[Federal Register: November 6, 2001 (Volume 66, Number 215)]
[Notices]               
[Page 56146-56191]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr06no01-113]                         

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DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

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

 
Safety Rating Program for Child Restraint Systems

AGENCY: National Highway Traffic Safety Administration (NHTSA), DOT.

ACTION: Notice, request for comments.

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SUMMARY: Section 14(g) of the Transportation Recall Enhancement, 
Accountability, and Documentation (TREAD) Act requires that, by 
November 2001, a notice be issued to establish a child restraint safety 
rating consumer information program to provide practicable, readily 
understandable, and timely information to consumers for use in making 
informed decisions in the purchase of child restraint systems (CRS).
    In response to this mandate, NHTSA has reviewed existing rating 
systems that other countries and organizations have developed, and 
conducted its own performance testing to explore a possible rating 
system for child restraints. The agency has tentatively concluded that 
the most effective consumer information system is one that gives the 
consumer a combination of information about child restraints' ease of 
use and dynamic performance, with the dynamic performance obtained 
through higher-speed sled testing and/or in-vehicle NCAP testing. The 
agency is also giving consideration to conducting both higher-speed 
sled tests and in-vehicle NCAP testing in conjunction with the Ease of 
use rating. This document provides a review of the information and 
reasoning used by the agency to reach that conclusion, describes the 
rating systems planned to meet the TREAD requirements, and seeks 
comment on this plan.

DATES: You should submit your comments early enough to ensure that 
Docket Management receives them not later than Janaury 7, 2002.

ADDRESSES: You should mention the docket number of this document in 
your comments and submit your comments in writing to: Docket 
Management, Room PL-401, 400 Seventh Street, SW., Washington, DC, 
20590.
    You may call Docket Management at 202-366-9324. You may visit the 
Docket from 10 a.m. to 5 p.m., Monday through Friday.

FOR FURTHER INFORMATION CONTACT: For issues related to a performance 
rating, you may call Brian Park of the New Car Assessment Program (NPS-
10) at 202-366-6012.
    For issues related to a compatibility/ease of use rating, you may 
call Lori Miller of the Office of Traffic Safety Programs (NTS-12) at 
202-366-9835.
    You may send mail to both officials at National Highway Traffic 
Safety Administration, 400 Seventh St., SW., Washington, DC, 20590.

SUPPLEMENTARY INFORMATION:

I. Overview
II. 2000 Public Meeting and Draft Child Restraint Systems Safety 
Plan
    A. 2000 Public Meeting
    B. 2000 Child Restraint Systems Safety Plan
    C. Public Comments About Child Restraint Ratings
III. CRS Dynamic Performance Rating Programs
    A. Existing Programs for Rating Dynamic Performance of CRS
    1. Consumer's Union
    2. Japanese NCAP
    3. Australian CREP
    B. Existing Programs for Rating Dynamic Performance of Vehicles 
Equipped with CRS
    1. Euro NCAP
    2. Australia
    C. CRS Dynamic Testing by IIHS
    D. CRS Dynamic Testing within NHTSA
    1. CRS Performance in FMVSS No. 213 Sled Testing
    a. Advantages
    b. Disadvantages
    2. CRS Performance in Higher-speed Sled Testing
    a. Advantages
    b. Disadvantages
    3. CRS Performance in NCAP Frontal Vehicle Testing
    a. Advantages
    b. Disadvantages
IV. Child Restraint Ease of Use Rating
    A. Child Passenger Safety Selection, Use, and Installation 
Website
    B. Summary of Existing Ratings for Ease of Use
    1. Australia
    2. Consumer's Union
    3. Euro NCAP
    4. ICBC.
    5 Japan
    C. Planned Child Restraint Ease of Use Rating System
    1. Assessment of Existing CRS Ease of Use Rating Systems
    2. Four Rating Categories
    a. Ready to Use
    b. Evaluation of Labels/Instructions
    c. Securing the Child
    d. Installation in Vehicle
    3. Weighting the Features
    4. Ease of Use Rating Protocol
    5. Overall Ease of Use Rating
V. Discussion and CRS Rating System Proposal
VI. Combined Child Restraint Rating
VII. Distribution
VIII. Submission of Comments
Figures
Table
Appendices
    Appendix A
    Appendix B
    Appendix C
    Appendix D

I. Overview

    Congress has directed the National Highway Traffic Safety 
Administration (NHTSA) to develop a child restraint safety rating 
system that is practicable and understandable (Section 14 (g) of the 
Transportation Recall Enhancement, Accountability, and Documentation 
(TREAD) Act, November 1, 2000, Pub.L. 106-414, 114 Stat. 1800) and that 
will help consumers to make informed decisions when purchasing child 
restraints. Section 14(g) reads as follows:

    (g) Child restraint safety rating program. No later than 12 
months after the date of the enactment of this Act, the Secretary of 
Transportation shall issue a notice of proposed rulemaking to 
establish a child restraint safety rating consumer information 
program to provide practicable, readily understandable, and timely 
information to consumers for use in making informed decisions in the 
purchase of child restraints. No later than 24 months after the date 
of the enactment of this Act the Secretary shall issue a final rule 
establishing a child restraint

[[Page 56147]]

safety rating program and providing other consumer information which 
the Secretary determines would be useful (to) consumers who purchase 
child restraint systems.

    In response to this mandate, the agency reviewed presentations 
given at a public meeting in February 2000, and comments submitted in 
response to a notice announcing a draft Child Restraint Systems Safety 
Plan. The agency also examined other existing and proposed child 
restraint programs. Four options that emerged were: (1) A rating based 
on Federal Motor Vehicle Safety Standard (FMVSS) No. 213 compliance 
tests (sled tests), (2) a rating based on higher-speed sled testing, 
(3) a rating based on in-vehicle testing, and (4) a rating based on 
ease of use. The agency then further explored each option to determine 
if it would generate information that is practicable, repeatable, and 
appropriate.
    After considering the various options, NHTSA has tentatively 
concluded that the most effective consumer information system is one 
that gives the consumer a combination of information about child 
restraints' ease of use and dynamic performance, with the dynamic 
performance obtained through higher-speed sled testing and/or in-
vehicle NCAP testing. The agency is also giving consideration to 
conducting both higher-speed sled tests and in-vehicle NCAP testing in 
conjunction with the ease of use rating.
    This notice is arranged as follows. First, the notice will discuss 
the February 2000 public meeting and the draft Child Restraint Systems 
Safety Plan, and the comments received from the public. Second, the 
notice will discuss other existing and proposed performance ratings, 
the research NHTSA has done, and NHTSA's current plan for rating child 
restraint performance. Third, the notice will discuss other existing 
and proposed ratings based on compatibility and/or ease of use, and 
NHTSA's current plan for rating child restraint ease of use. Fourth, 
the notice will discuss why NHTSA is not planning a summary rating for 
child restraints. Last, the notice will briefly discuss how NHTSA plans 
to distribute child restraint ratings to the public.

II. 2000 Public Meeting and Draft Child Restraint Systems Safety 
Plan

A. 2000 Public Meeting

    On February 9, 2000, NHTSA conducted a public meeting in 
Washington, DC, to discuss the safety performance of child restraint 
systems and options for giving consumers information on the safety 
performance of different child restraints (65 FR 1224, January 7, 2000, 
Docket No. NHTSA-2000-6628). The announced topics were voluntary 
standards, strategies for enhancing compliance margins, improved 
labeling, and possible ways of rating child restraint performance.

B. 2000 Child Restraint Systems Safety Plan

    On November 27, 2000, NHTSA published a notice requesting comments 
on a draft Child Restraint System Safety Plan (65 FR 70687, Docket No. 
NHTSA-2000-7938). The overall goal of NHTSA's Child Restraint Systems 
Safety Plan was to reduce fatalities and reduce injuries to U.S. 
children aged 0-10 years who are involved in crashes. To realize this 
goal, the plan employed three key strategies: encourage correct use of 
child restraints for all children, ensure that child restraints provide 
optimal protection, and give consumers useful information about 
restraining their child.

C. Public Comments About Child Restraint Ratings

    Several presenters at the public meeting and commenters to the plan 
addressed the idea of a performance rating based on compliance margins. 
The concept of compliance margins is based on Federal Motor Vehicle 
Safety Standard (FMVSS) No. 213, Child Restraint Systems (49 CFR 
571.213). Under this concept, child restraints would be ranked 
according to how large a margin they passed the standard's performance 
criteria. The larger the margin that the child restraint passed the 
standard by, the higher the child restraint would be ranked. A Maryland 
Child Safety Technician suggested the use of compliance tests to 
develop ratings, citing sufficient differences in crash test results. 
However, he voiced concerns whether such a rating system could address 
the issue of vehicle compatibility.
    Other commenters opposed the development of a CRS rating based on 
the compliance margin. Juvenile Products Manufacturers Association, 
Inc. (JPMA) stated that, ``while the current FMVSS No. 213 standard 
provides an exceptional rating system (essentially an easily-understood 
pass-fail), the industry would certainly consider some other type of 
performance rating system.'' However, JPMA noted that with so many 
variables, it is likely that a rating system may have a potentially 
negative effect rather than a positive one. JPMA thought it appropriate 
also to mention that ``the current dynamic standard, FMVSS No. 213, is 
more severe than about 95 percent of all crashes, and the historical 
performance of PROPERLY USED car seats both in testing and in the field 
is exceptional, better even than seat belts.'' \1\ Ford Motor Company 
and other child safety experts suggested that the agency consider 
having a rating system only after revising FMVSS No. 213. They stated 
that the current standard sled pulse is too severe and the test 
protocol is outdated. These commenters recommended that the revised 
standard should reflect the current child passenger environment.\2\
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    \1\ Robert Waller, Jr., Juvenile Products Manufacturers 
Association, Inc., Docket 6628.
    \2\ Comments on Child Restraint System Ratings, Ford Motor 
Company, Docket 7938.
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    Commenters addressed the idea of including child restraints in 
frontal New Car Assessment Program (NCAP) tests. Evenflo supports the 
addition of child restraints to NCAP tests. The company believes that 
because the performance requirements of FMVSS No. 213 are so demanding, 
all child restraints passing such a standard deserve a high rating. 
Evenflo believes that distinguishing safety performance between child 
restraints that pass FMVSS No. 213 is difficult. The company also feels 
that the addition of child restraints to NCAP tests will allow for an 
evaluation of how well the child restraint system works with the 
vehicles.\3\ ARCCA, Inc., favors the incorporation of child restraints 
into NCAP tests. ARCCA stated that, NCAP tests more closely replicate 
real world conditions than the FMVSS No. 213 compliance tests. In 
addition, the incorporation of child restraints into the program would 
maximize its benefits.
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    \3\ Evenflo Company, Inc., Randy Kiser, Docket 7938.
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    Both Partners for Child Passenger Safety \4\ and Graco Children's 
Products \5\ oppose adding child restraint systems to NCAP crash tests. 
These organizations believe that the performance of child restraints in 
NCAP tests may be characteristic of the child restraint, the vehicle, 
or the restraint/vehicle interaction. This poses questions as to the 
significance of the results of such tests. Ford agrees with these 
comments, adding that vehicle/CRS interface factors and various vehicle 
crash pulses obscure the results of child restraint performance in NCAP 
tests.\6\
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    \4\ Partners for Child Passenger Safety, Flaura K. Winston, MD, 
PhD, Dennis R. Durbin, MD, MSCE, Kristy Arbogast, PhD, Shannon D. 
Morris, Docket 7938.
    \5\ Graco Children's Products, Steve Gerhart, David E. Campbell, 
Docket 7938.
    \6\ Comments on Child Restraint System Ratings, Ford Motor 
Company, Docket 7938.
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    Consumers and consumer advocates almost universally expressed the 
opinion that any child restraint rating

[[Page 56148]]

should include factors for compatibility with various vehicles and ease 
of use. These commenters noted that a good performance rating would be 
meaningless if the child restraint was not compatible with the 
consumer's vehicle or was difficult to use properly.
    The Insurance Corporation of British Columbia (ICBC) claimed that 
high misuse rates of child restraints are a common finding. Children 
aged 3 years and older are restrained, most often, only in adult seat 
belts. To compensate for misuse, ICBC recommended that the NHTSA 
establish an ease of use rating.\7\ Evenflo also feels that the most 
problematic area, the area in which improvement would have the greatest 
positive impact, is in the nonuse and misuse of child restraints.\8\ 
The Automotive Coalition for Traffic Safety (ACTS) agreed, and stated 
that the dynamic performance of child restraints should not be a big 
issue. ACTS further suggested, however, that the recent addition of the 
top tether should reduce misuse. The University of North Carolina (UNC) 
Highway Safety Research was also a proponent of an ease of use rating. 
They stated that the crash test performance of child restraints is only 
part of the information that should be incorporated into a rating 
system. Safety Belt Safe concurred, mentioning that even top-rated 
systems are difficult to use. They stated that child restraint ratings 
should be based on real-world conditions and behavior, not solely on 
crash tests. Graco Children's Products, Inc. also asked that a rating 
system be based on more than simply crash performance. They suggested 
that other factors such as labeling and instruction clarity, ease of 
installation and vehicle compatibility, fit of child, and ease of use, 
be included.
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    \7\ Identification and Publication of Relative Performance of 
Different Child Restraint Systems, Insurance Corporation British 
Columbia, Betty Brown, Docket 6628.
    \8\ Evenflo Company Inc., Randy Kiser, Docket Number: 7938.
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    One manufacturer expressed concern about starting an ease of use 
rating system. The manufacturer asked what type of person would do the 
evaluating. This manufacturer believed that it would be a good idea to 
have inexperienced people conduct the evaluation of child restraint 
systems. The manufacturer suggested using the same people gives 
consistency in test methodology. This commenter thought the agency 
might have difficulty getting the same people always. The child 
restraint manufacturers also believed that a rating system would drive 
the child restraint manufacturers to improve their products and provide 
more ease of use features.
    NHTSA met with two manufacturers of child restraints, Britax and 
Evenflo. These two manufacturers both stated that the seats with higher 
cost are the restraints with more advanced features which are likely to 
be ease of use features. Both manufacturers described how a child 
restraint rating system might affect the retail market. They believed 
that the retail buyers would limit their purchases of child restraints 
to those with high ratings. Consequently, the agency might drive the 
retail market to the seats with the higher prices.

III. CRS Dynamic Performance Rating Programs

A. Existing Programs for Rating Dynamic Performance of CRS

1. Consumer's Union
    The July 2001 issue of Consumer Reports was the Consumer's Union's 
most recent report on child restraints.\9\ They gave a rating for the 
dynamic performance of each child restraint, which is part of the 
overall rating given to child restraints. This overall rating is the 
averaged score of dynamic performance, ease of use, installation, and 
stroller use. The installation score is determined by how securely a 
child restraint can be installed in three different cars with different 
seats and safety-belt types. Ease of use evaluates how difficult it is 
to adjust the straps and the harness. A stroller score is also given to 
applicable child restraints. This score is based on the safety, 
convenience, and the durability of the child restraint and stroller. 
The dynamic score was determined from a sled test representing a 30 mph 
(48 km/h) frontal crash. The seats were tested using dummies that 
approximate an infant, 3-year-old toddler, and 6-year-old child. Head 
Injury Criterion (HIC), chest G, head excursion, and knee excursion 
were compared with the injury criteria established by NHTSA to 
determine the dynamic performance rating.\10\ A six-category range was 
used to rate child restraints based on the dummy measurements. The six 
categories were: Not Acceptable, Poor, Fair, Good, Very Good, and 
Excellent.
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    \9\ Consumer Reports, Traveling With Kids, July 2001.
    \10\ Pittle, Greenberg, Galeotafiore, Champion, Comments of 
Consumer Union to the National Highway Traffic Safety Administration 
on the Child Restraint System Plan, Docket Number: NHTSA-7938, 2001.
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    The child restraints of the 2001 survey were tested both with and 
without the top tether. The results from this study showed that all but 
one child restraint provided better protection while using the top 
tether in frontal crashes.
2. Japanese NCAP
    The Ministry of Land, Infrastructure, and Transport (MLIT) in Japan 
recently announced a proposal to rate child restraint systems. MLIT is 
asking for comments at this time. Japanese NCAP proposes to evaluate 
baby seats (rear-facing) and infant seats (forward-facing or 
convertible). They do not plan to test bed-type-seats or booster seats. 
Nine-month-old and three-year-old child dummies will be used for the 
evaluation.
    Child restraints will be tested in frontal sled tests. Child 
restraints will be tested using the ECE Reg. 44 crash pulse at 35 mph 
(56 km/h) in a Toyota Estima (similar to the Sienna in the U.S.) sled 
buck. A rating system will comprise the dummy readings, the level of 
physical damage, release of CRS anchorage, and dummy kinematics. A 
four-tier rating system will be used: Excellent, Good, Acceptable, and 
Not Recommended.
3. Australian CREP
    The Child Restraint Evaluation Program (CREP) is a joint program 
run by many of the same groups as Australian New Car Assessment Program 
(ANCAP). CREP tests child restraints in dynamic sled tests with a top 
tether, which is required in Australia. Two frontal crashes are 
simulated at 49 and 56 km/h (30 and 35 mph). Side and rear crashes are 
simulated at 32 km/h (20 mph). CREP conducts another test at the same 
speed, but with the CRS positioned at a 45 deg. angle relative to the 
sled. One additional dynamic test is done to rear-facing and 
convertible child restraints only. This is an inverted test conducted 
at 16 km/h (10 mph) to simulate a rollover.
    CREP gives a rating, incorporating both the dynamic test results 
and ease of correct use results. They report these ratings as either 
preferred buy or standards approved. The preferred buy seats did well 
in the dynamic tests and the ease of correct use tests. The standards 
approved rating is given to seats that passed the 49 km/h (30 mph) 
test, but had excessive head movement or broke a load-bearing component 
during the 56 km/h (35 mph) test.\11\
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    \11\ www.nrma.com.au, July 23, 2001.

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[[Page 56149]]

B. Existing Programs for Rating Dynamic Performance of Vehicles 
Equipped With CRS

1. Euro NCAP
    The European New Car Assessment Program evaluates the safety of 
children in vehicle crash testing. The subject vehicle's manufacturer 
provides a recommendation for which child restraints are to be used 
during the tests. The Europeans install child restraints in vehicles 
and subject them to offset frontal and side impact tests. In the offset 
frontal testing, two child crash dummies are placed in the back of the 
test vehicle. The two types of child dummies used in the test are a 3-
year-old P dummy and an 18-month-old infant P dummy. Both dummies are 
placed in the appropriate CRS, either forward-facing or rear-facing, 
designated for their ages. For the side impact test, the dummies are 
secured in the same model child restraint used for the offset frontal 
crash test.
    Euro NCAP evaluates dummy kinematics. In addition, technicians 
evaluate ease of use, ease of installation in the vehicle, and how 
securely they can install the CRS. Currently, Euro NCAP does vehicle 
tests for child restraints without using a top tether. Euro NCAP gives 
points based on the dynamic performance of the child dummies during the 
full-scale crash tests. These points are subject to modifiers that will 
reduce the points earned. Such modifiers include penalties for 
ejection, poor seat labeling, and vehicle incompatibilities. A total of 
four points is possible for the child scores. These points are added to 
the overall total, which is used to determine the vehicle's star 
rating. However, if any anomaly leads to a dangerous event (e.g., if 
the child seat breaks or if a belt becomes unlatched), Euro NCAP notes 
the event to consumers in their publications and web site.\12\
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    \12\ http://www.euroncap.com/results.htm, August 23, 2001.
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2. Australia
    The Australian New Car Assessment Program (ANCAP) harmonized its 
testing procedures with Euro NCAP in 1999. Therefore, in accordance 
with the Euro NCAP procedures, ANCAP does both an offset frontal crash 
at 64 km/h (40 mph) and a side impact test at 50 km/h (31 mph). Two 
child restraints are placed 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 dynamic performance of child restraints in vehicle 
tests, however, the rating protocol will likely be different from that 
published by Euro NCAP.

C. CRS Dynamic Testing by IIHS

    The Insurance Institute for Highway Safety (IIHS) currently does 
not rate child restraints. However, IIHS recently did several vehicle 
frontal crash tests that included child restraints. Vehicle velocities 
in these car-to-car tests were 48 km/h (30 mph), and vehicle frontal 
engagement 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 
Hybrid III.
    IIHS evaluated the dummy results for the 6-month-old CRABI, the 12-
month-old Infant CRABI, and the 3-year-old Hybrid III. They used the 
corresponding reference values specified in the May 12th, 2000 Federal 
Register notice for FMVSS No. 208.\13\ The results for the 6-month-old 
CRABI and the 12-month-old CRABI were all well below the allowable 
limits. The results for the 3-year-old Hybrid III dummy showed all 
injury readings were less than the reference values except for neck 
tension. IIHS suggested that these results mean the current neck 
tension criterion overestimates the possibility of an AIS \14\ 
 3 injury.\15\
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    \13\ Notice for FMVSS No. 208, Federal Register, Vol. 65, No. 
93, page 30680, May 12, 2000.
    \14\ Association for the Advancement of Automotive Medicine, The 
Abbreviated Injury Scale, Des Plaines, 1990.
    \15\ Susan Meyerson & Adrian Lund, Insurance Institute for 
Highway Safety, ``Child Restraint Durability in High-Speed 
Crashes,'' 2001 SAE conference, SAE2001-01-0123.
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D. NHTSA CRS Dynamic Testing

    In response to the TREAD Act, NHTSA examined three dynamic test 
methods for rating child restraint systems. The first dynamic option 
was a sled test at 30 mph (48 km/h). This option would use the results 
of the FMVSS No. 213 compliance testing to determine a rating. Two 
possible rating schemes could be used to rate or rank the child 
restraint dynamic performance. One possible rating scheme would be 
based on the compliance margins with which a dummy met the limits of 
the standard on HIC, chest acceleration, head excursion, and knee 
excursion. A second rating scheme would use the injury risk curves that 
NCAP uses to rate adult occupant protection in a frontal crash. Scaling 
these curves to represent a 3-year-old child would produce a five-star 
classification system. The probability of injury for the 3-year-old 
child 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 option examined was a high-speed sled test 
at 35 mph (56 km/h). This test method would be similar to the current 
FMVSS No. 213 compliance test; however, the sled acceleration pulse 
would have a greater magnitude to increase the speed to 35 mph (56 km/
h). A third dynamic testing option considered was a full-scale crash 
test. This approach would add a child restraint in the rear seat of a 
vehicle when it is tested for frontal NCAP, and rate the vehicle on how 
well the CRS and vehicle work together to protect the child. These last 
two options would also use the scaled injury risk curves for a rating.
    Each of the next three sections describes the testing conducted by 
the agency to assess each of the proposed options. The summaries review 
the trends of child restraint system (CRS) responses in the Federal 
Motor Vehicle Safety Standard (FMVSS) No. 213 sled testing, higher-
speed sled testing, and frontal NCAP in-vehicle testing.
1. CRS Performance in FMVSS No. 213 Sled Testing
    As specified in Standard No. 213, 49 CFR Sec. 571.213, the agency 
does compliance testing of child restraints on a sled buck at a nominal 
speed of 30 mph (48 km/h). Currently, a Hybrid II dummy is used in 
testing to represent a 3-year-old child.
    In model year 2000, the agency tested 50 upright, forward-facing 
child restraints according to FMVSS No. 213. Twenty-four seats were 
tested without a top tether, and 26 seats were tested with a top 
tether. We restrained all seats with only a lap belt (no lower 
anchorage or shoulder belt). The pertinent test results are tabulated 
in the Appendix, Table A2.
    Currently, to pass the FMVSS No. 213 compliance test, a child 
restraint must achieve dummy injury numbers of a Head Injury Criterion 
(HIC) less than 1,000 and a resultant chest acceleration of less than 
60 G's. For the compliance tests, HIC is calculated using an unlimited 
period and chest acceleration uses a 3 ms clip. As shown in Figure 1, 
regardless of whether we equipped the child restraints with a top 
tether, all child restraints achieved dummy injury readings below the 
maximum allowable values. Figures 2 & 3 illustrate the margin of 
compliance for HIC and chest acceleration, respectively. The margin of 
compliance is one minus the measured injury reading divided by the 
injury assessment reference value (IARV) times 100. Higher percentages 
are better, having less probability of injury. Regarding the HIC, all 
model year 2000

[[Page 56150]]

child restraints tested easily fall within the limits specified by the 
FMVSS No. 213 compliance tests. Most had a compliance margin of more 
than 50%. Although the margin is not as large for chest acceleration, 
all tested child restraints passed this compliance requirement as well.
    FMVSS. No. 213 also has a requirement for head and knee excursion. 
Head excursion is limited to 720 mm (28 in) when a top tether is used, 
and 813 mm (32 in) without use of a top tether. Knee excursion is 
limited to 915 mm (36 in). Figures 4 & 5 illustrate the margin of 
compliance for head excursion and knee excursion, respectively. Head 
and knee excursion limits are compliance limits imposed to reduce the 
chances of a child striking the vehicle interior or submarining 
(sliding under the belt feet first) in an automotive crash. Head and 
knee excursions are much closer to the compliance limits than HIC and 
chest acceleration. (This may reflect attention to occupant protection, 
since increases in distance traveled by the occupant reduces the forces 
experienced by the occupant.)
    To further investigate the possibility of using FMVSS No. 213 
compliance testing to rate child restraints, NHTSA performed additional 
sled tests to gather child restraint protection data. These sled tests 
were performed in accordance with the specifications outlined in FMVSS 
No. 213 compliance tests, with two exceptions. The three-year-old 
Hybrid III dummy was used to assess injury rather than the Hybrid II 
dummy. Also, the current compliance test secures child seats in two 
configurations, lap belt only and lap belt with top tether. These 
additional sled tests secured the child seat with the lap/shoulder belt 
and tether. One child restraint tested was secured with LATCH.\16\
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    \16\ ``LATCH'' is a term used by industry and retail groups 
referring to the child restraint anchorage system required by 
Federal Motor Vehicle Safety Standard No. 225. LATCH stands for 
``Lower Anchorages and Tethers for Children.'' The term is used to 
refer to vehicles equipped with the anchorage system (e.g., ``LATCH 
vehicles'') and to child restraints equipped with attachments that 
connect to the anchorage system (e.g., ``restrained with LATCH,'' or 
``LATCH child restraints''). For convenience, we will use the term 
in this notice.
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    Nine child restraints were tested. Figure 6 shows the individual 
plots of chest acceleration versus HIC. Injury risk curves are also 
plotted, and illustrate that eight of the nine child restraints would 
receive a 5 star rating, while the other one would be borderline 5 
star/4 star.
Advantages and Disadvantages of a Rating System Based on FMVSS No. 213 
Compliance Testing
a. Advantages
--Ratings for most child restraint systems could be implemented quickly 
and inexpensively using Hybrid II results now obtained in Standard No. 
213 compliance testing.
--The compliance testing is a simple pass and fail rating system. 
Carrying out a rating based on the margin of compliance is 
straightforward. The performances of child restraints could be used as 
a rating system.
--The rating system based on sled testing subjects all child restraints 
to the same impulse loading, so child restraint performance is assessed 
with little or no influence of outside variables.
b. Disadvantages
--FMVSS No. 213 is currently under revision. Ford Motor Company and 
others suggest that the agency consider delaying the child restraint 
safety rating until after the revision of FMVSS No. 213.
--A rating based on dynamic sled testing does not take into account the 
compatibility between child restraints and vehicles. Many people 
believe that a child restraint and a subject vehicle must be evaluated 
as a system to effectively assess child safety protection.
--To the extent that current child restraints all exceed the standard 
by a wide margin, as in the case for HIC, the compliance margin may not 
meaningfully distinguish among child restraints. For example, if we use 
the star rating system, nearly every child restraint would get 5 stars. 
If we use the percentage of compliance margin, should we tell the 
public a child restraint with a 60% margin is safer than one with a 55% 
margin? Also, it would be difficult to explain to the public which 
compliance margin (i.e., HIC, chest acceleration, excursions) is more 
important to safety.
2. CRS Performance in Higher-speed Sled Testing
    Some commenters suggested that the agency should consider having a 
child restraint rating based on sled tests at a higher speed (35 mph) 
than the compliance testing (30 mph). As NCAP currently tests motor 
vehicles at 5 mph (8km/h) above the compliance tests, the same 
reasoning could be applied to the sled testing of child restraints. (It 
was also recommended that the rating system use a realistic vehicle 
pulse and a vehicle seat as part of the test condition.) To determine 
the viability of developing an effective rating system as a consumer 
program for child restraint testing, the agency has conducted higher-
speed sled testing.
    NHTSA conducted higher-speed sled tests using the same nine child 
restraints as in the previous section. The same FMVSS No. 213 test 
procedure was used with Hybrid III three-year-old dummies. To attain 
the higher speed, a sled pulse with a similar shape and duration length 
as that of the 213 pulse was used, except that the change-of-velocity 
was elevated from 30 mph (48km/h) to 35 mph (56km/h).
    All of the child restraints tested produced dummy injury 
measurements well below the FMVSS No. 208 criteria of 570 HIC and 55g 
chest acceleration. Figure 7 shows the results plotted with the NCAP 
injury risk curves. Although the injury assessment values are slightly 
greater for the 35 MPH (56 km/h) sled tests than the 30 mph (48 km/h) 
sled test (shown in Figure 6), eight of the nine child seats fell 
within the 5 star range, and one fell just below in the 4 star range.
Advantages and Disadvantages of a Rating System Based on Higher-speed 
Sled Tests
a. Advantages
--Running tests at higher speeds is the same approach we have used for 
front and side crashworthiness ratings in NCAP, and would be expected 
to magnify performance differences among child restraint systems beyond 
that obtained in compliance testing.
--A rating based on sled performance would be consistent because all 
child restraints would be subjected to the same impulse loading and 
would be placed on the same simulated seat.
b. Disadvantages
--A rating based on a higher sled test speed would again not take into 
account compatibility between child restraints and vehicles. Many 
people believe that a child restraint and a subject vehicle must be 
evaluated as a system to effectively assess child safety protection.
--A higher test speed with the Standard No. 213 crash pulse may be so 
severe that the information would not be a helpful indicator of 
expected CRS performance in the majority of real-world crashes.
--Based on tests with nine child seats, the higher test speed may not 
sufficiently ``spread out'' the performance differences to allow NHTSA 
to provide meaningful information to the public.

[[Page 56151]]

3. CRS Performance in NCAP Frontal Vehicle Testing
    The agency evaluates vehicle crashworthiness in frontal and side 
impact under the New Car Assessment Program (NCAP). Under this program, 
the agency conducts approximately 40 frontal and 40 side crash tests 
each year. For the frontal crash, the agency does these tests with two 
50th percentile adult male dummies in the front seat. Historically, 
NCAP does not put any occupants in the rear seats of the vehicles. 
However, because there is room in the rear seats of most vehicles, it 
has been suggested that NHTSA add child restraints to the rear of NCAP 
frontal crash tests.
    NHTSA has evaluated child restraints in frontal crash tests 
conducted under the New Car Assessment Program. In model year (MY) 2001 
testing, NCAP used various child restraints in the rear seats of 
vehicles undergoing frontal NCAP crash tests. Child restraints were 
placed in a total of twenty NCAP vehicles, varying in type and size. 
The agency evaluated performances of six different five-point-harness 
forward-facing child restraints. The evaluation assessed (1) the 
variability of CRS performance in various vehicle types and sizes, (2) 
CRS/vehicle interaction, and (3) performance among different child 
restraints. CRS performance in the NCAP vehicle tests is shown in Table 
A1 in the Appendix.
    In each vehicle tested, the subject child restraint was secured 
tightly, and as prescribed by the child restraint manufacturer's 
instructions. In addition, all child restraints, whether secured with 
LATCH or secured with a lap/shoulder belt, used a top tether. A Hybrid 
III three-year-old dummy was used to assess performance. All testing 
used the full instrumentation package available for the child dummy. 
The injury assessment reference values for FMVSS No. 208 were used to 
evaluate the results.
    Figure 8 shows the overall child dummy performance concerning the 
Head Injury Criterion (HIC 15) and resultant chest acceleration, 
plotted with the NCAP injury probability curves scaled for the three-
year-old. The performance is shown for child restraints with LATCH or 
with a belt restrained CRS with a top tether. As shown, many (38.7%) 
dummy readings exceeded the allowable injury criterion for HIC 15 (570) 
or the allowable chest G criterion (55 G's). Using the star rating 
system, most vehicles would be rated with 3 or 4 stars for rear seat 
child occupancy protection. Five samples had injury readings low enough 
for a five-star rating; only one vehicle was rated with two stars. This 
is in contrast to driver and right passenger frontal NCAP test results 
which result in about 88% 4 and 5 star ratings.
    All seats tested in the NCAP vehicle crash tests used five-point 
harnesses, while the FMVSS No. 213 tests use all types of harnesses. 
Figure 9 shows the model year 2000 compliance tests results for only 
seats with a five-point harness and lap belt only. This graph shows 
that the tethered seats produced lower HIC responses than those seats 
without a top tether. The HIC responses for both the tethered and the 
non-tethered seats are clustered among their respective seat types. In 
comparing the data in Figures 8 and 9, we may infer that the full-scale 
crashes produce a greater range of values for the Head Injury 
Criterion. One could further infer that the greater range of HIC 
response shown in the NCAP data of Figure 8 is due not only to the 
child restraint, but also due to crash variations, such as crash pulse, 
belt geometry (important for child restraints that use a lap/shoulder 
belt), seat contour, and seat cushion stiffness.
    The influence of these additional factors for crash testing is 
shown more clearly in Figure 10. Figure 10 shows seven vehicles that 
underwent NCAP crashes with the Cosco Triad child restraint. As shown, 
the Cosco Triad did not give the same performance in these seven NCAP 
vehicles. HIC injury values varied from approximately 300 to 650. The 
performances of the Evenflo Horizon V and the Fisher Price Safe Embrace 
II show like trends in vehicle testing. This is shown in Figure A1 in 
the Appendix.
    The agency has conducted this testing to address whether a specific 
child restraint would do the same in various NCAP vehicles. We 
determined that the answer is no. The agency next examined whether 
various child restraints would do equally well in a specific vehicle.
    Figure 11 shows the relative performance of four different CRSs 
crashed in two different minivans. Two crash tests were conducted with 
each minivan, and there were two child restraints placed in the rear 
seat for each test. The first Grand Caravan was tested with the Century 
STE and Horizon V. The second time, it was crashed with the Safe 
Embrace II and the Horizon V. For the Ford Windstar, the first test had 
two Safe Embrace II child restraints in the rear seat; in the second 
test, Cosco Triad child restraints were used. All child restraints in 
each comparison were 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 there was only one CRS (Safe Embrace II) that 
was used in both vehicles, CRS performance appeared to be better when 
tested in the Ford Windstar, and may be an indication that the vehicle 
has an influence on child safety protection.
    Figures 12 & 13 show vehicle crash pulse duration and acceleration 
peak versus chest acceleration. Although there is considerable scatter 
in the data, there appear to be slight trends, which would indicate 
that the vehicle's structural response could have an influence on the 
child restraint performance. Figure 12 suggests that, as the time 
duration of the crash increases, there is a reduction in chest 
acceleration. Figure 13 shows that, as the peak acceleration of the 
vehicle increases, there is a trend toward higher chest acceleration. 
(The agency did not find similar trends for the Head Injury Criterion.)
    Based upon this limited amount of data, it appears that a child 
restraint tested in a vehicle with good crash pulse characteristics 
(i.e., longer time duration, lower peak acceleration) could perform 
better than the same child restraint tested in a vehicle that does not.
    Further, good performance does not depend upon cost of the CRS. The 
agency examined the cost of child restraints (MY 2000) versus the 
relative performance of forward-facing child restraints tested with the 
three-year-old dummy in FMVSS No. 213 sled tests. Figure 14 shows no 
correlation between the cost of child restraints and their performance 
in dynamic sled testing. For the low IARV's, (HIC  400 and chest G 40), 
there are CRS from all price ranges. In addition, the two CRS with the 
highest HIC and chest G responses were in the $100-$150 cost range 
(i.e., a high cost range). Therefore, the limited available data show 
that a CRS need not be expensive to provide good child protection.
Advantages and Disadvantages of Rating a Vehicle Equipped With a Child 
Restraint
    Unlike the rating systems proposed for the sled tests at 30 mph (48 
km/h) and 35 mph (56 km/h) which rate only the child restraint, this 
option would rate the vehicle equipped with a CRS as a system in 
protecting the child.
    The following discusses the pros and cons 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 
the child restraint in overall safety

[[Page 56152]]

performance, since it would encourage vehicle manufacturers to take 
into account child restraint performance in designing vehicles.
--Using in-vehicle testing to evaluate a child restraint in the vehicle 
would enhance world harmonization with Euro NCAP and ANCAP.
--CRS testing can be easily incorporated into the New Car Assessment 
Program. The NCAP program conducts about 40 frontal crashes annually; 
adding child restraints to these tests could be done at a relatively 
low cost.
b. Disadvantages
--Such a system would provide a rating for the vehicle rather than the 
child restraint. Also, the consumer may mistakenly think that some 
child restraints may appear to have poor performance if the agency only 
tests them in certain vehicles, when in actuality they may perform well 
in other vehicles.
--To the extent that the agency only tests a child restraint in 
vehicles that perform well, that information may mislead the public 
about the protection offered by that child restraint in lesser-
performing vehicles.
--This rating system would not help consumers choose a child restraint 
suitable for an older vehicle model.
--Adding the CRS and dummy to the NCAP vehicle would require the 
removal of fluids and/or vehicle components to attain the test weight, 
and thereby potentially influence assessment of other NCAP crash 
results 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 child restraint rating program, NHTSA 
has also been mandated by Congress to consider how to provide consumer 
information on the physical compatibility of child restraints and 
vehicle seats on a model-by-model basis (Section 14(b)(4) of the TREAD 
Act).
    In May 1995, the Blue Ribbon Panel on Child Restraint and Vehicle 
Compatibility made a series of recommendations including a suggestion 
that vehicle manufacturers create a chart illustrating which hardware 
and what procedures of installation were necessary to ensure proper 
installation of child restraints in vehicles. In the Fall of 1995, 
NHTSA considered this recommendation and at the time, determined that 
the agency would try to develop a child restraint and vehicle 
compatibility database and make it available on a CD-ROM to child 
passenger safety advocates and others who assist the public with child 
safety education and proper installation. It was believed that the 
program would allow the cross-referencing of data regarding specific 
child restraints considering the weight and age of the child, vehicle 
make, model and year choices indicating available seating locations, 
resulting in a list of compatible child restraints and vehicle seating 
and installation information. The original plan was to have a database 
containing child restraint installation information for 100 different 
1993-1996 model year vehicles, using 35 child restraints.
    Over the course of developing this database, it became apparent 
that collecting data on several child restraints in hundreds of 
vehicles, resulting in the combination of thousands of child 
positioning possibilities was inherently subjective, prohibitively 
expensive, and very labor intensive. In addition, the information that 
would be available to assist consumers was limited to a certain type 
vehicle and a certain type child restraint, which would serve only a 
small number of consumers. Further, the LATCH rulemaking will greatly 
enhance the compatibility of child restraints and vehicles, which 
reduces the need for a CD-ROM database. Realizing these limitations, 
NHTSA began to explore ways in which we could develop a service that 
would provide accurate and up-to-date information to consumers on how 
to properly select the appropriate restraint for their child, and use 
and install it properly. In addition, NHTSA wanted to utilize the 
infrastructure of trained and certified child passenger safety 
technicians (over 19,000 to date) throughout the country.
    In March 2001, NHTSA developed and made available an internet-based 
service on its website, providing recommendations for the correct use 
of each type of child restraint to help consumers select the most 
appropriate child restraint system (http://www.nhtsa.dot.gov/people/
injury/childps/csr2001/csrhtml/safetyFeatures.html). It provides a 
current listing, along with pictures, of all new child restraints 
available along with a list of various features available on the child 
restraints that may make them easier to use and install. It provides a 
list of model year 2001 vehicles with child restraint features, as well 
as vehicle owner's manual instructions for child restraint 
installation. In addition, this website application includes pictures 
of proper use and step-by-step instruction on installation. It also 
describes and shows common compatibility problems between vehicles and 
child restraints and offers solutions to obtain the best fit. This 
website application allows for the continual addition of current and 
accurate information, at minimum cost, and significantly expands public 
access. The site has received thousands of visits per week since its 
placement in March.
    This application is not specific to child restraints and vehicles 
on a model-by-model basis, as originally intended. However, it provides 
guidelines for the selection of the appropriate restraint, tips for 
proper use and installation, and points consumers in the proper 
direction for installation assistance, by linking to a listing of 
thousands of inspection stations located throughout the country where 
consumers can go and have their child restraint inspected by a 
certified child passenger safety technician. For these reasons, and 
because providing the information on a model-by-model basis has proven 
to be limited, impracticable, and prohibitively costly, we have decided 
that the web-based approach is the appropriate method of providing the 
consumer information to the public.

B. Summary of Existing Ratings for Ease of Use

1. Australia
    The New South Wales Roads and Traffic Authority (RTA) joined with 
the National Roads and Motorists Association (NRMA) and the Royal 
Automobile Club of Victoria (RACV) to conduct a joint program to assess 
the relative performance of child restraints available in Australia. In 
addition to crash testing, the program covers installation, use and 
compatibility with a range of vehicles. The child restraints that 
performed the best were given a ``preferred buy rating.'' To be awarded 
a ``preferred buy rating,'' a child restraint must perform well in 
crash tests that are more severe than the Australian Standard and 
perform well for ease of correct installation and ease of use.
    Child restraint/vehicle compatibility is evaluated by fitting each 
restraint in both the rear center and rear left seats of test vehicles. 
The vehicles used to evaluate compatibility are the top-selling models 
in each of the following categories: large sedan, large station wagon, 
small hatchback, medium hatchback, multipurpose vehicle, and large 
four-wheel drive. In addition to the determination that the restraint 
and vehicle are compatible, the NRMA also evaluates restraints on how 
easy they

[[Page 56153]]

were to install in vehicles and how easily children could be secured in 
them.
2. Consumer's Union
    Consumers Union (CU), a nonprofit membership organization, has been 
evaluating child restraints for more than 25 years. Their child 
restraint ratings can be found on their web site and in their 
publication, Consumer Reports magazine.
    Consumers Union tests child restraints for crash protection, ease 
of use, and the ability to install properly the restraint with 
different seatbelts.\17\ In making its judgment about ease of use the 
following attributes are considered:

--Threading vehicle belt through restraint,
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    \17\ If an infant restraint is sold with a stroller the stroller 
is also evaluated.
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--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 
recline level adjustment.

    All of the items are evaluated subjectively on a five-point scale 
(Excellent, Very Good, Good, Fair, and Poor). The crash protection, 
ease of use, and installation ratings are also combined into an overall 
rating.
3. Euro NCAP
    In the European New Car Assessment Program, vehicle manufacturers 
recommend the make/model of a child restraint suitable for a 3-year-old 
child and a second restraint suitable for an 18-month-old infant. These 
restraints are then installed in the rear seat of the vehicle during 
the crash tests. Technicians then provide an evaluation of the ease of 
installation in the vehicle when setting up the test. NHTSA is not 
aware of any defined criteria for this evaluation. The evaluation 
provides information about the compatibility of some child restraint 
make/models with tested vehicles. In addition, if a vehicle does not 
have a device for deactivating a frontal protection air bag, a notation 
is made about the quality of the vehicle's warning about the hazards of 
air bags with child restraints.
4. ICBC
    The Insurance Corporation of British Columbia (ICBC) is a public 
agency in Canada that was established in 1973 to provide universal auto 
insurance to motorists in British Columbia, Canada. In July 1999, ICBC 
invited members of the child restraint usability task force of ISO/
TC22/SC12/WG1 (Child Restraints) to meet in Victoria, BC. The purpose 
of the two-day meeting was to prepare a draft document of usability 
criteria and objective tests for child restraint manufacturers. 
Consumer and insurance representatives who evaluated the ``usability'' 
of child restraints sold in BC subsequently used the draft document. 
The findings were subsequently published in an ICBC brochure called 
``Buying a Better Child Restraint.''
    Depending on features and type of restraint, the ICBC strategy 
rates some or all 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 within each feature category by the 
evaluators. The participants in the initial meeting rated each of these 
factors A, B or C according to risk and severity of misuse. The factors 
with the higher risks of injury if misused were rated ``A,'' while the 
factors with the lower risks of injury were rated ``C.'' The evaluators 
then rate each factor, based on agreed upon standards, either ``good,'' 
``acceptable,'' or ``poor.'' This rating is then combined with the A, 
B, or C weighting for that factor. All of the ratings for all of the 
factors for a feature are combined and an overall rating for that 
feature is determined. The ICBC does not combine the ratings for each 
feature to develop an overall rating.
5. Japan
    The Japanese Ministry of Land, Infrastructure and Transport, in 
cooperation with the National Organization for Automotive Safety & 
Victims' Aid, tests and evaluates the safety of automobiles currently 
on the market in Japan. The results of these tests are publicly 
released under the title New Car Assessment Japan. Japan has proposed 
rating child restraints as part of its New Car Assessment program in 
2002.
    In addition to dynamic testing, Japan has proposed rating child 
restraints on ease of use. Specialists would rate the restraint in five 
categories. These categories are the user manual and other information 
(i.e., ease of understanding and accuracy), illustrations and 
instructions on the child restraint (i.e., ease of understanding and 
accuracy), the safety features of the child restraint (i.e., recline 
device, cover, and attachment storage), ease of installation (i.e., 
ease of threading belts and ability to tightly install), and how well 
the child restraint fits into the vehicle (i.e., ease of adjustment and 
buckle release mechanism).
    Japan proposes to rate each item within the five categories using a 
5-level rating system. NHTSA was provided with a summary of the 
proposal translated into English, which did not indicate what criteria 
would be used for each category. The category rating would then be the 
average level of each item within that category. A graphical 
representation of the ratings would be presented on a ``radar chart'' 
with a spoke for each of the five categories.
C. Planned Child Restraint Ease of Use Rating System
1. Assessment of Existing Ease of Use Rating Systems
    After analyzing all the comments and gathered information, NHTSA 
has tentatively decided that it appears possible to have a fair and 
repeatable rating for ease of use. The agency has modeled its planned 
approach on that used by ICBC, because ICBC uses objective criteria for 
what is ``good,'' ``acceptable,'' and ``poor'' for each factor rated. 
NHTSA is also proposing to use a weighting system for the relative 
importance of each feature within each ease of use category. The agency 
is planning to rate ease of use features in four categories as A, B, or 
C, with A being the highest rating and C the lowest. In addition, NHTSA 
is also considering taking the ICBC rating system one step further by 
combining these four ratings into an overall rating for ease of use 
using the same scale.
    Almost all of the features evaluated by the other programs NHTSA 
examined are included in NHTSA's planned program. The difference 
between ICBC and the other ease of use rating systems (Australian, CU, 
Euro NCAP, and Japanese) was the known objective criteria for each 
feature in the ICBC program and the known weighting of the features 
within each category in the ICBC program. To the extent that a feature 
evaluated by another program is not included in our program, NHTSA has 
tentatively determined that it is not a feature related to safety when 
using

[[Page 56154]]

the child restraint in a vehicle.\18\ The additional difference between 
our planned approach and Euro NCAP is that Euro NCAP only evaluates 
those seats that have been selected by vehicle manufacturers for 
inclusion in the crash test. NHTSA hopes to be able to evaluate all or 
almost all the child restraints available in the US market at the time 
of the evaluation.
---------------------------------------------------------------------------

    \18\ NHTSA requests comments on whether we should delete any of 
the features we have proposed to include, or whether we should 
include features that we have not included in today's proposal. For 
example, should rear-facing restraints be rated according to the leg 
room they provide, which may be a feature that would make the 
restraint easier to use by infants with long legs?
---------------------------------------------------------------------------

    NHTSA personnel spent a day conducting a hands-on evaluation of the 
ICBC rating program to determine the repeatability of the program. With 
the assistance of a representative of the ICBC rating program, those 
present were divided into two teams. Both teams evaluated the same six 
seats. Their scores were put in a computer program that incorporates 
the weighting. The personnel compared the evaluation scores. While the 
teams had some minor differences in ratings for features within each 
category, the agency task force team evaluation resulted in 100 percent 
repeatability for each category.
    While NHTSA agrees that overall, the features selected and rated in 
the ICBC program are those that are most subject to misuse, analysis of 
each component and review of the evaluation criteria has led NHTSA to 
modify slightly the ICBC program. One of the reasons why changes were 
made was an effort to simplify the information provided to consumers. 
Other changes were made to reflect child restraint standards of the 
United States to the extent that they are different from those in 
Canada. Last, some modifications were also made based on information 
learned from the repeatability exercise. All of the changes are 
explained in greater detail below.\19\
---------------------------------------------------------------------------

    \19\ A copy of the planned evaluation form is included in the 
appendices to this notice. Details of the program are discussed only 
to the extent that they differ from ICBC's program.
---------------------------------------------------------------------------

2. Four Rating Categories
    Depending on features and type of restraint, the ICBC strategy 
rates up to seven 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 is planning to rate four 
categories for each restraint:

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

    NHTSA combined labeling and instructions into one category. In 
NHTSA's experience, most labels and instructions are stylistically 
similar, and therefore any restraint is likely to have the same rating 
in each of these categories. In addition, ICBC has indicated and our 
experience also showed, that these categories are the least objective. 
NHTSA believes that combining them into a single category would reduce 
the influence they would have on a combined rating for ease of use and/
or the importance a consumer would place on the individual rating. 
NHTSA also moved the criteria for ``Ease of Conversion'' to a 
``Securing the Child'' category, since the ease of adjusting a child 
restraint for different size children is directly related to the ease 
of securing a child in the restraint. Finally, NHTSA moved ``Tether 
Straps'' to the ``Installation in Vehicle'' category, because there is 
only one criterion related to tether straps, and because this category 
also relates to ease of installation in a vehicle.
a. Assembly
    NHTSA has decided to include the following features in the 
``Assembly'' category:

--All functional parts including seat pad or cover attached and ready 
to use
--Tether attached to child restraint
--Owner's manual easy to find
--Obvious storage pocket for manual

    NHTSA chose not to include the ICBC feature, ``any other add-ons in 
box'' because it is believed that such add-ons, for example extra pads, 
cup holders, sun canopy, were not related to ease of use or the safety 
function of the child restraint. Any add-on that is to be used and is a 
functional part of the restraint or related to correct use of the 
restraint is to be included under the ``all functional parts including 
seat pad or cover attached and ready to use'' category.
    NHTSA has chosen to modify the criteria used to evaluate the 
feature, ``obvious storage pocket for manual.'' ICBC defines ``good'' 
as ``easy access when CRS installed in all modes,'' an ``acceptable'' 
as ``easy access not accessible when CRS installed in all modes,'' and 
``poor'' as ``none found or not easy access/storage (incl. Plastic 
tabs).'' During NHTSA's evaluation of the ICBC criteria using several 
child restraints, we found that in some cases the storage pocket for 
the instructions manual was easily accessible in all modes, however it 
was difficult to use. In other words, it was difficult to take the 
instructions out of the storage pocket and difficult to put them back 
in. With this difficulty, it is believed that if consumers take the 
instructions out of the storage pocket they will not put them back. 
Therefore, NHTSA's planned criteria are:

--A = Easily accessible when installed in all modes and manual can be 
removed and replaced easily
--B = Easily accessible when installed in all modes but manual cannot 
be removed and replaced easily (any use of plastic clips as the sole 
means of storing the instructions will not be higher than ``B'')
--C = Not accessible when installed in all modes.

    NHTSA has also modified the criteria used to evaluate the feature 
``owner's manual easy to find.'' ICBC defines a ``good'' as ``yes, 
attached to CRS,'' an ``acceptable'' as ``in box,'' and a ``poor'' as 
``no.'' NHTSA regulations also require written instructions; therefore 
no child restraint manufactured for sale in the United States should 
receive a ``poor'' under the ICBC program. However, when evaluating the 
ICBC system, both infant restraints we evaluated had the written 
instructions attached between the restraint and the detachable base. 
This forces the consumer to learn how to release the base from the 
infant restraint without the assistance of instructions. NHTSA felt 
that a rating should distinguish between written instructions attached 
so that they were clearly visible as the restraint was removed from the 
box (many had them in a plastic bag attached to the harness) and those 
where you had to search for the written instructions. NHTSA also 
believes that any form of attachment is preferable to having the 
instructions loose in the box, and therefore has moved the ``in box'' 
criteria to ``C.'' \20\ While NHTSA did not find any restraints that 
would have received a ``C,'' NHTSA is concerned that if the 
instructions were loose they could be lost before purchase if the box 
were damaged or opened for inspection. NHTSA's planned criteria are:

    \20\ The agency is mindful that Standard No. 213 requires an 
owner registration card to be attached to the child restraint, and 
that too many materials attached to the restraint could dilute the 
consumer's attention to the registration card. Comments are 
requested on whether attaching the owner's manual to the restraint 
will overwhelm the card.
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--A = attached to child restraint in a clearly visible location
--B = attached to child restraint but not clearly visible
--C = in box, not attached


[[Page 56155]]


b. Evaluation of Labels/Instructions
    NHTSA has decided to evaluate the following features in the 
``Evaluation of Labels/Instructions'' category:

--Clear indication of child's size range
--All mode/s of use clearly indicated e.g., rear-facing only or 
forward- and rear-facing if convertible
--Air bag warning in written instructions
--Shows harness slots okay to use for occupant size
--Instructions for routing for both lap belt and lap/shoulder belt in 
all modes
--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's categories, NHTSA has deleted the 
feature ``is airbag warning visible no matter where CRS is installed.'' 
NHTSA requires an air bag warning label on rear-facing child restraints 
in a location that would receive a ``good'' under the ICBC program. 
Therefore, NHTSA feels this feature can be deleted. NHTSA is retaining 
the feature ``air bag warning in written instructions'' as NHTSA found 
a great variety in written instructions with regard to the visibility 
of this important information.
    NHTSA has added ``information on written instructions and on labels 
match'' as a separate feature. While NHTSA did not encounter any child 
restraint during its exercise that had different information on the 
labels than in the written instructions, the representative from ICBC 
indicated that they find this commonly. For example, the height or 
weight ranges may be different between the two sources of information. 
While NHTSA suspects this results because written instructions are 
printed in a large quantity and therefore not updated as frequently as 
labels, it could be very confusing to consumers. Therefore, NHTSA felt 
it deserved a separate category.
    NHTSA has also added a feature ``durability of labels.'' NHTSA has 
received complaints about labels fading and peeling. When evaluating 
the ICBC program, NHTSA found two child restraints with one or more 
labels already beginning to peel as they were removed from the box. In 
a recently published Notice for Proposed Rule Making (NPRM) on child 
restraint labels, NHTSA did not propose a durability requirement.\21\ 
However, we believe that adding this feature to the ratings will 
encourage manufacturers to improve label durability. To achieve an 
``A'' rating, all of the labels would have to use a technology such as 
molding or heat embossing. Sticky labels would receive a ``B'' rating 
unless any of the labels had already started to peel when the restraint 
was removed from the box. In the later case, the restraint will receive 
a ``C'' rating.
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    \21\ Docket Number: NHTSA-2001-10916.
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    Under ICBC's program, almost all labels receive a poor for many of 
the features unless the label is on both sides of the restraint. NHTSA 
has received comments on labeling upgrades requesting us to keep in 
mind the limited space on child restraints. Providing a rating on 
whether restraints have labels on both sides will encourage 
manufacturers to place labels on both sides, resulting in using the 
limited space on the restraint for additional labels. NHTSA is 
considering modifying the ratings to allow for an ``A'' rating if the 
label meets the specified criteria and is on one side of the restraint. 
To this end, child restraints would not receive a ``C'' rating if the 
label was only on one side of the restraint. Encouraging manufacturers 
to make instructions more accessible, easier to use, and clearer, 
should provide a justifiable solution instead of encouraging labels on 
both sides of the child restraint.
c. Securing the Child
    NHTSA has tentatively decided to evaluate the following features 
found in the ICBC ``Securing the Child'' category:

--Buckle can be secured in reverse (harness strap buckle)
--Harness adjustment easy to tighten and loosen when child restraint 
installed
--Number of harness slots/usable slots
--Ease of attaching/removing base
--Ease of conversion rear-facing to forward-facing or forward-facing to 
booster 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 two categories, the agency will 
slightly modify the rating criteria for two of the features. First, 
under ``buckle can be secured in reverse,'' (referring to the harness 
strap crotch buckle which on most child restraints has a red square 
buckle release) a ``good'' rating by ICBC is 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 rating to the following: an ``A'' rating is ``no, or yes 
but usual release works with same degree of effort,'' a ``B'' rating is 
``yes, but usual release requires more effort,'' a ``C'' rating is 
``yes, but can't use release mechanism.'' The safety concern with being 
able to reverse a buckle is that during an emergency a parent may be 
unable to release the mechanism and remove the child from the seat. 
NHTSA has tentatively chosen to modify this rating based on our opinion 
that if reversing the buckle did not make the release more difficult to 
use, there is not a safety concern. Further, NHTSA thought that 
reversing the buckle might provide a benefit for children who may have 
learned to unbuckle the release mechanism. With the buckle reversed, 
the child would be less likely to unbuckle him or herself.
    The other modification is the rating criteria for the feature 
``ease of changing harness slot position.'' Under the ICBC program a 
``good'' rating is ``easy to attach/remove; clear slots easy to thread; 
easy to attach to hardware,'' an ``acceptable'' rating is ``possible 
for one person to do; slots may be misaligned/pad in way/in slots; 
hardware slot shared,'' and a ``poor'' rating is ``other, slot size too 
small for easy threading; loose mandatory pieces; could misroute 
through buckle.'' Under the NHTSA program an ``A'' rating is ``no need 
to rethread; possible for one person to do,'' a ``B'' rating is 
``possible for one person to do, easy to attach/remove; large slots 
easy to thread,'' and a ``C'' rating is the same as that used by ICBC. 
The reason NHTSA is proposing to make a change to the evaluation 
criteria is that we've observed that no matter how easy it seems to 
rethread, some people will rethread the harness wrong.
d. Installation in Vehicle
    NHTSA has decided to evaluate the following features in the 
``Installation in Vehicle'' 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 occur

    NHTSA is considering adding a feature, ``Ease of tightening belt 
around CRS.'' Based on experience with installing child restraints we 
have found some features on child restraints, specifically on infant 
seat bases, that made tightening of the vehicle belt system difficult, 
or that resulted in the tilting of the infant seat base to one side 
upon tightening of the vehicle's lap and shoulder belt through the 
infant seat base, resulting in an improperly secured

[[Page 56156]]

child restraint. Therefore, we feel there is a need to consider this 
aspect of installation. NHTSA would need to develop evaluation criteria 
on what features of a child restraint would receive an ``A,'' ``B,'' or 
``C'' rating under this category. NHTSA is soliciting views and 
comments on this consideration.
3. Weighting the Features
    The ICBC program ranks each feature within each category based upon 
the level of importance. These rankings were determined by the child 
restraint usability task force of ISO/TC22/SC12/WG1 (Child Restraints) 
\22\ at a meeting in British Columbia. Each ease of use feature is 
rated as an A, B, or C according to risk of injury and severity of 
misuse. Component features that could be associated with a high risk of 
injury if misused are to be rated ``A''. Each ranking is assigned a 
numerical scale where A = 3 points, B = 2 points, and C = 1 point. The 
ratings are similarly assigned a numerical scale where good = 3 points, 
acceptable = 2 points, and poor = 1 point. To determine the rating for 
a category, the numerical value of the rating for each feature is 
multiplied by the numerical value of that feature's ranking. The 
maximum possible score is then divided into thirds to determine the 
point ranges for the category rating.
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    \22\ Working group TC22/SC12/WG1, ``Child Restraint Systems,'' 
to the International Organization for Standardization (ISO), a 
worldwide voluntary federation of ISO member bodies, is considering 
developing an ease of use usability rating system for child 
restraint systems. The group has based its preliminary work on the 
rating system of ICBC, which is similar to NHTSA's work thus far.
---------------------------------------------------------------------------

    This notice is proposing a slightly modified version of this 
scheme. Whereas we agree with the ICBC relative ratings for the 
component elements, we do not believe that enough is known to assign 
weights to the four categories in terms of importance. The discussion 
on the overall summary rating in Section 8 elaborates on this choice. 
The NHTSA proposed approach is as follows:
    Each component feature is assigned a numerical scale of 1-3 points, 
with features having the highest relationship to safety receiving 3 
points. The ratings are similarly assigned a numerical scale where A = 
3 points, B = 2 points, and C = 1 point. To determine the rating for a 
category, the numerical value of the rating for each feature is 
multiplied by the numerical value of that feature's ranking. Point 
ranges for A, B, and C are determined through a 3-part split of the 
range of possible points for that factor, from the minimum (if all 
scores were coded ``C'') to the maximum (if all scores were coded 
``A'') number of points. Appendix B and Appendix C displays this 
scheme, with a hypothetical example seat rated.
    NHTSA proposes to keep the same ranking as ICBC uses for the 
component features it has retained. For the four new features that we 
have added, we have assigned them a 2-point ranking. While we believe 
these features are important enough to add them to the rating system, 
their proposed lower ranking reflects the fact that ICBC chose not to 
include them.
4. Ease of Use Rating Protocol
    ICBC uses two 2-person teams to evaluate each child restraint. 
Prior to the evaluation, the teams have a day of training. ICBC has 
found that, while the rating for some features may vary between the 
teams, the overall rating for the category tends to be the same. To the 
extent that the teams end up with a different rating for a category, 
they jointly reexamine the child restraint before a rating is 
determined. Child restraints are installed in a bench seat of a generic 
minivan for purposes of the evaluation.
    NHTSA found that the ratings of the two teams we used in our 
evaluation also matched. Therefore, we are planning to use the same 
protocol for rating child restraints for ease of use.
    During the evaluation, the teams would install the child restraint 
in the current FMVSS No. 213 bench. If and when the FMVSS No. 213 bench 
is updated, the team will use the updated test bench. No dummy will be 
used during this process.
5. Overall Ease of Use Rating
    Market research in recent years has shown that most consumers 
prefer summary ratings or information because they find it quicker and 
easier to read and understand. At the same time, a certain significant 
percentage of consumers also like detailed information that is 
presented in hierarchical fashion, with the more general information 
presented initially. NHTSA is planning to combine the planned child 
restraint ease of use ratings into a summary ease of use rating. While 
NHTSA notes that it does not have clear information about how 
organizations that currently provide a summary rating determine that 
rating, study of the ICBC model has led to the conclusion that it is 
reasonable to apply a modified version of their model. The notable 
exception is that NHTSA does not believe it is possible to weight the 
importance of the four overall categories. As a result, a straight 
combination numerical rating is not proposed. If all of the individual 
scores were added to one overall numerical score, the factors 
containing more component elements would carry more weight. Therefore, 
the proposal for the combined rating is majority rule for the four 
categories, with two qualifiers. The two qualifiers are that a seat 
cannot receive a B rating if more than 1 out of 4 categories is a C 
and, correspondingly, a seat cannot receive an A rating if more that 1 
out of 4 categories is rated other than A. In the example in Appendix 
C, the seat received a high number of C ratings in important 
components, thereby resulting in 2 out of 4 categories being rated C. 
Application of the qualifier gives it a C rating.

V. Discussion and CRS Rating System Proposal

    The agency has not made a final determination on which of the four 
rating systems (three dynamic plus ease of use), or combination of 
those rating systems, would be most appropriate and responsive to the 
Congressional mandate of TREAD. However, we have tentatively concluded 
that the most effective consumer information system is one that gives 
the consumer a combination of information about child restraints' ease 
of use and dynamic performance, with the dynamic performance obtained 
through higher-speed sled testing and/or in-vehicle NCAP testing.
    Section 14(g) of TREAD set forth the requirement to establish a CRS 
rating consumer information program. Other sections of TREAD mention 
providing ``consumer information on the physical compatibility of child 
restraints and vehicle seats on a model-by-model basis'' [14(b)(4)] and 
``whether to include child restraints in each vehicle crash tested 
under the New Car Assessment Program'' [14(b)(9)]. From this, the 
agency has tentatively concluded that a rating program that rates the 
CRS and/or the vehicle would satisfy the Congressional mandate.
    Table 1 shows six factors that were felt to be of primary 
importance in determining an appropriate CRS rating system. From this 
table, it is clear that a single rating alternative does not achieve 
all of the six objectives. Ease of use is the only option that 
potentially addresses misuse, and thus the agency feels that such a 
rating option could have a substantial impact on proper CRS use. 
However, an Ease of Use rating would not provide information on dynamic 
performance. Given the advantages and disadvantages regarding the 
various dynamic performance rating options described in the preceding 
sections, the agency has tentatively

[[Page 56157]]

concluded that higher-speed sled tests and/or in-vehicle NCAP testing 
would be preferable methods for providing dynamic performance 
information. Comments on which dynamic rating option, individually or 
in conjunction with the Ease of use rating, would provide the most 
useful information to the consumer as well as improve overall child 
safety are requested. Comments are also requested on whether or not the 
agency should consider conducting both higher-speed sled tests and in-
vehicle NCAP testing in conjunction with the Ease of use rating. If, in 
addition to the Ease of use rating, the agency were to provide both a 
higher-speed sled test rating for the child seat, and an in-vehicle 
NCAP rating of child occupant protection for the vehicle, would such 
information be meaningful for the consumer and worth the costs of 
administering the tests given the relative advantages and disadvantages 
of each? Also, if the agency were to implement an in-vehicle NCAP 
rating system, what child seat(s) should be used? Should the agency 
select child seat(s) from those specified in FMVSS No. 208? If so, 
should a procedure be based upon only one of these seats to standardize 
the child seat for all vehicles? If only one child seat is selected, 
what criteria should the agency use in selecting that seat? If not, is 
the protocol provided below preferable?
Possible Assessment Protocol for Higher-speed Sled Tests
    The following assessment protocol for testing and rating a child 
restraint in a higher-speed sled test is proposed if this dynamic 
procedure is selected.

--The agency would select child restraints for higher-speed sled tests 
so that most of the forward-facing child restraint models sold in the 
United States would undergo the higher-speed sled test for the 
evaluation of child restraints.
--Forward-facing child restraints would be placed on the same seat used 
for the compliance test. The restraint would be secured to the using 
the LATCH system. Installation instructions prescribed by the 
manufacturer of the child restraint would be followed.
--Hybrid III three-year-old and/or 12 month CRABI dummies would be 
placed in the child restraint for assessing injury. Dummy selection 
would depend upon the weight rating of the CRS. Child restraints 
designed for weight classifications covering both dummies would be 
tested with both and provided two rating. Head and chest accelerations 
would be recorded. The injury assessment reference values developed for 
child dummies in FMVSS No. 208 would be calculated.
--A five star rating would be applied to the dynamic performance using 
the HIC and chest acceleration to compute probability of injury as was 
illustrated in Figure 7.
--Child restraints would also be examined for structural integrity 
after the test. The physical structural integrity evaluation specified 
in the FMVSS No. 213 procedure would be applied.
--A rating for the CRS would be made available to the public in a 
manner similar to that now employed for other NCAP vehicle results.
Possible Assessment Protocol for NCAP Frontal Vehicle Testing
    The following assessment protocol for testing and rating vehicles 
with child restraints for in-vehicle NCAP is proposed if this dynamic 
procedure is selected.

--After the agency has selected the vehicles for frontal NCAP testing, 
each vehicle manufacturer would be asked for a recommendation of at 
least three forward-facing child restraints for children up to a weight 
of 50 pounds for each vehicle to be tested. At least one of the vehicle 
manufacturer-recommended child restraints must have a retail price of 
less than $60. A different CRS manufacturer must make each of the three 
restraints. An integrated child restraint may be one of the recommended 
child restraints. Each of the three recommended child restraints must 
be currently available in the market. If the vehicle manufacturer chose 
not to make a recommendation, then the agency would choose from any 
child restraint available in the market.
--One of the three vehicle manufacturer-recommended child restraints 
would be selected for use in the crash test. A procedure that uses the 
child restraint in the LATCH configuration would be followed. The 
agency would follow both the vehicle and child restraint manufacturers' 
recommendations for installing the child restraint in the passenger 
vehicle. Our expectation is that the vehicle manufacturer's set-up 
instructions would be consistent with the installation instructions for 
the child restraint.
--A forward-facing child restraint would be placed in the seat directly 
behind the right front passenger, i.e., on the right-hand side of the 
second row of seats. A 3-year-old Hybrid III dummy would be placed in 
the child restraint system. Head and chest accelerations would be 
recorded. The injury assessment reference values developed for child 
dummies in FMVSS No. 208 would be calculated. If the vehicle is 
equipped with a built in child seat, testing could be conducted with 
either or both the built in and add on child restraints.
--A five star rating would be applied to the dynamic performance using 
the HIC and chest acceleration to compute probability of injury as was 
illustrated in Figure 7.
--Child restraints would also be examined for structural integrity 
after the test. The physical structural integrity evaluation specified 
in the FMVSS No. 213 procedure would be applied.
--A rating for child protection would be added to the vehicle frontal 
NCAP ratings. In the process of developing the proposed rating system, 
the agency 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. Child restraints are not currently compliance-tested under 
lateral loading conditions. Although lateral test requirements for CRS 
are being proposed in an upgrade to FMVSS No. 213 under a separate 
TREAD rulemaking action, the agency felt that the issue of a possible 
lateral rating should be considered following completion of the FMVSS 
No. 213 upgrade.
    2. The in-vehicle proposed protocol rates only one CRS in the rear 
seat. Due to the very tight schedule available for conducting and 
assessing potential CRS NCAP protocol, the agency elected to 
concentrate on forward-facing child restraints rather than attempt to 
also include rear-facing child restraints and/or booster seats. The 
decision to concentrate on the forward-facing CRS was based on the 
belief that the forward-facing CRS would provide the most meaningful 
information to the consumer, given that development of procedures for 
all three systems could not be accomplished in the short time frame. 
Following incorporation of the forward-facing CRS, the feasibility of 
incorporating a rating which included rear-facing CRS and/or booster 
seats would subsequently be considered.
    3. The in-vehicle proposed rating uses only the three-year-old 
dummy. Again, due to the very tight schedule, the agency felt it 
necessary to collect as much data as possible for one dummy and that 
the three-year-old would provide the most meaningful information for 
the consumer. Upon

[[Page 56158]]

incorporation of a child restraint system rating with the three-year-
old dummy, consideration would subsequently be given to dummies of 
other sizes.
    4. Higher-speed testing which was conducted by the agency used only 
Hybrid III three-year-old dummies. However, if the higher-speed dynamic 
performance is selected, utilization of both twelve month CRABI and 
Hybrid III three year old dummies would be proposed.
    Comments on these decisions and the agency's rationale for them are 
requested. Also, comments regarding possible future extension of the 
CRS NCAP rating to side impact, other types of CRS, and dummy size are 
also sought.

VI. Combined Child Restraint Rating

    NHTSA is not currently planning to do an overall summary rating 
combining ease of use and dynamic performance. To date, we have not 
been able to develop an acceptable methodology for a summary rating. 
However, we request comments and suggestions on this issue.

VII. Distribution

    NHTSA currently produces a print brochure titled Buying a Safer Car 
that provides NCAP ratings and safety feature information for new 
vehicles. Because new motor vehicles are commonly introduced in the 
fall, NHTSA produces the first printing for each model year in the 
fall. Because NCAP testing cannot begin until the vehicles are 
available from dealers, this printing only has test results for 
vehicles which were tested in previous model years and which have not 
changed significantly. A second printing is produced in the spring 
after the completion of the NCAP testing program.
    NHTSA also publishes an annual brochure titled Buying a Safer Car 
for Child Passengers. This brochure provides new vehicle safety 
features and other information relevant to children. The brochure 
identifies vehicles that have built-in child seats, manual air bag cut-
off switches, rear center rear seat lap/shoulder belts, rear-seat 
adjustable upper belts, and interior trunk releases.
    If NHTSA were to elect to have a rating based solely on a vehicle 
equipped with a child restraint, the existing brochures would be an 
appropriate venue for the distribution of the ratings. If NHTSA chooses 
another rating system, we believe new printed information about child 
restraint ratings will be needed. The current brochures are a helpful 
model for new print information about child restraint ratings. However, 
unlike vehicles, child restraint models do not tend to change on an 
annual cycle. Therefore, NHTSA would have to pick a date and only 
include in a print brochure child restraints that are available in the 
marketplace at that time. Representatives from ICBC have indicated that 
the largest concentration of new child restraint introductions seems to 
occur in Canada in the months of May and June. To assist us in timing a 
print brochure, NHTSA requests comments on whether this timing is also 
accurate for the United States.
    NHTSA notes that a print brochure could be used in addition to our 
web site. Unlike printing, this site can be updated on a continuous 
basis. Therefore, NHTSA could test child restraints as they became 
available and add new models to the web site when testing was complete.

VIII. Submission of Comments

How Do I Prepare and Submit Comments?

    Your comments must be written and in English. To ensure that your 
comments are correctly filed in the Docket, please include the docket 
number of this document in your comments.
    Your comments must not be more than 15 pages long. (49 CFR 553.21). 
We established this limit to encourage you to write your primary 
comments in a concise fashion. However, you may attach necessary 
additional documents to your comments. There is no limit on the length 
of the attachments.
    Please submit two copies of your comments, including the 
attachments, to Docket Management at the address given above under 
ADDRESSES.

How Can I Be Sure That My Comments Were Received?

    If you wish Docket Management to notify you upon its receipt of 
your comments, enclose a self-addressed, stamped postcard in the 
envelope containing your comments. Upon receiving your comments, Docket 
Management will return the postcard by mail.

How Do I Submit Confidential Business Information?

    If you wish to submit any information under a claim of 
confidentiality, you should submit three copies of your complete 
submission, including the information you claim to be confidential 
business information, to the Chief Counsel, NHTSA, at the address given 
above under FOR FURTHER INFORMATION CONTACT. In addition, you should 
submit two copies, from which you have deleted the claimed confidential 
business information, to Docket Management at the address given above 
under ADDRESSES. When you send a comment containing information claimed 
to be confidential business information, you should include a cover 
letter setting forth the information specified in our confidential 
business information regulation. (49 CFR Part 512.)

Will the Agency Consider Late Comments?

    We will consider all comments that Docket Management receives 
before the close of business on the comment closing date indicated 
above under DATES. To the extent possible, we will also consider 
comments that Docket Management receives after that date.
How Can I Read the Comments Submitted by Other People?
    You may read the comments received by Docket Management at the 
address given above under ADDRESSES. The hours of the Docket are 
indicated above in the same location.
    You may also see the comments on the Internet. To read the comments 
on the Internet, take the following steps:

I. Go to the Docket Management System (DMS) Web page of the Department 
of Transportation (http://dms.dot.gov/).
II. On that page, click on ``search.''
III. On the next page (http://dms.dot.gov/search/), type in the four-
digit docket number shown at the beginning of this document. Example: 
If the docket number were ``NHTSA-1999-1234,'' you would type ``1234.'' 
After typing the docket number, click on ``search.''
IV. On the next page, which contains docket summary information for the 
docket you selected, click on the desired comments.


[[Page 56159]]


    You may download the comments. However, since the comments are 
imaged documents, instead of word processing documents, the downloaded 
comments are not word searchable.
    Please note that even after the comment closing date, we will 
continue to file relevant information in the Docket as it becomes 
available. Further, some people may submit late comments. Accordingly, 
we recommend that you periodically check the Docket for new material.

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