Federal Motor Vehicle Safety Standards; Child Restraint Systems; Child Restraint Anchorage Systems
Federal RegisterAug 31, 1999
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SUMMARY: This document responds to some of the issues raised by
petitions for reconsideration of a March 1999 final rule establishing
Federal Motor Vehicle Safety Standard No. 225, Child Restraint
Anchorage Systems. The standard requires vehicle manufacturers to
install the upper (tether) anchorages of universal child restraint
anchorage systems, beginning September 1, 1999, and lower anchorages of
those systems beginning September 1, 2000. This fall, we plan to
publish a second document responding further to the petitions.
In response to concerns of several petitioners about leadtime for
and the stringency of the anchorage strength and other requirements in
the March 1999 final rule, this document permits vehicle manufacturers
to meet alternative requirements during an initial several year period.
During this period, manufacturers have the alternative of meeting
either the requirements in the March 1999 final rule or the less
stringent Canadian requirements for tether anchorages, and those set
forth in a draft standard being developed by a working group of the
International Organization for Standardization (ISO) for lower
anchorages. The temporary alternative for tether anchorages lasts until
September 1, 2001, and that for lower anchorages until September 1,
2002.
This document also clarifies the test procedures used to test
tether anchorages and the lower child restraint anchorage systems;
excludes shuttle buses from the standard; denies petitions from the
Coalition of Small Volume Automobile Manufacturers and Indiana Mills
and Manufacturing; and makes technical amendments to correct some of
the figures and other portions of the March 1999 final rule, including
amendments to Standard No. 213.
DATES: The amendments made in this rule are effective September 1,
1999.
Petitions for reconsideration of this rule must be received by
October 15, 1999.
ADDRESSES: Petitions for reconsideration should refer to the docket
number of this document and be submitted to: Administrator, Room 5220,
National Highway Traffic Safety Administration, 400 Seventh Street SW,
Washington, DC, 20590.
FOR FURTHER INFORMATION CONTACT:
For nonlegal issues: George Mouchahoir, PhD., (202-366-4919),
Office of Crashworthiness Standards, NHTSA.
For legal issues: Deirdre R. Fujita, Esq., Office of the Chief
Counsel (202-366-2992), NHTSA.
Both of these officials can be reached at the National Highway
Traffic Safety Administration, 400 Seventh St., SW, Washington, DC,
20590.
SUPPLEMENTARY INFORMATION:
I. Summary of March 1999 Final Rule
a. Final rule
b. Key implementation dates
c. Rationale for the compliance dates for the final rule
II. Petitions for Reconsideration of Final Rule
III. Response to Petitions
a. Universal child restraint anchorage systems for motor
vehicles
1. Leadtime
A. Tether anchorage
B. Lower anchorages
C. General issues about the options
2. Harmonization
3. Notice and opportunity to comment
4. Other issues
A. Procedures for testing tether anchorages
B. Issues relating to the application of the standard
C. Written instructions
b. Requirements for child restraints relating to September 1,
1999 compliance date
1. Audible or visual indication of attachment
2. Attachments must be permanent
c. Reasons for the effective date of this rule
IV. Corrections to Final Rule
V. Rulemaking Analyses and Notices
a. Executive Order 12866 (Federal Regulation) and DOT Regulatory
Policies and Procedures
b. Regulatory Flexibility Act
c. Executive Order 12612
d. Unfunded Mandates Reform Act
e. National Technology Transfer and Advancement Act
f. National Environmental Policy Act
g. Executive Order 12778 (Civil Justice Reform)
h. Paperwork Reduction Act
I. Summary of March 1999 Final Rule
a. Final Rule
On February 27, 1999, President Clinton announced a new motor
vehicle safety standard to improve the installation of child restraints
in motor vehicles. The new rule, published by NHTSA on March 5, 1999,
requires the installation of universal systems for attaching child
restraints in vehicles (64 FR 10786). Most vehicles will be required to
have these systems at two rear seating positions. Each system will have
three anchorages: two lower anchorages and one upper anchorage. The
lower anchorages are two 6 mm round steel bars fastened to the vehicle
roughly a foot apart and positioned where the vehicle seat cushion and
seat back meet. The upper anchorage is a ring to which the upper tether
of a child restraint can be attached. In addition, an upper anchorage
will be required at a third seating position. New child seats will have
components that snap or hook onto these anchorages. By requiring an
easy-to-use anchorage system that is independent of the vehicle seat
belts, the new rule makes it easier to install child restraints
securely and will thereby increase safety for children.
To the extent consistent with safety, we sought to harmonize our
rule with requirements being considered by standard bodies and
regulatory authorities in Europe and elsewhere. We considered a number
of alternatives to the anchorage system we ultimately adopted,
including anchorage system designs developed by General Motors and by
Cosco, a child restraint manufacturer. Ultimately, we chose to
establish performance requirements that were based on a draft standard
1 developed by the International Organization for
Standardization (ISO), a worldwide voluntary federation of ISO member
bodies. While safety was the overriding consideration, we made this
decision due, in part, to the global standardization advantages
associated with a harmonized standard. We stated that we anticipated
that the ISO, which began work on an independent child restraint
anchorage system in the early 1990's, will be adopting the draft
standard as a final standard within the next year, and that
incorporation of the ISO standard into the regulations of the European
Community is likely to follow. Our rule harmonized also with a
regulatory initiative by Transport Canada to require user-ready tether
anchorages in vehicles sold in Canada.
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\1\ ISO/DIS 13216-1, Road vehicles--Child restraint systems--
Anchorages in vehicles and attachments to anchorages--Part 1:
Dimensions, strength requirements and general requirements, June 22,
1998.
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In our final rule, we adopted most of the draft ISO standard for
the lower bars and most of the requirements of the Canadian
requirements for the tether anchorages. However, our final rule also
imposed strength requirements for tether anchorages and the lower bars
that, while essentially equivalent to the
[[Page 47567]]
requirements we proposed in our NPRM, are higher than those that are
specified by the draft ISO and the Canadian standards.
Tether Anchorage
The NPRM proposed that the tether anchorage would be tested in a
static pull test. A force of 5,300 Newtons (N) would be applied by a
belt strap that attaches to the tether anchorage, and applied in the
forward horizontal direction. The 5,300 N force would be attained
within 30 seconds, with an onset force rate not exceeding 135,000 N per
second, and maintained at the 5,300 N level for one second. We proposed
that each structural component of the anchorage must withstand the
5,300 N force, and that there must not be any complete separation or
failure of any anchorage component. Each tether anchorage would be
tested separately. However, if two or more designated seating positions
on a bench seat are equipped with a tether anchorage, separate 5,300 N
forces would be simultaneously applied to each tether anchorage.
The final rule adopted a static pull test using a test fixture,
instead of a belt strap, to apply the test forces to the tether
anchorage. The fixture has a configuration representative of a child
restraint system. The fixture is attached to the tether anchorage at
the fixture's top, and is attached to the vehicle seat at the fixture's
bottom end (at the intersection of the vehicle seat cushion and back)
using the vehicle's seat belt or the lower bars of a child restraint
anchorage system. The test force is applied pulling on a cable that is
attached to a point on the fixture. A force of 15,000 N is applied to
the fixture, which in turn, applies the force to the three anchorage
points (the tether anchorage and the seat belt anchorages or the lower
bars). Since the fixture is attached to three anchorage points, only a
portion of the 15,000 N force is actually applied to the tether
anchorage. The 15,000 N force is attained within 30 seconds, at an
onset force rate of not more than 135,000 N per second; and maintained
at the 15,000 N level for one second. The final rule requires that (a)
there must not be any point on the tether anchorage displaced more than
125 millimeters (mm) (approximately 5 inches); and (b) there must not
be complete separation of any anchorage component. Each tether
anchorage is tested separately, unless two or more designated seating
positions in a row of seats have a tether anchorage. In that case,
NHTSA has the option of testing both tether anchorages simultaneously.
Lower Anchorages
The NPRM proposed that the lower anchorages would also be tested in
a static pull test using a belt strap. Each lower anchorage at a
seating position would be tested separately from the other. A force of
5,300 N would be applied to the anchorage in the forward horizontal
direction. The 5,300 N force would be attained within 30 seconds, with
an onset force rate not exceeding 135,000 N per second, and maintained
at the 5,300 N level for ten seconds. The NPRM proposed that lower bars
conforming to the draft ISO standard were one of the means that could
be installed to meet the requirement to provide the lower anchorages of
a child restraint anchorage system. The NPRM proposed requiring that no
portion of any component attaching to the lower bar could move forward
more than 125 mm, and that there must not be complete separation of any
anchorage component.
The final rule required that bars be used as the lower anchorages
and adopted the method of testing lower bars set forth in the draft ISO
standard. That method uses a test fixture, representing a child
restraint system, that has attachments at the bottom end of the fixture
(at the intersection of the vehicle seat cushion and back) to attach to
the lower bars. The test force is applied by pulling on a cable that is
attached to a point on the fixture. A horizontal force of 11,000 N is
applied to the fixture, which in turn, simultaneously applies the force
to the two lower bars (the tether anchor is not attached). Since the
fixture is attached to both bars, the force is divided between them.
The 11,000 N force is attained within 30 seconds, at an onset force
rate of not more than 135,000 N per second; and maintained at the
11,000 N level for ten seconds. The final rule requires that the lower
bars must not allow a specified point on the test fixture to be
displaced more than 125 mm during the pull. The final rule specifies
that in the case of vehicle seat assemblies equipped with more than one
child restraint anchorage system, NHTSA has the option of testing the
child restraint anchorage systems simultaneously or testing the systems
separately.
b. Key Implementation Dates
The key implementation dates (mandatory compliance dates) in the
March 1999 final rule were:
1. Beginning September 1, 1999--
Motor vehicles
Eighty (80) percent of passenger cars must have a tether anchorage
for each of a specified number of designated seating positions. Any
voluntarily-provided lower bars of a child restraint anchorage system,
and any voluntarily-provided additional tether anchorages, in any
passenger car, light truck, bus and multipurpose passenger vehicle
(MPV) must meet the strength and other requirements of the standard.
Child restraints
Child restraint systems are required to comply with a more
stringent head excursion performance requirement. Effectively, this
means most must have top tether straps.
2. Beginning September 1, 2000--
Motor vehicles
All passenger cars and light trucks, buses and multipurpose
passenger vehicles (MPVs) must have specified number of tether
anchorages.
A specified percentage of passenger cars, and light trucks, buses
and MPVs must have lower anchorages.
3. On or after September 1, 2002--
Motor vehicles
All passenger cars, and all light trucks, buses and MPVs must have
the new lower anchorages for a specified number of seating positions.
Child restraints
Child restraint systems must have components that attach to the
lower bars.
c. Rationale for the Compliance Dates for the Rule
Our effective dates for requiring the universal child restraint
anchorages balanced several real world needs. Manufacturers need lead
time to develop and implement designs for the anchorage system,
particularly those for the lower bars, and to test their vehicles for
compliance with the standard and to so certify. However, we wanted
manufacturers to begin to provide the anchorages as quickly as possible
because a universal child restraint anchorage system will enhance the
safety of child restraints by making them easier to install securely
than by means of a vehicle's seat belt system. Our rule sought to
balance those needs by:
(1) Phasing-in the requirement for the lower bars over a three-year
period, beginning in 2000 (S4.3); and
(2) Requiring manufacturers to begin providing the user-ready upper
anchorages on September 1, 1999 (S4.2).
We believed that the requirement for user-ready upper anchorages
could be
[[Page 47568]]
implemented in most passenger cars 2 beginning September 1,
1999 and a year later in other types of vehicles because almost all new
vehicles sold in this country already have (unexposed, non-user-ready)
tether anchorages to meet a longstanding Canadian requirement for non-
user-ready anchorages. We also selected the September 1, 1999 date
because it is the compliance date that Canada had adopted for user-
ready tether anchorages in new passenger cars sold in that country.
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\2\ The requirements are phased-in to apply to 80 percent of a
manufacturer's production of passenger cars manufactured between
September 1, 1999 and August 31, 2000, and to all passenger cars
manufactured on or after September 1, 2000.
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Another need addressed by our implementation dates for the final
rule was to assure that any child restraint anchorage system or tether
anchorage installed in a vehicle will meet minimum performance
requirements, regardless of whether the system was a ``required
system'' or a ``voluntarily-installed system.'' This was done to ensure
that all of the 3-point child restraint anchorage systems provide at
least a minimum level of safety. Accordingly, we required that:
(3) any child restraint anchorage system or tether anchorage
installed in any new vehicle after September 1, 1999, must meet the
configuration, location and strength requirements of the standard
(S4.1).3
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\3\ Today's document also corrects S4.1 to include marking
requirements among those that voluntarily-installed anchorage
systems must meet.
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II. Petitions for Reconsideration of Final Rule
We received petitions for reconsideration of the final rule from
the Alliance of Automobile Manufacturers (``Alliance'') (whose members
are BMW, DaimlerChrysler, Ford, General Motors, Mazda, Nissan, Toyota,
Volkswagen, Volvo, Fiat and Isuzu), and from Honda, Volkswagen,
Porsche, DaimlerChrysler, General Motors, Mitsubishi, the National
Truck Equipment Association, Kolcraft, E-Z-On Products, Cosco, Toyota,
Ford, the Coalition of Small Volume Automobile Manufacturers, and
Indiana Mills and Manufacturing. See NHTSA Docket No. 98-3390, Notice
2.
The petitioners generally embrace the underlying tenet of the rule
that there is a need for tether anchorages and universal child
restraint anchorage systems to improve the securement of child
restraints in vehicles. Nevertheless, vehicle manufacturers ask us to
reconsider certain performance and other requirements. Some of them are
concerned about the strength requirements for the tether anchorage and
the lower bars, and assert that: (1) There is no safety need for
requirements as stringent as those specified; 4 (2) tether
anchorages installed in their model year (MY) 2000 vehicles were
designed to meet the less stringent Canadian requirements and they will
not be able to meet the requirements in the final rule by September 1,
1999; (3) they are unable to assure that voluntarily-installed
anchorages planned for their MY 2000 vehicles will meet the
requirements by September 1 of this year, and thus would have to ``tear
out'' voluntarily-installed additional anchorages that they had already
installed in vehicles slated for completion after September 1, 1999;
and (4) sufficient notice and opportunity to comment was not provided
for the requirements. The Alliance suggests that the agency either
adopt the Canadian requirements for the tether and the draft ISO
requirements for the lower bars, or delay the effective date for the
rule to allow manufacturers to modify their current anchorage designs.
These and the other petitioners also petition for reconsideration of a
number of other issues, including issues regarding the specific test
procedures of the rule and the application of the requirements to
particular types of vehicles or seating positions.
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\4\ Not all petitioners addressing this subject believe the
strength requirements were too stringent. Petitioner E-Z-On Products
suggest in its petition for reconsideration that we should consider
increasing the strength requirements for the tether anchorage.
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III. Response to Petitions
This document focuses on immediate problems that vehicle
manufacturers are having in certifying compliance with requirements
that will apply to them beginning on September 1, 1999. As noted above,
that is the date on which they must begin equipping new passenger cars
with tether anchorages meeting the configuration, location, strength
and marking requirements in the March 1999 final rule. It is also the
date on which voluntarily-installed tether anchorages and lower
anchorage bars must meet those requirements. This document also
addresses some other concerns as well, including suggestions for
clarifying certain steps and procedures for testing the anchorages and
requests to reconsider requirements of the final rule for child
restraint systems. We will respond to the remaining issues raised in
the petitions in separate documents that will be published in the near
future.
The key changes to those implementation dates made by today's final
rule are as follows:
From September 1, 1999 to August 31, 2001: tether
anchorages may meet strength and other requirements (i.e., those
specifying where anchorages may be located, and how many must be
provided in vehicles and in what seating positions they must be
provided) promulgated by Transport Canada instead of the requirements
set forth in the March 1999 final rule. This option will cease to be
available on September 1, 2001.
From September 1, 1999 to August 31, 2002: lower anchorage
bars may meet strength and other requirements (i.e., those specifying
anchorage dimension and location, stow ability, and marking) set forth
in a draft standard issued by the ISO instead of the requirements set
forth in the March 1999 final rule. This option will cease to be
available on September 1, 2002.
a. Universal Child Restraint Anchorage Systems for Motor Vehicles
1. Leadtime
As noted above, two requirements relating to child restraint
anchorage systems go into effect on September 1, 1999: (a)
manufacturers of passenger cars must provide the user-ready tether
anchorages; \5\ and (b) manufacturers must ensure that any tether
anchorage or child restraint anchorage system installed in any new
vehicle, voluntarily or pursuant to the standard, meets the
configuration, location, strength and marking requirements of the
standard (S4.1).
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\5\ The requirement for passenger cars is phased-in, beginning
September 1, 1999, with all cars required to meet the requirement as
of September 1, 2000. The compliance date for installing user-ready
tether anchorages in light trucks, multipurpose passenger vehicles,
and buses is September 1, 2000.
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The Alliance petitioned for reconsideration of the rule on the
basis of the practicability of meeting the September 1, 1999 effective
date requiring installation of user-ready tether anchorages in
passenger cars, stating that they cannot, by that date, complete the
testing that they need to do to certify that their vehicles will meet
the requirements of the final rule. They also need more time to make
interior trim and structural changes to the extent necessary to meet
the strength requirements. The Alliance states that member companies
had geared up to meet the Canadian requirements, and had completed
certification testing in passenger cars in preparation for certifying
to the same requirements in
[[Page 47569]]
the U.S.6 The Alliance states that the strength requirements
of our rule necessitate vehicle structure and interior trim changes and
that these involve ``significant tooling and lead time'' to implement.
Thus, many of their passenger car tether anchorage designs cannot be
modified in time to meet the compliance date. The Alliance suggests
that the agency either (a) Adopt the Canadian requirements for the
tether and the draft ISO requirements for the lower bars, or (b) ``at a
minimum delay the effective date for tether and child restraint lower
anchors for one year to allow manufacturers time to modify their
current anchor designs to meet these new, unique requirements.''
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\6\ The most significant differences between the Canadian
requirements and those in our final rule are:
--the magnitude of the force that is applied to the tether
anchorage (10,000 N, instead of 15,000 N);
--the rate that the force is applied to a tether anchorage in a
compliance test (Canada permits the manufacturer to specify the
force application rate, while under our test procedure NHTSA
specifies the rate; the rate of force application can affect the
stringency of the test);
--the number of tether anchorages required in multipurpose
passenger vehicles that have five or fewer seats (Canada requires
two tether anchorages, while we require three, in vehicles that have
three or more seating positions rearward of the driver); and
--the requirement to provide a tether anchorage at a center rear
seating position (Canada does not have such a requirement, while we
do).
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In addition, petitioners state that practicability problems arise
also from the requirement in S4.1 that manufacturers must ensure that
any tether anchorage or child restraint anchorage system voluntarily
installed in any new vehicle after September 1, 1999 meets the
performance requirements of the standard. The Alliance states that
member companies had completed certification testing in multipurpose
passenger vehicles, trucks and buses to comply voluntarily with the
tether anchorage requirements earlier than the September 2000
compliance date. Because the voluntarily-installed anchorages would not
meet the standard's requirements by September 1, 1999 as they are
required to under S4.1, some manufacturers would be forced to remove
anchorages in vehicles that will be completed after September 1, 1999,
or prevented from installing such anchorages in those vehicles, ``thus
depriving customers of [the anchorages'] safety benefit.'' Volkswagen
(VW) states in its separate petition that it already provides lower
anchorages designed to the draft ISO standard in its vehicles. That
petitioner states: ``if NHTSA * * * continues to maintain the
requirement in S4.1, then the provision of the systems would have to be
terminated.'' VW and the Alliance suggest that S4.1 be amended so that
voluntary systems complying with the draft ISO standard 7
(for the lower bars) and with Canadian requirements (for the tether
anchorage) are permitted.
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\7\ It is noted that ISO has not completed finalization of its
draft standard. On May 3, 1999, ISO revised the draft again.
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A. Tether anchorage. NHTSA has reviewed the issues raised by the
petitioners relating to whether it is practicable to meet the September
1, 1999 effective date for installing tether anchorages that satisfy
the requirements of the March 1999 final rule. The agency concludes
that the vehicle manufacturers are capable of meeting the strength
requirements in our March 1999 final rule for the tether anchorage with
sufficient leadtime. In fact, data from Transport Canada indicates that
many vehicles already have tether anchorages that can meet the 15,000 N
requirement. Transport Canada tested a series of 15 vehicles (1999
models), using the test procedures of its tether anchorage standard,
Canadian Motor Vehicle Safety Standard (CMVSS) 210.1, to measure loads
attained at tether anchorages of these vehicles. Tether anchorages of
12 of these vehicles did not fail when the applied load (applied by
means of a belt strap) reached a load ranging from 7,450 N to 7,884 N.
We have determined that applying a horizontal 15,000 N force to the
SFAD test fixtures results in forces of about 5,400 N applied
horizontally to the tether anchorage using SFAD 1, and about 7,000 N
applied horizontally to that anchorage using SFAD 2. (The difference is
primarily due to differences between SFAD 1 and SFAD 2 as to the
location of Point X on the test devices. Point X is where the force is
applied to the SFAD.) Thus, tether anchorages on most of the vehicles
tested by Canada sustained loads greater than the load that is
specified in our March 1999 final rule. Tether anchorages of three of
the 15 vehicles tested by Canada sustained between 6,979 N to 7,385 N.
The tether anchorages on these vehicle may or may not need to be
reinforced to meet our requirement. (These data were presented by
Transport Canada at a March 31, 1999 meeting with manufacturers in
Ottawa.)
While many vehicles may already meet the strength requirement of
the March 1999 final rule, a number of manufacturers have said that
they need time to run certification tests and analyses based on the
requirements of our final rule, as opposed to the Canadian
requirements. Some vehicle structure and trim might also have to be
changed to meet the strength requirements of the final rule. Thus,
while manufacturers that do not already comply can achieve the 15,000 N
performance required of tether anchorages in the near future, they will
need more time than the lead time provided in the final rule to make
any necessary changes and certify compliance of their vehicles with the
requirements of the final rule.
At the same time, user-ready tether anchorages installed as soon as
possible would serve a child passenger safety need because they will
increase the likelihood that parents will attach a top tether on the
child restraint system. A tethered child restraint offers improved
protection against head impact in a crash. A tether anchorage that
complies with the Canadian strength requirement will be better than no
tether anchorage at all (which would be the end result of manufacturers
removing voluntarily installed tether anchorages after September 1,
1999). Accordingly, we are amending the standard to permit
manufacturers the option of installing tether anchorages that meet
Canada's strength requirements, for a two-year interim period (until
August 31, 2001). During the interim, manufacturers can choose to meet
the Canadian requirements. The most significant differences between the
Canadian requirements and those in our final rule are Canada's
specification of a lower force (10,000 N, instead of 15,000 N) and
Canada's method of applying the force (permitting the manufacturer the
option of specifying the force application rate, instead of specifying
a range of application rates that the agency could use). During the
interim, manufacturers can assess their vehicles' ability to comply
with the 15,000 N force requirement and make structural changes to
their vehicles, as needed. Beginning September 1, 2001, all vehicles
will have to meet the 15,000 N strength requirement for all tether
anchorages, whether installed voluntarily or pursuant to our
standard.8
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\8\ Some petitioners suggest that the 15,000 N requirement is
unnecessary because Transport Canada adopted a 10,000 N requirement
and because, so they believe, a tether meeting Canada's requirements
will adequately withstand the forces that are imposed on a tether
anchorage in a crash. On the other hand, one petitioner (E-Z-On
Products) suggests that Canada's strength requirement should be
increased to a higher level, to adequately withstand forces
generated by children weighing 120 pounds or more.
To enable us to publish this document regarding the September 1,
1999 effective date of our rule as quickly as possible, we have
deferred our response to those comments to a later date. We are
evaluating these comments and will respond to them and to other
issues not addressed by today's document in a later document. For
the purposes of this notice, we believe that the 15,000 N strength
requirement is preferable to the 10,000 N requirement, for the
reasons discussed in the March 1999 final rule. Transport Canada has
publicly stated that it too is considering increasing its tether
strength requirement to 15,000 N, based on data obtained since that
country's implementation of its user-ready tether anchorage
requirement (see technical proposal, Canada Gazette Part I, March 6,
1999).
While the 15,000 N strength requirement is preferable in the
long run, we are balancing the benefits associated with tether
anchorages meeting only the Canadian requirements in the short run
against the possibility of there being no tether anchorages. Tether
anchorages meeting the Canadian requirement will still provide an
improvement to parents who might have attached a tether but did not
do so because a user-ready anchorage was not present in the vehicle.
In the short term, we are adopting an alternative allowing
compliance with a lesser requirement as a practicable temporary
approach that would reap benefits not otherwise obtainable during
the interim.
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[[Page 47570]]
The Alliance raises other issues related to their members'
designing and manufacturing vehicles to meet the requirements
established by Transport Canada for tether anchorages. Transport Canada
requires only two tether anchorages in MPVs with five or fewer
designated seating positions, while our final rule requires three
tether anchorages in these vehicles (the same number of tether
anchorages required of passenger cars). (For convenience, since most
MPVs with fewer than 6 seating positions are sport utility vehicles
(SUVs), we will refer to those MPVs as SUVs.) The Alliance states that
Transport Canada's requirement to mandate only two tether anchorages
for SUVs was based on comments submitted to it ``which stated that the
seating configurations and vehicle design constraints made the mandate
of three tether anchors in the rear seat impracticable for such
vehicles.'' Some manufacturers state in their owner's manual not to
install child restraints in the center position. The petitioner asks
that we amend our standard to require only two tether anchorages for
MPVs with five or fewer designated seating positions.
In evaluating this suggestion, we note that manufacturers have not
submitted information to NHTSA that explains why SUVs, as a vehicle
class, should have fewer tether anchorages than passenger cars or why a
third tether anchor in the rear seat of these vehicles is
impracticable. SUVs are used as passenger-carrying vehicles and are
increasing in popularity. Further, we note that the occupancy rate of
SUVs for children under 12 in the right front seat is 2.4 times that of
passenger cars. We also note that Transport Canada has indicated that
it might be revisiting this issue concerning the number of tether
anchorages it should require in SUVs. In view of the above information
and the absence of information as to why SUVs should have fewer tether
anchorages than passenger cars, we have decided to retain the
requirement for three tether anchorages in the long run. However, to
provide manufacturers with lead time to design and manufacture SUVs
with three anchorages, this rule allows manufacturers to provide only
two tether anchorages until August 31, 2001. Beginning September 1,
2001, three tether anchorages will have to be provided, if there are at
least three rear designated seating positions.
The Alliance also petitioned for reconsideration of our requirement
that a tether anchorage must be installed at a designated seating
position other than an outboard seating position, if the vehicle has
such a (center) seating position. Transport Canada does not have a
comparable requirement. The petitioner states that not all MPVs
scheduled for introduction by the 2001 model year (i.e., September 1,
2000) have designs that meet the requirement. Petitioner also states
that: ``this requirement is not practical for all [MPVs with six or
more designated seating positions]. For example, a child restraint
installed in the center position will block ingress/egress for the
third row outboard seating position in certain vehicles.''
NHTSA is relieving manufacturers from the requirement that one of
the tether anchorages must be at a center seating position, until
September 1, 2001. As a practical matter, this relief will only affect
manufacturers of vehicles with more than three rear designated seating
positions, i.e., vehicles other than passenger cars. Vehicles with
three rear designated seating positions must be equipped with three
tether anchorages. In passenger cars, the rear seat only has at most
three rear designated seating positions, so a center rear seat--
assuming there is one--will be equipped with a tether anchorage. This
amendment gives manufacturers (primarily of vehicles other than
passenger cars) until September 1, 2001 to design and manufacture
vehicles with a tether anchorage in a center seat. Until that date,
manufacturers will have the option of not providing a tether anchorage
at a center seating position, assuming they can provide the requisite
number of tether anchorages without equipping a center position. On or
after that date, a tether anchorage must be provided at a center (i.e.,
non-outboard) seating position, in vehicles with such a
position.9
---------------------------------------------------------------------------
\9\ The final rule required a tether at a non-outboard seating
position (a center position) to address the concerns of many
commenters that the center rear seating position in cars would not
have an improved means of attaching child restraints, even though
that is the position many parents in this country prefer to place
their child. (This belief is shared by the petitioner. Commenting on
a different issue, the Alliance stated on page 17 of its petition
for reconsideration that ``Alliance members believe that many
customers will want the flexibility to install a child restraint at
the center rear seat position. . .'') We believe that many parents
will want to place their child in a non-outboard seating position in
MPVs as well. These parents will either be frustrated if an improved
means of attaching child restraints is not provided at a center
position, and/or may use the non-tethered center position anyway,
and will not be able to attain for their child the improved safety
benefits of a tethered child restraint. As for practical problems
with blocking ingress/egress for the third row, we believe the
tether can be located to avoid such blockage. For example, the
tether anchor could be attached to the ceiling or to the back of the
lower part of the seat structure.
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B. Lower anchorages.This final rule also specifies that, from
September 1, 1999 until August 31, 2002, manufacturers installing the
lower bars of a child restraint anchorage system will have available a
compliance option. They may meet either all the requirements for lower
anchorages in our March 1999 final rule, or requirements in the draft
ISO standard for alternative configuration, location, strength and
marking requirements, and the requirements in our March 1999 final rule
on all other matters.10 As discussed in section III.a.1.C of
this preamble, a manufacturer's selection of a compliance option will
be irrevocable.
---------------------------------------------------------------------------
\10\ The most significant differences between the draft ISO
requirements for the lower anchorages of child restraint anchorage
systems and those in our final rule are:
a. the magnitude of the force that is applied to the lower
anchorages (11,000 N, instead of 8,000 N);
b. the rate that the force is applied to the lower anchorages in
a compliance test (the draft ISO standard specifies that the force
is fully applied within a time period of two seconds or less, while
under our test procedure NHTSA specifies the rate and the time
period for full application of the force may be up to 30 seconds);
c. the period of time that the force is held (the draft ISO
standard specifies that the 8,000 N force is held for a period of
0.25 seconds, while we specify that it is held for 10 seconds); and
d. the allowance of stowable/foldable anchorages (the draft ISO
standard permits these anchorages, while our final rule has a
requirement that precludes a stowable/foldable feature, S9.1.1(g)).
e. Other differences between our rule and the draft ISO standard
are discussed in the March 1999 final rule at 43 FR 10801-10802.
---------------------------------------------------------------------------
These amendments are made to provide manufacturers lead time to
develop lower anchorages that meet the strength requirements of our
standard. Lower anchorages meeting the draft ISO requirements will
provide an improved means of attaching child restraints. While the
11,000 N strength
[[Page 47571]]
requirement is preferable to the ISO 8,000 N requirement, we are
balancing the benefits associated with lower anchorages meeting the
draft ISO requirements in the short run against the possibility of
there being no improved means of attaching child restraints. Lower
anchorages meeting the draft ISO requirements will still provide an
improvement to parents who have difficulty attaching a child restraint
correctly in a vehicle or whose vehicle seats are incompatible with
child restraints. In the short term, we are adopting an alternative
allowing compliance with a lesser requirement as a practicable
temporary approach that would reap benefits not otherwise obtainable
during the interim. The agency is thus amending the standard to enable
manufacturers to provide child restraint anchorage systems in vehicles
as quickly as possible.
Many of the petitioners suggested that we permit rigid but
stowable/fold-away lower anchorages, as allowed in the draft ISO
standard. These petitioners have been developing stowable/fold-away
lower anchorages and believed that our final rule was going to permit
these anchorages to be installed in vehicles. Apparently these
petitioners believed that the final rule would incorporate all aspects
of the draft ISO standard, including provisions in the draft standard
for stowable anchorages. The draft standard does not expressly allow
stowable anchorages, but instead occasionally refers to various
requirements that lower anchorages have to meet while in a stored and/
or ``deployed'' condition. We are permitting stowable/fold-away anchors
during this interim period (until August 31, 2002) within which
manufacturer may meet the requirements of the draft ISO standard.
Specifications in the draft ISO standard that we have adopted in
this final rule state that the 8,000 N force that is applied in the
forward pull test and the 5,000 N force that is applied in the lateral
pull test is maintained for a period of 0.25 seconds 0.05
seconds. We interpret this hold period to mean that we may hold the
maximum force for several seconds or longer; however, the lower
anchorages must withstand the required force (i.e., meet the 125 mm
displacement limit) only for up to 0.30 seconds.
Several petitions ask us to reconsider the need for the 11,000 N
strength requirement for the lower anchorages. The 11,000 N is applied
to the lower anchorages by way of a test fixture that attaches to both
lower anchorages. NHTSA will respond to these issues in a subsequent
document responding to other issues in the petitions. In addition, we
will address suggestions concerning the test procedure used to test the
lower anchorages that are not addressed by today's document.
C. General issues about the options. This rule specifies that a
manufacturer's selection of a compliance option must be made prior to,
or at the time of vehicle certification and that selection is
irrevocable for that vehicle. The rationale for such a requirement was
explained in the March 1999 final rule as well as in other recent
agency rulemakings. To summarize, where a safety standard provides
manufacturers more than one compliance option, the agency needs to know
which option has been selected in order to conduct a compliance test.
Moreover, based on previous experience with enforcing standards that
include compliance options, the agency is aware that a manufacturer
confronted with an apparent noncompliance for the option it has
selected (based on a compliance test) may respond by arguing that its
vehicles comply with a different option for which the agency has not
conducted a compliance test. This response creates obvious difficulties
for the agency in managing its available resources for carrying out its
enforcement responsibilities, e.g., the possible need to conduct
multiple compliance tests for first one compliance option, then
another, to determine whether there is a noncompliance. To address this
problem, the agency is requiring that where manufacturer options are
specified, the manufacturer must select the option by the time it
certifies the vehicle and may not thereafter select a different option
for the vehicle. This will mean that failure to comply with the
selected option will constitute a noncompliance regardless of whether a
vehicle complies with another option. (Of course, as we have noted in
other rulemaking proceedings, a manufacturer may petition for an
exemption from the recall requirements of the statute on the basis that
the noncompliance is inconsequential as it relates to motor vehicle
safety.)
Executive Order 12866 and the President's memorandum of June 1,
1998, require each agency to write all rules in plain language.
Application of the principles of plain language includes consideration
of the following questions:
--Have we organized the material to suit the public's needs?
--Are the requirements in the rule clearly stated?
--Does the rule contain technical language or jargon that isn't clear?
--Would a different format (grouping and order of sections, use of
headings, paragraphing) make the rule easier to understand?
--Would more (but shorter) sections be better?
--Could we improve clarity by adding tables, lists, or diagrams?
--What else could we do to make the rule easier to understand?
While we generally complied with those requirements in drafting
this document, we did not make any significant changes to the Canadian
and ISO provisions regarding child restraint anchorage systems in
adding them to Standard No. 225. Since those additions are only
temporary, we did not attempt to determine whether there are any
significant opportunities for simplification or clarification of those
provisions. If anyone believes that simplification or clarification of
any of those provisions, or of any other part of the regulatory text,
is necessary, please write and tell us.
b. Harmonization
The Alliance also petitioned for reconsideration of the final rule
based on ``the lack of harmonization with other child restraint anchor
activities around the world.'' Petitioner states that the rule creates
a unique set of performance requirements that is not applied anywhere
else in the world and is not consistent with the Canadian requirements
for the tether or draft ISO requirements for the lower bars.
The most significant differences between the Canadian requirements
for tether anchorages and those in our final rule are set forth in
footnote 6, supra, and concern the magnitude of the force that is
applied to the tether anchorage and the rate that the force is applied
to a tether anchorage in a compliance test. The most significant
differences between the draft ISO requirements for the lower anchorages
of child restraint anchorage systems and those in our final rule are
set forth in footnote 10, supra, and relate to the magnitude of the
force that is applied to the lower anchorages, the rate that the force
is applied in a compliance test, and the period of time that the force
is held.
We believe that our final rule fully conforms to the agency's
policies and priorities in this area. The agency's policy is to advance
vehicle safety by identifying and adopting best safety practices from
around the world and by developing new standards reflecting
technological advances and current and anticipated safety problems.
Thus, while we seek to harmonize our safety standards with those of
other countries, we do so only to the extent consistent
[[Page 47572]]
with preserving our ability to adopt standards that meet U.S. vehicle
safety needs. ``Statement of Policy: NHTSA Priorities and Public
Participation in the Implementation of the UN/ECE 1998 Agreement on
Global Technical Regulations'' (January 5, 1999, 64 FR 563). In our
effort to harmonize with the Canadian requirements for the tether
anchorage and the draft ISO requirements for the lower anchorages, we
undertook an independent analysis of the basis for the strength
requirements for the respective anchorages. We were not aware of any
information warranting a 10,000 N force requirement for the tether. The
only data we had indicate that the level should be 15,000 N. Further,
as we said in the preamble to the final rule, we did not know why the
drafters of the draft ISO standard chose the 8,000 N requirement. We
also explained in the final rule document our reasons for differing
from the specifications in the draft ISO standard for applying the
force to the lower anchorages in the compliance test. That we set the
performance requirements based on an independent analyses is fully
consistent with NHTSA's policies and priorities on international
harmonization.
We also note that with regard to the strength requirements for the
lower bars, the draft ISO standard has not yet been adopted in final
form by any country. The draft ISO standard is still undergoing
revision by the working group charged with developing the standard.
Because no country has adopted strength or any other requirements for
the lower bars, our 11,000 N requirement, the first of its kind, is not
discordant with any other standard. We should also note that our
requirements are generally not mutually exclusive from those of Canada
for tether anchorages and those of the draft ISO standard for the lower
bars. Anchorages that are produced to meet the requirements of our
March 1999 final rule will meet all the requirements of the Canadian
and draft ISO standards.
3. Notice and Opportunity To Comment
The Alliance petitioned the agency to reconsider the strength test
procedures and requirements for tether anchorages and the lower
anchorages of a child restraint anchorage system. The Alliance argues
that the agency included these provisions in the final rule without
first giving the public an opportunity to comment on the provisions and
thus violated the informal rulemaking provisions of the Administrative
Procedure Act. The Alliance states that:
[T]he test procedures and strength requirements for the top tether
anchors and the test procedures for lower anchors were neither
proposed in the NPRM nor logically grow from it. The NPRM published
on February 20, 1997 discussed the strength requirement and test
procedure for top tethers in Part 571.210b, Section S4.4. It states
``. . . the tether anchorage with the tether anchorage hardware
installed shall, when tested in accordance with S5, withstand a
force of 5,300 N. There shall be no complete separation or failure
of any anchorage component.'' The final rule, in Section 6.3 imposes
a 125 mm deflection requirement that was not proposed or discussed
in the NPRM. In addition, the final rule, in Section 8 imposes a
test procedure that applies a 15,000 N force to a test fixture which
was not proposed or discussed in the NPRM.
The NPRM discusses the test procedure for lower anchorages in
Part 571.210a, Section S5. It states ``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 . . .'' The final rule, in Section 11, imposes a test
procedure which applies an 11,000 N force to a test fixture. This
test procedure is not proposed or discussed in the NPRM.
The agency disagrees with the Alliance. The test method adopted in
the final rule is similar to one of two alternative test methods
discussed in the NPRM in connection with assessing the real-world
performance of child restraint anchorage systems. The first approach
was to apply test forces to all anchorages, simultaneously, by means of
a child restraint. This method would also have tested child restraints
for compliance with Standard No. 213 by attaching the child restraint
to an actual vehicle anchorage system. Testing actual vehicle anchorage
systems with actual child restraints would have increased the real-
world representativeness of the test method. However, in the section of
the NPRM entitled ``Proposal for New Vehicle Standard, Highlights of
Proposal,'' we acknowledged that there were difficulties with this
approach:
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.
62 FR 7870.
Because NHTSA was concerned that testing a vehicle anchorage system
with an actual child restraint could possibly introduce factors that
could complicate enforcement efforts, the agency tentatively rejected
that alternative. We favored an alternative approach, which was to test
each anchor of a child restraint anchorage system individually by
attaching a belt strap to the anchor and pulling it at a specified
force. We discussed in the NPRM our tentative conclusion that this
alternative would replicate real-world performance, but acknowledged
that this approach also had limitations:
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. . . .
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.
Id.
Since use of the straps would avoid the problems associated with
use of child restraint systems, although at the cost of some loss of
real-world representativeness, we proposed a strength requirement and a
static pull test for the tether anchorage that were the same as the
then-Canadian proposal for user-ready tether anchorages. The agency
proposed that the anchorage would have to withstand a force of not less
than 5,300 N, applied to the tether anchorage by a belt strap (see I.a.
of this preamble, supra, for discussion of the provisions for the
strength requirements in the NPRM and final rule). In the section of
the NPRM entitled ``Proposal for New Vehicle Standard, Performance,''
the agency requested comments ``on whether more specificity is needed
for these strength requirements and on whether other performance
requirements should be included in the standard.'' 62 FR 7873.
In the final rule, we decided to apply the test forces to child
restraint anchorage systems by means of surrogates for child restraint
systems. We adopted use of the surrogates because they better simulate
the real-
[[Page 47573]]
world interaction between a child restraint and the vehicle anchorages
than testing the anchorages individually by means of a belt strap.
The adopted approach is very similar to the one we tentatively
rejected in the NPRM, i.e., the one that used actual child restraint
systems to apply the test forces. We had tentatively rejected that
approach out of concern that using child restraints in the compliance
test would introduce too many additional variables into the compliance
testing process. The decision to substitute child restraint surrogates
for actual child restraint systems adequately addressed the problem of
uncontrollable factors. The surrogates, called ``static force
application devices (SFADs)'' in the final rule, distribute the forces
generated in a crash as a child restraint does in dynamic crash
testing. However, because they are controlled test devices, their use
in compliance testing does not introduce the same potential concerns
noted above that using an actual child restraint could pose. In the
final rule, thus, we balanced the concerns underlying the interest
expressed in the NPRM in using actual child restraints to more
assuredly obtain test results related to real world performance with
the concerns also expressed in the NPRM in having the test be as
controlled as possible to remove unknown influences on the test
results.11
---------------------------------------------------------------------------
\11\ Standard No. 210 also uses test devices to apply test loads
to seat belt assembly anchorages. The devices are a pelvic body
block that represents a human pelvis and a torso block that
represents a human upper torso. Prior to our March 1999 final rule,
seat belts and seat belt anchorages were the standardized anchorage
system used to anchor child restraints in vehicles. The approach
taken by our March 1999 final rule, to use a test device to apply
the loads, is logically related to the method now used to test the
current anchorage system for child restraints.
---------------------------------------------------------------------------
The use of child restraint surrogates to test child restraint
anchorage systems in vehicles was strongly supported by the commenters.
Many vehicle manufacturers suggested that applying the load, by way of
a child restraint surrogate, to all three anchorages simultaneously
better evaluates how the tether anchorage would perform in the real
world than by testing the anchorages individually. GM suggested that
using a test fixture representative of a child restraint to apply a
test force is a more relevant measure of child restraint excursion than
the proposal. The fixture it suggested was the SFAD 1 fixture (which GM
calls ``the Structural Fixture'') ultimately adopted by our final rule.
``By using the Structural Fixture, the displacement of the CRS [child
restraint system] due to structural deformation of the anchorages is
more accurately demonstrated.'' (GM comment, page 8, and Attachment E
thereto, page 1, May 21, 1997, Item No. 96-095-N03-027 in Docket No.
96-095-N03.) GM and Ford suggested that loading all three anchorages at
one time (the two lower anchorages and the top tether anchorage) is the
most appropriate method to evaluate in a static load test how a child
restraint will perform dynamically in limiting forward excursion.
The fixtures we selected were jointly developed by the vehicle
manufacturers and Transport Canada for use in testing child restraint
anchorages in Canadian vehicles. Similar to this agency, Transport
Canada will use the SFAD 1 fixture to test tether anchorages at a
seating position that does not have the lower bars of a child restraint
anchorage system. (The fixture is attached at its bottom, at the
vehicle seat bight, by the vehicle's seat belt.) The other fixture,
``SFAD 2,'' will be used to test tether anchorages at a seating
position that has the lower bars of a child restraint anchorage system.
SFAD 2 is from the draft ISO standard ISO/DIS 13216-1. Both of these
fixtures were discussed for use in Canada's tether anchorage regulation
at a September 11, 1998 meeting between Canadian and US representatives
of vehicle and child restraint manufacturers and Canadian officials.
The meeting was organized by the Canadian Vehicle Manufacturers'
Association (CVMA). We placed a memorandum describing what we were
informed about the meeting into the docket; see 96-95-N3-00071, dated
October 31, 1997, as corrected in 96-95-N3-00071A, dated July 20, 1999.
The magnitude of the load that is to be applied to each test
fixture (15,000 N) is essentially equivalent to the magnitude of the
load that was proposed in the NPRM. Applying a horizontal 15,000 N
force to the SFAD 1 fixture, which in turn applies the load to three
anchor points on the vehicle (one of which is the tether anchor),
results in a horizontal force of about 5,400 N applied to the tether
anchorage, assuming no interference of the fixture with other vehicle
components. This was explained in the final rule, 64 FR 10808. (``This
final rule has increased this [the proposed strength requirement of
5,300 N applied horizontally to an individual anchor] to 15,000 N to
reflect the use of the fixture in testing tether anchorages.'')
Applying a horizontal 15,000 N force to SFAD 2, which in turn applies
the load to three anchor points on the vehicle, results in a horizontal
force of about 7,000 N applied to the tether anchorage, which is only
about 30 percent higher than the horizontal 5,300 N proposed in the
NPRM. In addition, as noted in the preamble to the final rule, we also
chose the force level because test data indicated that it is needed to
help ensure that tether anchorages will be able to bear the loads
generated by children in forward-facing child restraints (64 FR 10808).
In the final rule, we adopted a performance measure based on the
amount of deflection, i.e., it specified that tether anchorages must
not deflect such that a point on a test fixture moves more than 125 mm
during the application of test forces. We adopted the deflection limit
because it is a more objective measure of performance than the
requirement originally proposed in the NPRM, i.e., that an anchorage
``withstand'' the required force. The NPRM expressly requested comments
as to whether the ``withstand'' requirement and the other strength
requirements should be more specific, i.e., more objective. 62 FR 7873.
GM suggested in its comment to the NPRM that measuring movement of the
child restraint test fixture is a more relevant measure of child
restraint excursion. GM suggested in its comment that a final rule
require that a ``point I'' on the fixture must not displace more than
125 mm longitudinally from its initial position. Finally, the 125 mm
deflection requirement was proposed in the NPRM as the proposed
performance requirement for the two lower anchorages of the child
restraint anchorage system. Because those lower anchorages and the
tether anchorage together constitute a ``child restraint anchorage
system,'' it was a logical outgrowth of the NPRM that all three are
subject to the same deflection limit as a measure of acceptable
performance. By giving the public notice of the subjects and issues
being considered, and adopting changes that are a logical outgrowth of
the NPRM, the agency fully satisfied the requirements of the
Administrative Procedure Act.
With regard to the lower anchorages, we proposed that they could
consist of either a flexible latchplate system or a rigid bar anchorage
system (the system permitted by the draft ISO standard). Since the
testing of those systems presented essentially the same problems as
testing tether anchorages, we resolved those problems in the same way.
We tentatively rejected the use of child restraint systems to apply
test forces simultaneously to the lower anchorages and proposed instead
to apply test forces separately by means of a strap. Further, our
statements in the NPRM provided notice that we were determining the
appropriate level of
[[Page 47574]]
performance to mandate for the lower anchorages, and that the
requirements and procedures of the draft ISO standard were being
considered.
In response, a number of commenters urged us to adopt use of the
test fixture, representing a child restraint system, specified in the
draft ISO standard for the purpose of applying an 8,000 N force to the
lower anchorages. Comments were also provided on the levels of force
that should be applied to the anchorages, and the length of time those
should be held.
The procedures and requirements we adopted for the lower anchorages
are a logical outgrowth of the proposal. The test procedures we adopted
for testing the rigid bars are directly based on those in the draft ISO
standard. These procedures include use of a test fixture that applies
test loads to the two lower anchorages simultaneously, rather than
individually. For the reasons discussed above with respect to tether
anchorages, use of a test fixture is preferable both to testing the
lower anchorages separately using a strap and to testing them
simultaneously using actual child restraint systems. Finally, the
magnitude of the load that the final rule applies to the lower
anchorages simultaneously by way of the fixture (11,000 N) is almost
the same as the sum of the horizontal loads (10,600 N) that we proposed
in the NPRM for testing the strength of the lower anchorages (5,300 N
applied horizontally to each lower anchorage). We note that that force
level is also supported by test data (see discussion in preamble to
final rule, 64 FR 10805).
The Alliance also states that we did not provide notice and an
opportunity to comment on the requirement in the final rule to provide
three tether anchorages. The petitioner states:
The agency proposal would have had the effect of requiring only
two tether anchors, at seating positions with lower anchors. Thus
the agency has provided no notice of a requirement for a third
anchor at the center seat position, and no lead time.
We disagree with the Alliance that about the adequacy of notice. The
NPRM requested comments on the number of anchorage systems we should
require. The agency stated in the NPRM:
There was no consensus among the [14 rulemaking] 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. * * * 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.* * *
62 FR 7871.
These statements in the preamble to the NPRM provided clear notice
that we were exploring alternatives to the proposed number of required
child restraint anchorage systems. The notice specifically raised the
issues of requiring a tether anchorage in a center rear seating
position, of providing a tether anchorage at the location (center rear
seat) preferred by many parents for placing a child, and of how many
improved attachment systems are needed. Many commenters addressed the
issue of how many seating positions should have a child restraint
anchorage system, with most suggesting that an additional (i.e., third)
tether anchor should be required (if not a full child restraint
anchorage system). From these comments, we learned that many parents
will want an improved means of attaching child restraints in the center
rear seating position. We did not require that one of the two full
child restraint anchorage systems be installed in the rear center
position because it may be difficult to fit the lower anchorages of two
child restraint anchorage systems adjacent to each other in the rear
seat of small vehicles. However, we decided that a tether anchorage at
the center rear position will improve the attachment of child
restraints at that desired position and will provide parents with
flexibility in deciding where they restrain their children. Based on
the foregoing, we conclude that requiring a third tether anchorage and
one at a center seating position was a logical outgrowth of the NPRM
and that the agency fully satisfied the requirements of the APA.
4. Other issues
A. Procedures for testing tether anchorages. This section responds
to suggestions in some of the petitions for reconsideration for
amending the final rule's test conditions and procedures for testing
tether anchorages. Some petitioners believe that some of the test
conditions and procedures could be clearer and made more objective.
We have decided to adopt some of the suggestions and not adopt
others. The test conditions and procedures discussed in this section of
the document are those set forth in S7 and S8 of the final rule to test
tether anchorages that are certified as meeting the requirements of the
March 1999 final rule. As discussed today in Section III, above, until
September 1, 2001, manufacturers have the option of certifying their
tether anchorages to the requirements set by Transport Canada. Such
tethers will be tested according to the conditions and procedures in
the Canadian standard.
The Alliance suggests several changes to S8.1 of the final rule,
which specifies how the 15,000 N force will be applied to the tether
anchorage. Petitioner suggests that the initial angle of pull specified
in S8.1.(c)(2) should be 10 5 degrees, rather than ``not
more than 5 degrees.'' Petitioner explains that the angle of pull in
the final rule can cause the force application cable to rub on the SFAD
test device, thus potentially affecting the force on the tether strap.
NHTSA has made the suggested change. Interference of the SFAD on the
cable could affect the loads that are actually applied to the tether
anchorage, which is undesirable. Increasing the angle of pull to 10
5 degrees, from not more than 5 degrees, will eliminate the
potential for interference and will not significantly affect the
magnitude of the load applied to the device (the horizontal component
of the applied load may be reduced by about 3 percent).
The Alliance suggests other changes to the manner in which the test
force is applied to the tether anchorage. Petitioner suggests that
S8.1(c)(3) be amended to clarify that the requisite force is held for
one second, and not longer. We have made this change. Petitioner also
suggests that S8.1(c)(3) should permit manufacturers to select the time
period for application of the test force, as long as it is within the
30-second time limit. Such an amendment would permit the manufacturer
to load the tether anchorage with the maximum 15,000 N load in a short
period of time (relative to the 30-second time limit), e.g., 3 to 5
seconds. The petitioner states that Canada allows the vehicle
manufacturer to select the time period for application of the test
force, as long as the period is within the 30-second time limit, and
will use the manufacturer's selected force application time period in
compliance
[[Page 47575]]
testing. (We have confirmed with Transport Canada that this is
correct.)
The Alliance also questioned the absence of a specified rate of
increase of force during the test:
Because S8.1(c)(3) does not specify a linear increase in force
(or any other force/time profile), . . . [does] the agency mean to
specify a linear increase in force? Or does the agency intend to
include an infinite number of force application variations,
including increasing the force to just below the full load in less
than 1 second, and then holding at that level for the remainder of
the 30-second force application time? The results of such a force
application would vary significantly from a linear increase in
force.
We agree with the Alliance that, as written, this provision would
allow the agency to test compliance at a variety of force onset rates
and force/time profiles. While we believe that we could legitimately
provide for such variation, we are amending S8.1(c)(3) to provide for a
more specific rate of force application. Today's document specifies
that we will increase the pull force as linearly as practicable, from
the pre-load pull force of 500 N to the full force application of
15,000 N in 27 3 seconds, (i.e., not less than 24 seconds
and not more than 30 seconds).12 This means that the
compliance test laboratory will be instructed to attempt to increase
the force at a constant rate, but that variations due to the
limitations of the test equipment or the characteristics of the vehicle
will not invalidate the test. Equivalent changes will be made to S11
concerning the rate of force application for testing the lower bars of
child restraint anchorage systems.
---------------------------------------------------------------------------
\12\ Standard No. 210 does not provide any specific rate of
force increase, linear or otherwise. However, as set forth in our
Laboratory Test Procedure for Standard No. 210, we have conducted
our compliance tests using a linear increase in force over a 25-
second period.
---------------------------------------------------------------------------
We are denying petitioner's request that manufacturers be permitted
to specify the force application rate because we believe that the force
should be applied at a constant rate for as long a time period as
possible. This is to assure that the test adequately measures the
strength of the anchorage. Metal structures generally can withstand
greater forces under a faster rate of application than under a slower
one. This means that an anchorage that fails when the required force is
reached after 30 seconds might not fail if the required force is
reached in a very short period of time. Adopting the petitioner's
request could allow the use of weaker anchorages, resulting in a
possible reduction in safety. However, we will permit manufacturers who
have chosen the option of complying with the Transport Canada
requirements to specify the rate of load application during the interim
period. Manufacturers have been designing tether anchorages to meet the
Canadian requirement and will need time to reassess and possibly
reinforce the anchorage to meet the load requirement of our March 1999
final rule when the load is applied over a 27 3 second
period. We will provide them the needed leadtime, i.e., until September
1, 2001. On or after September 1, 2001, we will achieve the 15,000 N
load by increasing the load at an approximately constant rate over a 27
3 second period.
The Alliance also refers to a December 30, 1970 NHTSA
interpretation letter to Mr. Shuman of International Harvester Company
on the force application rate in Standard No. 210 to support
petitioner's view that the force application rate in Standard No. 225
is unrealistically long. Petitioner believes that the letter indicates
that we believed there is no significant difference between applying
the Standard No. 210 force in 0.1 seconds and holding it for 10 seconds
and holding the force for 39.9 seconds. Petitioner asks: ``Does the
agency now maintain that there is no significant difference between
applying peak forces for 1 second and applying peak forces for 30.9
seconds? If so, why does the agency specify unrealistically long force
application and hold times?'
The International Harvester letter concerns Standard No. 210's
specification that the force applied to seat belt anchorages is applied
within 30 seconds, and held at the maximum force level for 10 seconds.
The letter enunciates the position that if an anchorage is strong
enough to withstand the maximum force level of Standard No. 210 for 10
seconds when the required force is attained in 0.1 seconds, the
anchorage will likely be able to withstand the force held at 10 seconds
when the force is applied in a constant rate over about 30 seconds.
Even if this is correct in the context of Standard No. 210, the same
can not be assumed for child restraint tether anchorages. The force
applied to these anchorages is held for only 1 second, rather than 10
seconds. Because metal structures can generally withstand greater
forces under a faster rate of application than under a slower one,
there is a margin of safety incorporated into the load application rate
of Standard No. 225 to increase the likelihood that the anchorage will
not fail even under the most severe crash conditions.
The Alliance states that S8 specifies that the tether strap
attached to the test fixture is permitted too much variation in
elongation to objectively test the tether anchorage. The petitioner
suggests that a narrow range of elongation be specified, such as
between 7 and 9 percent at a force of 11,000 N. We have addressed this
concern by amending S8 to provide that a steel cable will be used to
attach the SFAD to the tether anchorage. The elongation of a steel
cable under load is both minimal and predictable.
The Alliance suggests that a tether hook be used to attach the
strap to the tether anchorage, rather than a ``bracket.'' Petitioner
states that without an objective bracket specification, manufacturers
cannot determine how the device will apply loads along the anchor
(e.g., along the entire anchor or concentrated at the center). However,
the Alliance states, attempts by vehicle manufacturers to apply test
forces specified in the final rule frequently break typical tether
hooks. NHTSA has amended S8 to specify use of a tether hook. The hook
that we will use will have the same overall dimensions as tether hooks
on child restraints, but will be made of high strength steel. Tether
hooks are required by S5.9(b) of Standard No. 213 to meet specified
configuration and geometry requirements.
With regard to the comment that tether hooks have broken under the
test loads specified in the final rule, we note that Transport Canada
has conducted tests that have not resulted in such breakage. In recent
tensile strength tests performed by Transport Canada, tether hooks were
able to sustain much higher loads than the loads expected in the test
specified by the final rule. Three hooks from each of four
manufacturers were tested to failure by applying a static tensile force
at an onset force rate of 135,000 N/s with a target load of 6,500 N and
held for a duration of 10 seconds. The average maximum loads observed
ranged from 8,870 N to 11,800 N. These loads are substantially higher
than the ones specified in the final rule. (These data were presented
by Transport Canada at a meeting with manufacturers, importers and
interested parties in Ottawa, Ontario, on March 30, 1999. A copy of
these data has been placed in the docket for our March 5, 1999 final
rule, 98-3390, notice 2.)
The Alliance petitioned for reconsideration of the 125 mm
displacement limit specified in S6.3.1(a) and in S6.3.2 for the tether
anchorage. As discussed in Section I of this document, the Alliance has
stated that 125 mm displacement limit was adopted without providing the
public notice of it and an opportunity to
[[Page 47576]]
comment. We responded to this comment in Section III, supra. Further,
we believe that the displacement limit is preferable to the alternative
that the tether anchorage ``withstand'' the required forces because a
displacement limit is far more objective than the latter in determining
whether an anchorage met the performance criteria. The petitioner also
states that the requirement is unclear:
It is not clear whether the agency will measure displacement
only in the direction of the tether strap, or if the total resultant
displacement calculated by combining displacement in all three
dimensions is intended. It is also not clear if the reference point
for the displacement is to be taken before or after the application
of the 500 N pre-load force. It is also unclear whether the maximum
displacement is measured under load or after the load is released.
NHTSA has amended S6.3.1 to specify that we will determine the
displacement for the tether anchor by measuring the horizontal
excursion of point X on the test device. The reference datum for this
measurement is where point X is located after preloading the SFAD with
a preload force of 500 N. From that datum, the displacement is the
total horizontal excursion that point X experiences during the loading.
This is consistent with the displacement criterion for the lower
anchorages. Standard No. 225 specifies that point X on SFAD 2 must not
be displaced more than 125 mm from where point X was after preloading.
The Alliance petitions to amend S6.2 to provide that the location
of a tether anchorage is found using the design H-point for a seat
position, rather than the actual H-point of the seat. The latter point
is determined using a three-dimensional H-point machine (3-Dimensional
seating manikin). The petitioner believes that ``[b]ecause of
variability in position of the 3-Dimensional Seating Manikin when
installed by different individuals and laboratories, the actual H-Point
as determined with the Manikin will also vary in location with respect
to the `design H-Point' for that seat position. These variations also
occur, in part, because of the poor fit of the Manikin in certain
seating positions, and differences in trim materials (e.g., cloth vs.
leather). Because of this inherent variability, the NHTSA procedure
does not objectively measure the proper position for a tether
anchorage.''
We disagree with the petitioner's concerns about the 3-dimensional
seating manikin and its use in the standard's test procedure to locate
the H-point of a vehicle seating position. We have not encountered
variability problems in our tests using the manikin. The manikin is
presently used in Federal Motor Vehicle Safety Standard No. 208,
``Occupant Crash Protection'' (49 CFR 571.208), to determine the H-
point of a seating position for positioning Hybrid III test dummies (49
CFR part 572, subpart E) in Standard No. 208 crash tests. It is also
used in Federal Motor Vehicle Safety Standard No. 214, ``Side Impact
Protection'' (49 CFR 571.214), to determine the H-point for positioning
side impact test dummies (49 CFR part 572, subpart M). Manufacturer's
representatives are usually present during our compliance tests for
these standards and are asked to check the dummy's positioning prior to
a test. The 3-dimensional seating manikin produces dummy positioning
equivalent to that obtained by manufacturers using the device in their
own test laboratories. Further, the manikin produces repeatable results
when used repeatedly in the same vehicle. We also believe that using
the 3-dimensional machine results in an H-point measurement that is
more representative of the real world than the H-point obtained through
use of the alternative suggested by the Alliance. This is because the
3-dimensional machine compresses the actual seat and provides a more
realistic H-point than that achieved on paper using the 2-dimensional
template. Further, it should also be noted that the position of the H-
point obtained using the 3-dimensional seating manikin is very close to
the H-point obtained using the 2-dimensional template. To the extent
needed, manufacturers can compensate for and design around the small
differences. Because we believe that the 3-dimensional seating manikin
yields data that are highly repeatable and reproducible and more
realistic than those obtained by the 2-dimensional template, the
request to specify the template is denied. (We are, however, specifying
that the template may be used during the two-year interim period as
part of the option allowing manufacturers to meet Canadian requirements
for the tether anchorages. Canada uses the template to determine the
location of tether anchorages.)
The Alliance suggests that the tether anchorage test procedure of
S8.1(b) be amended by adding an instruction for adjusting the fore-aft
position of the rear attaching bars of the test device used to test a
tether anchor at a seating position with a child restraint anchorage
system (the test device referred to as SFAD 2). We have added the
suggested instruction to S8.1(b). Petitioner also suggests that the
shape of the SFAD 2 attachments that contact the lower anchor bars be
specified because the shape could affect the outcome of the test. We
have modified Figure 17 of the standard to show in Detail B that the
rear of the slot in the SFAD 2 connecting arms has a diameter of 6.5
mm. The petitioner also suggests that a stiffness specification for
SFAD 2 be added as in the draft ISO standard, to ensure that the test
fixture is sufficiently strong to withstand the forces in the test. We
have added a stiffness specification, from the draft ISO standard, to
Figure 17.
Volkswagen (VW) petitioned to change the test device used to test a
tether anchor at a seating position that does not have the lower
anchorages of a child restraint anchorage system (the test device
referred to as SFAD 1). The vehicle's belts are used to attach SFAD 1
to the vehicle seat at the seat bight. A cable is used to attach the
top of SFAD 1 to the tether anchorage. VW states that ``[s]ome testing
has indicated that the design of the fixture interferes with belt
system routing requirements or geometry such that the stiff portion of
the buckle sits at the opening of the fixture rather than being inside
or outside the opening.'' The petitioner suggests that the SFAD 1
openings for the belt routing be consistent with the fixture in the
Society of Automotive Engineers (SAE) Recommended Practice J1819,
``Securing Child Restraint Systems in Motor Vehicle Rear Seats.'' J1819
specifies a common reference tool, a ``Child Restraint System
Accommodation Fixture,'' that approximates a child restraint system.
Both vehicle and child restraint manufacturers can use the fixture to
assess the degree to which their products are compatible.
NHTSA has addressed VW's comment by amending S8.1(b) of the final
rule to specify that if SFAD 1 cannot be attached to the vehicle seat
using the belts because of the location of the vehicle belt buckle, the
vehicle belt will not be used. Instead, SFAD 1 will be attached by
material whose breaking strength is equal to or greater than the
breaking strength of the webbing for the seat belt assembly installed
as original equipment at that seating position. We also specify that
the geometry of the attachment must duplicate the geometry, at the pre-
load point, of the attachment of the originally installed seat belt
assembly. These provisions are essentially the same as those specified
in Standard No. 210, ``Seat Belt Assembly Anchorages.'' We believe
these provisions address VW's concern, while providing more flexibility
to address the problem VW describes than
[[Page 47577]]
the approach suggested by VW. Our adopted approach will not affect the
outcome of the assessment of the tether anchor's strength.
Toyota suggests amending the provision that states that, for the
purpose of testing a tether anchorage at a seating position that has a
child restraint anchorage system, place the seat back in its most
upright position:
When the seat back is placed in its most upright position, in
some vehicle seats the SFAD 2 cannot attach to the lower anchorages.
In the real world, if a CRS [child restraint system] cannot attach
to the anchorages, we believe the vehicle owner will adjust the seat
back such that the CRS can be attached. Therefore, Toyota requests
that the agency amend S7(a) * * * to allow for adjustment of the
seat back for cases where the SFAD 2 cannot be attached to the lower
anchorages with the seat back in its most upright position.
To address Toyota's concern, we have added a statement to S7(a), which
states:
When SFAD 2 is used in testing and cannot be attached to the
lower anchorages with the seat back in this position, adjust the
seat back as recommended by the manufacturer in its instructions for
attaching child restraints. If no instructions are provided, adjust
the seat back to the position that enables SFAD 2 to attach to the
lower anchorages that is the closest to the most upright position.
B. Issues relating to the application of the standard. Several
petitioners ask us to reconsider the application of the standard to
certain vehicle types or seating positions, or ask for clarification of
the applicability of particular requirements. The Alliance asks that
the rule be amended to specify that the requirements of the standard
only apply to forward-facing rear designated seating positions, and not
to rearward-or side-facing rear seats. The petitioner states that
neither of the latter types of seats are recommended for child
restraint installation, so the requirement for the installation of
child restraint anchorage systems or tether anchorages should not apply
to them. The agency agrees and has amended the provisions of S4 of the
final rule to make clear that rear-and side-facing seats are not
counted in determining the number of required anchorages.
The Alliance asks us to confirm that a convertible that has no rear
designated seating position or which has an on-off switch for the
passenger air bag will only have to have lower anchorages in the front
passenger seating position, and not a tether anchorage. This is
partially correct. Vehicles that have no rear designated seating
position, and no on-off switch, are generally required to have a tether
anchorage at the front passenger seat (see, e.g., S4.4(c)).
Convertibles, however, are excluded on practicability grounds from the
requirement to have a tether anchorage (S5(a)). Thus, a convertible
with no rear designated seating position, and no on-off switch, is not
required to have a tether or a child restraint anchorage system in the
front passenger seat. Vehicles that have no rear designated seating
position but which have an on-off switch are generally required to have
a child restraint anchorage system in the front passenger seating
position (S5(c)(1)). Again, however, because convertibles are excluded
from the requirement to have a tether anchorage (S5(a)), a convertible
with no rear designated seating position and an on-off switch is
required to have the lower anchorages of a child restraint anchorage
system in the front passenger seating position, but is not required to
have a tether anchorage at that position. We have added language to
S5(c) to clarify these requirements.
Global Vehicle Services, Corporation asks us to clarify the
provisions of the standard as they apply to vehicles that have received
temporary exemptions under 49 CFR Part 555 from the requirement in
Standard No. 208 that an air bag be provided for the front passenger
seating position. This and other requests for reconsideration of
S5(d)'s prohibition against placing a child restraint anchorage system
in an air bag-equipped front passenger seating position will be
addressed in the next document we will be publishing in response to the
petitions for reconsideration.
The Coalition of Small Volume Automobile Manufacturers, Inc.
(Cosvam), asks us to reconsider the requirement that vehicles without
any rear designated seating position (and without an air bag on-off
switch) must be equipped with a tether anchorage at each front
passenger seating position (see, e.g., S4.4(c)). Cosvam asks that we
permit manufacturers to label the vehicle as ``unsuitable for child
seats'' and exclude so labeled vehicles from requirements to have a
tether anchorage. Cosvam said it believes that, because manufacturers
know their vehicles better than anyone else, and are ultimately held
responsible for issues involving vehicle design and performance, they
should be permitted to decide whether the use of a child restraint is
appropriate in their vehicles.
NHTSA is denying this request. We are concerned that child
restraints could be used in vehicles that do not have rear seating
positions, but have air bags at front passenger seating positions. Our
rule prohibits the installation of a full child restraint anchorage
system at the front seating position if the vehicle does not have an
on-off switch. The purpose of this prohibition is to reduce the
likelihood that a child restraint system would be used in the front
seat. However, because there could be parents who would use the
vehicle, notwithstanding the lack of a child restraint anchorage
system, to transport their children, we decided to require the
installation of a tether anchorage. The provision to which Cosvam
objects is primarily for the benefit of toddlers in forward-facing
child restraints. In the event the vehicle were used to carry these
toddlers, a tether anchorage would help keep the child restraint and
the restrained child as far as possible from a deploying air bag.
(NHTSA has received a number of telephone calls from owners of vehicles
with no rear seat asking for help in installing child restraints in
front seats.) A tether anchorage would be very helpful in reducing head
excursion toward the dashboard in the event of a crash. Further,
although we encourage vehicle manufacturers to fully inform potential
buyers of possible incompatibility problems between their vehicles and
child restraints, we are concerned that Cosvam's suggestion that the
vehicles in question should be permitted to be labeled as not suitable
for child restraints may not dissuade some parents from using the
vehicle to carry children. Parents do in fact use sports cars to
transport children in child restraint systems. NHTSA has received a
number of phone calls from owners of sports cars wanting to know which
child restraint system fits best in their vehicles. We believe that a
tether anchorage should be provided in these vehicles to improve the
securement of the child in the event the toddler is transported in the
vehicle. Accordingly, this request is denied.
Several petitioners ask us to reconsider the requirement in S9.3,
Adequate fit of the lower anchorages, that each vehicle and each child
restraint anchorage system in that vehicle must be designed such that
the child restraint fixture (CRF) specified in the standard can be
placed inside the vehicle and attached to the lower anchorages of each
child restraint anchorage system. Cosvam argues that this requirement
amounts to a ``prohibited design standard,'' and would require the
manufacturers of sports cars and similar vehicles to redesign or
eliminate rear seats of those vehicles. Cosvam asks us to add a
provision to the rule stating that vehicles having rear seats that
cannot accommodate the CRF, but lacking an
[[Page 47578]]
on-off switch for the air bag, need have neither a tether nor child
restraint anchorage system in the rear seat of the vehicle, nor a
tether anchorage in the front seating position. In other words, they
are excluded from the standard. The petitioner states: ``Manufacturers
should be permitted to exclude `small rear seat vehicles' because they
are, from a child restraint point of view, the same as vehicles without
rear seats.''
American Honda states in its petition that it can be very difficult
or impossible to get the CRF into the rear seating area of some
vehicles, such as small two-door cars. The commenter states that the
draft ISO standard (which developed the CRF and the procedures for its
use) specifies that ``To facilitate installation of the CRF in a
vehicle seat, the CRF may be constructed of smaller parts and assembled
in the vehicle seat. Alternatively, vehicle components maybe removed to
allow access.'' Honda requests that similar language be added to
Standard No. 225. Honda also states ``From a practical standpoint, we
believe that child restraints will be offered in various sizes,
including child restraints that are somewhat smaller than the CRF for
use in small vehicles. * * * Thus, if the CRF, in its full shape and
size, can be fitted to the lower anchorages, we believe it is not
important whether the CRF had to be assembled in place or some vehicle
components (e.g., front seat) had to be removed to facilitate getting
the CRF into the seat position where the lower anchorage fit was being
checked.''
Toyota, in its petition for reconsideration, states that some of
the rear seating positions in some carlines can not accommodate the
CRF, but are able to accommodate existing child restraints and will be
able to accommodate new child restraints that will use the child
restraint anchorage system. Toyota suggests that we exclude vehicles
that cannot accommodate the CRF, due to a lack of rear seating space,
from the fit requirements of S9.3, as long as the lower anchorages that
are required to be installed are designed to accommodate the lower
anchorages of the CRF.
We are amending S9.3 along the line suggested by Honda and not
adopting the suggestions of Cosvam and Toyota. We agree that S9.3 as
currently written could result in unnecessary design changes for some
vehicles. The CRF is larger than many child restraint systems. Even if
the CRF does not fit in a vehicle's rear seat, there will likely be
child restraint models that will be small enough to fit. Accordingly,
we are amending S9.3 to specify that, to facilitate installation of the
CRF in a vehicle seat, the side and top frames of the CRF may be
removed in order to place it in the vehicle. To illustrate the CRF with
the side and top frames removed, we are adding a Figure 1A to the
standard. We believe that this approach responds to Cosvam's and
Toyota's concerns about the ability of their vehicles to fit the CRF in
the rear seating system and makes it unnecessary to exclude vehicles as
these petitioners have requested. We do not believe sufficient
information has been provided to justify excluding vehicles with one or
two designated rear seating positions from the requirement to provide a
child restraint anchorage system at those positions. Some parents may
use the vehicle to transport children regardless of a label that tells
them that the vehicle is unsuitable for child restraints. (See
response, above, to Cosvam's request to label vehicles.) A child
restraint anchorage system in rear seating positions will provide
benefits to the children using them.
The Alliance asks us to confirm its understanding that the new
standard does not apply to tether anchorages and child restraint
anchorage systems installed in vehicles not listed in the Application
section of the standard (S2). That understanding is correct. We had
proposed in the NPRM the issuance of a separate standard establishing
requirements for the strength and location of tether anchorages, and
the application of this standard to any tether anchorage installed in
new passenger cars and multipurpose passenger vehicles, trucks and
buses (see proposed Standard No. 210b, 62 FR 7885). However, the final
rule applies to vehicles listed in the application section of Standard
No. 225, and not to anchorages installed in new vehicles. The Alliance
is correct that S4.1 of the standard (which requires that each tether
anchorage and each child restraint anchorage system installed, either
voluntarily or pursuant to Standard No. 225, in any new vehicle
manufactured on or after September 1, 1999, shall comply with the
configuration, location and strength requirements of the standard) does
not limit the voluntary installation of child restraint anchorage
systems or tether anchorages in vehicles not listed in S2 of the
standard. Although anchorage systems installed in these vehicles will
not be subject to the standard's requirements, they will be subject to
our defect authority. Manufacturers would therefore have to ensure that
the systems are free of safety-related defects. (The agency encourages
manufacturers to ensure that anchorage systems installed in vehicles
not subject to Standard No. 225 nonetheless voluntarily meet the
performance requirements of the standard to ensure that the systems
offer adequate crash protection. A parent is likely to assume that such
systems meet minimum performance requirements.)
The Alliance, and Ford, in a separate petition, ask NHTSA to
clarify S4.1 of the standard to permit what petitioners call ``ISO-
compatible anchorage systems.'' The Alliance explains that:
Installing two child restraint anchorage systems in the two
outboard positions of a typical three-passenger rear seat creates a
third non-complying ``child restraint anchorage system'' at the
center seat position. This anchorage system consists of the tether
anchorage and the inboard lower anchors of the two child restraint
anchorage systems at the outboard seating positions. This anchorage
system sometimes referred to as ISO-compatible, can be used to
install child restraints with webbing-based attachment systems, but
it does not meet all the technical requirements of the final rule. *
* *
S4.1 appears to prohibit installing child restraint anchorage
systems at both outboard-seating positions because doing so would
create a non-complying voluntary anchorage system at the center seat
position. The essential difference between complying anchorage
systems and ISO-compatible anchorage systems is that the lateral
spacing of anchors is not 280 mm in an ISO-compatible anchorage.
Because of non-standard lateral spacing, ISO-compatible anchorage
systems cannot be used to install child restraints using rigid
attachments. But these ISO-compatible anchorage systems can
typically be used to install child restraints equipped with webbing-
based round-bar attachments. * * * Because of non-standard spacing,
the SFAD 2 cannot be used to test the strength and stiffness of
these lower anchors and tether anchor as a system, but the lower
anchors would be subject to testing of the anchorage systems for the
outboard position. Alliance members would test the center tether
anchorage using the SFAD 1 or the 5.3 kN single-strap test.
Some Alliance members had planned to treat these center anchor
systems as voluntary, non-standard anchorage systems and to advise
customers that these center positions could be used to secure child
restraints equipped with webbing-mounted attachments. No Alliance
members plan to test these ISO-compatible anchorage systems as a
separate system, because all parts of such a system are subject to
testing as a tether anchorage or as part of the outboard child
restraint anchorage system. * * *
The Alliance petitions the agency to clarify S4.1 to allow
voluntary ``ISO-compatible'' systems. Such systems should not be
subject to the position and spacing requirements of FMVSS 225,
provided the manufacturer provides instructions for the proper
installation of child restraints in these positions in the vehicle
owner's manual. * * *
[[Page 47579]]
Standard No. 225 does not prohibit the installation of these so-
called ``ISO-compatible'' anchorage systems. An ISO-compatible system
is a system consisting of lower anchorage bars from adjacent, properly-
designed, child restraint anchorage systems. We do not consider an ISO-
compatible anchorage system to be a ``child restraint anchorage
system'' under Standard No. 225, because it does not have lower
anchorages of its own. The strength of the tether anchorage of the ISO-
compatible system will be tested using the SFAD 1 (attached by the
vehicle's belt system at the seating position where the ISO-compatible
system is located), or the single-strap (until 2004, see S6.3.2).
The National Truck Equipment Association (NTEA) asks us to exclude
shuttle-type buses from the standard. Petitioner states that these
vehicles are most often used as hotel or rental car shuttle vehicles
and as paratransit vehicles. Petitioner believes that these vehicles
should be excluded because almost all of the seats in them are side-
facing, and ``[w]e don't know that it is appropriate for child
restraint seats to be placed in a side-facing seat.'' NTEA also states
that the only forward-facing passenger seats in these vehicles is often
the rear bench, which is placed against the back wall of the vehicle.
Petitioner believes that there is no practicable method of anchoring
the tether strap.
We agree that it is unlikely that child restraints will be used in
shuttle type buses (with side-facing seats along the side perimeter
walls of the passenger compartment and whose only forward facing
seating positions in the passenger compartment are those along the rear
wall of the bus). These buses also have limited use geographically,
moving people relatively short distances. A tether anchorage may also
be more costly to install in the rear row of these buses, given the
proximity of the rear bench to the rear wall of the vehicle. In view of
these factors, the combination of higher costs and much lower usage
probably makes application of the standard not cost beneficial. We are
thus excluding ``shuttle buses'' from the standard. A definition of
shuttle bus is added to the standard to read as follows: Shuttle bus
means a bus with only one row of forward-facing seating positions
rearward of the driver's seat.
C. Written instructions. The Alliance and Porsche Cars North
America petitioned to delete S12 of the standard, which requires
vehicle manufacturers to provide written instructions for using the
tether anchorage and the child restraint anchorage system in the
vehicle. Included among the required instructions are those that
provide ``a step-by-step procedure, including diagrams, for properly
attaching a child restraint system to the tether anchorages and the
child restraint anchorage system.'' The Alliance states that S12
requires
too much detail for a vehicle owner's manual because of the great
variety of possible child restraint attachments on the market, even
if the vehicle manufacturer could know in advance, before the
publication of its owner's manual, the details regarding each child
restraint attachment likely to be offered during the vehicle's
anticipated period of useful service. Obviously, no manufacturer
will have such knowledge.
General instructions on using a child restraint anchorage system
are required by the introductory paragraph of S12. Instructions on
using the child restraint anchorage system will help increase the
likelihood that a child restraint anchorage system and a tether
anchorage would be properly used. However, the agency recognizes that
it may be difficult for vehicle manufacturers to anticipate how child
restraint manufacturers will design the components that attach to the
lower anchorage bars of a child restraint anchorage system. With these
considerations in mind, we have amended S12(c) to delete the
requirement for detailed instructions on attaching a child restraint to
a child restraint anchorage system. However, detailed instructions on
attaching a tether strap to the tether anchorage will still be
required. This requirement is being retained because the child
restraint standard (Standard No. 213) specifies the configuration and
geometry of the tether hook. Vehicle manufacturers, therefore, can
develop their written instructions with the tether hook design in mind.
We have also declined to delete S12 entirely, because S12(a) and (b)
will help parents identify which seating positions have the child
restraint anchorage systems, how to access the anchorages if they are
covered, and how to interpret the marks required by S9.5(a) of the
standard. This information will help increase the likelihood that the
anchorages will be properly used.
b. Requirements for Child Restraints Relating to September 1, 1999
Compliance Date
1. Audible or Visual Indication of Attachment
Kolcraft Enterprises petitioned for reconsideration asking NHTSA to
clarify or reconsider S5.9(d) of the final rule. That section requires
each child restraint system, other than a system with hooks for
attaching to the lower anchorages of the child restraint anchorage
system, to provide either an audible indication when each attachment to
the lower anchorages becomes fully latched or attached, or a visual
indication that all attachments to the lower anchorages are fully
latched or attached. Visual indications shall be detectable under
normal daylight lighting conditions.
Kolcraft states that:
While this provision makes sense after September 1, 2002 when
each new child restraint must be equipped with lower anchorage
attachment components, compliance with the provision is
impracticable in advance of that date (except for child restraints
that are voluntarily equipped with lower anchorage attachment
components in advance of the regulatory deadline). Yet, it appears
that Section 5.9(d) takes effect for all child restraints
manufactured on or after September 1, 1999, because the provision
does not explicitly specify a later effective date.
NHTSA did not intend to imply that child restraints that do not
have the means for attaching to the lower bars of a vehicle's child
restraint anchorage system must provide the audible or visual
indicators described in S5.9(d). Such a requirement does not make sense
for child restraints that do not have the attachments. For a child
restraint that has such attachments, the audible or visual indicators
would be needed to better ensure that parents properly latch the
attachments. Accordingly, we have revised S5.9(d) to make clear that it
applies only to child restraints with components that enable the
restraints to be securely fastened to the lower anchorages of a child
restraint anchorage system (other than child restraints with hooks for
attaching to the lower anchorages).
2. Attachments Must be Permanent
Indiana Mills & Manufacturing (IMMI) has petitioned us to
reconsider the requirement in S5.9(a) of Standard No. 213 that each
child restraint system must have the components that attach to the
lower bars of a child restraint anchorage system permanently attached
to the child restraint. We are denying this petition.
IMMI states that it believes that almost all child restraint
manufacturers will use a snap hook (on a strap) to fasten the child
restraint system to the lower bars. IMMI believes that ``a snap hook
and adjuster is virtually impossible to release when excessively
tightened.'' To overcome this perceived problem, petitioner wishes to
put a seat belt type push-button buckle on the webbing strap that
connects to the snap
[[Page 47580]]
hook. A latch plate would be permanently welded on to the child
restraint to couple with and unbuckle from the buckle on the snap hook
strap.
This design would not meet S5.9(a) of Standard No. 213 because the
snap hook is not permanently attached to the child restraint. While
IMMI believes that the design would make it easier to unfasten a child
restraint from the lower bars, we are concerned about the likelihood
that some parents will lose the non-permanent piece, which will render
them unable to use the child restraint anchorage system. In the NPRM
for the March 5, 1999 final rule, we raised the issue of whether a
final rule should encompass a scheme whereby a non-permanent piece
(similar to IMMI's webbing piece with the snap hook on one end and
buckle on the other) could be provided to consumers by vehicle
manufacturers to enable parents to adapt a child restraint anchorage
system for use with child restraints not originally made for such a
system. Commenters overwhelmingly opposed an adapter, believing that
the adapter would be lost or misused by consumers. (This issue is
discussed in the final rule at 64 FR 10798-10799.) Because of those
comments, we decided to mandate a single child restraint anchorage
system, and to require in S5.9(a) of Standard No. 213 that the
components that attach to the lower bars must be permanently attached
to the child restraint. With IMMI's system, some parents might forget
or lose the snap hook piece, and would not be able to attach the child
restraint to the anchorage system. We continue to believe that the
``permanently attached'' requirement serves a safety need by increasing
the likelihood that the components will be present when the child
restraint needs to be installed in a child restraint anchorage system.
With regard to IMMI's belief that excessively tightened snap hooks
will be virtually impossible to release, the March 1999 final rule
added a requirement to Standard No. 213 that the belt webbing has to be
adjustable so that the child restraint can be tightly attached to the
vehicle (S5.9(d)). We believe that most, if not all adjusters will also
be capable of releasing the tension of the belt so that the snap hook
can be easily unfastened. If we were to find that parents are having
difficult releasing snap hooks, we will consider rulemaking possibly to
require a release mechanism that will facilitate the easy release of
highly tightened snap hooks.
Ford states in its petition that although it supports the intent of
the requirement in S5.9(a) that components must be ``permanently
attached,'' Ford believes that the meaning of what constitutes
permanently attached needs to be clarified. Ford states on page 8:
Are existing child restraint belt harnesses ``permanently
attached,'' even though they can be removed for repositioning? For
example, is a buckle and crotch strap assembly ``permanently
attached'' if it can be removed for relocation to an alternate
position that is further forward? Are belts on a hybrid harness
booster that are designed to be removed when the restraint is
converted into a belt-positioning booster ``permanently attached?''
Can lower anchor attachments be removable so they can be relocated
to different positions depending on whether the child restraint is
being used rear-or forward-facing? Because attachment to lower
anchors is not appropriate for belt-positioning boosters, it would
be appropriate to allow lower anchor attachments to be removed from
harness boosters when they are converted into belt-positioning
boosters.
We have granted this part of the petition to clarify the meaning of
permanently attached. For maximum design flexibility in designing the
components on child restraints that attach to the lower bars, child
restraint manufacturers might want consumers to move or remove the
components that attach to the lower bars. Opposed to this is the
interest in ensuring that the components are present on child
restraints when needed. To balance these concerns, we have amended
S5.9(a) to add a sentence that ``The components must be attached such
that they can only be removed by use of a tool, such as a
screwdriver.'' We believe that this provision will permit child
restraint manufacturers some design flexibility, yet will limit how
easily the components can be removed. Limiting easy removal of the
components will increase the likelihood that components are in place
when needed.
c. Reasons for the Effective Date of This Rule
Section 30111(d) of our motor vehicle safety statute (Title 49
U.S.C. Chapter 301) requires that a safety standard may not become
effective before the 180th day after the standard is prescribed or
later than one year after it is prescribed, unless we find, for good
cause shown, that a different effective date is in the public interest
and publish the reasons for the finding. The effective date for this
final rule is September 1, 1999, which is the same effective date as
for the March 1999 final rule which today's rule amends. Today's rule
does not impose new requirements on manufacturers but permits them to
begin meeting, at the manufacturer's option, alternative strength
requirements for an interim period. This rule also clarifies test
procedures specified in the March 1999 final rule. Because today's rule
provides an alternative to manufacturers which they may begin meeting
in lieu of the requirements which come into effect September 1, 1999,
and clarifies test requirements that come into effect September 1, it
is in the public interest for the effective dates for today's rule to
be the same as that of the March 1999 rule: September 1, 1999.
IV. Corrections to Final Rule
This document makes the following corrections to the March 1999
final rule which have been brought to our attention by petitioners and
by other parties:
Standard No. 213 is amended by correcting the table to
S5.1.3.1(a) to show that backless booster seats are excluded from the
new 720 mm head excursion limit. These seats were excluded because, as
discussed in the preamble, the manufacturers of backless booster seats
may have practicability problems in meeting the requirement. In
addition, S5.9(a) of the standard is corrected to specify that for
rear-facing child restraints with detachable bases, only the base need
have the permanently attached components that enable the restraint to
be securely fastened to the lower bars of a child restraint anchorages
system (as opposed to requiring the components on both the base and the
restraint system itself). The agency intended to specify this
limitation in Standard No. 213 (see 64 FR at 10806-10807), but did not
do so in the regulatory text of the final rule.
Figures 1B and 1B' of Standard No. 213 are corrected by
revising some of the dimensions for the test assembly.
Paragraph S4.1 of Standard No. 225 is corrected to specify
that voluntarily-installed lower bars must meet marking requirements
along with configuration, location and strength requirements of the
standard. We stated in the preamble to the final rule that we were
specifying marking requirements: ``The agency has drafted this final
rule to apply the standard's configuration, location, strength and
marking requirements to any additional voluntarily-installed rigid bar
anchorage system installed on a new school bus, or on any other
vehicle.'' (64 FR at 10803, column 2.) However, we inadvertently did
not refer to marking requirements in S4.1.
S9.4.1 of Standard No. 225 is corrected by adding a
tolerance for defining the vertical longitudinal plane for the forward
direction force. The tolerance is from the draft ISO standard. In
addition, we added S9.4.1.1 to specify the vertical angles for the
forward and lateral direction forces. The
[[Page 47581]]
specified angles are also from the draft ISO standard.
S11(a) and (b) of Standard No. 225 are corrected by adding
a 135 N rearward force to remove slack or tension to the device prior
to its loading. The specified force is from the draft ISO standard.
The following figures in Standard No. 225 are corrected:
Figure 1 (added yaw/pitch/roll); Figure 2 (added mass of CRF and
corrected dimensions on top view); Figures 3 to 11 (darkened shading);
Figure 15 and 16 (corrected dimension that Transport Canada also has on
top view); Figure 17 (added 6.5 mm diameter on detail B, deleted point
Y on detail A, corrected 270 dimension on side view and added stiffness
details to side and back views and to note 5); Figure 18 (made force
application attachment as in Figure 17); and Figure 19 (degree sign).
V. Rulemaking Analyses and Notices
a. Executive Order 12866 (Regulatory Planning and Review) and DOT
Regulatory Policies and Procedures
This rulemaking document was not reviewed under E.O. 12866,
``Regulatory Planning and Review.'' We have considered the impacts of
this rulemaking action and have determined that this action is not
``significant'' within the meaning of the Department of
Transportation's regulatory policies and procedures. We have further
determined that the effects of this rulemaking are sufficiently minimal
that preparation of a full preliminary regulatory evaluation is not
warranted. We believe that manufacturers will be minimally affected by
this rulemaking because it does not change manufacturers'
responsibilities to begin installing tether anchorages and the lower
bars of child restraint anchorage systems on the compliance dates of
the March 5, 1999 final rule. The rule instead permits manufacturers to
begin meeting, at the manufacturer's option, alterative strength
requirements for an interim period. We believe there will be no
additional testing costs associated with this final rule. This rule
clarifies testing requirements but does not impose new test burdens.
The method of testing tether anchorages and the lower bars of child
restraint anchorage systems will be basically the same as they are
under the March 1999 final rule. Further, since the amendment is
permissive in nature, there are no costs associated with it.
b. Regulatory Flexibility Act
NHTSA has considered the effects of this rulemaking action under
the Regulatory Flexibility Act. I hereby certify that it will not have
a significant economic impact on a substantial number of small
entities. This rule affects motor vehicle manufacturers, almost all of
which are not small business. Even if there are motor vehicle
manufacturers that qualify as small entities, this rule will not have a
significant economic impact on them because these amendments are
generally permissive in nature, and have no costs associated with it.
Accordingly, the agency has not prepared a regulatory flexibility
analysis.
c. Executive Order 12612 (Federalism)
This rulemaking action has been analyzed in accordance with the
principles and criteria contained in Executive Order 12612, and the
agency has determined that this rule 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 (Public Law 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. This rule does not impose any unfunded
mandates as defined by that Act.
e. National Technology Transfer and Advancement Act
Under the National Technology Transfer and Advancement Act of 1995
(NTTAA)(Public Law 104-113), ``all Federal agencies and departments
shall use technical standards that are developed or adopted by
voluntary consensus standards bodies, using such technical standards as
a means to carry out policy objectives or activities determined by the
agencies and departments.'' This final rule permits manufacturers to
meet the specifications in the draft ISO standard for child restraint
anchorage systems during an interim period, as an alternative to
meeting the requirements of the March 1999 final rule. The
International Organization for Standardization (ISO) is a worldwide
voluntary federation of ISO member bodies. By permitting the
alternative in the short run, this rule is consistent with the NTTAA's
goals of encouraging long-term growth for U.S. enterprises and
promoting efficiency and economic competition through harmonization of
standards.
f. 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 will not have any significant impact on
the quality of the human environment.
g. Executive Order 12778 (Civil Justice Reform)
This 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.
h. Paperwork Reduction Act.
This rule does not contain any collection of information
requirements requiring review under the Paperwork Reduction Act of 1995
(Public Law 104-13). We noted in the March 1999 final rule that the
phase-in production reporting requirements described in that rule are
considered to be information collection requirements as defined by the
Office of Management and Budget (OMB) in 5 CFR part 1320. NHTSA will be
submitting a clearance request to OMB for review and clearance in the
near future. The agency notes that the clearance for the information
collection requirements of Standard 213, ``Child Restraint Systems,''
will expire September 1, 2000 (OMB Clearance No. 2127-0511). NHTSA
anticipates it will submit a request to OMB to renew the clearance of
that standard and, at or near the same time, will be submitting an
information collection request to OMB for review and clearance of the
information collections in the March 1999 final rule.
Pursuant to the Paperwork Reduction Act and OMB's regulations at 5
CFR section 1320.5(b)(2), NHTSA informs the potential persons who are
to respond to the collection of information that such persons are not
required to respond to the collection of information unless it displays
a currently valid OMB control number. The agency's current
[[Page 47582]]
OMB control numbers are displayed in NHTSA's regulations at 49 CFR Part
509, OMB Control Numbers for Information Collection Requirements.
List of Subjects in 49 CFR Part 571
Imports, Incorporation by reference, Motor vehicle safety,
Reporting and recordkeeping requirements, Tires.
In consideration of the foregoing, NHTSA amends 49 CFR Chapter V as
set forth below.
PART 571--FEDERAL MOTOR VEHICLE SAFETY STANDARDS
1. The authority citation for Part 571 is revised to read as
follows:
Authority: 49 U.S.C. 322, 30111, 30115, 30166 and 30177;
delegation of authority at 49 CFR 1.50.
2. In Sec. 571.213--
a. S5.1.3.1 as amended at 64 FR 10815, effective September 1, 1999,
is amended by revising ``Table to S5.1.3.1(A)--Add-On Forward-Facing
Child Restraints'';
b. S5.9(a) and (d) are revised; and
c. Figure 1B and Figure 1B', as amended at 64 FR 10820, effective
September 1, 1999, are revised.
The revised text reads as follows:
Sec. 571.213 Standard No. 213; Child restraint systems.
* * * * *
BILLING CODE 4910-59-P
[[Page 47583]]
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BILLING CODE 4910-59-C
[[Page 47584]]
* * * * *
S5.9 Attachment to child restraint anchorage system.
(a) Each add-on child restraint system manufactured on or after
September 1, 2002, other than a car bed, harness and belt-positioning
seat, shall have components permanently attached to the system that
enable the restraint to be securely fastened to the lower anchorages of
the child restraint anchorage system specified in Standard No. 225
(Sec. 571.225) and depicted in Drawing Package 100-1000 with Addendum
A: Seat Base Weldment (consisting of drawings and a bill of materials)
dated October 23, 1998, (incorporated by reference; see Sec. 571.5).
The components must be attached such that they can only be removed by
use of a tool, such as a screwdriver. In the case of rear-facing child
restraints with detachable bases, only the base is required to have the
components.
* * * * *
(d) Beginning September 1, 1999, each child restraint system with
components that enable the restraint to be securely fastened to the
lower anchorages of a child restraint anchorage system, other than a
system with hooks for attaching to the lower anchorages, shall provide
either an indication when each attachment to the lower anchorages
becomes fully latched or attached, or a visual indication that all
attachments to the lower anchorages are fully latched or attached.
Visual indications shall be detectable under normal daylight lighting
conditions.
* * * * *
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[[Page 47585]]
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[[Page 47586]]
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BILLING CODE 4910-59-C
[[Page 47587]]
3. Section 571.225 is amended by:
a. Revising S2, and by amending S3 by adding, in alphabetical
order, a definition for ``Seat bight'' and for ``Shuttle bus';
b. Revising S4.1, S4.2(a), S4.2(b), S4.2(c), S4.3(a)(1),
S4.3(a)(2), S4.3(b)(1), S4.3(b)(2), S4.3(b)(3), S4.4(a), S4.4(a)(1),
S4.4(a)(2), S4.4(b), and S4.4(c);
c. Adding S4.5;
d. Revising S5(c)(1)(ii) and (c)(2) in its entirety;
e. By designating the text of S6.2 as S6.2.1 and revising the
introductory text, and adding new text to S6.2 and new S6.2.2, S6.2.2.1
and S6.2.2.2;
f. Adding text to S6.3, revising S6.3.1 in its entirety, and adding
S6.3.4 and S6.3.4.1 through S6.3.4.4;
g. Revising S7(a), S8, S8.1, and the introductory paragraph of
S8.2;
h. Amending S9 by adding text following the heading of S9;
i. Revising S9.1.1(a) and S9.1.1(f); and adding S9.3(c);
j. Revising the introductory paragraph of S9.4.1 and revising
S9.4.1(a), and adding S9.4.1.1;
k. Revising S11(a), S11(b), S12(b) and S12(c);
l. Adding S15, S15.1, S15.1.1, S15.1.2, S15.1.2.1, S15.1.2.2,
S15.2, S15.2.1, S15.2.2, S15.3, S15.3.1, S15.3.2, S15.3.3 and S15.3.4;
m. Revising Figures 1 through 11, and Figures 15 through 19; and
n. Adding a Figure 1A between Figures 1 and 2.
The revised and added text and figures read as follows:
Sec. 571.225 Standard No. 225; Child restraint anchorage systems.
* * * * *
S2. Application. This standard applies to passenger cars; to trucks
and multipurpose passenger vehicles with a gross vehicle weight rating
(GVWR) of 3,855 kilograms (8,500 pounds) or less, except walk-in van-
type vehicles and vehicles manufactured to be sold exclusively to the
U.S. Postal Service; and to buses (including school buses) with a GVWR
of 4,536 kg (10,000 lb) or less, except shuttle buses.
* * * * *
S3. Definitions.
* * * * *
Seat bight means the area close to and including the intersection
of the surfaces of the vehicle seat cushion and the seat back.
Shuttle bus means a bus with only one row of forward-facing seating
positions rearward of the driver's seat.
* * * * *
S4.1 Each tether anchorage and each child restraint anchorage
system installed, either voluntarily or pursuant to this standard, in
any new vehicle manufactured on or after September 1, 1999, shall
comply with the configuration, location, marking and strength
requirements of this standard. The vehicle shall be delivered with
written information, in English, on how to appropriately use those
anchorages and systems.
S4.2 * * *
(a) Each vehicle with three or more forward-facing rear designated
seating positions shall be equipped with a tether anchorage conforming
to the requirements of S6 at no fewer than three forward-facing rear
designated seating positions. The tether anchorage of a child restraint
anchorage system may count towards the three required tether
anchorages. In each vehicle with a forward-facing rear designated
seating position other than an outboard designated seating position, at
least one tether anchorage (with or without the lower anchorages of a
child restraint anchorage system) shall be at such a designated seating
position. In a vehicle with three or more rows of seating positions, at
least one of the tether anchorages (with or without the lower
anchorages of a child restraint anchorage system) shall be installed at
a forward-facing seating position in the second row if such a forward-
facing seating position is available in that row.
(b) Each vehicle with not more than two forward-facing rear
designated seating positions shall be equipped with a tether anchorage
conforming to the requirements of S6 at each forward-facing rear
designated seating position. The tether anchorage of a child restraint
anchorage system may count toward the required tether anchorages.
(c) Each vehicle without any forward-facing rear designated seating
position shall be equipped with a tether anchorage conforming to the
requirements of S6 at each front forward-facing passenger seating
position.
S4.3 * * *
(a) * * *
(1) Each vehicle with three or more forward-facing rear designated
seating positions shall be equipped with a child restraint anchorage
system conforming to the requirements of S9 at not fewer than two
forward-facing rear designated seating positions. In a vehicle with
three or more rows of seating positions, at least one of the child
restraint anchorage systems shall be at a forward-facing seating
position in the second row if such a forward-facing seating position is
available in that row.
(2) Each vehicle with not more than two forward-facing rear
designated seating positions shall be equipped with a child restraint
anchorage system conforming to the requirements of S9 at each forward-
facing rear designated seating position.
(b) * * *
(1) Each vehicle with three or more forward-facing rear designated
seating positions shall be equipped with a tether anchorage conforming
to the requirements of S6 at no fewer than three forward-facing rear
designated seating positions. The tether anchorage of a child restraint
anchorage system may count towards the three required tether
anchorages. In each vehicle with a forward-facing rear designated
seating position other than an outboard designated seating position, at
least one tether anchorage (with or without the lower anchorages of a
child restraint anchorage system) shall be at such a designated seating
position. In a vehicle with three or more rows of seating positions, at
least one of the tether anchorages (with or without the lower
anchorages of a child restraint anchorage system) shall be installed at
a forward-facing seating position in the second row if such a forward-
facing seating position is available in that row.
(2) Each vehicle with not more than two forward-facing rear
designated seating positions shall be equipped with a tether anchorage
conforming to the requirements of S6 at each forward-facing rear
designated seating position. The tether anchorage of a child restraint
anchorage system may count toward the required tether anchorages.
(3) Each vehicle without any forward-facing rear designated seating
position shall be equipped with a tether anchorage conforming to the
requirements of S6 at each front passenger seating position.
S4.4 * * *
(a) Each vehicle with three or more forward-facing rear designated
seating positions shall be equipped as specified in S4.4(a)(1) and (2).
(1) Each vehicle shall be equipped with a child restraint anchorage
system conforming to the requirements of S9 at not fewer than two
forward-facing rear designated seating positions. At least one of the
child restraint anchorage systems shall be installed at a forward-
facing seating position in the second row in each vehicle that has
three or more rows, if such a forward-facing seating position is
available in that row.
(2) Each vehicle shall be equipped with a tether anchorage
conforming to the requirements of S6 at a third forward-facing rear
designated seating position. The tether anchorage of a child
[[Page 47588]]
restraint anchorage system may count towards the third required tether
anchorage. In each vehicle with a forward-facing rear designated
seating position other than an outboard designated seating position, at
least one tether anchorage (with or without the lower anchorages of a
child restraint anchorage system) shall be at such a designated seating
position.
(b) Each vehicle with not more than two forward-facing rear
designated seating positions shall be equipped with a child restraint
anchorage system conforming to the requirements of S9 at each forward-
facing rear designated seating position.
(c) Each vehicle without any forward-facing rear designated seating
position shall be equipped with a tether anchorage conforming to the
requirements of S6 at each front forward-facing passenger seating
position.
S4.5 As an alternative to complying with the requirements of S4.2
through S4.4 that specify the number of tether anchorages that are
required in a vehicle and the designated seating positions for which
tether anchorages must be provided, a vehicle manufactured from
September 1, 1999 to August 31, 2001 may, at the manufacturer's option
(with said option irrevocably selected prior to, or at the time of,
certification of the vehicle), meet the requirements of this S4.5. This
alternative ceases to be available on and after September 1, 2001. A
tether anchorage conforming to the requirements of S6 shall be
installed--
(a) for each designated seating position, other than that of the
driver, in a vehicle that has only one row of designated seating
positions;
(b) for each forward-facing designated seating position in the
second row of seating positions in a passenger car or truck;
(c) for each of any two forward-facing designated seating positions
in the second row of seating positions in a multipurpose passenger
vehicle that has five or fewer designated seating positions; and,
(d) for each of any three forward-facing designated seating
positions that are located to the rear of the first row of designated
seating positions in a multipurpose passenger vehicle that has six or
more designated seating positions.
* * * * *
S5. General exceptions.
* * * * *
(c)(1) * * *
(ii) Has an air bag on-off switch meeting the requirements of
S4.5.4 of Standard No. 208 (Sec. 571.208), shall have a child restraint
anchorage system for a designated passenger seating position in the
front seat, instead of only a tether anchorage. In the case of
convertibles, the front designated passenger seating position need have
only the two lower anchorages meeting the requirements of S9 of this
standard.
(2) Each vehicle that--
(i) Has a rear designated seating position and meets the conditions
in S4.5.4.1(b) of Standard No. 208 (Sec. 571.208); and,
(ii) Has an air bag on-off switch meeting the requirements of
S4.5.4 of Standard 208 (Sec. 571.208), shall have a child restraint
anchorage system for a designated passenger seating position in the
front seat, instead of a child restraint anchorage system that is
required for the rear seat. In the case of convertibles, the front
designated passenger seating position need have only the two lower
anchorages meeting the requirements of S9 of this standard.
* * * * *
S6.2 Location of the tether anchorage. A vehicle manufactured from
September 1, 1999 to August 31, 2001 may, at the manufacturer's option
(with said option irrevocably selected prior to, or at the time of,
certification of the vehicle), meet the requirements of S6.2.1 or
S6.2.2. Vehicles manufactured on or after September 1, 2001 must meet
the requirements of S6.2.1 of this standard.
S6.2.1 Subject to S6.2.1.1 and S6.2.1.2, the part of each tether
anchorage that attaches to a tether hook shall be located within the
shaded zone shown in Figures 3 to 7 of this standard of the designated
seating position for which it is installed, such that--
* * * * *
S6.2.2 Subject to S6.2.2.1 and S6.2.2.2, the portion of each user-
ready tether anchorage that is designed to bind with a tether strap
hook shall be located within the shaded zone shown in Figures 3 to 7 of
this standard of the designated seating position for which it is
installed, with reference to the H-point of a template described in
section 3.1 of SAE Standard J826 (June 1992) (incorporation by
reference; see Sec. 571.5), if:
(a) the H-point of the template is located--
(1) At the unique Design H-point of the designated seating
position, as defined in section 2.2.11.1 of SAE Recommended Practice
J1100 (June 1993) (incorporation by reference; see Sec. 571.5), at the
full downward and full rearward position of the seat, or--
(2) In the case of a designated seating position that has a means
of affixing the lower portion of a child restraint system to the
vehicle, other than a vehicle seat belt, midway between the two lower
restraint system anchorages;
(b) the torso line of the template is at the same angle to the
transverse vertical plane as the vehicle 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.
S6.2.2.1 Until September 1, 2001, the portion of each user-ready
tether anchorage that is designed to bind with the tether strap hook
may be located in a passenger car or multipurpose passenger vehicle
within the shaded zone shown in Figures 8 to 11 of the designated
seating position for which it is installed, with reference to the
shoulder reference point of a template described in section 3.1 of SAE
Standard J826 (June 1992) (incorporation by reference; see Sec. 571.5),
if:
(a) the H-point of the template is located--
(1) at the unique Design H-point of the designated seating
position, as defined in section 2.2.11.1 of SAE Recommended Practice
J1100 (June 1993) (incorporation by reference; see Sec. 571.5), at the
full downward and full rearward position of the seat, or--
(2) in the case of a designated seating position that has a means
of affixing the lower portion of a child restraint system to the
vehicle, other than a vehicle seat belt, midway between the two lower
restraint system anchorages;
(b) the torso line of the template is at the same angle to the
vertical plane as the vehicle 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.
S6.2.2.2 The portion of a user-ready tether anchorage in a vehicle
that is designed to bind with the tether strap hook may be located
outside the shaded zone referred to in S6.2.2, if no part of the shaded
zone is accessible without removing a seating component of the vehicle
and the vehicle is equipped with a routing device that--
(a) ensures that the tether strap functions as if the portion of
the anchorage designed to bind with the tether strap hook were located
within the shaded zone;
(b) is at least 65 mm behind the torso line, in the case of a non-
rigid-webbing-type routing device or a deployable routing device, or at
least 100 mm
[[Page 47589]]
behind the torso line, in the case of a fixed rigid routing device; and
(c) when tested after being installed as it is intended to be used,
is of sufficient strength to withstand, with the user-ready tether
anchorage, the load referred to in S6.3.4 or S6.3.4.1, as applicable.
S6.3 Strength requirements for tether anchorages. Subject to
S6.3.2, a vehicle manufactured from September 1, 1999 to August 31,
2001 may, at the manufacturer's option (with said option irrevocably
selected prior to, or at the time of, certification of the vehicle),
meet the requirements of S6.3.1 or S6.3.4. Subject to S6.3.2, vehicles
manufactured on or after September 1, 2001 must meet the requirements
of S6.3.1 of this standard.
S6.3.1 Subject to S6.3.2, when tested in accordance with S8, after
preloading the device with a force of 500 N, point X of the SFAD must
not be displaced horizontally more than 125 mm during the application
of the force.
* * * * *
S6.3.4 Subject to subsections S6.3.4.1 and S6.3.4.2, every user-
ready tether anchorage in a row of designated seating positions shall,
when tested, withstand the application of a force of 10,000 N--
(a) applied by means of one of the following types of test devices,
installed as a child restraint system would be installed in accordance
with the manufacturer's installation instructions, namely,
(1) SFAD 1, to test a tether anchorage at a designated seating
position that does not have a child restraint anchorage system; or
(2) SFAD 2, to test a tether anchorage at a designated seating
position that has a child restraint anchorage system;
(b) applied--
(1) in a forward direction parallel to the vehicle's vertical
longitudinal plane through the X point on the test device, and,
(2) initially, along a horizontal line or along any line below or
above that line that is at an angle to that line of not more than 5
degrees;
(c) approximately linearly over a time, at the option of the
vehicle manufacturer, of not more than 30 seconds, at any onset force
rate of not more than 135 000 N/s; and
(d) maintained at a 10,000 N level for one second.
S6.3.4.1 Until September 1, 2001, every user-ready tether
anchorage in a row of designated seating positions in a passenger car
may, when tested, subject to subsection S6.3.4.2, withstand the
application of a force of 5,300 N, which force shall be--
(a) applied by means of a belt strap that--
(1) extends not less than 250 mm forward from the vertical plane
touching the rear top edge of the vehicle seat back,
(2) is fitted at one end with suitable hardware for applying the
force and at the other end with a bracket for the attachment of the
user-ready tether anchorage, and
(3) passes over the top of the vehicle seat back as shown in Figure
19 of this standard;
(b) applied--
(1) in a forward direction parallel to the vehicle's longitudinal
vertical plane, and
(2) initially, along a horizontal line or along any line below that
line that is at an angle to that line of not more than 20 degrees;
(c) attained within 30 seconds, at any onset force rate of not more
than 135,000 N/s; and
(d) maintained at a 5,300 N level for one second.
S6.3.4.2 If the zones in which tether anchorages are located
overlap and if, in the overlap area, a user-ready tether anchorage is
installed that is designed to accept the tether strap hooks of two
restraint systems simultaneously, both portions of the tether anchorage
that are designed to bind with a tether strap hook shall withstand the
force referred to in subsection S6.3.4 or S6.3.4.1, as the case may be,
applied to both portions simultaneously.
S6.3.4.3 If a row of designated seating positions has more than
one user-ready tether anchorage, the force referred to in S6.3.4,
S6.3.4.1 or S6.3.4.2, as the case may be, shall be applied
simultaneously in the manner specified in the relevant subsection.
S6.3.4.4 The strength requirement tests shall be conducted with
the vehicle seat adjusted to its full rearward and full downward
position and the seat back in its most upright position. When SFAD 2 is
used in testing and cannot be attached to the lower anchorages with the
seat back in this position, adjust the seat back as recommended by the
manufacturer in its instructions for attaching child restraints. If no
instructions are provided, adjust the seat back to the position that
enables SFAD 2 to attach to the lower anchorages that is the closest to
the most upright position.
S7. Test conditions for testing tether anchorages.
* * * * *
(a) Vehicle seats are adjusted to their full rearward and full
downward position and the seat back is placed in its most upright
position. When SFAD 2 is used in testing and cannot be attached to the
lower anchorages with the seat back in this position, adjust the seat
back as recommended by the manufacturer in its instructions for
attaching child restraints. If no instructions are provided, adjust the
seat back to the position that enables SFAD 2 to attach to the lower
anchorages that is the closest to the most upright position.
* * * * *
S8. Test procedures. Each vehicle shall meet the requirements of
S6.3.1 and S6.3.3 when tested according to the following procedures.
Where a range of values is specified, the vehicle shall be able to meet
the requirements at all points within the range. For testing specified
in the procedures, the SFAD used in the test is connected to the
anchorage by means of a steel cable that is fitted at one end with a
high strength steel tether hook for attachment to the tether anchorage.
The tether hook meets the specifications in Standard No. 213
(Sec. 571.213) as to the configuration and geometry of tether hooks
required by that standard. A second steel cable is connected to the X
point through which the test force is applied.
S8.1 Apply the force specified in S6.3.1 as follows--
(a) Use the following specified test device, as appropriate:
(1) SFAD 1, to test a tether anchorage at a designated seating
position that does not have a child restraint anchorage system; or,
(2) SFAD 2, to test a tether anchorage at a designated seating
position that has a child restraint anchorage system.
(b) Attach the SFAD 1 to the vehicle seat using the vehicle belts
or the SFAD 2 to the lower anchorages of the child restraint anchorage
system, as appropriate, and attach the test device to the tether
anchorage, in accordance with the manufacturer's instructions provided
pursuant to S12 of this standard. For the testing specified in this
procedure, if SFAD 1 cannot be attached using the vehicle belts because
of the location of the vehicle belt buckle, the test device shall be
attached by material whose breaking strength is equal to or greater
than the breaking strength of the webbing for the seat belt assembly
installed as original equipment at that seating position. The geometry
of the attachment shall duplicate the geometry, at the pre-load point,
of the attachment of the originally installed seat belt assembly. All
belt systems used to attach SFAD 1 shall be tightened to a tension of
not less than 53.5 N and not more than 67 N, as
[[Page 47590]]
measured by a load cell used on the webbing portion of the belt. A
rearward force of 135 N 15 N shall be applied to the
center of the lower front crossmember of SFAD 2 to press the device
against the seat back as the fore-aft position of the rearward
extensions of the SFAD is adjusted to remove any slack or tension.
(c) Apply the force--
(1) Initially, in a forward direction in a vertical longitudinal
plane and through the Point X on the test device; and
(2) Initially, along a line through the X point and at an angle of
10 5 degrees above the horizontal. Apply a preload force
of 500 N to measure the angle; and then
(3) Increase the pull force as linearly as practicable to a full
force application of 15,000 N in not less than 24 seconds and not more
than 30 seconds, and maintain at a 15,000 N level for 1 second.
S8.2 Apply the force specified in S6.3.2 as follows:
* * * * *
S9 Requirements for the lower anchorages of the child restraint
anchorage system. As an alternative to complying with the requirements
of S9, a vehicle manufactured from September 1, 1999 to August 31, 2002
may, at the manufacturer's option (with said option irrevocably
selected prior to, or at the time of, certification of the vehicle),
meet the requirements in S15 of this standard. Vehicles manufactured on
or after September 1, 2002 must meet the requirements of S9 of this
standard.
* * * * *
S9.1.1 * * *
(a) Are 6 mm .1 mm in diameter;
* * * * *
(f) Are an integral and permanent part of the vehicle or vehicle
seat; and
* * * * *
S9.3 * * *
(c) To facilitate installation of the CRF in a vehicle seat, the
side, back and top frames of the CRF may be removed for installation in
the vehicle, as indicated in Figure 1A of this standard.
* * * * *
S9.4.1 When tested in accordance with S11, the lower anchorages
shall not allow point X on SFAD 2 to be displaced horizontally more
than 125 mm, after preloading the device, when--
(a) A force of 11,000 N is applied in a forward direction in a
vertical longitudinal plane that is parallel (0 5 degrees)
to the vehicle's longitudinal centerline; and
* * * * *
S9.4.1.1 Forces described in S9.4.1(a), forward direction, shall
be applied with an initial force application angle of 10 5
degrees above the horizontal. Forces described in S9.4.1(b), lateral
direction, shall be applied horizontally (0 5 degrees).
* * * * *
S11. Test procedure. * * *
(a) Forward force direction. Place SFAD 2 in the vehicle seating
position and attach it to the two lower anchorages of the child
restraint anchorage system. Do not attach the tether anchorage. A
rearward force of 135 15 N shall be applied to the center
of the lower front crossbar of SFAD 2 to press the device against the
seat back as the fore-aft position of the rearward extensions of the
SFAD is adjusted to remove any slack or tension. Apply a preload force
of 500 N at point X of the test device. Increase the pull force as
linearly as practicable to a full force application of 11,000 N in not
less than 24 seconds and not more than 30 seconds, and maintain at an
11,000 N level for 10 seconds.
(b) Lateral force direction. Place SFAD 2 in the vehicle seating
position and attach it to the two lower anchorages of the child
restraint anchorage system. Do not attach the tether anchorage. A
rearward force of 135 15 N shall be applied to the center
of the lower front crossbar of SFAD 2 to press the device against the
seat back as the fore-aft position of the rearward extensions of the
SFAD is adjusted to remove any slack or tension. Apply a preload force
of 500 N at point X of the test device. Increase the pull force as
linearly as practicable to a full force application of 5,000 N in not
less than 24 seconds and not more than 30 seconds, and maintain at a
5,000 N level for 10 seconds.
S12. * * *
(b) In the case of vehicles required to be marked as specified in
paragraphs S4.1, S9.5(a), or S15.4, explain the meaning of markings
provided to locate the lower anchorages of child restraint anchorage
systems; and
(c) Include instructions that provide a step-by-step procedure,
including diagrams, for properly attaching a child restraint system's
tether strap to the tether anchorages.
* * * * *
S15 Alternative to complying with the requirements of S9. As an
alternative to complying with the requirements of S9, a vehicle
manufactured from September 1, 1999 to August 31, 2002 may, at the
manufacturer's option (with said option irrevocably selected prior to,
or at the time of, certification of the vehicle), meet the requirements
in S15 of this standard. Vehicles manufactured on or after September 1,
2002 must meet the requirements of S9 of this standard.
S15.1 Dimensions and installation requirements.
S15.1.1 General. The vehicle anchorages are positioned near the
seat bight. The location of the anchorages is defined with respect to
the CRF. If the vehicle seat is adjustable, it is adjusted as
recommended by the vehicle manufacturer for use with child restraint
systems.
S15.1.2 Anchorage dimensions and location
S15.1.2.1 The lower anchorages shall consist of two bars that--
(a) Are 6 mm .1 mm in diameter;
(b) Are straight, horizontal and transverse;
(c) Are not less than 25 mm in length;
(d) Can be connected to, over their entire length, as specified in
paragraph S15.1.2.1(c), by the connectors of a child restraint system;
(e) Are 280 mm apart, measured from the center of the length of one
bar to the center of the length of the other bar; and
(f) Are an integral and permanent part of the vehicle or vehicle
seat.
S15.1.2.2 (a) The anchorage bars are located at the vehicle
seating position with the aid of and with respect to the CRF rearward
extensions, with the CRF placed against or near the vehicle seat back.
With the CRF attached to the anchorages and resting on the seat
cushion, the bottom surface shall have attitude angles within the
limits in the following table, angles measured relative to the vehicle
horizontal, longitudinal and transverse reference planes.
Table to S15.1.2.2(a)
------------------------------------------------------------------------
------------------------------------------------------------------------
Pitch...................................................... 15 deg.
10 d
e
Roll....................................................... 0 deg.
5 de
g
Yaw........................................................ 0 deg.
10 d
e
------------------------------------------------------------------------
Note: An explanation of the above angles is given in Figure 1.
(b) With adjustable seats adjusted as described in S15.1.2.2(c),
each lower anchorage bar shall be located so that a vertical transverse
plane intersecting the center of the bar is:
(1) Not more than 70 mm behind point Z of the CRF, measured
parallel to the bottom surface of the CRF and to the center of the bar,
with the CRF rear surface against the seat back; and
(2) Not less than 120 mm behind the vehicle seating reference
point, measured horizontally and to the center of the bar. (Note: To
facilitate installation of the CRF in a vehicle seat, the CRF may be
constructed of smaller
[[Page 47591]]
separable parts and assembled in the vehicle seat. Alternatively,
vehicle components may be removed to allow access.)
(c) Adjustable seats are adjusted as recommended by the vehicle
manufacturer for use with child restraint systems.
S15.2 Static Strength Requirements.
S15.2.1 The strength of the anchorages shall be determined using
the procedure of S15.3 to apply forces to the SFAD 2, installed in the
vehicle seating position and engaged with the anchorages. The vehicle
seat shall be installed in the vehicle, or in sufficient parts of the
vehicle so as to be representative of the strength and rigidity of the
vehicle structure. If the seat is adjustable, it shall be placed in the
position recommended by the vehicle manufacturer for use with child
restraint systems. If no adjusted position is recommended, the seat
shall be placed in any position, at the agency's option.
S15.2.2 Horizontal excursion of point X during application of the
8 kN and 5 kN forces shall be not more than 125 mm, after preloading
the device.
S15.3 Forces and directions.
S15.3.1 A rearward force of 135 N 15 N shall be
applied to the center of the lower front crossbar of SFAD 2 to press
the device against the seat back as the fore-aft position of the
rearward extensions of the SFAD is adjusted to remove any slack or
tension. Forces shall be applied to SFAD 2 in forward and lateral
directions according to the following table.
Table to S15.3.1.--Directions of Test Forces
------------------------------------------------------------------------
------------------------------------------------------------------------
Forward..................... 0 deg. 8 kN
5 deg.. 0.25 kN
Lateral..................... 75 deg. 5 kN
5 deg. (to both 0.25 kN
sides of straight
forward).
------------------------------------------------------------------------
S15.3.2 Forces in the forward direction shall be applied with an
initial force application angle of 10 5 degrees above the
horizontal. Lateral forces shall be applied horizontally (0 deg.
5 deg.). A pre-load force of 500 N 25 N shall
be applied at the prescribed loading point (point X) in Figure 17. The
force shall be increase
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