Phew–-more time to respond to NHTSA on compatibility

This morning I heard from Sandy Sinclair at NHTSA that we will have an additional month to respond to the request for comments mentioned in my blog from last week (see below).  So we will have until April 26th to get our thoughts in on the Vehicle-CRS Fit Program.

Deborah

In the thick of it -- Again!

There's never a dull moment around here. 

Although I'm out of the conference loop right now -- and sad to miss seeing a lot of friends at Lifesavers -- I'm working on a response to NHTSA's latest program plan.  This project, the Vehicle-CRS Fit Program, is an attempt to improve compatibility for installation of CRs in vehicles.  If you are interested in how the agency proposes to have vehicle manufacturers evaluate CRs to find ones that are compatible with their models, take a look at http://www.regulations.gov:

     Docket NHTSA–2010–00062 

     Consumer Information Program for Child Restraint Systems

The response time allowed was only a month, so comments are due by March 28, right in the midst of the Lifesavers Conference.  That means I'm scrambling to fully understand the document right now ... and I urge interested folks to take the time to comment. 

The proposal is particularly interesting for the description of the findings of the pilot evaluation.  The various problems that cropped up all sound very familiar, such as head restraints interfering with tether anchorage and lower anchors raised so high above the seat bight that LATCH straps cannot be tightened completely.  The evaluation forms proposed are based on these observations and will rely also on the explicit instructions on installation in the vehicle and CR guides.

The general plan, which will be entirely voluntary for vehicle manufacturers, would have them list a minimum of three current CR models of each type (RF, FF, BPB) that will fit well in various vehicle models, starting with the 2012 model year.  CRs within three price ranges must be listed and three CR manufacturers should be represented within each type of CR covered.  However, I wonder whether new, small manufacturers will easily be able break into such a system, which could have effects on the diversity of the market.

I can see a lot of value in using the evaluation form in planning new designs for both CRs and vehicles. It could serve as an expanded update of the Society of Automotive Engineers "J1819" voluntary agreement for seat belt configurations that improved CR-seat belt compatibility in the 1990s.

For vehicle models during the next few years, however, I can imagine that the limitation to three or more CR models per type could limit listings too much.  It would mean that, if only one CR will fit, the vehicle could not be listed and consumers would not have any guidance.  In addition, if no CR is found that fits in a vehicle, it would not be listed—but the vehicle manufacturer would not have to try all the possibilities and there would be no way of knowing whether it had or not. 

I also personally disagree with the assumption that the default tether anchor weight limit should be set at 40 pounds for vehicles whose manuals that do not list a weight. In such cases, the compatibility of the tether and tether anchor for high-weight harness CRs would not be incorporated into the evaluation.

There will be much more in our response to the agency.  For now, please consider taking a look at the plan yourself and letting the agency know what YOU think.

Deborah Davis Stewart