Federal Motor Vehicle Safety Standards; Child Restraint Systems; Tether Anchorages for Child Restraint Systems; Child Restraint Anchorage System

SUMMARY: This document proposes to require that motor vehicles and add-

on child restraints be equipped with a means independent of vehicle

safety belts for securing the child restraints to vehicle seats. The

adoption of the proposal would avoid problems of incompatibility

between child restraints and vehicle safety belts and increase the

correct installation of child restraints. This proposal would reduce

allowable head excursion, which would have the effect of requiring

child restraints to be equipped with an upper tether strap, and would

require vehicles to have two factory-installed, user-ready anchor

points for attaching the tether. It would also require vehicles to have

two rear vehicle seating positions equipped with a specialized lower

anchorage system, and require child restraints to be equipped with

means of attaching to that system.

The proposal for the lower anchorages is based on two of the

systems discussed at an October 1996 NHTSA public workshop concerning

alternative systems for providing dedicated means for attaching child

restraints to vehicle seats. Almost all of the different systems

evaluated and discussed at the workshop appeared comparable in terms of

demonstrated safety and public acceptance. However, one system appeared

to be less expensive and have the advantage of using hardware familiar

to consumers. This system is the ``uniform child restraint anchorages

(UCRA) system,'' referred to as such by a consortium of manufacturing

groups in a June 28, 1996 petition for rulemaking to the agency. The

International Standards Organization (ISO) Working Group on child

restraint systems recognized in a November 1996 meeting the need for

this system to permit improvements in the short term.

The other notable dedicated system is one supported by European

members of the ISO Working Group. This alternative, which is completing

development, uses a two-prong nonflexible item of hardware on the child

restraint to mate with two fixed anchorages at the bottom of the back

of the vehicle seat without the use of any belt webbing. Under today's

proposal, either of these systems could meet the proposed requirement

for a dedicated lower anchorage system, but manufacturers installing

the fixed anchorage system would also have to ensure that the system is

compatible with the UCRA system, so that UCRA-type child restraints can

be used in all vehicles equipped with either anchorage system.

To the extent possible, this proposal also harmonizes with the

actions of other regulatory agencies around the world. This proposal

seeks to harmonize with Canadian and Australian regulations by

requiring an upper tether anchorage and with prospective European

regulations by allowing a non-UCRA anchorage system.

This proposal pertains to the compatibility of child restraints

with motor vehicle seats, and not that of child restraints with

aircraft seats. The Federal Aviation Administration and NHTSA are

developing possible requirements and procedures for improving the

compatibility of child restraints in aircraft. If the agencies decide

that rulemaking is warranted on that issue, such rulemaking will be

commenced as a separate action.

DATES: Comments on this notice must be received by the agency no later

than May 21, 1997.

ADDRESSES: Comments should refer to the docket number and notice number

and be submitted in writing to NHTSA's Docket Section at the following

address: Until March 10, 1997: Room 6130, After March 10, 1997: Room

5109, 400 Seventh Street, S.W., Washington, D.C., 20590. Telephone:

(202) 366-5267. Docket hours are 9:30 a.m. to 4:00 p.m. Monday through

Friday.

FOR FURTHER INFORMATION CONTACT: At NHTSA, for nonlegal issues: Dr.

George Mouchahoir, Office of Vehicle Safety Standards (telephone 202-

366-4919). For legal issues: Deirdre Fujita, Office of the Chief

Counsel (202-366-2992). Both can be reached at the National Highway

Traffic Safety Administration, 400 Seventh St., S.W., Washington, D.C.,

20590.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Statement of the Problem

II. Improved Anchorage System

a. Standardized System

b. Competing Concepts

III. Public Workshop

a. Summary of Presentations

1. ISOFIX 4-point Rigid System

2. CANFIX 2-Point Rigid System

3. UCRA Soft Anchor System

4. European Industry Hybrid System

5. Car Seat Only System

b. Clinics

c. Cost

d. Tether

e. Agreement on Differences

f. Future Work

IV. Subsequent Developments

a. Albuquerque, N.M.

b. Additional Information

c. Petition on Scheme D (Hybrid System)

V. Evaluation of Concepts

a. Top Tether

b. Lower Anchorage Points

1. Improve Compatibility

2. Safety Performance

3. Consumer Acceptability

4. Costs and Burdens

5. Harmonization

6. Leadtime and Availability

7. Proposed System

c. Discussion of Alternatives

1. SAE Recommended Practice J1819

2. Lockability

3. Car Seat Only System

VI. Proposal for New Vehicle Standard

a. Highlights of Proposal

b. Applicability

c. Seating Positions

d. Construction

1. Lower anchorages

2. Upper anchorages

e. Performance

f. Instructions

VII. Proposal for Amendments to Child Seat Standard

a. Applicability

b. Required Components

c. Dynamic Performance

d. Instructions and Labeling

VIII. Proposed Effective Date

IX. Rulemaking Analyses and Notices

a. Executive Order 12866 (Regulatory Planning and Review) and

DOT Regulatory Policies and Procedures

b. Regulatory Flexibility Act

c. Executive Order 12612 (Federalism)

d. Unfunded Mandates Reform Act

e. National Environmental Policy Act

f. Executive Order 12778 (Civil Justice Reform)

X. Comments

I. Statement of the Problem

The effective use of child restraints is important because of the

number of children killed and injured in vehicle accidents. Annually,

about 600 children less than five years of age are killed and over

70,000 are injured as occupants in motor vehicle crashes. Data from the

National Center for Health Statistics (for 1991) indicates that motor

vehicle

[[Page 7859]]

occupant fatalities were the third leading cause of death for this age

group (NCHS, 1993).

While child seats are highly effective in reducing the likelihood

of death or serious injury in motor vehicle crashes, the degree of

their effectiveness depends on how they are installed. NHTSA estimates

that the potential effectiveness of child seats, when correctly used,

is 71 percent. However, it is estimated that imperfect securing of

children in the child seats and/or of the child seats in vehicles

reduce that effectiveness from the potential 71 percent to an actual 59

percent. That is, as a group, child seats (those that were used

correctly together with those that were misused) have an actual

effectiveness of 59 percent.

Child restraint effectiveness is reduced by limitations imposed by

vehicle belt design, and by belt anchorage locations. Child seats are

generally designed to attach to a vehicle by means of the vehicle's lap

belt system. While child seats provide high levels of safety when

correctly attached to a standard vehicle seat assembly with only a lap

belt, in most vehicles different types of seat belt systems exist in

addition to or in lieu of a lap belt. Among the different types are

belt systems with a locking latchplate, a non-locking (sliding)

latchplate, a reversible lockable retractor, an emergency-locking

retractor, or an automatic seat belt. Some of these belt systems, such

as those equipped with a locking retractor, are able to hold a child

seat without use of attachment accessories, but a parent must correctly

manipulate the system, such as by pulling the belt completely out of

the retractor and then feeding excess slack back into it after buckling

in the child seat. Some belt systems can be used to secure a child seat

only when used with an accessory item that impedes movement of the belt

or child seat in a crash, such as a locking clip or supplemental strap.

Some belt systems, such as an automatic seat belt, may not be

compatible with a child seat at all.

The agency recognizes the difficulty of designing vehicle seat

belts to restrain both child restraint systems and a wide range of

weights and sizes of individuals. Some vehicle seats have the seat belt

anchorage positioned far forward of the vehicle ``seat bight'' (the

intersection of the seat cushion and the seat back). Forward-mounted

anchor points may better protect an adult using the vehicle seat belt

system by drawing the vehicle belt low across the pelvis where the body

can best tolerate the forces in a crash. However, when used with a

child seat, the belt anchor is so far forward of the seat bight that

the vehicle belts cannot initially provide any resistance to the

forward, longitudinal motion of a child seat reacting to a decelerating

crash pulse. The child restraint moves forward until it is sufficiently

far forward of the belt anchorages that the belt finally can resist the

forward, longitudinal motion of the child seat. This forward movement

of the child restraint can result in excessive forward movement of the

child's head, and a greater likelihood of head impact.

Child restraint effectiveness is also reduced by incorrect securing

of children and child restraints due to the complexities of adapting

vehicle belts to those purposes and due to failure to follow

instructions. To properly install child restraints, devices such as

lockable retractors, locking clips, and supplemental belts must be used

in many cases. Unfortunately, it appears that many people installing a

child seat are either unfamiliar with the use of these devices (which

generally are not used or needed except in conjunction with a child

restraint), not able to understand or unwilling to read instructions

concerning their proper use, or unable to surmise from their design how

to use them correctly. People generally are frustrated about the

difficulty in installing child seats correctly in vehicle seats. Recent

user trials conducted in the U.S.1 and Canada 2 found that

virtually all the people surveyed in the studies expressed high levels

of dissatisfaction with conventional means of attaching child

restraints in vehicles. NHTSA receives an average of about 50 calls a

day to its Consumer Complaint Hotline from people asking for step-by-

step guidance in installing their child seats. When an article appears

in the media about incompatibility problems between child restraints

and vehicle seats, those calls typically increase to over 500 a day.

All of these callers express frustration at the difficulty of

installing a child seat securely, and all urge NHTSA to make the

installation easier. NHTSA understands that child restraint

manufacturers also receive a large number of similar calls and asks

that commenters verify this.

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\1\ ``An Evaluation of the Usability of Two Types of Universal

Child Restraint Seat Attachment Systems,'' General Motors

Corporation, 1996.

\2\ ``The ICBC Child Restraint User Trials,'' Rona Kinetics and

Associates Ltd. Report R96-04, prepared for the Insurance

Corporation of British Columbia, December 1996.

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A four-state study done for NHTSA in 1996 examined people who use

child restraint systems and found that approximately 80 percent of the

persons made at least one significant error in using the systems.

(``Patterns of Misuse of Child Safety Seats,'' DOT HS 808 440, January

1996.) Observed misuse due to a locking clip being incorrectly used or

not used when necessary was 72 percent, and misuse due to the vehicle

safety belt incorrectly used with a child seat (unbuckled,

disconnected, misrouted, or untightened) or used with a child too small

to fit the belts was 17 percent.

II. Improved Anchorage System

a. Standardized System

The difficulty with using vehicle safety belts to attach child

restraints arises from the fact that those belts are primarily designed

to restrain and protect larger and older vehicle occupants. Given the

inability to change vehicle belt design and anchorage location because

of this purpose, the agency is seeking a means of securing a child

restraint that is independent of the safety belt. For a number of

years, industry groups and governmental bodies have explored improving

the securement of a child seat on a vehicle seat. The child seat and

motor vehicle industry is unanimous that the means of attaching child

restraints to the vehicle interior should be easier, more efficient and

without incompatibility problems. Further, all agree that there should

be a universal and independent means of attaching child restraints.

That is, there should be means that are either identical or at least

compatible, regardless of vehicle make or model, and that are dedicated

solely for use in securing child restraints. The importance of

universality across vehicle make or model also compels a universal

requirement for the anchorage system, and would mitigate against having

the system be available on an optional basis.

The concept of a universal and independent anchorage system was

embraced by the ``Blue Ribbon Panel on Child Restraint and Vehicle

Compatibility,'' which NHTSA Administrator Ricardo Martinez, M.D.,

formed in February 1995 to improve the use and attachment of child

safety seats.3 In its May 30, 1995 report recommending ways to

improve the compatibility between child restraints

[[Page 7860]]

and vehicle seating positions, the panel recommended that there be an

entirely separate anchorage system for child restraint installation,

given the complex variables affecting the proper installation of child

restraints using existing vehicle safety belts.

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\3\ The Blue Ribbon Panel included child safety advocates and

representatives of the motor vehicle, child safety seat and seat

belt industries, including representatives from Ford, Chrysler,

General Motors, Mercedes Benz, Volkswagen, BMW, Volvo, Nissan,

Toyota, Honda, Century, Gerry, Fisher-Price, Cosco, Evenflo,

Kolcraft, Riley Hospital, DANA Foundation, American Academy of

Pediatrics, University of Michigan, TRW, and Takata, and advocates

Stephanie Tombrello and Annemarie Shelness.

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While there is universal agreement on the need to improve the ease

with which child seats can be properly secured to vehicle seats and

concurrence with the merits of a separate anchorage system, there is

disagreement on which system is best. It is assumed that a

``universal'' anchorage system must standardize the means of

attachment, so that it and it alone would be required for all affected

vehicles, and it alone would be the system with which child seats would

be required to be compatible. This is needed to ensure universal

compatibility between child seats and vehicles.

b. Competing Concepts

In 1990, the ISO began work on a universal child seat anchorage

system (``ISOFIX''). The ISOFIX concept originated as a 4-point rigid

system, where four sturdy braces are mounted on the bottom of a child

restraint. Each brace has a latch at its end. Two of the latches

connect, through holes at the vehicle seat bight, to a metal bar in the

seat frame. The other two latches, at the bottom braces, connect to a

bar below the vehicle seat cushion. The ISOFIX system is supported by

Volvo, as well as others.

Other concepts for universal anchorage systems have developed as

alternatives to the 4-point ISO system, many in response to perceived

problems with the ISOFIX system, such as ISOFIX being too rigid, too

susceptible to false latching, too bulky, unreasonably expensive, and

too heavy.

Transport Canada developed the CANFIX system, which consists of two

rigid rear anchorages at the seat bight (rather than the four points of

ISOFIX), plus an upper tether. This system envisions all vehicles to be

equipped with upper tether anchorage locations. CANFIX is supported by

Australia, which refers to the system as CAUSFIX. At this time, neither

Canada nor Australia requires the CANFIX or CAUSFIX but both are

interested in pursuing such a requirement in the near-term. It is

noted, however, that Transport Canada has stated that in lieu of rigid

lower anchorage points, it could support soft anchorages such as those

of the ``UCRA'' system described below, in addition to an upper tether.

General Motors (GM) helped develop a ``uniform child restraint

anchorage (UCRA)'' system consisting of two lower anchorages near the

bight line and an upper tether anchorage. The lower anchorages have

small latches that are compatible with easy-to-use buckles (as well as

tether hooks) that would be installed on the child seat. The top tether

anchorage would have a buckle or tether hook that is compatible with a

tether and latch or hook on the child seat.

GM joined with thirteen other vehicle and child restraint

manufacturers in petitioning NHTSA to require the UCRA system on

vehicles and componentry compatible with the anchor system on child

seats. The joint petitioners are: the American Automobile Manufacturers

Association (AAMA), which includes General Motors, Chrysler, and Ford;

five companies of the Association of International Automobile

Manufacturers (AIAM) (Honda, Isuzu, Nissan, Subaru, and Toyota); the

Juvenile Products Manufacturer's Association (JPMA), which includes

child restraint manufacturers Century, Evenflo, Fisher-Price, Gerry and

Kolcraft; and Indiana Mills and Manufacturing, a supplier of belt

systems and hardware.

As another alternative to the ISOFIX 4-point rigid system, several

European ISO manufacturer members are currently developing a hybrid

system. The system consists of two lower anchorage points located in

the seat bight and an upper tether anchorage point located behind the

vehicle seat back. A child restraint system could be attached to the

two lower anchorage points by means of either a buckle (such as the

UCRA buckle) or the ISOFIX connector. The object of this option is to

achieve worldwide compatibility between the UCRA and ISOFIX types of

connectors.

The four systems described above are the four options, known as

``Schemes'' A through D, that the ISO has been considering for the past

year. The four-point rigid anchor system (ISOFIX) is known as Scheme A;

the two-point rigid anchor and rigid attachment, plus tether, is Scheme

B; the two-point flexible anchor and flexible attachment, plus tether,

is Scheme C; and the two-point rigid or semi-rigid anchor and flexible

attachment is Scheme D.

Another approach for a universal anchorage system was advanced by

Cosco, a child restraint manufacturer. Cosco suggested in a July 1,

1996 petition for rulemaking to NHTSA that vehicle manufacturers alone

should be responsible for improving compatibility between child seats

and vehicle seats and the ease of installation of child seats. Cosco

believed that vehicles should provide a dedicated Type I lap belt for

child seats, at or rear of the vehicle seat bight. Cosco calls its

system the ``Car Seat Only (CSO)'' system. Cosco envisions that the CSO

system would require no changes in the design and manufacture of child

restraints.

III. Public Workshop

The relative merit of each of the systems was discussed at a public

workshop NHTSA held on October 16 and 17, 1996 in Washington, D.C.

Attending were about 100 persons from the U.S., Canada, Europe, Japan

and Australia, representing governments and manufacturers of motor

vehicles and child restraints, as well child safety advocates.4

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4 A transcript of the meeting has been placed in NHTSA Docket

No. 96-095, Notice 01, and is available from Neal R. Gross, Court

Reporters and Transcribers, 1323 Rhode Island Avenue, N.W.,

Washington, D.C., 20005 (telephone 202-234-4433).

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NHTSA held this two-day meeting to discuss the various alternatives

of universal child restraint anchorage systems that are being

considered by the agency, safety advocates, and automotive and child

safety organizations, such as the Society of Automotive Engineers (SAE)

and the ISO. The five options described above were presented and

discussed as to design characteristics, safety performance, public

acceptance and economic considerations. The meeting focused on bringing

to discussion the characteristics of the various alternatives and not

necessarily on reaching a consensus on a system. Participants had the

opportunity to experiment with the UCRA and hybrid systems in actual

vehicles that were provided by their respective manufacturers.

a. Summary of Presentations

The following discussion summarizes the remarks of each presenter.

1. ISOFIX 4-point Rigid Systems

Thomas Turbell (Sweden), presenting on Scheme A (ISOFIX), reviewed

the ISO work of the last six years on the 4-point system. He said that

the first ideas on an anchorage system envisioned a fixation point in

the vehicle where forward-facing child seats and rear-facing seats

could be installed. The ISOFIX type 1 system (two rigid points), the

ISOFIX Type 2 system (``DELTAFIX,'' two rigid points and one point in

the front) were compared in an early user trial with the conventional

Swedish child restraint system (installation by the seatbelt and by two

lower tethers attached to the seat frame). Eighty percent of the users

installed the

[[Page 7861]]

ISOFIX type 1 system correctly the first time, 60 percent the DELTAFIX,

and only 30 percent the conventional system. Eighty-nine percent of the

subjects indicated that they wanted the new ISOFIX type 1 system.

Ninety percent were willing to pay a 50 percent increase over a normal

price of a child seat at that time.

Work on the system continued in subsequent meetings of the ISO

group in Stockholm in 1993, and Munich, where a list of features

considered essential for the system was developed. For example,

``misuse should be almost impossible, the cushion of the car seat

should have no influence on the system, and * * * the performance

should be better than the present systems.'' A ``UNIFIX'' proposed by

the UK was later changed to the UNIFIX-2 four-point, and in 1993 in San

Antonio, the ISO group decided that this was the system to develop. In

1993, the group had its first draft ISO standard on the system, and in

1994 it had a sixth draft completed.

In London in 1995, the ISO group split the draft standard into

three parts because there were problems with certain aspects of it. The

Blue Ribbon Panel indicated a positive regard for the ISOFIX system,

and the group received a resolution from the European Parliament

pushing them to introduce the ISOFIX as soon as possible.

In San Diego in 1995, General Motors presented its ideas on the

UCRA and the Blue Ribbon Panel modified its earlier support for ISOFIX.

In subsequent meetings in Cologne and London in 1996, GM presented its

findings on its user clinic, and the Hybrid system was presented. Since

then, a consumer clinic has been conducted on the different ISO schemes

and a working group meeting has been held in Albuquerque.

After reviewing the history of the development of the ISOFIX, Mr.

Turbell noted concerns to consider. He believed that the anchorage

system should be unrestricted by design patents. ``[Patents] will

probably stop [an internationally] standardized system.'' He noted a

concern about small cars being able to fit anchorage systems in a small

rear seat, stating ``[W]e can't let the available space in the smallest

rear seat decide the size of the child restraints.'' He also stated his

belief that rigid systems might have an advantage over other systems

with regard to the ease with which an air bag switch-off device can be

incorporated.

2. CANFIX 2-Point Rigid System

France Legault (Transport Canada), presenting Scheme B (CANFIX)

(the system is also known as CAUSFIX in Australia), explained that

Canada varied from the four-point ISOFIX system because of Canada's

high regard for tethers on child seats and tether anchorages in

vehicles. Canada requires anchorages in passenger cars, and will soon

introduce a regulation extending the requirement to trucks,

multipurpose passenger vehicles, and sport utility vehicles.

Ms. Legault stated that CANFIX has one flexible top tether anchored

to the body of the vehicle, and two lower rigid points based on the

ISOFIX system. CANFIX has the possibility to include improved tether

installation with better adjustability, e.g., in a reel or ratchet

mechanism. It also has the possibility of a tether interlock, which

would prevent the entire system from being installed if one of the

points is not attached, and the possibility of an air bag switch-off.

She said that before CANFIX was presented to the ISO group in 1995,

Canada conducted sled testing and found that performance of the system

was slightly improved over a conventional type of child restraint

system. In that work, Canada also was able to design and build a device

to test anchorages in a vehicle by pulling on them.

Canada's position on a universal child restraint anchorage system

is that while it has sponsored the two-point rigid system, Canada is

also open to the idea of soft anchors at the bottom ``depending on

usability and cost. * * *'' However, Canada definitely supports a

tether. Ms. Legault indicated that Canada will retain its head

excursion and chest acceleration criteria, which have the effect of

requiring a tether, because of the perceived safety benefits of a

tether. Canada will be improving its tether regulation to require

factory installation of the actual hardware for the anchorage.

Currently, Canada requires only a hole or a threaded hole, and the

consumer has to obtain and install the bolt and latchplate.

Canada believes harmonization is an important consideration in

developing a universal child restraint anchorage system. Cost is

important, and well as useability. Ms. Legault said that a positive

engagement feature (e.g., a click or other indication on an engaged

attachment) would be important for usability. She is concerned about a

``transition period,'' where new and old vehicles and child seats could

be intermixed. New child restraints equipped with components for an

anchorage system must be capable of use with older vehicles lacking a

system. Ms. Legault said that testing with a CANFIX prototype showed

that, in about 85 percent of its vehicles (lacking receptors for the

rigid points), the prongs would go in between the seat cushion and seat

back, so that the seat belt could still be used to attach the child

seat.

Canada is in the process of testing the CANFIX and several

conventional restraints to make sure that the tether will provide

additional protection, not just when it is properly used but also when

it is used with varying amounts of slack. Canada will be testing high-

mounted tethers and low-mounted tethers. Early test results show that a

tether improves performance in head and chest acceleration and head

excursion, even if the tether is loose. A tether also reduces neck

forces and moments.

Canada conducted surveys to determine the use rate of tethers. In a

1992 survey of owners of vehicles that provided no tether anchorage,

about 25 percent installed the anchorage and used it. Of vehicles that

had standard anchorages, tether use doubled. In addition, new data from

the Province of Quebec show that its tether use increased from 47

percent to 65 percent after vehicles became equipped with a tether

anchor, even when motorists had to take the extra step of installing

the tether anchorage hardware.

3. UCRA Soft Anchor System

David Campbell (Century Products), Kazuhiko Miyadara (Toyota), and

Jack Havelin (GM), presented Scheme C (UCRA) and the petition for

rulemaking on the UCRA. Mr. Campbell stated that the key objectives of

its work on a uniform child restraint anchorage system are ``to find a

single world-wide system, to address the issue of compatibility and

misuse, while improving dynamic performance of current restraints.'' He

stated that the system should be independent of the adult seat belt

system so that manufacturers can have the flexibility to optimize the

performance of the anchorage system for child restraints and allow the

adult seat belt system to be optimized for the other occupants in the

vehicle. Mr. Campbell stated that child restraint manufacturers believe

that the UCRA system is the best system because the buckle and latch

plate system is intuitive:

They are the type of systems that are currently available in

vehicles * * *. Secondly, it will minimize misuse. You won't have

the routing issues that we have through current child restraints

today with the vehicle lap belts because they are attached and you

know how to use it.

The UCRA also is designed so that current child restraints can be

easily adapted to use it. This could be done by

[[Page 7862]]

means of a special belt provided by restraint manufacturers. The belt

would have buckles on both ends to use with the UCRA latchplates, and

would route through the current belt path used today.

Mr. Campbell said that the manufacturing costs of the UCRA are

lower than those for some of the other systems. There also is less

added weight. He agreed with most of NHTSA's estimates about the weight

increases of the various systems, but believed the UCRA would add only

about 1 to 1.6 pounds (lb), rather than NHTSA's estimate of 4.5 lb. He

stated that it would take less leadtime to begin implementing a UCRA

requirement as opposed to the alternative systems, because the UCRA

uses ``existing technology--known systems, known belts, known buckles,

known latch plates.'' Expanding on the cost issue, the presenter stated

that current child restraints cost and sell at retail between $35.00

and $90.00 in the U.S.:

Our market price is very sensitive, and one of the objectives we

have is to increase the usage rate and not have a negative effect on

the current usage rate. Soft anchors are predicted to add something

in the order of magnitude of $20.00 to the cost of a child

restraint. The Canadian CANFIX, the estimates were about $55.00 at

retail, and for the ISOFIX it was $95.00. * * * Car seat loaner

programs could be affected by this.

Mr. Campbell also stated that the UCRA systems meets Standard 213's

performance criteria without attaching the tether. Tethered, it meets

Canada's requirements. He stated that use of the tether does

significantly reduce head and knee excursions, but there is some trade

off in chest accelerations and HIC values, and the use of the tether in

a higher position can help reduce that HIC.

Mr. Miyadara discussed past and current work evaluating usability,

safety and cost issues for a two-point rigid system, a two-point soft

system and current child restraint systems.

A past study evaluated usability in a customer preference clinic of

current, past and future users. No significant difference was found

between the two-point hard and the two-point soft system. Safety was

assessed in dynamic testing. Some differences in HIC and chest G values

were found, but the actual effect that those differences could have on

a child occupant were unknown. The presenter expected, though, that

safety could be somewhat improved with regard to chest Gs. The

presenter said that one of Toyota's biggest concerns with both a two-

point rigid and a two-point soft system is with potential ``loose fit''

of a child restraint on a vehicle anchorage system.

A study of vehicle and child seat cost impacts indicated that a

two-point soft system should be much more acceptable to the customer.

Mr. Miyadara discussed current work on addressing the ``loose fit''

issue. Toyota has been jointly developing a device that could be used

with a soft system to avoid the problem of consumers installing a child

seat so that its fit is too loose. Toyota is evaluating a strap type

device with belt adjuster, strap type with A-lock, lever-type and

ratchet type. Toyota believes that it can work out the loose fit issue

for a soft system in the near future.

Toyota's future work includes a customer preference clinic on the

Schemes A through C systems, and dynamic testing.

Mr. Miyadara concluded by stating that Toyota's goals in joining in

the AAMA et al. petition is to achieve international harmonization and

provide increased safety to children by eliminating or decreasing

misuse and improving crash performance, at a cost acceptable to the

consumer. Further, to address the problems of incompatibility as soon

as possible, the system should be implemented quickly. Mr. Miyadara

said Toyota does not believe there is any reason to select the two-

point rigid system over the two-point soft system. He also suggested

that NHTSA consider conducting a customer preference clinic of its own.

Mr. Havelin addressed what he believed to be confusion about GM's

position on a universal anchorage system. He said that GM supports an

internationally harmonized requirement. Mr. Havelin stated that GM

believes that an anchorage system should, foremost, increase child

restraint use rates (citing the statistic that three out of four of the

fatally injured children in the U.S. under the age of five are not

using a child restraint), and secondly, reduce the potential for misuse

and improve crash protection. GM suggested that NHTSA ``establish the

template'' for international harmonization by issuing an NPRM based on

three principles. ``First, what does our common customer want, that is,

the child seat manufacturer's customer as well as the vehicle

manufacturer's customer. We think the results of customer clinics need

to be tempered to some degree by sound benefit/cost analysis * * * And

finally, that template should be based on valid science. * * * [S]ome

[consumer clinics and cost analyses] are better than others and we need

to be focused on which ones are valid and which ones are not.''

Mr. Havelin said that GM believes consumers prefer the UCRA system

because the dual straps on the child seats use familiar anchorage

hardware, and provide an intuitive, secure installation. Also, the

tether is obvious and provides a secure anchorage. All three of the

strap anchors give a positive indication when correctly attached. He

said that other reasons the UCRA is preferred is that the child seat

would be light and compact, and without any threatening surfaces (e.g.,

rigid prongs) associated with it. GM believes that the UCRA is within

the acceptable cost range for consumers.

The presenter also highlighted other perceived benefits of the

UCRA, such as that it need not be tethered to meet Standard 213's

performance requirements, can be retrofitted into existing vehicles,

incorporates what GM considers to be ``fully developed and field-proven

hardware, and can be implemented faster than the other attachment

systems.''

4. European Industry Hybrid System

Klaus Werkmeister (Germany), presenting Scheme D, provided some

historical background on the development of a universal child restraint

anchorage system. He believed that interest in a worldwide universal

system started in the late 1980's to address a high rate of severe

accidents where children were killed or injured. Experts determined

that the real problem with those accidents was not the severity of the

crash, but the considerable misuse rate of child seats due to the wrong

adaptation of seat belts.

In preparing for an April 1996 meeting in Cologne of the ISO

Working Group of Child Restraint Systems, German vehicle manufacturers

met to identify criteria they believed were important for an anchorage

system. They developed a list of 12 properties. First, there should be

no top tether, due to concerns about its non-use. Second, the system

must have two lower symmetrical anchorage points, because unacceptable

performance may result from an unsymmetrical configuration. Third, due

to the configuration and dimensions of interior vehicle compartments,

especially of smaller cars, there must be a 250 mm to 280 mm lateral

spacing between the latch points. Fourth, the latch points must have a

degree of stability to ensure that excursion limits are not exceeded.

Fifth, the child restraint must be able to attach through a one-hand

operation, to ensure that the restraint can be easily installed.

[[Page 7863]]

Sixth, there must be a means to prevent attaching the child restraint

on one side only. Seventh, the user must be able to tension the child

restraint with one hand. Eighth, there must be no reduction of seat

comfort for adult passengers. Ninth, the locking device that attaches

the child seat to the vehicle system must be attached to the child

restraint, not the vehicle, to limit overall cost impacts. Tenth, to

avoid design restrictions, the locking device need not be required to

be a pushpad buckle. Eleventh, to ensure that a child restraint does

not have excessive webbing or ratcheting devices, the length of the

adjustment system used to tension the system should not exceed 200 mm.

Lastly, the dimensions of the latch points on the vehicle should be as

specified in Scheme A.

The presenter said that dynamic testing of the four-point rigid and

the soft anchor system showed a reduction in safety performance when

the systems are not properly tightened. Also, a non-symmetrical

configuration resulted in very high head acceleration.

Mr. Werkmeister said that the Scheme D system incorporates ideas

from both rigid and soft anchor systems. The system calls for defining

a field around the ISOFIX fixture, which might include an area behind

the seat bight (where hard anchors could be located), or an area in

front of the seat bight (where semi-rigid anchors could be). A

connector would be used to attach the child seat to the anchorage on

the vehicle. At the option of the child restraint manufacturer, the

connector could be attached to a piece of webbing (such as in the UCRA

system), or could be built into the child seat (as in the ISOFIX rigid

systems). The presenter estimates that the cost of the connector system

would be about $12 for the vehicle and $9 to $15 for the child seat.

The presenter expressed concerns about use rates for a top tether,

believing that use rates will be far less than Canada's 65 percent. He

also discussed concerns about the width between anchorage points and a

symmetrical configuration of the child restraint. He emphasized the

need for design flexibility in an anchorage system. He believed

manufacturers should be provided maximum design flexibility to meet

performance requirements and market demands, and believed that Scheme D

best provides this.

5. Car Seat Only System

John Reynolds and Carol Dingledy (Cosco), presented the ``Car Seat

Only (CSO)'' system. Mr. Reynolds stated that Cosco looked at three

critical issues when evaluating universal anchorage systems. First,

Cosco looked at performance and determined that a system must not

reduce the safety performance of existing child restraints. Second,

Cosco looked at ``implementation,'' or the transition phase between the

existing and new systems, the primary problem being the mix of new car

seats with old cars, and old car seats with new cars. Third, Cosco

looked at how the systems could affect the cost of child restraints,

and in turn, overall use rates. Mr. Reynolds stated that after

evaluating the systems under these criteria, Cosco decided to develop

its CSO system. Cosco believed that because the system is a simple lap

belt, it would have the least negative impact in terms of

implementation and transition. Further, the CSO system would have the

lowest cost to the car seat user, since the cost to the restraint

manufacturer is virtually none.

Ms. Dingledy elaborated on Cosco's concerns with implementation

time and cost. She said that adopting a system other than the CSO will

require considerable research on the part of child seat manufacturers

to determine if seats comply. She said that, given the variety of car

seats that must be tested (e.g., infant-only, convertible, forward- and

rear-facing) and the different types of vehicle seats, just researching

a new system prior to rulemaking will take at least many months, if not

a year or so. She also indicated that research is needed to determine

whether a rigid system might place excessive forces on a child's neck,

particularly a young child who has less developed neck muscles. She was

also concerned that the actual implementation of competing systems

would require long leadtimes to implement (possibly two to five years

development time, plus 10 years production time), as well as a great

deal of public education. The presenter stated that this is in contrast

to the CSO, which can be implemented much more quickly and which

requires little education. Ms. Dingledy said that international

harmonization of an anchorage system does not appear to be realistic in

the near term.

The presenter discussed cost concerns at length. She said that a

system that significantly increases the price of car seats will

decrease the number of new seats purchased at retail, possibly

resulting in (1) more used child seats being purchased or (2) more

children being incorrectly restrained in seats they have outgrown or by

adult belts when they are too small for the belts. She believes

consumers in the U.S. will resist purchasing car seats that retail

between $100 and $200, and that even a $20 increase would slash sales

dramatically. She indicated that the average price of a convertible

restraint is $63, but about one quarter of the car seats purchased cost

$50 or less; less than 5 percent cost $100 or more. She believes that

perhaps 10 percent of persons purchasing car seats would be unable to

purchase a seat if prices increase dramatically. She emphasized a

concern about the impacts of cost increases on loaner programs.

Ms. Dingledy estimated that a 10 percent decrease in child seat use

rates would result in approximately 40 additional child fatalities

annually. She also said that about three million car seats are sold

each year to retail stores and loan programs. The presenter cautioned

that a 10 percent reduction in the number of seats sold means 300,000

children per year riding without a new car seat, which translates into

1.2 million additional children riding unrestrained.

Ms. Dingledy stated that questions arising about the CSO system

concerning the possibility that adults may mistakenly use the CSO belts

are unwarranted. She said that an adult would prefer a lap/shoulder

belt to a lap only belt due to the superior performance and comfort of

a Type II belt. She also said that the CSO belt could be installed at a

location that makes it inaccessible for use with an adult, and could be

prominently labeled or color contrasted to distinguish it from an adult

belt system.

At the conclusion of her remarks, Ms. Dingledy introduced Frank

Rumpleton (appearing on behalf of the Juvenile Products Manufacturers

Association) (``JPMA''), who presented the views of the North American

car seat manufacturers. He said that the number one priority of these

manufacturers is to increase the usage and more importantly the proper

use of child restraint systems. In addition, they wish to ensure that

the changes made to child seats are simple, intuitive and easy for the

caregivers to use. They also support worldwide harmonization.

Underlying all these priorities, however, is the belief that

initiatives must be cost effective, because of a direct correlation

between cost and use rates. He said that every dollar of cost at least

doubles at the retail shelf. He suggested that the cost of an anchorage

system could be better absorbed on the vehicle side than on the child

restraint side.

The presenter said that JPMA categorically rejects the four-point

ISOFIX system and the two-point CANFIX or CAUSFIX rigid system, because

of cost. He said that JPMA supports soft anchor systems, which includes

the UCRA, CSO and Scheme D.

[[Page 7864]]

JPMA hoped that all parties attending the workshop would focus on the

soft systems as a starting point and focus on the similarities and the

positive aspects of each of these proposals, to develop a solution that

maximizes the potential use of child restraints and minimizes the cost

to the ultimate consumer.

b. Clinics

Separate presentations were made on the public acceptance and

support of the development of a universal anchorage system. The

Insurance Corporation of British Columbia (ICBC) along with Rona

Kinetics reported on the findings of its clinic on usability of various

alternatives. The study surveyed 76 subjects in Vancouver, Canada

representing a cross section of age, sex, and experienced/unexperienced

groups. General Motors presented the findings of a February 1996,

clinic that was conducted in Troy, Michigan with a sample of about 400

subjects. Toyota also presented a customer preference study on various

types of soft and rigid anchor systems that was conducted in Japan on

rigid and soft systems. Finally, a study was recently initiated in the

UK and a progress report on its findings of an initial small number of

subjects surveyed was presented.

Generally, the findings of these clinics were in agreement on two

major issues: 1) all subjects surveyed seem to prefer a universal

anchorage system over the current child restraints and 2) no

significant difference in consumer acceptance was detectable when

comparing between a rigid and soft anchorage system.

c. Cost

The participants agreed that the cost of the rigid options is much

higher than the soft anchorage system, with added costs to the child

restraint system of about $100 for the 4-point ISOFIX, $60 for the

CANFIX and $20 for the UCRA soft anchorage system. Cosco, whose

alternative does not incur additional costs to current child

restraints, raised important concerns regarding the potential negative

effects of high increases to the retail price of current child

restraints. Concerns over families not being able to afford the

increase and over loaner programs with fixed budgets for purchasing and

providing free child seats to low income families were discussed. The

issue of cost increases was in conflict with European countries

expectations, according to the attendants from Sweden who indicated

that these added costs do not have such implications as expected in the

U.S. market.

d. Tether

Other discussions addressed specific issues pertinent to the

development of universal child restraint anchorage systems. One major

issue that was discussed pertained to the upper tether. A

representative from the Insurance Institute for Highway Safety

presented an overview of the experiences and possible reasons for non-

use of the upper tether in the US during the 1980s. On the other hand,

a participant from Australia reported that the use of the upper tether

in Australia is about 98%. Transport Canada also reported substantial

increases in use of the tether in Canada. These experiences seem to

indicate that the high usage of upper tether stems from the fact that

the tether anchor points are provided on the vehicle and are visible to

and easily accessible for use by consumers. There appeared to be an

agreement among participants that a child restraint with an upper

tether provides better protection to the child during a crash.

e. Agreement on Differences

In the interactive exchange among attendees during the course of

the workshop, several important points relating to development of a

universal child seat anchorage system emerged. The following key views

were expressed:

User clinics indicate that consumers are overwhelmingly

unhappy with the manner with which current child seats are attached to

vehicle seats and wish to see improvement.

The various systems evaluated in consumer trials (ISOFIX,

schemes A through C) do not differ much in terms of safety performance

(assuming proper installation) and public acceptance.

Schemes B, C and D (CANFIX, UCRA and the Hybrid) are

virtually variations of the same system, except for the hardware used

to connect the child seat to the vehicle. CANFIX has specified a rigid

anchor and rigid connectors on the child seat. UCRA specifies a buckle

and latchplate system; the buckle would be on a piece of webbing

attached to the child restraint and the latchplate would be on a semi-

rigid stalk at the vehicle seat bight. The Hybrid system would specify

a 6 mm bar (e.g., a D ring) that could connect to a child seat either

in front of or behind the vehicle seat bight. The UCRA system differs

from the Hybrid system only with regard to the connector piece that

fastens the child restraint to the vehicle.

Purchasers of child restraints in the U.S. are very

sensitive to price. Sixty-four percent of the car seats sold in the

U.S. sell for less than $60. Consumers in this country are unwilling to

pay the $300 it costs on average for a child seat in Sweden.

The European manufacturers generally still prefer a rigid

system, while U.S. manufacturers oppose it. Canada has indicated a

willingness to move from a rigid two-point plus tether (Scheme B) to a

soft two-point plus tether system.

Scheme D (the Hybrid system) has potential in

accommodating both rigid and soft systems. It would provide the

greatest design flexibility, in that it would specify minimum elements

of the vehicle anchor (e.g., a 6 mm bar) and a location that could

connect to a child seat either in front of or behind the vehicle seat

bight. It would provide vehicle manufacturers the option of supporting

the anchor rigidly or semi-rigidly. Child restraint manufacturers could

choose any means to attach to the anchor. A child seat could have a

telescopic or a rigid device, or a soft attachment (piece of webbing),

so long as the child seat can attach to the anchor.

Each system has strengths but also possible weaknesses.

Questions were raised about the cost, weight and development time

needed for a rigid system, the slack that could be introduced into the

belts of a soft system and the suitability of a soft system with fold-

over seats, the need for anchors to be visible to consumers in a Hybrid

system, the possibility of slack and misrouted belts with the CSO

system, and the actual use of a top tether in tethered systems.

The various systems under consideration are unencumbered

by patents of any kind. Britax (a European child restraint

manufacturer), when asked about a certain patent application, expressly

declared that it holds no patents or applications for patent or other

claims that would hinder third parties from making ISOFIX equipped

vehicles or child restraints using rigid or semi-rigid anchorages.

f. Future Work

Manufacturers of motor vehicles and child restraints extensively

explored the differences between the UCRA and European hybrid systems

with an agreement to further develop this option to harmonize between

the European vehicle manufacturers and Britax and the US and Japanese

child restraint/vehicle manufacturers. These participants expressed

that future efforts would be made to elaborate on progress of this

development at a November 7 and 8, 1996, ISO Working Group on child

safety meeting in Albuquerque,

[[Page 7865]]

New Mexico and future meetings of the Group.

IV. Subsequent Developments

a. Albuquerque, New Mexico

During the November 7 and 8, 1996 meeting of the ISO Working Group

on Child Restraint Systems (ISO/TC 22/SC 12/WG 1), the Group voted on a

proposition containing two resolutions on the specifications for the

anchorage of a universal child restraint anchorage system. The first

resolution recognized the need to allow two anchorage systems: one

based on two-prong nonflexible hardware (a system that is under

development), and another based on flexible UCRA-type hardware (a

system that is available today). A second resolution opposed an upper

tether anchor in motor vehicles.

Following the Albuquerque meeting, the Secretariat of the ISO

Working Group opposed the proposition--which was intended to advise

different governments on how to treat the use of ISOFIX with and

without a top tether--on the basis that it goes beyond the mandate of

the Working Group. A re-voting of an amended resolution was conducted

by correspondence with the delegations of country members, and was due

back to the Secretariat on December 6, 1996. The voting on this

resolution was to select between: i) specifying a top tether anchorage

in vehicles; ii) not specifying the tether; or, iii) either of these

options. It was also agreed that two reports--one for the rigid and one

for the rigid/semi rigid options--will be prepared by members of the

Working Group to describe and specify these systems.

The result of the re-voting was a resolution to produce two draft

standards for universal child restraint attachment interfaces. One

draft standard would cover an attachment system comprising the UCRA-

type attachments on the lower points. The other standard would cover

the rigid anchorage system. The standards would not include

specifications for an upper tether anchorage. (The results of the re-

voting and copies of the rough drafts of the two reports were placed on

December 13, 1996 in Docket No. 96-095, Notice 01 for the readers'

review.)

b. Additional Information

On November 21, 1996, some of the UCRA petitioners provided the

agency with additional information supporting their petition. NHTSA

representatives met with representatives from General Motors, Century

Products, Indiana Mills and the Lear Corporation, at the request of the

latter, to discuss the resolutions of the ISO Working Group meeting in

Albuquerque. (A December 13, 1996 memorandum describing this meeting

and attaching the handouts is entry number 16 in Docket 96-95, Notice

1.) The petitioners emphasized that the North American child restraint

manufacturers strongly favor the UCRA system with an upper tether and

have doubts that a determination can be made at this time that the

rigid system would be a long term solution. They also presented the

findings of an evaluation that Indiana Mills performed in response to a

NHTSA call for harmonization during the public workshop. (The agency

had requested that hardware manufacturers explore the feasibility of an

anchorage system that would accommodate buckles, snap hooks and ISO-

type connectors with a flat latch or round link, for consideration at

the Albuquerque ISO meeting.) Indiana Mills described the advantages

and disadvantages of the various types of hardware and its reasons for

supporting the existing technology of a flat latch plate/buckle system.

Lear Corporation presented cost data for rigid and soft attachments to

various types of vehicle seating systems. It stated that the vehicle

added cost data should be considered as a complement to the NHTSA study

cost figures. Specifically, it included cost figures on items, such as

covers and trim of rigid anchors, that were not included in the costing

of the NHTSA study. The data showed that the costs of the soft

anchorage system per seat on the vehicle range from about $4 to $10, as

compared to about $13 to $30 for the rigid anchorage points system.

c. Petition on Scheme D (Hybrid System)

On December 18, 1996, BMW, Chrysler, Ford, Land Rover, Mercedes-

Benz, Volkswagen, and the University of Michigan Child Passenger

Protection Research Program, petitioned NHTSA to consider an approach

based on Scheme D and modify the suggestions made in the UCRA petition.

These petitioners supported a system incorporating two ``latch plates''

formed of 6 mm diameter elements for the vehicle, ``coupled with the

alternatives for the [child restraint system], namely, tether hooks or

buckles on belts with tilt-lock adjusters for tension release, or the

rigid ISOFIX connectors on a sliding element.'' The petitioners believe

that this system will offer vehicle and child restraint manufacturers

the greatest design flexibility, and will further international

harmonization at an early date.

V. Evaluation of Concepts

During the course of the agency's deliberations on a universal

child restraint anchorage system and as a result of the discussions at

the October 1996 workshop and other information, the agency has

tentatively determined that child seats can be better secured to a

vehicle (thereby reducing incompatibility problems and increasing

safety) by providing three anchorage points between the restraint and a

vehicle seat. One point is at the top center of the restraint

(attachment of a child restraint to a vehicle would be accomplished at

that point through a top tether), and the other two are at the vehicle

seat bight.

a. Top Tether

ISO Schemes B and C (CANFIX/CAUSFIX and UCRA) include provisions

for a top tether. Cosco indicated it would support a tether

requirement, although the manufacturer is concerned whether tethers

will be used in this country. The European systems do not call for

tethers.

As a result of the agency's deliberations on this rulemaking,5

the agency reevaluated its view of a top tether on child restraints.

NHTSA currently does not require a tether or a tether anchorage on

vehicles. The agency does not prohibit a tether, but generally requires

child restraints to meet Standard 213's 30 mph dynamic testing

requirements without attaching a tether to reflect the historically low

use rate of tethers in this country.

---------------------------------------------------------------------------

\5\ On November 15, 1996, the American Academy of Pediatrics

(AAP) petitioned NHTSA to amend Standard 213 to require child

restraint manufacturers to supply tether straps on all child seats

and require vehicle manufacturers to provide tether anchors at all

rear seating positions. AAP also requested that child restraint

manufacturers be required to make tether straps for existing car

seats available to consumers by mail order and at retail outlets.

NHTSA granted this petition on January 14, 1997.

---------------------------------------------------------------------------

NHTSA tentatively concludes that a top tether should be provided to

better secure a child restraint. By restraining the top portion of a

child seat, a tether would supplement the vehicle belt system in

limiting forward movement of the child restraint in a crash. With less

forward movement, head excursion can be reduced.

This document proposes a performance requirement that would have

the practical effect of requiring a tether on child seats. A new head

excursion requirement for forward-facing seats would be added to limit

excursion to 720 mm (28.35 inches) forward of the Z-point on the test

seat assembly when a child seat is attached

[[Page 7866]]

to the standard seat assembly in accordance with the manufacturer's

instructions. To meet this requirement, manufacturers will likely have

to provide a top tether, which would be attached in the test for this

new requirement. NHTSA believes that the head excursion limit of 720 mm

is practicable with a tether because it is the same as the Canadian

requirement and because most, if not all, child restraint manufacturers

currently produce child restraints for sale in Canada and thus already

meet the requirement for those products. The 720 mm requirement would

promote harmonization with Canadian requirements. Further, the European

child restraint manufacturers believe that a 720 mm limit could be

achieved with the rigid anchorage system with two lower anchorages and

no upper tether.

Test data strongly support the safety value of a tether. AAMA et

al. submitted test results in support of a requirement for a tether

anchorage, stating:

Test results clearly demonstrate that a fastened tether can

significantly reduce dummy head excursion measurements which most

developers and evaluators use as the primary predicator [sic] of a

CRS's performance in field accidents * * * .

An Australian report cites forward-facing CRS test results,

indicating that ``as well as reducing head excursion, a top tether,

with the right high mounted geometry, significantly reduces head

acceleration and neck loads in frontal impacts'' [footnote excluded]

* * * . Recent computer simulations and tests of the recommended

UCRA concept suggest that * * * a fastened tether significantly

reduces dummy head excursion during high severity frontal impacts.

Computer simulations conducted by petitioners AAMA et al. showed a

reduction in force levels experienced by a restrained dummy's head,

neck and chest when a tether was used as compared to no tether, and a

reduction in head and knee excursions. Actual testing of child

restraint systems with and without a tether showed that with the tether

attached, there generally were reductions in head injury criterion

(HIC) values and chest g's, and in head and knee excursions.

These findings are consistent with NHTSA's limited testing of

tethers. In two tests of an Evenflo Scout forward-facing convertible

seat with the inboard anchor of the lap belt restraining the child

restraint to the test seat assembly positioned four inches forward of

the seat bight, the HIC and 3 ms chest acceleration clip were 631 and

59.6 g's respectively. When the child restraint was tethered on its

top, these HIC and chest clip measurements were reduced to 503 and 42.2

g's, respectively.

In her comments at the October public workshop, Ms. Legault of

Transport Canada reported that on-going testing of tethered, untethered

and loosely-tethered restraints indicate improved head acceleration,

head excursion and chest acceleration with a tether strap, even when

the strap is loose. Additionally, upper neck forces and moments were

also improved with a tether. (Transcript of October 17, 1996, pp. 32-

34.) (However, Indiana Mills tests showed increased HIC and chest g's

for a child seat with a dual strap anchorage with a tether, compared to

one without a tether. Comments are requested explaining these

increases.)

However, nonuse of the tether has been a problem in the U.S. In an

effort to boost use rates, NHTSA once proposed requiring all vehicles

under 10,000 lb GVWR to have tether anchorages at all rearmost seating

positions, to make it possible for motorists to easily attach the

tether straps on their child restraints to the vehicle. 45 FR 81625;

December 11, 1980. At the time of the proposal, tether use was about 50

percent. NHTSA terminated rulemaking on this proposal after determining

that (a) since the proposal, there was a continual shift toward

untethered seats, so that most seats did not need a tether to meet

Standard 213's requirements; (b) motor vehicle manufacturers had

increasingly been voluntarily providing provisions, such as

indentations to identify anchorage points and pre-drilled or threaded

holes, in their vehicles to facilitate the attachment of tether straps;

and (c) the most effective way to promote child safety would be to

amend Standard 213 to require all child restraints to meet Standard

213's requirements without attachment of the tether. July 5, 1985; 50

FR 27632.

Petitioners AAMA et al. believe that a tether will be used. GM's

consumer focus group testing indicates a positive response toward a

tether, particularly if the tether anchorage is equipped with all the

components needed for use with the child restraint. The petitioners

state, ``Australian field experience shows very high tether use rates

are obtainable when factory installed tether anchorages are provided.''

(Emphasis in text.) Indeed, top tether use is reported in excess of 95

percent in Australia, primarily due to requirements for installation of

the anchorages and to early and continuous public education on the use

of tethers. ``Options for a Universal Child Restraint Attachment

System,'' M. Lumley, June 14, 1996, revised October 10, 1996.

Petitioners are also encouraged by information from the Canadian

Province of Quebec indicating a 65 percent tether use rate in vehicles

required to have just a tether anchorage, and not the tether hardware.

``This in spite of the fact, that vehicle owners must install the

tether anchorage hardware themselves or return to their dealer to have

it installed.''

In an effort to increase tether use in Canada, Transport Canada is

proposing to require vehicles to have a factory-installed, user-ready

tether anchorage, with hardware included. Transport Canada believes

that tether use will increase if an anchorage equipped with all needed

parts for consumer use is provided at the factory. NHTSA tentatively

believes that this information from petitioners AAMA et al. and from

Transport Canada provides a basis for concluding that tethers would be

used if child seats are equipped with a tether and vehicles are

equipped with a factory-installed, easy- and ready-to-use tether

anchorage. Accordingly, in view of the potential added safety value of

a tether, the agency proposes requiring installation of a ready-to-use

tether anchorage at the two seating positions that would be required to

have the lower anchorages dedicated for attaching a child restraint

system. (See infra, section VI.c.) For purposes of harmonization, the

proposed requirements for the tether anchorages are essentially

identical to those proposed by Transport Canada.

However, because NHTSA does not know the extent to which tethers

will be used in this country, the agency believes the standard should

also retain the present head excursion requirement, which limits

excursion to 813 mm (32 inches) without use of a tether strap.

Retaining the requirement would ensure a minimum level of safety

performance when the tether strap is not used. Further, NHTSA proposes

that child restraints dynamically tested on a child restraint anchorage

system with UCRA anchorages should be subject to the 813 mm (32 inches)

head excursion requirement without attaching the tether. This accords

with the AAMA et al. petition, which suggests not attaching the tether.

Comments are requested on this issue. Comments are also requested on

the potential of using tethers in aircraft.

b. Lower Anchorage Points

Improving the lower anchorage points of a child seat to the vehicle

would make it easier for parents to correctly attach a child seat to

the vehicle.

NHTSA stated in the Federal Register notice announcing the workshop

that an

[[Page 7867]]

anchorage system should accomplish the following:

Improve the compatibility between child restraint systems

and vehicle seats and belt systems, thereby decreasing the potential

that a child restraint was improperly installed;

Ensure an adequate level of protection during crashes;

Ensure correct child restraint system use by ensuring that

the child restraint systems are convenient to install and use;

Ensure that the child restraint systems and anchorages are

cost effective; and

Achieve international compatibility of child restraint

performance requirements for uniform anchorage points.

In remarking on the various ISO schemes and in other presentations,

participants in NHTSA's workshop concurred with and elaborated on these

considerations.

1. Improve Compatibility

All of the anchorage systems appear to improve compatibility

between child restraint systems and vehicle belt systems. Consumers

comparing ISO Schemes A, B and C systems against conventional child

restraints indicated that the new methods of attachment are easier than

current methods. Cosco's CSO system was not evaluated in these studies,

but to the extent that the CSO does not depend on a locking clip or

other means to adapt the belt to a child restraint, an improvement over

existing belt systems, at least concerning that aspect of design, can

be assumed. The CSO belt would still have to be routed correctly

through the child restraint. All anchorage systems would improve

compatibility between child restraint systems and forward-mounted

anchors. Views were expressed at the October 1996 workshop that Schemes

A, B and C systems would improve compatibility between child restraints

and contoured vehicle seats. A rigid anchor system may suspend the

child restraint above the contoured seat, and a UCRA would provide some

resistance to the side-to-side motion of a child seat on a humped

contoured seat. The CSO might not be as effective on humped seats in

limiting side-to-side motion of a child restraint.

2. Safety Performance

ISO Schemes A, B and C systems have performed satisfactorily in

dynamic tests. The CSO system has not been tested, but it simulates the

standard seat assembly used in Standard 213 compliance tests.

Consumer clinics indicate that ISO Scheme A, B and C systems are

comparable in terms of a user's ability to correctly install them.

Users are able to install child restraints correctly in those systems.

Scheme D and the CSO were not evaluated.

The degree to which an anchorage system will be correctly used

outside the context of a clinic is unknown at this time, but design

differences between the systems could affect such use. Attendees at the

public workshop expressed concern with potential misuse problems that

could arise by virtue of the design of each system. A type of misuse

that could occur with a rigid system (ISOFIX four-point or CANFIX) is

if the user does not fully attach all points of the system. Test data

indicate that performance of the child restraint is severely degraded

if one or more points are not attached. Some attendees believed that

users must be able to see clearly where to insert the child seat

connector to the vehicle system, and that a guide of some sort is

needed if the attachment point is behind the seat bight. Some believed

that an education campaign is needed to teach people how to use the

system since a rigid bar anchorage is unfamiliar in this country.

Proponents of the UCRA system believe that the soft anchor system

is superior to a rigid system in that the connectors are buckles and

latches that are consumer-familiar in design to the seat belt hardware

on vehicles. Proponents believe that users will know ``intuitively''

how to use the connector and will recognize the sound and feel of the

click that indicates a positive attachment. Several participants

expressed concern about a possible misuse problem arising due to the

presence of webbing on the connectors, i.e., that slack in the webbing

will negate a tight fit of a child seat on the system. Toyota indicated

it is developing a means of addressing this potential problem.

Cosco believes the CSO system ``is the most intuitive system

suggested because people have been using this type of system for

years.'' NHTSA believes that while users might be familiar with the

system, the CSO system poses some of the same problems as the lap belt

currently used to attach child restraints. The belt would have to be

correctly routed through the child restraint, which is a problem

occurring with present seats. Slack in the belt would negate a secure

fit of the child seat, so an adjuster of some sort would be needed, and

it would have to be positioned on the belt where a user could maneuver

around the child seat to tighten the belt. The seat belt would have to

be long enough to permit it to be fastened around all types of child

restraints, including restraints for children with special needs. A

common complaint with current child seats is the difficulty of routing

the belts through the system and pulling the belt tight. It appears

that the CSO system might not alleviate those problems in all

restraints. Further, there is the potential that the CSO belt would be

inadvertently used by an adult occupant as a restraint, particularly in

a seating position equipped with a lap belt, even if the CSO belt were

labeled.

It may be possible to attach child seats with either a rigid anchor

(ISOFIX four-point rigid, CANFIX) or a soft anchor (UCRA) system design

to a vehicle seat in the same way that current child seats are

attached, using the occupant belt system (and meet minimum performance

criteria). Thus, it may be possible to use them in a vehicle that lacks

an anchorage system. The ability to attach a child seat in a

conventional manner, i.e., using the vehicle belt, is an essential

feature addressing the use of new child seats with old vehicles, and

vice versa (old child seats with new vehicles). Ms. Legault of

Transport Canada said that testing with a CANFIX prototype showed that,

in about 85 percent of its vehicles (lacking receptors for the rigid

points), the prongs could be inserted between the seat cushion and seat

back, so the seat belt could still be used to attach the child seat.

All child seats with UCRA-designed anchorages can be attached to a

vehicle by use of the existing vehicle safety belt, because the UCRA

design is based on a simple addition of buckles to current models of

child seats. The CSO design would also result in all child seats being

able to be attached in a conventional manner. It is unknown whether the

four-point ISOFIX seat could be attached with an existing vehicle belt

and perform satisfactorily.

The various systems differ in their ability to allow child seats

and vehicles to be retrofitted with features of the anchorage system.

The ability to retrofit is desirable, since it would increase the

number of seats that provide improved protection. Retrofitting seats

and vehicles would provide all children the benefits of the improved

technology. It does not appear that the four-point ISOFIX or the two-

point CANFIX allows for retrofitting either the child restraint or the

vehicle. These rigid anchorage systems necessitate an elaborate

redesign of existing child seats. The anchorage pins on the vehicle

seat would have to be precisely aligned with the prongs on the child

seat to ensure that the system performs properly. Alignments of this

nature are generally

[[Page 7868]]

not believed to be feasible in the aftermarket.

Proponents of the UCRA system state that existing seats can be

installed using the UCRA system if the system is supplemented by a

special belt with buckles at each end that are compatible with the UCRA

latchplates on the vehicle. The belt would be provided to the owner of

the old (pre-standard) child seat to route through the existing belt

route path on the child seat. Further, proponents of the UCRA system

believe that vehicles can be retrofitted with the UCRA system. The CSO

system calls for no change in the design of a child seat, so old child

seats could be used with a CSO system in a vehicle. Cosco did not

indicate whether vehicles can readily be retrofitted with the CSO belt

system, although it appears as feasible as retrofitting them with the

UCRA system.

3. Consumer Acceptability

Consumer clinics indicate that ISO Scheme A (rigid four-point), B

(CANFIX) and C (UCRA) systems are comparable in terms of consumer

acceptance. Participants in GM's clinic indicated a preference for

UCRA. Scheme D and the CSO were not evaluated in the clinics.

Participants in all the clinics indicated a desire to see an

improvement in the way child restraints are attached to vehicles. With

regard to bulk and added weight to a child restraint, the CSO adds no

weight, and the UCRA appears to have an advantage over a rigid system

and the CANFIX. The rigid prongs and supporting structure on a rigid

system add much more weight than the buckles of a UCRA and also

protrude from the child restraint.

4. Costs and Burdens

Cost is an area where the systems differ greatly. The cost of the

rigid options is much higher than the soft anchorage system, with added

costs to the child restraint system of about $100 for the four-point

ISOFIX, $60 for the CANFIX and $14 for the UCRA soft anchorage system.

The agency is concerned that the $60 to $100 added costs of the rigid

systems could engender public dissatisfaction with child restraints,

reduce child restraint use rates and significantly reduce the number of

seats available through car seat loaner programs. The CSO system does

not incur additional costs to current child restraints.

Schemes A, B and C systems are fairly design restrictive, in

specifying the geometry and location of assorted components on the

vehicle and child seat. Scheme D (Hybrid) and the CSO specify only the

features of the vehicle system, and not of the child seat. Design

flexibility allows manufacturers latitude in meeting market demands and

developing new technology, yet would be a trade-off in standardization

of the anchorage system.

5. Harmonization

Harmonization was one of the major goals of the agency's October

1996 public workshop. NHTSA stressed the importance of international

harmonization during the workshop and urged ISO member country member

delegates to agree on a unique child restraint anchorage system.

The UCRA system would harmonize with Canada, Australia, New Zealand

and Japan in specifying a top tether. With the top tether proposal, the

proposed rule would harmonize with Transport Canada's current head

excursion threshold and with its planned new regulation proposing to

require manufacturers to provide anchors for tethers in motor vehicles.

The rigid anchor system is endorsed by European members of the ISO

Working Group.

6. Leadtime and Availability

The different systems are at varying stages of development in

design concept. Final design of the four-point ISOFIX system and the

two-point rigid CANFIX have not been completed, although proponents of

those systems believe that completion is imminent. Design of the UCRA

system is completed.

The view was expressed at the October 1996 workshop that the

leadtime needed to implement a requirement for a rigid system would be

much longer than that needed to implement the UCRA system. This is

because the UCRA uses ``existing technology--known systems, known

belts, known buckles, known latch plates'' (quoting David Campbell).

Cosco argues that its CSO system would be the fastest to implement.

7. Proposed System

The agency has decided to base a proposal for a universal child

restraint anchorage system primarily on the UCRA system. The four-point

and two-point rigid and the UCRA appear comparable in terms of safety

performance and public acceptance, but the UCRA appears to have

advantages over the others with respect to its cost impact, near-term

availability and ability to address intermix and retrofit issues.

Further, the UCRA system has advantages in terms of its usability. The

agency believes the familiarity of its components (particularly the

crucial connector pieces--buckles and latchplates--that attach a child

seat to the vehicle system) is a definite advantage over the other

systems. Also, the UCRA system is not as bulky or heavy as the other

systems, which increases its usability.

In addition, NHTSA believes that the soft anchor system has a

potential for use in restraining child seats in aircraft. The Federal

Aviation Administration (FAA) stated in a submission to NHTSA's docket

for the October 1996 public workshop on a universal anchor system that

``preliminary review and evaluation of the proposed ISOFIX systems

under consideration by [NHTSA] suggest that the UCRA concept presents

the best solution in the aircraft environment.'' 96-95-N01-008. FAA is

concerned that the rigid prongs of an ISOFIX-type child seat may not be

compatible with aircraft seat cushions or suited for narrow aircraft

seats.

While NHTSA has decided to propose the UCRA system due to its

advantages in cost, usability, potential for use in aircraft, and the

fact that it is proven technology available today, the agency is still

interested in the possibility of achieving harmonization on a universal

anchorage system. To that end, NHTSA is proposing to permit vehicle

manufacturers to substitute the two lower rigid points of ISO Scheme D

(the Hybrid system) in place of the UCRA anchors, provided that the

vehicle is also equipped with adapters that enable the lower rigid

points to accommodate UCRA-type child restraint systems.

The European manufacturer members of the ISO Working Group on Child

Restraints Systems believe that their countries will require the two

rigid anchorage points in the future.6 Accommodating both hardware

systems would be consistent with the agency's goal of solving the

problem of incompatibility between child restraints and motor vehicles

as expeditiously as possible, while promoting harmonization. The UCRA

system, being a well developed and familiar current technology, is

currently available. The non-flexible system would be given the

opportunity to be developed, tested and evaluated in the market place

to prove what its proponents believe to be its superiority as the child

restraint anchorage technology of the future.

---------------------------------------------------------------------------

\6\ It should be noted that the work thus far by the ISO has

been at the Working Group level. Any ISO standard on this matter has

still to go to higher committee before it becomes a standard.

---------------------------------------------------------------------------

NHTSA tentatively concludes that the two proposed systems can

coexist in the

[[Page 7869]]

short term. The UCRA system will not hinder any development of the non-

flexible hardware system. The proposed rule allows vehicle

manufacturers to install a 6 mm pin to attach a child restraint that is

equipped with jaw-type non-flexible hardware. The proposed rule would

not prevent manufacturers of child restraints from developing a

restraint with non-flexible hardware, and would facilitate a transition

to future technology. However, in the interest of eradicating

incompatibility problems henceforth, child restraints with non-flexible

hardware would be required to have components (e.g., buckles),

permanently attached to the child restraints, that are compatible with

the UCRA anchorages. This proposal considers the UCRA system to be

paramount, and a rigid system would be allowed as long as the UCRA

system is universal for all vehicles and child restraint systems.

c. Discussion of Alternatives

A number of other approaches have been suggested to minimize or

eliminate incompatibility between child seats and vehicle seats. This

section addresses these alternatives to the approach proposed today.

1. SAE Recommended Practice J1819

In 1994, the Society of Automotive Engineers (SAE) published its

Recommended Practice SAE J1819, ``Securing Child Restraint Systems in

Motor Vehicle Rear Seats,'' to promote compatibility between child

seats and vehicle rear seats and seat belts. J1819 provides voluntary

design guidelines to vehicle manufacturers for certain characteristics

of rear seats and seat belts, such as seat cushion shape and stiffness,

and seat belt anchorage location, belt length, buckle and latchplate

size, and lockability. In addition, J1819 provides design guidelines to

child seat manufacturers for child seat features that correspond to the

vehicle features.

J1819 specifies a ``Child Restraint System Accommodation Fixture''

to represent a child seat, so that designers of both the vehicle and

child seat can evaluate each product for compatibility.

NHTSA tentatively concludes that J1819 alone does not fully solve

incompatibility problems. It is a tool for evaluating incompatibility,

not a requirement that vehicle seats and child restraints must be

compatible.

In the October 1996 workshop, Mr. Howard Willson (who chairs the

Children's Restraint Systems Standards Committee of the SAE) stated

that J1819 might be amended to add ``a test for seat contour.'' The

test would enable vehicle manufacturers to ``identify seating positions

where it's probable that child restraints will not work well because of

seat contour.'' He also stated

I doubt that we will agree to simply design our seating positions so

that they're all as flat as the seats in a pick-up truck used to be,

for example. There is an appeal to a shaped seat, an appeal to the

users. (Transcript of October 18, pp. 8-9.)

At the same workshop, Mr. David Campbell said that a child

restraint anchorage system--

should be independent of the adult seat belt system so that

manufacturers can have the flexibility to optimize the performance

of the anchorage system for child restraints and allow the adult

seat belt system to be optimized for the other occupants in the

vehicle. (Transcript of October 12, p. 40.)

NHTSA tentatively agrees with this statement. Further, NHTSA

recognizes that it is very difficult for a single system to optimize

the safety protection for adults of all ranges and child restraints of

different types. Nonetheless, the agency requests comments discussing

possible design alternatives to a universal child restraint anchorage

system.

2. Lockability

In 1993, NHTSA amended its occupant crash protection standard

(Standard 208) to adopt a ``lockability'' requirement effective

September 1, 1995. The rule requires vehicle lap belts or the lap belt

portion of lap/shoulder belts to be capable of being used to tightly

secure child safety seats, without the need to attach a locking clip or

any other device to the vehicle's seat belt webbing, retractor or any

other part of the vehicle. 58 FR 52922, October 13, 1993. The

requirement applies to seating positions other than the driver's

position on vehicles with a gross vehicle weight rating of 10,000

pounds or less.

The rule requires the lap belt to be lockable and specifies test

procedures demonstrating compliance with the lockability requirement.

The rule does not specify how the vehicle belt is to be locked, except

to prohibit locking by ``inverting, twisting or otherwise deforming''

the belt webbing. An example of a permitted means of locking a belt is

extending the belt all the way, then feeding in the slack.

NHTSA tentatively concludes that the lockability requirement is

insufficient alone in addressing incompatibility problems. While the

requirement ostensibly makes a locking clip obsolete, it still depends

on the user knowing enough and making the effort to manipulate the belt

system. Also, the vehicle belt must be routed correctly through the

child restraint, which may not be an easy task in all cases. Further,

the lockability requirement does not address incompatibility problems

arising from forward-mounted seat belt anchors. Excessive forward

movement of a child seat can still occur, even if the feature is

engaged and the belt is ``locked.'' Comments are requested on this

issue. NHTSA is considering deleting the lockability requirement as

unnecessary if requirements for a child restraint anchorage system are

adopted. A lockability requirement may not be needed for a seating

system with a universal anchorage system since the vehicle's belt would

no longer be used for attaching a child restraint. However, lockability

might be needed to attach child seats that are not equipped for a

universal anchorage system, even if the vehicle seat has such a system.

3. Cosco's CSO system

Cosco's CSO system is appealing in its simplicity and low cost, but

the CSO system is essentially no different from the current lap belt

means of attaching child restraints to vehicle seats. NHTSA is

concerned that the CSO system might not make attaching a child seat

significantly easier than it is today. As noted previously, the CSO

belt would have to be correctly routed through the child restraint,

which manufacturers believe many consumers find difficult to do. In

addition, from photographs of the CSO system, it might be difficult to

tighten the belt. Consumers have expressed concern about their child

seat not being secure on the vehicle seat because of the lateral side-

to-side motion of the child restraint that occurs no matter how tightly

the lap belt is adjusted. On a contoured, humped, seat, there is even

more lateral ``play.'' The CSO system might not be able to address

these concerns. Cosco provided no data on these issues assessing the

viability of this approach. Another concern relates to the potential

that the CSO belt would be inadvertently used by an adult occupant as a

restraint, even if the CSO belt were labeled. It is also unknown how

consumers will accept the addition of more seat belt systems in the

rear seat, in addition to the Type I and II belts already provided in

the rear seat. The agency requests data or comment on any research that

has been done on the CSO system evaluating its acceptability by

consumers, its performance with child restraints, the potential for

correct use with child restraints and for misuse by adult passengers.

Focus group testing comparing the CSO system to the UCRA and other

standardized systems would be especially helpful.

[[Page 7870]]

VI. Proposal for New Vehicle Standard

a. Highlights of Proposal

The most significant requirements proposed by this document are

highlighted below.

(1) A new safety standard would require all passenger cars and

light trucks and vans to be equipped with a child seat anchorage

system, defined in the standard, at two rear seating positions. If an

air bag cutoff switch is provided that deactivates the air bag for the

front passenger position, one system would have to be provided in that

position, and another in a rear seating position. If there is no rear

seat and no air bag cutoff switch, an anchorage system would be

disallowed in the front passenger seat. A built-in child seat may be

substituted for one of the systems, but not both, since rear-facing

built-in systems are currently unavailable.

(2) The system would consist of two lower anchorages at the vehicle

seat bight (the intersection of the seat cushion and the seat back) and

a top tether anchorage. The lower anchorages could consist of either

UCRA-type latchplates or rigid anchorages (ISO Scheme D), provided that

connectors are provided with the Scheme D anchorages that enables a

child seat with UCRA buckles to be used with the rigid anchorages. The

child restraint system standard (Standard 213) would be amended, in

effect, to require child seats to be equipped with a top tether, and

with attachment components (e.g., buckles) that are compatible with the

UCRA latchplates on the vehicle.

(3) The proposed requirements would specify the construction of the

child restraint anchorage system, the location of the anchorages, and

the geometry of related components, such as the hardware that attaches

to a child seat.

(4) A new safety standard would specify performance and location

requirements for the tether anchorages. The standard would apply to all

tether anchorages installed in a vehicle, regardless of whether the

anchorage is required by a safety standard or voluntarily installed by

the manufacturer. The agency tentatively believes that all anchorages

should be subject to the proposed performance and location requirements

to ensure that any anchorage used in the vehicle performs properly.

(5) To prevent the anchorages from failing in a crash, the vehicle

anchorages, including structural components of the assembly, would have

to withstand specified loads in a static pull test.

(6) Child restraint systems would be dynamically tested under

Standard 213 when attached to the vehicle system. The standard seat

assembly specified in the standard to test add-on child seats would be

revised to incorporate the upper and lower anchorages of a child

restraint anchorage system. It would have both UCRA anchorages (Scheme

C) and rigid anchors (Scheme D). A head excursion limit of 813 mm (32

inches) would have to be met without attaching the top tether.

(7) A child seat equipped with features enabling it to be attached

to an anchorage system would also have to meet the present 813 mm head

excursion requirement of Standard 213 when tested with just a lap belt.

This is to ensure a minimum level of safety performance when the child

seat is used in a vehicle that does not have an anchorage system.

(8) In addition, each child restraint would have to meet a 720 mm

(28 inches) head excursion requirement when tested according to the

manufacturer's instructions. A tether provided with the child restraint

may be attached in this test.

(9) Instructions for using the anchorage system would have to be

provided with each child restraint and in the vehicle owner's manual.

As discussed above, this proposal is based on the premise that a

child restraint anchorage system would make child seats compatible with

motor vehicles, and thus increase the safety value of restraints. The

approach taken by this proposal would be to rectify the vehicle-to-

child restraint incompatibility problem along two lines: vehicles would

be required to have a child restraint anchorage system with components

``ready'' to attach a child seat, and child restraints would be

required to have components ``ready'' to attach to the vehicle system.

By having a dedicated anchorage system for child restraint systems,

manufacturers can optimize the designs of their vehicle belt and child

restraint systems to provide higher safety protection to both adults

and children.

A potential but seemingly necessary limitation in the proposed

compliance tests is that the vehicle system is statically tested by

devices that replicate the loads imposed by a child seat, and a child

restraint is dynamically tested on a seat assembly simulating a vehicle

seat. That is, an actual vehicle anchorage system would not be tested

with an actual child restraint, and vice versa. This is to avoid

possibly complicating enforcement efforts if an apparent failure arises

in a compliance test. If vehicles were tested with actual child seats,

and vice versa, and if a vehicle anchorage system, for example, were

found to fail the proposed requirements, an issue could arise as to

whether the failure was with the vehicle system, or with the child seat

attached to the vehicle system. To avoid this complication, the

compliance tests must be as controlled as possible to remove unknown

influences on the performance of regulated parts.

While the actual vehicle-to-child seat attachment would not be

tested, NHTSA believes that the performance obtained in the compliance

test will reflect the real-world performance of the anchorage system

and the child restraint. This is because the geometry of the belts and

latchplates primarily responsible for the vehicle-to-child seat

interface would be precisely specified by this proposal. These

components would have to be provided on vehicles and child seats

precisely as specified in the standards. In turn, these components, in

the same geometry as that specified in the standards, would be used in

the compliance tests. Thus, the vehicle-to-child seat interface should

be adequately tested.

b. Applicability

The requirement for a child restraint anchorage system would apply

to passenger cars and trucks and multipurpose passenger vehicles (MPVs)

under 10,000 pounds (lb) gross vehicle weight rating (GVWR) (hereafter

referred to as ``LTVs''), except as noted below.

Petitioners AAMA et al. suggested, with respect to trucks and MPVs,

that the requirement be limited to those with a GVWR of 8,500 lb or

less and an unloaded vehicle weight of 5,500 lb or less. AAMA stated:

The GVWR range suggested was incorporated using the identical

GVWR range currently required to meet the dynamic performance

requirements of FMVSS 208 for occupant protection. The relatively

small number of vehicles larger than those within this range, the

physical dynamics of these size vehicles and the unexpected use of

CRSs [child restraint systems] in them, support maintaining this

GVWR range for this proposal.

NHTSA agrees that vehicles with GVWRs of more than 10,000 lb are

much less frequently used to carry young children (as compared to

vehicles with GVWRs of less than 10,000 lb) and thus should be excluded

from a requirement to provide a child restraint anchorage system.

However, child restraint systems could be used in vehicles with a GVWR

between 8,500 and 10,000 lb, such as in vehicles used for

transportation to child care programs. In the interest of best ensuring

that a child restraint anchorage

[[Page 7871]]

system would be available when needed and to minimize incompatibility

problems between child restraints and vehicle seats to the extent

possible, NHTSA proposes to apply this rule to trucks, buses and

multipurpose passenger vehicles with a GVWR of 10,000 lb or less.

Comments are requested on this issue.

AAMA et al. suggested excluding walk-in van-type vehicles and

vehicles manufactured to be sold exclusively to the U.S. Postal

Service. The agency agrees that these vehicles are unlikely to be used

for transporting children in child safety seats. NHTSA made the

determination in the rulemaking adopting the lockability requirement,

supra, that these vehicles are not likely to be used to carry children

in child seats. Accordingly, NHTSA proposes to exclude these vehicles

from today's proposed vehicle standard.

The AAMA petitioners suggested that the standard should not apply

to a vehicle that ``the manufacturer designates as not intended for CRS

use.'' The petitioner further suggested that ``[v]ehicles not intended

for CRS use shall include this information in the vehicle's owner's

manual'' and on a label in the vehicle. The agency has tentatively

decided against this approach. NHTSA does not know, and petitioners did

not explain, why manufacturers should be permitted to exclude a vehicle

from the proposed requirements, given that such a provision could

substantially reduce the number of vehicles that are equipped with an

anchorage system. Reducing the universe of vehicles equipped with the

anchorage system would eviscerate the ``universality'' of the system,

which could result in many consumers not having an improved means of

attaching a child restraint in their vehicle.

c. Seating Positions

This proposal would require the child seat anchorage system (i.e.,

a top tether anchorage and lower anchorages) in two rear seating

positions. NHTSA proposes requiring the system to be placed in a rear

seating position because available data indicate that the rear seating

positions are the safest positions in which to install a child

restraint system. Vehicles that lack a rear seating position capable of

fitting a rear-facing child seat would be required to provide a system

in the front seat if the vehicle has a cutoff switch that deactivates

the air bag installed at the right front passenger position in the

vehicle. However, a child restraint anchorage system would also have to

be installed in the rear seat of these vehicles, because a rear seat

that is too small to fit a rear-facing child restraint can nonetheless

probably fit a forward-facing seat. If the vehicle lacks a rear seat

and does not have an air bag cutoff switch, an anchorage system would

be disallowed in the front passenger seat. A built-in child seat may be

substituted for one of the anchorage systems, but not both, since

built-in seats currently cannot accommodate a rear-facing restraint.

There was no consensus among the petitioners as to the number of

child restraint anchorage systems that should be required and where in

the rear they should be. Many believe that the system should be

installed at each of the outermost designated seating positions of the

second row (and a tether anchorage in the rear lap-belt center

position). The Japanese vehicle manufacturers believe that only one

rear seat position should be required to have the system. Fisher-Price,

a child restraint manufacturer, believes that the rear center seating

position is recognized as the safest and that the system should

therefore be required there.

NHTSA has tentatively determined that each vehicle with a rear seat

should have at least two rear seating positions that can properly hold

a child restraint system. The agency is concerned whether there is a

need for an anchorage system at more than two seating positions. NHTSA

requests information on this issue, such as demographic data on the

number of children in child restraints typically transported in a

family vehicle. It is noted that nothing in the proposed standard would

prohibit a vehicle manufacturer from voluntarily providing child

restraint anchorage systems in rear seats at more than the required

seating positions, if a purchaser wants additional systems.

This proposal does not specify that both anchorage systems would

have to be provided at an outboard position. In some vehicles with

large interiors, it may be possible to install one of the required

systems in a center seating position.

d. Construction

Requirements are proposed for the construction of the child

restraint anchorage system. The system would consist of two child

restraint anchorages at the vehicle seat bight and a tether anchorage.

1. Lower anchorages

The proposed rule would permit manufacturers to conform lower

anchorages to either option A, consisting of requirements based on the

UCRA system (ISO Scheme C), or option B, based on the Hybrid system

(Scheme D).

Option A (UCRA System)

For vehicles incorporating the UCRA system, the standard would

specify that lower anchorages are located 280 mm apart, measured to the

centerline of each latchplate when fully extended in a plane parallel

to the vehicle's longitudinal axis. When fully extended, the tip of

each latchplate must not extend more than 50 mm forward of the seat

bight. The 50 mm value was suggested to ensure accessibility of the

lower anchorages. The petitioners and the ISO ad hoc group specified

this figure in a November 15, 1996 draft ISO/WD13216-1i report. 7

NHTSA tentatively believes the value is reasonable to ensure that the

lower latchplates are not so rearward that they may be buried in the

seat bight, yet are not so forward that excessive forward movement of a

child seat could result.

---------------------------------------------------------------------------

\7\ This figure is consistent with the ISO/WD 13216-1i report

that are in the December 13, 1996 submittal to Docket No. 96-095,

Notice 1.

---------------------------------------------------------------------------

The standard would also specify the geometry of related components,

such as webbing and latchplates (tongues) of the lower anchorage

points. NHTSA is proposing the latchplate geometry that was suggested

in the petition by AAMA et al. The agency is proposing to specify the

geometry of these components as necessary to ensure the universality of

the anchorage system. 8 It negates the likelihood that a used

child restraint with particular attachment components would be ``handed

down'' or sold to a person owning a vehicle with an incompatible

anchorage system. Further, since a simple, effective way of testing

anchorage systems with varying components has not been devised,

specifying the geometry is the best means of ensuring that anchorage

systems will securely attach a child restraint, and provide an adequate

level of child protection.

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\8\ While the geometry of the vehicle latchplates would be

mandated, child restraint systems would not have designs specified,

other than that to have ``components permanently attached to the

system that securely fasten to the [vehicle's] latchplates''

(proposed S5.9(a)). However, the agency anticipates the use of UCRA

buckles.

---------------------------------------------------------------------------

The lower anchorages would be equipped with specialized latchplates

that would attach to buckles on a child seat. The geometry of the

components is such that the webbing, buckles and latchplates are

similar in design to components found on current adult occupant belt

systems. This is to ensure that the components and their operation are

familiar to persons installing a child seat. The geometry of the

components is such that they are smaller in size than

[[Page 7872]]

like components on the adult occupant belt systems. This is to reduce

the likelihood that the person installing a child restraint might

confuse the belts and buckles of the child seat anchorage system with

the adult occupant belt systems.

Several participants at the October 1996 workshop expressed

concerns or suggestions about aspects of the UCRA's belt systems. Klaus

Werkmeister expressed concern that the UCRA system's lower anchorages

could be lost in the seat bight of a foldover seat after the seat is

flattened to make room for cargo and then reinstalled as a seat. On the

other hand, John Gane said that the ICBC clinic had folding rear seats

and that these didn't interfere with either the hard or soft anchor

systems. Transcript, October 17, 1996, page 228-230. Comments are

requested on this issue.

Mr. Gane also suggested that the ICBC clinic indicated that the

side straps for the UCRA should be distinguished from the straps

comprising the harness for the child. He said that when the straps were

not distinguished, ``we had a huge failure rate of people to understand

how the seat was intended to work.'' Id., p. 220. (Some clinic

participants attached the vehicle anchor belt to the child restraint's

internal harness.) ICBC later modified the UCRA child restraint to

color code the belts. Comments are requested on whether the straps of

the UCRA should be distinguished, and if so, what measures should be

required to distinguish them (e.g., color coding and/or labeling).

Howard Willson stated that the webbing-supported anchorages of the

UCRA should be required to have a specific stiffness so that users can

use one hand to attach the child seat connector to the anchorage. The

AAMA et al. petitioners also suggested that the latchplates should not

displace rearward more than 25 mm under a 50 N rearward load. Comments

are requested on the need for such a requirement, the level at which a

requirement should be set, the means of testing a requirement, and

limiting side-to-side deflection of the latchplates which may degrade

the ability to attach the child seat with just one hand. Comments are

also requested on any other performance that should be required of the

UCRA system to ensure that it will be effective.

Option B (Scheme D)

For vehicles incorporating the ISO Scheme D system, the standard

would specify anchorage dimensional and marking requirements developed

in draft by the ISO in ``ISO/WD 13216-1i Road Vehicles-Child Restraint

Systems-Standardized Universal Attachment to Vehicle (ISOFIX)--Part 1:

Dimensions and General Requirements,'' (November 15, 1996). The rule

would require the lower anchorages to be 6 mm diameter transverse

horizontal round bars with a minimum effective length of 25 mm. The

spacing between the bars would be 280 mm apart, center-to-center. This

value is harmonized with ISO to be agreeable with manufacturers of

European, Japanese and U.S. motor vehicles. 9 Other specifications

for the location of the lower anchorage bars would also be set forth in

the standard. The anchorage location zone would be determined using a

child restraint apparatus (see Figures 1, 2 and 3 of the proposed

standard).

---------------------------------------------------------------------------

\9\ This figure is consistent with the ISO/WD 13216-1i report

that are in the December 13, 1996 submittal to Docket No. 96-095,

Notice 1.

---------------------------------------------------------------------------

Vehicle manufacturers incorporating the Scheme D system would also

be required to provide connectors that would enable the system to be

used with a UCRA-type child seat. The connector would have a component

on one end that latches onto the 6 mm bar, and a UCRA latchplate on the

other for attaching a UCRA child seat to the anchorage system. Comments

are requested on the degree to which the geometry of the connector

should be specified. A connector would have to be provided for each

Scheme D lower anchorage point. NHTSA believes that a connector should

be provided to ensure that parents having a UCRA-type child restraint

can use the restraint in any vehicle. This aspect of the proposal was

not included in the petition from BMW et al. Those petitioners

suggested that a connector from a child restraint to the vehicle

anchorages should be provided on the child restraint, by the child

restraint manufacturer. Comments are requested on this issue.

2. Upper Anchorage

The tether anchorage would be harmonized with Canadian and

Australian requirements. Canada is preparing to require vehicles to

have a factory-installed, user-ready tether anchorage. While AAMA et

al. originally petitioned to require a specialized buckle that would be

compatible with a latchplate on a child seat tether, petitioners have

indicated a desire to harmonize with Canada and Australia. Thus, a

simple anchor (such as a ring) on the vehicle would be sufficient,

although a more sophisticated anchor could be provided if it is

compatible with the tether hook that today's NPRM proposes to require

on child restraints.

e. Performance

The main performance requirement for the anchorage system would

specify strength criteria for the lower and upper anchorages and

related hardware. In addition, the standard would require the system to

meet Standard 209's belt and buckle requirements, such as those

relating to abrasion, resistance to light, corrosion resistance and

temperature resistance. Comments are requested on whether Standard

213's buckle release requirements (S5.4.3.5) should also be met. Among

other things, those requirements specify that a buckle must not release

when subjected to a force of less than 40 N, and shall release when a

force of not more than 62 N is applied.

The proposed strength criteria are to prevent the anchorages from

failing in a crash. The anchorages, including structural components of

the assembly, would have to withstand specified loads in a static pull

test.

The performance criteria for the lower anchorages would require

that, in a static test of the anchorages: (a) no portion of the

latchplate for each anchorage shall move more than 125 mm forward of

the seat bight when subjected to a forward force of 5,300 N and, (b)

there shall be no complete separation of any anchorage component of the

assembly (including webbing, straps, latchplates, adjustment and

anchorage hardware and retractors).

The static pull test would specify that each lower anchorage is

tested to withstand the application of a 5,300 N forward load. In the

test, a force of 5,300 N would be applied to each anchorage in the

forward direction parallel to the vehicle's longitudinal vertical

plane. The force would be applied by means of a belt strap that is of

sufficient length to extend not less than 250 mm forward from the

vertical plane intersecting the seat bight. The belt would be fitted at

one end with hardware for applying the force, and at the other end with

hardware for attachment to the anchorage latchplate. The 5,300 N force

is attained within 30 seconds, with an onset force rate not exceeding

135,000 N per second, and is maintained at the 5,300 N level for ten

seconds. The test procedure and force level were selected to harmonize

with the proposed Canadian regulations on the upper tether, as well as

with the suggested force level of the UCRA petition. The same test is

proposed for the rigid anchor system with the adapter attached to each

anchor point.

[[Page 7873]]

A static pull test would also be specified in a new standard

10 for the upper tether anchorage, in accordance with Canada's

proposed tether anchorage requirement. The force level and application

rate would harmonize with the proposed Canadian regulations on the

upper tether. The standard would specify that each structural component

of the anchorage shall withstand a force of not less than 5,300 N, and

that there shall be no complete separation or failure of any anchorage

component. Comments are requested on whether more specificity is needed

for these strength requirements, and on whether other performance

requirements should be included in the standard.

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\10\ Assuming a final rule on this subject is issued, the

requirements set forth in the proposed tether standard could be

incorporated into the standard on the child restraint system

anchorage system, rather than in a separate standard.

---------------------------------------------------------------------------

Each tether anchorage would be tested separately. However, more

than one tether anchorage installed on a row of seats would be tested

simultaneously.

f. Instructions

The standard would require that instructions about attaching a

child restraint to the vehicle anchorage system be provided in the

vehicle owner's manual. The instructions would have to indicate the

seating positions equipped with a child restraint anchorage system, and

include instructions that provide a step-by-step procedure, including

diagrams, for properly attaching a child restraint system to a vehicle

anchorage system equipped with UCRA-type anchorages. In addition, for a

vehicle equipped with a rigid anchorage system, instructions would also

have to be provided for properly attaching a child restraint to the

rigid system.

VII. Proposal for Amendments to Child Seat Standard

a. Applicability

Standard 213 would be amended to require all child seats, other

than belt positioning seats, to be equipped with components that are

compatible with the UCRA anchorages on the vehicle system. Belt-

positioning seats, which are a type of booster seat designed for older

children, are designed to use a vehicle's lap and shoulder (Type II)

belt system to restrain the child occupant. Because a vehicle's belt

system is not necessarily directly routed around or through a belt-

positioning seat to secure it to a vehicle, and because upper torso

protection is provided by the shoulder portion of the Type II belt,

there does not appear to be any incompatibility between a vehicle seat

or its seat belts and belt-positioning seats. Also, because a Type II

belt system is placed around the child occupant who is seated on a

belt-positioning seat, there would be a minimal amount of forward

movement of the child and child seat before forward movement is

restrained by the Type II belts.

b. Required Components

Requirements would be established for the components of the child

seat that attach to the vehicle system. A child restraint would be

permitted to have components that attach to rigid or semi-rigid Scheme

D anchorages (Hybrid system), but the restraint must nonetheless have

the UCRA attachments permanently attached to it. This would ensure that

persons owning any type of child seat can use the restraint in any

vehicle (i.e., all vehicles would be able to attach a UCRA-type seat,

either attached to a UCRA system, or by way of UCRA connectors to

Hybrid anchorages). The agency requests comments on whether child

restraints intended to be used with systems that have Hybrid anchorages

should be required to provide an adapter, rather than the UCRA

components.

By way of reduced allowances on head excursion, each child seat

would be required to have a tether that attaches to the vehicle. To

minimize the chances of incompatibility between the seat and the

vehicle, the standard would specify the exact geometry of the tether

hook.

The regulatory text for this proposal does not include a provision

that the child seat components attaching to the lower anchorages of the

vehicle system have retractors to take up excessive slack in the belts.

NHTSA requests comments on whether a retractor is needed or is manual

adjustment enough to ensure that the child seat will be snug against

the vehicle seat back. Excessive slack in the connecting belts could

result in excessive head and knee excursions for the child occupant,

and a greater likelihood of head impact.

In the October 1996 workshop, Kazuhiko Miyadara, Jocelyn Pedder of

Transport Canada, and others indicated that a soft anchor system should

have a means of taking up slack in the belts. Comments are requested on

what type of retractor, if any, should be specified for the UCRA.

c. Dynamic Performance

The dynamic test specified in Standard 213 would be used to

evaluate the performance of the child seat when attached to the

universal vehicle anchorage system. The standard seat assembly

specified in the standard to test add-on child seats would be revised

to incorporate a child restraint anchorage system meeting the proposed

specifications. A child restraint would be attached to the system using

the appropriate buckles and other components of the child restraint.

Injury criteria and other performance requirements specified in

Standard 213 would have to be met when the child seat is attached to

the anchorage system.

Forward-facing restraints would be required to meet a head

excursion limit of 720 mm (28.35 inches) when tested in accordance with

its manufacturer's instructions. To meet this requirement, most

manufacturers would likely have to provide a top tether, which would be

attached in the test for this new requirement. Restraints would also be

required to meet a head excursion limit of 813 mm (32 inches) when the

tether is not attached, to ensure that a minimum level of safety is

provided in a misuse situation. Each child seat would also have to meet

the 720 mm (tethered) and 813 mm (untethered) head excursion limits

when attached by a lap belt. This test would be to ensure a minimum

level of safety performance when the child seat is used in a vehicle

that does not have a UCRA or rigid anchor system.

NHTSA believes that Standard 209's belt and buckle requirements

relating to abrasion, resistance to light, corrosion resistance and

temperature resistance, should apply to the webbing and hardware

installed on a child seat to connect to a vehicle system as required by

the existing provisions of S5.4 of Standard 213. The agency tentatively

concludes that these belt and buckle requirements of Standard 209

should apply to ensure the safe performance of the belts and associated

hardware.

d. Instructions and Labeling

Standard 213 would be amended to require that instructions about

attaching a child restraint to the vehicle anchorage system be provided

in the printed instructions accompanying each restraint. The

instructions would have to provide a step-by-step procedure, including

diagrams, for properly attaching a child restraint system to a vehicle

anchorage system equipped with UCRA-type anchorages, and if the child

restraint is intended for a vehicle equipped with a rigid or Hybrid

anchorage system, instructions for properly attaching to such a system.

NHTSA also proposes amending Standard 213's labeling requirements, to

either add a new provision or amend an existing one such as S5.5.2(g),

to instruct owners to secure the child restraint system with either a

vehicle

[[Page 7874]]

belt or components attaching to a vehicle's child restraint anchorage

system.

S5.5.2(j) of Standard 213 would already require a label instructing

owners to secure the top tether strap of the child restraint. That

section states that in the case of each child restraint system equipped

with an anchorage strap, the following must be permanently labeled:

SECURE THE TOP ANCHORAGE STRAP PROVIDED WITH THIS CHILD RESTRAINT AS

SPECIFIED IN THE MANUFACTURER'S INSTRUCTIONS.

Comments are requested on what changes, if any, should be made to this

labeling requirement to increase the likelihood that parents will

attach the top tether strap.

VIII. Proposed Effective Date

In their petition, AAMA et al recommended a schedule for phasing in

the suggested requirements, should those requirements be adopted. The

petitioners requested different schedules for vehicle manufacturers,

child restraint manufacturers, and final-stage vehicle manufacturers

and alterers. The latter group of manufacturers are typically small

businesses. (See table 2, below.) The schedules suggested by AAMA et

al. are based on the assumptions that (a) the attaching system

envisioned by the petitioners is adopted, and (b) a final rule is

issued by January 1, 1997.

The petitioners suggest that vehicle manufacturers be permitted two

alternatives in phasing in complying vehicles, beginning September 1,

1998. Under the first alternative, 10 percent of the vehicles

manufactured in the first model year after September 1, 1998, would be

required to have the child restraint anchorage system (manufactured on

or after September 1, 1998, through August 31, 1999), 30 percent of the

vehicles manufactured in the second model year (ending August 31,

2000), 50 percent in the third model year (ending August 31, 2001), and

100 percent in the fourth year (ending August 31, 2002). Under the

second alternative, no vehicle need comply with the proposed standard

before September 1, 2000, but 75 percent of a manufacturer's vehicles

produced on or after September 1, 2000 through August 31, 2001 (model

year 2001) would have to comply with the requirements, and 100 percent

of its vehicles manufactured on or after September 1, 2001 would have

to comply.

The requested schedule for child seat manufacturers also includes

two alternatives for phasing in complying child seats, beginning

September 1, 1998. The petition refers to child restraints manufactured

in a particular ``model year,'' which apparently assumes the September

1 to August 31 cycle traditionally used to designate vehicle model

years. Under the first alternative, 5 percent of the child seats

manufactured in the first ``model year'' after September 1, 1998 would

be required to have the components enabling the child restraint to

attach to the universal vehicle system (model year ending August 31,

1999), 15 percent of the child restraints manufactured in the second

model year (ending August 31, 2000), 25 percent in the third model year

(ending August 31, 2001), and 100 percent in the fourth year (ending

August 31, 2002). Under the second alternative, no child restraint need

comply with the proposed amendments to Standard 213 before September 1,

2000, but 50 percent of a manufacturer's restraints produced on or

after September 1, 2000 through August 31, 2001 (model year 2001) would

have to comply with the requirements, and 100 percent of its child

seats manufactured on or after September 1, 2001 would have to comply.

The petitioners provided the following table showing the requested

phase-in schedules for vehicle and child seat manufacturers:

Petitioners Requested Phase-In Alternatives (Percent of Products Required to Comply)

----------------------------------------------------------------------------------------------------------------

Vehicle Child seat

manufacturers Vehicle manufacturers Child seat

Model year alternative #1 manufacturers alternative #1 manufacturers

(percent) alternative #2 (percent) alternative #2

----------------------------------------------------------------------------------------------------------------

1999........................................ 10 0 5 0

2000........................................ 30 0 15 0

2001........................................ 50 75 25 50

2002........................................ 100 100 100 100

----------------------------------------------------------------------------------------------------------------

The requested schedule for final-stage manufacturers and alterers

would provide these manufacturers the option of using the phase-in

schedule for vehicle manufacturers, described above, or the alternative

of having the requirements become mandatory on September 1, 2001 for

100 percent of a manufacturer's vehicles, and not before.

NHTSA has made the following tentative decisions about leadtime.

The agency believes that the proposed requirement that vehicles provide

a user-ready tether anchorage and that child seats provide a tether can

be made effective at a much earlier date than a requirement for the

lower anchorages of a child restraint anchorage system. Passenger cars,

in particular, generally are already equipped with a tether anchor

(Canada has required a tether anchorage in passenger cars since 1989),

so it appears that a user-ready anchorage can be provided in the near

future. Canada is proposing an effective date of September 1, 1999 for

its tether hardware requirement for passenger cars. NHTSA proposes that

its tether anchorage requirement for passenger cars be the same as the

Canadian proposal.

For LTVs, Canada has also proposed that its tether anchor (hole)

requirement be effective September 1, 1999, and its tether hardware

requirement effective a year later. In view of these dates and that

anchorages (holes) are apparently not as currently available on LTVs as

on passenger cars, NHTSA proposes a September 1, 2000 effective date

for its tether hardware requirement for LTVs.

With regard to child restraints, restraints manufactured in the

U.S. and sold in Canada already are equipped with a tether to meet

Canadian requirements. NHTSA believes that most U.S. manufacturers

produce child restraints for sale in Canada. NHTSA is considering an

effective date of September 1, 1999 for its proposal to effectively

require tethers by way of reducing Standard 213's head excursion

requirement.

As to a requirement for the lower anchorages, the petitioners did

not explain why a phase-in is needed, or why more than four years would

be needed to implement the requirement. The agency is determined to

remedy the

[[Page 7875]]

problem of incompatibility of child restraints and motor vehicles as

promptly as possible and requests comments on the feasibility of having

full implementation (100 percent of affected vehicles) in a shorter

period, e.g., two years after the publication of a final rule. GM

indicated in the UCRA petition that if allowed, it would begin

installing the UCRA system on vehicles before completion of this

rulemaking on UCRAs. (NHTSA replied in an August 27, 1996 letter that

manufacturers are permitted to voluntarily install the system before

completion of a final rule.) Given that the UCRA technology is

developed and available, and capable of being installed in today's

vehicles, the agency believes the system could be implemented within

two years. The same issue arises with regard to the effective date for

requiring child restraints to be equipped with buckles and other

components compatible with the UCRA system. Comments are requested on

why a phase-in is needed, and on whether a shorter compliance date is

possible.11

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\11\ A phase-in of an amendment to an equipment standard is

uncommon. It should be noted that to implement a phase-in

requirement, the agency would require manufacturers to provide

information on the total annual sales of their seats, so that the

agency can determine whether the requisite number of seats complied

with the new requirements.

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NHTSA recognizes that the rigid attachment system may need longer

time to implement, especially on vehicles that may need to redesign

their vehicle seats and/or floor pans. This was acknowledged by the

international safety community in the December 6, 1996 ISO resolution

that the rigid system is a hardware alternative that needs some time

for development, as compared to the flexible hardware option. (See

section IV.a., supra.) The agency's proposal would allow the long term

rigid anchors solution to coexist with the UCRA approach that is

available today. Even though the proposed lead time of 24 months may

not be sufficient for the rigid anchorage hardware technology, the

proposed rule provides vehicle manufacturers with the option of

implementing the rigid system (with connectors) once it is developed,

while providing a UCRA-type system in the short term.

IX. Rulemaking Analyses and Notices

a. Executive Order 12866 (Federal Regulation) and DOT Regulatory

Policies and Procedures

NHTSA has examined the impact of this rulemaking action and

determined that it is economically significant within the meaning of

Executive Order 12866 and significant within the meaning of the

Department of Transportation's regulatory policies and procedures.

NHTSA has prepared a Preliminary Economic Assessment (PEA) for this

notice which discusses issues relating to the potential costs, benefits

and other impacts of this regulatory action.

A copy of this analysis has been placed in the docket for this

rulemaking action. Interested persons may obtain copies of this

document by writing to the docket section at the address provided at

the beginning of this notice.

To briefly summarize the analysis, NHTSA estimates that the cost of

a rule requiring the UCRA system would be approximately $160 million.

The cost of the rule related to the vehicle would range, per vehicle,

from $3.88 (one UCRA in front seat only) to $7.76 (for one UCRA in

front seat and one in back seat or two UCRAs in rear seats). NHTSA

estimates that 15 million vehicles would be affected: 9 million

passenger cars and light trucks with ``adequate'' rear seats, 3 million

vehicles with no rear seat, and 3 million vehicles that can only

accommodate a forward-facing child seat in the rear seat (not a rear-

facing infant seat). The cost of the rule for vehicles is estimated to

be about $105 million. The cost of the UCRA attachments on the child

seat is estimated to be about $55 million (3.9 million child restraints

(excluding belt-positioning boosters) at $14 per seat).

The benefits of the rule are estimated to be 24 to 32 lives saved

per year, and 2,187 to 3,615 injuries prevented.

As discussed in the PEA for this proposal, in view of the cost of

the UCRA attachments on a child restraint, estimated to be about $14

per restraint, NHTSA requests information on the price elasticity of

child restraints. NHTSA is concerned about the potential effects of

this rule on the purchase behavior of consumers. As one participant in

the October 1996 workshop pointed out, if consumer demand is

sufficiently sensitive to new car seat prices, the resulting changes in

car seat usage could partially or totally offset the benefits of the

proposed rule. NHTSA has estimated that the proposed rule will raise

the price of the average car seat by $14. For a $50 car seat, this

represents a 28 percent increase in price. On the other hand, each of

the States and the District of Columbia require the use of child

restraints in motor vehicles. To what extent, if at all, would an

increase in the price of a child restraint lead to a decrease in demand

for the product, notwithstanding child restraint use laws mandated by

each State? Also, NHTSA and child restraint manufacturers have been

inundated with calls from parents asking for help in installing seats

correctly. Would this interest in child safety motivate a sufficiently

large number of people to pay $14 for changes to a child restraint that

would make a restraint easier to install and more secure on a vehicle

seat? NHTSA is especially interested in comments from consumers on

these questions.

Consumers have essentially four choices: buy a car seat despite the

higher price, buy a used seat, seek a giveaway or loaner program, or

forego the seat altogether. If a 28 percent price increase were to

result in a 10 percent decrease in new sales and thus a corresponding

decline in usage (assuming options two and three are not available),

then the estimated benefits of the rule (24 to 32 fatalities prevented

per year) could be offset by an estimated 24 fatalities from reductions

in the number of seats in use. Consumers turning to the used car seat

market would receive no benefit from the proposed rule. The offsetting

effects would be reduced if there is a corresponding increase in

giveaway and loaner programs, but by virtue of the price increase these

programs would have to find new or additional funding.

The agency does not know how many programs exist and requests

information on this issue. A cost increase could result in fewer seats

being purchased by the program for loan or giveaway. On the other hand,

persons responsible for some State loaner/giveaway programs informed

the agency that if the new seats cost more, they would be able to find

the funding to keep up with demand. They also said that the time saved

installing child seats in each vehicle and making adjustments would be

worth the difference in price.

Unfortunately, NHTSA has not located any data or estimates of the

actual sensitivity of new child restraint sales to price changes. For

the sake of comparison, a large proportion of consumer goods exhibit

greater sensitivity to price than that described in the hypothetical

example above, even in the short run. If new child restraint purchases

in fact exhibit the same magnitude of price sensitivity as many other

consumer goods, the proposed rule could increase rather than reduce the

overall risks to the Nation's children.

For these reasons, NHTSA strongly encourages data, analyses, and

comment on this issue. The agency also requests comments on ways to

mitigate these effects, such as ways to minimize effects on price. For

example, the $14 cost increase includes the cost of two buckles that

attach to latchplates of the

[[Page 7876]]

UCRA system on the vehicle. Would costs be reduced if the latchplates

were part of the child restraint and the buckles part of the vehicle

system? This assumes that the buckle hardware is of higher cost than

the latchplates. Should NHTSA conclude that both (1) the combination of

expected child restraint price changes and consumer sensitivity to

those price changes is sufficiently large and (2) there are no cost-

effective ways to mitigate these effects such that the final rule will

result in a net increase in child safety, NHTSA would need to

reconsider the proposal.

b. Regulatory Flexibility Act

The Regulatory Flexibility Act of 1980 (Public Law 96-354), as

amended, requires agencies to evaluate the potential effects of their

proposed and final rules on small businesses, small organizations and

small governmental jurisdictions. Section 603 of the Act requires

agencies to prepare and make available for public comment an initial

regulatory flexibility analysis (IRFA) describing the impact of

proposed rules on small entities. NHTSA has included an IRFA in the PEA

for this proposal.

NHTSA tentatively believes that the proposed rule could have a

significant impact on a substantial number of small entities. The

proposed rule would affect motor vehicle manufacturers, almost all of

which would not qualify as small businesses, and portable child

restraint manufacturers. NHTSA estimates there to be about 10

manufacturers of portable child restraints, four or five of which could

be small businesses.

Business entities are generally defined as small businesses by

Standard Industrial Classification (SIC) code, for the purposes of

receiving Small Business Administration assistance. One of the criteria

for determining size, as stated in 13 CFR 121.601, is the number of

employees in the firm. There is no separate SIC code for child

restraints, or even a category that they fit into well. However, there

are categories that could be appropriate. To qualify as a small

business in the Motor Vehicle Parts and Accessories category (SIC

3714), the firm must have fewer than 750 employees. The agency has

considered the small business impacts of this proposed rule based on

this criterion. On the other hand, to qualify as a small business in

the category including manufacturers of baby furniture, the firm must

have fewer than 500 employees. Comments are requested on which Standard

Industrial Classification code would best represent child restraint

manufacturers.

The IRFA discusses the possible impacts on small entities and

requests information that would assist NHTSA in further analyzing those

impacts. As discussed in the IRFA, the incremental cost increase of $14

to the current price of a child restraint would significantly raise the

price of child restraints, which could have a significant economic

impact on a substantial number of small businesses. NHTSA does not know

the elasticity of demand for child restraints. While child restraint

use is mandated by each State, there is significant nonuse of

restraints. An increase in the price of a child restraint could lead to

a decrease in demand for the product, notwithstanding the restraint use

laws.

According to information from Cosco (see summary, above, of NHTSA's

October 1996 public workshop), the average purchase price of a

convertible car seat today is $63. About 25 percent of the car seats

purchased cost $50 or less; less than five percent cost $100 or more.

Cosco estimated that at least 10 percent of the people would not be

able to purchase a car seat if prices increased significantly.

Comments are requested on the effect that raising child restraint

prices by $14 (UCRA attachments) to possibly $100 (hard anchor system)

would have on small businesses that manufacture child restraints. Would

an across-the-board increase in price reduce small business sales? What

is the magnitude of the impact?

As discussed above in section IX.a., a loaner program could have

fewer seats available. Assuming that would be the case, NHTSA seeks

information on the extent to which the number of seats a program makes

available impacts on the organization itself. For example, do proceeds

from loaner or giveaway programs (where a nominal fee might be charged)

support the not-for-profit organization's activities?

NHTSA tentatively believes that there are no alternatives to the

proposal which would accomplish the stated objectives of 49 U.S.C.

Sec. 30101 et seq. and which would minimize any significant economic

impact of the proposed rule on small entities. As discussed above in

section V.c., ``Discussion of Alternatives,'' NHTSA considered a number

of other approaches to minimize or eliminate incompatibility between

child seats and vehicle seats. SAE Recommended Practice J1819,

``Securing Child Restraint Systems in Motor Vehicle Rear Seats,'' does

not appear sufficient alone to solve incompatibility problems. It is a

tool for evaluating incompatibility, not a requirement that vehicle

seats and child restraints must be compatible. Further, it is very

difficult for a single system to optimize the safety protection for

adults of all ranges and child restraints of different types. The

current ``lockability'' requirement does not appear sufficient alone in

addressing incompatibility, because it still depends on the user

knowing enough and making the effort to manipulate and correctly route

the belt system. Also, the lockability requirement does not address

incompatibility problems arising from forward-mounted seat belt

anchors. The ``Car Seat Only (CSO)'' system suggested by Cosco probably

would not make attaching a child seat significantly easier than it is

today. The CSO belt would have to be correctly routed through the child

restraint, which is a problem occurring with present seats, and appears

hard to tighten. Also, Cosco provided no information showing that the

CSO belt would improve the securement of a child restraint on contoured

(especially humped) seats. Another concern relates to the potential for

inadvertent use by an adult occupant.

Comments are requested on possible alternatives to the proposal

which mitigate any significant economic impact of the proposed rule on

small entities, while accomplishing the objectives of 49 U.S.C.

Sec. 30101 et seq.

c. Executive Order 12612

This proposed rule has been analyzed in accordance with the

principles and criteria contained in Executive Order 12612, and the

agency has determined that this proposal does not have sufficient

federalism implications to warrant the preparation of a Federalism

Assessment.

d. Unfunded Mandates Reform Act

The Unfunded Mandates Reform Act of 1995 (Pub. L. 104-4) requires

agencies to prepare a written assessment of the costs, benefits and

other effects of proposed or final rules that include a Federal mandate

likely to result in the expenditure by State, local or tribal

governments, in the aggregate, or by the private sector, of more than

$100 million annually. NHTSA has included an evaluation in the PEA for

this proposal. The costs and benefits of the proposal are discussed

above and throughout the PEA. (As explained above, the cost would be

approximately $105 million for vehicles, and $55 million for child

restraints. The benefits would be saving approximately 24 to 32

children's lives per year, and preventing 2,187 to 3,615 injuries. An

independent means of attaching child restraints would also enable

vehicle manufacturers to optimize the design of vehicle belt systems

for adult occupants.)

[[Page 7877]]

Participants in a NHTSA public meeting held in March 1995 at the

Lifesavers National Conference on Highway Safety Priorities, who

typically work in State highway traffic safety agencies, community

traffic safety programs and State or local law enforcement agencies,

expressed strong support for a requirement for a universal child

restraint anchorage system, such as that proposed in this NPRM. Support

for a universal child restraint anchorage system, such as that proposed

in the NPRM, was also expressed at NHTSA's October 1996 public workshop

on various types of anchorage systems. As discussed above in sections

V.c. and IX.b., and in the PEA, the agency does not believe that there

are feasible alternatives to the proposal, including SAE Recommended

Practice J1819, the lockability requirement or Cosco's CSO system.

e. National Environmental Policy Act

NHTSA has analyzed this rulemaking action for the purposes of the

National Environmental Policy Act. The agency has determined that

implementation of this action would not have any significant impact on

the quality of the human environment.

f. Executive Order 12778 (Civil Justice Reform)

This proposed rule does not have any retroactive effect. Under

section 49 U.S.C. 30103, whenever a Federal motor vehicle safety

standard is in effect, a state may not adopt or maintain a safety

standard applicable to the same aspect of performance which is not

identical to the Federal standard, except to the extent that the state

requirement imposes a higher level of performance and applies only to

vehicles procured for the State's use. 49 U.S.C. 30161 sets forth a

procedure for judicial review of final rules establishing, amending or

revoking Federal motor vehicle safety standards. That section does not

require submission of a petition for reconsideration or other

administrative proceedings before parties may file suit in court.

X. Comments on the Proposal

Interested persons are invited to submit comments on the proposal.

It is requested, but not required, that 10 copies be submitted.

All comments must not exceed 15 pages in length. (49 CFR 553.21).

Necessary attachments may be appended to these submissions without

regard to the 15-page limit. This limitation is intended to encourage

commenters to detail their primary arguments in a concise fashion.

If a commenter wishes to submit certain information under a claim

of confidentiality, three copies of the complete submission, including

purportedly confidential business information, should be submitted to

the Chief Counsel, NHTSA, at the street address given above, and seven

copies from which the purportedly confidential information has been

deleted should be submitted to the Docket Section. A request for

confidentiality should be accompanied by a cover letter setting forth

the information specified in the agency's confidential business

information regulation. 49 CFR Part 512.

All comments received before the close of business on the comment

closing date indicated above for the proposal will be considered, and

will be available for examination in the docket at the above address

both before and after that date. To the extent possible, comments filed

after the closing date will also be considered. Comments received too

late for consideration in regard to the final rule will be considered

as suggestions for further rulemaking action. Comments on the proposal

will be available for inspection in the docket. The NHTSA will continue

to file relevant information as it becomes available in the docket

after the closing date, and it is recommended that interested persons

continue to examine the docket for new material.

Those persons desiring to be notified upon receipt of their

comments in the rules docket should enclose a self-addressed, stamped

postcard in the envelope with their comments. Upon receiving the

comments, the docket supervisor will return the postcard by mail.

List of Subjects 49 CFR Part 571

Imports, Motor vehicle safety, Motor vehicles.

PART 571--[AMENDED]

In consideration of the foregoing, NHTSA proposes to amend 49 CFR

Part 571 as set forth below.

1. The authority citation for Part 571 would continue to read as

follows:

Authority: 49 U.S.C. 322, 30111, 30115, 30117 and 30166;

delegation of authority at 49 CFR 1.50.

2. Section 571.210a would be added to read as follows:

Sec. 571.210a Standard No. 210a; Child restraint anchorage system.

S1. Purpose and scope. This standard establishes requirements for a

system for anchoring child restraint systems to increase the likelihood

that child restraints are properly secured in motor vehicles.

S2. Application. This standard applies to passenger cars, and to

multipurpose passenger vehicles, trucks and buses with a GVWR of 10,000

pounds or less, except walk-in van-type vehicles and vehicles

manufactured to be sold exclusively to the U.S. Postal Service.

S3. Definitions.

Child restraint anchorage means any component involved in

transferring child restraint loads to the vehicle structure, including

but not limited to, the attachment hardware on the vehicle structure,

webbing and straps attached to the vehicle and hardware attached

thereto, the seat frames, seat pedestals, and the vehicle structure

itself.

Child restraint anchorage system means a system that is designed

for attaching a child restraint to a vehicle at a particular designated

seating position and for transferring child restraint loads to the

vehicle structure and that consists of--

(1) Two lower child restraint anchorages at the seat bight; and

(2) A tether anchorage for attaching a top tether strap of a child

restraint system.

Child restraint apparatus means the fixture depicted in Figures 1,

2 and 3 of this standard which simulates the dimensions of a child

restraint, and which is used to determine the space required by the

child restraint and the location and access to the lower anchorages.

Seat bight means the intersection of the vertical plane tangent to

the forward most point of the seat back and the horizontal plane

tangent to the uppermost point of the seat cushion.

Tether anchorage is defined in 49 CFR 571.210b, ``Tether anchorages

for child restraint systems.''

S4. Requirements. Each motor vehicle shall meet the requirements in

this section when, as specified, tested in accordance with S5 and this

paragraph.

S4.1 Type.

(a) Except as provided in S4.1(b) through (d) of this section, each

vehicle shall be equipped with a child restraint anchorage system for

at least two rear designated seating positions.

(b) A vehicle may be equipped with a built-in child restraint

system conforming to the requirements of Standard No. 213 (49 CFR

571.213) in lieu of one of the child restraint anchorage systems

required by S4.1(a) of this section.

(c) A vehicle that meets the conditions concerning rear seats in

either S4.5.4.1(a) or S4.5.4.1(b) of Standard No. 208 (49 CFR 571.208)

and

[[Page 7878]]

that has an air bag cutoff switch meeting the requirements of S4.5.4 of

Standard 208 shall have a child restraint anchorage system installed

for a designated seating position in the front seat, and for a position

in the rear seat if the vehicle has a rear seat.

(d) A vehicle that has no forward-facing designated seating

positions to the rear of the front seating positions and no air bag

cutoff switch meeting the requirements of S4.5.4 of Standard 208, shall

not have a child restraint anchorage system installed for a designated

seating position in the front seat.

S4.2 Lower anchorages.

The child restraint anchorage system shall have two lower

anchorages and shall conform to either S4.2.1, or S4.2.2 and S4.2.3, at

the manufacturer's option.

S4.2.1 Flexible anchorages.

S4.2.1.1 Configuration and Geometry.

A child restraint anchorage system shall incorporate two lower

anchorages with latchplates conforming to the configuration and

geometry specified in Figure 4 of this standard.

S4.2.1.2 Location.

(a) When fully extended in a plane parallel to the vehicle's

longitudinal axis, the centerlines of the two latchplates are 280 mm

apart.

(b) When fully extended in a plane parallel to the vehicle's

longitudinal axis, the tip of each latchplate must not extend more than

50 mm forward of the seat bight.

S4.2.1.3 Strength.

When tested in accordance with S5 of this standard, a child

restraint anchorage system shall meet the following requirements:

(a) No portion of the latchplate for each lower anchorage shall

pass through a vertical, transverse plane that is 125 mm forward of the

seat bight; and

(b) There shall be no complete separation of any anchorage

component component (including webbing, straps, hooks and buckles,

latchplates, adjustment and attachment hardware and retractors).

S4.2.2 Rigid or semi-rigid anchorages.

S4.2.2.1 Configuration and geometry.

A child seat anchorage system shall incorporate two lower

anchorages that are 6 mm diameter transverse horizontal round bars with

a minimum length of 25 mm.

S4.2.2.2 Location.

(a) The transverse spacing of the bars shall be 280 mm, center-to-

center.

(b) The lower anchorage bars are located with respect to the child

restraint apparatus rearward extensions as shown in Figures 2 and 3 of

this standard, with the child restraint apparatus placed on the vehicle

seat cushion and against the vehicle seat back. Anchorage bars that are

rigidly supported are to be 50 mm rearward of the rearmost surface of

the fixture, while semi-rigidly supported bars may be located from 50

mm rearward to 10 mm forward of that surface. The center of rigidly

supported lower anchorage bars shall be at least 120 mm behind the

vehicle seating reference point.

(c) Rigidly supported lower anchorage bars must be in a zone from

10 to 20 mm above the bottom surface of the child restraint apparatus,

while semi-rigidly supported bars must be in a zone from 0 to 20 mm

above that surface.

S4.2.2.3 Strength.

When tested in accordance with S5 of this standard, a child

restraint anchorage shall meet the following requirements:

(a) No portion of any component attaching to the lower anchorage

bars shall move forward more than 125 mm.

(b) There shall be no complete separation of any anchorage

component.

S4.2.3 Connectors.

Each vehicle equipped with lower anchorages conforming to S4.2.2 of

this standard shall be equipped with connectors that permit the

attachment of a child restraint that is equipped with components which

attach to lower anchorages conforming to S4.2.1. Each connector shall

be equipped with a latchplate conforming to the configuration and

geometry specified in Figure 4 of this standard. When attached to a

lower anchorage, the tip of each latchplate must not extend more than

50 mm forward of the seat bight when the connector is fully extended.

S4.3 Tether anchorage.

The child restraint anchorage system shall incorporate a tether

anchorage conforming to 49 CFR 571.210b, ``Tether anchorages for child

restraint systems.''

S4.4 Webbing, buckles and belt adjustment hardware.

S4.4.1 Webbing.

The webbing provided with a child restraint anchorage system

shall--

(a) After being subjected to abrasion as specified in S5.1(d) or

S5.3(c) of FMVSS No. 209 (49 CFR 571.209), have a breaking strength of

not less than 75 percent of the strength of the unabraded webbing when

tested in accordance with S5.1(b) of FMVSS 209; and

(b) Meet the requirements of S4.2(e) through (h) of FMVSS No. 209

(49 CFR 571.209).

S4.4.2 Buckles and belt adjustment hardware.

Each belt buckle and item of belt adjustment hardware used in a

child restraint anchorage system shall conform to the requirements of

S4.3(a) and S4.3(b) of FMVSS No. 209 (49 CFR 571.209).

S4.5 Marking and Guidance.

For lower anchorages conforming to S4.2.2, at least one lower

anchorage bar is to be readily visible to the person installing a child

restraint. The vehicle seat cushion or seat back shall include markings

or features to assist in the correct lateral positioning of the child

restraint system as it is moved rearward to engage the lower

anchorages.

S4.6 Instructions.

The vehicle owner's manual shall:

(a) Indicate the seating positions equipped with a child restraint

anchorage system;

(b) Include instructions that provide a step-by-step procedure,

including diagrams, for properly attaching a child restraint system to

a vehicle anchorage system equipped with lower anchorages conforming to

the requirements of S4.2.1 (with or without use of a connector); and,

(c) Include instructions for properly installing a child restraint

system in a vehicle anchorage system equipped with lower anchorages

conforming to the requirements of S4.2.2, if the vehicle is equipped

with such anchorages.

S5 Test procedures.

S5.1 Lower anchorages.

Test each lower anchorage separately, with or without connectors

provided with the vehicle. Apply a force of 5,300 N to each anchorage

in the forward horizontal direction parallel to the vehicle's

longitudinal axis. Apply the force by means of a belt strap that

extends at least 250 mm forward of the seat bight. The belt is fitted

at one end with hardware for applying the force, and at the other end

with hardware that attaches to an anchorage or connector. Apply force

to the belt strap so that the 5,300 N force is attained within 30

seconds, with an onset force rate not exceeding 135,000 N per second,

and is maintained at the 5,300 N level for at least 10 seconds.

S5.2 Tether anchorage.

Tether anchorages are tested according to the procedures specified

in 49 CFR 571.210b, ``Tether anchorages for child restraint systems.'

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Figure 1--Child Restraint Apparatus-Isometric

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Figure 2a--Child Restraint Apparatus Anchorages Front View

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Figure 2b--Child Restraint Apparatus Anchorages Side and Plan View

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3. Section 571.210b would be added to read as follows:

Sec. 571.210b Standard No. 210b; Tether anchorages for child restraint

systems

S1. Purpose and scope. This standard establishes requirements for

the strength and location of tether anchorages to ensure proper

anchoring of child restraint systems.

S2. Application. This standard applies to tether anchorages

installed in passenger cars manufactured on or after September 1, 1999,

and in multipurpose passenger vehicles, trucks and buses manufactured

on or after September 1, 2000.

S3. Definitions.

Tether anchorage means any component that transfers loads from

tether anchorage hardware to the vehicle structure.

Tether anchorage hardware means any component that transfers tether

strap loads to a tether anchorage and is designed to accept a tether

strap hook.

Tether strap means a device that is fitted with a tether strap hook

and secured to the rigid structure of a child restraint system and that

transfers the load from that system to the anchorage hardware.

Tether strap hook means a device, illustrated in Figure 11 of

Standard No. 213 (49 CFR 571.213), used to attach a tether strap to

tether anchorage hardware.

S4. Requirements. Each tether anchorage shall meet the requirements

of this section.

S4.1 Configuration.

S4.1.1 Except as provided by S4.1.2, each tether anchorage shall--

(a) Be equipped with tether anchorage hardware that is easily

accessible and that permits the attachment of a tether hook meeting the

configuration and geometry specified in Figure 11 of Standard No. 213

(49 CFR 571.213) of this section;

(b) Be located in accordance with S4.2 of this section; and

(c) Be sealed to prevent the entry of exhaust fumes.

S4.2 Anchorage positioning requirements.

S4.2.1 Passenger cars and multipurpose passenger vehicles. The

vertical centerline of each tether anchorage and each tether anchorage

hardware component shall be located within the shaded zone shown in

Figures 2, 3, 4 and 8 of this standard, with reference to the shoulder

reference point of a template described in section 3.1 of SAE Standard

J826 (June 1992), where

(a) The H-point of the template is located at the unique Design H-

point of the seat, as defined in section 2.2.11.1 of SAE Recommended

Practice J1100 (June 1993), at the full rearward and downward position

of the seat;

(b) The torso line of the template is at the same angle from the

vertical plane as the seat back with the seat adjusted to its full

rearward and full downward position and the seat back in its most

upright position; and,

(c) The template is positioned in the vertical longitudinal plane

that contains the H-point of the template.

S4.2.2 Trucks and buses. Subject to S4.3.2.1, the vertical

centerline of each tether anchorage and each tether anchorage hardware

in a truck or bus shall be located within the shaded zone shown in

Figures 5, 6, 7, and 8 of this standard, with reference to the H-point

of a template described in section 3.1 of SAE Standard J826 (June

1992), where

(a) The H-point of the template is located at the unique Design H-

point of the seat, as defined in section 2.2.11.1 of SAE Recommended

Practice J1100 (June 1993), at the full rearward and downward position

of the seat;

(b) The torso line of the template is

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