Federal Motor Vehicle Safety Standards; Child Restraint Systems, Child Restraint Anchorage Systems; Incorporation by Reference
Federal Register, Volume 80 Issue 15 (Friday, January 23, 2015)
Federal Register Volume 80, Number 15 (Friday, January 23, 2015)
Proposed Rules
Pages 3743-3785
From the Federal Register Online via the Government Printing Office www.gpo.gov
FR Doc No: 2015-00162
Page 3743
Vol. 80
Friday,
No. 15
January 23, 2015
Part II
Department of Transportation
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National Highway Traffic Safety Administration
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49 CFR Part 571
Federal Motor Vehicle Safety Standards; Child Restraint Systems, Child Restraint Anchorage Systems; Incorporation by Reference; Proposed Rule
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
49 CFR Part 571
Docket No. NHTSA-2014-0123
RIN 2127-AL20
Federal Motor Vehicle Safety Standards; Child Restraint Systems, Child Restraint Anchorage Systems; Incorporation by Reference
AGENCY: National Highway Traffic Safety Administration (NHTSA), Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM); request for comments.
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SUMMARY: In accordance with NHTSA's 2011-2013 Priority Plan and the Moving Ahead for Progress in the 21st Century Act (MAP-21), this document proposes to amend Federal Motor Vehicle Safety Standard (FMVSS) No. 225, ``Child restraint anchorage systems,'' to improve the ease of use of the lower anchorages of child restraint anchorage systems and the ease of use of tether anchorages. This document also proposes changes to FMVSS No. 213, ``Child restraint systems,'' to amend labeling and other requirements to improve the ease of use of child restraint systems with a vehicle anchorage system. This NPRM proposes rulemaking on these and other requirements to increase the correct use of child restraint anchorage systems and tether anchorages, and the correct use of child restraints, with the ultimate goal of reducing injuries to restrained children in motor vehicle crashes.
DATES: Comments must be received on or before March 24, 2015.
Proposed compliance date: We propose that the compliance date for the amendments in this rulemaking action would be three years following the date of publication of the final rule in the Federal Register. We propose to permit optional early compliance with the amended requirements.
ADDRESSES: You may submit comments to the docket number identified in the heading of this document by any of the following methods:
Federal eRulemaking Portal: Go to http://www.regulations.gov. Follow the online instructions for submitting comments.
Mail: Docket Management Facility, M-30, U.S. Department of Transportation, West Building, Ground Floor, Rm. W12-140, 1200 New Jersey Avenue SE., Washington, DC 20590.
Hand Delivery or Courier: West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue SE., between 9 a.m. and 5 p.m. Eastern Time, Monday through Friday, except Federal holidays.
Fax: (202) 493-2251.
Regardless of how you submit your comments, please mention the docket number of this document.
You may also call the Docket at 202-366-9324.
Instructions: For detailed instructions on submitting comments and additional information on the rulemaking process, see the Public Participation heading of the Supplementary Information section of this document. Note that all comments received will be posted without change to http://www.regulations.gov, including any personal information provided.
Privacy Act: Please see the Privacy Act heading under Rulemaking Analyses and Notices.
FOR FURTHER INFORMATION CONTACT: For technical issues, you may call Cristina Echemendia, Office of Crashworthiness Standards (telephone: 202-366-6345) (fax: 202-493-2990). For legal issues, you may call Deirdre Fujita, Office of Chief Counsel (telephone: 202-366-2992) (fax: 202-366-3820). 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
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Executive Summary
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Statutory Mandate
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Efforts To Improve Vehicle/Child Restraint Compatibility and Ease of Use of Child Restraint Anchorage Systems
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ISO Rating System
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SAE Guidelines
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NCAP Vehicle-CRS Fit Program
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UMTRI's LATCH Usability Study
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Overview of the Study
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Three Seat Characteristics Were Well Correlated With Correct Use
A. Clearance Angle
B. Attachment Force
C. Anchorage Depth
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UMTRI's Assessment of the ISO, SAE, and NCAP Programs
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NHTSA's Preference Is the UMTRI Approach
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Proposal To Improve Lower Anchorage Usability
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Clearance Angle
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Attachment Force
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Anchorage Depth
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Estimated Rate of Current Compliance
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Proposal To Improve Tether Anchorage Usability
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Limit the Zone
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Anchorage Must Be Accessible
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Standardized Configuration
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Clearance Around the Tether Anchorage
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Conspicuity and Identification of Anchorages
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Marking Lower Anchorages
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Marking Tether Anchorages
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Conspicuity and Identification of CRS Connectors
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Lower Anchorage Connectors
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Tether Hook
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Request for Comments
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Center Rear Seat
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Third Row
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Vehicles Currently Excluded From FMVSS No. 225
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Written Instructions
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Terminology
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Recommendation for Tether Anchor Use
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Proposed Effective Date
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Regulatory Notices and Analyses
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Public Participation
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Executive Summary
Introduction
In accordance with NHTSA's 2011-2013 Priority Plan and Subtitle E of MAP-21, this document proposes to amend FMVSS No. 225 to improve the ease of use of child restraint anchorage systems. First, we propose to amend FMVSS No. 225 to adopt requirements that would make it easier for consumers to attach child restraints to the lower anchorages of child restraint anchorage systems. The requirements would ensure that vehicle manufacturers produce lower anchorages that: (
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Have sufficient clearance around each lower anchorage for consumers to maneuver the child restraint system (CRS) connector; (b) are located such that the CRS connector can be attached to the bar using a reasonable amount of force; and, (c) are within two centimeters (cm) of the outer surface of the ``seat bight'' (the seat bight is approximately the intersection of the seat bottom cushion and seat back cushion).
Second, we propose to make tether anchorages easier to use by standardizing the configuration of the anchorage such that it is ``a rigid bar of any cross section shape,'' by prohibiting the anchorages from being placed under a vehicle seat or hidden under carpet, and by requiring them to be placed where there is enough space around the anchorage for consumers to tighten the tether strap.
Third, this document proposes to amend FMVSS No. 225 and FMVSS No. 213 to require, among other things, vehicles and CRSs to use a standardized symbol to more effectively identify the anchorages in the vehicle and the components on CRSs that attach to those anchorages.
In addition, this document requests comments on several issues relating to the usability of child restraint anchorage systems. We request comment on whether child restraint anchorage
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systems and/or tether anchorages should be required in more rear seating positions than currently required, including in vehicles now excluded from FMVSS No. 225. We also request comment on the merits of requiring vehicle and CRS manufacturers to use standardized terminology in users' manuals in describing components of the child restraint anchorage system and the connectors of child restraint systems, to enhance consumer education and increase correct use of child restraint anchorage systems and child restraints. Finally, test data indicate that tether anchorages are sufficiently robust to provide crash protection to virtually all children restrained in a harnessed child restraint. We request comment on the merits of consumer information that advises consumers to attach the tether when restraining a child in a harnessed child restraint, regardless of the weight of the child.
Background
In 1999, NHTSA issued FMVSS No. 225,\1\ a standard that requires vehicle manufacturers to equip vehicles with child restraint anchorage systems that are standardized and independent of the vehicle seat belts. The child restraint anchorage system required by FMVSS No. 225 is a 3-point system consisting of two lower anchorages and a tether anchorage designed for attaching a child restraint system to a vehicle. Each lower anchorage consists of a six millimeter (mm) diameter straight rod, or ``bar,'' onto which a CRS connector can be attached. The two lower anchorage bars are typically located at or near the seat bight in a position where they will not be felt by seated adult occupants. The tether anchorage is a part to which a tether hook of a CRS can be attached. Standard No. 225 requires vehicles with three or more forward-facing rear seating positions to be equipped with child restraint anchorage systems at not fewer than two rear seating positions and a tether anchorage at an additional rear seating position. That third tether anchorage can be used when installing a CRS with the vehicle's seat belt. The requirements of FMVSS No. 225 were phased into new vehicles from 1999 to 2002 beginning with the tether anchorage in passenger cars in 1999, and ending with full implementation of FMVSS No. 225 for passenger cars, multipurpose passenger vehicles (MPVs), and trucks and buses \2\ on September 1, 2002.
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\1\ 49 CFR 571.225.
\2\ Specifically, trucks and MPVs with a gross vehicle weight rating (GVWR) of 3,855 kilograms (kg) (8,500 pounds (lb)) or less, and to buses with a GVWR of 4,536 kg (10,000 lb) or less.
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The 1999 rule also amended FMVSS No. 213 to require CRSs to be equipped with connectors that enable the CRS to attach to the vehicle's lower anchorages of the child restraint anchorage system.3 4 A new head excursion performance requirement was added for forward-
facing child restraints (other than booster seats), and to meet it, child restraints typically use a tether strap affixed to the top of the restraints. The tether strap must have a hook that is designed to attach to the tether anchorage of the child restraint anchorage system (see S5.9(b) of FMVSS No. 213).
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\3\ 49 CFR 571.213, sections S5.3.2, S5.9. Excepted from the requirement were booster seats, car beds, and harnesses.
\4\ Additionally, Standard No. 213 requires all CRSs to be capable of attachment to the vehicle seat by a seat belt, even if the CRS has lower anchorage connectors.
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In this NPRM we use the following term for the full vehicle system: ``Child restraint anchorage system.'' \5\ We use the following for the lower anchorage points of a child restraint anchorage system: ``Lower anchorage(s).'' The tether securement point is called a ``tether anchorage.'' For the CRS, we use the following terms to refer to the various parts of a child restraint that connect to the child restraint anchorage system, as appropriate: ``Child restraint system connectors (or CRS connectors),'' ``lower anchorage connector(s),'' ``tether anchorage connector,'' ``tether strap,'' and ``tether hook.''
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\5\ Many in the child passenger safety community refer to the child restraint anchorage system as the ``LATCH'' system, an abbreviation of the phrase ``Lower Anchors and Tethers for Children.'' The term was developed by a group of manufacturers and retailers soon after the 1999 final rule, for use in educating consumers on the availability and use of the anchorage system and for marketing purposes. ``LATCH'' has been used in various materials in the field and by NHTSA to refer to the vehicle 3-point child restraint anchorage system, but at times the term has been used to refer just to the lower two anchorages of the system, and at times it has been used to refer to the connectors of the child restraint system that attach to the lower anchorages. Also, apparently a number of consumers identify the tether anchorage solely with the ``LATCH'' system, and so mistakenly do not attach the CRS's tether strap when using the vehicle belt system to attach a child restraint. Because some ambiguity has developed with the use of the term ``LATCH,'' we generally avoid using the term ``LATCH'' in this NPRM when possible.
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Developments Post-1999 Final Rule
Child restraint anchorage systems meeting FMVSS No. 225, and child restraints meeting the associated requirements of FMVSS No. 213, have been successfully implemented in the fleet. Consumers who use the system generally like the system.\6\ However, many consumers do not use child restraint anchorage systems because they do not know enough about the systems.\7\ Many consumers also misuse the child restraint anchorage system or find aspects of it difficult to use.
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\6\ Decina, L., et al., ``Child Restraint Use Survey: LATCH Use and Misuse,'' December 2006, (``Decina study''), DOT HS 810 679, Docket No. NHTSA-2006-26735. The Decina study is summarized in Appendix A to this preamble.
\7\ Id.
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In 2007, NHTSA held a public meeting on child restraint anchorage systems to see how the systems could be improved.\8\ There were repeated comments at the meeting that the lower anchorages often were embedded deep into the seat bight, making it difficult for consumers to reach the lower anchorages and attach the lower anchorage connectors. There were also complaints that it was difficult to attach lower anchorage connectors to the lower anchorages because of surrounding stiff cushions or fabric/leather or the proximity of seat belt buckles.
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\8\ Docket No. NHTSA-07-26833. A summary of the public meeting can be found in Appendix B to this preamble.
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Following the 2007 meeting, the agency identified improving the ease of use of child restraint anchorage systems as an area of significance to NHTSA. NHTSA announced in the NHTSA Vehicle Safety and Fuel Economy Rulemaking and Research Priority Plan 2011-2013 (March 2011) (``2011 Priority Plan'') \9\ that the agency is addressing issues to improve the usability of child restraint anchorage systems and may initiate rulemaking on issues relating to the presence of anchorage systems in center rear seats, tether anchorage locations, weight limits of anchorages,\10\ and labeling of the anchorage locations.
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\9\ http://www.nhtsa.gov/staticfiles/rulemaking/pdf/2011-2013_Vehicle_Safety-Fuel_Economy_Rulemaking-Research_Priority_Plan.pdf
\10\ The agency addressed the issue of the weight limit of the lower anchorages by a new labeling requirement that informs consumers of the load limits of the child restraint anchorage system. See 77 FR 11626, February 27, 2012; response to petition for reconsideration, 79 FR 10396, February 25, 2014. NHTSA originally designed the child restraint anchorage systems to be strong enough to withstand crash forces generated by a 29.5 kg (65 lb) mass (the mass would be from the child restraint plus the restrained child). Child restraint systems and the children for whom many of them are designed have become heavier over the years. To ensure the lower anchorages are strong enough to hold the CRS plus child in serious and severe crashes, NHTSA adopted a labeling requirement applying to child restraints which, together with the restrained child, would impose a combined weight over 29.5 kg (65 lb) on the lower anchorages. These CRSs must have a label informing consumers to use the seat belt system instead of the lower anchorages to attach the child restraint to the vehicle seat once the combined weight exceeds 29.5 kg (65 lb).
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The ease of use of child restraint anchorage systems is inherently challenging because the vehicle is manufactured by one party and the child restraint is manufactured by another. The vehicle seat is designed with occupant comfort and safety in mind, along with aesthetics; child restraint compatibility can be difficult to plan for given the wide and constantly changing array of child restraints. Through usability requirements adopted in the 1999 final rule, we improved the interface between the vehicle anchorage system and the child restraint. Yet, our improvements for the vehicle side focused on standardizing the parameters of the 3-point anchorage system and specifying where the anchorage system should be positioned overall in a vehicle and relative to a ``child restraint fixture'' (CRF) test device to optimize ease of use. Although the 1999 final rule recognized the importance of having the lower anchorages visible or marked with an emblem signaling the presence and location of the anchorages, the final rule was the first undertaking by any country to establish a universal child restraint anchorage system independent of the vehicle belts. Thus, in making the first step toward standardizing a child restraint anchorage system, the agency only partially standardized the marking, and did not regulate features of the vehicle seat relating to cushion stiffness and other characteristics of the vehicle seat. For similar reasons, NHTSA refrained from standardizing CRS features that might affect compatibility, such as CRS size and mass.
New Information Improving Anchorage Systems
New information from the University of Michigan Transportation Research Institute (UMTRI) has identified characteristics of the vehicle seat that UMTRI has found to enhance the usability of child restraint anchorage systems. In April 2012, UMTRI published a study \11\ titled, ``LATCH Usability in Vehicles'' (hereinafter ``LATCH Usability study''), that identified vehicle seat characteristics shown to affect the quality of child restraint installations. UMTRI found that the correct use of lower anchorages was associated with the following features:
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\11\ Klinich et al., ``LATCH Usability in Vehicles,'' UMTRI-
2012-7, April 2012. Link: http://deepblue.lib.umich.edu/handle/2027.42/90856. The report was sponsored by the Insurance Institute for Highway Safety (IIHS) for developing IIHS's rating of the usability of the child restraint anchorage systems in various vehicles. See IIHS Status Report: Vol. 47 No. 3, April 12, 2012.
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``Clearance angle'' greater than 54 degrees (clearance angle relates to the clearance around a lower anchorage from interfering parts that can make it difficult to maneuver the CRS lower anchorage connector);
``attachment force'' of 178 Newtons (N) (40 pounds (lb)) or less (attachment force is the amount of force needed to attach a lower anchorage connector); and,
``anchorage depth'' (location of the anchorage within the seat bight) of less than 2 centimeters (cm).
Further, improved designs in anchorage markings have been developed by the International Standardization Organization (ISO) that can better communicate to the consumer the location and presence of the lower anchorages and tether anchorage, and further harmonize the safety standard with those of other countries.
Today's NPRM uses the information from UMTRI and ISO to propose enhancements to the usability requirements in FMVSS No. 225.
Overview of Proposal
Our ease of use improvements focus on reducing the physical effort needed to attach a child restraint to the lower anchorages and to the tether anchorage, and on improving how easily the anchorages can be correctly identified and accessed by a consumer.
Ease of Using Lower Anchorages
FMVSS No. 225's current location requirements for the lower anchorage bars intend for the bars to be accessible, but some consumers find it difficult to use the bars. We propose new requirements for the bars to improve ease of use: a minimum clearance angle of 54 degrees, a maximum attachment force of 178 N (40 lb), and a location limit of less than 2 cm within the seat bight. These are the ease of use specifications the UMTRI LATCH Usability study found to correlate with correct child restraint installation by test subjects.
Ease of Using Tether Anchorages
Standard No. 225 currently requires vehicle manufacturers to equip vehicles with a tether anchorage at three rear designated seating positions (two of these positions are also required to be equipped with lower anchorages) that enables the attachment of a standardized tether hook. The standard currently requires tether anchorages to be located in a specified zone and to be accessible without the need for any tools other than a screwdriver or coin. To improve the usability of the tether anchorage, we propose the following requirements to make it easier for consumers to recognize and reach the anchorage.
We propose to amend FMVSS No. 225 to reduce the zone in which a tether anchorage must be located, to prevent tether anchorages from being placed deep under a vehicle seat.
We propose to require tether anchorages to be accessible without the need for any tools and without folding the seat back or removing carpet or other vehicle components. (The tether anchorage may be covered with a cap, flap or cover, provided that the cap, flap or cover is specifically designed to be opened, moved aside or to otherwise give access to the anchorage without the use of any tools and is labeled with a specific symbol indicting the presence of the tether anchorage underneath.)
Almost all tether anchorages are rigid metal bars, but there are a few made from flexible webbing, which confuses some consumers who are looking for a bar. We propose amending FMVSS No. 225 to require the tether anchorage to be a rigid bar.
Some tether anchorages are too close to a structure, such as a head restraint, to allow tightening of the tether strap. We propose to specify a minimum 165 mm (6.5 in) distance from a reference point on the vehicle seat to the tether anchorage so that adequate clearance will be provided for tightening of the tether strap. We also propose amending FMVSS No. 213 to limit the length of the CRS tether hardware assembly (which consists of a tether hook and hardware to tighten and loosen the tether strap) to 165 mm (6.5 in) so that the tightening mechanism can be easily used in the newly-specified clearance space around a tether anchorage.
Enhanced Ability To Identify Anchorages
Standard No. 225 currently requires the lower anchorage bars either to be visible or the vehicle seat back marked showing the location of the bars. To improve consumers' ability to find and use lower anchorages, we propose amending FMVSS No. 225 to require motor vehicles to be marked with the ISO-developed mark near the location of each lower anchorage bar, even if the lower anchorage is visible. Similarly, we propose requiring each tether anchorage to be marked with the ISO-
developed mark for tether anchorages. In addition, we propose amending FMVSS No. 213 to require the ISO mark on the lower anchorage connectors (the components on the child restraint system that attach the child restraint to the lower anchorages of a child restraint
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anchorage system) and on the tether hook.\12\ We also propose to require vehicle manufacturers to provide written information (e.g., in vehicle owners' manuals) explaining the meaning of the ISO lower anchorage bar and tether anchorage markings, and to require child restraint manufacturers to explain (in the CRS user's manual) the meaning of the ISO mark on the lower anchorage connectors and tether hook.
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\12\ NHTSA is planning to develop new simplified education and consumer information programs building on the requirements proposed in this NPRM. Education efforts and consumer information programs would be developed to teach consumers to look for the ISO-developed marks in the vehicle to locate the lower anchorages and tether anchorages in their vehicles and to ``match'' them to the ISO marks on the CRS.
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Rulemaking Goal
The 2005 Decina study \13\ found that many consumers did not know what child restraint anchorage systems were, that anchorages were available in the vehicle, the importance of using the anchorages or how to use them properly. We believe that as the requirements proposed today make the anchorages more conspicuous and more clearly marked, awareness should improve. With improved awareness, more consumers will likely attempt to use the anchorage system.\14\
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\13\ ``Child Restraint Use Survey: LATCH Use and Misuse,'' supra.
\14\ Field data show that use of child restraint anchorage systems has noticeably increased since 2006. National Child Restraint Use Special Study (NCRUSS), DOT HS 811 679, http://www-nrd.nhtsa.dot.gov/Pubs/811679.pdf, and ``A Look Inside American Family Vehicles 2009-2010,'' Safe Kids USA (http://www.safekids.org/assets/docs/safety-basics/safety-tips-by-risk-area/sk-car-seat-report-2011.pdf). These data are discussed in Appendix A of this preamble.
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The Decina study found that users who attempted to use child restraint anchorage systems generally liked the systems. Drivers with experience attaching a CRS using a child restraint anchorage system and using a vehicle seat belt strongly preferred using the lower anchorages over the seat belts. Moreover, the study also found that consumers were more likely to install a CRS correctly using a child restraint anchorage system than when a seat belt was used. NHTSA believes that as consumers' awareness of child restraint anchorage systems increases, more consumers will try them and more will use them. If the systems can be made easier to use, more consumers will like and regularly use the system compared to current usage.
UMTRI's LATCH Usability study found that test subjects who correctly used the lower anchorage hardware were 3.3 times more likely to achieve a tight CRS installation than subjects who made errors using the hardware. Thus, we believe that if child restraint anchorage systems can be made easier to use correctly, more consumers will achieve a tight fit of the CRS in the vehicle. The tight fit of the CRS will lead to reduced child head and torso excursions in motor vehicle crashes, and fewer child head and torso injuries in crashes.
Estimated Costs and Benefits
The agency estimates that the proposed requirements for improved usability of child restraint anchorage systems would not result in any increase in material cost, but would entail some redesign of vehicle seat features. Approximately 79 percent of vehicles would need some redesign to meet the proposed lower anchorage usability requirements. Some tether anchorages would have to be repositioned further from the head restraint to meet the minimum strap wrap-around distance requirement. A small number of vehicles that currently have webbing loops for tether anchorages would need to be changed to have rigid anchorage bars. The agency believes that these design modification are minor and mainly concern the vehicle seat and not the vehicle structure. NHTSA is proposing a 3-year lead time for complying with a final rule, which, we believe, would provide sufficient time for vehicle manufacturers to accommodate any redesign of the vehicle seat in their normal course of manufacture without a cost increase.
For child restraints, we estimate that approximately 30 percent of forward-facing child restraints may need to have minor modification made to the tether hardware assembly to meet the 165 mm (6.5 in) maximum length requirement. We are proposing a 3-year lead time to meet the requirement.
The proposal requires all the lower anchorages and tether anchorages to be marked with the ISO mark. We estimate the cost of ISO marks for a set of lower anchorages to be $0.05 and that for the tether anchorage to be $0.025. The total incremental cost of equipping all child restraint anchorage systems with appropriate ISO marks is about $0.58 million. The proposal also requires similar ISO marks on child restraint anchorage connectors, for which the agency estimates an incremental cost of $0.74 million. The cost of changing the written instructions accompanying the vehicle or the CRS to explain the ISO markings is expected to be negligible (15 16
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\15\ See Sec. 31502(b)(2). That section also specifies that in such case that an amendment does not meet the requirements and considerations of Sec. 30111(a) and (b) of title 49, United States Code, the Secretary shall submit a report to Congress describing the reasons for not prescribing such a standard. Footnote added.
\16\ Another exception is in Sec. 31505, which specifies that if the Secretary determines that any deadline for issuing a final rule under this Act cannot be met, the Secretary shall provide Congress with an explanation for why such deadline cannot be met and establish a new deadline for that rule. Footnote added.
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The agency has interpreted Sec. 31502(a) as directing DOT to initiate rulemaking to improve the ease of use of lower anchorages and tether anchorages currently required by FMVSS No. 225 if improved anchorages are feasible. This interpretation is based on the plain meaning of the phrase ``improve the ease of use.'' We interpret ``improve'' to mean to enhance or increase the ease of use of prevailing FMVSS No. 225 lower anchorages and tether anchorages, which, in passenger cars and small MPVs, are present ``in all rear seat seating positions.'' Our 2011 Priority Plan took this approach in focusing on improving current tether anchorage locations and labeling of anchorage locations. This NPRM satisfies the mandate by proposing requirements that would improve the ease with which
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consumers can access and use the anchorages, and improve the visibility of the anchorages so that consumers can more easily identify them as parts of a child restraint anchorage system.
Furthermore, this document also requests comment on whether additional lower anchorages and tether anchorages should be required in vehicles. We request comment on the need for, and feasibility of, additional child restraint anchorage systems and tether anchorages in rear seating positions, particularly in the third row of vehicles with three rows of seating. We also request comments on the merits and feasibility of installing lower anchorages and tether anchorages in vehicles now excluded from requirements to provide such anchorages.
Section 31502 gives us discretion in determining whether a final rule in this rulemaking is warranted. We anticipate issuing a final rule unless an amendment ``does not meet the requirements and considerations set forth in subsections (a) and (b) of section 30111 of title 49, United States Code.'' \17\ The requirements and considerations of Sec. Sec. 30111(a) and (b) apply to NHTSA's FMVSS rulemaking under the Vehicle Safety Act. Under Sec. 30111(a), the Secretary is authorized to prescribe FMVSSs that are practicable, meet the need for motor vehicle safety, and are stated in objective terms. ``Motor vehicle safety'' is defined in the Vehicle Safety Act as ``the performance of a motor vehicle or motor vehicle equipment in a way that protects the public against unreasonable risk of accidents occurring because of the design, construction, or performance of a motor vehicle, and against unreasonable risk of death or injury in an accident, and includes nonoperational safety of a motor vehicle.'' Under Sec. 30111(b) of the Vehicle Safety Act, when prescribing such standards, the Secretary must consider relevant available motor vehicle safety information, consult with appropriate agencies, consider whether a standard is reasonable, practicable, and appropriate for the particular type of motor vehicle or motor vehicle equipment for which it is prescribed, and consider the extent to which the standard will further the statutory purpose of reducing traffic accidents and deaths and injuries resulting from traffic accidents. We understand MAP-21 as directing us to determine, after initiating rulemaking, whether the changes under consideration to FMVSS No. 225 meet the requirements and considerations set forth in subsections (a) and (b) of 49 U.S.C Sec. 30111 and are feasible. We will make a decision about a final rule after that assessment.
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\17\ Sec. 31502(b)(2).
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Efforts To Improve Vehicle/Child Restraint Compatibility and Ease of Use of Child Restraint Anchorage Systems
Following issuance of FMVSS No. 225, there have been several efforts to improve the compatibility of child restraint anchorage systems and CRSs, and the ease of using the systems.
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ISO Rating System
ISO developed a rating system and criteria to provide child restraint and vehicle manufacturers tools for the assessment of the usability of ISOFIX \18\ systems.\19\ The ISO approach evaluates and rates the usability of a CRS's ISOFIX features, a vehicle's ISOFIX system, and the interaction between the two. ISO also provides consumers (parents and caregivers) with information to assist them in selecting a CRS and vehicle with ISOFIX systems that are easy to use, with the aim that the information will result in more correct installations. (More information about the ISO draft standard is in Appendix C to this preamble.)
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\18\ ISOFIX is a system, mostly used in Europe, for the connection of child restraint systems to vehicles. The system has two vehicle rigid anchorages, two corresponding rigid attachments on the child restraint system and a means to limit the pitch rotation of the child restraint system. While the ISOFIX system is not used in the U.S., the system is very similar to the FMVSS No. 225 child restraint anchorage system and therefore, the evaluation developed by ISO is relevant to our work here.
\19\ ``Road vehicles--Methods and criteria for usability evaluation of child restraint systems and their interface with vehicle anchor systems--Part 1: Vehicles and child restraint systems equipped with ISOFIX anchors and attachments,'' (November 2010).
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SAE Guidelines
The Society of Automotive Engineers (SAE) developed a draft SAE recommended practice entitled J2893, ``Guidelines for Implementation of the Child Restraint Anchorage System in Motor Vehicles and Child Restraint Systems.'' \20\ The document provides guidelines for vehicle manufacturers to consider when designing characteristics of vehicle lower and upper (tether) anchorages, and for CRS manufacturers for corresponding features of CRS lower anchorage and tether connectors, so that each product can be made more compatible with the other. SAE developed tools and procedures for evaluating the child restraint anchorage system hardware features in vehicles and on child restraints. The guidelines assess whether the child restraint fixture can attach to the lower anchorages, the force and clearance angles needed to attach to the lower anchorages, the collinearity of the lower anchorages, the marking of the anchorages with the ISO symbol, etc. (Appendix C to this preamble has more information about the SAE guidelines.)
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\20\ The SAE J2893 recommended practice is designated as a ``work-in-progress'' by SAE and has not been finalized.
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NCAP Vehicle-CRS Fit Program
On February 25, 2011, NHTSA published a Federal Register document requesting comment on the agency's plan to establish a new consumer information program, as part of the agency's New Car Assessment Program (NCAP), to improve compatibility between vehicles and child restraint systems and the ease of using the systems. The contemplated program involves vehicle manufacturers voluntarily providing NHTSA information about which CRSs fit in specific vehicle models, and NHTSA, in turn, posting this information on the NCAP Web site for consumers to use when making purchasing decisions. This ``Vehicle-CRS Fit program,'' still under consideration by NHTSA, is described in more detail in Appendix C of this preamble.
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UMTRI's LATCH Usability Study
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Overview of the Study
In 2012, UMTRI published a report entitled, ``LATCH Usability in Vehicles,'' \21\ describing UMTRI's study to identify characteristics of child restraint anchorage systems that make the anchorage system easier to use. The study was conducted in three phases, the objectives of which were to:
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\21\ Klinich et al., supra. Link: http://deepblue.lib.umich.edu/handle/2027.42/90856. The report was sponsored by the Insurance Institute for Highway Safety (IIHS) for developing IIHS's rating of the usability of the child restraint anchorage systems in various vehicles. See IIHS Status Report: Vol. 47 No. 3, April 12, 2012. http://www.iihs.org/sr/default.aspx.
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Survey model year (MY) 2010-2011 vehicles to document characteristics of child restraint anchorage systems in the current vehicle fleet;
Evaluate the proposed ISO 29061-1: 2010 rating system (ratings for both the vehicle and the vehicle-to-child restraint interaction), SAE draft J2893 recommended practice,\22\ and NHTSA's proposed NCAP Vehicle-CRS Fit program to see if outcomes from those programs are associated with quality installations by volunteer subjects; and,
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\22\ The SAE J2893 Version 1--Draft 7 was used for the study. SAE J2893 is still under development.
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Conduct volunteer tests for evaluating the quality of child restraint
Page 3749
installations using vehicle features as the independent measures.
In the first phase of the study, UMTRI measured the child restraint anchorage system hardware and rear seat geometry of 98 top-selling MY 2010 and 2011 vehicles. The vehicles surveyed were those often used for transporting children that also represented a wide range of different child restraint anchorage system hardware. Included in the survey were passenger cars, minivans, sports utility vehicles (SUVs), and pickup trucks. The vehicle measurements were based on procedures in the ISO draft standard and the SAE draft recommended practice, and some additional measures developed for the study, such as the depth of the lower anchorages into the seat bight.
In the second phase, UMTRI calculated the usability scores for each vehicle in the survey using the protocols in ISO 29061-1: 2010,\23\ SAE draft J2893,\24\ and NHTSA's February 2011 NCAP Vehicle-CRS fit program under consideration. ISO ratings of vehicle child restraint anchorage system usability ranged from 41 percent to 78 percent. UMTRI calculated the ISO vehicle/child restraint interaction scores for 20 vehicles, identifying vehicles with a range of vehicle features, and 7 child restraints. ISO vehicle/child restraint interaction scores ranged from 14 percent to 86 percent. Vehicles assessed using the SAE draft recommended practice met between 2 and all 10 of the recommendations. UMTRI evaluated the proposed NHTSA Vehicle-CRS Fit program criteria at one rear seating position (behind the driver's seat) for 12 vehicles and 7 child restraints. The 7 CRSs selected represented a variety of restraint types (rear facing infant seats, convertible seats, combination seats and belt-positioning booster seats) and child restraint anchorage connector features. Of the 24 pairings with 12 vehicles and two rear-facing convertibles, one installation met all of NHTSA's proposed vehicle-CRS fit criteria. Twenty-three (23) installations of the 24 vehicle/infant seat pairings and 45 installations of the 48 vehicle/forward-facing harness CRS pairings met all of the proposed vehicle-CRS fit criteria.
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\23\ ``Road vehicles--Methods and criteria for usability evaluation of child restraint systems and their interface with vehicle anchor systems--Part 1: Vehicles and child restraint systems equipped with ISOFIX anchors and attachments,'' (November 2010).
\24\ The SAE draft recommended practice does not involve a rating system; therefore, UMTRI developed a grade based on how many of the ten guidelines were met.
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In the third phase, UMTRI conducted volunteer testing using 36 subjects, 12 vehicles, and 3 CRS models to see if outcomes from the ISO, SAE and NCAP programs are associated with quality installations (correct installations) of child restraints by the subjects. The subset of 12 vehicles was chosen to provide a variety of child restraint anchorage system hardware characteristics. The 3 CRSs selected in this phase were the Safety First Alpha Omega Elite, Chicco KeyFit, and Graco SnugRide 30.
The study considered a ``correct'' installation to meet the following criteria:
(1) Tight installation--Child restraint did not move more than 1 inch laterally or fore/aft when tested with a moderate pull/push applied at the restraint belt path.
(2) Correct use of lower anchors (if applicable)--Child restraint connectors were fully engaged with the correct vehicle hardware in the correct orientation and the CRS belt webbing connecting to the child restraint anchorages was flat.
(3) Correct use of seat belt (if applicable)--Seat belt was routed through the correct belt path, was not twisted, and was buckled and locked correctly.
(4) Correct use of tether anchorage (if applicable)--Tether hook attached to the correct vehicle hardware in the correct orientation, routed around or under the head restraint as directed by the vehicle manual, and tightened so that there was 10 mm (0.39 in) or less of slack (measured by pinching the slack and measuring the height of the loop).
(5) Correct installation angle--Installation angle was considered correct for rear-facing installations if the restraint indicator was at the correct level, and was considered correct for forward-facing installations if the recline foot was in the forward-facing position.
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Three Seat Characteristics Were Well Correlated With Correct Use
Using a series of mixed-model logistic regression models with various lower anchorage characteristics assessed in the study, UMTRI identified three features of lower anchorages that the volunteer testing showed were well correlated to the correct installation of CRSs. These were: Clearance angle, attachment force, and anchorage depth. UMTRI stated that the odds of correct CRS installation when the child restraint anchorage system met the minimum criterion for clearance angle, attachment force, and lower anchorage depth are 5, 9, and 7 times higher, respectively. UMTRI showed that subjects were 19 times more likely to correctly install the CRS if the vehicle met all three usability criteria than if none of the criteria were met. Using multi-variate regression analysis of the volunteer data, UMTRI found that subjects who correctly used the lower anchorage hardware were 3.3 times more likely to achieve a tight CRS installation than subjects who made errors using the hardware.
A. Clearance Angle
Clearance angle refers to the clearance around a lower anchorage from parts that interfere with the ability to maneuver the CRS lower anchorage connector. The interfering parts can include part of the vehicle seat structure or excessively stiff seat cushion material. Clearance angle is measured by a tool (specified in the SAE draft J2893 recommended practice) that attaches to the lower anchorages. In UMTRI's procedure a vertical force of 66.7 N (15 lb) \25\ is applied to the tool. The angle the tool achieves when that force is applied is the ``clearance angle.''
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\25\ The 6.8 kg (15 lb) force application is the same as that in the SAE J2893 protocol.
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UMTRI determined the performance limits for clearance angle by analyzing the vehicle characteristics and rate of correct installation from the volunteer tests. Based on the user trial data shown in Figure 1 below, UMTRI determined that a clearance angle greater than 54 degrees will increase the likelihood of correct CRS installation.
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GRAPHIC TIFF OMITTED TP23JA15.000
B. Attachment Force
Attachment force refers to the force needed to attach a child restraint's lower anchorage connector to a lower anchorage in a vehicle. UMTRI measured the force required to attach a CRS connector to a vehicle lower anchorage using a force gauge specified in SAE draft J2893. The tool is similar in shape and size to various CRS lower anchorage connectors in the market and to the connectors used on the Child Restraint Fixture and the Static Force Application Device 2 (SFAD2) of FMVSS No. 225. A force gauge in the tool measures the force required to fully engage the CRS connector to a lower anchorage in a vehicle. A stiff seat cushion and/or obstructions surrounding a lower anchorage may increase the attachment force.
Based on the data shown in Figure 2 below, UMTRI determined that an attachment force less than 178 N (40 lb) has a high likelihood of correct CRS installation.
GRAPHIC TIFF OMITTED TP23JA15.001
Page 3751
C. Anchorage Depth
Anchorage depth refers to how deeply the lower anchorages are embedded in a vehicle seat (usually in the seat bight). UMTRI developed a simple tool that easily measures lower anchorage depth. The tool consists of a hook-type CRS connector which is marked every 2 cm.\26\ Lower anchorages that are set deeper into the seat bight are more difficult to locate, identify, and use.
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\26\ UMTRI's tool was marked with different colored electrical tape at 2 cm intervals from the hook. When the tool was hooked onto the lower anchorage of the vehicle, the different colors of tape were exposed. For example, if the lower anchorage were exposed and not recessed in the seat bight at all, all colors in the hook were visible.
GRAPHIC TIFF OMITTED TP23JA15.002
Based on the data shown in Figure 3 above, UMTRI determined that a lower anchorage depth less than 2 cm has a significantly higher rate of correct lower anchorage use than for anchorage depths greater than 2 cm.
UMTRI found that, while clearance angle, attachment force and anchorage depth are important, due to the correlation of the three factors it was not possible to truly identify their separate contributions to prediction of correct CRS installation. UMTRI believed that lower anchorage designs in vehicles should consider all three characteristics to improve rates of correct installation of child restraints.
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UMTRI's Assessment of the ISO, SAE, and NCAP Programs
As part of UMTRI's LATCH Usability study,\27\ UMTRI evaluated vehicles using the draft ISO standard 29061-1:2010 and the derived SAE grade \28\ and found no correlation between usability ratings and correct installation of child restraints in the vehicles in user trials. Results indicated that the ISO vehicle rating, the ISO vehicle/
child restraint interaction rating and the derived SAE grade showed no correlation with rates of the volunteers' correct CRS installation using the lower anchorages (see Figure 4 below).
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\27\ LATCH Usability study, 2012, supra.
\28\ SAE recommend practice is not a rating system; therefore, UMTRI developed a grade based on how many of the ten guidelines were met.
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Page 3752
GRAPHIC TIFF OMITTED TP23JA15.003
UMTRI also evaluated \29\ NHTSA's proposed Vehicle-CRS Fit program criteria using 12 vehicles and 7 child restraints. The user data showed that, among vehicle and child restraint combinations that would be considered compatible under the proposed criteria, only 16 percent were correctly installed by the volunteers.
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\29\ Id.
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NHTSA's Preference Is the UMTRI Approach
NHTSA has evaluated the draft ISO standard and the SAE draft recommended practice and concludes that neither approach would likely improve the usability of child restraint anchorage systems as effectively as the specifications proposed in today's NPRM. The ISO draft standard primarily rates vehicles and does not directly mandate improvements to the usability of child restraint anchorage systems. Further, as discussed above, UMTRI evaluated vehicles using the draft ISO standard 29061-1:2010 and found no correlation between usability ratings and correct installation of child restraints in the vehicles in user trials.
The draft SAE recommended practice J2893 would also be limited because it is only a guideline and does not mandate improved usability. In addition, as noted above, UMTRI evaluated the SAE derived grade from the 10 guidelines and found no correlation between the SAE derived grade and correct installation of child restraints in the vehicles in user trials.\30\
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\30\ Id.
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We believe that the amendments resulting from today's NPRM would be more effective in improving ease of use and the fit of child restraints in vehicles than NHTSA's proposed Vehicle-CRS fit program. The fit program only examines the fit of a small number of specific CRSs selected by the vehicle manufacturer for a specific vehicle model. Today's NPRM would ensure a more universal compatibility between vehicles and child restraints. The Vehicle-CRS fit program would be a voluntary program, so vehicle manufacturers have the option of not providing NHTSA any information about the fit of child restraints in their vehicles. In contrast, the changes resulting from this NPRM would be mandated and universal for all vehicles and all child restraints. The changes made to vehicle seats resulting from this rulemaking would make all child restraints easier to use and fit tightly on vehicle seats. In addition, UMTRI evaluated the NCAP Vehicle-CRS fit proposal and found that volunteers in user trials had a low rate of correctly installing CRSs even when the CRSs were ones meeting the NCAP program's ``fit'' criteria.\31\
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\31\ Id.
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Proposal To Improve Lower Anchorage Usability
This NPRM proposes amendments to improve the three features of lower anchorages--clearance angle, attachment force, and anchorage depth--that were shown to have a positive impact on correct child restraint installations in user trials in UMTRI's LATCH Usability study. NHTSA has reviewed the UMTRI study and tentatively concludes that the features have been reasonably shown to have a significant bearing on correct installations. Also, lower anchorages meeting the proposed requirements for clearance angle, attachment force, and anchorage depth appear feasible.\32\ The UMTRI procedures for measuring clearance angle and attachment force are similar to those in the draft SAE J2893 recommended practice which were developed with industry input and participation.\33\ NHTSA has evaluated the procedures in 10 vehicles (MY 2005-2013) and they appear objective and repeatable. The agency made minor modifications to the measurement tools to enhance their ease of use and to further improve the repeatability of measurements.\34\
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\32\ We are also proposing improved marking of child restraint anchorages and child restraint anchorage connectors to improve the ease of use of child restraint anchorage systems.
\33\ We note that General Motors made the suggestion that NHTSA explore SAE's draft guidelines in its comments at the 2007 LATCH public meeting.
\34\ NHTSA Technical Report, ``Evaluation of LATCH Usability Procedure,'' which is in the docket for this NPRM.
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Comments to NHTSA's 2007 LATCH public meeting on child restraint anchorage system usability included many complaints about the difficulty of attaching lower anchorage connectors to lower anchorages because of interference from surrounding stiff cushions, fabric/leather or buckles. There were also observations about the difficulty of using the lower anchorages because they are often embedded in the
Page 3753
seat bight. It appears that the proposed changes would sufficiently address these problems.
We tentatively conclude that this NPRM would ultimately increase child safety. The NCRUSS \35\ data show that a loose CRS installation comprises one of the five most significant mistakes consumers make in the field when installing child restraints. We wish to reduce loose CRS installations in the field since a loose installation could result in higher excursions of the child and CRS during a crash and a greater risk of injury due to the child's possible contact with vehicle interior structures, as compared to correct (tight) installations. We believe that if child restraint anchorage systems can be made easier to use correctly, then correct (tight) installations will increase.
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\35\ National Child Restraint Use Special Study, supra.
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Clearance Angle
Clearance angle relates to the clearance around a lower anchorage from interfering parts that can make it difficult to maneuver and attach a CRS lower anchorage connector. We believe that a clearance angle requirement would facilitate easier attachment of a CRS lower anchorage connector by preventing interference from surrounding components.
``Clearance angle'' is a criterion included in draft SAE J2893, and the tool we would use to measure the clearance angle was based on a tool developed by the SAE in draft J2893 (Version 1--Draft 7).\36\ The tool, illustrated in Figure 5 below, includes a load cell with a handle to measure the applied vertical force on the tool and a potentiometer to measure the angle with respect to the horizontal achieved by the tool during the force application. In our proposed test procedure, the tool would be attached to a lower anchorage. A vertical force of 66.7 N (15 lb) is applied to the tool. The angle the tool achieves (with respect to the horizontal) when that force is applied is the ``clearance angle.'' We propose to amend FMVSS No. 225 to adopt a clearance angle requirement of not less than 54 degrees, as supported by the findings of the UMTRI LATCH Usability study. The requirement would apply to each lower anchorage in a vehicle.
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\36\ UMTRI used this measurement tool in its LATCH Usability Study and measured the applied vertical force and the resulting clearance angle using a force gauge and an inclinometer, respectively.
GRAPHIC TIFF OMITTED TP23JA15.004
We note that draft SAE J2893 specifies that the clearance angle should be greater than 75 degrees. We have differed from that draft specification because the UMTRI LATCH Usability study has user trial data to show that a clearance angle greater than 54 degrees is sufficient to increase the likelihood of correct CRS installation. We are not aware of similar user data to support the SAE target of 75 degrees.
Our proposed 66.7 N (15 lb) force application is the same as that in the draft SAE J2893 protocol. We believe that the force represents a low force that an adult can easily apply. A NHTSA study to determine the force that able-bodied adults could apply to open emergency exit windows found that this force ranged from 66.7 N (15 lb) to 533.7 N (120 lb) with a mean of 244.6 N (55 lb).\37\
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\37\ Docket No. NHTSA-2007-28793-24.
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Attachment Force
``Attachment force'' refers to the force needed to attach a child restraint lower anchorage connector to a lower anchorage. After considering the UMTRI LATCH Usability study, we propose to amend FMVSS No. 225 to require child restraint anchorage systems to be manufactured such that the attachment force needed to attach an attachment force tool to the lower anchorage must be less than 178 N (40 lb). UMTRI's
Page 3754
volunteer subjects study indicates that an attachment force less than 178 N (40 lb) has a high likelihood of correct CRS installation.
The attachment force tool, illustrated in Figure 6 below, is based on the tool specified in SAE draft J2893 (Version 1 Draft 7) and which was used in the UMTRI LATCH Usability study. The end of the tool is similar in shape and size to various ``push-on'' CRS lower anchorage connectors in the market and to the connectors used on the SFAD2 of FMVSS No. 225. In order to improve the repeatability of the measurements obtained by the tool, the agency modified the tool used in the UMTRI LATCH Usability study as follows. A trigger switch was included to determine when the tool is fully engaged to a lower anchorage in a vehicle. A button load cell in a push handle was added to measure the force needed to fully engage the tool to the anchorage. Finally, a potentiometer was included to measure the approach angle of the tool with respect to the horizontal.
GRAPHIC TIFF OMITTED TP23JA15.005
We note that draft SAE J2893 specifies that the attachment force should be less than 75 N (16.9 lb), which is more stringent than that proposed in this NPRM. We are proposing a 178 N (40 lb) limit because it is supported by the findings of UMTRI's LATCH Usability study showing the correlation of the limit with correct CRS installation. We are not aware of such data supporting the SAE limit under consideration.
There is also a slight difference between the draft SAE J2893 procedure and UMTRI's procedure regarding how the measurement is taken. The SAE draft procedure specifies that, when taking the measurement, the attachment force tool approaches the lower anchorage at an angle near zero degrees (i.e., it is parallel to the seat bottom cushion surface). UMTRI found that it is not possible to attach the tool to the lower anchorages in most vehicles when it is held parallel to the seat bottom cushion. UMTRI modified the SAE protocol for measuring the attachment force such that the force is measured at the angle (from 0 to 45 degrees) to the horizontal producing the lowest force value. In addition to making it possible to attach the tool to the lower anchorages, UMTRI believed that the 0 to 45 degrees range of angles for attaching the measurement tool to the lower anchorages better represents how a parent would attach a CRS lower anchorage connector to the lower anchorages compared to the SAE method. NHTSA tentatively agrees with UMTRI's conclusions and has proposed the 0 to 45 degree range in this NPRM.
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Anchorage Depth
Anchorage depth refers to how deeply the lower anchorages are embedded in the vehicle seat (usually in the seat bight or seat back). UMTRI's LATCH Usability study found that an anchorage depth of less than 2 cm within the seat bight is associated with a significantly higher rate of correct lower anchorage use than anchorage depths greater than or equal to 2 cm. NHTSA proposes a requirement that each lower anchorage must have an anchorage depth of less than 2 cm, as measured by a specially-designed compliance tool (the tool is illustrated in Figure 7, below). The tool incorporates a hook-type CRS connector. The distance 2 cm from the backside of a lower anchorage bar when the connector is attached to a lower anchorage is marked on the tool (as shown in Figure 8, below). In a compliance test, the tool would be attached to a lower anchorage. The 2 cm mark would have to be visible from a vertical longitudinal plane passing through the center of the bar, along a line making an upward 30 degree angle with a horizontal plane, without the technician's manipulating the seat cushions in any way.
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We tentatively conclude that the proposed anchorage depth requirement would make the requirement in S9.2.2(a) of FMVSS No. 225 unnecessary, so we propose deleting S9.2.2(a). S9.2.2(a) specifies that the lower anchorages must be located less than 70 mm (2.75 in) behind the rearmost point at the bottom plane of the CRF while the CRF is pressed rearward against the seat back with a horizontal force of 100 N (22.4 lb). The purpose of S9.2.2(a) is to ensure that the lower anchorages are not deeply recessed into the seat bight. We tentatively conclude that the proposed requirement for anchorage depth takes the place of S9.2.2(a) by ensuring the lower anchorages are not deeply recessed. The proposed 2 cm (0.8 in) limit on anchorage depth would not permit lower anchorages to be as deeply recessed into the vehicle seat as permitted by S9.2.2(a). The UMTRI volunteer study showed that accessibility of the lower anchorages--and correct CRS installation--is better determined using anchorage depth than the current requirement in S9.2.2(a).
On the other hand, we have tentatively determined that S9.2.2(b) continues to be needed and should be retained even if a limit on anchorage depth is adopted. S9.2.2(b) specifies that the lower anchorages must be located more than 120 mm (4.7 in) behind the SgRP.\38\ Its intent is to ensure that the lower anchorages are not so far forward so as to cause discomfort to occupants not in CRSs or pose an unreasonable risk of injury in rear impacts.
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\38\ SgRP (seating reference point) is the unique design H-point as defined in SAE Recommended Practice J1100, ``Motor Vehicle Dimensions,'' revised June1984.
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We believe the requirement in S9.2.2(b) does not conflict with the proposed anchorage depth requirement. UMTRI's survey of 98 MY 2010-2011 vehicles showed that the seat bight of the surveyed vehicles was at least 140 mm (1.5 in) from the estimated SgRP, as shown in Figure 9. (UMTRI's measurement referenced the H-point, which with regard to rear seats that do not move, is at the same location as the SgRP.) The proposed anchorage depth requirement specifies that the anchorage has to be less than 2 cm deep into the seat bight. Lower anchorages can be positioned less than 2 cm deep into the seat bight and still meet S9.2.2(b).
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Estimated Rate of Current Compliance
UMTRI's survey of 98 MY 2010-2011 vehicles \39\ showed that 9 percent met none of the three provisions, 31 percent met one provision, 37 percent met two provisions, and 21 percent met all three provisions for lower anchorages. Ninety percent met the attachment force provision (54 degrees) and 28 percent met the anchorage depth (54 degrees......... 58.0% Have we 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 isn't 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 we improve clarity by adding tables, lists, or diagrams?
What else could we do to make the rule easier to understand?
If you have any responses to these questions, please write to us with your views.
In our proposed regulatory text for FMVSS No. 225, we have removed outdated sections and deleted obsolete language in an effort to make the standard more concise and easier to understand. We also propose to renumber some sections when multiple outdated paragraphs would be deleted, so that the standard would be easier to read. Please let us know if there are other housekeeping measures we could take to improve the plain language of the standard.
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Public Participation
In developing this proposal, we tried to address the concerns of all our stakeholders. Your comments will help us improve this proposed rule. We welcome your views on all aspects of this proposed rule, but request comments on specific issues throughout this document. Your comments will be most effective if you follow the suggestions below:
--Explain your views and reasoning as clearly as possible.
--Provide solid technical and cost data to support your views.
--If you estimate potential costs, explain how you arrived at the estimate.
--Tell us which parts of the proposal you support, as well as those with which you disagree.
--Provide specific examples to illustrate your concerns.
--Offer specific alternatives.
--Refer your comments to specific sections of the proposal, such as the units or page numbers of the preamble, or the regulatory sections.
--Be sure to include the name, date, and docket number with your comments.
Your comments must be written and in English. To ensure that your comments are correctly filed in the docket, please include the docket number of this document in your comments.
Your comments must not be more than 15 pages long (49 CFR 553.21). We established this limit to encourage you to write your primary comments in a concise fashion. However, you may attach necessary additional documents to your comments. There is no limit on the length of the attachments.
Please submit your comments to the docket electronically by logging onto http://www.regulations.gov or by the means given in the ADDRESSES section at the beginning of this document.
Please note that pursuant to the Data Quality Act, in order for substantive data to be relied upon and used by the agency, it must meet the information quality standards set forth in the OMB and DOT Data Quality Act guidelines. Accordingly, we encourage you to consult the guidelines in preparing your comments. OMB's guidelines may be accessed at http://www.whitehouse.gov/omb/fedreg/reproducible.html.
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How do I submit confidential business information?
If you wish to submit any information under a claim of confidentiality, you should submit three copies of your complete submission, including the information you claim to be confidential business information, to the Chief Counsel, NHTSA, at the address given above under FOR FURTHER INFORMATION CONTACT. In addition, you should submit a copy from which you have deleted the claimed confidential business information to the docket. When you send a comment containing information claimed to be confidential business information, you should include a cover letter setting forth the information specified in our confidential business information regulation. (49 CFR part 512.)
Will the agency consider late comments?
We will consider all comments that the docket receives before the close of business on the comment closing date indicated above under DATES. To the extent possible, we will also consider comments that the docket receives after that date. If the docket receives a comment too late for us to consider it in developing a final rule (assuming that one is issued), we will consider that comment as an informal suggestion for future rulemaking action.
How can I read the comments submitted by other people?
You may read the comments received by the docket at the address given above under ADDRESSES. You may also see the comments on the Internet (http://regulations.gov).
Please note that even after the comment closing date, we will continue to file relevant information in the docket as it becomes available. Further, some people may submit late comments. Accordingly, we recommend that you periodically check the docket for new material.
Anyone is able to search the electronic form of all comments received into any of our 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.). You may review DOT's complete Privacy Act Statement in the Federal Register published on April 11, 2000 (Volume 65, Number 70; Pages 19477-78).
List of Subjects in 49 CFR Part 571
Imports, Motor vehicle safety, Motor vehicles, and Tires; Incorporation by Reference.
In consideration of the foregoing, NHTSA proposes to amend 49 CFR part 571 as set forth below.
PART 571--FEDERAL MOTOR VEHICLE SAFETY STANDARDS
0
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The authority citation for Part 571 continues to read as follows:
Authority: 49 U.S.C. 322, 30111, 30115, 30117 and 30166; delegation of authority at 49 CFR 1.95.
0
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Section 571.5 is amended by adding paragraphs (k)(5) through (k)(8), to read as follows:
Sec. 571.5 Matter incorporated by reference.
* * * * *
(k) * * *
(5) Reserved
(6) Drawing Package, ``NHTSA Anchorage Depth Tool,'' dated August 19, 2013, into Sec. 571.225.
(7) Drawing Package, ``NHTSA Attachment Force Tool,'' dated May 22, 2013, into Sec. 571.225.
(8) Drawing Package, ``NHTSA Clearance Angle Tool,'' dated May 21, 2013, into Sec. 571.225.
* * * * *
0
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Section 571.213 is amended by adding S5.6.1.12, revising S5.9(a), S5.9(b) and S5.9(c), and adding Figure 15 and Figure 16 in numerical order, to read as follows:
Sec. 571.213 Child restraint systems.
* * * * *
S5.6 Printed Instructions for Proper Use.
* * * * *
S5.6.1.12 In the case of child restraint systems marked as specified in S5.9 (a) and (b), explain that the markings identify the lower anchorage connectors and the tether anchorage connector, respectively, and that the consumer should look for corresponding marks on the vehicle child restraint anchorage system to attach the appropriate connectors of the child restraint system.
* * * * *
S5.9 Attachment to child restraint anchorage system.
(
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Each add-on child restraint, other than a car bed, harness and belt-positioning seat, shall have components permanently attached that enable the restraint to be securely fastened to the lower anchorages of the child restraint anchorage system specified in Standard No. 225 (Sec. 571.225) and depicted in Drawing Package SAS-100-1000, Standard Seat Belt Assembly with Addendum A or in Drawing Package, ``NHTSA Standard Seat Assembly; FMVSS No. 213, No. NHTSA-213-2003'' (both incorporated by reference, see Sec. 571.5). The connectors must be attached to the add-on child restraint by use of a tool, such as a screwdriver. In the case of rear-facing child restraints with detachable bases, only the base is required to have the connectors. The connectors designed to attach the add-on child restraint to the lower anchorages of the child restraint anchorage system shall be permanently marked with the pictogram in Figure 15. The pictogram is not less than 9 mm in diameter.
(b) In the case of each child restraint system that has components for attaching the system to a tether anchorage, those components shall include a tether hook that conforms to the configuration and geometry specified in Figure 11 of this standard. The tether hook or the tether strap shall be permanently marked with either pictogram shown in Figure 16. If the mark is on the tether strap or on a tag attached to the tether strap, the mark must be located within 25 mm of the tether hardware assembly (which consists of a tether hook and a webbing tightening mechanism designed to tighten or loosen the tether strap).
(c) In the case of each child restraint system that has components, including belt webbing, for attaching to an anchorage of a child restraint anchorage system, the belt webbing shall be adjustable so that the child restraint can be tightly attached to the vehicle. The length of the tether hardware assembly, which consists of a tether hook and a mechanism designed to tighten and loosen the tether strap, shall not exceed 165 mm.
* * * * *
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Notes 1. Drawing not to scale.
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Symbol may be shown in mirror image.
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Color of the symbol is at the option of the manufacturer.
GRAPHIC TIFF OMITTED TP23JA15.017
Notes 1. Drawing not to scale.
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Symbol may be shown in mirror image.
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Color of the symbol is at the option of the manufacturer.
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Either symbol may be marked at the option of the manufacturer.
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Section 571.225 is amended by:
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Revising S4.2;
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Removing S4.3, S4.4 and S4.5, redesignating S4.6 as S4.3 and revising newly redesignated S4.3;
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Removing S5(e);
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Revising S6.1(a), S6.1(b), S6.2, and removing S6.2.1 through S6.2.2.2;
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Revising S6.3 and removing S6.3.1 through S6.3.4.4;
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Revising the first sentence of S8, the introductory text of S8.1, and removing and reserving S8.2;
0
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Removing the introductory text of S9, revising S9.1.1(d) and S9.2.2(a), adding S9.2.4 and S9.2.5, and revising S9.5;
0
-
Revising S11, S12(b) and S12(c), and adding S12(d);
0
-
Removing S13 through S16.4;
0
-
Revising Figures 3, 8 and 9, removing and reserving Figures 10, 11, and 19, and adding Figures 24 through 27.
The revised and added text and figures read as follows:
Sec. 571.225 Child restraint anchorage systems.
* * * * *
S4.2 Vehicles shall be equipped as specified in paragraphs (a) through (c) of this paragraph, except as provided in S5.
(
-
Each vehicle with three or more forward-facing rear designated seating positions shall be equipped as specified in S4.2(a)(1) and (2).
(1) Each vehicle shall be equipped with a child restraint anchorage system conforming to the requirements of S6 and S9 at not fewer than two forward-facing rear designated seating positions. At least one of the child restraint anchorage systems shall be installed at a forward-
facing seating position in the second row in each vehicle that has three or more rows, if such a forward-facing seating position is available in that row.
(2) Each vehicle shall be equipped with a tether anchorage conforming to the requirements of S6 at a third forward-facing rear designated seating position. The tether anchorage of a child restraint anchorage system may count towards the third required tether anchorage. In each vehicle with a forward-facing rear designated seating position other than an outboard designated seating position, at least one tether anchorage (with or without the lower anchorages of a child restraint anchorage system) shall be at such a designated seating position.
(b) Each vehicle with not more than two forward-facing rear designated seating positions shall be equipped with a child restraint anchorage system conforming to the requirements of S6 and S9 at each forward-facing rear designated seating position.
(c) Each vehicle without any forward-facing rear designated seating position shall be equipped with a tether
Page 3777
anchorage conforming to the requirements of S6 at each front forward-
facing passenger seating position.
S4.3 Movable seats. (
-
A vehicle that is equipped with a forward-
facing rear designated seating position that can be moved such that it is capable of being used at either an outboard or non-outboard forward-
facing seating position shall be considered as having a forward-facing non-outboard seating position. Such a movable seat must be equipped with a tether anchorage that meets the requirements of S6 or a child restraint anchorage system that meets the requirements of S6 and S9, if the vehicle does not have another forward-facing non-outboard seating position that is so equipped.
(b) Tether and lower anchorages shall be available for use at all times, except when the seating position for which it is installed is not available for use because the vehicle seat has been removed or converted to an alternate use such as allowing for the carrying of cargo.
* * * * *
S6.1 * * *
(
-
Consist of a rigid bar of any cross section shape that permits the attachment of a tether hook (of a child restraint system) meeting the configuration and geometry specified in Figure 11 of Standard No. 213 (Sec. 571.213);
(b) Be accessible without the need for any tools and without folding the seat back or removing carpet or other vehicle components to access the anchorages. However, the tether anchorage may be covered with a cap, flap or cover, provided that the cap, flap or cover is specifically designed to be opened, moved aside or to otherwise give access to the anchorage and is labeled with the symbol shown in Figure 27 of this standard.
* * * * *
S6.2 Location of the tether anchorage.
(a)(1) Subject to S6.2(b), the part of each tether anchorage to which a tether hook attaches must be located within the shaded zone shown in Figures 3 to 7 of this standard of the designated seating position for which it is installed. The zone is defined with reference to the seating reference point (see Sec. 571.3). (For purposes of the figures, ``H Point'' means seating reference point.) A tether anchorage may be recessed in the seat back, provided that it is not in the strap wrap-around area at the top of the vehicle seat back. For the area under the vehicle seat, the forwardmost edge of the shaded zone is defined by the intersection of the vehicle floor with a plane that is parallel to the torso line reference plane and which passes through the rearmost point of the bottom of the seat at the centerline of the seat, as shown in Figure 3.
(2) The distance of the tether anchorage from a reference point (SB) obtained by the intersection of a plane parallel to the torso line reference plane that passes through the rearmost point of the seat and the strap wrap-around line from the V-point to the tether anchorage, shall be no less than 165 mm as shown in Figure 8 of this standard. The rearmost point of the seat includes the rearmost point of the head restraint, if a head restraint is present. For adjustable head restraints, the rearmost point of the seat is determined with the head restraint positioned at its highest position. For adjustable head restraints, the strap wrap-around line from the V-point to the tether anchorage shall be routed under the head restraint and between the adjustment bars or adjacent to an adjustment bar. In vehicle seating positions with integrated head restraints or with head restraints that do not provide space under the head restraint to route a tether strap, route the strap wrap-around line from the V-point to the tether anchorage over the head restraint. In seating positions without head restraints, route the strap wrap-around line from the V-point to the tether anchorage over the seat back.
(b) In the case of a vehicle that--
(1) Has a user-ready tether anchorage for which no part of the shaded zone shown in Figures 3 to 7 of this standard of the designated seating position for which the anchorage is installed is accessible without removing a seating component of the vehicle; and
(2) Has a tether strap routing device that is--
(i) Not less than 65 mm behind the torso line for that seating position, in the case of a flexible routing device or a deployable routing device, measured horizontally and in a vertical longitudinal plane; or
(ii) Not less than 100 mm behind the torso line for that seating position, in the case of a fixed rigid routing device, measured horizontally and in a vertical longitudinal plane, the part of that anchorage that attaches to a tether hook may, at the manufacturer's option (with said option selected prior to, or at the time of, certification of the vehicle) be located outside that zone.
(iii) The measurement of the location of the flexible or deployable routing device described in S6.2(b)(2)(i) is made with SFAD 2 properly attached to the lower anchorages. A 40 mm wide nylon tether strap is routed through the routing device and attached to the tether anchorage in accordance with the written instructions required by S12 of this standard. The forwardmost contact point between the strap and the routing device must be within the stated limit when the tether strap is flat against the top surface of the SFAD and tensioned to 55 to 65 N. In seating positions without lower anchorages of a child restraint anchorage system, the SFAD 2 is held with its central lateral plane in the central vertical longitudinal plane of the seating position. The adjustable anchorage attaching bars of the SFAD 2 are replaced by spacers that end flush with the back surface of the SFAD 2.
(iv) The distance from the routing device (where the strap has completely cleared the routing device as shown in Figure 9) to the tether anchorage shall be no less than 165 mm.
S6.3 Strength requirements for tether anchorages.
(
-
When tested in accordance with S8, the tether anchorage must not separate completely from the vehicle seat or seat anchorage or the structure of the vehicle.
(b) Provisions for simultaneous and sequential testing. (1) In the case of vehicle seat assemblies equipped with more than one tether anchorage, the force referred to in S6.3 may, at the agency's option, be applied simultaneously to each of those tether anchorages. However, that force may not be applied simultaneously to tether anchorages for any two adjacent seating positions whose midpoints are less than 400 mm apart, as measured in accordance with S6.3(b)(i) and (ii) and Figure 20.
(i) The midpoint of the seating position lies in the vertical longitudinal plane that is equidistant from vertical longitudinal planes through the geometric center of each of the two lower anchorages at the seating position. For those seating positions that do not provide lower anchorages, the midpoint of the seating position lies in the vertical longitudinal plane that passes through the SgRP of the seating position.
(ii) Measure the distance between the vertical longitudinal planes passing through the midpoints of the adjacent seating positions, as measured along a line perpendicular to the planes.
(2) A tether anchorage of a particular child restraint anchorage system will not be tested with the lower anchorages of that anchorage system if one or both of those lower anchorages have been previously tested under this standard.
* * * * *
S8 Test procedures. Each vehicle shall meet the requirements of S6.3
Page 3778
when tested according to the following procedures. * * *
S8.1 Apply the force specified in S6.3 as follows--
* * * * *
S8.2 Reserved
S9. Requirements for the lower anchorages of the child restraint anchorage system.
* * * * *
S9.1.1 * * *
(d) The bars must not be capable of being stowable or foldable.
* * * * *
S9.2 Location of the lower anchorages.
* * * * *
S9.2.2 * * *
(
-
Located such that when the lower anchorage depth tool depicted in Drawing Package, ``NHTSA Lower Anchorage Depth Tool,'' dated June 2014 (incorporated by reference; see Sec. 571.5), is attached to the anchorage bar, the 2 cm mark on the tool is visible from a vertical longitudinal plane passing through the center of the bar, along a line making an upward 30 degree angle with a horizontal plane; and
* * * * *
S9.2.4 The lower anchorages shall be located such that no more than 178 N (40 lb) of force is needed to securely attach the tool, depicted in Drawing Package, ``NHTSA Attachment Force Tool,'' dated June 2014 (incorporated by reference; see Sec. 571.5), to an anchorage bar with the tool positioned in at least one angle from 0 degrees to 45 degrees from the horizontal using the procedure in S11(b) of this standard.
S9.2.5 The lower anchorages shall be located such that the tool depicted in Drawing Package, ``NHTSA Clearance Angle Tool,'' dated June 2014 (incorporated by reference; see Sec. 571.5), measures a clearance angle of at least 54 degrees using the procedure in S11(c) of this standard.
* * * * *
S9.5 Marking and conspicuity requirements.
S9.5.1 Requirements for lower anchorages.
(
-
Above each bar installed pursuant to S4, the vehicle shall be permanently marked with a circle that:
(1) Is not less than 13 mm in diameter;
(2) Contains the pictogram shown in Figure 24 of this standard; and
(3) Is located such that its center is on each seat back between 50 and 100 mm above or on the seat cushion 100 25 mm forward of the intersection of the vertical transverse and horizontal longitudinal planes intersecting at the horizontal centerline of each lower anchorage, as illustrated in Figure 22. The center of the circle must be in the vertical longitudinal plane that passes through the center of the bar (25 mm).
(4) The circle may be on a tag.
(b) The bars may be covered by a removable cap or cover, provided that the cap or cover is permanently marked with the pictogram shown in Figure 24. If the cap or cover is permanently attached to the vehicle, the lower anchorage bars are not required to be separately marked with the pictogram. If the cap or cover is not permanently attached to the vehicle, the lower anchorage bars must also be marked with the circle meeting S9.5.1(a)(1) through (a)(3) of this standard.
S9.5.2 Requirements for tether anchorages.
(
-
For each tether anchorage installed pursuant to S4, there shall be a permanent mark that:
(1) Consists of the pictogram shown in Figure 25 of this standard that is not less than 20 mm in diameter;
(2) The center of the circle in the longitudinal direction must be in the vertical longitudinal plane that passes through the center of the tether anchorage bar (5 mm), as shown in Figure 26 (Front View) of this standard.
(3) The nearest edge of the mark shall be located not more than 25 mm away from the tether anchorage bar as shown in Figure 26 (Side View) of this standard.
(b) The tether anchorage bar may be covered by a cap or cover that is removable without the use of any tool, provided that the cap or cover is permanently labeled with a mark meeting the requirements of S9.5.2(a)(1). The center of the mark on the cap or cover shall be centered at the middle of the tether anchorage bar, as shown in Figure 27 of this standard. If the cap or cover is permanently attached to the vehicle, the tether anchorage is not required to be separately marked. If the cap or cover is not permanently attached to the vehicle, the tether anchorage must also be marked with the circle meeting S9.5.2(a)(1) through S9.5.2(a)(3) of this standard.
* * * * *
S11. Test procedures. Each vehicle shall meet the requirements of this standard when tested according to the following procedures. Where a range of values is specified, the vehicle shall be able to meet the requirements at all points within the range.
(
-
Strength requirements.
(1) Forward force direction. Place SFAD 2 in the vehicle seating position and attach it to the two lower anchorages of the child restraint anchorage system. Do not attach the tether anchorage. A rearward horizontal force of 135 15 N is applied to the center of the lower front crossbar of SFAD 2 to press the device against the seat back as the fore-aft position of the rearward extensions of the SFAD is adjusted to remove any slack or tension. Apply a preload force of 500 N horizontally and in the vertical centerline of the SFAD 2 at point X. Increase the pull force as linearly as practicable to a full force application of 11,000 N in not less than 24 seconds and not more than 30 seconds, and maintain at an 11,000 N level for 1 second.
(2) Lateral force direction. Place SFAD 2 in the vehicle seating position and attach it to the two lower anchorages of the child restraint anchorage system. Do not attach the tether anchorage. A rearward force of 135 15 N is applied to the center of the lower front crossbar of SFAD 2 to press the device against the seat back as the fore-aft position of the rearward extensions of the SFAD is adjusted to remove any slack or tension. Apply a preload force of 500 N horizontal and perpendicular to the longitudinal centerline of the SFAD 2 at point X of the test device. Increase the pull force as linearly as practicable to a full force application of 5,000 N in not less than 24 seconds and not more than 30 seconds, and maintain at a 5,000 N level for 1 second.
(b) Attachment force. The seat back angle, if adjustable, is set at the manufacturer's nominal design seat back angle. Remove any lower anchorage cover if present. To measure attachment force, hold the force attachment tool perpendicularly aligned with the center of the lower anchorage. Position the tool at an angle of 0 to 45 degrees from the horizontal, and push the tool towards the lower anchorage. Measure the force needed to engage the tool to the lower anchorage.
(c) Clearance angle. The seat back angle, if adjustable, is set at the manufacturer's nominal design seat back angle. Remove any lower anchorage cover if present. To measure clearance angle, attach the clearance angle tool to the lower anchorage and apply a vertical force of 67 N (15 lb) to the tool. Measure the angle (with respect to the horizontal) of the tool while the force is being applied.
* * * * *
S12. Written instructions.
* * * * *
(b) In the case of vehicles required to be marked as specified in paragraphs S4.1, S9.5.1 and S9.5.2, explain the
Page 3779
meaning of markings provided to locate the lower anchorages of child restraint anchorage systems and the top tether anchorages;
(c) Include instructions that provide a step-by-step procedure, including diagrams, for properly attaching a child restraint system's tether strap to the tether anchorages; and
(d) Include instructions on how to locate and access the tether anchorage and the lower anchorages.
Figures to Sec. 571.225
* * * * *
GRAPHIC TIFF OMITTED TP23JA15.018
GRAPHIC TIFF OMITTED TP23JA15.019
Notes: SB point is the intersection of the plane parallel to the torso line reference plane that passes through the rearmost point of the vehicle seat, and the strap wrap-around line from the V-point to the tether anchorage.
Page 3780
GRAPHIC TIFF OMITTED TP23JA15.020
* * * * *
GRAPHIC TIFF OMITTED TP23JA15.021
Notes: 1. Drawing not to scale.
-
-
Symbol may be shown in mirror image.
-
Color of the symbol at the option of the manufacturer.
GRAPHIC TIFF OMITTED TP23JA15.022
Page 3781
Notes: 1. Drawing not to scale.
-
Symbol may be shown in mirror image.
-
Color of the symbol at the option of the manufacturer.
GRAPHIC TIFF OMITTED TP23JA15.023
(Tolerance of 5 mm)
GRAPHIC TIFF OMITTED TP23JA15.024
(Tolerance of 10 mm in the Longitudinal and/or Lateral Plane.)
Note: The following Appendices will not appear in the CFR.
Appendix A: Field Studies
Decina Study--2005
Three years after FMVSS No. 225 was fully phased in and child restraints made to meet the corresponding changes in FMVSS No. 213, NHTSA conducted a survey from April to October 2005 to assess the progress made since 2002 and identify the possible needs for additional steps. See Decina et al., ``Child Restraint Use Survey: LATCH Use and Misuse,'' supra.). NHTSA wanted to know whether drivers of vehicles equipped with child restraint anchorage systems were using the systems to secure child restraints to the vehicle seat, and if so, whether they were properly installing the restraints. In the survey, the make/model and the type of restraint installed in each seating position were recorded for each vehicle, and the demographic characteristics and the type of child restraint system were collected for each occupant. In addition, information was gathered about the drivers' knowledge of child restraint anchorage systems, along with their opinions on how easy it was for them to use the systems. The study involved 1,121 children from birth to age 4 in child restraint systems.
Key findings of the survey were:
(
-
Of the child restraints located in a seating position equipped with an upper tether anchor, 55 percent were attached to the vehicle using the upper tether.
(b) Among the 87 percent who placed the CRS at a position equipped with lower anchors, 60 percent used the lower attachments to secure the restraint to the vehicle.
(c) In 13 percent of the vehicles equipped with child restraint anchorage systems in which there was a child restraint, the restraint was placed in a seat position not equipped with lower anchors--instead, the vehicle seat belt was used to secure the restraint to the vehicle.
(d) Sixty-one (61) percent of upper tether nonusers and 55 percent of lower anchorage nonusers cited their lack of knowledge--
not knowing what the anchorages were, that they were available in the vehicle, the importance
Page 3782
of using them, or how to use them properly--as the reason for not using them.
(e) Of those drivers with experience using both lower anchorages and seat belts: (1) 81 percent of upper tether anchorage users and 74 percent of lower anchorage users said upper tether and/or lower anchorages were easy to use; and (2) 75 percent preferred the lower anchorages over seat belts.
(f) Sixty-one (61) percent of child restraints installed with child restraint anchorage systems were securely installed.
All in all, the Decina study found that consumers who have experience with the child restraint anchorage systems like them. Among consumers having knowledge of both lower anchorages and seat belt attachment, 75 percent preferred using lower anchorages. Further, the report found that child restraint anchorage systems are helping to reduce the incorrect installation of child restraints (61 percent of child restraints installed with child restraint anchorage systems were securely installed, as compared to about 40-46 percent of CRSs installed by seat belts securely installed).
However, the report also indicated that proper use of child restraint anchorage systems is not inherently evident. Many drivers do not use the anchorage system because they do not know about it or understand its purpose. There is also some confusion about where the anchorages can be found. In addition, there were differing degrees of difficulty using the anchorages depending on location and configuration of the CRS hardware.
National Child Restraint Use Special Study--2011 Data
The National Child Restraint Use Special Study (NCRUSS) is a large-scale nationally-representative survey that involves both an inspection of the child passenger's restraint system by a CPST and a detailed interview of the driver.\102\ The survey collected information on drivers and their child passengers of ages 0-8 years between June and August 2011. NCRUSS data were collected at 24 primary sampling units (PSUs) across the country. The PSUs were previously established from a separate ongoing data collection effort, the National Automotive Sampling System (NASS). The PSUs are defined geographically, similar to cities or counties. The PSUs were selected to cover urban, rural, and suburban environments and are located in 17 different states.
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\102\ National Child Restraint Use Special Study, DOT HS 811 679, http://www-nrd.nhtsa.dot.gov/Pubs/811679.pdf (Full report pending).
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The survey collected 4,167 observations on children under 9 years of age, of which 268 (weighted percentage = 8.5 percent) were of infant seats with a base, 142 (weighted percentage = 3.6 percent) were of convertible or all-in-one type CRSs installed in rear-facing mode and 1,983 (weighted percentage = 49.6 percent) were of convertible, combination or all-in-one type CRSs installed in forward-facing mode with harness. The remaining observations were of children in other types of restraints including booster seats, seat belts, vests, car beds, etc. The survey also found less than 2 percent of children unrestrained.
For CRSs with internal harnesses, the survey results show that 49 percent of CRSs were installed with lower anchorages, 44 percent were installed with seat belts, and 7 percent with both seat belt and lower anchorages. When the analysis was restricted to only vehicles equipped with child restraint anchorage systems, 61 percent of the CRSs were installed using the lower anchorages and 9 percent with both seat belt and lower anchorages. Decina had found that 55 percent of the harnessed CRSs observed in vehicles with child restraint anchorage systems were attached using the lower anchorages. The NCRUSS study shows a 15 percent increase in the rate of all lower anchorage installations from 2005 to 2011.
As for tether use, for forward-facing CRSs with internal harnesses,\103\ tether use was 71 percent when installed with the lower anchorages and 31 percent when installed with seat belts.
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\103\ Rear-facing seats and booster seats are not typically equipped or used with tether straps in the U.S.
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Safe Kids Worldwide (Safe Kids) Data
In September 2011, Safe Kids published a study based on 79,000 observations from ``car seat check'' events and appointments that took place between October 1, 2009 and September 30, 2010.\104\ Safe Kids developed a standardized checklist that it uses at car seat check events and records how the child and/or child restraint arrived at the event and how the child and/or child restraint left the event. The checklists are then scanned and entered into a database that Safe Kids manages and updates.
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\104\ ``A Look Inside American Family Vehicles 2009-2010,'' Safe Kids USA (http://www.safekids.org/assets/docs/safety-basics/safety-tips-by-risk-area/sk-car-seat-report-2011.pdf).
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The study found that correct installation ranged between 39 to 61 percent for seat belt installations and between 46 to 60 percent for lower anchorage installation. Safe Kids defined correct seat belt installation as one in which the child restraint's manufacturer's instructions were followed and that is in accordance with the Child Passenger Safety Certification Program (CPSCP) \105\ best practices, including seat belt routing, tightness (must not move more than 1 inch side to side or front to back when grasped by the belt path) and having a locked seat belt. Correct lower anchorage installation consisted of using the lower anchorages as instructed in both the CRS and vehicle manuals as well as following the CPSCP best practices including: Using correct hardware, using connectors in the right direction, correct identification of the designated lower anchors in the vehicle and installation tightness.
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\105\ The National Child Passenger Safety Certification Program certifies individuals as CPSTs. NHTSA assists in developing the curriculum of the certification; the National CPS Board oversees the quality and integrity of the training and certification requirements; and Safe Kids Worldwide functions as the certifying body.
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Safe Kids found a 7 percentage point difference in correct use between lower anchorage installations and seat belt installations for infant seats with base, and a 10 percentage point difference in correct use between lower anchorage installations and seat belt installations of forward-facing seats, with lower anchorage installations having the higher rates of correct use. For other rear-facing seats, seat belt installations had a 1 percentage point advantage of correct use compared to installations with lower anchorages.
As for tether use, the study found 59 percent correct tether use in forward-facing CRSs.
We also reviewed Safe Kids sample data from the first quarter of 2012 comprising 17,000 observations. The data showed that 48 percent of CRSs with internal harness were installed with the lower anchorages, 46 percent with the seat belt and 6 percent with both seat belt and lower anchorages in all vehicles (data did not distinguish whether the vehicles were equipped with child restraint anchorage systems). Overall tether usage in forward-facing CRSs with internal harness was only 29 percent. Tether use was 45 percent when the CRS was attached with lower anchorages and 15 percent when the CRS was attached with seat belt.\106\
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\106\ The reduced tether use in the 2012 Safe Kids data compared to NHTSA's NCRUSS study could be attributed to the differences in the two observation samples. The Safe Kids observations are made at seat check stations where caregivers come to seek advice from the CPSTs on correct CRS installation. These caregivers may be novice CRS users or are unsure of the method of CRS installation. Therefore, this convenience sample of observations may be biased towards incorrect or non-ideal CRS installations. On the other hand, the NCRUSS observations are from a stratified sample representative of CRS use and installation in the United States and are designed to be bias-free.
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Appendix B: Summary of 2007 Public Meeting
In response to the 2006 report by Decina et al., supra, NHTSA held a public meeting on February 8, 2007 to bring together child restraint and vehicle manufacturers, retailers, technicians, researchers, and consumer groups to discuss ways to improve child passenger safety through improving CRS designs and increasing the proper use of child restraint systems.\107\ Questions were posed to the participants of the public meeting regarding child restraint anchorage system design, ease of use, and approaches to educating the public about proper use.\108\ NHTSA solicited comments on design considerations for tether anchorage locations, lower anchorage accessibility, system availability in the center seating position, and design of child restraint hooks and connectors. With respect to child restraint anchorage system ease of use, NHTSA was interested in the development of more user-friendly connectors, consumer information on vehicle child restraint anchorage system hardware, and CRS and vehicle compatibility. As for consumer education, NHTSA wanted to know what types of
Page 3783
questions consumers had and how to spread child restraint anchorage system awareness.
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\107\ 72 FR 3103, January 24, 2007, notice of public meeting, request for comments.
\108\ Id.
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The agency received comments from vehicle manufacturers, child passenger advocacy groups, researchers, and individuals. While the comments and suggestions received on child restraint anchorage system were varied, the main themes were as follows:
Lower Anchorages: There was support for improving the conspicuity, accessibility, and ease of use of the lower anchorages without compromising comfort to adult occupants, and standardizing the location of the lower anchorages.
Markings of Anchorages: There were suggestions for requiring all anchorages to be marked by the International Standards Organization (ISO) symbol regardless of anchorage visibility, requiring similar markings for the CRS connectors, and considering color coded labels to clarify the anchorage locations for each DSP.
Child restraint anchorage system for rear center seat: There was support for requiring a child restraint anchorage system in all rear center seats, or developing provisions to use the inboard anchorages of the outboard seating position for the center seat while taking into consideration the possibility of misuse when two CRSs are connected to the same anchorage.
Child restraint anchorage system for 3rd row seating positions: Some suggested requiring additional child restraint anchorage system-equipped DSPs for vehicles with three or more rows.
Consumer education: There were suggestions on using consistent terminology in education material and developing up-to-date uniform curriculum, requiring that a DVD or Web site be included in the instruction manual for CRS installation, emphasizing the use of tethers and explicitly encouraging the use of child restraint anchorage systems rather than simply listing it as an option for installation.
A more detailed summary of comments received from the 2007 public meeting regarding child restraint anchorage system ease of use is set forth below.
Lower Anchorage Usability
Advocates for Highway Safety (Advocates), the American Academy of Pediatrics (AAP), and Safe Ride News (SRN) suggested that lower anchors be located farther forward in the seat bight to increase visibility and make installation and removal easier.
Advocates suggested that lower anchors need to be just as accessible as seat belts. Otherwise, parents will continue to install child restraints with seat belts over the LATCH system.
SafetyBelt Safe USA (SBS) said that it is more difficult to remove restraints from recessed anchors.
SRN called for further research into whether hidden lower anchors are a deterrent to using the LATCH system.
Honda was concerned that moving anchors out of the seat bight would cause occupant discomfort and would necessitate the redesign of some seats. Instead, Honda suggested that there might be a different way to clear space around anchors without moving them forward.
General Motors (GM) suggested that NHTSA evaluate SAE's lower anchor access design guidelines.
Conspicuity and Identification of Anchors (Marking of Anchors)
GM, Advocates, AAP, SRN, and the University of Virginia (UVA) recommended that all tethers and lower anchors, regardless of visibility, be conspicuously marked. GM suggested that the industry develop a voluntary agreement to label all tethers with an anchor symbol and all lower anchors with a baby dot symbol. The connectors on the child restraint would also be labeled with the same symbols for easy matching.
AAP, SRN, and several CPSTs recommended that sets of lower anchors be labeled or color coded to clarify which seating position they serve, especially in the case of overlapping lower anchors.
Tether Anchorage Specifications, Location, and Accessibility
GM and SRN supported further restriction of the tether zone to eliminate problems associated with tethers located underneath seats and to make tether anchors more accessible. It was also noted that further limitation of this zone would also ensure that child restraints with shorter tether straps would be able to reach the tether anchor.
Honda recommended that NHTSA gain full understanding of the optimal tether locations for different vehicle configurations before further restricting the zone. It noted that tether anchor locations in many vehicles are limited due to strength requirements.
Honda recommended that NHTSA consider the comfort, ingress/egress and excursion space of other occupants when determining acceptable tether locations.
AAP recommended that vehicle manufacturers provide tether locations forward of seats for use with rear-facing seats.
Anchorage System for Center Seat
GM and Honda recommended that provisions be developed for the use of inboard lower anchors from outboard seats to create a center seat full LATCH system. However, Honda noted that it does not currently encourage this type of use since these anchors often are not set 280 mm (11 in) apart, as specified in FMVSS No. 225. Honda, SBS, GM and SRN recommended that NHTSA research the range of safe distances between lower anchors in order to determine the feasibility of this type of use.
AAP was concerned that if consumers are given the option of attaching a child seat to the inboard anchors of outboard seats, they will then attach two child restraints to the same lower anchor when installing adjacent restraints. One CPST recommended a solution of making lower anchors smaller in size to discourage parents from attempting to attach multiple restraints to a single anchor.
Advocates, UVA, and three CPSTs suggested that all center seats be equipped with a full LATCH system.
AAP, Advocates, and two CPSTs agreed that conflicting information is currently given to parents regarding the center seat position being the ``safest'' and the availability of full LATCH systems in the center seat. The commenters suggested that this discrepancy should be reconciled to avoid confusion when installing seats in the center position. Possible solutions suggested include a dedicated set of center seat anchors or built-in center seat child restraints.
Full LATCH for 3rd Row Seat Positions
SRN and SBS suggested that the minimum number of full LATCH systems for a vehicle with three rows be increased. They thought that providing more LATCH systems per vehicle could reduce the number of incidences where multiple restraints are attached to a single anchor.
Consumer Education
AAP advised against inconsistent vocabulary, recommending that NHTSA clarify certain terminology, such as ``LATCH'' referring to the entire system rather than just the lower anchorages.
Cohort 22 and UVA suggested that either a DVD or a Web site link be included in instruction manuals to provide users an installation video that would better clarify what a ``tight fit'' means.
Honda suggested making a tether strap routing procedure available to consumers.
AAP believed that the importance of the tether in the LATCH system must be emphasized to consumers. SRN recommended that manuals explicitly encourage the use of LATCH rather than simply listing it as an option for installation.
GM, Honda, SRN, and a CPST emphasized the importance of consumer education and public awareness of LATCH. SRN suggested that an up-to-date and uniform curriculum of information be developed so that the information given to parents and caregivers is consistent from all sources (e.g. hospitals, police, and doctors).
Appendix C: Other Usability Efforts
International Organization for Standardization (ISO)
ISO, a worldwide voluntary federation of ISO member bodies, is drafting an approach toward improving the usability of a child restraint anchorage system called ``ISOFIX.'' \109\ (ISO 29061-
1:2010, Road vehicles--Methods and criteria for usability evaluation of child restraint systems and their interface with vehicle anchorage systems--Part 1: Vehicles and child restraint systems equipped with ISOFIX anchorages and attachments.) The draft ISO approach uses a rating system and criteria to provide child restraint and vehicle manufacturers with a tool for the assessment of the usability of ISOFIX systems. ISO also provides consumers (parents and caregivers) with information to assist them in selecting a CRS and vehicle with ISOFIX systems that are easy to use, with the aim that the information will result in more correct installations.
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\109\ ISOFIX is a system, mostly used in Europe, for the connection of child restraint systems to vehicles. The system has two vehicle rigid anchorages, two corresponding rigid attachments on the child restraint system and a means to limit the pitch rotation of the child restraint system.
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The ISO approach evaluates and rates the usability of the CRS's ISOFIX features, the
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vehicle's ISOFIX system, and the interaction between the two. While the ISOFIX system is not used in the U.S., the system is very similar to the FMVSS No. 225 child restraint anchorage system and therefore, the evaluation developed by ISO can mostly be applied to our systems. The vehicle assessment with this methodology include the instructions on how to identify the number and location of ISOFIX-equipped seating positions, the visibility and labeling of the ISOFIX anchorages, the proximity of hardware equipment to the tether anchorage that could be mistakenly used to attach the tether, and interference between lower anchorages and seat belt equipment. The interaction between the vehicle and CRS is evaluated using the criteria listed in Table 2.
The ISOFIX systems of the CRS, vehicle, and the interaction between the two are rated using a weighted scoring system with the weights corresponding to the importance of each criterion for improving ease of use and correct installation. Each criterion is rated on a 3 point scale where a rating of good, average, and poor are given a score of 3, 1, and 0, respectively. The importance of each criterion is also rated on a 3 point scale ranging from 1 to 3, with 3 being the most important.
Table 2--Criteria Items in Form 3 of ISO 29061-1:2010 With Scoring
System
CRS and vehicle interaction
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Score Good,
average and Importance
poor (3/1/0 (A,B,C = 3/2/1
points points
respectively) respectively)
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3.1.1 Using the CRS, are the prepared
vehicle ISOFIX anchorages accessible
during the connecting process (i.e.,
is it possible to use them?)
3.1.2 ISOFIX anchorages accessible
during installation process?
3.1.3 Is there clear feedback that the
CRS is correctly attached to the
ISOFIX anchorages?
3.1.4 Can the ISOFIX attachments be
tightened after the initial
connection to the lower anchorages?
3.1.5 Flexible attachments only: When
properly installed, no hidden slack
can exist in lower attachments.
3.1.6 Is the child harness fully
operable when ISOFIX is installed
properly?
3.2.1 Actions required to attach the
tether to the tether anchorage?
3.2.2 Can tether be tightened
properly?
3.2.3 Is there clear feedback that the
child restraint system is correctly
attached to the tether anchorage?
3.3.1 Actions required to adjust the
primary anti-rotational device to the
correct position (e.g., a support leg
in a rearward installation)?
3.3.2 Actions required to operate any
secondary anti-rotational device(s)
e.g., a rebound bar, or rebound
tether(s), in a rearward
installation?
3.4.1 CRS and base preparation: CRS
Base and CRS shell ready for
installation?
3.4.2 Actions required to attach the
CRS shell to base?
3.4.3 Is there a clear feedback of
correct locking of the CRS to the
base?
3.4.4 Actions required to detach CRS
from base?
3.5.1 Ease of releasing tension of
tether?
3.5.2 Actions required to detach and
store the tether strap after tension
has been released?
3.5.3 Ease of releasing tension of
flexible CRS attachments?
3.5.4 Actions required to remove and
store the primary anti-rotational
device?
3.5.5 Actions required to remove and
store any secondary anti-rotational
device(s)?
3.5.6 Actions required to detach the
attachments from the ISOFIX
anchorages?
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Society of Automotive Engineers (SAE) Recommended Practice (Draft)
A draft SAE recommended practice entitled J2893,\110\ ``Guidelines for Implementation of the Child Restraint Anchorage System in Motor Vehicles and Child Restraint Systems,'' developed by SAE's Child Restraint Systems Standards Committee, provides guidelines to vehicle manufacturers for certain characteristics of vehicle lower and upper (tether) anchorages, and to CRS manufacturers for corresponding features of CRS lower anchorage and tether connectors, so that each of their products can be made more compatible with the other. SAE developed tools and procedures for evaluating the child restraint anchorage system hardware features in vehicles and child restraints. The eleven guidelines include the following:
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\110\ The SAE J2893 Version 1-Draft 7 was used for the UMTRI study. Any mention of the SAE J2893 recommendations throughout this document will refer to this draft version of the guidelines which are still under development.
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Can the child restraint fixture attach to the lower anchors?
Is the force to attach lower anchors less than 75 Newton (N) (16.9 pound (lb))?
Is the clearance angle as measured with a specified angle measurement tool greater than 75 degrees?
When resting unattached on the vehicle seat, is the lateral angle of the child restraint fixture less than 5 degrees?
When installed on the lower anchors, is the pitch angle of the child restraint between 5 and 20 degrees?
Does a specified collinearity tool attach to the lower anchors?
Does a specified angle measurement tool contact any rigid structure around the lower anchors?
When installed, is the distance from the Z-point on the child restraint fixture to the seat cushion less than 51 mm?
Are tether anchors marked with the ISO Symbol?
Are lower anchors marked with the ISO symbol?
If a tether router is present, does it accommodate a specified tether hardware assembly clearance tool?
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NCAP's Pending Vehicle-CRS Fit Program
On February 25, 2011,\111\ NHTSA published a request for comments on the agency's plan to adopt a new consumer information program that would be part of the agency's New Car Assessment Program (NCAP). The intent of the program is to make it easier for consumers to obtain a CRS that fits well in their vehicle. (76 FR 10637, February 25, 2011, Docket No NHTSA-2010-0062.)
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\111\ 76 FR 10637, February 25, 2011 request for comment, Docket No NHTSA-2010-0062. NHTSA is in the process of considering the next steps for the program.
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NHTSA proposed the Vehicle-CRS Fit program to be a voluntary program, in which NHTSA would make available to consumers information provided by vehicle manufacturers as to the specific CRSs that fit in specific vehicle models. NHTSA developed a set of criteria to define what constitutes an acceptable ``fit'' under the program. The plan was for vehicle manufacturers to use the criteria to assess the fit of child restraints in their vehicles and determine which CRSs can be identified as fitting the vehicle. The vehicle manufacturers
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would provide this information to NHTSA, and NHTSA in turn would post this information on the agency's NCAP Web site, www.safercar.gov.
The agency proposed that part of the assessment of an adequate fit would evaluate the interface of the CRS with the child restraint anchorage system. The agency proposed that the following criteria be included in evaluating the fit of a CRS in a vehicle:
Whether the tether of the CRS can be attached to the tether anchorage;
Whether the tether can be properly tightened once attached to the tether anchorage;
Whether the lower anchorage connectors on the CRS can be properly attached to the vehicle's lower anchorages;
Whether the lower anchorage connectors on the CRS can be tightened (if necessary) once connected to the lower anchorages;
Whether the seat belt buckles for adjacent seating positions are available for use by other passengers after the CRS is installed in the vehicle using the lower anchorages of a child restraint anchorage system; and
Whether the upper weight limit of the CRS is less than the upper weight limit specified for the vehicle's lower anchorages.
NHTSA envisioned that consumers would use the information on the safecar.gov Web site to see the CRSs that the vehicle manufacturer has said will fit a particular vehicle. As part of the program, NHTSA would conduct spot-checks of the manufacturers' information to verify that the identified CRSs do meet the fit criteria of the program.
Issued on: January 5, 2015.
R. Ryan Posten,
Associate Administrator for Rulemaking.
FR Doc. 2015-00162 Filed 1-22-15; 8:45 am
BILLING CODE 4910-59-P
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