelsalready beginning to peel as they wereremoved from the box. In a recentlypublished Notice for Proposed RuleMaking (NPRM) on child restraintlabels, NHTSA did not propose adurability requirement.21 However, webelieve that adding this feature to theratings will encourage manufacturers to

improve label durability. To achieve an‘‘A’’ rating, all of the labels would haveto use a technology such as molding orheat embossing. Sticky labels wouldreceive a ‘‘B’’ rating unless any of thelabels had already started to peel whenthe restraint was removed from the box.In the later case, the restraint willreceive a ‘‘C’’ rating.

Under ICBC’s program, almost alllabels receive a poor for many of thefeatures unless the label is on both sidesof the restraint. NHTSA has receivedcomments on labeling upgradesrequesting us to keep in mind thelimited space on child restraints.Providing a rating on whether restraintshave labels on both sides will encouragemanufacturers to place labels on bothsides, resulting in using the limitedspace on the restraint for additionallabels. NHTSA is considering modifyingthe ratings to allow for an ‘‘A’’ rating ifthe label meets the specified criteria andis on one side of the restraint. To thisend, child restraints would not receivea ‘‘C’’ rating if the label was only on oneside of the restraint. Encouragingmanufacturers to make instructionsmore accessible, easier to use, andclearer, should provide a justifiablesolution instead of encouraging labelson both sides of the child restraint.

c. Securing the Child

NHTSA has tentatively decided toevaluate the following features found inthe ICBC ‘‘Securing the Child’’ category:—Buckle can be secured in reverse

(harness strap buckle)—Harness adjustment easy to tighten

and loosen when child restraintinstalled

—Number of harness slots/usable slots—Ease of attaching/removing base—Ease of conversion rear-facing to

forward-facing or forward-facing tobooster and back again

—Visibility of harness slots—Ease of changing harness slot position—Ease of reassembly if pad/cover

removed for cleaning—Ease of adjusting/removing shield

In addition to combining the twocategories, the agency will slightlymodify the rating criteria for two of thefeatures. First, under ‘‘buckle can besecured in reverse,’’ (referring to theharness strap crotch buckle which onmost child restraints has a red squarebuckle release) a ‘‘good’’ rating by ICBCis a ‘‘no,’’ an ‘‘acceptable’’ rating is ‘‘yes,but usual release works,’’ and a ‘‘poor’’rating is ‘‘yes & difficult to release/access.’’ NHTSA has modified the ratingto the following: an ‘‘A’’ rating is ‘‘no,or yes but usual release works withsame degree of effort,’’ a ‘‘B’’ rating is

‘‘yes, but usual release requires moreeffort,’’ a ‘‘C’’ rating is ‘‘yes, but can’tuse release mechanism.’’ The safetyconcern with being able to reverse abuckle is that during an emergency aparent may be unable to release themechanism and remove the child fromthe seat. NHTSA has tentatively chosento modify this rating based on ouropinion that if reversing the buckle didnot make the release more difficult touse, there is not a safety concern.Further, NHTSA thought that reversingthe buckle might provide a benefit forchildren who may have learned tounbuckle the release mechanism. Withthe buckle reversed, the child would beless likely to unbuckle him or herself.

The other modification is the ratingcriteria for the feature ‘‘ease of changingharness slot position.’’ Under the ICBCprogram a ‘‘good’’ rating is ‘‘easy toattach/remove; clear slots easy to thread;easy to attach to hardware,’’ an‘‘acceptable’’ rating is ‘‘possible for oneperson to do; slots may be misaligned/pad in way/in slots; hardware slotshared,’’ and a ‘‘poor’’ rating is ‘‘other,slot size too small for easy threading;loose mandatory pieces; could misroutethrough buckle.’’ Under the NHTSAprogram an ‘‘A’’ rating is ‘‘no need torethread; possible for one person to do,’’a ‘‘B’’ rating is ‘‘possible for one personto do, easy to attach/remove; large slotseasy to thread,’’ and a ‘‘C’’ rating is thesame as that used by ICBC. The reasonNHTSA is proposing to make a changeto the evaluation criteria is that we’veobserved that no matter how easy itseems to rethread, some people willrethread the harness wrong.

d. Installation in Vehicle

NHTSA has decided to evaluate thefollowing features in the ‘‘Installation inVehicle’’ category:—Separation of vehicle belt path—Ease of vehicle belt routing (hand

clearance)—Ease of seat belt routing (boosters)—Ease of use of any belt-positioning

hardware on CRS including lock-off—Tether easy to tighten and release—Belt-positioning device allowing slack

to occurNHTSA is considering adding a

feature, ‘‘Ease of tightening belt aroundCRS.’’ Based on experience withinstalling child restraints we have foundsome features on child restraints,specifically on infant seat bases, thatmade tightening of the vehicle beltsystem difficult, or that resulted in thetilting of the infant seat base to one sideupon tightening of the vehicle’s lap andshoulder belt through the infant seatbase, resulting in an improperly secured



22 Working group TC22/SC12/WG1, ‘‘ChildRestraint Systems,’’ to the InternationalOrganization for Standardization (ISO), aworldwide voluntary federation of ISO memberbodies, is considering developing an ease of useusability rating system for child restraint systems.The group has based its preliminary work on therating system of ICBC, which is similar to NHTSA’swork thus far.

child restraint. Therefore, we feel thereis a need to consider this aspect ofinstallation. NHTSA would need todevelop evaluation criteria on whatfeatures of a child restraint wouldreceive an ‘‘A,’’ ‘‘B,’’ or ‘‘C’’ rating underthis category. NHTSA is soliciting viewsand comments on this consideration.

3. Weighting the Features

The ICBC program ranks each featurewithin each category based upon thelevel of importance. These rankingswere determined by the child restraintusability task force of ISO/TC22/SC12/WG1 (Child Restraints) 22 at a meeting inBritish Columbia. Each ease of usefeature is rated as an A, B, or Caccording to risk of injury and severityof misuse. Component features thatcould be associated with a high risk ofinjury if misused are to be rated ‘‘A’’.Each ranking is assigned a numericalscale where A = 3 points, B = 2 points,and C = 1 point. The ratings aresimilarly assigned a numerical scalewhere good = 3 points, acceptable = 2points, and poor = 1 point. Todetermine the rating for a category, thenumerical value of the rating for eachfeature is multiplied by the numericalvalue of that feature’s ranking. Themaximum possible score is then dividedinto thirds to determine the point rangesfor the category rating.

This notice is proposing a slightlymodified version of this scheme.Whereas we agree with the ICBC relativeratings for the component elements, wedo not believe that enough is known toassign weights to the four categories interms of importance. The discussion onthe overall summary rating in Section 8elaborates on this choice. The NHTSAproposed approach is as follows:

Each component feature is assigned anumerical scale of 1–3 points, withfeatures having the highest relationshipto safety receiving 3 points. The ratingsare similarly assigned a numerical scalewhere A = 3 points, B = 2 points, andC = 1 point. To determine the rating fora category, the numerical value of therating for each feature is multiplied bythe numerical value of that feature’sranking. Point ranges for A, B, and C aredetermined through a 3-part split of therange of possible points for that factor,from the minimum (if all scores werecoded ‘‘C’’) to the maximum (if all

scores were coded ‘‘A’’) number ofpoints. Appendix B and Appendix Cdisplays this scheme, with ahypothetical example seat rated.

NHTSA proposes to keep the sameranking as ICBC uses for the componentfeatures it has retained. For the four newfeatures that we have added, we haveassigned them a 2-point ranking. Whilewe believe these features are importantenough to add them to the ratingsystem, their proposed lower rankingreflects the fact that ICBC chose not toinclude them.

4. Ease of Use Rating ProtocolICBC uses two 2-person teams to

evaluate each child restraint. Prior tothe evaluation, the teams have a day oftraining. ICBC has found that, while therating for some features may varybetween the teams, the overall rating forthe category tends to be the same. To theextent that the teams end up with adifferent rating for a category, theyjointly reexamine the child restraintbefore a rating is determined. Childrestraints are installed in a bench seat ofa generic minivan for purposes of theevaluation.

NHTSA found that the ratings of thetwo teams we used in our evaluationalso matched. Therefore, we areplanning to use the same protocol forrating child restraints for ease of use.

During the evaluation, the teamswould install the child restraint in thecurrent FMVSS No. 213 bench. If andwhen the FMVSS No. 213 bench isupdated, the team will use the updatedtest bench. No dummy will be usedduring this process.

5. Overall Ease of Use RatingMarket research in recent years has

shown that most consumers prefersummary ratings or information becausethey find it quicker and easier to readand understand. At the same time, acertain significant percentage ofconsumers also like detailedinformation that is presented inhierarchical fashion, with the moregeneral information presented initially.NHTSA is planning to combine theplanned child restraint ease of useratings into a summary ease of userating. While NHTSA notes that it doesnot have clear information about howorganizations that currently provide asummary rating determine that rating,study of the ICBC model has led to theconclusion that it is reasonable to applya modified version of their model. Thenotable exception is that NHTSA doesnot believe it is possible to weight theimportance of the four overallcategories. As a result, a straightcombination numerical rating is not

proposed. If all of the individual scoreswere added to one overall numericalscore, the factors containing morecomponent elements would carry moreweight. Therefore, the proposal for thecombined rating is majority rule for thefour categories, with two qualifiers. Thetwo qualifiers are that a seat cannotreceive a B rating if more than 1 out of4 categories is a C and, correspondingly,a seat cannot receive an A rating if morethat 1 out of 4 categories is rated otherthan A. In the example in Appendix C,the seat received a high number of Cratings in important components,thereby resulting in 2 out of 4 categoriesbeing rated C. Application of thequalifier gives it a C rating.

V. Discussion and CRS Rating SystemProposal

The agency has not made a finaldetermination on which of the fourrating systems (three dynamic plus easeof use), or combination of those ratingsystems, would be most appropriate andresponsive to the Congressionalmandate of TREAD. However, we havetentatively concluded that the mosteffective consumer information systemis one that gives the consumer acombination of information about childrestraints’ ease of use and dynamicperformance, with the dynamicperformance obtained through higher-speed sled testing and/or in-vehicleNCAP testing.

Section 14(g) of TREAD set forth therequirement to establish a CRS ratingconsumer information program. Othersections of TREAD mention providing‘‘consumer information on the physicalcompatibility of child restraints andvehicle seats on a model-by-modelbasis’’ [14(b)(4)] and ‘‘whether toinclude child restraints in each vehiclecrash tested under the New CarAssessment Program’’ [14(b)(9)]. Fromthis, the agency has tentativelyconcluded that a rating program thatrates the CRS and/or the vehicle wouldsatisfy the Congressional mandate.

Table 1 shows six factors that werefelt to be of primary importance indetermining an appropriate CRS ratingsystem. From this table, it is clear thata single rating alternative does notachieve all of the six objectives. Ease ofuse is the only option that potentiallyaddresses misuse, and thus the agencyfeels that such a rating option couldhave a substantial impact on proper CRSuse. However, an Ease of Use ratingwould not provide information ondynamic performance. Given theadvantages and disadvantages regardingthe various dynamic performance ratingoptions described in the precedingsections, the agency has tentatively



concluded that higher-speed sled testsand/or in-vehicle NCAP testing wouldbe preferable methods for providingdynamic performance information.Comments on which dynamic ratingoption, individually or in conjunctionwith the Ease of use rating, wouldprovide the most useful information tothe consumer as well as improve overallchild safety are requested. Commentsare also requested on whether or not theagency should consider conducting bothhigher-speed sled tests and in-vehicleNCAP testing in conjunction with theEase of use rating. If, in addition to theEase of use rating, the agency were toprovide both a higher-speed sled testrating for the child seat, and an in-vehicle NCAP rating of child occupantprotection for the vehicle, would suchinformation be meaningful for theconsumer and worth the costs ofadministering the tests given the relativeadvantages and disadvantages of each?Also, if the agency were to implementan in-vehicle NCAP rating system, whatchild seat(s) should be used? Should theagency select child seat(s) from thosespecified in FMVSS No. 208? If so,should a procedure be based upon onlyone of these seats to standardize thechild seat for all vehicles? If only onechild seat is selected, what criteriashould the agency use in selecting thatseat? If not, is the protocol providedbelow preferable?

Possible Assessment Protocol forHigher-speed Sled Tests

The following assessment protocol fortesting and rating a child restraint in ahigher-speed sled test is proposed if thisdynamic procedure is selected.—The agency would select child

restraints for higher-speed sled testsso that most of the forward-facingchild restraint models sold in theUnited States would undergo thehigher-speed sled test for theevaluation of child restraints.

—Forward-facing child restraints wouldbe placed on the same seat used forthe compliance test. The restraintwould be secured to the using theLATCH system. Installationinstructions prescribed by themanufacturer of the child restraintwould be followed.

—Hybrid III three-year-old and/or 12month CRABI dummies would beplaced in the child restraint forassessing injury. Dummy selectionwould depend upon the weight ratingof the CRS. Child restraints designedfor weight classifications coveringboth dummies would be tested withboth and provided two rating. Headand chest accelerations would berecorded. The injury assessment

reference values developed for childdummies in FMVSS No. 208 would becalculated.

—A five star rating would be applied tothe dynamic performance using theHIC and chest acceleration tocompute probability of injury as wasillustrated in Figure 7.

—Child restraints would also beexamined for structural integrity afterthe test. The physical structuralintegrity evaluation specified in theFMVSS No. 213 procedure would beapplied.

—A rating for the CRS would be madeavailable to the public in a mannersimilar to that now employed forother NCAP vehicle results.

Possible Assessment Protocol for NCAPFrontal Vehicle Testing

The following assessment protocol fortesting and rating vehicles with childrestraints for in-vehicle NCAP isproposed if this dynamic procedure isselected.—After the agency has selected the

vehicles for frontal NCAP testing,each vehicle manufacturer would beasked for a recommendation of at leastthree forward-facing child restraintsfor children up to a weight of 50pounds for each vehicle to be tested.At least one of the vehiclemanufacturer-recommended childrestraints must have a retail price ofless than $60. A different CRSmanufacturer must make each of thethree restraints. An integrated childrestraint may be one of therecommended child restraints. Eachof the three recommended childrestraints must be currently availablein the market. If the vehiclemanufacturer chose not to make arecommendation, then the agencywould choose from any child restraintavailable in the market.

—One of the three vehiclemanufacturer-recommended childrestraints would be selected for use inthe crash test. A procedure that usesthe child restraint in the LATCHconfiguration would be followed. Theagency would follow both the vehicleand child restraint manufacturers’recommendations for installing thechild restraint in the passengervehicle. Our expectation is that thevehicle manufacturer’s set-upinstructions would be consistent withthe installation instructions for thechild restraint.

—A forward-facing child restraintwould be placed in the seat directlybehind the right front passenger, i.e.,on the right-hand side of the secondrow of seats. A 3-year-old Hybrid IIIdummy would be placed in the child

restraint system. Head and chestaccelerations would be recorded. Theinjury assessment reference valuesdeveloped for child dummies inFMVSS No. 208 would be calculated.If the vehicle is equipped with a builtin child seat, testing could beconducted with either or both thebuilt in and add on child restraints.

—A five star rating would be applied tothe dynamic performance using theHIC and chest acceleration tocompute probability of injury as wasillustrated in Figure 7.

—Child restraints would also beexamined for structural integrity afterthe test. The physical structuralintegrity evaluation specified in theFMVSS No. 213 procedure would beapplied.

—A rating for child protection would beadded to the vehicle frontal NCAPratings. In the process of developingthe proposed rating system, theagency made several decisions.These decisions and our rationale for

making them are the following:1. For in-vehicle testing, only frontal

NCAP tests are being proposed. Childrestraints are not currently compliance-tested under lateral loading conditions.Although lateral test requirements forCRS are being proposed in an upgradeto FMVSS No. 213 under a separateTREAD rulemaking action, the agencyfelt that the issue of a possible lateralrating should be considered followingcompletion of the FMVSS No. 213upgrade.

2. The in-vehicle proposed protocolrates only one CRS in the rear seat. Dueto the very tight schedule available forconducting and assessing potential CRSNCAP protocol, the agency elected toconcentrate on forward-facing childrestraints rather than attempt to alsoinclude rear-facing child restraints and/or booster seats. The decision toconcentrate on the forward-facing CRSwas based on the belief that the forward-facing CRS would provide the mostmeaningful information to theconsumer, given that development ofprocedures for all three systems couldnot be accomplished in the short timeframe. Following incorporation of theforward-facing CRS, the feasibility ofincorporating a rating which includedrear-facing CRS and/or booster seatswould subsequently be considered.

3. The in-vehicle proposed rating usesonly the three-year-old dummy. Again,due to the very tight schedule, theagency felt it necessary to collect asmuch data as possible for one dummyand that the three-year-old wouldprovide the most meaningfulinformation for the consumer. Upon



incorporation of a child restraint systemrating with the three-year-old dummy,consideration would subsequently begiven to dummies of other sizes.

4. Higher-speed testing which wasconducted by the agency used onlyHybrid III three-year-old dummies.However, if the higher-speed dynamicperformance is selected, utilization ofboth twelve month CRABI and HybridIII three year old dummies would beproposed.

Comments on these decisions and theagency’s rationale for them arerequested. Also, comments regardingpossible future extension of the CRSNCAP rating to side impact, other typesof CRS, and dummy size are also sought.

VI. Combined Child Restraint Rating

NHTSA is not currently planning todo an overall summary rating combiningease of use and dynamic performance.To date, we have not been able todevelop an acceptable methodology fora summary rating. However, we requestcomments and suggestions on this issue.

VII. Distribution

NHTSA currently produces a printbrochure titled Buying a Safer Car thatprovides NCAP ratings and safetyfeature information for new vehicles.Because new motor vehicles arecommonly introduced in the fall,NHTSA produces the first printing foreach model year in the fall. BecauseNCAP testing cannot begin until thevehicles are available from dealers, thisprinting only has test results forvehicles which were tested in previousmodel years and which have notchanged significantly. A second printingis produced in the spring after thecompletion of the NCAP testingprogram.

NHTSA also publishes an annualbrochure titled Buying a Safer Car forChild Passengers. This brochureprovides new vehicle safety features andother information relevant to children.The brochure identifies vehicles thathave built-in child seats, manual air bagcut-off switches, rear center rear seatlap/shoulder belts, rear-seat adjustableupper belts, and interior trunk releases.

If NHTSA were to elect to have arating based solely on a vehicleequipped with a child restraint, theexisting brochures would be anappropriate venue for the distribution ofthe ratings. If NHTSA chooses another

rating system, we believe new printedinformation about child restraint ratingswill be needed. The current brochuresare a helpful model for new printinformation about child restraintratings. However, unlike vehicles, childrestraint models do not tend to changeon an annual cycle. Therefore, NHTSAwould have to pick a date and onlyinclude in a print brochure childrestraints that are available in themarketplace at that time.Representatives from ICBC haveindicated that the largest concentrationof new child restraint introductionsseems to occur in Canada in the monthsof May and June. To assist us in timinga print brochure, NHTSA requestscomments on whether this timing is alsoaccurate for the United States.

NHTSA notes that a print brochurecould be used in addition to our website. Unlike printing, this site can beupdated on a continuous basis.Therefore, NHTSA could test childrestraints as they became available andadd new models to the web site whentesting was complete.

VIII. Submission of Comments

How Do I Prepare and SubmitComments?

Your comments must be written andin English. To ensure that yourcomments are correctly filed in theDocket, please include the docketnumber of this document in yourcomments.

Your comments must not be morethan 15 pages long. (49 CFR 553.21). Weestablished this limit to encourage youto write your primary comments in aconcise fashion. However, you mayattach necessary additional documentsto your comments. There is no limit onthe length of the attachments.

Please submit two copies of yourcomments, including the attachments,to Docket Management at the addressgiven above under ADDRESSES.

How Can I Be Sure That My CommentsWere Received?

If you wish Docket Management tonotify you upon its receipt of yourcomments, enclose a self-addressed,stamped postcard in the envelopecontaining your comments. Uponreceiving your comments, DocketManagement will return the postcard bymail.

How Do I Submit Confidential BusinessInformation?

If you wish to submit any informationunder a claim of confidentiality, youshould submit three copies of yourcomplete submission, including theinformation you claim to be confidentialbusiness information, to the ChiefCounsel, NHTSA, at the address givenabove under FOR FURTHER INFORMATIONCONTACT. In addition, you shouldsubmit two copies, from which youhave deleted the claimed confidentialbusiness information, to DocketManagement at the address given aboveunder ADDRESSES. When you send acomment containing informationclaimed to be confidential businessinformation, you should include a coverletter setting forth the informationspecified in our confidential businessinformation regulation. (49 CFR Part512.)

Will the Agency Consider LateComments?

We will consider all comments thatDocket Management receives before theclose of business on the commentclosing date indicated above underDATES. To the extent possible, we willalso consider comments that DocketManagement receives after that date.

How Can I Read the CommentsSubmitted by Other People?

You may read the comments receivedby Docket Management at the addressgiven above under ADDRESSES. Thehours of the Docket are indicated abovein the same location.

You may also see the comments onthe Internet. To read the comments onthe Internet, take the following steps:I. Go to the Docket Management System

(DMS) Web page of the Departmentof Transportation (http://dms.dot.gov/).

II. On that page, click on ‘‘search.’’III. On the next page (http://

dms.dot.gov/search/), type in thefour-digit docket number shown atthe beginning of this document.Example: If the docket number were‘‘NHTSA–1999–1234,’’ you wouldtype ‘‘1234.’’ After typing thedocket number, click on ‘‘search.’’

IV. On the next page, which containsdocket summary information for thedocket you selected, click on thedesired comments.



You may download the comments.However, since the comments areimaged documents, instead of wordprocessing documents, the downloadedcomments are not word searchable.

Please note that even after thecomment closing date, we will continueto file relevant information in the

Docket as it becomes available. Further,some people may submit late comments.Accordingly, we recommend that youperiodically check the Docket for newmaterial.

Authority: 49 U.S.C. 322, 30111, 30115,30117, 30166, and Pub.L. 106–414, 114 Stat.1800; delegation of authority at 49 CFR 1.50.

Issued on: October 29, 2001.Stephen R. Kratzke,Associate Administrator for SafetyPerformance Standards.BILLING CODE: 4910–59–P

































































[FR Doc. 01–27547 Filed 10–31–01; 9:55 am]BILLING CODE 4910–59–C


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56146 Federal Register /Vol. 66, No. 215/Tuesday, November ...56146 Federal Register/Vol. 66, No. 215/Tuesday, November 6, 2001/Notices turning a corner, or parking, loss of power