Section One: Reformulating the TREAD Objective

Under Section 14(i) of the Transportation Recall Enhancement, Accountability, and Documentation (TREAD) Act, the Secretary of Transportation is required to, "…develop [a] 5 year strategic plan to reduce deaths and injuries caused by failure to use the appropriate booster seat in the 4 to 8 year old age group by 25 percent." While it is highly desirable to "...reduce fatalities and injuries caused by failure to use the appropriate booster seat in the 4 to 8 year old age group by 25 percent," NHTSA does not believe this to be an attainable objective. This belief was corroborated by an examination of 10 years of fatal and injury crash data involving 4- to 8-year-old passengers. ² The examination of the crash data revealed that:

• Virtually 100 percent restraint use by booster seat age children would be needed to achieve a 25 percent reduction in the total number of fatalities. Achieving 100 percent use within a 5-year time frame is an unrealistic objective and,

• Even achieving 100 percent restraint use would not result in a 25 percent reduction in the number of children injured. Only about 21 percent of children 4-to 8-years old are reported as unrestrained in non-fatal crashes. While this high use rate may reflect the over-reporting of restraint use common in police-reported data, the number of unrestrained children is insufficient to produce a 25 percent reduction in the number of injured children, even if all were restrained.

NHTSA believes that its programs should focus on attainable objectives. Because the crash data show that a program designed solely to increase use of belt-positioning booster seats would not result in a 25 percent reduction in the number of booster seat age children killed and injured in passenger vehicle crashes, it would not be an attainable objective.

The Agency's research also shows that the lack of any restraint use in a motor vehicle is the greatest risk to 4- to 8-year-old passengers. In 2000, almost half of the 4- to 8-year-old passengers killed in crashes were reported as totally unrestrained. In addition to the high number of fatalities, thousands of children were seriously injured in crashes because they were unrestrained. NHTSA research has shown that the use of adult belts alone by a booster seat age child reduces his/her risk of fatality by 48 percent (in the back seat) and that the use of a belt-positioning booster seat reduces the child's risk of being killed in a crash by 54 percent. ³ This 6 percent improvement, though significant, is marginal when compared to the 48 percent gain realized by restraining a child in a lap/shoulder belt alone over not restraining the child at all. Thus, while it must be kept in mind that increasing booster seat use to 100 percent is NHTSA's ultimate goal, the greatest gain in occupant protection for this age group would be obtained by getting unrestrained child passengers into any form of occupant restraint.

Therefore, the objective of NHTSA's program will be to reduce the number of unrestrained booster seat age children (placing them into any form of occupant restraint), while emphasizing that booster seats are the best and proper restraints for children in this age group. Such a program, while not completely departing from the objectives of the TREAD Act, reformulates them.

To measure progress towards the success of a program to eliminate non-restraint use among 4- to 8-year-olds and promote booster seat use, NHTSA proposes the following goal:

2006 Goal: Increase restraint use (of any type) by 4- to 8-year-old occupants to 85 percent (from 63 percent in 1999), as measured by the National Occupant Protection Use Survey (NOPUS).

An increase in restraint use (booster seat or otherwise) should result in a reduction in the number of 4- to 8-year-old children killed or seriously injured in motor vehicle crashes. NHTSA's program, therefore, will include the following goals to track the effect of increasing restraint use on fatalities and injuries to booster seat age children:

Goal for 2006: Reduce the percentage of unrestrained 4- to 8-year-old occupants that die in passenger vehicle crashes to 39 percent (from 63 percent in 1999), as measured by the Fatality Analysis Reporting System (FARS).

Goal for 2006: Reduce the number of moderate to severe injuries per 100,000 4- to 8-year-old passenger vehicle occupants involved in motor vehicle crashes to 1,050 (from 1,509 in 1999), as measured by the National Automotive Sampling System (NASS) Crashworthiness Data System (CDS). ⁴

Goal for 2006: Reduce the number of incapacitating injuries 4- to 8-year-old passenger vehicle occupants per 100,000 to 5,700 (from 6,540 in 1999), as measured by the NASS System General Estimate System (GES). ⁵

Persuading parents who do not restrain their children at all to place them in any kind of occupant restraint would reduce the number of children killed or seriously injured. Providing additional protection to these children from belt-positioning booster seats would further enhance their overall safety.

² Based on data used in the report, Fatalities and Injuries to 0-8 Year Old Passenger Vehicle Occupants Based on Impact Attributes, DOT HS 809 410, March 2002.

³ Based on data used in the report, Effectiveness of Lap/Shoulder Belts in the Back Outboard Seating Positions, DOT HS 808 945, June 1999.

⁴ The NASS CDS examines medical records and classifies all injuries to occupants by severity – AIS 1 (least severe) to AIS 6 (most severe or non-survivable).

⁵ The NASS GES uses the KABCO scale: K- killed, A- serious or incapacitating, B- non-incapacitating, C- possible injury or complaint of pain, O- not injured.

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