Why NHTSA revised its position on child restraint re-use.

    The National Highway Traffic Safety Administration (NHTSA) recently revised its advice to parents regarding replacement of child safety seats that have been involved in a crash. This policy change was made to ensure that parents or caregivers continue to correctly restrain their child following a minor crash and reduce the financial burden of unnecessary child safety seat replacement. This letter is to alert you to the change and explain why it is necessary.

    Over the past several months, NHTSA, in cooperation with the National Child Passenger Safety Board and others, revised the child passenger safety technician training curriculum to include current issues and changes regarding installation of child safety seats. As part of this process, the agency reviewed its internal policies and recommended practices to ensure consistency and maximum customer service to the motoring public.

    As we conducted this review, NHTSA became aware of research indicating that child safety seats are very robust and continue to provide high levels of crash protection even after being involved in a crash test. Considering this evidence of child seat performance after an impact, and the fact that minor low-speed crashes vastly outnumber more serious collisions, the agency recognized that guidance is needed to assist parents and caregivers in determining what type of crash warrants automatic child seat replacement.

    The agency continues to recommend that parents and caregivers check with the child seat manufacturer with regard to performance, operation and installation of their child restraint. However, NHTSA also recognizes that minor crashes are unlikely to affect child seat performance. Further, the agency is concerned that advising replacement of a child safety seat after a minor crash creates a financial burden on some parents and could lead to parents or caregivers using no restraint system while seeking a replacement or discarding the seat without replacing it.

    The agency conducted a thorough review of literature on the performance of child safety seats in crashes. A study published by the Canadian Association of Road Safety Professionals examined results of nearly 450 sled tests of child safety seats that were performed at approximately 10 mph. Visual seat inspection and x-ray analysis revealed no damage (for more information see www.carsp.ca/publications/newsletter/sn_0001.pdf). A second study, published by the Society of Automotive Engineers (SAE 2001-01-0123), examined the performance of six infant and six toddler restraints that were each exposed to two or more 30 mph offset frontal crash tests. While minor damage was apparent on many of the seats following the first crash test, subsequent tests showed that the seats still met all relevant requirements of the Federal Motor Vehicle Safety Standards (FMVSS).

    NHTSA believes that existing evidence is sufficient to warrant a revision to its public advice on the issue. The agency continues to advise parents and caregivers that child safety seats should be replaced if they have been involved in a moderate or severe crash. However, NHTSA now believes that child safety seats are sufficiently durable that they do not have to be automatically replaced following a minor crash. Common sense should be used in deciding whether to replace such a seat.

    To assist parents or caregivers in determining if a crash is minor, NHTSA developed a list of criteria. It should be noted that these criteria were designed to provide a wide margin of safety between cases for which reuse is recommended and those crashes that might reasonably be expected to affect future child seat performance.

    A crash is considered to be minoróand the child seat involved in it is safe for reuseóif it meets ALL of the following criteria:

    1. A visual inspection of the child safety seat, including inspection under any easily movable seat padding, does not reveal any cracks or deformation that might have been caused by the crash;

    2. The vehicle in which the child safety seat was installed was capable of being driven from the scene of the crash;

    3. The vehicle door nearest the child safety seat was undamaged;

    4. There were no injuries to any of the vehicle occupants; and;

    5. The air bags (if any) did not deploy.

    Crashes that meet ALL of these criteria are much less severe than the dynamic test used in compliance tests of FMVSS No. 213 "Child Restraint Systems," and are highly unlikely to affect future child safety seat performance. Therefore, parents and caregivers can be confident that child restraints involved in these minor crashes will continue to provide a high level of protection.

    For those situations where the parent or caregiver determines that any of these criteria has not been met, or if they are unsure that damage to the seat has occurred, NHTSA advises parents or caregivers to contact their automobile insurance company regarding its policy on replacement of seats.

    I want to thank you for your commitment to educating parents and caregivers on the importance of making informed decisions regarding child safety seat use. We are committed to maintaining policies that are science-based and data driven. Stakeholders with data that address post-crash reuse of child safety seats are encouraged to provide this information to the agency. We look forward to maintaining a dialogue with you as we continue to collect additional data and research on this issue.

    Sincerely yours,

    Jeffrey P. Michael
    Director, Office of Impaired Driving
        and Occupant Protection
    Program Development and Delivery