This Preliminary Regulatory Evaluation analyzes the potential impact of new performance requirements for child restraint systems in frontal crashes. This rulemaking is in response to the Transportation Recall Enhancement, Accountability, and Documentation (TREAD) Act, Public Law 106-414 to improve child restraint systems in frontal crashes.


    The agency proposes (1) to use new dummies including a 12-month-old CRABI and a Hybrid III 3-year-old, a 6-year old, and a weighted 6-year-old in the compliance test, (2) to extend FMVSS 208 scaled child injury criteria, with a modification in the neck injury criteria, to FVMSS 213, and (3) to use a real-world representative child safety seat and crash pulse in the compliance test.

    Test Results

    The agency has conducted several child restraint system (CRS) tests with the proposed dummies under the current the FMVSS 213 crash environment. Four out of five rear-facing CRS and all 5 forward-facing CRS tests with the 12-month-old CRABI dummy failed the proposed neck requirement. One out of five CRS tests with a 3-year-old dummy failed the proposed neck requirement. Of the booster seat tests, 4 of 11 tests with the 6-year-old dummy and 1 out of 3 tests with the weighted 6-year-old dummy also failed the neck criterion. Some of the child restraints also failed the proposed head and chest injury criteria. Those that passed the neck criterion had a minimal or no compliance margin.

    No tests have been conducted under the proposed seat assembly and crash pulse environment. But, the agency believes these changes would not impact the crash test outcome.

    Technical Feasibility

    The proposed standard appears technically feasible for older children because some of the tested seats passed the proposed injury criteria for 3-year-old and weighted 6-year-old dummies (although, with minimal or no compliance margins). However, the agency has not yet identified any particular design alternatives that would increase compliance margins for those that passed. No system has yet been tested that will pass the proposed requirement for forward-facing CRABI dummy tests. The feasibility of this test is thus uncertain. The CRS manufacturers are not currently required to design their CRSs to neck injury. It is possible that the proposed neck injury requirement might be too stringent for the FMVSS 213 environment.


    The proposal would prevent an estimated 4-6 fatalities and reduce 6 MAIS 2-5 non-fatal injuries. In the 0-1 age groups, the benefits are an estimated 3-5 fatalities and a reduction of 5 MAIS 2-5 non-fatal injuries in a forward-facing CRS. In addition, the proposal would save one fatality and mitigate one MAIS 2-5 injury in the 4-6 years old group. Estimated benefits for other age groups of children rounded down to 0. The estimated benefits reflect a low CRS use by older children in fatal and MAIS 2-5 frontal crashes. The benefits would be higher if more children were restrained in a CRS. There are no estimated benefits from the proposed seat assembly and crash pulse changes.


    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 cannot estimate the costs of those countermeasures. The proposal will specify the use of new dummies in compliance tests, including testing with a weighted 6-year-old dummy, so manufacturers' testing costs would increase. The new dummy and added testing costs are estimated to be $2.72 million.

    Lead Time

    Assuming that the agency issues a final rule on this proposal in October 2002, the agency proposes two years of leadtime. A longer leadtime might be needed to attain neck measurement values to pass the proposed criteria.