CHAPTER VI. COST AND LEAD TIME




In order to comply with the proposed upgrade of FMVSS 213, manufacturers will incur costs to redesign and test their child restraint systems. Because the proposed new standards include a broader range of test dummies, additional dummies have to be purchased by manufacturers. This chapter discusses these changes and added testing costs.




A. Child Restraint Costs

At this time the agency has not identified countermeasures to improve child restraints in frontal tests that would allow them to meet the proposed criteria. Thus, the agency can not estimate the costs of those countermeasures. It appears that most child restraints will not meet the proposal for the 12-month-old dummy, or for the 6-year-old dummy, or if they meet the proposal it is with a minimal or no margin of compliance. Although it is apparent that most systems will require some type of redesign, the agency does not currently have information as to how manufacturers could redesign their CRSs to comply with the proposed standards. The agency is seeking comment on how such systems could be redesigned and how much the changes would increase the price of CRSs.




B. Compliance Test Costs

The section discusses the estimated costs for a vehicle or manufacturer to perform compliance tests. Costs are in 2001 dollars.

Sled Test

Based on current experience with sled tests currently carried out by NHTSA's enforcement program, the cost of a sled test is estimated to be about $1,300.

Dummy Costs

Table VI-1 lists the cost estimates for proposed child dummies (Hybrid III) and those used in the current FMVSS 213 (Hybrid II). The dummy cost estimates for the proposal would be those with the minimum instrumentation. These estimates were based on the commercial prices of various available child dummies.

Table VI-1
Costs of Child Dummies
(2001 Dollars)

** Currently specified dummies for CRS certification

Testing Costs by Dummy Size

Table VI-2 lists the costs of proposed compliance tests. The increment test costs of updating the current FMVSS 213 to the proposal is listed in Table VI-3. The new proposal does not require extra tests for CRSs that were designed to hold a child up to 50 pounds. Thus, costs for testing these types of CRS is estimated to be the costs of new dummies. For booster seats, however, there is an extra test using the weighted 6-year-old dummy. The increment dummy cost is the total cost of the new dummies since new dummies must be purchased for testing.

Table VI-2
Costs of Proposed Compliance Tests
(2001 Dollars)

Table VI-3
Incremental Costs of Upgrading FMVSS 213
(2001 Dollars)

C. Total Cost of the Amendment

The total cost of the amendment would be the sum of three type of costs: (1) the total costs of the manufacturers have to spend to improve the CRS, (2) the total dummy costs that CRS manufacturers have to purchase for testing, and (3) the total costs of sled tests that CRS manufacturers have to conduct to meet the proposal.

Costs of CRS

As stated earlier, the agency has not yet been able to identify the countermeasures, thus, the analysis does not estimate the total redesign costs of CRS.

Total Dummy Costs

NHTSA estimates there are 10 manufacturers of portable child restraints. Three of these companies have a total of 10 or fewer employees. The proposal requires a new set of dummies be used in the compliance tests. The analysis assumes that all of these manufacturers, except the three companies with 10 or fewer employees, would purchase all of the proposed four dummies - a 12-month-CRABI, a 3-year-old, a 6-year-old, and a weighted 6-year-old. A set of 4 proposed dummies cost about $207,300 (= $30,000 + $61,700 + $57,800 + $57,800). The total dummy costs for these seven manufacturers are estimated to be $1.45 million. The rest of three companies are assumed to employ other fully equipped facilities to conduct the tests.

Total Sled Test Costs

The number of tests required would depend on the type of CRS models. The analysis uses the agency's 1998-2000 certification tests to estimate the annual number of production CRS models in the current market. Excluding the discontinuous ones, there are about 31 infant seat models, 57 convertible seat models, 33 booster seat models, and 2 infant/convertible/booster combined seat models. Each infant seat and booster seat is required to pass two sled tests to be certified. Each of the convertible seats is required to pass a total of 12 sled tests to be certified. However, this analysis assumes the CRS manufacturers would only conduct about 6 tests for the convertible seats. Thus, the CRS manufacturers of the infant/convertible/booster seat models would conduct 10 sled tests for each of the models. In total, the CRS manufacturers would conduct an estimated 490 sled tests. Each test costs $1,300. The total sled costs would cost an estimated $63,700 (= $1,300 * 490). Table IV-4 lists the number of sled tests by CRS model types.

Table IV-4
Costs of the Sled Tests

The estimated total cost of the sled tests is only the costs for the initial number of the tests that the CRS manufacturers have to conduct. The cost estimate does not include the costs for the additional tests that the CRS manufacturers would conduct to improve the failed CRSs. The analysis assumes that each model will tested 4 times on average and that 2 child restraint systems can be put on each sled. The total cost is $1,274,000

Total Cost of the Amendment

The cost of CRS is not estimated due to unidentified countermeasures, thus, the total cost of the amendment estimated here is only the sum of the cost of dummies and cost of the sled tests. The total amount is estimated to be $2.72 (= $1.45 + $1.27) million.




D. Leadtime

TREAD requires the agency to complete this rulemaking by November 1, 2002. Assuming that the agency issues a final rule on this proposal in October 2002, the agency proposes two years of leadtime after publication of a final rule before requiring the new dummies and proposed injury criteria and performance limits. The new dummies include a 12-month-old CRABI, a Hybrid III 3-year-old, a Hybrid III 6-year-old, and a Hybrid III weighted 6-year-old.

A majority of the child restraints tested with the 12-month-old CRABI and the 6-year-old dummies failed the proposed neck injury criteria. Those that passed had a small or no compliance margin. The agency has not yet identified any countermeasures. Therefore, a longer leadtime might be needed. The agency requests comments on how much leadtime would be adequate.