Anthropomorphic Test Devices; Q3s 3-Year-Old Child Side Impact Test Dummy; Incorporation by Reference

Published date03 November 2020
Citation85 FR 69898
Record Number2020-21478
SectionRules and Regulations
CourtNational Highway Traffic Safety Administration
69898
Federal Register / Vol. 85, No. 213 / Tuesday, November 3, 2020 / Rules and Regulations
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety
Administration
49 CFR Part 572
[Docket No. NHTSA–2020–0088]
RIN 2127–AL04
Anthropomorphic Test Devices; Q3s 3-
Year-Old Child Side Impact Test
Dummy; Incorporation by Reference
AGENCY
: National Highway Traffic
Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION
: Final rule.
SUMMARY
: This final rule amends
NHTSA’s regulation on
anthropomorphic test devices (ATD) to
add design and performance
specifications for a test dummy
representing a 3-year-old child, called
the ‘‘Q3s’’ test dummy. The Q3s is an
instrumented dummy that can assess
the performance of child restraint
systems in protecting small children in
side impacts. Adding the Q3s provides
NHTSA a new test device that can be
used to improve side impact protection
for children.
DATES
: The effective date of this final
rule is: January 4, 2021. The
incorporation by reference of the
publications listed in the rule has been
approved by the Director of the Federal
Register as of January 4, 2021.
Petitions for reconsideration: Petitions
for reconsideration of this final rule
must be received not later than
December 18, 2020. The petition will be
placed in the docket. Anyone is able to
search the electronic form of all
documents received into any of the
agency’s dockets by the name of the
individual submitting the comment (or
signing the comment, if submitted on
behalf of an association, business, labor
union, etc.).
ADDRESSES
: Petitions for reconsideration
of this final rule must refer to the docket
and regulatory information number
(RIN) set forth above and be submitted
to the Administrator, National Highway
Traffic Safety Administration, 1200 New
Jersey Avenue SE, Washington, DC
20590. Note that all petitions received
will be posted without change to http://
www.regulations.gov, including any
personal information provided. To
facilitate social distancing due to
COVID–19, please email a copy of the
petition to nhtsa.webmaster@dot.gov.
Privacy Act: In accordance with 5
U.S.C. 553(c), DOT solicits comments
from the public to better inform its
rulemaking process. DOT posts these
comments, without edit, to
www.regulations.gov, as described in
the system of records notice, DOT/ALL–
14 FDMS, accessible through
www.dot.gov/privacy. In order to
facilitate comment tracking and
response, the agency encourages
commenters to provide their name, or
the name of their organization; however,
submission of names is completely
optional. Whether or not commenters
identify themselves, all timely
comments will be fully considered. If
you wish to provide comments
containing proprietary or confidential
information, please see below.
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
under
FOR FURTHER INFORMATION
CONTACT
. In addition, you should
submit a copy, from which you have
deleted the claimed confidential
business information, to Docket
Management at the address given above.
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 NHTSA’s
confidential business information
regulation (49 CFR part 512). To
facilitate social distancing due to
COVID–19, NHTSA is treating
electronic submission as an acceptable
method for submitting confidential
business information (CBI) to the agency
under 49 CFR part 512. https://
www.nhtsa.gov/coronavirus.
FOR FURTHER INFORMATION CONTACT
: For
technical issues: Peter Martin, NHTSA
Office of Crashworthiness Standards
(telephone 202–366–5668) (fax 202–
493–2990), email Peter.Martin@dot.gov.
For legal issues: Deirdre Fujita, NHTSA
Office of Chief Counsel (telephone 202–
366–2992) (fax 202–366–3820), email
Dee.Fujita@dot.gov. Mailing address:
National Highway Traffic Safety
Administration, U.S. Department of
Transportation, 1200 New Jersey
Avenue SE, West Building, Washington,
DC 20590.
SUPPLEMENTARY INFORMATION
:
Table of Contents
I. Executive Summary
II. Background
a. 2013 Part 572 NPRM and 2014 FMVSS
No. 213 NPRM
b. Comments on the 2013 Part 572 NPRM
III. Summary of Differences Between the
NPRM and This Final Rule
a. Acceptance Criteria for the Qualification
Tests
b. Qualification Test Procedures
c. Engineering Drawings and the
Procedures for Assembly, Disassembly,
and Inspection (PADI)
IV. Response to Comments (Part I) on
Developing the Regulation
a. Copyright and Patent Issues
b. Dummy Availability and Associated
Data
c. Developmental Stage of the Dummy
d. Biofidelity
e. Repeatability and Reproducibility (R&R)
V. Post-NPRM Test Program Overview
a. Test Locations
b. Other Data
c. Component Tests in the Post-NPRM Test
Program
d. Controlling Variability
VI. Results of the Post-NPRM Test Program
and the Final Acceptance Criteria for the
Qualification Tests
a. Background
b. Process for Setting the Final
Qualification Criteria
c. Head
d. Neck
e. Lumbar Column
f. Shoulder
g. Thorax
h. Pelvis
VII. Response to Comments (Part II) on the
Dummy Qualifications and Test
Procedures
a. Head Qualification
b. Neck Qualification
c. Arm Position
VIII. Post-NPRM Data From Humanetics
a. Qualification Tests
b. Mass and Anthropometry Measurements
IX. Drawing Package and PADI
X. Other Issues
a. Durability
b. Consideration of Alternatives
XI. Rulemaking Analyses and Notices
I. Executive Summary
This final rule amends NHTSA’s
regulation on anthropomorphic test
devices (49 CFR part 572) by adding a
new Subpart W that sets forth design
and performance specifications and
qualification tests for a test dummy
representing a 3-year-old child, called
the Q3s test dummy. The Q3s is an
instrumented dummy that can assess
the performance of child restraint
systems in protecting small children in
side impacts. The Q3s weighs 14.5
kilograms (kg) (32.0 pounds) and has a
seated height of 556 millimeters (mm),
and is representative of a 50th
percentile 3-year-old child. The Q3s
dummy’s main parts (head, thorax,
neck, shoulder, spine, abdomen, pelvis,
and relevant instrumentation) and
biofidelity are described in detail in a
November 21, 2013 notice of proposed
rulemaking (NPRM) preceding this final
rule (78 FR 69944, 69946). NHTSA
plans to use the Q3s test dummy in a
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NPRM to amend Federal Motor Vehicle Safety
Standard (FMVSS) No. 213, ‘‘Child restraint
systems,’’ January 28, 2014, 79 FR 4570.
2
Test dummies specified in 49 CFR part 572 are
subjected to a series of tests, called ‘‘qualification
tests,’’ to ensure that their components are
functioning properly. Conformity to the acceptance
criteria for the qualification tests qualify the
dummy as an objective and suitable test device for
the assessment of occupant safety in compliance
tests specified in the FMVSSs. Conformity assures
that the dummy can respond properly in the
compliance test, while non-conformance indicates
the need for adjustment, repair or replacement.
Qualification tests also monitor the response of
components that may tend to deteriorate over time.
For each test, certain dummy sensors and signal
characteristics (such as the magnitude and timing)
have been specified as qualification targets. By
monitoring these sensors, the qualification tests
assure that the dummy is functioning properly.
Loose or damaged dummy hardware is often
manifested in a signal that does not conform to the
qualification targets, thus indicating that dummy
maintenance may be needed. Conformity also
assures that the sensors themselves are working
properly.
3
The parts list, engineering drawings, and the
PADI for the Q3s are available for examination in
the docket for this final rule.
4
The additional data also led to NHTSA’s making
some technical modifications to the proposed part
572 specifications, i.e., NHTSA removed the
requirement for the pubic load in the pelvis impact
test, revised aspects of the neck and lumbar tests,
and corrected some of the drawings for the dummy.
The agency discusses and lists the technical
changes from the NPRM to this final rule below in
this preamble.
proposed side impact test for child
restraints.
1
This final rule incorporating the Q3s
into 49 CFR part 572 standardizes
NHTSA’s specifications on the dummy
for testing and research purposes.
Subpart W specifies a set of
qualification tests and acceptance
criteria for the Q3s’s head, neck,
shoulder, thorax, lumbar, and pelvis,
assessing 35 response mechanisms for
the dummy.
2
Additionally, Subpart W
incorporates by reference a technical
data package (TDP) for the Q3s
consisting of a set of engineering
drawings, a parts list, and a user’s
manual that has procedures for
assembly, disassembly, and inspection
(PADI) of the dummy.
3
Q3s dummies
manufactured to meet the acceptance
criteria for the qualification tests and
the TDP will be uniform in their design,
construction, and response to impact
forces.
As discussed in the November 21,
2013 NPRM, the Q3s was found to
exhibit repeatable performance in CRS
side impact sled testing and in
component-level qualification testing.
However, NHTSA acknowledged in the
NPRM that the agency’s findings in the
proposed rule were based on only a few
Q3s dummies then in existence. At the
time of publication of the NPRM, the
Q3s was a proprietary product owned
by Humanetics Innovative Solutions
Inc. (HIS), and HIS was the only source
from which to obtain the dummy.
NHTSA developed the Q3s NPRM based
on NHTSA’s testing experiences with
four units that the agency had
purchased from HIS. In the NPRM, the
agency expressed a desire to examine
more data on more dummies from
multiple test labs and an expectation
that it will ‘‘continue to collect
qualification data’’ and ‘‘will examine
all qualification data provided to us by
commenters.’’ 78 FR at 69959.
NHTSA received comments on the
Q3s NPRM from the Juvenile Products
Manufacturers Association (JPMA),
Graco Children’s Products, Inc. (Graco),
Dorel Juvenile Group (Dorel), and HIS.
Several commenters said they could not
obtain the Q3s dummies from the
dummy manufacturer HIS and so had
little or no information about the ATD.
Some expressed concern that the
dummy’s repeatability and
reproducibility of performance were not
assessed across various test facilities.
Some asked for more data from tests
with more dummies to round out the
qualification corridors. In addition, the
commenters made several technical
comments relating to the ATD.
Subsequently, in mid-2014, HIS began
delivery of new Q3s dummies to end-
users that included NHTSA, CRS
manufacturers, and testing laboratories.
In 2014 and 2015, to obtain more data
on the Q3s, NHTSA undertook
systematic testing of the new units from
HIS, contracting with laboratories to
carry out a full series of qualification
tests with six Q3s dummies. The units
included three of the agency’s original
four dummies together with new
dummies manufactured in 2014.
The agency set up a series of
experiments designed to evaluate the
performance of the Q3s in several
different labs, examining the
repeatability and reproducibility of the
Q3s’s performance. NHTSA designed
the test program to assess all sources of
variability, to quantify the degree of
variability, determine its acceptability,
and assess whether the underlying
cause was a non-uniform test procedure
at a lab (and among the labs), an aspect
of dummy design, or the dummy
manufacturer’s production of Q3s units.
Data from the tests were used to finalize
the acceptance criteria for the
qualification tests and ensure that a high
level of repeatability and reproducibility
(R&R) will be maintained henceforth.
4
For this final rule, HIS has removed
all proprietary rights to the Q3s. Single-
source restrictions were in place during
the NPRM stage (HIS retained rights to
manufacture the dummy). However, the
dummy drawings and designs are now
free of any restrictions. This includes
restrictions on their use in fabrication
and in building computer simulation
models of the dummy.
Benefits and Costs
The benefits associated with this
rulemaking cannot be quantified. The
incorporation of the test dummy into 49
CFR part 572, the first-ever child test
dummy incorporated by NHTSA for use
in side impacts, has the potential to
significantly improve child passenger
safety in motor vehicles. Adopting the
Q3s gives NHTSA a tool to assess the
performance of dynamic side impact
protection requirements for child
restraints using an ATD representative
of children for whom the CRS is
designed, and quantitatively evaluate
the effectiveness of CRSs in preventing
or attenuating head and chest impacts in
side impacts. In addition, the
availability of this dummy in a
regulated format will provide a test tool
that can potentially be used with other
products designed to benefit children in
side impacts.
This final rule does not impose any
requirements on anyone. NHTSA has
proposed to use the Q3s in its
compliance testing of the FMVSS No.
213 test under development, but even
following adoption of the test,
manufacturers would not be required to
use the Q3s or assess the performance
of their products in the manner
specified in the standard. Child restraint
manufacturers would be affected by this
final rule only if they choose to use the
Q3s to test their products.
For entities choosing to own the Q3s,
NHTSA estimates that the estimated
cost of an uninstrumented Q3s dummy
is approximately $50,000.
Instrumentation installed within the
dummy needed to perform the
qualification in accordance with part
572, subpart W, adds approximately
$20,000, for a total cost of about
$70,000.
Summary of Decision
The data presented in the 2013 NPRM
and obtained in NHTSA’s post-NPRM
test program demonstrate that the Q3s is
a valuable tool for use in side impact
testing. Adopting the Q3s into 49 CFR
part 572 enhances NHTSA’s efforts to
reduce unreasonable risks posed by side
crashes to children.
II. Background
a. 2013 Part 572 NPRM and 2014
FMVSS No. 213 NPRM
On November 21, 2013, NHTSA
published an NPRM proposing design
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Section 31501(a) of Subtitle E, ‘‘Child Safety
Standards,’’ of MAP–21 (July 6, 2012) (Pub. L. 112–
141).
and performance specifications and
qualification tests for the Q3s, a new test
dummy representative of a 3-year-old
child for use in side impact testing (78
FR 69944). On January 28, 2014,
NHTSA published an NPRM proposing
to amend FMVSS No. 213 to add a new
side impact test in which the Q3s would
be used. The proposed side impact test
applies to CRSs designed for children
weighing up to 18 kg (40 pounds) (79 FR
4570). The proposal responds to a
statutory mandate in the ‘‘Moving
Ahead for Progress in the 21st Century
Act’’ (MAP–21),
5
that NHTSA ‘‘issue a
final rule amending Federal Motor
Vehicle Safety Standard Number 213 to
improve the protection of children
seated in child restraint systems during
side impact crashes.’’ These two NPRMs
are referred to herein as the part 572
NPRM and the FMVSS No. 213 NPRM,
respectively.
b. Comments on the 2013 Part 572
NPRM
NHTSA received comments on the
part 572 NPRM from HIS, Graco
Children’s Products, Inc. (Graco), Dorel
Juvenile Group, Inc. (Dorel), and the
Juvenile Products Manufacturers
Association (JPMA). Some of the
comments on the FMVSS No. 213
NPRM discussed subjects pertaining to
the part 572 NPRM, which NHTSA
discusses in this document as
appropriate. The commenters on the
FMVSS No. 213 NPRM include Evenflo
Company, Inc. (Evenflo), Britax Child
Safety, Inc. (Britax), Consumers Union,
Advocates for Highway and Auto Safety
(Advocates), and Transport Research
Laboratory, UK (TRL).
Commenters on the part 572 NPRM
discussed issues related to the following
main areas: single source and patents;
dummy and qualification data
availability, biofidelity; repeatability
and reproducibility of results (R&R);
qualification test corridors, drawing
errors; and test procedure protocols.
These issues and NHTSA’s responses to
the comments are discussed below in
this preamble.
III. Summary of Differences Between
the NPRM and This Final Rule
a. Acceptance Criteria for the
Qualification Tests
A comparison of the acceptance
criteria for the qualification tests (or
‘‘qualification limits’’) in the NPRM
versus the final rule is summarized in
Table 1. All changes from the NPRM are
discussed below in this preamble. The
velocities and acceleration pulses of the
impacting pendulums, which ensure
that qualification test conditions are
uniform, are unchanged from the
NPRM.
T
ABLE
1—Q3
S
Q
UALIFICATION
L
IMITS
[NPRM vs. final rule]
Test Measurement Units NPRM Final rule
Head—Frontal .......................... Resultant acceleration ................................................................. G ............ 250–297 ......... 255–300.
Off-axis acceleration (Ay) ............................................................ G ............ ¥20 to +20 .... ¥15 to +15.
Head—Lateral ........................... Resultant acceleration ................................................................. G ............ 113–140 ......... 114–140.
Off-axis acceleration (Ax) ............................................................ G ............ ¥20 to +20 .... ¥15 to +15.
Neck—Flexion .......................... Maximum rotation ........................................................................ deg ......... 70–82 ............. 69.5–81.0.
Time of max rotation .................................................................... msec ...... 55–63 ............. no req.
Peak moment (My) ...................................................................... N-m ........ 41–51 ............. 41.5–50.7.
Time of peak My .......................................................................... msec ...... 49–62 ............. note 1.
Decay time to 0 from peak angle ................................................ msec ...... 50–54 ............. 45–55.
Neck—Lateral ........................... Maximum rotation ........................................................................ deg ......... 77–88 ............. 76.5–87.5.
Time of max rotation .................................................................... msec ...... 65–72 ............. no req.
Peak moment (Mx) ...................................................................... N-m ........ 25–32 ............. 25.3–32.0.
Time of peak Mx .......................................................................... msec ...... 66–73 ............. note 1.
Decay time to 0 from peak angle ................................................ msec ...... 63–69 ............. 61–71.
Neck—Torsion .......................... Maximum rotation ........................................................................ deg ......... 75–93 ............. 74.5–91.0.
Time of max rotation .................................................................... msec ...... 91–113 ........... no req.
Peak moment (Mz) ...................................................................... N-m ........ 8–10 ............... 8.0–10.0.
Time of peak Mz .......................................................................... msec ...... 85–105 ........... note 1.
Decay time to 0 from peak angle ................................................ msec ...... 84–103 ........... 85–102.
Shoulder ................................... Lateral displacement .................................................................... mm ......... 16–21 ............. 17.0–22.0.
Peak probe force ......................................................................... N ............ 1240–1350 ..... 1123–1437.
Thorax with Arm ....................... Lateral displacement .................................................................... mm ......... 23–28 ............. 22.5–27.5.
Peak probe force ......................................................................... N ............ 1380–1690 ..... 1360–1695.
Thorax without Arm .................. Lateral displacement .................................................................... mm ......... 24–31 ............. 24.5–30.5.
Peak probe force ......................................................................... N ............ 620–770 ......... 610–754.
Lumbar—Flexion ...................... Maximum rotation ........................................................................ deg ......... 48–57 ............. 47.0–58.5.
Time of max rotation .................................................................... msec ...... 52–59 ............. no req.
Peak moment (My) ...................................................................... N-m ........ 78–94 ............. 78.2–96.2.
Time of peak My .......................................................................... msec ...... 46–57 ............. note 1.
Decay time to 0 from peak angle ................................................ msec ...... 50–56 ............. 49–59.
Lumbar—Lateral ....................... Maximum rotation ........................................................................ deg ......... 47–59 ............. 46.1–58.2.
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The qualification tests have proven reliable and
sound in qualifying the Q3s throughout the
dummy’s developmental stages and in qualifying
virtually all other test dummies specified in part
572.
7
This document can be found in the docket for
this final rule.
T
ABLE
1—Q3
S
Q
UALIFICATION
L
IMITS
—Continued
[NPRM vs. final rule]
Test Measurement Units NPRM Final rule
Time of max rotation .................................................................... msec ...... 50–59 ............. no req.
Peak moment (Mx) ...................................................................... N-m ........ 78–97 ............. 79.4–98.1.
Time of peak Mx .......................................................................... msec ...... 46–57 ............. note 1.
Decay time to 0 from peak angle ................................................ msec ...... 47–59 ............. 48–59.
Pelvis ........................................ Peak pubic load ........................................................................... N ............ 700–870 ......... no req.
Peak probe force ......................................................................... N ............ 1570–1810 ..... 1587–1901.
1
Maximum moment occurs during the time interval while the rotation is within the specified interval.
b. Qualification Test Procedures
The agency made a few adjustments
to the proposed qualification test
procedures, which are summarized in
Table 2 below. (Noteworthy changes are
discussed in this preamble.) For
simplicity, the English units that were
shown in parentheses in the regulatory
text of the NPRM are omitted. The
qualification tests themselves are
essentially unchanged from the NPRM.
6
T
ABLE
2—S
UMMARY OF
R
EVISIONS TO
P
ROCEDURES
Reg. text affected section Description of change
§ 572.212(c)(1) Head drop test ................................................................ Ambient temp. now 20.6–22.2 deg C.
§ 572.213(c)(1)(i) Neck flexion test, §572.213(c)(2)(i) Neck lateral flex-
ion test, § 572.213(c)(3)(i) Neck torsion test, §572.217(c)(1)(i) Lum-
bar flexion test, § 572.217(c)(2)(i) Lumbar lateral flexion test.
Maximum moment now occurs when rotation is within the specified
range.
§ 572.213(b)(3)(ii) Neck torsion test ......................................................... Correction on time = 0 definition.
§ 572.213(c)(2)(ii) Neck lateral flexion test, §572.217(c)(2)(ii) Lumbar
lateral flexion test. Correction on specifying left vs. right mirroring in test setup figures.
§ 572.214(c)(4) Shoulder test, §572.215(c)(4) Thorax with arm tests .... New steps to position arm against thorax.
§ 572.218(a) Pelvis assembly and test procedure, §572.219 Test con-
ditions and instrumentation. Pubic load cell now optional since pubic criterion has been omitted.
§ 572.212(c)(4) Head drop test, Figures W1, W2 .................................... Surface finish: 0.2–2.0 microns RMS.
§ 572.212(c)(2)(ii) Lumbar lateral flexion test ........................................... Headform sagittal plane perpendicular (not parallel) to the motion of
the pendulum.
Figures W6, W7, W8, W11 ...................................................................... Correction on probe mass: Now 3.81 kg.
Throughout regulatory text ....................................................................... English units omitted.
This final rule also corrects the
following errors. The surface finish of
the steel plate used in the head
qualification test was not specified
correctly in the NPRM. The correct
specification is 0.2–2.0 microns root
mean square (RMS). In the lateral
lumbar qualification test, the proposed
regulatory text was unclear in how it
described the orientation of the
headform, so it has been clarified. In
Figures W6, W7, W8, and W11 of the
proposed regulatory text, the probe mass
was labeled incorrectly as 3.85 kg. The
correct value is 3.81 kg.
c. Engineering Drawings and the
Procedures for Assembly, Disassembly,
and Inspection (PADI)
For this final rule, NHTSA has revised
some of the engineering drawings to
address discrepancies between the PADI
and the engineering drawings, and some
inconsistencies HIS noticed between the
drawings it provided NHTSA for
development of the NPRM and the
dummies HIS produced. The changes
are all valued-added revisions that
either correct errors or provide missing
information. They are not alterations
that would change the dummy in any
meaningful way or alter the dummy’s
response in either pre-test qualification
testing or dynamic sled testing with
CRSs. The changes to the drawings and
the PADI are discussed in detail in
Section IX below. A comprehensive
listing of changes is described in the
document, ‘‘Q3s Engineering Drawing
Changes, Rev. J, May 2016.’’
7
The
design of the Q3s is essentially
unchanged.
IV. Response to Comments (Part I) on
Developing the Regulation
a. Copyright and Patent Issues
HIS had certain property rights in the
Q3s engineering drawings during the
notice and comment period of this
rulemaking. As discussed in the NPRM
(78 FR at 69965–69966), during the
notice and comment period, the Q3s
engineering drawings used to fabricate
the dummy were available in the docket
for public review and comment, but
most displayed the HIS name in the title
block with a note restricting copying of
or using the drawings other than for
commenting purposes. NHTSA stated in
the NPRM that the name, note, and all
restrictions associated with the
drawings will be removed at the final
rule stage. Separately, in the NPRM,
NHTSA noted its awareness that a
patent application filed by HIS may
cover certain parts of the Q3s dummy.
Comments Received
NHTSA received several comments
expressing concern about the
intellectual property restrictions on the
dummy. JPMA and Dorel expressed
concern that manufacturers will be
bound to purchase a single-sourced
dummy that is subject to patents and
unregulated price points.
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The patent issue was discussed in the NPRM (78
FR at 69965). Around the time of the NPRM,
NHTSA became aware that HIS had filed a patent
application with the United States Patent and
Trademark Office potentially covering certain parts
of the Q3s dummy. However, the patent eventually
issued—for a rib cage incorporating a polyurethane
material with a type of metal insert—is not used in
the current design. (See U.S. Patent No. 8,840,404
B2, ‘‘Rib cage for assembly for crash test dummy,’’
September 23, 2014.) Accordingly, the patent does
not apply to the version of the Q3s specified in this
final rule.
9
Graco apparently was able to obtain and assess
a new Q3s unit during the reopened comment
period. In a comment on the FMVSS No. 213
NPRM, Graco states that it ‘‘supports the use of the
Q3s ATD for side impact testing based on NHTSA’s
data and confirmed structural performance during
the developmental testing period. Graco has been
using the Q3s in our internal lab for about 6 months
and we are satisfied with the overall performance
of the ATD.’’ ‘‘Feedback Document for FMVSS 213
Side Impact [NPRM], Oct. 1, 2014, p.10.
10
For the NPRM, NHTSA established
qualification requirements based on replicate trials
conducted sequentially on the four NHTSA-owned
Q3s units at VRTC. These tests were used to set the
upper and lower limits of the qualification
corridors. They were initially set as follows: Either
±3 standard deviations from the mean or ten
percent from the mean, whichever was narrower.
Upper and lower bounds were then rounded to the
next whole number away from the mean using three
significant digits such that the final bounds were
slightly wider than the initial bounds. NHTSA
expected to refine and narrow the corridors when
additional data was received on other Q3s units.
11
The adjustments made to the limits and
procedures are listed Tables 1 and 2, supra.
12
In the TDP drawings placed in the NPRM
docket, the HIS build level that HIS identified for
the ATD is reflected in the top level assembly
drawing of the Q3s, 020–0100 (sheet 1). This
drawing shows that HIS marked revision level D in
the title block.
NHTSA Response
The Q3s specified in this final rule is
free of any known copyright or patent
restrictions.
Although copyright restrictions were
in place during the NPRM stage for the
Q3s engineering drawings, all
restrictions are removed for this final
rule. The HIS name and the copyright
note have been removed from all of the
drawings. The dummy drawings are free
of any restrictions and can be used in
dummy fabrication and in building
computer simulation models of the
dummy. Moreover, there are no patents
associated with the Q3s adopted by this
final rule.
8
b. Dummy Availability and Associated
Data
The difficulty in obtaining the Q3s
was brought up in comments to both the
part 572 and the FMVSS No. 213
NPRMs by several commenters. JPMA
indicated it was not possible to learn of
the strengths and limitations of the Q3s,
particularly regarding its repeatability,
reproducibility, and reliability. Graco,
Britax and Evenflo indicated that the
lack of availability of the dummy to the
CRS industry and outside test facilities
has prevented a more complete
evaluation of the dummy across various
test facilities and multiple CRS
manufacturers. Dorel and HIS
commented that more data from more
dummies are needed to round out the
qualification corridors.
NHTSA Response
It is true that the Q3s was generally
unavailable from HIS during the original
comment period which ended April 28,
2014. Because of that unavailability, on
June 4, 2014, NHTSA reopened the
comment period for the FMVSS No. 213
NPRM, granting a petition from JPMA
(79 FR 32211). NHTSA agreed at that
time to reopen the comment period
until October 2, 2014, because the Q3s
was slated to become widely available
from HIS to CRS manufacturers around
mid-2014.
9
Since mid-2014, the dummy
has been available, as HIS has filled
many orders for the Q3s since then.
Regarding the qualification corridors,
NHTSA concurs that development of
qualification corridors is benefitted
when more data are available on the
ATD’s performance in the qualification
tests. In the NPRM for this final rule (78
FR 69959), the agency acknowledged
that there was a limited amount of
qualification data available to NHTSA
for use in setting the proposed
qualification limits.
10
NHTSA stated in
the NPRM that the agency expected to
receive qualification data from end-user
commenters on the dummies tested at
their own laboratories, and that, with
those data, the agency would adjust the
qualification limits to account for a
greater population of dummies, and
modify the test procedures as needed.
11
When data from users were not
forthcoming because of the
unavailability of the Q3s, NHTSA
designed a test program to obtain the
desired data once the dummy became
available. In mid-2014, NHTSA
borrowed three new Q3s units from
existing owners (manufactured by HIS
and delivered to end-users in mid-2014)
to collect comparative qualification data
with their new units. The agency
systematically tested the three new
units, as well as three of the agency’s
older units (manufactured in 2012 or
before and used to develop the 2013
part 572 NPRM). NHTSA hired test labs
to carry out a full series of qualification
tests with the six Q3s dummies.
The agency’s design of experiments
allowed NHTSA to assess the
reproducibility and repeatability of the
dummy and sort out sources of
variability. NHTSA examined variability
due to any non-uniform test procedure
at each lab (and among the labs),
variability in the dummy design, and
variability in HIS’s production of
multiple Q3s units. Using this
systematic process, NHTSA compiled
the additional test data, and those
submitted by other end-users, to set the
acceptance criteria for the qualification
tests for the Q3s. The post-NPRM test
program is discussed at length in this
preamble in Sections V and VI.
c. Developmental Stage of the Dummy
Comment Received
The NPRM referred to the Q3s as the
‘‘build level D’’ iteration of the dummy
(Build D). ‘‘Build level’’ is a term used
by HIS to describe a specific revision
level of the dummy relative to previous
versions it sold. The Q3s drawings that
HIS provided NHTSA prior to the
publication of the NPRM were marked
as revision level D.
12
In its comment, HIS states that it
considers the build level D dummy to be
out of date, and that the dummy
specified in a final rule should be
referred to as ‘‘Build E.’’ HIS states that
not using the ‘‘Build E’’ designation
could cause hardship to its customers
who might not know which version of
the dummy they own, or who might
erroneously assume that their build
level D dummy is up to date when in
fact the ATD ‘‘may be missing key
updates.’’
NHTSA Response
For the reasons set forth below,
NHTSA declines to make the change.
NHTSA does not believe that using the
HIS naming conventions for this final
rule is necessary or warranted. For the
final rule, the agency has adopted a
drawing package that has been
periodically fine-tuned since
publication of the NPRM in 2013
(discussed in sections below), so the
revision level of the Technical Data
Package had been updated from
Revision (Rev.) D to Rev. J. We do not
believe that NHTSA has to name the
Q3s ‘‘Build E’’ to enable HIS to notify
customers who bought Build D units
built between December 2010 and
November 2013 that their units may be
missing key updates. HIS can use its
sales records and customer outreach to
determine which Q3s units its
customers bought and which need
updating. With those records and
outreach, HIS can determine the type of
conversion needed to bring the units up
to date and facilitate their customers’
updates of the previously-purchased
ATDs.
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http://www.nhtsa.gov/Research/Databases+and
+Software.
14
See Docket NHTSA–2013–0118–0008, page 2.
15
See Docket NHTSA–2013–0118, ‘‘Biofidelity
Assessment of the Q3s Three Year-Old Child Side
Impact Dummy,’’ July 2012.
16
Irwin AL, Mertz HJ, Elhagediab AM, Moss S
(2002). Guidelines for Assessing Biofidelity of Side
Impact Dummies of Various Sizes and Ages. Stapp
Car Crash Journal V46: 297–319, SAE International,
Warrendale, PA.
17
Aside from its response to impact, the size and
shape of the Q3s is based on child anthropometry.
The size and shape of the ATD is not scaled from
an adult model or other dummy size.
18
Mertz HJ (1984), ‘‘A procedure for normalizing
impact response data,’’ Paper No. SAE 840884,
Biomechanics of Impact Injury and Injury
Tolerances of the Thorax-Shoulder Complex—PT–
45, SAE International, Warrendale, PA.
19
Mertz HJ, Irwin AL, Melvin JW, Stalnaker RL,
Beebe MS (1989), ‘‘Size, weight, and biomechanical
impact response requirements for adult size small
female and large dummies,’’ Paper No. SAE 890756,
Automotive Frontal Impacts, SP–782, pp 133–144,
SAE International, Warrendale PA.
20
Melvin JW (1995), ‘‘Injury assessment reference
values for the CRABI 6-month infant dummy in a
rear-facing infant restraint with airbag
deployment,’’ Paper No. SAE 950872, SAE Congress
and Exposition, Detroit, pp 1–12, SAE International,
Warrendale PA.
21
Kleinberger M, Yoganandan N, Kumaresan S
(1998), ‘‘Biomechanical considerations for child
occupant protection,’’ 42nd Annual Proceedings for
the Association for the Advancement of Automotive
Medicine, pp 115–136, Charlottesville, VA.
22
Mertz HJ, Jarrett K, Moss S, Salloum M, Zhao
Y (2001), ‘‘The Hybrid III 10-year-old dummy,’’
Paper No. 2001–22–0014, Stapp Car Crash Journal,
V45, SAE International, Warrendale, PA.
Comment Received
Dorel believed that many aspects of
the Q3s, such as the fixture used to run
the neck torsion qualification tests, were
not fully engineered, and are thus not
finalized and ready for sale. Dorel also
cited unavailability of specialized Q3s
signal processing software as a hold-up
to its dummy evaluation.
NHTSA Response
Dorel is mistaken in believing that the
Q3s and its complementary fixtures
used in qualification testing were not
fully engineered. The NPRM for the Q3s
provided all the information needed to
assess the dummy in qualification tests,
including complete engineering
drawings of the neck torsion fixture.
The neck torsion fixtures were not
rights-protected in the NPRM for the
Q3s. The agency knows of at least two
other labs in addition to the agency’s
Vehicle Research and Test Center
(VRTC) that have built them on their
own (MGA Research Corporation
(MGA)) and Calspan).
With regard to Dorel’s software
concern, NHTSA has not developed
specific software for the express
purpose of processing qualification data
for the Q3s or any other dummy.
NHTSA does not provide software that
would fully automate the processing of
raw signals to determine the PASS/FAIL
outcomes in each of the eleven Q3s
qualification tests. Such software is a
third-party product. As with all part 572
regulations, NHTSA specifies the test
procedures, the test equipment, the
instrumentation, and the filter
frequencies of the test signals. The
means to process the signals (in
accordance with the part 572
specifications) is left to the discretion of
each test lab.
NHTSA does maintain a library of
software tools that aid in the processing
of raw signal data.
13
This includes a
collection of Microsoft Windows
graphical applications for analysis and
processing of signal data. Core
algorithms in this package include
minimum/maximum applications,
signal scaling, numerical integration,
and digital filtering as specified by
many FMVSS and part 572 standards
(including Subpart W for the Q3s.)
These tools may be used to process data
generated in Q3s qualification tests.
d. Biofidelity
The part 572 NPRM discussed
NHTSA’s findings that the Q3s is
suitably biofidelic overall and especially
in the head, thorax and neck which are
the body segments most critical for the
intended use of the dummy in side
impact testing. (78 FR at 69947–69950.)
Comment Received
In its comment, JPMA stated its belief
that the Q3s’s biofidelity is not
representative of a 3-year-old, living
child. JPMA stated
14
As the agency is aware, its assessment of
the Q3s focused on (1) a scaled-down version
of post mortem adult human subject data,
and (2) cadaver testing under dynamic
loading. Unfortunately, the scaled-down
adult data presumes incorrectly that adults
and children are the same internally, which
is simply not the case. For example,
children’s bones and bodies in general are
much more flexible than their adult
counterparts. Merely scaling adult data on
the basis of mass, geometric and stiffness
ratios will not represent accurate child-
centered data. Therefore, while appropriate
in size and weight to a live 3-year-old, the
Q3s is not representative of live, reactive 3-
year-old children. Due to the known
differences between the Q3s and the children
the ATD is supposed to represent, the
developing side impact test standard carries
with it a certain level of inherent risk — that
child restraints built to comply with the new
standard will be moving away from real-
world effectiveness.
NHTSA Response
NHTSA’s biofidelity assessment of the
Q3s (provided in a report in the docket
for the NPRM
15
) compared the
responses of the dummy to targets
previously established for a three-year-
old child. The targets themselves were
published in a Stapp Journal article by
the SAE Hybrid III Dummy Family Task
Group.
16
For ethical reasons, biomechanical
response data on children under impact
loading are very limited. Therefore,
scaling techniques are necessary to
derive the child impact response targets
from laboratory tests on adult post-
mortem human subjects (PMHS).
17
The SAE scaling procedure followed
an impulse-momentum approach to
derive response targets for a three-year-
old from targets established previously
for adults. The procedure made use of
adult-to-child ratios of mass,
anthropometry, and bone stiffness. In its
comments, JPMA implied that this
procedure does not account for
differences in bone flexibility between
adults and children. This is not the case.
Differences in bone flexibility are
integral to the scaling process, which
employs adult-to-child bone stiffness
ratios. For three-year-old vs. adult
scaling, a bone stiffness ratio of 0.475
was applied. This ratio was derived
using measurements of the elastic
modulus of human bone samples from
actual children as explained in the
Stapp article. The scaling ratios were all
applied to a lumped mass and spring
model to arrive at biomechanical
corridors for a three-year-old. Stated
differently, the scaling theory used to
establish the impact response of a
human three-year-old does account for
differences in flexibility and stiffness
between adults and children.
Details on the derivation of the
scaling model and its application may
be found in Mertz (1984)
18
and Mertz,
et al. (1989).
19
NHTSA notes that the
impulse-momentum approach was used
for other part 572 child dummies,
including the CRABI infant dummy
20
and the Hybrid III family of child
dummies.
21 22
Thus, the biomechanical
targets used to assess the Q3s were
derived the same way as the targets for
all other child dummies. Given the
limitations on pediatric data, NHTSA
believes the scaling process represents
an appropriate, best available method of
estimating the living, human child’s
response characteristics.
To summarize, NHTSA believes that
the scaling process used to derive
biomechanical response targets for the
Q3s is well-founded and reasonable.
The scaling process does not presume
that adults and children are the same
internally. The process assumes that the
response of the targeted subject depends
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CRSs subject to a side impact test would likely
use padded side wings as one of the main
countermeasures to meet side impact protection
requirements.
24
For pendulum impacts, biofidelity is generally
assessed as ‘‘external’’ or ‘‘internal.’’ External
biofidelity is related to the force generated on the
face of a pendulum impact probe upon striking a
subject. In other words, probe forces generated by
dummies are compared against probe forces
generated by PMHS. Internal biofidelity is related
to a measurement on or within the subject itself,
such as shoulder deflection or spine acceleration,
for which corresponding measurements are made
on both the PMHS and the test dummy.
25
78 FR at 69949. ‘‘Biofidelity Assessment of the
Q3s Three-Year-Old Child Side Impact Dummy,’’
July 2012, Docket No. NHTSA–2013–0118.
26
Standard deviations are based on a sample and
calculated using the ‘‘n–1’’ method.
on its internal stiffness, and that
internal stiffness varies by the age of the
subject. The agency is satisfied with the
overall biofidelity of the Q3s and is
convinced that CRSs built to comply
with the new side impact standard
using the Q3s will be effective in the
real world.
Q3s Shoulder
NHTSA evaluated the biofidelity of
the Q3s shoulder in component testing
under the loading of a pendulum. In the
NPRM, NHTSA described an
‘‘unpadded’’ test conducted involving
an SAE International protocol (Irwin,
2002) that uses a rigid pendulum in a
pure lateral direction. In the test, the
Q3s shoulder showed high stiffness
with respect to lateral shoulder
displacement and probe force under this
test protocol. NHTSA later reexamined
shoulder biofidelity under ‘‘padded’’
conditions that the agency believed
corresponded more closely to the
planned use of the Q3s in the proposed
FMVSS No. 213 test than the unpadded
condition. In the latter test, NHTSA
used the Ohio State protocol (Bolte et
al., 2003), which utilizes the same
impactor mass and speed as the SAE
International test but with foam padding
attached to the impactor face. NHTSA
determined that the latter condition was
particularly relevant because the Q3s
would most likely be exposed to a
padded side structure (‘‘wing’’) of the
child restraint in the test.
23
The striking
surface, like the probe in the Ohio State
test, would be padded.
Under the Ohio State protocol, the
shoulder of the Q3s was also stiff when
assessed for biofidelity as measured by
its deflection (about 10 mm below the
nominal biofidelity target). However,
NHTSA found that the magnitude of the
force applied by the padded probe
(about 400 N) was well within the upper
and lower limits of biofidelity.
Therefore, NHTSA believed that the
Q3s’s shoulder loading of the child
restraint, which could affect the overall
motion of the dummy’s upper torso and
head (relevant for the measurement of
injury criteria under consideration), was
representative of an actual human. (78
FR at 69949–69950.)
Comment Received
JPMA commented that it believed the
shoulder of the Q3s is too stiff relative
to a human child. The commenter stated
that, because the shoulder is too stiff,
the trajectory of the head during a
compliance test will be unrealistic such
that it could register artificially high
HIC values. JPMA asserted that child
restraint designs will thus need to be
ultra-conservative in their ability to
keep HIC low, and that this, in turn,
could necessitate a seat design that is
uncomfortable for children. JPMA was
concerned that, to get comfortable,
children may take on seating postures
that could ultimately put the child at
higher risk than when seated in a
current CRS (i.e., one that is not
designed to meet a new side impact
requirement). The commenter did not
did not provide any data or analysis
supporting these views.
NHTSA Response
It is important to highlight the point
made in the NPRM that, under
conditions that correspond closest to the
intended use of the Q3s in the proposed
FMVSS No. 213 side impact test (i.e.,
using a foam-covered probe that is more
akin to the shoulder interaction with a
CRS ‘‘wing’’), the force response of the
padded probe (external biofidelity
24
)
nearly matches the target.
25
With the
magnitude of the force generated by the
padded probe well within the envelope
for a biofidelic response, these data
show that the Q3s shoulder is biofidelic
in the manner in which it will exert
force on the CRS. Thus, this loading of
the child restraint, which would affect
the overall motion of the dummy’s
upper torso and head (through which
the FMVSS No. 213 injury criteria under
consideration would be measured), is
representative of an actual human.
JPMA did not provide any analysis or
rationale supporting its conclusions that
the Q3s shoulder will cause artificially
high HIC values and that uncomfortable
seat designs will result. Given all
available data and information about the
test dummy, NHTSA is satisfied with
the biofidelity of the Q3s shoulder and
how the ATD’s shoulder, head and torso
will interact when the dummy is
restrained in a child restraint in the side
impact test.
e. Repeatability and Reproducibility
(R&R)
A test dummy’s R&R may be assessed
in sled tests and component tests.
‘‘Repeatability’’ is defined here as the
similarity of responses from a single
dummy when subjected to multiple
repeats of a given test condition.
‘‘Reproducibility’’ is defined as the
similarity of test responses from
multiple dummies when subjected to
multiple repeats of a given test
condition. Sled tests establish the
consistency of the dummy’s kinematics,
its impact response as an assembly, and
the integrity of the dummy’s structure
and instrumentation under controlled
and representative crash test conditions.
In component tests, the test conditions
as well as the test equipment are
carefully controlled to assure the
dummy is subjected to a tightly
controlled impulse and to minimize
external effects on the dummy’s
responses.
Assessment of R&R
NHTSA’s assessment of R&R was
based on a statistical analysis of
variance. The percent coefficient of
variation (CV) is a measure of variability
expressed as a percentage of the mean.
The CV is calculated as follows:
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See NPRM for the original subpart B Hybrid II
50th percentile male ATD (40 FR 33466; August 8,
1975).
28
The assessment categories in Table 3 differ
slightly from those applied during the NPRM stage.
In the NPRM R/R analysis, a similar Table 3
categorized the CV ranges as either ‘‘Excellent,’’
‘‘Good,’’ ‘‘Marginal,’’ or ‘‘Poor.’’ For this final rule,
we do not use these terms in the table to describe
the CV ranges. Rather, the new Table 3 provides
further explanation of the action taken by the
agency when the CV for a particular test condition
was in a specified range, which, we believe, is more
informative and helpful to the reader. Also,
although the previous nomenclature for the CV
ranges provided a convenient shorthand, we believe
the terms it used could be misconstrued by the
reader as reflective of a final assessment of the
qualities of the ATD being tested.
29
The response of the head was measured by the
acceleration of the head. Additionally, R&R of the
head was also assessed via its injury correlate, the
head impact criterion (HIC). HIC is computed from
the head acceleration measurements.
30
The Biomechanics data base may be accessed
at: http://www.nhtsa.gov/research-data/databases-
and-software.
NHTSA has used CVs to assess the
repeatability and reproducibility of
ATDs throughout the history of part
572, starting in 1975.
27
Separate CVs for
repeatability and reproducibility, by
labs and by dummies, were computed.
The CVs were used to assess the degree
to which the current population of Q3s
dummies were able to attain targeted
responses. In the NPRM, we described
how provisional upper and lower limits
for all qualification requirements were
set at a maximum of 10% (before
rounding) from a nominal response
target. For any particular requirement,
the 10% condition was always met in
our post-NPRM testing when the CVs
were all below 5% for repeatability and
6% for reproducibility. Under these
circumstances, there is a high degree of
uniformity in the construction of the
dummy components being tested and in
the procedures followed by the labs for
that test requirement.
For example, in the post-NPRM test
series for neck flexion, neck moments
from 81 trials were recorded. In all 81
trials, the neck moment was well within
10% of the nominal target and the CVs
were all below 5% for repeatability and
below 6% for reproducibility. Thus, in
our post-NPRM assessments, when the
CVs for a particular test condition were
below 5% and 6% for repeatability and
reproducibility, respectively, no further
examination of the data or test condition
was carried out.
On the other hand, when a test
condition produced a CV above 5% for
repeatability or 6% for reproducibility,
a response in at least one trial was
usually beyond 10% of the nominal
target. When a CV exceeded 10%,
several trials were beyond 10% of the
target. In these instances, a close
examination of the data, dummies, and
procedure was performed to pinpoint
the source of the variability. Corrective
actions were taken in most cases.
Our investigative criteria for
repeatability uses a slightly lower CV
than for reproducibility (5% vs. 6%) as
shown in Table 3. Since repeatability is
an assessment of the same dummy by
the same test laboratory, whereas
reproducibility is an assessment of
multiple dummies at more than one lab,
reproducibility assessments include
many more sources of variability.
Hence, repeatability CVs are generally
lower than reproducibility CVs.
T
ABLE
3—CV S
CORE
C
ATEGORIZATION FOR
R
EPEATABILITY AND
R
EPRODUCIBILITY
28
Repeatability CV
score Reproducibility CV
score Assessment
<5% ........................ <6% ........................ No further investigation; all trials within ±10% of the target response.
5%–10% ................. 6%–10% ................ Sources of variability investigated. One or more trials beyond ±10% of target response.
10% ...................... 10% ...................... Corrective actions considered for revisions to test procedure or dummy design. Several trials be-
yond ±10% of target response.
R&R in Sled Tests
Since the Q3s dummy is being
considered as a measurement device for
a proposed regulatory test that would
evaluate CRS performance in side
impact crashes, NHTSA assessed the
R&R of the dummy in actual CRS side
impact sled tests. This assessment was
discussed in the NPRM (78 FR at
69951–69953), where two Q3s units
were tested five times each. Of the
greatest importance to the assessment
were the two measurements associated
with injury assessment reference values
for CRS requirements under the
proposed side impact upgrade to
FMVSS No. 213. These were the
response of the head
29
and the lateral
thorax displacement.
The CVs for the response of the head
were less than 3% for all measures of
R&R. For the lateral thorax
displacement, the CV for reproducibility
was also under 6%, and CV for
repeatability was under 5% for one of
the two Q3s units. For the other unit,
the data in one of the tests was quite
different from the others. This
discrepancy was traced to an
inconsistency in the pre-test position of
the dummy’s elbow in one of the tests
which had resulted in a CV for
repeatability of 9% for that unit.
In consideration of the elevated CVs,
NHTSA ran another (‘‘supplemental’’)
series of sled tests with an improved
arm-positioning protocol. This was also
described in the NPRM (78 FR at 69952–
69953). Five trials were run with a
single unit. The repeatability for the
thorax displacement in this series had a
CV of 4%. The response of the head
again was highly uniform, with a CV of
3%.
Given this high degree of uniformity
in those tests and since the design of the
dummy was essentially unchanged,
NHTSA was satisfied with the R&R of
the Q3s in sled testing and determined
there was no need to perform additional
sled testing for a final rule.
Comment Received
In its comments, Dorel said that it
computed a CV of 32.6% for HIC results
from ten tests in the supplemental
series.
NHTSA Response
The agency believes that Dorel may
have misread the results of this series of
tests. There were only five tests in this
series, not ten as suggested by Dorel.
None of the HIC values listed by Dorel
correspond with those in NHTSA’s test
series, so it is unclear where Dorel’s
data were derived. The agency’s test
data are available to the public in
NHTSA’s Biomechanics Data Base
(BIODB).
30
The CV in sled testing was
only 3% for the HIC values. Given these
data, Dorel’s comment appears to be
mistaken. In view of this high degree of
uniformity, NHTSA is satisfied with the
R&R of the Q3s in sled tests.
R&R in Component Qualification Tests
In the NPRM, acceptance criteria for
the qualification tests were proposed to
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A copy of the report has been placed in the
docket for this final rule.
assure that the high level of R&R
exhibited in the sled tests would be
preserved in any dummy presented for
compliance testing. In other words, the
qualifications would serve to weed out
any dummy that had a substantially
different response from the uniformity
of the original four units. The proposed
acceptance criteria were based on a
series of eleven component tests with
multiple Q3s units in replicate trials. An
upper limit and lower limit for an
acceptable response were set for each
test. The limits were chosen to be wide
enough to account for normal variations
in dummy and laboratory differences,
and narrow enough to assure consistent
and repeatable measurements in
compliance testing.
As part of this analysis, R&R was
assessed for each set of qualification test
outcomes. As discussed in the NPRM,
most CVs were well under 5% and all
were under 10%. The agency was
aware, however, that for the NPRM the
assessment was carried out using only
four units, with all tests run at a single
laboratory (VRTC). NHTSA explained in
the NPRM that the agency anticipated
finalizing the Q3s limits based on
additional qualification data we would
receive subsequent to the NPRM (78 FR
at 69959). Various commenters
responding to the NPRM expressed the
view that the repeatability and
reproducibility assessment of the Q3s
ought to be assessed across various test
facilities. Some asked for more data
from tests with more dummies to round
out the qualification corridors.
After the NPRM was published,
NHTSA proceeded to obtain more
qualification test data as it had planned.
NHTSA investigated whether newer
dummies tested at different labs
exhibited the same level of R&R as
NHTSA’s original units. In the test
program NHTSA designed in mid-2014,
the agency used different labs to test
both newer Q3s units and the original
dummies, and obtained data that could
be compared to the existing NPRM data
from the original four units.
In 2014 and 2015, NHTSA
systematically tested three new units
that HIS delivered to end-users and
three of the agency’s original four
dummies. NHTSA examined the R&R of
the Q3s’s performance to assess all
sources of variability so as to identify
the degree of variability and whether it
was due to a non-uniform test procedure
at a lab (and among the labs), an aspect
of dummy design, or the dummy
manufacturer’s production of Q3s units.
This systematic approach enabled
NHTSA to assess the potential to which
factors resulting in the variability could
be remedied, adopt measures to mitigate
the variances where possible, and assess
the quality of the data on the Q3s. The
testing also provided data that helped
round out the qualification corridors.
The program is discussed below. Test
results and analyses are discussed in
detail in a NHTSA report entitled,
‘‘NHTSA’s Q3s Qualification Testing,
2014–2015, May 2016.’’
31
V. Post-NPRM Test Program Overview
a. Test Locations
NHTSA collected data from tests run
at three different laboratories (Calspan,
MGA and HIS) independent of NHTSA,
and conducted additional tests at
NHTSA’s VRTC.
At each independent lab, a full set of
qualification tests were run (consisting
of 11 different types of tests) on two
NHTSA-owned units and a new unit.
Several trials, or repeat tests, were
carried out on each dummy for each of
the 11 qualification tests. Tests were
done using qualification test equipment
owned by each laboratory. Tests were
run in strict accord with the procedures
described in the NPRM. The input
parameters for each test had to conform
to the specifications set forth in the
proposed qualification procedures. For
example, a test in which the probe
impact speed did not meet the required
parameters did not count toward the
total test repetitions. After each test, a
post-test inspection of the dummy was
carried out to determine if the ATD
incurred any damage resulting from the
test.
NHTSA Tests at Outside Labs—Calspan
and MGA
NHTSA contracted the services of
Calspan and MGA to perform the series
of qualification tests. The test series are
summarized in Table 3. All tests were
carried out between January through
March 2015.
NHTSA In-House Tests (VRTC)
Prior to shipping NHTSA’s two
dummies to Calspan and MGA, NHTSA
tested the ATDs to the qualification tests
at VRTC, but only one trial per test
condition was carried out. These results
(in addition to those provided in the
NPRM) served as a comparative baseline
for subsequent tests on the same units
at the outside labs. Also, the agency
arranged with Britax to test its new Q3s
dummy that Britax had received from
HIS in 2014. The tests were conducted
at VRTC, and the results were added to
the data pool.
Tests at HIS
In addition to the data NHTSA itself
collected, the agency was also given
data by HIS. In 2014, NHTSA lent HIS
two of NHTSA’s Q3s dummies for HIS
to use to compare its qualification
procedures and equipment to that
described in the NPRM. HIS ran the
qualification tests and provided NHTSA
with the data from the tests. The agency
also obtained from Calspan, MGA and
Britax the qualification results
performed by HIS on the new Q3s units
sold to those end-users. These data were
supplied by HIS to each respective
purchaser of the dummy at the time of
delivery. The owners, in turn, provided
the data to NHTSA. The test results
were added to the data pool.
Table 4, below, provides an overview
of the qualification testing conducted at
each lab.
T
ABLE
4—O
VERVIEW OF
Q3
S
Q
UALIFICATION
T
ESTING
Lab Q3s serial No. Dummy owner Number of
trials Year of tests Note
VRTC ..................................... 004 NHTSA .................................. 5 2012 Results shown in NPRM.
006 NHTSA .................................. 5 2012 Results shown in NPRM.
007 NHTSA .................................. 5 2012 Results shown in NPRM.
007 NHTSA .................................. 1 2014 Prior to HIS testing.
007 NHTSA .................................. 1 2015 Prior to MGA testing.
008 NHTSA .................................. 5 2012 Results shown in NPRM.
008 NHTSA .................................. 1 2015 Prior to MGA testing.
3538 Britax ..................................... 5 2015 Leased from Britax.
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The other 15 were time-related criteria (such as
the time peak at which the maximum neck rotation
occurs) or criteria that contained zero in their
intervals (such as the peak off-axis acceleration in
the head drop test). NHTSA did not include these
measurements in the R&R assessment because the
CV statistical measure is not a good indicator of
variability in these instances.
33
If a dummy is qualified, it can act as an
objective device in compliance tests such as those
proposed in the FMVSS No. 213 NPRM. If
disqualified, a dummy must be replaced or
repaired.
34
The few instances where CVs for test
repeatability were greater than 5% are discussed in
greater detail below in this preamble.
35
As will be discussed later in this document,
NHTSA has corrected aspects of the lateral head
drop and lateral neck test procedures that had
contributed to the elevated variability in the results.
Further, the agency has decided not to adopt the
pubic force limit in the pelvis test.
T
ABLE
4—O
VERVIEW OF
Q3
S
Q
UALIFICATION
T
ESTING
—Continued
Lab Q3s serial No. Dummy owner Number of
trials Year of tests Note
HIS ......................................... 004 NHTSA .................................. 3 2014 Leased from NHTSA.
007 NHTSA .................................. 3 2014 Leased from NHTSA.
3538 Britax ..................................... 2 2014 Pre-delivery to Britax.
5860 MGA ...................................... 2 2014 Pre-delivery to MGA.
059 Calspan ................................. 2 2014 Pre-delivery to Calspan.
MGA ...................................... 007 NHTSA .................................. 5 2015 Contract with NHTSA.
008 NHTSA .................................. 5 2015 Contract with NHTSA.
5860 MGA ...................................... 5 2015 Contract with NHTSA.
Calspan 007 NHTSA .................................. 5 2015 Contract with NHTSA.
008 NHTSA .................................. 5 2015 Contract with NHTSA.
059 Calspan ................................. 5 2015 Contract with NHTSA.
b. Component Tests in the Post-NPRM
Test Program
The component tests were the 11
qualification tests proposed for the Q3s.
For each test, there were at least 2
dummy responses for a total of 35 in all.
Of the 35 responses, 20 were derived
from peak values (such as the peak
resultant acceleration for the head drop
test or maximum probe force for the
pendulum tests). Those 20 were
assessed for R&R.
32
The 20
measurements that NHTSA assessed for
R&R encompassed each of the eleven
types of qualification tests.
c. Controlling Variability
An assessment of dummy R&R is
dependent on controlling variability
within and among test labs in
conducting the qualification tests. A
dummy must provide repeatable and
reproducible results in the tests, but a
qualification test must be repeatable and
reproducible to serve its purpose to
either qualify or disqualify a dummy.
33
Controlling variability within and
among test labs is important for assuring
the qualification tests fulfill their
purpose.
With this in mind, when NHTSA
collected post-NPRM data and observed
variability in the test results, the agency
closely analyzed any effect a test lab’s
internal practices, protocols and
procedures might have had on the
results. Variability caused by a lab’s not
being able to run a test repeatedly (‘‘test
repeatability’’) is discussed in each
section below. In addition, NHTSA
assessed the objectivity of the test
methods themselves, or ‘‘test
reproducibility,’’ to assure that tests
with the Q3s at different labs would
produce reproducible results.
NHTSA also identified instances in
which repeatability was compromised
due to a discernable problem with the
dummy, such as variability in a
particular dummy’s responses over time
(‘‘dummy repeatability’’).
The agency also assessed ‘‘dummy
reproducibility,’’ i.e., the uniformity of
the dummies themselves. This is partly
a function of how well HIS was able to
manufacture dummies that behave
uniformly. Thus, NHTSA was especially
interested in comparing the responses of
older versus newer units. The agency
only used the results from the same lab
for this assessment.
Summary of Test Repeatability
Assessment
NHTSA assessed the ability of each of
the three outside labs (Calspan, MGA
and HIS) to attain a repeatable response
by analyzing the effect test lab practices,
protocols and procedures might have
had on the results. Test repeatability
was based on same-lab trials with the
same dummy: Serial no. 007 (owned by
NHTSA), the only dummy tested by all
three labs. Thirty-five responses were
assessed at each lab.
Additionally, NHTSA performed a
separate assessment at Calspan and
MGA based on tests with NHTSA-
owned dummy serial no. 008. (HIS did
not test serial no. 008.)
At Calspan, all test repeatability CVs
were below 5% for all tests and for both
dummies (serial nos. 007 and 008). At
MGA, the CVs were below 5% except in
two instances: The Mz measurement in
the ‘‘Neck Torsion’’ test (5.9%) and in
the resultant head acceleration in the
‘‘Lateral Head Drop’’ test (10.0%). Both
occurred with dummy serial no. 007.
All tests at MGA on serial no. 008
yielded CVs below 5% for test
repeatability. At HIS (with serial no. 007
only), the CVs where below 5% in all
but two instances: The ‘‘Lateral Head
Drop’’ test (5.6%) and the ‘‘Thorax With
Arm’’ test (9.3%).
34
These findings demonstrate a high
level of test repeatability and the ability
of the three outside labs to carry out the
qualification tests. In summary, NHTSA
is confident in the data generated by the
test labs in this test program.
Summary of Test Reproducibility
Assessment
NHTSA assessed the objectivity of the
test methods to provide consistent
results at different labs. The agency
evaluated test results from replicate
tests on the same dummy (Q3s serial no.
007) at different labs (this ATD was the
only unit tested at all four labs). NHTSA
also assessed test reproducibility with
Q3s serial no. 008, which was tested at
VRTC, MGA, and Calspan (but not HIS).
For all 35 sets of measurements, all
but three had test reproducibility CVs
under 6%. The three sets of tests that
had CVs over 6% were: The resultant
head acceleration in the lateral head
drop test; the Mx component in the
lateral neck test; and the pubic force in
the pelvis test.
35
The results are
discussed in greater depth in a later
section below.
Summary of Dummy Repeatability
Dummy repeatability is a measure of
how much the response of a given
dummy changes during the course of
testing. One with a high degree of
repeatability exhibits little change from
one qualification trial to the next. A
change in response could be caused by
a hardening or softening of polymeric
components over time or the
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Torn lumbar column. Throughout NHTSA’s
test experience with the Q3s, dating back to the
NPRM, there was only one instance where dummy
durability was an issue. In the very last series of
tests on serial no. 008 run at Calspan in March
2015, a tear in the rubber column within the lumbar
assembly was observed after the first lumbar
qualification trial. In subsequent tests, the tear
became visibly worse and the lumbar moment and
rotation both increased with each successive
impact. The biggest jump occurred between trials 1
and 2, where the maximum neck rotation jumped
from being centered within the limits of
acceptability to just outside the limits. The agency
views this instance as a successful demonstration
of the ability of the qualification test to weed out
a damaged unit.
37
A nut with a nylon collar insert, often referred
to by its tradename, NYLOC, is a nut that resists
turning.
propagation of cracks and other defects
that occur over repeated impacts.
Repeatability could also be affected by
loose assembly tolerances. Dummies are
routinely disassembled and re-
assembled, and wide allowances for
settings (such as the joint torques) could
result in poor repeatability.
During the course of the qualification
testing of the Q3s, NHTSA closely
examined the root cause of any
variability in trial-by-trial test results
that might reveal a problem with the
dummy (i.e., a problem with dummy
repeatability) rather than simple test
variability. There was only one instance
where repeatability was compromised
due to a discernable problem with the
dummy.
36
This instance, which affected
the uniformity of the lumbar spine, is
discussed below, along with NHTSA’s
simple fix to the problem. Aside from
that, there were no other problems with
dummy repeatability in any of the tests.
Once the fix to the lumbar was
implemented, it was demonstrated to
have a highly uniform response. NHTSA
also examined changes in the response
of the dummy over time and found that
such changes had only a negligible
effect on dummy repeatability. This is
also discussed below.
Loosening of lumbar cable. NHTSA
observed that in the lumbar flexion
tests, the first trial tended to register a
lower moment that subsequent trials.
This was consistent with all dummies at
all labs. NHTSA examined the wire
cable that runs through the center of the
rubber column, which was initially
placed under tension by tightening a
lock nut with a nylon insert
37
prior to
the first trial. After the first trial, it was
apparent that the nut did not stay in its
set position. It could be loosened by
hand.
This affected the response of the
lumbar spine, as the tension on the
cable governs the response of the
lumbar column. NHTSA controls this in
the PADI by prescribing the torque for
the nut on the center cable. However,
the torque on a nut with a nylon insert
is partly dependent on the condition of
the nut itself. A newer nut can resist
more torque without affecting the cable
tension than a worn nut. In other words,
the tension on the cable (and the
moment) can vary depending on the
condition of the nylon insert of the nut.
To alleviate this situation, NHTSA has
replaced the nut with two jam nuts, i.e.,
two standard nuts twisted against each
other.
No pronounced changes in response
over time. NHTSA assessed also the
agency’s older unit, serial no. 007, for
signs that one or more responses was
exhibiting a definitive change during
the course of testing due to any sort of
deterioration. This unit was tested
repeatedly over the course of many
years, with the initial tests pre-dating
the NPRM. NHTSA examined data from
2012 to 2015 to see if there were any
definitive trends in response changes.
To avoid any lab-to-lab variability that
could act as a confounder, NHTSA
assessed the results from a single lab,
VRTC. Data were collected in three
separate periods: In 2012 (five trials for
the NPRM), in 2014 (one trial prior to
sending it to HIS), and in 2015 (one trial
just prior to the MGA/Calspan series).
Of all the responses, only two had a
definitive change in response over the
three test periods: Lumbar moment and
shoulder deflection. In these instances,
the 2015 trial produced a lower/higher
response than any of the previous trials
(lower for the lumbar moment, higher
for the shoulder deflection), while the
2014 trial produced a result that was
between the 2015 and 2012 trials.
Yet, even for these two instances, the
change in response was negligible. For
the lumbar moment, the change in
moment was just 2 Nm: 82.6 Nm (lowest
of the 2012 trials), 82.1 Nm (in 2014),
and 80.6 Nm (in 2015). Similarly, the
change in shoulder deflection was less
than 1 mm: 19.0 mm (highest of the
2012 trials), 19.5 mm (in 2014), and 19.6
mm (in 2015). In both instances, all
responses fell well within the
qualification limits specified in this
final rule. NHTSA observed no other
problems with deterioration over time.
In summary, NHTSA has determined
that there are no problems with dummy
repeatability that might compromise the
overall uniformity of Q3s responses.
The one problem with dummy
repeatability has been resolved and
there are no further concerns.
Summary of Dummy Reproducibility
Assessment
In assessing dummy reproducibility,
NHTSA examined the uniformity of the
dummies themselves. This is partially a
function of how well the manufacturer
HIS produced dummies that behave
uniformly. The agency was especially
interested in comparing the responses of
older vs. newer units.
To eliminate the effects of lab-to-lab
variability, NHTSA only used same-lab
results for this assessment. NHTSA also
combined results for left and right
aspects since the dummy was designed
to yield the same response in impacts to
both. Thus, four separate assessments of
dummy reproducibility were carried
out, one per lab, against the units
referenced in Table 5 below.
T
ABLE
5—Q3
S
D
UMMIES
U
SED IN
R
EPRODUCIBILITY
A
SSESSMENTS AT
V
ARIOUS
L
ABS
Lab Serial numbers of older NHTSA units Serial numbers of new units
VRTC ................................................................. 004, 006, 007, 008 ........................................... 3538 (Britax-owned unit).
HIS ..................................................................... 004, 007 ........................................................... 3538 (Britax-owned unit); 5860 (MGA-owned
unit); 059 (Calspan-owned unit).
MGA ................................................................... 007, 008 ........................................................... 5860 (MGA-owned unit).
Calspan .............................................................. 007, 008 ........................................................... 059 (Calspan-owned unit).
As a secondary assessment, NHTSA
compared only the three new units
against each other in tests at HIS (HIS
was the only lab that tested all three
new units). This gave the agency a better
sense as to whether the newer units,
when considered as a single lot, had
more inter-dummy variability as
compared to NHTSA’s original lot of
four units. (As a point of reference,
NHTSA assessed dummy
reproducibility in the NPRM based on
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The high CVs for dummy reproducibility
indicates that some newer Q3s dummies in the field
may have to have parts reworked or replaced to
produce a ‘‘pass’’ in the head drop test and thorax
without arm test. Going forward, this final rule’s
setting of the acceptance criteria for the
qualification tests should help provide checks and
controls in the ATD’s manufacturing processes,
which in turn should facilitate the production of
ATDs that meet the acceptance criteria for the
qualification tests.
39
For example, the NPRM’s 3-standard-deviation
interval for the time at which the peak neck
moment occurs was only 7 ms.
tests with the agency’s four units (serial
nos. 004, 006, 007, and 008) at VRTC
and the CVs were less than 6% in all
eleven qualification tests.)
The agency’s ratings of dummy
reproducibility of the new units in the
secondary assessment produced CVs in
the 6% to 10% range for about 25
percent of the qualifications. The CVs of
the other 75 percent were all under 6%,
and no further investigation was
performed.
NHTSA investigated any set of tests
with a CV above 5% for repeatability
and 6% for reproducibility to determine
the source of the variability. Responses
in the lateral head drop and thorax
impact test were non-uniform. When
units manufactured since 2014 were
compared to older units as two separate
sets, NHTSA observed differences in
responses for several qualifications. In
general, the newer Q3s units did not
exhibit the same high level of dummy
reproducibility observed in NHTSA’s
four older units.
As explained later in sections below,
in a few limited instances, values
obtained from a qualification test of a
newer ATD were too dissimilar to those
from tests of other Q3s units to be
included within a set of reasonable
qualification limits. Including them
would have unacceptably widened the
limits, lessened the uniformity of the
ATDs, and unacceptably reduced the
biofidelity of the Q3s. In such instances,
the agency considered the particular
dummy part substandard and the values
from tests of the part beyond the
performance criteria for the
qualification test.
38
VI. Results of the Post-NPRM Test
Program and the Final Acceptance
Criteria for the Qualification Tests
a. Background
In the NPRM, NHTSA proposed
acceptance criteria based on replicate
trials conducted sequentially on four
NHTSA-owned Q3s units at a single
laboratory (VRTC). These tests were
used to set the upper and lower limits
of the qualification intervals and were
used to assess the repeatability of the
Q3s.
Of the 35 measurements, the bounds
of 21 measurements were proposed as
±3 standard deviations from the mean.
Of the 14 other measurements that were
set to ±10%, 12 were set at ±2 standard
deviations from the mean or greater.
Two had bounds that were less than ±2
standard deviations: Peak pubic load
(1.9 standard deviations) and peak neck
torsion moment (0.5 standard
deviations).
At the time of the NPRM, NHTSA
recognized that 3 standard deviations
comprised a wider-than-usual bound
from a probabilistic standpoint. NHTSA
regarded the bound as a starting point
based wholly on the statistics of the
measurements. Three standard
deviations were wide enough to account
for normal variations in dummy and
laboratory differences and narrow
enough to assure consistent and
repeatable measurements in compliance
testing. Moreover, many of the bounds
were, in practice, extremely narrow
from an operational standpoint owing to
factors (equipment, set-ups, technicians)
lending themselves to highly repeatable
testing at a single lab (VRTC).
39
NHTSA
anticipated finalizing the Q3s limits
based on additional qualification data
the agency would receive subsequent to
the NPRM (78 FR at 69959).
b. Process for Setting the Final
Qualification Limits
The data from the post-NPRM test
program and other sources, discussed
above, have helped NHTSA finalize the
qualification test procedures and round
out the qualification corridors. In
specifying qualification tests and
acceptance criteria for the qualification
tests, NHTSA’s goal is to assure that a
‘‘pass’’ is a true indicator of a dummy
that is uniform in its design and
performance. This goal is achieved by
ensuring that the tests themselves are
repeatable and reproducible, and by
setting limits (or tolerances) on the
qualification targets.
As discussed in the previous section,
test and dummy R&R have been
demonstrated at four different labs. The
proposed targets and acceptance criteria
for the qualification tests in the NPRM
were based entirely on the statistics of
the agency’s replicate tests. NHTSA
considered those targets and limits as
starting points, given that the agency
did not have data from other labs. Since
then, the agency has expanded the
qualification database by adding much
more data on tests with several
dummies across four test labs. For this
final rule, the qualification targets and
limits are based on the statistics of the
measurements, but also on the following
factors.
Other Part 572 ATDs. NHTSA
considered the qualification limits of
the other part 572 ATDs in use today in
setting those for the Q3s. For example,
the qualification bounds for the most
recent dummy incorporated into part
572 (the Hybrid III 10-year-old child
dummy (HIII–10C); see part 572, subpart
T), are derived from tests on about 30
different dummies, with data supplied
from about ten different laboratories.
For the HIII–10C, there are nine
qualifications based on a maximum
measurement (such as a peak force), and
the average limits (i.e., the values
defining the range of acceptable
measurements) are 9.9% from the
midpoint. The low is 8.4% (neck
rotation in the neck extension test) and
the high is 10.8% (seen in two
qualifications: neck moment in the
extension test and chest deflection in
the thorax impact test).
A limit of 11% from the midpoint is
the average for all part 572 dummies
and all qualifications. NHTSA has used
this value as a benchmark for setting the
limits for the Q3s in this final rule. The
agency scrutinized any limit above 11%
from the midpoint to ensure it could be
justified.
Biofidelity targets. In setting the
qualification limits, the agency
considered the biofidelity targets that
were used as the basic design criteria of
the Q3s during its development. The
corridors surrounding biofidelity targets
are generally wider than qualification
limits owing to larger variances
associated with tests with human
subjects. In the NPRM, NHTSA
compared the responses of various Q3s
body regions against their respective
human biofidelity corridors. For the
most part, the responses of the body
regions fell within the biofidelity
corridors (including the responses for
the head and thorax). For the final rule,
NHTSA made sure that a contemplated
qualification limit would not result in
acceptance of a dummy response that is
outside the biofidelity corridors.
Some body regions, such as the
shoulder, were shown in the NPRM to
be stiff relative to the biofidelity targets.
For these body regions, any shifts in the
qualification limits for the final rule
were generally made in a direction that
was closer to the biofidelity target. In
other words, NHTSA avoided moving
the nominal qualification target further
from the biofidelity target.
Test input parameters. For this final
rule, NHTSA has not changed the input
parameters in any of the eleven
qualification tests from those of the
NPRM. The input parameters include
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40
Cradling of the head is shown in the regulatory
text figures, but specifics on how to release the head
are left to the operator.
41
The cradle problem at MGA highlighted the
need for a drop test mechanism with a high degree
of precision. Any slight deviation in the point of
impact was shown to produce a large variation in
both the resultant and off-axis acceleration. This
was particularly true in the lateral head drop, where
the curvature of the head at the point of impact
contributes to the variation.
42
When two halves of a mold meet, the
corresponding line or seam appearing on the
molded object is referred to as the parting line.
impact speeds, probe masses, drop
heights, and dimensional measurements
related to dummy positioning.
Tolerances on test inputs are also
unchanged.
For this final rule, nineteen Q3s
qualifications are centered around a
maxima. For these measurements, the
limits proposed in the NPRM were
spread around a nominal target response
by plus or minus 9.9% (on average) of
the target. The average spread in this
final rule is slightly higher, at 10.1%.
However, as seen in Table 1, supra, the
limits are narrower for 11 of the
nineteen qualifications, and only the
shoulder has limits greater than 12%:
Internal shoulder deflection (12.8%)
and shoulder probe force (12.3%).
Newer dummies and other test labs.
NHTSA considered the population of all
dummies tested—both old and new—
and all four labs that were used.
Recognizing that the newest dummies
may be representative of the future
population of Q3s dummies, steps were
taken to be inclusive of them as
reasonably possible. NHTSA also
recognized that all four labs were highly
experienced in dummy qualification
testing, so in theory any dummy that
qualified at one lab should have
qualified at the others. When this was
not the case, the situation was analyzed
to determine the source of the problem.
Balancing the factors. In setting the
final qualification limits for the final
rule, NHTSA examined the test data on
a trial-by-trial basis and balanced all the
factors discussed above. For example,
for the lumbar flexion qualification,
while keeping the 11% goal in mind
NHTSA set the qualification limits such
that serial no. 059 (a new unit owned
and tested by Calspan) was just under
the upper limit in four of five trials,
while serial no. 5860 (a new unit owned
by and tested by MGA) was just over the
lower limit in four of five trials.
Balancing the factors enabled NHTSA to
set qualification limits spread 10.9%
from the nominal target in a manner that
included as many test trials from the
new units as reasonable. In contrast, if
the 10.9% limits were centered around
the average of all responses, the Calspan
unit would have failed to qualify in all
trials.
In summary, the agency analyzed the
data from the testing of the seven Q3s
units (the four NHTSA-owned units and
the three new units) to the qualification
tests proposed in the NPRM, assessing,
among other matters, the measurements
made by the units when tested to the
qualification tests and the R&R of the
dummies. Tests were run for both right
and left side impacts. Average, standard
deviation, and coefficient of variation
were computed for each required
measurement parameter of each
qualification procedure.
c. Head
The head injury criterion (HIC), based
on the Q3s’s head acceleration, has been
proposed as a criterion in the FMVSS
No. 213 side impact NPRM and is
important for assessing countermeasures
that protect the child’s head in side
impacts. Thus, a uniform response of
the dummy’s head-neck system is
important to achieve. Two qualification
tests serve to assure the uniformity of
the head response in an impact: A
lateral head drop test and a frontal head
drop test. In both qualification tests, the
pass/fail specification is based on the
resultant acceleration measured at the
center of gravity (CG) of the head.
Procedures for both tests also place
limitations on the off-axis acceleration
to assure that the free-fall of the head is
uniform prior to impact.
Lateral Head Drop
The lateral head drop test is carried
out by cradling the head within a
looped wire rope, suspending the head
200 mm above a steel plate, and
releasing the wire rope. The head is
oriented within the cradle so that its
lateral aspect strikes the plate. Lateral
impacts are carried out on the left and
right aspects of the head.
40
The NPRM proposed that the head
must respond with peak resultant
acceleration between 113 g and 140 g
when dropped from a 200-mm height
such that the side of the head lands onto
a flat rigid surface (lateral head drop).
Off-axis acceleration was proposed to be
+/¥20 Gs. These values were based on
tests of NHTSA’s four Q3s dummies.
For the final rule, NHTSA has set the
lateral qualification limits as: Peak
resultant acceleration is 114–140 Gs
(spaced 10.2% from the range’s
midpoint of 127 Gs). Off-axis
acceleration: +/¥15 Gs. These values
are based on tests of the seven Q3s
dummies.
Test Repeatability. Test repeatability
problems became apparent once the
agency began to assess lateral head drop
data from the outside labs. NHTSA
believes that the problem existed even
at the time of the NPRM as many of the
CVs reported in the NPRM were just
under 5%, which, upon reexamination,
were high for such a simple test. None
of the CVs for the frontal head drop was
over 2 percent.
The problem was first discovered in
the initial tests performed at MGA on
serial no. 007. Fourteen trials were
needed to attain the desired sample of
ten trials (five left, five right) in which
the off-axis acceleration was under the
NPRM’s requisite 20 Gs (and only three
of those were under 15 Gs). The CV for
the resultant head acceleration was over
8% in the trial tests, which is
unacceptably high.
The variability was eventually traced
to MGA’s head drop apparatus. MGA
had used a one-piece cable loop to
cradle the head, and the cradle was
released via a magnetic actuator. Upon
release, the head rotated slightly during
its free-fall creating elevated off-axis
accelerations and high variability in the
resultant accelerations.
For its subsequent series of tests on
serial nos. 008 and 5680, MGA
developed an improved test protocol
that included a two-cable cradle that
mitigated the problem. Off-axis
acceleration was below 20 Gs in all
twenty trials and below 15 Gs in sixteen
of the trials.
41
Calspan had similar difficulty with its
drop apparatus, which made use of a
pneumatic actuator to release the cradle.
In its initial tests, Calspan needed
nineteen trials to attain the desired
sample of 5 left and 5 right trials with
an off-axis acceleration under 20 Gs.
However, like MGA, Calspan could
achieve the 20 G limit in their
subsequent series (with ten trials each
with serial nos. 008 and 059).
At VRTC, the cradle was released by
cutting the end of the cable. There were
no problems with keeping the off-axis
accelerations below 20 Gs, though in
retrospect it was still unusually high for
such a simple test (the average was 12
Gs, with a range of 7–18 Gs).
High off-axis acceleration was
particularly problematic for serial no.
007 (one of the older, NHTSA-owned
units) at all four labs where it was tested
(53 trials total). NHTSA observed that
the flesh parting line
42
on the head
coincided with the point of impact,
causing added variability for that
particular unit (the effect was more
pronounced with serial no. 007 than
with other dummies.) About half of the
tests with no. 007 produced off-axis
accelerations greater than 15 Gs, with 13
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All NPRM upper/lower limits, including 20 Gs,
were derived from the statistics of the tests. With the further data obtained in the post-NPRM program, NHTSA has determined that 20 Gs was
too broad.
tests (21%) greater than 20 Gs. Just 14
tests were less than 10 Gs.
When data from VRTC, Calspan, and
HIS were further examined, it became
apparent that elevated off-axis
acceleration was correlated with high
variability in the resultant acceleration.
The scatter in data is evident in Table
6 (which represents all dummy tests,
not just serial nos. 007 and 008). The CV
in the resultant acceleration is shown to
increase when the off-axis acceleration
falls in higher ranges. It is highest
(10.24%) when the off-axis acceleration
is above 15 Gs and it is lowest (4.04%)
when under 10 Gs. In the ranges of 0–
10 Gs, 0–15 Gs, and 10–15 Gs, the CVs
are all about the same and all under the
5%. Thus, NHTSA concludes that 15 Gs
is a more appropriate limit than 20 Gs.
43
T
ABLE
6—R
ELATIONSHIP
B
ETWEEN
O
FF
-A
XIS
A
CCELERATION AND
V
ARIABILITY IN
R
ESULTANT
A
CCELERATION
Off-axis acceleration, Gs Number of
trials
Resultant acceleration
Limits, % of
midpoint CV (%)
0–5 ............................................................................................................................................... 0 ........................ ........................
0–10 ............................................................................................................................................. 21 7.7 4.04
0–15 ............................................................................................................................................. 84 10.2 4.47
10–15 ........................................................................................................................................... 64 10.2 4.58
0–20 ............................................................................................................................................. 114 16.2 6.38
10–20 ........................................................................................................................................... 94 16.2 6.71
15–20 ........................................................................................................................................... 30 16.2 9.20
Over 15 ........................................................................................................................................ 34 18.4 10.24
All ................................................................................................................................................. 118 18.4 7.34
For this final rule, NHTSA has set the
limit for off-axis acceleration to +/¥15
Gs. NHTSA notes that this limit is the
same as those for the two other part 572
side impact dummies (Subpart U—ES–
2re (50th percentile adult male) and
Subpart V—SID–IIsD (small adult
female)). NHTSA believes the 15 G limit
(as opposed to an even lower limit) is
sufficient to assure dummy uniformity,
and that lowering it to a lesser value is
needlessly onerous on test labs because
it will likely require many more trials to
achieve acceptable test results. Unlike a
frontal drop, where the direction of the
drop is symmetric with the sagittal
plane of the head, the lateral drop is
asymmetric, making it difficult to attain
an off-axis acceleration below 10 Gs.
When only those tests where the off-
axis acceleration was under 15 Gs were
included, the CVs for repeatability and
test reproducibility for the peak
resultant acceleration were all 5% or
less at all labs with all Q3s dummies.
The agency notes that attaining the
requisite +/¥ 15 G may require multiple
drop tests. Nonetheless, in NHTSA’s test
program all labs could eventually attain
this limit with each dummy they tested.
Moreover, NHTSA believes it would be
a relatively simple matter for labs to
come up with a way to run the test such
that the head does not slip and turn
during its free fall, which should enable
them to meet the 15 G off-axis limit
without difficulty.
Dummy Reproducibility. When
assessing dummy reproducibility in the
lateral drop test, for the reasons stated
above the agency also omitted drop tests
where the off-axis head acceleration is
greater than 15 Gs, and the tests at MGA
on serial no. 007. There was still an
ample number of trials (84) without
those tests to make a reasonable
assessment of dummy reproducibility.
The CVs for dummy reproducibility
in lateral head drop tests at the various
labs ranged for 7.0% to 11.7%, which
reflects a fairly wide range of head
acceleration responses. Nonetheless, the
qualification criteria are set at 114–140
Gs, which reflects the upper and lower
limits spaced only 10.2% from the
midpoint.
NHTSA concludes that the
qualification limit of 10.2% is
appropriately balanced to accommodate
dummy reproducibility without being
unreasonably hard for test labs to attain.
The narrowness of the final limits is
also consistent with other part 572
dummies, as shown in Table 7 below,
and is needed to assure a sufficient level
of uniformity in head response. As
stated above, the head’s acceleration is
an important criterion for assessment of
head injury. Thus, the acceptance
criteria should be narrow enough to
achieve a uniform response of the head-
neck system of the Q3s.
T
ABLE
7—A
CCEPTANCE
C
RITERIA FOR
R
ESULTANT
H
EAD
A
CCELERATIONS IN
H
EAD
D
ROP
T
ESTS FOR
V
ARIOUS
ATD
S
Dummy Aspect
Resultant head acceleration
Lower limit, G Upper limit, G +/¥ % of
midpoint
Q3s (final rule) ................................................................................................. Lateral ............ 114 140 10.2
Q3s (proposed) ................................................................................................ Lateral ............ 113 140 10.7
Side Impact Dummy Crash Test Dummy, Small Adult Female (SID–IIsD) .... Lateral ............ 115 137 8.7
Side Impact Crash Test Dummy 50th Percentile Adult Male (ES–2re) .......... Lateral ............ 125 155 10.7
Q3s (final rule) ................................................................................................. Anterior .......... 255 300 8.1
Q3s (proposed) ................................................................................................ Anterior .......... 250 297 8.6
Hybrid III (HIII) 3-Year-Old Child Crash Test Dummy (HIII–3C) .................... Anterior .......... 250 280 5.7
Six-year-old Child Test Dummy (HIII–6C) ....................................................... Anterior .......... 245 300 10.1
HIII 10-Year-Old Child Test Dummy (HIII–10C) ............................................. Anterior .......... 250 300 9.1
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‘‘Biofidelity Assessment of the Q3s Three Year-
Old Child Side Impact Dummy,’’ supra.
T
ABLE
7—A
CCEPTANCE
C
RITERIA FOR
R
ESULTANT
H
EAD
A
CCELERATIONS IN
H
EAD
D
ROP
T
ESTS FOR
V
ARIOUS
ATD
S
Continued
Dummy Aspect
Resultant head acceleration
Lower limit, G Upper limit, G +/¥ % of
midpoint
HIII 5th Percentile Adult Female (frontal) Test Dummy .................................. Anterior .......... 250 300 9.1
NHTSA observed that the envelope of
114–140 Gs reflects the data from all the
considered tests of the Q3s, but that two
of the three newest dummies, those
owned by Calspan and Britax, registered
high head acceleration responses
relative to NHTSA’s older units and the
newer MGA unit. NHTSA had to decide
how to set the qualification limits for
the head given the differences in
dummy head performance.
If NHTSA had set qualification limits
to include at least one test trial from all
dummies tested (the NHTSA-owned
units and the three newer units), limits
greater than 13% would have resulted.
The agency was concerned that such
limits would be too wide for regulatory
purposes, especially because the Q3s’s
head acceleration measurements would
probably determine a pass or fail in any
future application of the dummy. No
other part 572 ATD has limits wider
than 11% for a head drop test (anterior
or lateral).
The agency also considered the
possibility of calibrating the limits
around the new units (which generally
produced higher head accelerations)
even though one or more of the NHTSA-
owned units may not be able to qualify.
When only the three new units were
considered (combining data from tests at
VRTC, MGA, HIS, and Calspan), limits
within 11% were possible.
After further investigation, however,
NHTSA decided against this alternative
too. The agency’s first step in assessing
whether to use only the new units was
to assess the biofidelity of the new Q3s
units. When the agency assessed the
head of the Britax unit (which produced
the highest response) against the
biofidelity targets to confirm that it was
within the limits of acceptability, the
agency found it was not. The limits of
biofidelity acceptance are generally
wider than qualification limits owing to
the variability associated with human
subjects. As explained in the NPRM, the
test to assess lateral biofidelity is
slightly different from the qualification
test (78 FR at 69949). Derived by SAE
(Irwin, et al, 2002), the target response
is referenced from the non-fracture zone
of the head (opposite the point of
impact). For a 3-year-old, the target
resultant acceleration is 114–171 Gs.
The test results for the NHTSA-owned
units fell squarely within these limits.
For the Britax unit, however, the tests
produced a resultant acceleration of 189
Gs, which is well beyond the limits of
acceptability. Thus, if the qualification
limits were recalibrated around the
newer units, the limits would be set
based on readings of a non-biofidelic
dummy. NHTSA decided that such an
approach would sacrifice dummy
biofidelity and is unacceptable.
Accordingly, NHTSA decided that the
final acceptance criteria for the lateral
head drop qualification test should be
centered around essentially the same
midpoint as the NPRM. Thus, all
NHTSA-owned units remain centered
within the limits of acceptability. There
is no potential sacrifice in biofidelity,
unlike the result if limits were
established around non-biofidelic Q3s
units.
NHTSA notes that, under the
qualification limits of this final rule, a
‘‘pass’’ was observed with the older
NHTSA-owned units at all labs and in
almost every trial. Newly-manufactured
Q3s dummies, on the other hand, did
not always qualify. Of the three new
units tested, only the MGA unit
consistently produced a passing result
against the final qualification criteria.
The Britax unit was well above the
upper limit, a result that was observed
repeatedly in all trials at both labs in
which it was tested. The Calspan unit
was borderline acceptable. HIS had
reported responses within the limits,
but Calspan was not able to consistently
produce a passing result at its lab. Given
these results, there is a possibility that
some dummy heads of newer Q3s units
in the field may need to be re-worked
to pass the lateral head drop criterion of
this final rule.
Frontal Head Drop
The NPRM proposed that the head
must respond with peak resultant
acceleration between 250–297 Gs (8.6%
of the midpoint) when dropped from a
376 mm height. The head is oriented
such that its sagittal plane is parallel
with the direction of impact and the
anterior-most aspect of the forehead
strikes a steel plate. Off-axis
acceleration was proposed to be +/¥15
Gs. These values were set based on tests
of NHTSA’s 4 Q3s dummies.
For the final rule, NHTSA has set the
frontal qualification limits as: Peak
resultant acceleration is 255–300 Gs
(8.1% of the midpoint). Off-axis
acceleration: +/¥15 Gs (no change from
NPRM). These values are based on tests
of the seven Q3s dummies.
Test R&R. The CVs for test R&R were
universally low at all labs and for all
dummies (all below 4%). Unlike a
lateral drop, the motion in the head in
the frontal drop is symmetric about the
sagittal plane, i.e., rotation of the head
during and after the impact takes place
about the y-axis only. This makes it
much easier to produce a repeatable
response and to attain a low off-axis
acceleration. In the NPRM, the off-axis
limit for acceleration was only 15 Gs
(vs. 20 Gs for the lateral drop). The 15
G off-axis limit was easily met at all labs
with all dummies. NHTSA notes that
the 15 G limit for frontal drops is also
consistent with other part 572 dummies,
as shown previously.
Dummy Reproducibility. For the
frontal drop test, the CVs for dummy
reproducibility were under 6% for all
but one dummy—serial no. 5860, the
MGA-owned unit. Relative to the others,
the MGA head registered low responses
at both labs (HIS and MGA) where it
was assessed, resulting in an elevated
CV statistic of 8.0% at HIS and 5.4% at
MGA. If only the new units are
considered (combining data from tests at
VRTC, MGA, HIS, and Calspan), the CV
statistic is 6.8% for all three units vs.
3.4% when the MGA unit is excluded.
The Britax and Calspan units had high
responses in the lateral drop tests but
were in line with each other and with
NHTSA’s older units in the frontal head
drop test.
The lower limit of 255 Gs coincides
with the lower limit of an acceptable
biofidelic response as described in the
NPRM.
44
At this limit, the MGA unit
did not qualify in any of its seven trials
at either of the two labs where it was
tested (HIS and MGA), as its response
was too low. The highest response it
produced in any of the trials was 242 G,
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45
In the NPRM, the set of limits for the moment
was constructed via the +/¥10% rule rather than
+/¥3 standard deviations.
well below the biofidelity target. This
response is unacceptably low (non-
biofidelic). Aside from the MGA unit,
only the Calspan unit was at all
marginal. Its response was borderline
low in tests at HIS (253 Gs on average),
but at Calspan it was squarely within
the limits.
NHTSA’s final upper limit of 300 Gs
(raised from 290 Gs in the NPRM) is still
well within the acceptable biofidelity
limit of 315 G. There were no problems
staying under the upper limit for any
dummy in any trial at any lab. By
raising the upper limit to 300 Gs,
NHTSA is maintaining essentially the
same limit widths (8.1% of the
midpoint) as those proposed in the
NPRM.
As noted above, a uniform head
response for the Q3s is particularly
important to assess child side impact
protection. Thus, NHTSA has set the
resultant acceleration limits for the
frontal head drop narrower than the
11% guideline target for all responses.
This approach is consistent with other
part 572 dummies. The Q3s width of
8.1% (i.e., the +/¥ limits of the nominal
qualification target) is roughly the
equivalent to the average of the other
dummies.
d. Neck
A biofidelic and repeatable kinematic
response of the head-neck system is
important to quantify the protection
offered by CRSs in an impact. The
acceptable criteria for the neck
qualification test in this final rule
consist of three test components: Lateral
flexion, frontal flexion, and torsion neck
pendulum tests. These tests serve to
assure uniformity of the head
kinematics in both a head impact and
non-impact. In each test, the neck
moment, the rotation of the neck, and
the timing associated with the moment
and rotation are assessed. All three use
the conventional part 572 swinging
pendulum to apply a prescribed
impulse to the neck, with a headform
designed to mimic the inertial
properties of the head attached to it.
Lateral Flexion
The lateral flexion test specifies a 3.8
m/s impact speed with a prescribed
deceleration pulse. A column of
collapsible aluminum honeycomb is
used to decelerate the pendulum at a
relatively constant level of force. Part
572 specifications for almost all other
dummies use the pendulum/honeycomb
device for testing necks. Test labs
generally adjust the honeycomb in some
manner (for instance, by modifying the
number of cells engaged by the
impacting face of the pendulum) to
attain the prescribed pulse.
The NPRM proposed a maximum
rotation of 77–88 degrees (6.7% from
the midpoint). The maximum moment
was proposed to be 25–32 Nm (12.3%
of the midpoint).
This final rule sets the maximum
rotation at 76.5–87.5 degrees (6.7% of
the midpoint). The maximum moment
is set at 25.3–32.0 Nm (11.7% of the
midpoint).
Test R&R and Dummy
Reproducibility. All four labs exhibited
CVs below 5% for test repeatability in
lateral flexion for both the rotation and
the moment.
NHTSA did, however, observe some
lab-to-lab variability in the bending
moment which resulted in CVs for test
reproducibility that ranged from 6.3% to
7.2% for both Q3s units that were used
in the assessment. This was not entirely
unexpected.
45
The variability in test
reproducibility is likely attributed to
lab-to-lab differences in the aluminum
honeycomb, such as the lab
modifications of the number of
honeycomb cells used in the
qualification tests. Also, after impact,
the trajectory of the headform does not
occur within a single plane of motion
because the neck bends along its non-
symmetric axis. This generally reduces
test reproducibility.
The agency did not discern any trends
that would indicate that the responses
of the necks have changed over time.
Also, the CVs were under 5% for test
reproducibility and under 6% for
dummy reproducibility for all measures
of neck rotation and neck moment. This
further suggests that the variability is
due to the variability in test equipment
(i.e., honeycomb) among the various
labs.
In summary, all dummies and all labs
could demonstrate a qualification pass
for both rotation and moment. The
results show that the necks themselves
were highly uniform, but test labs may
need to evaluate different honeycomb
configurations to demonstrate a passing
response. Experimenting with
honeycomb is typical of the
qualification process with all part 572
dummies.
Frontal Flexion
The NPRM proposed a maximum
rotation of 70–82 degrees (7.9% of the
midpoint), and a maximum moment of
41–51 Nm (10.9% of the midpoint).
For the final rule, the acceptance
criteria for the frontal flexion test are set
as: Maximum rotation is 69.5–81.0
degrees (7.6% of the midpoint). The
maximum moment is 41.5–50.7 Nm
(10.0% of the midpoint). The frontal
flexion test specifies a 4.7 m/s impact
speed and its own deceleration pulse.
Crushing of aluminum honeycomb is
also used to generate the prescribed
deceleration pulse.
Test R&R and Dummy
Reproducibility. The CVs for test R&R
and dummy reproducibility were
universally low at all labs and for all
dummies and for both neck rotation and
neck moment (all below 4%). Unlike the
lateral and torsion tests, the motion in
the headform in the frontal flexion test
is symmetric about the sagittal plane. In
other words, rotation of the headform
during and after the impact takes place
about the y-axis only. This makes it
much easier to produce a repeatable
response and to attain a low off-axis
acceleration.
For the neck flexion test, the wide
intervals specified in the NPRM (built
around 3 standard deviations) proved to
be unnecessarily large, even with the
latest results from the additional
dummies tested at different labs added
to the data pool. Therefore, NHTSA has
narrowed the limits for the final rule
from those of the NPRM. All dummies
at all labs were demonstrated to pass at
the narrower limits of the final rule.
Torsion
During CRS testing, the Q3s neck
might flex with varying degrees of neck
twist. The agency, therefore, proposed a
procedure to assure that the neck is
uniform under twist. The proposed neck
torsion test uses a special test fixture
attached to the part 572 pendulum,
which imparts a pure torsion moment to
the isolated neck. It specifies a 3.6
m/s impact speed with a defined
deceleration pulse. Qualification is
based on the rotation and moment about
the long axis of the neck.
The NPRM proposed that, for the neck
torsion test, the maximum rotation must
be 75–93 degrees (10.7% of the
midpoint). The maximum moment is
8.0–10.0 Nm (11.1% of the midpoint).
For this final rule, the final
acceptance criteria for the qualification
test are set as follows. The maximum
rotation limits are 74.5–91.0 degrees
(10.0% of the midpoint). The maximum
moment limits are 8.0–10.0 Nm (11.1%
of the midpoint) (unchanged from the
NPRM).
Test R&R and Dummy
Reproducibility. All four labs exhibited
low CVs for test repeatability and
reproducibility for both the rotation and
the moment, with one exception. At
MGA, the variability in neck moments
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The following discussion also applies to the
timing specifications for the lumbar column
qualification tests.
on serial no. 007 was slightly elevated
(CV=5.9%) for the left aspect only.
However, this elevation is mostly a
function of the low moment generated
by the test (only 9 Nm nominally),
where variations as little as +/¥1 Nm
created a high CV. All moments were,
in fact, within the prescribed, and
narrow, 8–10 Nm range specified in the
NPRM. The CVs for dummy
reproducibility were universally low
(below 6%) at all labs and for all
dummies, and for both neck rotation
and neck moment. In every trial, all
dummies at all labs demonstrated a pass
in accordance with the acceptance
criteria of this final rule.
e. Lumbar Column
The Q3s’s rubber lumbar column
bends during a CRS side impact test.
This bending can affect the overall
kinematics of the dummy, including the
excursion of the head. It can also affect
lateral loads and the deflection of the
thorax.
Lumbar qualification consists of two
types of pendulum tests: A lateral test
and a frontal test. For both tests, the
lumbar spine element containing the
flexible column is removed from the
dummy, like the neck qualification
tests. The lumbar tests use the same part
572 swinging arm pendulum and the
headform device used in the neck
qualification tests. The headform is not
intended to represent the inertial
properties of a body region as it is with
the neck tests. Rather, it merely
provides an apparatus that helps to
ensure a repeatable test condition. The
lumbar tests also use crushable
aluminum honeycomb to attain a
prescribed deceleration pulse.
In the case of the lumbar
qualification, lateral and frontal tests are
conducted at the same impact speed of
4.4 m/s and specify the same pendulum
impulse. The rotation of the lumbar
column, the lumbar moment, and the
timing associated with the moment and
rotation are set forth in this final rule.
The agency notes that the lumbar
qualifications for lateral and frontal tests
are almost identical. This is to be
expected since the lumbar element is a
circular cylinder constructed from an
isotropic material (rubber), and so,
theoretically, the directional properties
should be the same for lateral vs. frontal
bending. However, the agency has
established two separate sets of
acceptance criteria owing to possible
dissimilarities brought on by the
molding and bonding processes and
asymmetries of inertial influences due
to differences in the configuration of
mounting plates and headform.
Further, the frontal flexion test helps
assure that the metal-to-rubber bond of
the lumbar is intact in a manner the
lateral flexion test does not. This was
demonstrated during the very last series
of tests on NHTSA-owned serial no. 008
Q3s dummy, where NHTSA observed a
slight separation after the first of five
trials. The subsequent trials all
produced a rotation failing the limits of
the NPRM and the final rule, whereas
lateral flexion tests performed on the
damaged part resulted in passes. That is,
the frontal test detected the tear in the
part, whereas the lateral test did not.
Lateral Flexion
This test mimics the main bending
direction of the Q3s’s torso during a
CRS side impact test as proposed in the
FMVSS No. 213 upgrade. This test
assures uniformity in such bending.
The NPRM proposed a maximum
rotation of 47–59 degrees (11.3% of the
midpoint). The maximum moment was
proposed to be 78–97 Nm (10.9% of the
midpoint).
This final rule sets the maximum
rotation at 46.1–58.2 degrees (11.6% of
the midpoint). The maximum moment
is set at 79.4–98.1 Nm (10.5% of the
midpoint).
Test R&R and Dummy
Reproducibility. At all four labs, the CVs
for test repeatability and test
reproducibility were below 5% and 6%,
respectively, for both the rotation and
the moment with all dummies. For
dummy reproducibility, however, the
CVs were above 6% at two of the labs.
Tests revealed that two of the newer
units, the Britax-owned unit (tested at
VRTC) and the MGA-owned (tested at
MGA), produced greater rotations than
the older NHTSA-owned units. As a
result, the CVs for dummy
reproducibility in lumbar rotation at
VRTC and MGA were 6.5% and 7.4%,
respectively.
All dummies at all labs were
demonstrated to pass the qualification
limits of this final rule. The margins for
acceptance are essentially the same as
those of the NPRM, but the midpoints
for both rotation and moment have been
shifted slightly downward for rotation
and upward for moment.
Frontal Flexion
The proposed FMVSS No. 213 side
impact test is carried out at a slight
oblique angle. Typically, the torso of the
Q3s bends laterally and slightly
forward, so NHTSA has included a
frontal (forward) component to the
lumbar qualification.
The NPRM proposed a maximum
rotation of 48–57 degrees (8.6% of the
midpoint) in the NPRM. The maximum
moment was proposed to be 78–94 Nm
(9.3% of the midpoint).
This final rule sets the maximum
rotation at 47.0–58.5 degrees (10.9% of
the midpoint). NHTSA set the
maximum moment at 78.2–96.2 Nm
(10.3% of the midpoint).
Test R&R and Dummy
Reproducibility. The CVs for test
repeatability and reproducibility were
under 5% and 6%, respectively, at all
labs and all dummies for both rotation
and moment. However, the new MGA-
owned unit produced consistently
higher rotations than the two NHTSA-
owned units, resulting in a CV of 8.0%
for reproducibility of the dummy’s
lumbar in rotation. At VRTC, the new
Britax-owned unit had rotations that
were also high, resulting in a CV
dummy reproducibility score of 6.6%.
At Calspan, its new unit produced
consistently higher lumbar moments
than the two NHTSA-owned units.
Thus, the Calspan CV score for dummy
reproducibility of the lumbar moment
was elevated (7.7%).
All dummies at all labs were
demonstrated to pass the qualification
limits of this final rule. In setting the
new limits, NHTSA has slightly
widened the margins for acceptance
relative to the NPRM for both rotation
and moment to accommodate the newer
units. In both instances, the margins are
still under the 11% goal.
Timing Specifications Associated With
Lumbar Qualification
All pendulum tests for the lumbar
column have specifications on the time
at which the maximum moment and
maximum rotation occur. The agency
has revised the way signal timing is
assessed for the lumbar column and
neck qualification tests and has slightly
increased the time that it takes the
lumbar column (or neck) to return from
its position at peak rotation to the
position of zero rotation. The discussion
of those issues can be found in the
section below.
Timing Specifications Associated With
Neck and Lumbar Qualification
46
1. Maximum Moment and Rotation
All pendulum tests for the neck and
lumbar column place specifications on
the time at which the maximum
moment and maximum rotation occur.
This final rule revises the way signal
timing is assessed.
The test data indicate that the
proposed time specifications were
generally met. There were only a few
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Subpart N, Six-Year-Old Child Test Dummy,
Beta Version (HIII–6C); Subpart P, Hybrid III 3- Year-Old Child Crash Test Dummy, Alpha Version (HIII–3C); Subpart T, Hybrid III 10-Year-Old Child
Test Dummy (HIII–10C).
instances where the peak time was just
under or just over the prescribed
interval. All the tests would have met
the time specifications if the intervals
were expanded by just 1 ms, except for
the time specification for the maximum
moment in the neck lateral flexion test
(see Table 8 below). Here, 60 trials
(about half of all trials) were below the
NPRM lower limit. However, for this
test, the range of allowable times was
only a 7 ms interval, whereas the
intervals in the other four tests ranged
from 11 to 20 ms.
The 7 ms time interval was very
narrow because, along with all
qualification intervals proposed in the
NPRM, it was derived solely from the
statistics of the then-available test data.
The interval of 7 ms represented three
standard deviations from the mean of
data gathered during the NPRM stage.
The very narrow time interval was the
result of running the tests at a single lab
(VRTC) under highly similar impulses
and using aluminum honeycomb from a
common lot.
T
ABLE
8—NPRM T
IME
S
PECIFICATIONS FOR
N
ECK AND
L
UMBAR
Q
UALIFICATION
T
ESTS
NPRM time specifications Number of trials with a time
that differed from the NPRM
time specifications
Qualification test Max.
rotation
(ms)
Max.
moment
(ms) Max.
rotation
(ms)
Max.
moment
(ms)
Neck frontal flexion .......................................................................................... 55–63 49–62 1 0
Neck lateral flexion .......................................................................................... 65–72 66–73 0 60
Neck torsion ..................................................................................................... 91–113 85–105 0 2
Lumbar frontal flexion ...................................................................................... 52–59 46–57 2 1
Lumbar lateral flexion ...................................................................................... 50–59 46–57 0 1
The agency’s latest pooling of test
data reveals that the timing disparity in
the neck lateral flexion test is related to
lab-to-lab variability, not to test
repeatability or dummy repeatability.
For any given lab, the times are
clustered within a very narrow interval
of about 6 ms for all trials of all
dummies tested at that lab. Thus, the
timing discrepancy appears to be related
to the test protocol, not dummy
reproducibility.
Time specifications in final rule.
NHTSA could have expanded this
interval by 6 ms (which would have put
it in line with the other intervals in part
572), which would have resulted in a
pass for all trials. However, rather than
adjusting the NPRM time interval in that
way, the agency has adjusted the way
signal timing is assessed. For the final
rule, the agency has adopted the same
performance specification that is used
for other part 572 child dummies
(Subpart N—HIII–6C; Subpart P—HIII–
3C; Subpart T—HIII–10C).
47
Instead of
using time t = 0 as a reference for the
maximum moment, the final rule
specifies a range for the peak moment
during the time interval when the
rotation is above a specified limit. For
neck flexion, the regulatory text
specifies that Plane D, referenced in
Figure W3 of Part 572, shall rotate in the
direction of pre-impact flight with
respect to the pendulum’s longitudinal
centerline between 69.5 degrees and
81.0 degrees and that, during the time
interval while the rotation is within
these angles, the peak moment
measured by the neck transducer shall
have a value between 41.5 N-m and 50.7
N-m.
Similar wording is used for the neck
lateral, neck torsion, lumbar frontal, and
lumbar lateral tests. All dummies
passed the time specifications at all labs
in all trials using this approach.
This revised specification for the
timing is better than what was proposed
in the NPRM because lab technicians
following the procedure would not have
to pinpoint time = 0 as specified in the
NPRM. In the NPRM, time t = 0 is
defined as: ‘‘All instrumentation data
channels are defined to be zero when
the longitudinal centerline of the neck
and pendulum are parallel.’’ In practice,
determining the instant at which the
parallel alignment occurs can be
challenging, and has a significant
bearing on a pass vs. fail outcome (as
shown by the post-NPRM data, where it
was not unusual that a pass vs. fail
outcome was determined by less than 1
ms). Referencing a particular data point
(the point of maximum rotation)
identifies the reference time with greater
precision.
2. Decay Times
The specification for decay time
specifies the time that it takes the neck
or lumbar column to return from its
position at peak rotation to the position
of zero rotation. This specification is
included in all other part 572 dummies
mentioned previously. It serves to
assure uniformity of the hyperelastic
material used to construct the neck (or
lumbar column). It also ensures that the
later part of the impulse brought on by
the collapse of the aluminum
honeycomb structure is uniform.
The NPRM proposed decay times
listed below in Table 9. In about 15%
of the post-NPRM trials, the NPRM
decay times were not met for neck and
lumbar frontal flexion. Expanding the
NPRM decay interval by only a few
milliseconds results in PASS in all trials
for all dummies at all labs.
T
ABLE
9—Q3
S
M
OMENT
D
ECAY
T
IMES FOR
N
ECK AND
L
UMBAR
Q
UALIFICATION
T
ESTS
Test NPRM
decay time,
ms
Final rule
decay time,
ms
Number of trials
that differed from
the NPRM decay
time specifications
Neck frontal flexion ................................................................................................................ 50–54 45–55 10
Neck lateral flexion ................................................................................................................ 63–69 61–71 0
Neck torsion ........................................................................................................................... 84–103 85–102 0
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The NPRM limits for probe force were at 4.2%,
but they were unusually narrow, even considering
that all data was gathered at a single lab (VRTC).
There is no limit narrower than 5% for any part 572
qualification requirement (displacement or
otherwise).
49
The Infra Red Telescoping Rod for Assessment
of Chest Compression (IR–TRACC) is a device that
measures deflection. It was developed by General
Motors and is manufactured by HIS. NHTSA knows
of no other suppliers of this device. On the other
hand, there are no patents or restrictions that would
prevent another company from manufacturing the
device. Further, although the final rule specifically
calls out the IR–TRACC, NHTSA would consider an
amendment in the future to specify the use of an
alternative device if one were developed that could
sufficiently measure the thorax deflection as the IR–
TRACC does. At this time no such device has been
developed.
T
ABLE
9—Q3
S
M
OMENT
D
ECAY
T
IMES FOR
N
ECK AND
L
UMBAR
Q
UALIFICATION
T
ESTS
—Continued
Test NPRM
decay time,
ms
Final rule
decay time,
ms
Number of trials
that differed from
the NPRM decay
time specifications
Lumbar frontal flexion ............................................................................................................ 50–56 49–59 11
Lumbar lateral flexion ............................................................................................................ 47–59 48–59 0
Decay time in final rule. The decay
intervals for the final rule are listed in
Table 9. In qualification tests for other
part 572 dummies, the intervals for neck
decay times ranged from 10 to 35 ms.
NHTSA considers 10 ms a practical
lower limit on the interval, accounting
for the precision of the measurement
system of any given lab. Thus, the decay
times have been adjusted so that the
intervals are no narrower than 10 ms.
With these time intervals, all dummies
met the decay time interval at all labs
in all trials.
f. Shoulder
This test assures that the shoulder
acts uniformly in the way it deforms
under load and distributes the load
under a lateral impact during CRS
testing, thus helping to ensure that
whole-body kinematics are consistent.
Shoulder qualification is
accomplished with a lateral impact to
the shoulder using a 3.8 kg probe at an
impact speed of 3.6 m/s. Conformity is
based on the maximum probe force and
the maximum deflection of the
shoulder, as measured by a
potentiometer installed within the
dummy.
The NPRM proposed that the peak
probe force must be 1240–1350 N (4.3%
of the midpoint), and that maximum
displacement of the shoulder must be
16–21 mm (13.5% of the midpoint).
This final rule sets the peak probe
force to be 1123–1437 N (12.3% of the
midpoint). Maximum shoulder
displacement is 17.0–22.0 mm (12.8%
of the midpoint).
Test R&R and Dummy
Reproducibility. The CVs for test
repeatability and reproducibility were
below 5% and 6%, respectively, for the
measurements of probe force and
shoulder displacement with all
dummies at all labs.
However, compared to the other three
labs, the probe forces in tests at HIS
were consistently higher for the newer
dummies, whereas for the older NHTSA
units, test repeatability at HIS had
noticeably more scatter. This trend may
have been related to arm positioning.
During the latest testing series, NHTSA
realized that, contrary to the agency’s
intent, the Q3s’s upper arm can meet the
position setting described in the NPRM
in both medial/lateral rotation and in
ab/adduction. In other words, the NPRM
did not specify a unique position for the
upper arm. To address this, in the final
rule, there are more instructions in the
dummy positioning procedure for the
shoulder test as to where to position the
Q3s’s elbows and arms. This simple step
should result in better R&R of the
qualification test.
The CV for dummy reproducibility of
the shoulder force was elevated in three
of the assessments (ranging from 6.1%
to 7.8%). Two of the newer units—5860
owned by MGA and 059 owned by
Calspan—were different from the others
in that they produced lower probe
forces, particularly for the left aspect.
This has resulted in slightly expanded
qualification limits for the shoulder.
While the limits for probe force have
been widened, the midpoint is
essentially the same. At 12.3%, the
limits are now wider than the 11% goal,
but still considerably narrower than
those of other part 572 side impact
dummies (the limits for the ES–2re and
SID–IIsD are both 16%).
48
Also, there is
no immediate injury reference value
directly related to the shoulder in the
proposed FMVSS No. 213 side impact
test, so its uniformity is less important.
For shoulder deflection, the range of
the limits is essentially the same as
those of the NPRM, but they have been
shifted upward to allow greater
deflection. NHTSA considers this an
improvement to the specification. From
a biofidelity standpoint, the shoulder is
stiff relative to a human. Shifting the
deflection limits upward (rather than
downward) is consistent with a more
biofidelic response. The 12.8% shoulder
deflection limits sound relatively wide,
but are not of concern because they are
a function of the low level of deflection
seen in the test (only 17–22 mm). This
5 mm interval is lower than that of any
deflection-based limit of any other part
572 dummy (several dummies have
limits with 6 mm intervals).
Almost all dummies at all labs met
the probe force and shoulder
displacement criteria of this final rule.
The only exception was with the probe
force on the left aspect of the MGA unit.
In all trials run at MGA, the force was
well below the qualification limits, so it
is possible the dummy may need some
remedial work, e.g., a part replacement
or some other fix. On the other hand,
the dummy’s response was well-
centered between the limits in trials at
HIS, so the MGA results could have
resulted from a problem with the test set
up or position of the arm.
g. Thorax
The response of the thorax under
lateral loading is a high-priority
performance target for the Q3s because
thorax deflection is an injury reference
measurement in the proposed FMVSS
No. 213 side impact test. Qualification
of the thorax is carried out under two
separate conditions: Without arm
interaction (a test probe strikes the
thorax directly); and with the arm in
place (with the elbow lowered so that
the probe strikes the upper arm).
Thorax Without Arm
The ‘‘thorax without arm’’ test assures
uniformity of the thorax structure,
including its mount to the spine, and its
response to a direct impact in terms of
rib deflection. For this test, the arm is
completely removed from the dummy.
The test is carried out by striking the
dummy on the lateral aspect of the
thorax with a 3.8 kg probe at a speed of
3.3 m/s. Conformity is based on the
probe force and the thorax displacement
as measured by an IR–TRACC
49
mounted within the dummy’s chest
cavity.
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Some already-purchased newer Q3s dummies
in the field might have the overly stiff thorax. Users
may have to remedy the part to pass the thorax
without arm test.
The NPRM proposed that the peak
probe force must be 620–770 N (10.8%
of the midpoint). The maximum
displacement of the thorax was
proposed to be 24–31 mm (12.7% of the
midpoint).
This final rule sets the peak probe
force to be 610–754 N (10.6% of the
midpoint). Maximum thorax
displacement is 24.5–30.5 mm (10.9%
of the midpoint).
Test R&R and Dummy
Reproducibility. The CVs for test
repeatability and reproducibility were
all below 5% and 6%, respectively, for
the measurements of probe force and
thorax displacement with all dummies
at all labs. However, several of the CVs
for dummy reproducibility were
between 6% and 10%. The data showed
that the new MGA and Britax units were
stiffer than the other ATDs, resulting in
higher probe forces and lower thorax
displacements than the other dummies.
The high stiffness in the newer units
is a major concern for NHTSA.
Throughout the development cycle of
the Q3s, the agency has stressed the
importance of lateral thorax biofidelity.
In the NPRM, NHTSA demonstrated
that thorax biofidelity was assessed
through a series of pendulum impacts
prescribed by SAE International. The
probe force was used to assess the
external biofidelity of the thorax, and
upper torso (T1) acceleration was used
to assess internal biofidelity. The tests
showed that the units that NHTSA used
to develop the NPRM (which included
serial nos. 004, 006, 007, and 008) all
performed very close to the biofidelity
targets.
Given the thorax results with the
MGA and Britax units, it was important
to assess their performance against the
biofidelity targets. NHTSA re-ran the
biofidelity tests on two units: An older
NHTSA-owned unit (serial no. 007) and
the new, stiffer unit, the MGA-owned
serial no. 5860. The tests on serial no.
007 served as a benchmark and again
showed that it performed very much
like it had during the NPRM stage (i.e.,
close to the biofidelity targets). On the
other hand, serial no. 5860 (the MGA
unit) was barely within the margins for
acceptable biofidelity. It exhibited
elevated T1 acceleration and straddled
the upper corridor of the target for the
probe force but stayed within the
corridor.
For the final rule, NHTSA formulated
the acceptance criteria for the
qualification test so that they stayed
under the 11% goal for qualification
limits. The nominal response of the
MGA unit served as the upper limit
since it met the biofidelity corridor. All
responses generated in tests of the
Britax unit fell outside the qualification
limits, however. The probe responses in
the Britax tests were well above the final
upper qualification limit at both labs
where it was tested (HIS and VRTC) for
all trials, both right and left. It is also
noted that the Britax unit’s deflection
was on the lower border of the final
qualification limit for thorax deflection.
The results of tests of the newer Britax
unit show that its thorax was much too
stiff. NHTSA considered this thorax
substandard. In formulating the probe
force limits for the thorax without arm
test, the data from the Britax unit is not
within the acceptance criteria.
50
Thorax With Arm
The ‘‘thorax with arm’’ test loads the
ribcage through the upper arm. It
assures uniformity of the arm in the way
the arm absorbs energy and interacts
with the thorax in a lateral impact.
This test is carried out with the elbow
lowered and the upper arm aligned with
the dummy’s thorax. The lower arm is
positioned to make a 90° angle with the
upper arm. (For this final rule, the
added stipulation for upper arm
positioning (discussed earlier in
conjunction with the shoulder test) will
be used in this test too, to help labs
attain the specified response.)
The position of the 3.8 kg probe
relative to the thorax is the same as in
the ‘‘thorax without arm’’ test (the same
probe is used as well). However, the
impact speed of the probe for this
‘‘thorax with arm’’ test is 5.0 m/s (vs. 3.3
m/s). Conformity is again based on the
probe force and the IR–TRACC’s
measure of thorax displacement.
The NPRM proposed that the peak
probe force must be 1380–1690 N
(10.1% of the midpoint). The maximum
displacement of the thorax was
proposed to be 23–28 mm (9.8% of the
midpoint).
This final rule sets the peak probe
force to be 1360–1695 N (11.0% of the
midpoint). Maximum thorax
displacement is 22.5–27.5 mm (10.0%
of the midpoint).
Test R&R and Dummy
Reproducibility. The CVs for test
repeatability were below 5% for all
assessments except one. At HIS, four
separate repeatability assessments were
scored based on tests with two NHTSA-
owned units, serial nos. 004 and 007,
with separate scores for right-side and
left-side impacts. Three of the four
produced CV scores below 5%. The
fourth (on serial no. 007, right side)
produced an elevated CV score of 9.3%,
which was driven upward by greatly
elevated probe forces in two of the six
trials. HIS did not provide an
explanation for the elevated force levels.
The CV for test reproducibility was
below 6% in all instances except, again,
for the probe force on the right side of
serial no. 007. A CV score of 7.4% was
driven upward by the same two trials
discussed above. Without the two, the
CV was 4.3%.
Dummy reproducibility ratings were
elevated for this test (individual lab
scores ranged from 11% <CV 15%).
NHTSA’s assessment revealed scatter in
the measurement of probe force among
the newer Q3s units. The lowest forces
were generated by the Calspan-owned
unit while the Britax-owned unit
produced consistently high forces.
Probe forces in trials with the MGA-
owned unit were between those
produced with the Calspan-owned and
Britax-owned units, and in line with the
older NHTSA-owned units.
The final qualification limits for the
thorax displacement are essentially the
same as those of the NPRM. At these
limits (10% of the midpoint), all
dummies were demonstrated to pass at
all labs. NHTSA considers the
acceptance interval of 5 mm (for the
22.5–27.5 mm limit) to be tight. As
described earlier for the shoulder
qualification (which also has a 5 mm
interval), no other part 572 interval is
less than 6 mm.
For the probe force, the final limits
(1360–1695 N) have been expanded
slightly from those of the NPRM (10.1%
to 11%). However, they have been
restricted to the 11% goal since the
stiffness of the lateral aspect of the
dummy can influence its interaction
with a CRS in a side impact test.
This test has screened out some Q3s
units from qualifying. Calspan could not
qualify serial no. 059 (its own unit). All
trials produced probe forces well below
the 1360 N limit. The Britax-owned unit
straddled the upper limit of 1695 N. The
added stipulation for upper arm
positioning should be beneficial in
helping attain the specified response.
h. Pelvis
This test helps assure uniformity in
the way the pelvis loads a CRS during
a side impact test. The qualification test
is carried out by striking the lateral
aspect of the pelvis (near the hip) with
a 3.8 kg probe at 4.0 m/s. (The probe is
the same as that used in the shoulder
and thorax qualifications.)
Conformity is based on the force
measured by the impacting probe. The
NPRM proposed that the peak probe
force must be 1575–1810 N (7.1% of the
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51
By removing the pubic load requirement, the
pubic load cell is no longer necessary and a ‘‘blank’’
structural replacement may be installed in its place.
52
See ‘‘NHTSA’s Q3s Qualification Testing,
2014–2015, May 2016,’’ in the docket for this final
rule. The agency also generally provides
qualification plots in NHTSA’s compliance test
reports for CRS testing. These reports are available
for the public to download.
53
Note that HIC15 = 570 is the pass/fail reference
value proposed for the Q3s in NHTSA’s NPRM to
upgrade FMVSS No. 213 (see 79 FR 4570). It is also
the pass/fail reference value for the Hybrid III 3-
year-old dummy when assessing the deployment of
air bags in FMVSS No. 208, ‘‘Occupant crash
protection.’’
midpoint). This final rule sets the peak
probe force at 1587–1901 N (9.0% of the
midpoint).
The NPRM had also proposed to limit
the peak pubic load measured by a load
cell within the dummy. The NPRM
proposed that the peak pubic load be
between 700–870 N (10.8% of the
midpoint). As explained below, on
further consideration, NHTSA has not
adopted the pubic load criterion.
Test R&R and Dummy
Reproducibility. For the probe force, the
CVs for test repeatability were below
5% for all assessments at all labs.
Essentially all dummies at all labs were
demonstrated to pass the probe force
limit. The only exception was with the
right aspect of the serial no. 008
dummy, a NHTSA-owned unit. While in
all trials run on this dummy at MGA the
force was well below the lower
qualification limit for probe force, the
response for this dummy was well
centered between the limits in trials at
VRTC and Calspan. Thus, there may
have been a test set up anomaly at MGA
on serial no. 008, and the low forces
caused two instances of elevated CVs for
test reproducibility (7.6%) and dummy
reproducibility (6.7%).
For the pubic load measurement, the
CVs for test reproducibility and dummy
reproducibility were mostly above 6%
and as high as 15%. NHTSA analyzed
the data and found sources for the
variability in both the test procedure
and in differences among the dummies.
The undesirable test reproducibility
rating is most likely a consequence of
striking the dummy at the hip over the
ball and socket joint that joins the femur
to the pelvis. The force generated by the
probe is transmitted to the pubic load
cell through this joint only. Since a ball
joint exerts no reaction moments to
restrict rotation, even if the dummy and
probe are lined up precisely in the pre-
test set up, upon impact there is little to
control the rotation of the femur relative
to the pelvis. Thus, the reaction force in
the direction of the pubic load cell will
have a relatively high degree of
variability from one test set up to the
next.
Further, differences in the
construction of the dummy most likely
exacerbated the variability related to
striking the ball and socket joint. The
test probe contacts the dummy on the
surface of the femur, which is made
largely of urethane and plastic. The
femur bone itself is a plastic part (with
a steel reinforcement) embedded within
a thick molding consisting of urethane
foam coved by a polyvinyl chloride
(PVC) skin. By their very nature, these
parts require much larger dimensional
tolerances than metal parts and they
have a much more variable response to
impact. Furthermore, the relationship
between the point of impact on the
femur skin and the center of the femur
head is loosely controlled (there is no
dimensional requirement for this
relationship on the engineering
drawings).
Due to the elevated degree of
variability associated with the pubic
load, NHTSA has decided not to adopt
the pubic load criterion in the final
rule.
51
Uniformity in the pubic load is
not a necessary qualification since it is
not associated with any proposed injury
assessment reference value in the
FMVSS No. 213 rulemaking. Further,
probe force—which NHTSA is adopting
as a qualification—is a better measure of
dummy loading to the child restraint
system, which is the primary concern
for the pelvis.
VII. Response to Comments (Part II) on
the Acceptance Criteria and Test
Procedures for the Qualification Tests
In this section, NHTSA responds to
comments on specific aspects of the
acceptance criteria and test procedures
used for the qualification tests.
a. Head Qualification
Comment Received
Dorel stated that HIC signal data are
not available to them for further
analysis. Dorel also believed that the
proposed limits of acceptability, 113–
140 Gs for lateral acceleration, allow too
wide of an acceptance band, thus
creating what the commenter said was
the potential for a high degree of HIC
variability in CRS compliance testing.
NHTSA Response
NHTSA has provided data tables and
plots of dummy instrumentation signals
within supporting reports referenced in
this final rule and in the NPRM.
52
The
qualification report describes a series of
sled tests with two Q3s units, serial nos.
006 and 007, in which each unit was
tested five times in left side impacts
under otherwise identical conditions. In
these tests, the average HIC value was
700.4 with a CV of 2.4%.
In contemporary head qualification
tests on the left aspect of these same
units (five trials each), the CV of the
resultant head acceleration was 2.97%,
which is slightly greater than the HIC
variability observed in sled tests.
Therefore, in any future repeat testing of
a particular CRS with multiple Q3s
units, the variability seen in HIC values
caused by slightly different dummy
heads is expected to be no more than
the variability allowed by the
qualification limits of +/¥10.2%.
NHTSA views this level of variability as
representative of a reasonable design
margin. For example, to assure that
HIC
15
= 570 is not exceeded,
53
a
manufacturer may need to design their
CRS to achieve an average HIC value of
only HIC
15
= 517. This accounts for a
possible outcome that might be 10.2%
higher if a test is run with any other Q3s
unit.
Thus, the agency does not agree there
is a potential for a high degree of HIC
variability in compliance testing.
Furthermore, in the final rule, the limits
on the resultant head acceleration in the
lateral head drop test narrowed slightly
(114–140 Gs) from those proposed in the
NPRM (113–140 Gs). As discussed
above, NHTSA has also narrowed the
allowable off-axis acceleration to +/¥15
Gs from +/¥20 Gs in the NPRM. This
change has a positive effect on assuring
head uniformity in a lateral impact.
As stated earlier, the qualification
limits of 114–140 Gs assure a
sufficiently high level of uniformity in
the responses of replicate dummies
without being unreasonably hard for test
labs to attain. The limits are also
consistent with other part 572 dummies
as shown previously (see Table 7).
Comment Received
Dorel commented on the data
produced by the head drop tests and the
duration of the impact event. It noted a
variation in the duration of the
acceleration of about 12% from the
mean among the four heads that the
agency tested. By showing that the
duration of the acceleration seen in
NHTSA’s head qualification tests varies,
Dorel surmised that the dummy head
may produce variance in HIC that is
unacceptably wide.
NHTSA Response
With regard to the duration of the
impact event, the NPRM did not set a
specification for the duration of the
head drop acceleration, and no such
specification exists for any other
dummy within part 572. Such a
specification is not needed because the
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The Q3 is one of a group of dummies known
as the Q-series used in the European CRS regulation
(UNECE Reg. No. 129) in frontal, side, and rear
impact tests. Both the Q3s and the Q3 represent a
three-year-old and are very similar in their
construction and appearance. However, the Q3s is
designed for side impacts only. Differences and
Continued
shape of the acceleration response
produced by the head drop test is highly
uniform among all heads. Also, the
input energy changes very little from
test to test because drop height and head
mass are controlled tightly. Thus, a head
acceleration response of lower
magnitude will be longer in duration
owing to energy conservation laws.
Qualification is therefore based only on
the magnitude of the head acceleration
response; otherwise, the system would
be over-constrained.
The head qualification test protocols
(both for lateral and frontal) do not
impose a rigorous time = 0 setting.
Instead, the tests are meant only to
record the peak amplitude of
acceleration. Also, since there is no
specification for the duration of the
acceleration pulse, there is no definitive
protocol to set time = 0. To impose such
a specification could unnecessarily
compromise the integrity of the main
purpose of the test itself (to objectively
measure head acceleration) because the
means to pinpoint time = 0 (such as a
contact electrode placed on the rigid
impact plate at the point of contact with
the head) could influence the response
of the head.
Comment Received
For the Q3s head drop tests, the
NPRM regulatory text proposed an
ambient temperature range of 18.9 to
25.6 degrees Celsius (C). This range is
wider than what is specified for other
part 572 dummies, and is wider than
what was specified in the agency’s
support document, ‘‘Qualification
Procedures for the Q3s Child Side
Impact Crash Test Dummy,’’ which was
docketed with the NPRM. The latter
specifies a range of 20.5 to 22.2 degrees
C, which is consistent with other part
572 dummies.
HIS commented that the ambient
temperature should be 20.5 to 22.2
degrees C, noting that HIS has not tested
Q3s head assemblies within the larger
temperature range and does not know
how that temperature may affect the
performance of the head.
NHTSA Response
NHTSA agrees with this comment, as
the wider temperature range was in
error. For this final rule, the range is
specified as 20.5–22.2 degrees C in
accordance with NHTSA’s support
document. The agency further notes that
its Q3s testing has all been carried out
within the tighter temperature range.
b. Neck Qualification
Comment Received
HIS seeks clarification on whether the
headform rotation calculation is
performed on the filtered angular rate
data or whether the computation should
be filtered after the integration. HIS
suggests clarifying the regulatory text on
this matter.
NHTSA Response
The outputs of the transducers were
specified in the NPRM regulatory text,
§ 572.219, Test conditions and
instrumentation. For the pendulum
angular rate sensor, channel frequency
class (CFC) 60 is specified. Thus, the
rotation calculation is performed on an
angular rate sensor (ARS) signal that is
already filtered to CFC 60. No changes
in the final rule are needed to address
this point.
Comment Received
HIS notes that the NPRM’s impact
velocity in the lateral neck flexion is
specified with a tolerance of ±0.05 m/s,
whereas all the other Q3s qualification
tests have a velocity tolerance of ±0.1
m/s. HIS believes the tighter tolerance
will be difficult to maintain and
measure. It recommends a tolerance of
±0.1 m/s for all tests, including the
lateral neck pendulum test.
NHTSA Response
The tighter tolerance proposed in the
NPRM was in error. For this final rule,
NHTSA has revised the proposed
regulatory text to indicate a tolerance of
±0.1 m/s for the impact velocity in the
lateral neck pendulum test, as suggested
by HIS. The correct specification for
velocity is 3.8 ±0.1 m/s. NHTSA has
also corrected a minor error in the
support document, ‘‘Qualification
Procedures for the Q3s Child Side
Impact Crash Test Dummy,’’ which
incorrectly specifies the impact velocity
in the fore-aft neck flexion test as 4.7–
4.8 m/s. The correct specification for
fore-aft velocity is 4.7 ±0.1 m/s.
Comment Received
HIS requested NHTSA clarify Figure
W4 in the NPRM, which depicts the
assembly for the lateral neck flexion
test. A set-up for a right flexion test is
shown. The regulatory text states that
the set-up for a left flexion test would
be a mirror image of Figure W4. Figure
W4 shows the approximate location of
an ARS mounted on the pendulum
interface block. Whereas the entire
assembly is designed so that the neck
may be flip-mounted for either a right or
a left test, the interface block itself may
remain bolted to the pendulum for both
tests; i.e., neither it nor the ARS
attached to it need to be flipped. HIS
asked NHTSA to clarify this in the final
rule.
NHTSA Response
NHTSA agrees that flipping the
position of the ARS is not necessary for
right vs. left tests. NHTSA clarified this
in the final rule regulatory text for
§ 572.213(c)(2)(ii) by stating that the
mirror image would include all
components beneath the pendulum
interface plate in Figure W4.
The agency notes that the same
situation exists for the lateral lumbar
test depicted in Figure W10. NHTSA
has made the same clarification to
§ 572.217(c)(2)(ii).
Comment Received
For the neck torsion test, HIS noted
that the NPRM regulatory text provides
two definitions as to when the data
channels are to be zeroed. The first time
occurs prior to running the test and
requires collecting a data point for each
channel during the setup of the test. The
second time is when the pendulum
makes contact with the striker plate.
This occurs during the test and would
require identifying where (in the data
set) time zero occurs, recording the
value of each data channel at that point,
and then subtracting that value from
corresponding data set for each channel.
HIS noted that processing the data
under each definition would result in
different outputs for each channel. HIS
recommends that a single method for
‘‘zero definition’’ should be established
for processing the data.
NHTSA Response
The NPRM contained an error.
Zeroing of data channels occurs only
once, at the step when the zero pins are
installed. For this final rule, § 572.213
(b)(3)(iv) has been corrected by
removing the last sentence that had
stated: ‘‘All data channels shall be at the
zero level at this time.’’
c. Arm Position
Comments Received
Several comments on the NPRM for
the proposed FMVSS No. 213 side
impact test suggested that NHTSA
should specify an exact position of the
dummy’s arm during testing. According
to Graco and TRL, the initial arm
position has a significant effect on the
chest compression measurement in
FMVSS No. 213 side impact tests. TRL
also noted that when the Q3 dummy
54
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similarities between the two dummies are covered
in the NPRM in greater detail.
(similar to the Q3s) is used in side
impact tests specified in the European
CRS regulation (UNECE Reg. No. 129,
‘‘Enhanced child restraint systems,’’), its
arm position also influences test results.
NHTSA Response
NHTSA agrees that the Q3s’s arm
position influences chest deflection in
impacts to the side of the torso. The
agency recognized this prior to the part
572 and FMVSS No. 213 proposals, so
NHTSA assured that the Q3s shoulder
design included a ball detent within the
shoulder joint to aid in setting the arm
precisely. The detent was specified in
the NPRM version of the dummy and
has been retained in the version
specified for this final rule. To further
address this issue, in this final rule
there are more instructions in the
dummy positioning procedure as to
where to position the Q3s’s elbows and
arms. NHTSA will address positioning
the Q3s’s arm in the FMVSS No. 213
side impact test, as appropriate.
VIII. Post-NPRM Data From
Humanetics
a. Qualification Tests
On February 9, 2016, HIS submitted a
data spreadsheet to the NPRM docket
that contains qualification results for
Q3s units that they built and tested
between 2013 and 2015. The
spreadsheet includes the data on the
units sold to Britax, MGA, and Calspan
which had been obtained by NHTSA
independently from the dummy owners
and is already included in our analysis
as explained earlier. HIS’s spreadsheet
also contains data for seven other units
(owners not disclosed) that NHTSA had
not obtained.
In addition to providing the data
itself, HIS recommended limits for each
qualification requirement based on the
means of their measurements contained
within their spreadsheet, plus/minus
two standard deviations. In computing
standard deviations, each trial carried
an equal weight. However, there were
uneven numbers of trials (over ten trials
for some units and three or less for
many others), which gave greater weight
to the responses of particular dummies.
Furthermore, HIS stated that they
removed extreme data outliers,
redundant tests, and lab-to-lab variation
tests from the dataset. No further
information was given on how many
tests were excluded or the criteria for
determining outliers, and no
explanation was given on why
redundant tests (which are needed to
assess repeatability) were removed.
Thus, the standard deviations derived
from the HIS dataset have limited
interpretive value.
All tests on the seven additional units
appear to have been performed at HIS.
Since we do not have data on the seven
units from other laboratories, which is
needed to fully evaluate repeatability
and reproducibility, the data contained
within the spreadsheet are not included
in our overall assessment of R/R
described earlier. Nonetheless, we
examined HIS’s data for the seven
additional units to compare them
against the data that we collected.
All qualification test requirements
were examined against the additional
HIS data with the exception of the
timing requirements for the neck and
lumbar moments and the pubic force
requirement. The final rule specifies
that the peak moment must occur
during the time interval in which the
rotation is within a specified set of
rotation angles. We could not deduce
whether the seven units conformed to
the final rule because time-history data
was not provided by HIS. We excluded
the pubic force requirement since it has
been dropped from the Final Rule.
We limited our examination of HIS’s
data to trials that were inclusive of HIS’s
recommended limits. We did this to
examine the degree to which the seven
new units are acceptable by both HIS’s
standards and the final rule. (About 5%
of the trials listed in the HIS submission
had responses that were more than two
standard deviations away from the mean
response. We did not include those data
points.) We counted how many HIS
trials had responses that were outside
the limits specified by the final rule.
In three of the qualification tests, the
‘‘Head, Frontal’’ test, the ‘‘Thorax
without Arm’’ test, and the ‘‘Thorax
with Arm’’ test, a trend was seen in
which multiple Q3s units did not
conform to the final rule in 25% or more
of test trials. These instances are shown
in bold in the Table 10. This trend is
consistent with our analysis presented
earlier in which we determined that the
thorax was too stiff and the resultant
acceleration of the head was too low (in
the frontal head drop test only) on some
of the newer units.
T
ABLE
10—F
INAL
R
ULE VS
. HIS’
S
D
ATA
P
OSTING OF
F
EBRUARY
9, 2016
[Qualification tests in which two or more Q3s units failed to meet a requirement in 25% of their test trials]
1
Q3s dummy serial No.
Qualification test Final rule requirement 0229 9558 2313 7218 9526 2244 5579
Head, Frontal ................. Res. Accel, 255–300 G ......................................... 0 of 3 2 of 3 1 of 3 2 of 2 10 of 10 4 of 4 1 of 2
Thorax without Arm ........ Probe force, 610–754 N ........................................ 7 of 7 3 of 6 4 of 4 2 of 7 3 of 12 5 of 7 0 of 4
Thorax displacement,
24.5–30.5 mm. ................................................................................ 1 of 7 0 of 6 2 of 4 2 of 7 3 of 12 0 of 7 0 of 4
Thorax with Arm ............. Thorax Displacement, 22.5–27.5 mm ................... 3 of 6 0 of 4 0 of 12 0 of 4 0 of 17 .. 0 of 5 1 of 4
1
Interpretation. For s/n 9558 in Head, Frontal test: ‘‘2 of 3’’ indicates two trials (of a total of three) produced a resultant acceleration outside
the range of 255–300 G range specified by the Final Rule. The bold, italics entry indicates a ratio 25% of nonconforming trials to total trials.
As mentioned earlier in this
preamble, owners of new units may
need to take remedial action to improve
the responses of their dummies in the
frontal head drop test and the thorax
impact tests. HIS’s data on all other
qualification tests shows that the seven
additional units are consistent with the
dummy responses observed in our
analysis presented earlier. With the
exception of the instances shown in
Table 10, HIS’s new dummies are all
aligned within the qualification
response limits specified by the final
rule. The non-conforming dummy
responses shown in Table 10 are
discussed in more detail below.
Head, frontal: Resultant head
acceleration. The heads of six of the
seven new units registered acceleration
levels below the lower limit of 255 Gs
specified in the final rule. HIS also
provided test results on several spare
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heads (not associated with a particular
dummy). For each of those heads, the
acceleration levels were under 255 Gs in
half or more of their respective test trials
(about 240 G on average). These levels
were also below the NPRM lower limit
of 250 G, which was the minimum
target response at the time the heads
were tested.
This condition is similar to that of the
MGA head described in the NHTSA
analysis presented earlier. Recalling that
255 Gs coincides with the lower limit of
an acceptable biofidelic response, we
demonstrated that the response of the
MGA head was unacceptably low (non-
biofidelic). Likewise, three of the new
heads appear to be unacceptable since
their responses were well below 255 Gs
in all of their trials. Most of the other
new heads had responses that were
borderline unacceptable with average
responses close to 255 Gs. Owners of
these units may need to take remedial
action in order to have dummy heads
that would meet today’s final rule.
HIS did not provide a rationale on
why they were unable to attain the
target response interval of the NPRM,
though they did suggest that a lower
target for a new unit is needed to
account for material aging. According to
their analysis, the response of a head
that was newly manufactured in 2008
increased by 10% over a period of six
years, which they presumed was due to
aging. However, the upper response
limit in the final rule is 300 G, which
represents an 18% increase above the
lower limit of 255 G. HIS did not
demonstrate that an even lower limit is
needed to account for aging.
Notably, one new unit, serial no.
0229, was within the limits for all trials
(an average of 269 G over three trials).
An HIS spare head also produced an
acceptable response in its only trial (271
G). This demonstrates that it is possible
to manufacture new dummy heads that
consistently produce acceleration
responses above 255 G. With regard to
a possible aging effect, even if the
responses of these units increased by
10% they would still be below the
upper limit of 300 G.
Thorax without Arm: Probe force and
Thorax displacement. For six of the
seven new units, the probe force
exceeded the Final Rule’s upper limit
and the thorax deflection was borderline
in the majority of test trials. (The
averages of the seven units were 766 N
for force and 25.8 mm for displacement,
and the intervals in the Final Rule are
610–754 N and 24.5–30.5 mm).
Two units in particular, serial nos.
0229 and 2313, exceeded the upper
force limit in all trials. The average force
levels for these two units (775 N and
813 N, respectively) also exceeded the
NPRM range (620–770 N), which was
the target response interval at the time
the dummies were tested. HIS did not
provide a rationale on why they were
unable to attain the target response.
Typically, a trial exhibiting a high force
produces a low deflection, indicating
that the thorax is too stiff. In HIS’s data,
this was the case for any trial in which
the probe force exceeded the upper limit
specified by the final rule.
This condition was also the case for
the Britax unit presented earlier in our
analysis in which we highlighted the
importance of thorax stiffness to the
overall acceptability of the dummy. We
demonstrated that the newer Britax unit
was much too stiff and well outside the
biofidelity corridors. Serial nos. 0229
and 2313 also appear to be too stiff.
Owners of these two units, and perhaps
four of the others, may need to remedy
their dummies to reduce the thorax
stiffness.
Notably, one unit, serial no. 5579, was
within the limits for force and
displacement in all trials. Also, serial
no. 9526 was fitted with two separate
thorax assemblies, one of which was
also within the limits for all of its trials.
This demonstrates that a given dummy
may be manufactured or remedied with
a thorax having a stiffness within the
biomechanical and qualification limits.
Thorax with Arm: Lateral
displacement. This test is designed to
assure uniformity of the arm. However,
the stiffness of the thorax (which is
evaluated by the ‘‘Thorax without Arm’’
test) does influence the dummy
response. For the ‘‘Thorax with Arm’’
test, six of the seven new units
responded within the final rule’s limits
for lateral displacement in the majority
of their trials. However, one unit, serial
no. 0229, exceeded the upper limit for
displacement in half of its trials. But
since the thorax of this unit was
determined to be too stiff (as seen in the
‘‘Thorax without Arm’’ test data), we do
not consider its performance in the
‘‘Thorax with Arm’’ test to be a valid
criterion for setting the qualification
limits.
b. Mass and Anthropometry
Measurements.
HIS’s posting on February 9, 2016,
also contained anthropometry and body
segment mass measurements for the
additional pool of dummies. These
measurements were considered by
NHTSA and the final rule has been
revised accordingly. This is discussed
further in Section IX, Drawing Package
and PADI, under the heading of Mass
and anthropometry. In all cases, the
dummy measurements provided by HIS
for anthropometry and mass are within
the tolerances prescribed by the final
rule.
IX. Drawing Package and PADI
Engineering Drawings
For this final rule, NHTSA has revised
some of the engineering drawings to
address discrepancies between the PADI
and the engineering drawings, and some
inconsistencies HIS noticed in the
drawings it provided NHTSA for
development of the NPRM. The changes
either correct errors or provide missing
information. They are not alterations
that would change the dummy in any
meaningful way or alter the dummy’s
response in either pre-test qualification
testing or dynamic sled testing with
CRSs. A comprehensive listing of
changes is described in the document,
‘‘Q3s Engineering Drawing Changes,
Rev. J, May 2016,’’ supra, a copy of
which can be found in the docket for
this final rule.
Neck assembly revision to aid end-
users. In the NPRM, the engineering
drawings for the neck cable
inadvertently allowed interference to
occur with the lower neck load cell
during the assembly of the head and
neck (see drawing 020–2415, cable
length = 81.3 mm). In the case of the
Calspan-owned unit, the cable extended
8.07 mm past the neck when torqued,
but the load cell interface plate was only
7.90 mm thick. All components were
within the drawing specifications, but
since there was no assembled
specification, interference occurred.
For the final rule, this situation has
been corrected by shortening the cable
and adding a new, special-purpose
retaining nut that provides the
necessary clearance. Additionally, the
TDP provides drawings for a wrench
designed to accept the specialized nut,
the use of which makes it easier to
properly torque the nut on the center
cable. (The PADI provides detailed
assembly instructions on adjusting the
nut.)
The neck cable assembly (part number
020–2415) of an older Q3s unit may be
swapped out with a revised cable and
new lock nut with no further changes to
the dummy. NHTSA performed neck
qualification tests with the agency’s
older units fitted with the revised cable
and nut and confirmed that it did not
affect the performance of the neck. (The
results are documented in ‘‘Q3s
Engineering Drawing Changes, Rev. J,
May 2016,’’ supra.) Owners of older Q3s
units may still use an older, unrevised
cable assembly as long as there is
clearance between the retaining nut and
the surface of the neck end plate.
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In NHTSA’s experience with other part 572
ATDs, deformable parts typically have the shortest
service lives. The parts that are replaced most often
are those that are either molded or bonded together
(such as the Q3s lumbar assembly). For example,
NHTSA has found the typical service life for HIII– 10C rib sets and neck assemblies to be about thirty
sled tests.
Mass and anthropometry. The main
assembly drawing of the Q3s (drawing
020–0100) contains separate sheets that
provide mass and anthropometry
measurements and tolerances of various
body segments. In the NPRM, these
measurements were based on the four
units owned by NHTSA and the
recommendations of HIS. For the final
rule, the sheets have been updated to
reflect measurements and tolerances
derived from the larger pool of
dummies. All revisions are also closer to
biofidelity targets. For example, the
overall mass has been changed to 14.5
kg (from 14.233 kg), which matches the
human target.
Other general changes: Errors and
missing dimensional information, fit
and assembly, manufacturing
preferences. These changes have been
made to improve the production and
manufacture of future Q3s dummies. An
older Q3s dummy is not affected by
these revisions.
Errors and missing dimensional
information. Several drawings are
changed to correct errors or add missing
information. Examples include the use
of a standard convention to specify hole
locations and diameters and additional
views (such as isometrics) to clearly
show part dimensions and assemblies.
Fit and assembly. Several drawings
have revised dimensions that make
existing parts fit better and assemble
more easily. Examples include slight
changes on many dimensions, including
overall dimensions, hole locations, and
the addition of chamfers to parts.
Manufacturing preferences. Some
drawings are revised to accommodate
manufacturing material selections and
material processes. An example is a
change to the finish on the femur bone.
Also, some revisions make the material
call-outs on parts more general, to give
dummy manufacturers more leeway on
material selection in meeting the
acceptance criteria for the qualification
tests. Examples include call-outs for
rubber, vinyl, or urethane parts.
Procedures for Assembly, Disassembly,
and Inspection (PADI)
Neck assembly. Section 5.3, Neck, has
been updated to reflect the installation
of a protective cap over a revised lock
nut for the neck center cable. (This
change is discussed above.) Also, the
version of the PADI in the NPRM
depicted an outdated version of the
neck center cable. Pictures and
illustrations of this part have been
updated in accordance with drawing
202–2415, Tension cable assembly,
which shows a round fitting attached to
the cable. Prior to the NPRM, an older
version of the dummy had used a square
fitting, and the agency mistakenly
depicted the square fitting in the PADI.
Jam nuts for lumbar cable. Section
5.7.3, Lower Torso Assembly and
Installation, has been updated to reflect
installation of jam nuts in lieu of a lock
nut with a nylon insert. This issue has
been discussed in an earlier section.
New part numbers for several
fasteners. For this final rule, several
engineering drawings have been revised
to reflect new part numbers for
fasteners. Correspondingly, the agency
has revised table listings throughout the
PADI to reflect the new part numbers.
In most cases, only the part number has
changed, not the part itself, so
corresponding changes to pictures and
descriptions were not necessary. There
were, however, a limited number of new
parts, such as the new lock nut and snap
cap on the neck center cable, that have
been added to the PADI with new
pictures.
X. Other Issues
a. Durability
Any dummy codified into 49 CFR part
572 must have sufficient durability. In
general, the energy levels in part 572
qualification tests represent the energy
levels at which dummies are expected
to be exposed in the FMVSS
applications.
As discussed in the NPRM (78 FR at
69961–69965), NHTSA assessed the
durability of the Q3s dummy and did
not see any durability problems. High-
energy tests were run using the standard
qualification test conditions at increased
kinetic energy levels. Dummy
positioning and set-up procedures were
like that specified for the qualification
procedures, but the impact speeds (and
energy levels) were increased. This was
achieved by dropping the test probe
from a greater height. High energy tests
were conducted for the head, neck,
shoulder, thorax (with and without
arm), lumbar, and pelvis. There were no
problems with durability in any of the
tests.
NHTSA did not find a need to repeat
the high-level energy testing discussed
in the NPRM since the data had
demonstrated the Q3s’s sufficient
durability. The agency also notes that
the four NHTSA-owned units have been
in service since 2011, and the agency’s
records indicate that the torn lumbar
column (described earlier) was the only
instance of Q3s part failure of any sort.
55
Given the results of the durability
testing discussed in the NPRM and the
agency’s record of low maintenance to
its own Q3s units, the dummy is
demonstrated to be highly durable and
suitable for use in FMVSS No. 213.
b. Consideration of Alternatives
As discussed in the NPRM, NHTSA
considered alternative test dummies to
incorporate into part 572 instead of the
Q3s, but none were better than the Q3s
for testing CRSs in the proposed FMVSS
No. 213 side impact test. The closest
viable alternatives were the modified
HIII–3C and the Q3.
The HIII–3C is a ‘‘frontal’’ test dummy
used in FMVSS No. 208, ‘‘Occupant
crash protection,’’ to evaluate air bag
aggressiveness or air bag suppression
when a child is close to a deploying air
bag, and in FMVSS No. 213’s frontal
sled test for the evaluation of child
restraint performance. The HIII–3C was
not designed for lateral impacts, but the
agency developed a retrofit package for
the dummy to install a new head and
neck with better lateral biofidelity. The
retrofitted dummy is referred to as the
‘‘3Cs.’’ As explained in the NPRM, the
Q3s outperformed or is equivalent to the
3Cs in every aspect of biofidelity related
to a dummy’s response in a side impact.
In addition, the Q3s has thorax
deflection instrumentation, which the
3Cs does not. NHTSA has concluded
that the Q3s is a better dummy than the
3Cs to measure injury assessment values
in side impacts and is a preferable ATD
for use in the proposed side impact
upgrade to FMVSS No. 213.
The Q3s was derived from the original
Q3 dummy developed in Europe. The
Q3 is intended for use in frontal, side,
and rear impacts. Many of the Q3’s basic
design concepts are included in the Q3s.
However, as reported by the European
Enhanced Vehicle-Safety Committee
(Wismans, et al., 2008), the Q3s is
superior to the Q3 in terms of lateral
biofidelity and other matters. NHTSA
considers the Q3s preferable to the Q3
for the proposed FMVSS No. 213 side
impact test.
NHTSA concludes that the Q3s is
superior to other commercially available
child side impact test dummies and
should be adopted into 49 CFR part 572.
The Q3s dummy is a state-of-the-art
device that will allow for a better
assessment of the risk of injury to child
occupants than the 3Cs or the Q3. The
availability of Q3s’s injury measuring
capability is important to the design,
development and evaluation of the side
impact protection provided by child
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Section 31501(a) of Subtitle E, ‘‘Child Safety
Standards,’’ MAP–21, Public Law 112–141.
57
See drawing 020–0150 in the TDP.
restraint systems. The Q3s test dummy
is available today, and has been
thoroughly evaluated for suitable
reproducibility and repeatability of
results.
XI. Rulemaking Analyses and Notices
Executive Order 12866, Executive Order
13563, and DOT Rulemaking
Procedures
We have considered the potential
impact of this final rule under Executive
Orders 12866 and 13563, and the
Department of Transportation’s
administrative rulemaking procedures
set forth in 49 CFR part 5, subpart B.
This final rule has been determined to
be nonsignificant and was not reviewed
by the Office of Management and
Budget (OMB) under E.O. 12866. We
have considered the qualitative costs
and benefits of this final rule under the
principles of E.O. 12866.
This document would amend 49 CFR
part 572 by adding design and
performance specifications for a test
dummy representative of a 3-year-old
child that the agency plans to use in
FMVSS No. 213 side impact compliance
tests and for research purposes. As
stated in 49 CFR 572.3, Application,
part 572 does not in itself impose duties
or liabilities on any person. It only
serves to describe the test tools that
measure the performance of occupant
protection systems. Thus, this part 572
rule itself does not impose any
requirements on anyone. Businesses are
affected only if they choose to
manufacture or test with the dummy.
Because the economic impacts of this
rule are minimal, no further regulatory
evaluation is necessary.
There are benefits associated with this
rulemaking but they cannot be
quantified. The incorporation of the Q3s
into 49 CFR part 572 would enable
NHTSA to use the ATD in the proposed
FMVSS No. 213 side impact test.
Adoption of side impact protection
requirements in FMVSS No. 213
enhances child passenger safety and
fulfils a mandate in MAP–21 that
NHTSA ‘‘issue a final rule amending
Federal Motor Vehicle Safety Standard
Number 213 to improve the protection
of children seated in child restraint
systems during side impact crashes.’’
56
In addition, the availability of the Q3s
in a standardized, regulated format
would be beneficial by providing a
suitable, stabilized, and objective test
tool to the safety community for use in
better protecting children in side
impacts.
The costs associated with the Q3s
only affect those who choose to use the
Q3s. This part 572 final rule does not
impose any requirements on anyone. If
incorporated into an FMVSS, NHTSA
will use the Q3s in its compliance
testing of the requirements, but
regulated entities are not required to use
the Q3s or assess the performance of
their products in the manner specified
in the FMVSSs.
Based on NHTSA’s dummy purchase
contract with HIS, the estimated cost of
an uninstrumented Q3s dummy is
approximately $50,000. Instruments
installed within the dummy needed to
perform the qualification in accordance
with part 572 include: Three uni-axial
accelerometers within the head of the
dummy (about $500 each); an upper
neck load cell (about $10,000); a
shoulder potentiometer (about $500);
and a single-axis IR–TRACC within the
thorax cavity (about $8,000). The cost of
this instrumentation adds
approximately $20,000 for a total cost of
about $70,000.
There are minor costs associated with
conducting the qualification tests. Most
of the qualification fixtures are common
with those used to qualify other part 572
dummies (including the neck
pendulum, the quick-release fixture
used in the head drop test, and the
bench used in the probe impact tests).
Some additional equipment unique to
the Q3s may be fabricated from
drawings within the technical data
package, for an estimated cost of about
$20,000 (price may vary widely
depending on prevailing labor rates).
This includes the cost to fabricate a load
cell blank
57
used in the head drop tests,
the torsion fixture for the neck torsion
test, the special headform used in the
neck and lumbar flexion tests, the leg
positioning tool used in the probe
impact tests, and the 3.81 kg test probe
itself. The costs of the instrumentation
equipment needed to perform the
qualification tests amounts to an
additional $3,460 (two angular rate
sensors, $1,230 apiece; one test probe
accelerometer, $500; one rotary
potentiometer, $500.) This part 572 rule
does not impose these costs on anyone.
Child restraint manufacturers are
affected by this final rule only if they
elect to use the Q3s to test their
products.
Dummy refurbishments and part
replacements are a routine part of ATD
testing. Various parts will likely have to
be refurbished or replaced. However,
the Q3s has proven to have high
durability in sled testing. In addition,
since the dummies are designed to be
reusable, costs of the dummies and of
parts can be amortized over a number of
tests.
Executive Order 13771
Executive Order 13771 titled
‘‘Reducing Regulation and Controlling
Regulatory Costs,’’ directs that, unless
prohibited by law, whenever an
executive department or agency
publicly proposes for notice and
comment or otherwise promulgates a
new regulation, it shall identify at least
two existing regulations to be repealed.
In addition, any new incremental costs
associated with new regulations shall, to
the extent permitted by law, be offset by
the elimination of existing costs. Only
those rules deemed significant under
section 3(f) of Executive Order 12866,
‘‘Regulatory Planning and Review,’’ are
subject to these requirements. As
discussed above, this rule is not a
significant rule under Executive Order
12866 and, accordingly, is not subject to
the offset requirements of 13771.
Regulatory Flexibility Act
Pursuant to the Regulatory Flexibility
Act (5 U.S.C. 601 et seq., as amended by
the Small Business Regulatory
Enforcement Fairness Act (SBREFA) of
1996), whenever an agency is required
to publish a proposed or final rule, it
must prepare and make available for
public comment a regulatory flexibility
analysis that describes the effect of the
rule on small entities (i.e., small
businesses, small organizations, and
small governmental jurisdictions),
unless the head of the agency certifies
the rule will not have a significant
economic impact on a substantial
number of small entities. The Small
Business Administration’s regulations at
13 CFR part 121 define a small business,
in part, as a business entity ‘‘which
operates primarily within the United
States.’’ (13 CFR 121.105(a)).
NHTSA has considered the effects of
this rulemaking under the Regulatory
Flexibility Act. I hereby certify that this
rulemaking action will not have a
significant economic impact on a
substantial number of small entities.
This action will not have a significant
economic impact on a substantial
number of small entities because the
addition of the test dummy to part 572
will not impose any requirements on
anyone. NHTSA will use the ATD in
agency testing but will not require
anyone to manufacture the dummy or to
test motor vehicles or motor vehicle
equipment with it.
National Environmental Policy Act
NHTSA has analyzed this final rule
for the purposes of the National
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With respect to the safety standards, the
National Traffic and Motor Vehicle Safety Act
contains an express preemptive provision: ‘‘When
a motor vehicle safety standard is in effect under
this chapter, a State or a political subdivision of a
State may prescribe or continue in effect a standard
applicable to the same aspect of performance of a
motor vehicle or motor vehicle equipment only if
the standard is identical to the standard prescribed
under this chapter.’’ 49 U.S.C. 30103(b)(1). Second,
the Supreme Court has recognized the possibility of
implied preemption: State requirements imposed
on motor vehicle manufacturers, including
sanctions imposed by State tort law, can stand as
an obstacle to the accomplishment and execution of
a NHTSA safety standard. When such a conflict
exists, the Supremacy Clause of the Constitution
makes the State requirements unenforceable. See Geier v. American Honda Motor Co., 529 U.S. 861
(2000).
Environmental Policy Act and
determined that it will not have any
significant impact on the quality of the
human environment.
Executive Order 13045 and 13132
(Federalism)
Executive Order 13045 (62 FR 19885,
April 23, 1997) applies to any rule that:
(1) Is determined to be ‘‘economically
significant’’ as defined under E.O.
12866, and (2) concerns an
environmental, health, or safety risk that
NHTSA has reason to believe may have
a disproportionate effect on children. If
the regulatory action meets both criteria,
NHTSA must evaluate the
environmental health or safety effects of
the planned rule on children, and
explain why the planned regulation is
preferable to other potentially effective
and reasonably feasible alternatives
considered by the agency.
This final rule is not subject to the
Executive Order because it is not
economically significant as defined in
E.O. 12866.
NHTSA has examined today’s final
rule pursuant to Executive Order 13132
(64 FR 43255, August 10, 1999) and
concluded that no additional
consultation with States, local
governments or their representatives is
mandated beyond the rulemaking
process. The agency has concluded that
this final rule will not have federalism
implications because the rule would not
have ‘‘substantial direct effects on the
States, on the relationship between the
national government and the States, or
on the distribution of power and
responsibilities among the various
levels of government.’’ This final rule
will not impose any requirements on
anyone. Businesses will be affected only
if they choose to manufacture or test
with the dummy.
Further, no consultation is needed to
discuss the preemptive effect of today’s
final rule. NHTSA’s safety standards can
have preemptive effect in two ways.
This rule amends 49 CFR part 572 and
is not a safety standard.
58
This part 572
final rule will not impose any
requirements on anyone.
Civil Justice Reform
With respect to the review of the
promulgation of a new regulation,
section 3(b) of Executive Order 12988,
‘‘Civil Justice Reform’’ (61 FR 4729,
February 7, 1996) requires that
Executive agencies make every
reasonable effort to ensure that the
regulation: (1) Clearly specifies the
preemptive effect; (2) clearly specifies
the effect on existing Federal law or
regulation; (3) provides a clear legal
standard for affected conduct, while
promoting simplification and burden
reduction; (4) clearly specifies the
retroactive effect, if any; (5) adequately
defines key terms; and (6) addresses
other important issues affecting clarity
and general draftsmanship under any
guidelines issued by the Attorney
General. This document is consistent
with that requirement.
Pursuant to this Order, NHTSA notes
as follows.
The issue of preemption is discussed
above in connection with E.O. 13132.
NHTSA notes further that there is no
requirement that individuals submit a
petition for reconsideration or pursue
other administrative proceeding before
they may file suit in court.
Paperwork Reduction Act
Under the Paperwork Reduction Act
of 1995, a person is not required to
respond to a collection of information
by a Federal agency unless the
collection displays a valid control
number from the Office of Management
and Budget (OMB). This final rule will
not have any requirements that are
considered to be information collection
requirements as defined by the OMB in
5 CFR part 1320.
National Technology Transfer and
Advancement Act
Section 12(d) of the National
Technology Transfer and Advancement
Act of 1995 (NTTAA), Public Law 104–
113, section 12(d) (15 U.S.C. 272)
directs NHTSA to use voluntary
consensus standards in its regulatory
activities unless doing so would be
inconsistent with applicable law or
otherwise impractical. Voluntary
consensus standards are technical
standards (e.g., materials specifications,
test methods, sampling procedures, and
business practices) that are developed or
adopted by voluntary consensus
standards bodies. The NTTAA directs
NHTSA to provide Congress, through
OMB, explanations when the agency
decides not to use available and
applicable voluntary consensus
standards.
The following voluntary consensus
standards have been used in developing
the Q3s:
SAE Recommended Practice J211,
Rev. Mar 95, ‘‘Instrumentation for
Impact Tests—Part 1—Electronic
Instrumentation;’’ and
SAE J1733 of 1994–12 ‘‘Sign
Convention for Vehicle Crash Testing.’’
Unfunded Mandates Reform Act
Section 202 of the Unfunded
Mandates Reform Act of 1995 (UMRA),
Public Law 104–4, requires Federal
agencies to prepare a written assessment
of the costs, benefits, and other effects
of proposed or final rules that include
a Federal mandate likely to result in the
expenditure by State, local, or tribal
governments, in the aggregate, or by the
private sector, of more than $100
million annually (adjusted for inflation
with base year of 1995). Before
promulgating a NHTSA rule for which
a written statement is needed, section
205 of the UMRA generally requires the
agency to identify and consider a
reasonable number of regulatory
alternatives and adopt the least costly,
most cost-effective, or least burdensome
alternative that achieves the objectives
of the rule.
This final rule will not impose any
unfunded mandates under the UMRA.
This rule does not meet the definition
of a Federal mandate because it does not
impose requirements on anyone. It
amends 49 CFR part 572 by adding
design and performance specifications
for a 3-year-old child side impact test
dummy that the agency would use in
FMVSS No. 213 and for research
purposes. This final rule would affect
only those businesses that choose to
manufacture or test with the dummy. It
would not result in costs of $100
million or more to either State, local, or
tribal governments, in the aggregate, or
to the private sector.
Incorporation by Reference
Under regulations issued by the Office
of the Federal Register (1 CFR 51.5(a)),
an agency, as part of a final rule that
includes material incorporated by
reference, must summarize in the
preamble of the final rule the material
it incorporates by reference and discuss
the ways the material is reasonably
available to interested parties or how
the agency worked to make materials
available to interested parties.
In this final rule, NHTSA incorporates
by reference a technical data package for
the Q3s consisting of a set of
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engineering drawings for the test
dummy, a parts list, and a user’s manual
that has procedures for assembly,
disassembly, and inspection of the
dummy. Q3s dummies manufactured to
meet the qualification requirements and
the technical data package will be
uniform in their design, construction,
and response to impact forces.
NHTSA has placed a copy of the
technical data package in the docket for
this final rule. Interested persons can
download a copy of the materials or
view the materials online by accessing
www.Regulations.gov, telephone 1–877–
378–5457, or by contacting NHTSA’s
Chief Counsel’s Office at the phone
number and address set forth in the
FOR
FURTHER INFORMATION CONTACT
section of
this document. The material is also
available for inspection at the
Department of Transportation, Docket
Operations, Room W12–140, 1200 New
Jersey Avenue SE, Washington, DC
Telephone: 202–366–9826. This final
rule also incorporates versions of SAE
Recommended Practice J211/1 parts 1
and 2 and SAE J1733. The material is
available for review at NHTSA and is
available for purchase from SAE
International.
Plain Language
Executive Order 12866 requires each
agency to write all rules in plain
language.
Application of the principles of plain
language includes consideration of the
following questions:
Has the agency organized the material
to suit the public’s needs?
Are the requirements in the rule
clearly stated?
Does the rule contain technical
language or jargon that is not clear?
Would a different format (grouping
and order of sections, use of headings,
paragraphing) make the rule easier to
understand?
Would more (but shorter) sections be
better?
Could the agency improve clarity by
adding tables, lists, or diagrams?
What else could the agency do to
make this rulemaking easier to
understand?
If you have any responses to these
questions, please send them to NHTSA.
Regulation Identifier Number
The Department of Transportation
assigns a regulation identifier number
(RIN) to each regulatory action listed in
the Unified Agenda of Federal
Regulations. The Regulatory Information
Service Center publishes the Unified
Agenda in April and October of each
year. You may use the RIN contained in
the heading at the beginning of this
document to find this action in the
Unified Agenda.
List of Subjects in 49 CFR Part 572
Motor vehicle safety, Incorporation by
reference.
In consideration of the foregoing,
NHTSA amends 49 CFR part 572 as
follows:
PART 572—ANTHROPOMORPHIC
TEST DEVICES
1. The authority citation for part 572
continues to read as follows:
Authority: 49 U.S.C. 322, 30111, 30115,
30117 and 30166; delegation of authority at
49 CFR 1.95.
2. Subpart W, consisting of §§ 572.210
through 572.219, is added to read as
follows:
Subpart W—Q3s Three-Year-Old Child Test
Dummy
Sec.
572.210 Incorporation by reference.
572.211 General description.
572.212 Head assembly and test procedure.
572.213 Neck assembly and test procedure.
572.214 Shoulder assembly and test
procedure.
572.215 Thorax with arm assembly and test
procedure.
572.216 Thorax without arm assembly and
test procedure.
572.217 Lumbar spine assembly and test
procedure.
572.218 Pelvis assembly and test procedure.
572.219 Test conditions and
instrumentation.
Appendix A to Subpart W of Part 572—
Figures
Subpart W—Q3s Three-Year-Old Child
Test Dummy
§ 572.210 Incorporation by reference.
Certain material is incorporated by
reference (IBR) into this part with the
approval of the Director of the Federal
Register under 5 U.S.C. 552(a) and 1
CFR part 51. To enforce any edition
other than that specified in this section,
NHTSA must publish a document in the
Federal Register and the material must
be available to the public. All approved
material is available for inspection at
the Department of Transportation,
Docket Operations, Room W12–140,
1200 New Jersey Avenue SE,
Washington DC 20590, telephone 202–
366–9826, and is available from the
sources listed in paragraphs (a) and (b)
of this section. It is also available for
inspection at the National Archives and
Records Administration (NARA). For
information on the availability of this
material at NARA, email fedreg.legal@
nara.gov or go to www.archives.gov/
federal-register/cfr/ibr-locations.html.
(a) NHTSA Technical Information
Services, 1200 New Jersey Ave. SE,
Washington, DC 20590, telephone 202–
366–5965.
(1) A parts/drawing list entitled,
‘‘Parts/Drawings List, Part 572 Subpart
W, Q3s Three-Year-Old Child Side
Impact Dummy, May 2016,’’ (Parts/
Drawings List); IBR approved for
§ 572.211.
(2) A drawings and inspection
package entitled, ‘‘Drawings and
Specifications for Q3S Three-Year-Old
Child Test Dummy, Part 572 Subpart W,
May 2016,’’ (Drawings and
Specifications); IBR approved for
§§ 572.211, 572.212, 572.213, 572.214,
572.215, 572.216, 572.217, 572.218, and
572.219.
(3) A procedures manual entitled
‘‘Procedures for Assembly, Disassembly,
and Inspection (PADI) of the Q3s Child
Side Impact Crash Test Dummy, May
2016,’’ (PADI); IBR approved for
§§ 572.211, 572.215(b), 572.216(b), and
572.219(a).
(b) SAE International, 400
Commonwealth Drive, Warrendale, PA
15096, call 1–877–606–7323, https://
www.sae.org/.
(1) SAE Recommended Practice J211/
1, Rev. Mar 95, ‘‘Instrumentation for
Impact Tests—Part 1—Electronic
Instrumentation,’’ (SAE J211); IBR
approved for § 572.219;
(2) SAE Information Report J1733 of
1994–12, ‘‘Sign Convention for Vehicle
Crash Testing,’’ December 1994, (SAE
J1733); IBR approved for § 572.219.
§ 572.211 General description.
(a) The Q3s Three-Year-Old Child
Test Dummy is defined by the following
materials:
(1) The Parts/Drawings List
(incorporated by reference, see
§ 572.210);
(2) The Drawings and Specifications
(incorporated by reference, see
§ 572.210);
(3) The PADI (incorporated by
reference, see § 572.210).
(b) The structural properties of the
dummy are such that the dummy
conforms to this subpart in every
respect before use in any test.
§ 572.212 Head assembly and test
procedure.
All assemblies and drawings
referenced in this section are contained
in Drawings and Specifications,
incorporated by reference, see § 572.210.
(a) The head assembly for this test
consists of the complete head (drawing
020–1200) with head accelerometer
assembly (drawing 020–1013A), and a
half mass simulated upper neck load
cell (drawing 020–1050).
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(b) When the head assembly is tested
according to the test procedure in
paragraph (c) of this section, it shall
have the following characteristics:
(1) Frontal head qualification test.
When the head assembly is dropped
from a height of 376.0 ± 1.0 mm in
accordance with paragraph (c) of this
section, the peak resultant acceleration
at the location of the accelerometers at
the head CG shall have a value between
255 G and 300 G. The resultant
acceleration vs. time history curve shall
be unimodal; oscillations occurring after
the main pulse must be less than 10
percent of the peak resultant
acceleration. The lateral acceleration
shall not exceed 15 G (zero to peak).
(2) Lateral head qualification test.
When the head assembly is dropped
from a height of 200.0 ± 1.0 mm in
accordance with paragraph (c) of this
section, the peak resultant acceleration
at the location of the accelerometers at
the head CG shall have a value between
114 G and 140 G. The resultant
acceleration vs. time history curve shall
be unimodal; oscillations occurring after
the main pulse must be less than 10
percent of the peak resultant
acceleration. The X-component
acceleration shall not exceed 15 G (zero
to peak).
(c) The test procedure for the head
assembly is as follows:
(1) Soak the head assembly in a
controlled environment at any
temperature between 20.6 and 22.2 °C
and a relative humidity from 10 to 70
percent for at least four hours prior to
a test.
(2) Prior to the test, clean the impact
surface of the skin and the impact plate
surface with isopropyl alcohol,
trichloroethane, or an equivalent. The
skin of the head and the impact plate
surface must be clean and dry for
testing.
(3)(i) For the frontal head test,
suspend and orient the head assembly
with the forehead facing the impact
surface as shown in figure W1 in
appendix A to this subpart. The lowest
point on the forehead must be 376.0 ±
1.0 mm from the impact surface. Assure
that the head is horizontal laterally.
Adjust the head angle so that the upper
neck load cell simulator is 28 ± 2
degrees forward from the vertical while
assuring that the head remains
horizontal laterally.
(ii) For the lateral head test, the head
is dropped on the aspect that opposes
the primary load vector of the ensuing
full scale test for which the dummy is
being qualified. A left drop set up that
is used to qualify the dummy for an
ensuing full scale left side impact is
depicted in figure W2 in appendix A to
this subpart. A right drop set-up would
be the mirror image of that shown in
figure W2. Suspend and orient the head
assembly as shown in figure W2. The
lowest point on the impact side of the
head must be 200.0 ± 1.0 mm from the
impact surface. Assure that the head is
horizontal in the fore-aft direction.
Adjust the head angle so that the head
base plane measured from the base
surface of the upper neck load cell
simulator is 35 ± 2 degrees forward from
the vertical while assuring that the head
remains horizontal in the fore-aft
direction.
(4) Drop the head assembly from the
specified height by means that ensure a
smooth, instant release onto a rigidly
supported flat horizontal steel plate
which is 50.8 mm thick and 610 mm
square. The impact surface shall be
clean, dry and have a surface finish of
not less than 0.2 microns (RMS) and not
more than 2.0 microns (RMS).
(5) Allow at least 2 hours between
successive tests on the same head.
§ 572.213 Neck assembly and test
procedure.
All assemblies and drawings
referenced in this section are contained
in Drawings and Specifications,
incorporated by reference, see § 572.210.
(a)(1) The neck and headform
assembly for the purposes of the fore-aft
neck flexion and lateral neck flexion
qualification tests, as shown in figures
W3 and W4 in appendix A to this
subpart, consists of the headform
(drawing 020–9050, sheet 1) with
angular rate sensor installed (drawing
SA572–S58), six-channel neck/lumbar
load cell (drawing SA572–S8), neck
assembly (drawing 020–2400), neck/
torso interface plate (drawing 020–9056)
and pendulum interface plate (drawing
020–9051) with angular rate sensor
installed (drawing SA572–S58).
(2) The neck assembly for the
purposes of the neck torsion
qualification test, as shown in figure W5
in appendix A to this subpart, consists
of the neck twist fixture (drawing
DL210–200) with rotary potentiometer
installed (drawing SA572–S51), neck
adaptor plate assembly (drawing
DL210–220), neck assembly (drawing
020–2400), six-channel neck/lumbar
load cell (drawing SA572–S8), and twist
fixture end plate (drawing DL210–210).
(b) When the neck and headform
assembly as defined in paragraph (a)(1)
of this section, or the neck assembly as
defined in paragraph (a)(2) of this
section, is tested according to the test
procedure in paragraph (c) of this
section, it shall have the following
characteristics:
(1) Fore-aft neck flexion qualification
test. (i) Plane D, referenced in figure W3
in appendix A to this subpart, shall
rotate in the direction of pre-impact
flight with respect to the pendulum’s
longitudinal centerline between 69.5
degrees and 81.0 degrees. During the
time interval while the rotation is
within these angles, the peak moment
measured by the neck transducer
(drawing SA572–S8) shall have a value
between 41.5 N-m and 50.7 N-m.
(ii) The decaying headform rotation
vs. time curve shall cross the zero angle
with respect to its initial position at
time of impact relative to the pendulum
centerline between 45 to 55 ms after the
time the peak rotation value is reached.
(iii) All instrumentation data channels
are defined to be zero when the
longitudinal centerline of the neck and
pendulum are parallel.
(iv) The headform rotation shall be
calculated by the following formula
with the integration beginning at time
zero:
Headform rotation (deg) = [(Headform
Angular Rate)
y
¥(Pendulum
Angular Rate)
y
] dt
(v) (Headform Angular Rate)
y
is the
angular rate about the y-axis in deg/sec
measured on the headform (drawing
020–9050, sheet 1), and (Pendulum
Angular Rate)
y
is the angular rate about
the y-axis in deg/sec measured on the
pendulum interface plate (drawing 020–
9051).
(2) Lateral neck flexion qualification
test. (i) Plane D, referenced in Figure W4
in appendix A to this subpart, shall
rotate in the direction of pre-impact
flight with respect to the pendulum’s
longitudinal centerline between 76.5
degrees and 87.5 degrees. During the
time interval while the rotation is
within these angles, the peak moment
measured by the neck transducer
(drawing SA572–S8) shall have a value
between 25.3 N-m and 32.0 N-m.
(ii) The decaying headform rotation
vs. time curve shall cross the zero angle
with respect to its initial position at
time of impact relative to the pendulum
centerline between 61 to 71 ms after the
time the peak rotation value is reached.
(iii) All instrumentation data channels
are defined to be zero when the
longitudinal centerline of the neck and
pendulum are parallel.
(iv) The headform rotation shall be
calculated by the following formula
with the integration beginning at time
zero:
Headform rotation (deg) = [(Headform
Angular Rate)
y
¥(Pendulum
Angular Rate)
y
] dt
(v) (Headform Angular Rate)
y
is the
angular rate about the y-axis in deg/sec
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measured on the headform (drawing
020–9050, sheet 1), and (Pendulum
Angular Rate)
y
is the angular rate about
the y-axis in deg/sec measured on the
pendulum interface plate (drawing 020–
9051).
(3) Neck torsion qualification test. (i)
The neck twist fixture (drawing DL210–
200), referenced in figure W5 in
appendix A to this subpart, shall rotate
in the direction of pre-impact flight with
respect to the pendulum’s longitudinal
centerline between 74.5 degrees and
91.0 degrees, as measured by the rotary
potentiometer (drawing SA572–S51).
During the time interval while the
rotation is within these angles, the peak
moment measured by the neck
transducer (drawing SA572–S8) shall
have a value between 8.0 N-m and 10.0
N-m.
(ii) The decaying neck twist fixture
rotation vs. time curve shall cross the
zero angle with respect to its initial
position at time of impact relative to the
pendulum centerline between 85 to 102
ms after the time the peak rotation value
is reached.
(iii) All instrumentation data channels
are defined to be zero when the zero
pins are installed such that the neck is
not in torsion.
(c) The test procedure for the neck
assembly is as follows:
(1) Soak the neck assembly in a
controlled environment at any
temperature between 20.6 and 22.2 °C
and a relative humidity between 10 and
70 percent for at least four hours prior
to a test.
(2)(i) For the fore-aft neck flexion test,
mount the neck and headform assembly,
defined in paragraph (a)(1) of this
section, on the pendulum, described in
figure 22 to § 572.33, so that the
midsagittal plane of the headform is
vertical and coincides with the plane of
motion of the pendulum, and with the
neck placement such that the front side
of the neck is closest to the honeycomb
material as shown in figure W3 in
appendix A to this subpart.
(ii) For the lateral neck flexion test,
the test is carried out in the direction
opposing the primary load vector of the
ensuing full scale test for which the
dummy is being qualified. A right
flexion test set-up that is used to qualify
the dummy for an ensuing full scale
right side impact is depicted in figure
W4 in appendix A to this subpart. A left
flexion test set-up would be depicted by
a mirror image of all components
beneath the pendulum interface plate in
Figure W4. Mount the neck and
headform assembly, defined in
paragraph (a)(1) of this section, on the
pendulum, described by figure 22 to
§ 572.33, so that the midsagittal plane of
the headform is vertical and coincides
with the plane of motion of the
pendulum, and with the neck placement
such that the right (or left) side of the
neck is closest to the honeycomb
material as shown in figure W4.
(iii) For the neck torsion test, the test
is carried out in the direction opposing
the primary load vector of the ensuing
full scale test for which the dummy is
being qualified. A right torsion test set-
up that is used to qualify the dummy for
an ensuing full scale right side impact
is depicted in figure W5 in appendix A
to this subpart. A left flexion test set-up
would be a mirror image of that shown
in figure W5. Mount the neck assembly,
defined in paragraph (a)(2) of this
section, on the pendulum, described by
figure 22 to § 572.33, as shown in figure
W5.
(3)(i) Release the pendulum and allow
it to fall freely from a height to achieve
an impact velocity of 4.7 ± 0.1 m/s for
fore-aft flexion, 3.8 ± 0.1 m/s for lateral
flexion, and 3.6 ± 0.1 m/s for torsion,
measured by an accelerometer mounted
on the pendulum at time zero.
(ii) Stop the pendulum from the
initial velocity with an acceleration vs.
time pulse that meets the velocity
change as specified in table 1 to this
section. Integrate the pendulum
accelerometer data channel to obtain the
velocity vs. time curve beginning at time
zero.
(iii) Time zero is defined as the time
of initial contact between the pendulum
striker plate and the honeycomb
material.
T
ABLE
1
TO
§ 572.213
Time
(ms)
Fore-aft
Flexion
(m/s)
Time
(ms) Lateral Flexion
(m/s) Time
(ms) Torsion
(m/s)
10 ......................................................................................... 1.1–2.1 10 1.7–2.2 10 0.9–1.3
20 ......................................................................................... 2.8–3.8 15 2.5–3.0 15 1.4–2.0
30 ......................................................................................... 4.1–5.1 20 3.4–3.9 20 2.0–2.6
§ 572.214 Shoulder assembly and test
procedure.
All assemblies and drawings
referenced in this section are contained
in Drawings and Specifications,
incorporated by reference, see § 572.210.
(a) The shoulder assembly for this test
consists of the torso assembly (drawing
020–4500) with string pot assembly
(drawing SA572–S38 or SA572–S39)
installed.
(b) When the center of the shoulder of
a completely assembled dummy
(drawing 020–0100) is impacted
laterally by a test probe conforming to
§ 572.219, at 3.6 ± 0.1 m/s according to
the test procedure in paragraph (c) of
this section:
(1) Maximum lateral shoulder
displacement (compression) relative to
the spine, measured with the string
potentiometer assembly (drawing
SA572–S38 or SA572–S39), must not be
less than 17.0 mm and not more than
22.0 mm. The peak force, measured by
the impact probe as defined in § 572.219
and calculated in accordance with
paragraph (b)(2) of this section, shall
have a value between 1123 N and 1437
N.
(2) The force shall be calculated by
the product of the impactor mass and its
measured deceleration.
(c) The test procedure for the shoulder
assembly is as follows:
(1) The dummy is clothed in the Q3s
suit (drawing 020–8001). No additional
clothing or shoes are placed on the
dummy.
(2) Soak the dummy in a controlled
environment at any temperature
between 20.6 and 22.2 °C and a relative
humidity from 10 to 70 percent for at
least four hours prior to a test.
(3) The shoulder test is carried out in
the direction opposing the primary load
vector of the ensuing full scale test for
which the dummy is being qualified. A
left shoulder test set-up that is used to
qualify the dummy for an ensuing full
scale left side impact is depicted in
figure W6 in appendix A to this subpart.
A right shoulder set-up would be a
mirror image of that shown in figure
W6. Seat the dummy on the
qualification bench described in figure
V3 to § 572.194, the seat pan and seat
back surfaces of which are covered with
thin sheets of PTFE (Teflon) (nominal
stock thickness: 2 to 3 mm) along the
impact side of the bench.
(4) Position the dummy on the bench
as shown in Figure W6, with the ribs
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making contact with the seat back
oriented 24.6 degrees relative to vertical,
the legs extended forward along the seat
pan oriented 21.6 degrees relative to
horizontal with the knees spaced 40 mm
apart. Position the arms so that the
upper arms are parallel to the seat back
(±2 degrees) and the lower arms are
parallel to the dummy’s sagittal plane
and perpendicular to the upper arms.
Move the elbows inward (medially)
until initial contact occurs between the
sleeve and the portion of the suit
covering the thorax while maintaining
the relationships between the arms, seat
back, and sagittal plane.
(5) The target point of the impact is
a point on the shoulder that is 15 mm
above and perpendicular to the
midpoint of a line connecting the
centers of the bolt heads of the two
lower bolts (part #5000010) that connect
the upper arm assembly (020–9750) to
the shoulder ball retaining ring (020–
3533).
(6) Impact the shoulder with the test
probe so that at the moment of contact
the probe’s longitudinal centerline
should be horizontal (±1 degree), and
the centerline of the probe should be
within 2 mm of the target point.
(7) Guide the test probe during impact
so that there is no significant lateral,
vertical, or rotational movement.
(8) No suspension hardware,
suspension cables, or any other
attachments to the probe, including the
velocity vane, shall make contact with
the dummy during the test.
§ 572.215 Thorax with arm assembly and
test procedure.
All assemblies and drawings
referenced in this section are contained
in Drawings and Specifications,
incorporated by reference, see § 572.210.
(a) The thorax assembly for this test
consists of the torso assembly (drawing
020–4500) with an IR–TRACC (drawing
SA572–S37) installed.
(b) When the thorax of a completely
assembled dummy (drawing 020–0100)
is impacted laterally by a test probe
conforming to § 572.219 at 5.0 ± 0.1 m/
s according to the test procedure in
paragraph (c) of this section:
(1) Maximum lateral thorax
displacement (compression) relative to
the spine, measured with the IR–TRACC
(drawing SA572–S37) and processed as
set out in the PADI (incorporated by
reference, see § 572.210), shall have a
value between 22.5 mm and 27.5 mm.
The peak force occurring after 5 ms,
measured by the impact probe as
defined in § 572.219 and calculated in
accordance with paragraph (b)(2) of this
section, shall have a value between 1360
N and 1695 N.
(2) The force shall be calculated by
the product of the impactor mass and its
measured deceleration.
(3) Time zero is defined as the time
of contact between the impact probe and
the arm. All channels should be at a
zero level at this point.
(c) The test procedure for the thorax
with arm assembly is as follows:
(1) The dummy is clothed in the Q3s
suit (drawing 020–8001). No additional
clothing or shoes are placed on the
dummy.
(2) Soak the dummy in a controlled
environment at any temperature
between 20.6 and 22.2 °C and a relative
humidity from 10 to 70 percent for at
least four hours prior to a test.
(3) The test is carried out in the
direction opposing the primary load
vector of the ensuing full scale test for
which the dummy is being qualified. A
left thorax test set-up that is used to
qualify the dummy for an ensuing full
scale left side impact is depicted in
figure W7 in appendix A to this subpart.
A right thorax set-up would be a mirror
image of that shown in figure W7. Seat
the dummy on the qualification bench
described in figure V3 to § 572.194, the
seat pan and seat back surfaces of which
are covered with thin sheets of PTFE
(Teflon) (nominal stock thickness: 2 to
3 mm) along the impact side of the
bench.
(4) Position the dummy on the bench
as shown in figure W7 in appendix A to
this subpart, with the ribs making
contact with the seat back oriented 24.6
degrees relative to vertical, the legs
extended forward along the seat pan
oriented 21.6 degrees relative to
horizontal with the knees spaced 40 mm
apart. On the non-impact side of the
dummy, the long axis of the upper arm
is positioned parallel to the seat back
(±2 degrees). On the impact side, the
upper arm is positioned such that the
target point intersects its long axis as
described in paragraph (c)(5) of this
section. The long axis of the upper arm
is defined by section line A–A in
drawing 020–9750. Both of the lower
arms are set perpendicular to the upper
arms and parallel to the dummy’s
sagittal plane. Move the elbows inward
(medially) until initial contact occurs
between the sleeve and the portion of
the suit covering the thorax while
maintaining the relationships between
the arms, seat back, and sagittal plane.
(5) The target point of the impact is
the point of intersection on the lateral
aspect of the upper arm and a line
projecting from the thorax of the
dummy. The projecting line is
horizontal, runs parallel to the coronal
plane of the dummy, and passes through
the midpoint of a line connecting the
centers of the bolt heads of the two IR–
TRACC bolts (part #5000646). The
projected line should intersect the
upper arm within 2 mm of its long axis.
(6) Impact the arm with the test probe
so that at the moment of contact the
probe’s longitudinal centerline should
be horizontal (±1 degrees), and the
centerline of the probe should be within
2 mm of the target point.
(7) Guide the test probe during impact
so that there is no significant lateral,
vertical, or rotational movement.
(8) No suspension hardware,
suspension cables, or any other
attachments to the probe, including the
velocity vane, shall make contact with
the dummy during the test.
§ 572.216 Thorax without arm assembly
and test procedure.
All assemblies and drawings
referenced in this section are contained
in Drawings and Specifications,
incorporated by reference, see § 572.210.
(a) The thorax assembly for this test
consists of the torso assembly (drawing
020–4500) with IR–TRACC (drawing
SA572–S37) installed.
(b) When the thorax of a completely
assembled dummy (drawing 020–0100)
with the arm (drawing 020–9700 or
020–9800) on the impacted side
removed is impacted laterally by a test
probe conforming to § 572.219 at 3.3 ±
0.1 m/s according to the test procedure
in paragraph (c) of this section:
(1) Maximum lateral thorax
displacement (compression) relative to
the spine, measured with the IR–TRACC
(drawing SA572–S37) and processed as
set out in the PADI (incorporated by
reference, see § 572.210), shall have a
value between 24.5 mm and 30.5 mm.
The peak force, measured by the impact
probe as defined in § 572.219 and
calculated in accordance with paragraph
(b)(2) of this section, shall have a value
between 610 N and 754 N.
(2) The force shall be calculated by
the product of the impactor mass and its
measured deceleration.
(c) The test procedure for the thorax
without arm assembly is as follows:
(1) The dummy is clothed in the Q3s
suit (drawing 020–8001). No additional
clothing or shoes are placed on the
dummy.
(2) Soak the dummy in a controlled
environment at any temperature
between 20.6 and 22.2 °C and a relative
humidity from 10 to 70 percent for at
least four hours prior to a test.
(3) The test is carried out in the
direction opposing the primary load
vector of the ensuing full scale test for
which the dummy is being qualified. A
left thorax test set-up that is used to
qualify the dummy for an ensuing full
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scale left side impact is depicted in
figure W8 in appendix A to this subpart.
A right thorax set-up would be a mirror
image of that shown in Figure W8. Seat
the dummy on the qualification bench
described in figure V3 to § 572.194, the
seat pan and seat back surfaces of which
are covered with thin sheets of PTFE
(Teflon) (nominal stock thickness: 2 to
3 mm) along the impact side of the
bench.
(4) Position the dummy on the bench
as shown in figure W8 in appendix A to
this subpart, with the ribs making
contact with the seat back oriented 24.6
degrees relative to vertical, the legs
extended forward along the seat pan
oriented 21.6 degrees relative to
horizontal with the knees spaced 40 mm
apart, and the arm on the non-impacted
side positioned so that the upper arm is
parallel (±2 degrees) to the seat back and
the lower arm perpendicular to the
upper arm.
(5) The target point of the impact is
the midpoint of a line between the
centers of the bolt heads of the two IR–
TRACC bolts (part #5000646).
(6) Impact the thorax with the test
probe so that at the moment of contact
the probe’s longitudinal centerline
should be horizontal (±1 degrees), and
the centerline of the probe should be
within 2 mm of the target point.
(7) Guide the test probe during impact
so that there is no significant lateral,
vertical, or rotational movement.
(8) No suspension hardware,
suspension cables, or any other
attachments to the probe, including the
velocity vane, shall make contact with
the dummy during the test.
§ 572.217 Lumbar spine assembly and test
procedure.
All assemblies and drawings
referenced in this section are contained
in Drawings and Specifications,
incorporated by reference, see § 572.210.
(a) The lumbar spine and headform
assembly for the purposes of the fore-aft
lumbar flexion and lateral lumbar
flexion qualification tests, as shown in
Figures W9 and W10 in appendix A to
this subpart, consists of the headform
(drawing 020–9050, sheet 2) with
angular rate sensor installed (drawing
SA572–S58), six-channel neck/lumbar
load cell (drawing SA572–S8), lumbar
spine assembly (drawing 020–6000),
lumbar interface plate (drawing 020–
9062) and pendulum interface plate
(drawing 020–9051) with angular rate
sensor installed (drawing SA572–S58).
(b) When the lumbar spine and
headform assembly is tested according
to the test procedure in paragraph (c) of
this section, it shall have the following
characteristics:
(1) Fore-aft lumbar flexion
qualification test. (i) Plane D, referenced
in figure W9 in appendix A to this
subpart, shall rotate in the direction of
pre-impact flight with respect to the
pendulum’s longitudinal centerline
between 47.0 degrees and 58.5 degrees.
During the time interval while the
rotation is within these angles, the peak
moment measured by the neck/lumbar
transducer (drawing SA572–S8) shall
have a value between 78.2 N-m and 96.2
N-m.
(ii) The decaying headform rotation
vs. time curve shall cross the zero angle
with respect to its initial position at
time of impact relative to the pendulum
centerline between 49 to 59 ms after the
time the peak rotation value is reached.
(iii) All instrumentation data channels
are defined to be zero when the
longitudinal centerline of the lumbar
spine and pendulum are parallel.
(iv) The headform rotation shall be
calculated by the following formula
with the integration beginning at time
zero:
Headform rotation (deg) = [(Headform
Angular Rate)
y
¥(Pendulum
Angular Rate)
y
] dt
(v) (Headform Angular Rate)
y
is the
angular rate about the y-axis in deg/sec
measured on the headform (drawing
020–9050, sheet 2), and (Pendulum
Angular Rate)
y
is the angular rate about
the y-axis in deg/sec measured on the
pendulum interface plate (drawing 020–
9051).
(2) Lateral lumbar flexion
qualification test. (i) Plane D, referenced
in figure W10, shall rotate in the
direction of pre-impact flight with
respect to the pendulum’s longitudinal
centerline between 46.1 degrees and
58.2 degrees. During the time interval
while the rotation is within these
angles, the peak moment measured by
the neck/lumbar transducer (drawing
SA572–S8) shall have a value between
79.4 N-m and 98.1 N-m.
(ii) The decaying headform rotation
vs. time curve shall cross the zero angle
with respect to its initial position at
time of impact relative to the pendulum
centerline between 48 to 59 ms after the
time the peak rotation value is reached.
(iii) All instrumentation data channels
are defined to be zero when the
longitudinal centerline of the lumbar
spine and pendulum are parallel.
(iv) The headform rotation shall be
calculated by the following formula
with the integration beginning at time
zero:
Headform rotation (deg) =
[(Headform Angular Rate)
y
¥(Pendulum
Angular Rate)
y
] dt
(v) (Headform Angular Rate)
y
is the
angular rate about the y-axis in deg/
sec measured on the headform
(drawing 020–9050, sheet 2), and
(Pendulum Angular Rate)
y
is the
angular rate about the y-axis in deg/
sec measured on the pendulum
interface plate (drawing 020–9051).
(c) The test procedure for the lumbar
spine assembly is as follows:
(1) Soak the lumbar spine assembly in
a controlled environment at any
temperature between 20.6 and 22.2 °C
and a relative humidity between 10 and
70 percent for at least four hours prior
to a test.
(2)(i) For the fore-aft lumbar flexion
test, mount the lumbar spine and
headform assembly, defined in
paragraph (a) of this section, on the
pendulum described Figure 22 to
§ 572.33 so that the midsagittal plane of
the headform is vertical and coincides
with the plane of motion of the
pendulum, and with the lumbar spine
placement such that the front side of the
lumbar spine is closest to the
honeycomb material.
(ii) For the lateral lumbar flexion test,
the test is carried out in the direction
opposing the primary load vector of the
ensuing full scale test for which the
dummy is being qualified. A right
flexion test set-up that is used to qualify
the dummy for an ensuing a full scale
right side impact is depicted in figure
W10 in appendix A to this subpart. A
left flexion test set-up would be
depicted by a mirror image of all
components beneath the pendulum
interface plate in Figure W10. Mount
the lumbar spine and headform
assembly, defined in paragraph (a)(1) of
this section, on the pendulum described
in figure 22 to § 572.33 so that the
midsagittal plane of the headform is
vertical and perpendicular to the
direction of motion of the pendulum,
and with the lumbar spine placement
such that the right (or left) side of the
lumbar spine is closest to the
honeycomb material.
(3)(i) Release the pendulum and allow
it to fall freely from a height to achieve
an impact velocity of 4.4 ± 0.1 m/s,
measured by an accelerometer mounted
on the pendulum as shown in Figure 22
to § 572.33 at time zero.
(ii) Stop the pendulum from the
initial velocity with an acceleration vs.
time pulse that meets the velocity
change as specified in table 1 to this
section. Integrate the pendulum
accelerometer data channel to obtain the
velocity vs. time curve beginning at time
zero.
(iii) Time zero is defined as the time
of initial contact between the pendulum
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striker plate and the honeycomb
material.
T
ABLE
1
TO
§ 572.217
Time
(ms)
Fore-aft
flexion
(m/s)
Lateral
flexion
(m/s)
10 ...................... 1.3–1.7 1.3–1.7
20 ...................... 2.7–3.7 2.7–3.7
30 ...................... 4.1–4.9 4.0–4.8
§ 572.218 Pelvis assembly and test
procedure.
All assemblies and drawings
referenced in this section are contained
in Drawings and Specifications,
incorporated by reference, see § 572.210.
(a) The pelvis assembly (drawing 020–
7500) for this test may include either a
uniaxial pubic load cell (drawing
SA572–S7) or a pubic load cell
structural replacement (drawing 020–
7150) installed on the non-impact side
of the pelvis.
(b) When the center of the pelvis of a
completely assembled dummy (drawing
020–0100) is impacted laterally by a test
probe conforming to § 572.219 at 4.0 ±
0.1 m/s according to the test procedure
in paragraph (c) of this section:
(1) The peak force, measured by the
impact probe as defined in § 572.219
and calculated in accordance with
paragraph (b)(2) of this section, shall
have a value between 1587 N and 1901
N.
(2) The force shall be calculated by
the product of the impactor mass and its
measured deceleration.
(c) The test procedure for the pelvis
assembly is as follows:
(1) The dummy is clothed in the Q3s
suit (drawing 020–8001). No additional
clothing or shoes are placed on the
dummy.
(2) Soak the dummy in a controlled
environment at any temperature
between 20.6 and 22.2 °C (69 and 72 °F)
and a relative humidity from 10 to 70
percent for at least four hours prior to
a test.
(3) The pelvis test is carried out in the
direction opposing the primary load
vector of the ensuing full scale test for
which the dummy is being qualified. A
left pelvis test set-up that is used to
qualify the dummy for an ensuing full
scale left side impact is depicted in
figure W11 in appendix A to this
subpart. A right pelvis test set-up would
be a mirror image of that shown in
figure W11. Seat the dummy on the
qualification bench described in figure
V3 to § 572.194, the seat pan and seat
back surfaces of which are covered with
thin sheets of PTFE (Teflon) (nominal
stock thickness: 2 to 3 mm) along the
impact side of the bench.
(4) Position the dummy on the bench
as shown in figure W11 in appendix A
to this subpart, with the ribs making
contact with the seat back oriented 24.6
degrees relative to vertical, the legs
extended forward along the seat pan
oriented 21.6 degrees relative to
horizontal with the knees spaced 40 mm
apart. The arms should be positioned so
that the arm on the non-impacted side
is parallel to the seat back with the
lower arm perpendicular to the upper
arm, and the arm on the impacted side
is positioned upwards away from the
pelvis.
(5) Establish the impact point at the
center of the pelvis so that the impact
point of the longitudinal centerline of
the probe is located 185 mm from the
center of the knee pivot screw (part
#020–9008) and centered vertically on
the femur.
(6) Impact the pelvis with the test
probe so that at the moment of contact
the probe’s longitudinal centerline
should be horizontal (±1 degrees), and
the centerline of the probe should be
within 2 mm of the center of the pelvis.
(7) Guide the test probe during impact
so that there is no significant lateral,
vertical, or rotational movement.
(8) No suspension hardware,
suspension cables, or any other
attachments to the probe, including the
velocity vane, shall make contact with
the dummy during the test.
§ 572.219 Test conditions and
instrumentation.
All assemblies and drawings
referenced in this section are contained
in Drawings and Specifications,
incorporated by reference, see § 572.210.
(a) The following test equipment and
instrumentation is needed for
qualification as set forth in this subpart:
(1) The test probe for shoulder,
thorax, and pelvis impacts is of rigid
metallic construction, concentric in
shape, and symmetric about its
longitudinal axis. It has a mass of 3.81
± 0.02 kg and a minimum mass moment
of inertia of 560 kg-cm
2
in yaw and
pitch about the CG. One-third (
1
3
) of the
weight of the suspension cables and
their attachments to the impact probe is
included in the calculation of mass, and
such components may not exceed five
percent of the total weight of the test
probe. The impacting end of the probe,
perpendicular to and concentric with
the longitudinal axis, is at least 25.4 mm
long, and has a flat, continuous, and
non-deformable 70.0 ± 0.25 mm
diameter face with an edge radius
between 6.4–12.7 mm. The probe’s end
opposite to the impact face has
provisions for mounting of an
accelerometer with its sensitive axis
collinear with the longitudinal axis of
the probe. No concentric portions of the
impact probe may exceed the diameter
of the impact face. The impact probe
shall have a free air resonant frequency
of not less than 1000 Hz, which may be
determined using the procedure listed
in the PADI (incorporated by reference,
see § 572.210).
(2) Head accelerometers have
dimensions, response characteristics,
and sensitive mass locations specified
in drawing SA572–S4 and are mounted
in the head as shown in drawing 020–
0100, sheet 2 of 5.
(3) The upper neck force and moment
transducer has the dimensions, response
characteristics, and sensitive axis
locations specified in drawing SA572–
S8 and is mounted in the head-neck
assembly as shown in drawing 020–
0100, sheet 2 of 5.
(4) The angular rate sensors for the
fore-aft neck flexion and lateral neck
flexion qualification tests have the
dimensions and response characteristics
specified in drawing SA572–S58 and
are mounted in the headform and on the
pendulum as shown in figures W3 and
W4 in appendix A to this subpart.
(5) The string potentiometer shoulder
deflection transducers have the
dimensions and response characteristics
specified in drawing SA572–S38 or
SA572–S39 and are mounted to the
torso assembly as shown in drawing
020–0100, sheet 2 of 5.
(6) The IR–TRACC thorax deflection
transducers have the dimensions and
response characteristics specified in
drawing SA572–S37 and are mounted to
the torso assembly as shown in drawing
020–0100, sheet 2 of 5.
(7) The lumbar spine force and
moment transducer has the dimensions,
response characteristics, and sensitive
axis locations specified in drawing
SA572–S8 and is mounted in the torso
assembly as shown in drawing 020–
0100, sheet 2 of 5.
(8) The angular rate sensors for the
fore-aft lumbar flexion and lateral
lumbar flexion qualification tests have
the dimensions and response
characteristics specified in drawing
SA572–S58 and are mounted in the
headform and on the pendulum as
shown in figures W9, W10 in appendix
A to this subpart.
(b) The following instrumentation
may be required for installation in the
dummy for compliance testing. If so, it
is installed during qualification
procedures as described in this subpart:
(1) The optional angular rate sensors
for the head have the dimensions and
response characteristics specified in any
of drawings SA572–S55, SA572–S56,
SA572–S57 or SA572–S58 and are
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mounted in the head as shown in
drawing 020–0100, sheet 2 of 5.
(2) The upper spine accelerometers
have the dimensions, response
characteristics, and sensitive mass
locations specified in drawing SA572–
S4 and are mounted in the torso
assembly as shown in drawing 020–
0100, sheet 2 of 5.
(3) The pelvis accelerometers have the
dimensions, response characteristics,
and sensitive mass locations specified
in drawing SA572–S4 and are mounted
in the torso assembly as shown in
drawing 020–0100, sheet 2 of 5.
(4) The T1 accelerometer has the
dimensions, response characteristics,
and sensitive mass location specified in
drawing SA572–S4 and is mounted in
the torso assembly as shown in drawing
020–0100, sheet 2 of 5.
(5) The lower neck force and moment
transducer has the dimensions, response
characteristics, and sensitive axis
locations specified in drawing SA572–
S8 and is mounted to the neck assembly
as shown in drawing 020–0100, sheet 2
of 5.
(6) The tilt sensor has the dimensions
and response characteristics specified in
drawing SA572–S44 and is mounted to
the torso assembly as shown in drawing
020–0100, sheet 2 of 5.
(7) The pubic force transducers have
the dimensions and response
characteristics specified in drawing
SA572–S7 and are mounted in the torso
assembly as shown in drawing 020–
0100, sheet 2 of 5.
(c) The outputs of transducers
installed in the dummy and in the test
equipment specified by this part are to
be recorded in individual data channels
that conform to SAE J211 (incorporated
by reference, see § 572.210) except as
noted, with channel frequency classes
(CFCs) as follows:
(1) Pendulum acceleration, CFC 180,
(2) Pendulum angular rate, CFC 60,
(3) Neck twist fixture rotation, CFC
60,
(4) Test probe acceleration, CFC 180,
(5) Head accelerations, CFC 1000,
(6) Headform angular rate, CFC 60,
(7) Neck moments, upper and lower,
CFC 600,
(8) Shoulder deflection, CFC 180,
(9) Thorax deflection, CFC 180,
(10) Upper spine accelerations, CFC
180,
(11) T1 acceleration, CFC 180,
(12) Pubic force, CFC 180,
(13) Pelvis accelerations, CFC 1000.
(d) Coordinate signs for
instrumentation polarity are to conform
to SAE J1733 (incorporated by reference,
see § 572.210).
(e) The mountings for sensing devices
have no resonant frequency less than 3
times the frequency range of the
applicable channel class.
(f) Limb joints are set at one G, barely
restraining the weight of the limb when
it is extended horizontally. The force
needed to move a limb segment is not
to exceed 2G throughout the range of
limb motion.
(g) Performance tests of the same
component, segment, assembly, or fully
assembled dummy are separated in time
by not less than 30 minutes unless
otherwise noted.
(h) Surfaces of dummy components
may not be painted except as specified
in this subpart or in drawings subtended
by this subpart.
Appendix A to Subpart W of Part 572—
Figures
BILLING CODE 4910–59–P
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James C. Owens,
Deputy Administrator.
[FR Doc. 2020–21478 Filed 11–2–20; 8:45 am]
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