Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 10637 

DEPARTMENT OF TRANSPORTATION 

National Highway Traffic Safety 

Administration 

[Docket NHTSA–2010–00062] 

Consumer Information; Program for 

Child Restraint Systems 

AGENCY: National Highway Traffic 

Safety Administration (NHTSA), 

Department of Transportation (DOT). 

ACTION: Request for comments. 

SUMMARY: On April 24, 2009, DOT 

announced that NHTSA would establish 

a new consumer information program, 

as part of the New Car Assessment 

Program, to help caregivers find a child 

restraint system (‘‘child safety seat’’) that 

fits their vehicle. Under the program, 

NHTSA will make available information 

from vehicle manufacturers as to the 

specific child safety seats the 

manufacturers recommend for 

individual vehicles. This document 

primarily details observations from an 

agency pilot study conducted to 

determine reasonable conditions for 

participation in such a program. It also 

proposes a set of forms comprised of 

objective criteria which vehicle 

manufacturers can use to identify child 

safety seats that fit their vehicles. The 

agency anticipates that this program 

will make it easier for caregivers to 

select a child safety seat that fits in their 

vehicle. 

DATES: Comments should be submitted 

early enough to ensure that they are 

received no later than March 28, 2011. 

ADDRESSES: Comments should refer to 

the docket number above and be 

submitted by one of the following 

methods: 

• Federal Rulemaking Portal: http:// 

www.regulations.gov. Follow the online 

instructions for submitting comments. 

Fax: 1–202–493–2251. 

• Mail: Docket Management Facility, 

U.S. Department of Transportation, 1200 

New Jersey Avenue, SE., West Building 

Ground Floor, Room W12–140, 

Washington, DC 20590–0001. 

• Hand Delivery: West Building 

Ground Floor, Room W12–140, 1200 

New Jersey Avenue, SE., Washington, 

DC between 9 a.m. and 5 p.m. ET, 

Monday through Friday, except Federal 

Holidays. 

• Instructions: For detailed 

instructions on submitting comments 

and additional information on the 

rulemaking process, see the Public 

Participation heading of the 

Supplementary Information section of 

this document. Note that all comments 

received will be posted without change 

to http://www.regulations.gov, including 

any personal information provided. 

• Privacy Act: Anyone is able to 

search the electronic form of all 

comments received into any of our 

dockets by the name of the individual 

submitting the comment (or signing the 

comment, if submitted on behalf of an 

association, business, labor union, etc.). 

You may review DOT’s complete 

Privacy Act Statement in the Federal 

Register published on April 11, 2000 

(Volume 65, Number 70; Pages 19477– 

78). 

FOR FURTHER INFORMATION CONTACT: For 

non-legal issues related to the VehicleChild Restraint System (CRS) Fit 

program, you may contact Ms. Jennifer 

N. Dang, Office of Crashworthiness 

Standards (Telephone: 202–493–0598). 

For legal issues, you may contact Ms. 

Deirdre Fujita, Office of Chief Counsel 

(Telephone: 202–366–2992). You may 

send mail to these officials at the 

National Highway Traffic Safety 

Administration, 1200 New Jersey 

Avenue, SE., West Building, 

Washington, DC 20590–0001. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Executive Summary 

II. Introduction 

III. The Current Child Safety Problem 

IV. NHTSA’s CRS Activities 

V. Addressing Vehicle-CRS Compatibility 

A. Consumer Information 

B. LATCH 

VI. Considerations for Development of a New 

Consumer Information Program To 

Address Vehicle-CRS Compatibility 

VII. Review of Worldwide Child Restraint 

Consumer Information Programs 

VIII. Conditions for Participation, Program 

Administration, and Distribution 

A. Conditions for Participation in the 

Vehicle-CRS Fit Program 

B. Program Administration 

C. Program Distribution 

IX. Pilot Study To Assess Effectiveness of 

Preliminary Vehicle-CRS Fit Program 

Evaluation Criteria 

A. Development of Vehicle-CRS Fit 

Evaluation Forms 

B. Pilot Study Approach 

1. Vehicle Selection 

2. CRS Selection 

C. General Pilot Study Observations 

X. Pilot Study Observations and Resulting 

Proposed Fit Criteria 

A. Vehicle Seat Belts 

B. Top Tether Anchorages 

C. Lower Anchorages 

D. Head Restraints 

E. CRS Installation, Use, and Tightness 

F. Vehicle Owner’s Manual 

G. Weight Limits 

H. Rear-Facing CRS 

XI. Conclusions and Effective Date 

XII. Paperwork Reduction Act 

XIII. Public Participation 

Appendices 

APPENDIX A: Worldwide Child Restraint 

Consumer Information Programs 

A. Child Restraints Evaluation Program 

(CREP) 

B. Consumers Union 

C. EuroNCAP 

D. Japan NCAP (JNCAP) 

E. New Program for the Assessment of 

Child Restraint Systems (NPACS) and 

the Child Seat Rating Scheme 

APPENDIX B: Pilot Study Evaluation Form 

APPENDIX C: Observations From VehicleCRS Pilot Study 

APPENDIX D: Proposed Vehicle-CRS Fit 

Assessment Forms 

APPENDIX E: Installation Methods for 

Assessing Vehicle-CRS Fit 

I. Executive Summary 

Child restraint systems (CRS) are very 

effective at protecting children sitting in 

vehicles that are involved in motor 

vehicle crashes. Nonetheless, past 

studies have shown that installation 

mistakes that reduce or negate the 

effectiveness of CRS still occur 

frequently. Instances of misuse for child 

restraints can be attributed to user error 

or to incompatibilities between the 

child restraint and the vehicle. To 

address misuse due to user error, 

NHTSA conducts a CRS Ease of Use 

(EOU) program. To address the need for 

increased compatibility, DOT 

announced, on April 24, 2009, that 

NHTSA would establish a new 

consumer information program, as part 

of the New Car Assessment Program, to 

help caregivers find a child restraint 

system that fits their vehicle. 

The agency believes that this program 

will (1) provide consumer service by 

offering guidance on vehicle-CRS 

matchups, (2) complement NHTSA’s 

Ease of Use program, 4 Steps for Kids 

consumer information campaign, as 

well as other child passenger safety 

initiatives, and (3) encourage child 

restraint and vehicle manufacturers to 

work together to address the need for 

increased compatibility. 

This document outlines factors that 

the agency deemed significant to the 

development of a Vehicle-CRS Fit 

program and details observations from 

an agency pilot study conducted to 

determine reasonable conditions for 

participation in such a program. It also 

proposes a set of forms comprised of 

objective criteria that vehicle 

manufacturers can use to identify child 

safety seats that fit their vehicles. In 

developing the proposed evaluation 

forms, the agency considered general 

installation techniques that are required 

for all CRS installations, specific 

installation techniques and other factors 

that apply to certain types of CRS or 

particular modes of use, and vehicle 

features that may influence proper CRS 


srobinson on DSKHWCL6B1PROD with NOTICES
10638 Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 

1 Decina L.E. and Lococo K. H. (2004). Misuse of 

Child Restraints. NHTSA Publication No. DOT HS 

809 671, Page 2. 

2As part of the program, NHTSA will spot-check 

the fit of CRSs in vehicles to make sure that the 

information is accurate. 

3Traffic Safety Facts 2007: Occupant Protection, 

DOT HS 810 991, National Center for Statistics and 

Analysis, 1200 New Jersey Ave, SE., Washington, 

DC 20590, Page 4. 

4http://www.iihs.org/laws/ChildRestraint.aspx. 

5Traffic Safety Facts 2008: Children, DOT HS 811 

157, National Center for Statistics and Analysis, 

1200 New Jersey Ave, SE., Washington, DC 20590, 

Page 4. 

6Traffic Safety Facts 1998: Children, DOT HS 808 

951, National Center for Statistics and Analysis, 400 

7th Street, SW., Washington, DC 20590, Page 4. 

7Traffic Safety Facts: Child Restraint Use in 

2008—Demographic Results, NHTSA Publication 

No. DOT HS 811 148, National Center for Statistics 

and Analysis, 1200 New Jersey Ave, SE., 

Washington, DC 20590, Pages 2–5. 

8Traffic Safety Facts 2008: Occupant Protection, 

DOT HS 811 157, National Center for Statistics and 

fit. Under the program, NHTSA will 

disseminate a list of child restraints that 

manufacturers suggest will fit in their 

individual vehicles on Safercar.gov. 

To participate in the program, vehicle 

manufacturers shall recommend at least 

three current model year child restraints 

within each of three different CRS 

categories (rear-facing, forward-facing, 

and booster). For the forward-facing 

category, at least one high-weight 

harness CRS shall be recommended, and 

for the booster category, no more than 

one of the three recommended booster 

seats may be a dedicated backless 

booster. Additionally, the three 

recommended CRS for each of the three 

CRS categories shall be from three 

different CRS manufacturers and shall 

also meet three established price points 

(inexpensive, moderately-priced, and 

expensive) based on the child restraint’s 

Manufacturer’s Suggested Retail Price. 

To ensure recommended CRS satisfy the 

proposed fit evaluation criteria, the 

agency is also proposing to conduct its 

own assessments to spot-check fit for 

recommended vehicle-CRS 

combinations. 

The agency is proposing this program 

for voluntary participation by vehicle 

manufacturers and is seeking comment 

on all of its aspects. 

II. Introduction 

NHTSA is primarily responsible for 

reducing deaths, injuries, and economic 

losses as a result of motor vehicle 

crashes. Child safety seats, technically 

referred to as child restraint systems 

(CRS) by Federal Motor Vehicle Safety 

Standard (FMVSS) No. 213, ‘‘Child 

restraint systems,’’ are widely agreed to 

be the most effective motor vehicle 

safety equipment available for 

restraining children. Although parents 

and caregivers strive to protect their 

children in motor vehicles, 

unfortunately, statistics on CRS misuse 

reveal that installation mistakes still 

happen with considerable frequency. A 

2004 study conducted with the support 

of NHTSA estimated that errors in 

installation, identified as critical errors 

by the study, occur at a high rate of 72.6 

percent.1 While this study found the 

most common reasons for misuse to be 

loose harness straps securing the child 

to the CRS and loose vehicle seat belt 

attachment to the CRS, other types of 

misuse were also observed. Though 

instances of misuse such as loose 

vehicle seat belts can be attributed to 

user error, in some cases it may also be 

attributed to incompatibilities between 

the CRS and the vehicle. Due to the 

variety of vehicle and child restraint 

features in the U.S. market, some 

combinations of child restraints and 

vehicles make proper installation more 

difficult to achieve. 

In the spring of 2009, the Secretary of 

Transportation tasked the agency with 

conducting a top-to-bottom review of 

child restraint regulations and consumer 

information. As a result of this internal 

review, the agency determined that 

while CRS are effective at protecting 

children, more can be done to improve 

their performance. Several agency 

initiatives were developed toward that 

end. Several programs pursue upgrading 

FMVSS No. 213 by adding side impact 

requirements to the standard, and by 

evaluating future improvements to its 

frontal impact requirements. 

In addition, a new consumer 

information initiative was begun to 

enhance the ease with which parents 

and caregivers can choose a CRS for 

their vehicle, knowing that the CRS will 

fit their vehicle when installed. Under 

the program, NHTSA will make 

available recommendations from vehicle 

manufacturers as to the specific child 

safety seats, in various price ranges, that 

fit in individual vehicles. NHTSA 

believes that providing parents with 

information about which child restraints 

fit in their vehicle(s) will improve 

consumers’ confidence in and comfort 

with using CRSs, and will reduce 

installation mistakes. 

This document describes the agency’s 

efforts to develop, pilot test, and 

propose a Vehicle-CRS Fit program for 

consumer information purposes. The 

agency is proposing this program, which 

will be part of NHTSA’s New Car 

Assessment Program (NCAP), for 

voluntary participation by vehicle 

manufacturers and is seeking comment 

on all of its aspects. Vehicle 

manufacturers who wish to participate 

could use finalized versions of the 

evaluation forms provided in this 

document as a means of determining 

whether a particular CRS meets the 

agency’s criteria for fit in their vehicles. 

Once a vehicle manufacturer has 

determined that a child restraint 

satisfies the agency’s criteria for fit, it 

may submit this information to NHTSA 

for publication on the agency’s 

consumer information Web site, http:// 

www.safercar.gov.2

III. The Current Child Safety Problem 

Child restraints reduce fatal injury by 

71 percent for children less than 1 year 

old and by 54 percent for toddlers (1– 

4 years old) in passenger cars.3

Similarly, in light trucks, the 

corresponding reductions are 58 and 59 

percent for infants and toddlers. 

The agency, along with 

manufacturers, local governments, and 

consumer groups, have consistently 

urged the public to put all children in 

age-appropriate restraints in the rear 

seats of vehicles. In recent years, many 

States have also passed child restraint 

and booster seat laws, which require 

children to travel in approved restraints 

for their age.4 These education and 

regulatory efforts are working; over the 

past decade, the percentage of 

unrestrained child fatalities has 

decreased significantly: 23 percent in 

2008 5 compared to 43 percent in 1998.6

In June of 2009, NHTSA published a 

Research Note that provided more 

detailed demographic information about 

child restraint use. In a national 

probability sample of gas stations, day 

care centers, recreation centers, and 

restaurants in five fast food chains, it 

determined that 99 percent of children 

under age 1, 92 percent of children from 

ages 1 to 3, 89 percent of children ages 

4 to 7, and 85 percent of children ages 

8 to 12 were restrained.7

Tragically, in 2008, there were still 

297 passenger vehicle occupant 

fatalities among children under 4 years 

of age. Restraint use was not known for 

all of these fatalities, but of the 282 

children whose restraint use was 

known, 94 (32 percent) of those children 

were unrestrained. In the same year, 

however, an estimated 244 lives of 

children under age 5 were saved by 

proper restraint use. Of these lives 

saved, 219 were attributed to the use of 

child restraints and 25 to the use of 

adult safety belts. If 100 percent 

restraint use for children under age 5 

had been attained in 2008, the agency 

estimates that 79 additional lives, for a 

total of 323 children, could have been 

saved that year.8


srobinson on DSKHWCL6B1PROD with NOTICES
Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 10639 

Analysis, 1200 New Jersey Ave, SE., Washington, 

DC 20590, Page 4. 

9 67 FR 67448, Docket NHTSA–2001–10053. 

10 73 FR 6261, Docket NHTSA–2006–25344. 

11Ease of Use Ratings can be found either in 

Docket NHTSA–2006–25344 or at http:// 

www.nhtsa.gov/portal/nhtsa_eou/. 

12Some child restraints have built-in devices for 

locking the vehicle seat belt in place so that the 

retractor or separate locking clips do not have to be 

used. 

13These experts include members of The National 

Child Passenger Safety Board, AAA, Safe Kids 

Worldwide, The Children’s Hospital of 

Philadelphia, vehicle and CRS manufacturers, and 

others. 

14CPST best practice methodology is considered 

the most acceptable way to transport a child safely 

on the basis of the child’s age, weight, height, and 

body development. 

IV. NHTSA’s CRS Activities 

When a parent or caregiver is seeking 

information regarding a new CRS 

purchase, the agency’s guidance is that 

a caregiver should select a restraint that 

is certified as meeting FMVSS No. 213, 

fits the child, can be used correctly 

every time, and can achieve a proper 

installation in the vehicle in which it 

will be used. The agency addresses 

these recommendations in the following 

ways: 

• All child restraints sold in the 

United States must comply with the 

requirements in FMVSS No. 213. This 

standard contains dynamic frontal 

impact sled tests as well as strict 

labeling and component durability and 

strength requirements. All child 

restraints are evaluated on a pass-fail 

basis. Test dummies representing 

newborn, twelve-month-old, three-yearold, and six-year-old children are 

secured in age-, height- and weightappropriate CRS to evaluate their 

dynamic performance. The latter three 

dummies are instrumented and must 

meet HIC (Head Injury Criterion), head 

excursion, and chest acceleration 

requirements when subjected to the 213 

test. FMVSS No. 213 also specifies knee 

excursion requirements for CRS tested 

with the three-year-old and six-year-old 

dummies, and additional structural 

durability and requirements with which 

all CRS must comply. 

• To ensure that consumers choose a 

child restraint that fits their child, the 

agency created its 4 Steps for Kids 

consumer information campaign. This 

initiative arranges the agency’s child 

passenger safety message into four 

phases, or ‘‘steps,’’ of a child’s 

development. The first three ‘‘steps’’ are 

CRS-related guidelines that explain to 

consumers how to properly transition 

children from rear-facing restraints to 

forward-facing restraints and finally to 

belt-positioning boosters. The fourth 

‘‘step’’ provides information on when it 

is appropriate for children to transition 

into rear seat adult lap/shoulder belts. 

Choosing age-, height-, and weightappropriate restraints for children 

throughout their development reduces 

their risk of injury in a crash. 

• As mentioned earlier in the 

introduction, high rates of misuse for 

child restraints have been observed. To 

address this concern, along with child 

restraint usability, the agency conducts 

a CRS Ease of Use (EOU) program. The 

agency published a Final Notice 

announcing the EOU program in 

November of 2002.9 This program 

created child restraint usability ratings 

based on five categories: Ease of 

Assembly, Clarity of Labeling, Clarity of 

Instructions, Ease of Securing the Child, 

and Ease of Securing the CRS in the 

Vehicle. Substantial improvement in 

CRS usability features was observed: 

Only 57 percent of child restraints 

received the top rating when the 

program began, and by 2007, 81 percent 

of child restraints received the top 

rating. In 2008, the program was 

updated to reflect changes in the CRS 

fleet by: Amending certain criteria, redistributing the Ease of Assembly 

criteria category among the remaining 

four, and converting to a five-star rating 

system instead of the previous threeletter rating system.10 The agency 

continues to add child restraint 

usability ratings to the list each year. As 

of December 2009, ratings for 128 child 

restraints were available.11 Child 

restraints are evaluated separately from 

vehicles through this program, but 

certain facets of the program relate to 

vehicle installation. The ‘‘Ease of 

Securing the CRS in Vehicle’’ category 

addresses features on the child restraint 

that aid in vehicle installation. For 

example, built-in seat belt lock-offs 12

eliminate the need for a locking clip in 

many instances. Wider belt paths allow 

the caregiver to more easily route the 

seat belt or lower attachment belt 

through the belt path, and push-button 

lower anchor connectors may be pushed 

on and removed with the touch of a 

button. Features such as these lessen the 

effort required to install a child restraint 

and are, in many cases, accommodated 

by the vehicle. 

• The agency also conducts several 

other child passenger safety initiatives. 

NHTSA maintains the content of the 

National Child Passenger Safety 

Certification curriculum through 

partnerships with respected child 

passenger safety experts.13 This 

certification program is estimated to 

have trained tens of thousands of 

interested individuals to become Child 

Passenger Safety Technicians (CPSTs). 

During this certification, individuals 

learn how to properly install a large 

variety of child restraints and how to 

assist parents and caregivers in doing so 

themselves. CPSTs are an especially 

valuable resource to the agency because 

they can provide information to the 

caregivers at the community level. The 

curriculum is monitored and updated as 

necessary based on changes to the CRS 

fleet and best practice methodology.14

The agency also manages National Child 

Passenger Safety Week, an annual 

campaign during which community 

organizations across the country host 

safety seat checkups and other child 

passenger safety awareness events. 

NHTSA’s major child passenger safety 

initiatives (FMVSS No. 213, 4 Steps for 

Kids, Ease of Use, and the CPST 

Curriculum) help parents and caregivers 

select an age-, height-, and weightappropriate CRS that is simple to use 

and that is safe. However, the agency 

has recognized for some time that 

because of incompatibility issues 

between the vehicle and the CRS, 

parents and caregivers may still have 

difficulty not only selecting a CRS that 

fits their vehicle(s), but also properly 

installing selected child restraints in 

their vehicle(s). The CPST Curriculum 

may also not reach the general public. 

Accordingly, the agency has taken 

several steps to address vehicle-CRS 

compatibility issues. 

V. Addressing Vehicle-CRS 

Compatibility 

A. Consumer Information 

To date, the agency’s attempts at 

developing a consumer information 

program that addresses vehicle-CRS 

compatibility issues have encountered a 

number of challenges. One of the most 

difficult issues the agency has had to 

resolve is how to manage the enormous 

amount of information that can be 

generated on the dozens of CRSs and 

vehicles on the market and the possible 

interface between each CRS and each 

vehicle model. 

In the fall of 1995, NHTSA tried to 

develop a vehicle and child restraint 

database. At the time, the agency 

surmised that a vehicle-CRS matrix 

could be distributed via CD–ROM to 

caregivers, child passenger safety 

advocates, and any other parties that 

educate the public about proper child 

restraint use. The resulting matrix was 

intended to be all-inclusive; information 

on specific child restraints would be 

coupled with details about vehicle 

makes, models, and available seating 

positions in which they could be 

successfully installed. However, during 

the database development, the agency 


srobinson on DSKHWCL6B1PROD with NOTICES
10640 Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 

15 Decina, L.E., Lococo, K.H., Doyle, C.T., Child 

Restraint Use Survey: LATCH Use and Misuse, 

NHTSA Publication No. DOT HS 810 679, National 

Highway Traffic Safety Administration, December 

2006, Page 2. 

16Additionally, it was found that caregiver 

preference played a large role in LATCH use. For 

example, even though the CRS may technically fit 

in the vehicle seat, the caregiver may find that 

locating the LATCH anchors is difficult due to stiff 

vehicle cushions or the deep placement of anchors 

within some vehicles’ seat bights. Others may 

simply be more comfortable using the seat belt to 

install the child restraint because of prior 

experience with that method of installation; others 

may simply assume that the seat belt is safer. 

17The agency’s review of child restraint 

consumer information programs is included as 

Appendix A. 

18 ISO is a collection of organizations from 162 

countries responsible for establishing world-wide 

voluntary industry standards. Representatives from 

determined that its initial work toward 

providing information on the 

compatibility of 35 CRS with 100 

vehicles from model years 1993–1996 

was overly ambitious. The sheer number 

of vehicle/CRS combinations made the 

data collection efforts overwhelming, 

especially considering that the agency 

was only working with a subset of the 

entire vehicle and CRS fleets. The initial 

matrix was also limited in its 

usefulness; the data applied only to the 

specific combinations of vehicles and 

child restraints listed. Because the 

development of the database proved 

unworkable, and because adoption of a 

standardized CRS attachment system 

was under consideration, the agency 

decided to discontinue its efforts to 

develop a vehicle-CRS matrix. 

B. LATCH 

On March 5, 1999, the agency issued 

a final rule establishing FMVSS No. 225, 

‘‘Child restraint anchorage systems.’’ 

This standard, which became fully 

effective on September 1, 2002, required 

the Lower Anchors and Tethers for 

CHildren (LATCH) system in most 

passenger vehicles and compatible 

hardware components on child 

restraints. A ‘‘LATCH’’ system is 

comprised of a set of small bars (known 

as lower anchors) located near the seat 

bight, and a third attachment point 

(known as a top tether anchor) located 

above or behind the vehicle seat. 

FMVSS No. 225 requires a LATCH 

system to be installed at two rear seating 

positions on vehicles, and a top tether 

anchor at a third position. The final rule 

also amended FMVSS No. 213 to require 

child restraints to be equipped with 

attachments that mate with vehicles’ 

lower anchors. 

The intention of the rulemaking was 

to provide an easy-to-use CRS 

attachment system that is independent 

of the vehicle seat belts. Through 

LATCH, incompatibility problems were 

reduced, and CRS installation made 

more intuitive and more effective. 

LATCH successfully resolved some of 

the compatibility problems that users 

experienced with seat belts. In most 

vehicles, child restraints can be 

installed using LATCH successfully. In 

a 2006 NHTSA survey, loose installation 

rates of child restraints had decreased 

from previous studies: Sixty-one percent 

of child restraints were securely 

installed using LATCH in the 2006 

study, whereas a 2004 study examining 

incorrect installations with seat belts 

found only up to forty-six percent of 

child restraints were securely 

installed.15 The report concluded that 

there are two main reasons for this 

development: The absence of locking 

clips and the simplified process of 

fastening the LATCH attachments to the 

vehicle anchors. Many caregivers prefer 

using LATCH over seat belts when 

possible. Of those surveyed with 

experience using both LATCH and a 

seat belt, seventy-five percent preferred 

LATCH. Fifty-five percent of those who 

did not use LATCH were either unaware 

that lower anchors were available in 

their vehicle or were unsure how to use 

them.16

In short, the LATCH system has 

successfully provided caregivers with 

an alternative to seat belts installations. 

Caregivers using LATCH to install their 

child restraint no longer have to 

remember a host of additional seat belt 

installation steps such as locking the 

vehicle seat belt when installing the 

child restraint. They also do not have to 

wrestle with seat belt geometry 

incompatibilities such as buckle stalk 

lengths and anchor points. 

VI. Considerations for Development of 

a New Consumer Information Program 

To Address Vehicle-CRS Compatibility 

NHTSA is committed to improving 

vehicle-CRS compatibility and 

providing better consumer information. 

LATCH has improved the ease with 

which a CRS can be installed in a 

vehicle; however, it does not 

standardize the contours of the vehicle 

seat or the footprint of the CRS. 

Consequently, some child restraints 

might fit a particular vehicle better than 

other child restraints. Getting parents to 

select a restraint that is known to fit 

their vehicle ensures that they begin the 

installation process with a higher 

potential for success and level of 

efficiency in attaining a correct 

installation. It can also reduce their 

frustration and confusion. For these 

reasons, the agency has decided to 

develop and propose a consumer 

information program to address CRS fit 

in vehicles. 

The agency hopes that a program that 

focuses on vehicle-CRS compatibility 

will drive not only improved vehicle 

designs, but perhaps improved CRS 

designs, too, as child restraint and 

vehicle manufacturers will likely have 

to work together to address the need for 

increased compatibility. Changes to CRS 

footprints, redesigned belt paths, and 

more LATCH-friendly hardware are a 

few of the design changes that could be 

introduced as a result of compatibilityfocused efforts. Although the agency 

realizes that implementation of such 

changes may take time, we believe that 

voluntary design improvements will 

nonetheless occur due to the increased 

cooperative efforts between vehicle and 

CRS manufacturers to improve vehicleCRS compatibility. 

To best serve consumers, the agency 

believes that any program designed to 

assess vehicle-CRS compatibility should 

complement and supplement other 

child restraint and vehicle information 

it promulgates. Such a program should 

also result in a robust, repeatable 

assessment so that it is effective at not 

only helping parents and caregivers 

choose a child restraint that fits their 

vehicle(s), but also, in turn, helps deter 

misuse and frustration stemming from 

incompatibilities. We believe this can 

best be achieved by developing a 

program that is based solely on objective 

criteria. A program based on objective 

criteria should be simpler for 

manufacturers and evaluators to 

understand and use compared to one 

based on subjective assessments. 

Establishing objective assessment 

criteria should also help to minimize 

manufacturer concerns that consumers 

selecting a recommended CRS may still 

have difficulty fitting the CRS in their 

vehicle(s). This may promote increased 

voluntary participation as a result and 

ultimately provide consumers with the 

CRS information that they need. 

VII. Review of Worldwide Child 

Restraint Consumer Information 

Programs 

In developing a program that would 

assist consumers in finding a child 

restraint that fits in their vehicle(s), 

NHTSA examined other child restraintrelated consumer information and rating 

programs internationally and did not 

find a system that met all of the agency’s 

needs.17 However, a portion of a draft 

ISOFIX usability standard developed by 

the International Standards 

Organization (ISO) was found to be most 

relevant.18


srobinson on DSKHWCL6B1PROD with NOTICES
Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 10641 

these countries have helped publish over 17,500 

international standards on various technical 

subjects, products, and processes. 

19 ISO/DIS 29061–1. Road vehicles—Methods and 

criteria for usability evaluation of child restraint 

systems and their interface with vehicle anchorage 

systems. 

20 Vehicle-CRS fit recommendations will be 

accepted only for those vehicles having Gross 

Vehicle Weight Ratings (GVWRs) of 10,000 lbs. or 

less, as this program is intended to supplement 

NCAP, which limits testing to vehicles having 

GVWRs of 10,000 lbs. or less. 

21The agency understands that in some cases, 

such as in transporting four children in a vehicle 

with only five seating positions, forward-facing 

restraints or booster seats may be correctly installed 

in the front right passenger seat. However, as the 

agency wants to encourage that children be 

properly restrained in the rear of the vehicle unless 

the vehicle in which they are traveling does not 

have a rear seating location, the agency does not 

want to suggest to parents and caregivers that the 

front seat is an acceptable travel position for 

younger occupants by providing vehicle-CRS fit 

recommendations for this seat. Therefore, the 

agency does not expect vehicle manufacturers to 

Continued 

In 1999, ISO published a draft 

standard outlining specifications for a 

rigid anchor system, known as 

‘‘ISOFIX,’’ for attaching child restraints 

to vehicles. In 2004, it also developed a 

draft standard on tether anchorages and 

their acceptable locations in vehicles. 

Together, these two draft standards 

outlined the requirements for a 

dedicated in-vehicle CRS installation 

system that is very similar to the U.S. 

LATCH system. In addition, ISO has 

since drafted rating forms for evaluating 

the usability of vehicle ISOFIX designs 

with different child restraints.19 The 

intent of these ratings forms is to assess 

the usability of a particular vehicle’s 

ISOFIX system as well as a particular 

child restraint’s installation features 

(which is similar to, but not as 

comprehensive as, the agency’s current 

Ease of Use program). In addition, the 

forms also assess the interface between 

that vehicle and CRS when the user 

actually performs an installation. 

Of all the consumer information and 

ratings programs the agency examined, 

the ISO draft standard most closely fit 

the agency’s needs because of its unique 

assessment of the installation interface 

between a CRS and a vehicle. However, 

the agency was not able to draw 

extensively from the draft ISO usability 

standard for the proposed Vehicle-CRS 

Fit program for a number of reasons. For 

instance, in light of its comprehensive 

Ease of Use program, the agency did not 

see a need for including a CRS usability 

evaluation as a part of this Vehicle-CRS 

Fit program, nor did the agency feel that 

inclusion of criteria pertaining to the 

usability of CRS attachment hardware 

was warranted. Adopting a program that 

evaluates the actual vehicle-CRS 

interface would effectively address 

certain ISO criteria related to the 

usability of CRS attachment hardware in 

vehicles because the attachment 

hardware may generate installation 

issues, such as instability, that can 

prohibit a child restraint from fitting 

properly in a vehicle. Some of the ISO 

criteria also incorporate the ease of 

performing tasks related to the 

installation, and many of these are then 

designated ‘‘good,’’ ‘‘average,’’ or ‘‘poor.’’ 

For the proposed program, the agency 

wanted to include only objective 

installation criteria that pertain to 

proper fit, i.e., whether a proper fit was 

achieved, not the ease of attaining that 

fit. In addition, the ISO draft rating 

forms only evaluate ISOFIX 

installations. The agency wanted a 

program that assessed both LATCH and 

seat belt installations. Finally, the ISO 

draft standard does not cover booster 

seats either, and the agency wanted to 

include these in its Vehicle-CRS Fit 

program since they are an important 

part of its child passenger safety 

initiatives. 

VIII. Conditions for Participation, 

Program Administration, and 

Distribution 

Observations from an agency pilot 

study confirmed that installation issues 

can arise from either the child restraint 

or the vehicle, and can also be vehicleCRS interface specific. For some 

vehicles, the same fit problem was 

observed when installing several 

different CRS types (infant, convertible, 

combination, booster, etc.) and models 

of child restraints. Considering that 

these same child restraints could be 

properly installed in several other 

vehicle models, it appears that for the 

vehicle models in which the subject 

child restraints would not fit, design 

changes to accommodate a greater 

number of CRS models would be 

appropriate. In some instances, 

inadequate fit was observed for every 

seat belt or LATCH installation for every 

child restraint installed in a vehicle. 

Therefore, it is likely that manufacturers 

of such vehicles would need to make 

changes to improve fit for both LATCH 

and seat belt installations to have 

information included in the consumer 

information program described today. 

Additionally, it was found that certain 

vehicle features may prohibit the 

installation of certain types of CRS in 

certain seating positions. Consequently, 

it may not be reasonable for vehicle 

manufacturers to claim that a child 

restraint fits in all applicable seating 

locations within a vehicle. Furthermore, 

space constraints, particularly for 

smaller vehicle models, may dictate the 

position of a vehicle’s front seats or rear 

seating positions that are acceptable for 

installation of certain CRS. 

A. Conditions for Participation in the 

Vehicle-CRS Fit Program 

In the interest of time and the need for 

improved consumer information, the 

agency is proposing that this program 

begin as a voluntary effort in MY 2012 

for vehicle manufacturers only; however 

we are seeking comment on whether 

more time is needed. We believe that 

consumers will shop for a CRS having 

their vehicle already in mind, so it 

would be most reasonable for the fit 

program to be vehicle-based. The agency 

also believes gaining access to vehicles 

is more difficult and burdensome for 

child restraint manufacturers than it is 

for vehicle manufacturers to gain access 

to child restraints. However, the agency 

does not think that child restraint 

manufacturers should be excluded from 

the vehicle-CRS fit efforts; in fact, the 

contrary is true. NHTSA highly 

encourages vehicle and child restraint 

manufacturers to work together to 

complete these fit assessments. 

However, at this time, the agency will 

only collect vehicle-child restraint fit 

suggestions from vehicle 

manufacturers.20

The agency is proposing that vehicle 

manufacturers should install child 

restraints in their vehicles, and while 

doing so, should bear in mind the 

considerations outlined throughout this 

document, and use the evaluation forms 

included in Appendix D (once they are 

finalized) to assess CRS fit in their 

vehicles. For a manufacturer to indicate 

that a specific child restraint fits in a 

particular vehicle, the child restraint 

must be assessed in all applicable 

modes of use and in all appropriate 

seating positions in the vehicle. 

Depending on the restraint, modes of 

use can include, but are not limited to: 

Rear-facing, forward-facing, booster 

(high-back and backless), with and 

without a base, and with both ‘‘short’’ 

and ‘‘long’’ belt paths, where applicable. 

Child restraints that manufacturers 

determine fit a vehicle must fit in every 

appropriate seating location in the 

vehicle. For most passenger cars, 

appropriate seating positions will 

include those in the rear or second row; 

however, additional rows of seating 

must also be assessed, if applicable. 

Because of the agency’s continuing 

efforts to ensure that children ride in the 

rear seat, the agency does not expect 

manufacturers of vehicles with rear 

seats that can accommodate child 

restraints to provide fit suggestions for 

the front right passenger seat.21 For twoVerDate Mar<15>2010 16:39 Feb 24, 2011 Jkt 223001 PO 00000 Frm 00087 Fmt 4703 Sfmt 4703 E:\FR\FM\25FEN1.SGM 25FEN1

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assess front right passenger seat fit if a usable rear 

seat exists. 

seaters and pickup trucks without a rear 

seat that have an air bag on-off switch, 

however, we believe that it would be 

appropriate to indicate child restraints 

that fit the front right passenger seat. 

The agency is proposing to not permit 

manufacturer recommendations of child 

restraints or boosters that fit in only 

certain seating positions or rows in the 

vehicle. The agency feels that parents 

and caregivers who purchase a child 

restraint for their vehicle based on this 

program should have the option to use 

it in all appropriate seating locations. 

This is especially important when the 

family grows and child restraints are 

often moved from the center to the two 

outboard seating positions or from the 

second to the third row. However, the 

pilot study showed that it may be 

difficult for vehicle manufacturers to 

meet this condition for participation. In 

a number of cases, an excellent fit was 

possible in outboard seating positions, 

but not in the center position, or viceversa. Accordingly, although the agency 

tentatively believes that this stipulation 

is necessary, we are requesting comment 

on whether we should permit a CRS to 

be identified by the vehicle 

manufacturer as fitting its vehicle even 

if the CRS does not fit in all seating 

positions. Although we would like 

eventually to list only those child 

restraints that fit unconditionally in 

vehicles, should we accept, at this point 

in the program, a listing of CRSs that fit 

in only certain seating positions? 

Limitations on CRS use in the vehicle 

could be noted on Safercar.gov. We 

question whether requiring that a CRS 

fit all seating positions in all rows 

(except the driver’s seat row) may result 

in reduced vehicle manufacturer 

participation in the short term and no 

CRS being listed for a number of 

vehicles on Safercar.gov. 

Although vehicle manufacturers must 

ensure that recommended child 

restraints fit for all applicable modes of 

their use, the agency has tentatively 

decided to allow the manufacturer to 

specify that a child restraint fits when 

installed with either LATCH or the 

vehicle seat belts (plus top tether, if 

applicable). Of course, it is most ideal 

for a child restraint to fit correctly using 

either method of installation. However, 

the agency’s pilot study revealed that 

requiring both methods for this program 

would make it difficult for many 

manufacturers to participate. Depending 

on the vehicle design, either a LATCH 

or seat belt installation was found to be 

problematic for many of the CRS 

selected for the pilot study, but not 

necessarily both. 

The agency feels that giving the 

vehicle manufacturers the option to 

assess fit for either LATCH or seat belt 

installations will likely result in better 

participation and useful information for 

consumers. This approach can alert 

consumers to incompatibilities related 

to LATCH anchor spacing, seat belt 

length, buckle stalk length, etc., that 

they may not have been otherwise aware 

of, hopefully decreasing the number of 

incorrect installations in the field. The 

agency also suspects that some vehicle 

manufacturers will be interested in 

making design changes to increase the 

number of child restraints that can 

achieve a proper installation in their 

vehicle(s) with either LATCH or seat 

belts. The agency recognizes, however, 

that making vehicle improvements to 

either system can require some lead 

time. Consequently, in the interim, 

manufacturers can provide consumers 

with fit suggestions based on either 

child restraint installation method. 

The agency is also proposing that to 

participate in the Vehicle-CRS Fit 

program (i.e., to have the CRS 

information included on Safercar.gov), 

vehicle manufacturers need to identify 

at least three current model year child 

restraints within each of three different 

categories: rear-facing, forward-facing, 

and booster. We are proposing to 

condition participation on listing 

restraints in all type/age categories as a 

way to encourage manufacturers to 

address systematically and 

comprehensively the issue of CRS fit for 

all ages and sizes of children. These 

categories were also chosen because 

they follow NHTSA’s 4 Steps for Kids 

program. 

Child restraints within each of the 

three type/age categories should also be 

from three different child restraint 

manufacturers. This condition for 

participation is being proposed to 

encourage vehicle manufacturers to 

work with a variety of child restraint 

manufacturers and products. It will also 

discourage a vehicle manufacturer from 

forming partnerships with only one 

child restraint manufacturer and thus 

minimize consumer confusion or belief 

that only one brand of child restraint is 

acceptable for use in their vehicle. Also, 

NHTSA believes that this condition may 

give manufacturers with low volume 

child restraint models the opportunity 

to gain additional exposure. To satisfy 

the booster category, we are proposing 

that no more than one of the three 

booster seats can be a dedicated 

backless booster. This condition is being 

proposed for a few reasons. For one, 

most backless boosters have higher 

minimum height and weight 

requirements than their high-back 

counterparts. Therefore, requiring more 

high-back boosters in order to 

participate serves to cover a greater 

range of child sizes. In addition, some 

high-back boosters are designed such 

that the back can eventually be removed 

and used as a backless booster when the 

child reaches a certain height. In this, 

there are a number of products on the 

market that are both styles in one and 

would have to be evaluated for fit in 

both high-back and backless modes 

anyway. Further, the agency suspects 

that due to their increased complexity, 

high-back boosters will likely exhibit 

more fit complications. 

The agency is tentatively proposing to 

not permit vehicle manufacturers to 

recommend fewer than three child 

restraints for any one of the three 

categories (rear-facing, forward-facing, 

and booster); recommendations of only 

one or two child restraints for any one 

category will not be posted on 

Safercar.gov. The agency questions 

whether this approach is appropriate or 

whether providing one or two 

recommendations for any one category 

may better serve consumers than 

providing no CRS recommendations for 

a particular category. Comments are 

requested on this issue. 

Since it is generally advisable for 

parents to keep children in a harness for 

as long as possible to ensure the highest 

level of crash protection, the agency is 

proposing to further stipulate that at 

least one high-weight harness CRS be 

identified in the forward-facing 

category. These high-weight harness 

CRS are child safety seats that allow use 

of internal harness systems on children 

weighing more than 40 pounds. If a 

vehicle manufacturer has fulfilled the 

basic program participation conditions, 

they then have the option of also 

recommending ‘‘All-in-one,’’ ‘‘three-inone,’’ and built-in child restraints. 

Recommendations made for these CRS 

types, however, are optional. They 

would have to be in addition to those 

made for child restraints outlined 

previously as conditions for 

participation. Figure 1 depicts the 

acceptable types of CRS that can be 

recommended within each of the three 

main categories. 


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22Similar to how NHTSA conducts its EOU 

program, the agency is proposing that two twoperson agency teams would spot-check fit 

recommendations in the same vehicle. If both teams 

did not reach similar conclusions about whether a 

CRS meets the fit requirements for a particular 

vehicle, another NHTSA representative would make 

the final determination. 

23Each year, vehicle manufacturers provide 

evidence to the agency that they have conducted 

(and passed) a series of tests designed to assess the 

aggressivity of side air bags with respect to out-ofposition occupants. Participating vehicle 

manufacturers are given credit on Safercar.gov in 

exchange for providing this data. 

The agency’s last proposed condition 

for participation in this program regards 

price points. Within each of the three 

categories (rear-facing, forward-facing, 

and booster), vehicle manufacturers 

must identify products that meet 

established price categories based on the 

child restraint’s Manufacturer’s 

Suggested Retail Price (MSRP). The 

proposed price points for each category, 

which were established based on a 

survey of model year 2009 CRS, are 

shown in Table 1. These price points 

were established so that CRS selection 

is not limited to the most expensive 

child restraints available, and again to 

ensure a variety of CRS makes and 

models. A child restraint does not need 

to be expensive to provide adequate 

crash protection. Likewise, the agency 

wants to encourage through this 

program that a child restraint does not 

need to be expensive in order to fit 

properly in one’s vehicle. If a vehicle 

manufacturer would like to fulfill only 

the minimum conditions for 

participation for three child restraint 

recommendations in a particular 

category, they must include at least one 

restraint that falls in the ‘‘inexpensive’’ 

range and at most one restraint in the 

‘‘expensive’’ range. If more than three 

child restraints are recommended for 

any one category, the additional child 

restraints may fall within any price 

point the vehicle manufacturer chooses. 

The agency is proposing to provide 

vehicle manufacturers with this pricepoint information with the Buying a 

Safer Car information request and plans 

to re-evaluate the price points as 

needed. Comments are requested on this 

approach. 

TABLE 1—PRICE POINTS FOR CRS CATEGORIES

Rear-facing Forward-facing Booster 

Inexpensive .......................................................................................................... < $100 < $130 < $80 

Moderately Expensive ......................................................................................... $100–$200 $130–$230 $80–$100 

Expensive ............................................................................................................ > $200 > $230 > $100 

B. Program Administration 

The agency proposes that the easiest 

way to collect child restraint and 

vehicle fit suggestions is through 

NCAP’s annual Buying a Safer Car 

information request since vehicle 

manufacturers are already familiar with 

its submission process. Though 

participation in this program would be 

voluntary, the agency would also need 

to ensure that any fit information it 

receives from manufacturers is correct. 

As in the pilot study, the agency could 

rent or lease vehicles to spot-check 

child restraints identified by vehicle 

manufacturers as fitting specified 

vehicles. Using the final versions of the 

evaluation forms proposed in this 

document, the agency would spot-check 

the vehicle-CRS fits identified by the 

vehicle manufacturers.22

C. Program Distribution 

The agency is proposing that the 

vehicle-CRS fit combinations identified 

by vehicle manufacturers be published 

via the Safercar.gov Web site, the 

agency’s main consumer information 

portal. Adding this information to 

Safercar.gov can provide consumers 

with the best available vehicle-CRS fit 

information and provide market 

incentives among manufacturers. In the 

past, this has helped to ensure the 

success of voluntary programs such as 

the agency’s side air bag out-of-position 

testing initiative through NCAP.23

Nearly every vehicle manufacturer 


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24Federal Register Volume 72, No 175, 51908– 

51973. September 11, 2009. 

voluntarily participated in this program 

within two years. The agency has also 

taken a similar approach in MY 2011 for 

promoting vehicles with advanced crash 

avoidance technologies.24 Though this 

program does not assess the occupant 

protection afforded by a particular 

vehicle-CRS combination in a crash, the 

agency believes that giving consumers 

information on whether a child restraint 

may be installed properly in a vehicle 

does provide indirect safety benefits. By 

providing consumers with information 

about child restraints that have been 

successfully installed in particular 

vehicles, the agency seeks to improve 

consumers’ confidence in and comfort 

with selecting and using CRSs, and to 

reduce installation mistakes in the field. 

For the Vehicle-CRS Fit program, the 

agency is proposing to display all 

suggested child restraints along with 

information pertaining to vehicle star 

ratings and safety features. As is the 

case in the Ease of Use program, NHTSA 

plans to minimize consumer confusion 

by emphasizing to consumers that the 

child restraint suggestions are not 

recommendations based on the CRS or 

vehicle’s safety performance. 

Furthermore, to reduce manufacturer 

concerns that displaying particular 

child restraint suggestions on 

Safercar.gov will imply that assessments 

are an indicator of occupant safety in 

the event of a vehicle crash, the agency 

proposes to add a disclaimer to the 

Vehicle-CRS Fit assessment section of 

the Web site which will state, ‘‘NOTE: 

The restraints above have been 

determined to fit successfully in this 

vehicle via the method(s) listed. This is 

an assessment of installation ONLY and 

should NOT be considered a safety 

claim for the vehicle or the child 

restraint. ALL child restraints and 

vehicles sold in the United States must 

pass rigorous Federal standards. Child 

restraints provide high levels of safety 

when selected to be age- and sizeappropriate for the child and properly 

installed.’’ 

In addition, it will be further 

explained that the child restraints listed 

may not be the only products that can 

achieve a successful installation in that 

vehicle. To address concerns that 

parents and caregivers may believe that 

child restraints listed on Safercar.gov 

are the only CRS that are acceptable for 

their child and that will fit in their 

vehicle, the agency proposes to also 

include the following note: ‘‘This list of 

child restraints is not all-inclusive. 

Vehicle manufacturers voluntarily 

provide this information for parents and 

caregivers as a starting point to help 

them select a child restraint that fits 

their child and fits their vehicle. You 

may find other child restraints that fit 

equally as well as those presented 

above. Also, you may contact a Child 

Passenger Safety Technician (CPST) in 

your area to check that your child seat 

both fits and is installed properly in 

your vehicle by clicking here: http:// 

www.nhtsa.gov/cps/cpsfitting/ 

index.cfm.’’ 

If, during spot-checking activities, a 

child restraint is found to not meet the 

fit assessment criteria, NHTSA is 

proposing to remove that information 

from Safercar.gov Web site. This is 

consistent with removing the ‘‘M’’ from 

vehicles determined not to meet the side 

air bag out-of-position testing 

requirements. The same strategy was 

employed when spot-checking the 

performance of certain crash avoidance 

technologies for MY 2011 vehicles and 

beyond. If the deletion of that child 

restraint means the vehicle no longer 

meets the participation conditions for 

that category, the agency proposes to 

give the vehicle manufacturer the 

opportunity to indicate another child 

restraint, which will be checked for fit 

by the agency. If no alternatives can be 

found, and the vehicle no longer meets 

the program’s participation conditions, 

it is proposed that all child restraint 

suggestions for that vehicle will be 

deleted from Safercar.gov. Alternatively, 

the agency proposes to allow the vehicle 

manufacturer to contest the result from 

the spot-check test by demonstrating 

that the restraint in question fulfills the 

fit assessment criteria. Such a challenge 

will be reviewed by agency staff and a 

decision will be made as to whether the 

restraint meets the assessment criteria 

for ‘‘fit’’ and hence, the listing of the 

child restraint. 

For each vehicle model, the agency 

envisions a detailed page on 

Safercar.gov that shows consumers the 

child restraints that have been indicated 

as appropriate for all vehicle seating 

position in the three categories—rearfacing, forward-facing, and booster. We 

also propose to indicate LATCH 

availability in the vehicle and whether 

the manufacturer has indicated each 

child restraint fits properly using 

vehicle seat belts, LATCH, or both. 

Having a dedicated Web page will also 

give the agency the opportunity to 

reinforce important principles and 

programs such as 4 Steps for Kids and 

the CRS Ease of Use program. 

Consumers will be shown the height 

and weight ranges for the child 

restraints of interest. The agency also 

intends to link consumers to other areas 

of child passenger safety on NHTSA’s 

Web site as well as offer installation tips 

and best practice guidance. 

The agency intends to use this Web 

site to disseminate any installation 

notes that the vehicle manufacturer may 

need to communicate. Such additional 

information can include, but would not 

be limited to: Front seat positioning 

along the seat track, sharing of outboard 

lower anchorages to ‘‘create’’ a center 

LATCH position, instances in which 

using lower anchors or seat belts in 

certain seating locations eliminates the 

use of other positions, etc. 

IX. Pilot Study To Assess Effectiveness 

of Preliminary Vehicle-CRS Fit 

Program Evaluation Criteria 

A. Development of Vehicle-CRS Fit 

Evaluation Forms 

In deciding to model its Vehicle-CRS 

Fit program after the draft ISO CRS– 

Vehicle usability program, the agency 

wanted, most importantly, to draw on 

the concept of developing a set of 

standard criteria to achieve the most 

repeatable assessments possible. The 

agency believed that developing 

standard evaluation forms would be the 

most beneficial approach for both 

vehicle manufacturers and consumers. 

The consumer information program 

would be enhanced if vehicle 

manufacturers, CRS manufacturers, 

consumers, and NHTSA have a common 

understanding of what the program 

considers a ‘‘proper fit.’’ Vehicle 

manufacturers would be able to directly 

use these forms in their internal 

assessments and would have more 

certainty in knowing that NHTSA will 

agree with their assessments of fit. 

Without a set of evaluation criteria, it 

could be possible for some vehicle 

manufacturers to submit data to the 

agency that does not meet NHTSA’s 

expectations for a proper installation. In 

addition, if varying criteria were used, 

the agency might not be able to assist 

consumers in understanding what a 

manufacturer’s fit recommendations 

constitute. 

As mentioned previously, to ensure a 

robust assessment, the agency reasoned 

that only objective criteria should be 

considered for the Vehicle-CRS Fit 

program. Accordingly, the agency’s 

program will not assess how easily a 

child restraint can be installed in a 

vehicle, but will simply assess whether 

it can be installed successfully (i.e., 

whether the child restraint can fit in the 

vehicle). Although this is somewhat 

contrary to the draft ISO CRS-vehicle 

usability program, NHTSA believes 

there is subjectivity in the draft ISO 

criteria concerning the assessment of the 

ease of fit (such as those that require the 


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25The National Child Passenger Safety 

Certification Training Program is a curriculum 

designed to teach participants about the importance 

of child safety and how to properly install child 

restraints. Certified technicians, CPSTs, are 

equipped with the knowledge to explain 

installation procedures to parents and caregivers so 

that they may safely transport their families, and to 

empower them with the knowledge to confidently 

install and reinstall child restraints as needed. The 

training program, which is based on the concept of 

learning (the facts, skills, and information), 

practicing (the new skills and information), and 

explaining/teaching (what was learned to parents 

and caregivers), was developed by NHTSA in the 

mid-1990s and has been updated by the agency as 

needed. The National Child Passenger Safety Board 

oversees the quality and integrity of the training 

and certification requirements, while Safe Kids 

Worldwide administers certification. CPSTs receive 

hands-on experience through a variety of activities, 

including child safety seat checks, and their 

exposure to common installation problems, 

incompatibility issues, general knowledge of child 

restraints and features, make them a valuable 

resource for parents and caregivers seeking child 

restraint installation assistance. 

26The 2003.5 Mazda Prote ́ge ́ was included in this 

study because it was readily available for 

assessment and its vehicle seat characteristics were 

considered representative of those observed in the 

modern fleet. 

evaluator to assess the ease of 

performing a task). 

The agency has tentatively 

determined that the best way to 

objectively evaluate CRS fit in vehicles 

is to develop criteria based on factors 

known to influence installation, as 

outlined in the National Child Passenger 

Safety Certification Training Program 

student manual.25 The agency 

considered both general installation 

techniques (i.e., those that are required 

for all child restraint installations), as 

well as specific techniques that may be 

necessary for installation of certain 

types of child restraints or particular 

modes of use, such as ensuring that 

infant and rear-facing convertible 

restraints can be installed to the proper 

recline angle, ensuring that seat belts are 

of adequate length to install CRS with 

multiple belt paths (both long and 

short), and that the carry handle on 

infant restraints can be positioned 

according to manufacturer instructions. 

The agency was careful to incorporate 

vehicle features that influence proper 

CRS fit, such as top tether anchorages, 

lower anchorages, vehicle seat belts, and 

vehicle head restraints. In addition, we 

added criteria surrounding CRS 

installation tightness, and maximum 

weight limits of LATCH anchorages, as 

each of these factors can also dictate 

vehicle-CRS compatibility. It should be 

noted that many of the factors that were 

determined to be influential to 

achieving proper CRS installation based 

on the CPST student manual, including 

attachment to lower anchors, ability to 

tighten lower attachments once they are 

connected to lower anchors, maximum 

side-to-side and front-to-back movement 

of the CRS once it is installed, operation 

of the CRS harness once the CRS is 

installed, and tightening of the top 

tether once it is attached to the tether 

anchor, also mimicked criteria included 

in the draft ISOFIX usability standard. 

Comments are requested on our use of 

the National Child Passenger Safety 

Certification Training Program student 

manual and the manual’s 

determinations as to whether a CRS fits 

a vehicle. The benefits of using the 

manual are that the criteria contained 

therein have been used in the child 

passenger safety community for years as 

determinants of CRS fit. Accordingly, 

the manual serves as the primary guide 

to proper CRS installation and is a 

prominent child passenger safety 

resource. The installation criteria 

included in the manual are based on 

common sense, simplicity, and a ‘‘best 

practices’’ perspective. Furthermore, the 

agency’s pilot study confirmed that 

applying the criteria outlined in the 

CPST manual resulted in secure CRS 

installation. However, because the 

agency is unaware of any test or 

accident data supporting some of the 

criteria specified for proper installation, 

the agency does not know if certain 

criteria should be used verbatim from 

the manual. An example of this is the 

criterion that no more than 20 percent 

of a child restraint’s base may hang over 

the edge of the vehicle seat. Comments 

are requested as to why 20 percent 

should be used as the limit. Could the 

delineation be set at 25 percent, or 60 

percent? NHTSA requests comments on 

the merits of using each of the criteria 

discussed in this document, and 

requests that commenters supporting 

the use or non-use of a criterion submit 

data supporting their position. 

Probably the most important aspect of 

child restraint installation that the 

agency considered when developing the 

criteria, was to ensure that a given CRS 

can be installed in a particular vehicle 

according to the instructions of both the 

child restraint and vehicle 

manufacturers. The agency 

acknowledges that in the field, child 

restraints may be equipped with 

installation features that are not 

required by FMVSS No. 213. Some 

examples of these features are tethers 

that some CRS manufacturers 

recommend using on some convertible 

CRS when the CRS is installed rearfacing, and some manufacturer 

recommendations to use LATCH 

attachments on a booster seat, to keep a 

booster seat in place. Though top tethers 

on rear-facing CRSs and LATCH 

attachments on booster seats are not 

required by Standard No. 213, the 

agency believes that, if recommended by 

the child restraint manufacturer for use 

in attaching the CRS to the vehicle, such 

features must be able to be used in the 

particular vehicle being assessed. 

Accordingly, the agency believes that it 

was also important to add criteria to 

ensure that a CRS could be installed to 

meet the installation requirements 

stipulated in both the vehicle owner’s 

manual and the CRS user’s manual. 

Preliminary evaluation criteria were 

developed based on the aforementioned 

considerations and were organized into 

a draft evaluation form, which served as 

the basis for the pilot study conducted 

by the agency. This draft form is 

included in Appendix B for reference. 

B. Pilot Study Approach 

To ensure that the preliminary 

evaluation criteria were robust enough 

to assess CRS fit in vehicles, the agency 

conducted a hands-on pilot study in 

which ten CPSTs installed various child 

restraints into different makes and 

models of newer vehicles. During each 

installation, the draft evaluation forms 

were used to gauge whether the subject 

child restraint could be properly 

installed in each vehicle. The pilot 

study sought to determine whether the 

criteria were complete enough to 

reasonably assess various and important 

aspects of proper CRS installation and 

whether they could sufficiently 

highlight instances of incompatibility 

between CRS and vehicles. 

1. Vehicle Selection 

When choosing pilot study vehicles, 

the agency attempted to select various 

types of vehicles, including two- and 

four-door passenger cars, station 

wagons, and sport utility vehicles 

(SUVs). Vehicles from different 

manufacturers were selected so a wide 

range of designs and characteristics that 

could influence child restraint fit was 

included in the study.26 In addition, 

vehicles were chosen that had 

challenging seat contours, head restraint 

designs, and top tether and lower 

anchor locations. Most of the pilot study 

vehicles were rented from local car 

rental companies. Selection was 

therefore limited to vehicles that were 

available at the time of the study. 

Table 2 shows a summary of the 

vehicles that were selected for the 

study. 


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27For all child restraints and installation modes 

assessed during the pilot study, two CPSTs 

conducted independent assessments and arrived at 

a mutual agreement as to whether a CRS could be 

properly installed in a particular vehicle. 

28 It was determined that removed criteria were 

already reflected in other criteria. 

TABLE 2—PILOT STUDY VEHICLES

Body style Vehicle make model Model year 

2dr Passenger Car ...................................................................... Mitsubishi Eclipse ...................................................................... 2009 

2dr Passenger Car ...................................................................... Pontiac G5 ................................................................................. 2009 

4dr Passenger Car ...................................................................... Chevrolet Impala ........................................................................ 2009 

4dr Passenger Car ...................................................................... Chrysler Sebring ........................................................................ 2008 

4dr Passenger Car ...................................................................... Dodge Charger .......................................................................... 2009 

4dr Passenger Car ...................................................................... Ford Focus ................................................................................. 2009 

4dr Passenger Car ...................................................................... Hyundai Elantra ......................................................................... 2009 

4dr Passenger Car ...................................................................... Mazda Protege ........................................................................... 2003.5 

4dr Passenger Car ...................................................................... Toyota Yaris ............................................................................... 2008 

Station Wagon ............................................................................ Subaru Forester ......................................................................... 2006 

Sport Utility Vehicle ..................................................................... Nissan Murano ........................................................................... 2009 

Sport Utility Vehicle ..................................................................... Toyota RAV4 .............................................................................. 2007 

2. CRS Selection 

Similar to the methodology used to 

select pilot study vehicles, the agency 

sought child restraints from different 

manufacturers that covered a wide range 

of features and footprints in an effort to 

continue exploring incompatibility 

issues. The agency also selected CRS 

that spanned a large price range and 

ensured that the pilot study covered at 

least two of each of the six types of child 

restraints—infant, convertible, 

combination, high-back booster, 

backless booster, and all-in-one seats. 

To conserve funds, CRS selection was 

limited to a selection of models used for 

the 2009 CRS Ease of Use program. The 

thirteen chosen CRS are listed in Table 

3. 

TABLE 3—PILOT STUDY CHILD RESTRAINTS

CRS type CRS model MSRP 

Infant ........................................................................................... Combi Shuttle EX ...................................................................... $170 

Infant ........................................................................................... Graco Snugride 32 ..................................................................... 140 

Infant ........................................................................................... Safety 1st Designer 22 .............................................................. 80 

Convertible .................................................................................. Graco ComfortSport ................................................................... 80 

Convertible .................................................................................. Britax Boulevard CS .................................................................. 310 

Convertible .................................................................................. Sunshine Kids Radian XT .......................................................... 250 

Combination ................................................................................ Safety 1st Summit ...................................................................... 100 

Combination ................................................................................ Britax Frontier ............................................................................ 280 

High-Back Booster ...................................................................... Learning Curve B505 ................................................................. 100 

Backless Booster ........................................................................ Magna Clek Olli ......................................................................... 100 

Backless Booster ........................................................................ Evenflo Amp ............................................................................... 25 

All-in-One .................................................................................... Safety 1st All in One .................................................................. 140 

All-in-One .................................................................................... Evenflo Symphony ..................................................................... 200 

C. General Pilot Study Observations 

The pilot study exposed vehicle-CRS 

incompatibility issues stemming from 

vehicle seat belts, lower anchorages, top 

tether anchorages, vehicle interior 

space, and vehicle seat geometry, each 

of which will be described in the 

sections to follow. The specific results 

of the pilot study are included as 

Appendix C of this document. 

Based on the pilot study evaluation 

form criteria, not every child restraint in 

the pilot study was determined to fit 

properly in every pilot study vehicle. 

More incompatibilities were observed 

during seat belt installations than 

during those with LATCH. When seat or 

seat back contour incompatibilities were 

observed, it often led to neither method 

of installation meeting the pilot study 

criteria for fit. There were no child 

restraints that were unable to fit in any 

pilot study vehicle according to the 

pilot study evaluation forms. Likewise, 

there was no vehicle in which none of 

the pilot study child restraints were 

determined to fit. However, it is clear 

from the chart in Appendix C that some 

vehicles had more incompatibilities 

with pilot study CRS than others. 

Likewise, some pilot study child 

restraints had more incompatibilities 

with the pilot study vehicles than 

others. 

In general, the evaluation criteria used 

for the pilot study permitted robust and 

repeatable assessments.27 However, it 

was determined that the evaluation form 

should be modified so that the act of 

filling out the assessment forms would 

be more logical and efficient. 

Consequently, the single evaluation 

form was expanded to three separate 

evaluation forms, one each for rearfacing, forward-facing, and booster 

modes. This three-form approach 

mirrors the format of the agency’s 

existing CRS Ease of Use program, 

follows the logic of 4 Steps for Kids, and 

permits distinction between installation 

methods. Furthermore, criteria were 

also removed or clarified based on the 

pilot study observations.28 The revised 

forms have been included in Appendix 

D. The criteria that serve as the basis for 

these evaluation forms will be discussed 

below, as well as the agency’s 

explanations of how these forms were 

derived and should be used. 

X. Pilot Study Observations and 

Resulting Proposed Fit Criteria 

The following section details 

incompatibility observations made by 

CPSTs during the Vehicle-CRS Fit pilot 

study. Photographs of these 

observations can be found in the 

document titled, Vehicle-CRS Fit Pilot 

Study Observations, included in this 


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29 During a crash, the vehicle’s front end is 

designed to crush and absorb the crash energy, 

which effectively extends the distance, and 

accordingly time, over which the occupant 

compartment comes to rest. Tightly coupling the 

occupants to the vehicle will permit them to realize 

the full effects of riding down the crash with the 

vehicle and will reduce the forces acting on the 

body. Therefore, it is imperative that for applicable 

child restraints, not only is the child securely 

restrained by the internal harness, but also that the 

child restraint is tightly attached to the vehicle to 

ensure adequate ride-down. This will effectively 

serve to lessen the likelihood that the child’s 

movement will be stopped abruptly because of 

contact with a hard vehicle surface. 

30A locking clip is a device, normally provided 

by the child restraint manufacturer, which keeps 

the lap portion of a lap/shoulder belt tight by 

securing it near the latch plate. The locking clip 

prevents the seat belt (and thus the child restraint) 

from moving freely. 

31 § 571.208, S7.1.1.5. 

32 Decina L.E. and Lococo K. H., Misuse of Child 

Restraints. NHTSA Publication No. DOT HS 809 

671, National Highway Traffic Safety 

Administration, 2004, Pages 33–34. 

33 69 FR 70904, December 8, 2004. 

34A Type II seat belt is defined by FMVSS No. 

209, ‘‘Seat belt assemblies,’’ to be a combination of 

pelvic and upper torso restraints, which is 

commonly referred to as a lap/shoulder or threepoint belt. 

35A Type I seat belt is defined by FMVSS No. 209 

to be a lap belt for pelvic restraint. 

36Booster Seat Use in 2008. May 2009. NHTSA 

Publication No. DOT HS 811 121. 

37 Decina, L.E., Lococo, K.H., Doyle, C.T., Child 

Restraint Use Survey: LATCH Use and Misuse, 

NHTSA Publication No. DOT HS 810 679, National 

Highway Traffic Safety Administration, December 

2006, Page 3. 

38High-weight harness child restraints permit 

children weighing more than 40 lbs. to be restrained 

by the internal harness of the CRS until they reach 

a higher maximum weight limit stipulated by the 

CRS manufacturer. 

docket. This section also references 

additional widely-known vehicle-CRS 

incompatibilities that may not have 

been observed directly in this study, but 

were known to the CPSTs through their 

previous or anecdotal experience. 

Through the collective expertise of the 

agency and the CPSTs participating in 

the pilot study, the set of modified 

evaluation forms, included in Appendix 

D, was developed and is thus being 

proposed for use by the agency in 

assessing the fit of CRS in vehicles. 

In each section, observations from the 

pilot study will be discussed and 

followed by the criteria the agency is 

recommending be used to assess 

vehicle-CRS fit. If needed, additional 

clarifications about a criterion’s 

intention are presented after the criteria 

themselves. 

A. Vehicle Seat Belts 

Prior to the introduction of LATCH, 

vehicle seat belts were the sole method 

of securing child restraints in vehicles. 

Seat belts are used to secure a child 

restraint to a vehicle by routing them 

through a structurally-reinforced belt 

path in the restraint. When the child 

restraint is attached tightly to the 

vehicle, and the child is then secured 

tightly to the CRS, the child and its 

restraint are effectively coupled to the 

vehicle, which ensures proper ridedown as the vehicle comes to a stop 

during a crash.29

Seat belts have traditionally been a 

contributing factor to vehicle-CRS 

incompatibilities, especially when 

locking clips are required for proper 

installation.30 The agency has issued a 

number of regulations to address the 

difficulty of using a locking clip. 

Beginning in 1996, the lap belt portion 

of all vehicle seat belts other than the 

driver’s have been required to be 

‘‘lockable’’ in order to help eliminate the 

need to use locking clips.31 The majority 

of vehicle manufacturers choose to 

employ either a locking latch plate or a 

‘‘switchable’’ retractor in order to meet 

this requirement. Either of these 

solutions is an improvement over the 

need to use additional devices such as 

a locking clip to secure the seat belt. 

However, the agency found in a study 

on CRS misuse that loose vehicle seat 

belt-CRS attachment was the first or 

second-most prevalent type of critical 

misuse in the field depending on the 

type of restraint.32 Though the study did 

not cite the exact reasons for loose seat 

belt installations, it is possible that a 

portion of those may have been due to 

a failure to lock the seat belt properly. 

Not all parents or caregivers are aware 

that seat belts must be completely 

pulled out to engage switchable 

retractors, nor are they aware of 

techniques that can help ensure locking 

latch plates remain locked. For these 

reasons, seat belts are often still misused 

when installing child restraints. 

In December of 2004, the agency 

published a final rule requiring Type II 

seat belts in center rear seating 

positions.33 34 Previously, lap/shoulder 

belts were only required in outboard 

seating positions; as a result, some 

vehicle manufacturers had continually 

installed only Type I lap belts in the 

center rear seats of vehicles.35 Installing 

lap/shoulder belts in the center rear 

seating position allows all rear positions 

to be acceptable for booster seat use, 

rather than only the outboard positions. 

This is particularly important 

considering booster seat use has 

increased.36 Accordingly, booster 

misuse rates should decline over time as 

the fleet of older vehicles with lap belts 

diminishes. 

Even with the introduction of LATCH, 

vehicle seat belts remain vital to the 

installation of child restraints in many 

vehicles. An agency LATCH study 

found that 25 percent of parents and 

caregivers familiar with using both 

lower attachments and anchors, as well 

as seat belts to secure child restraints, 

actually preferred seat belt installations 

over LATCH installations.37 In addition, 

there are a number of reasons why a seat 

belt installation may be the only choice 

for installing a child restraint. For one, 

most vehicles do not have lower 

anchors at the center rear seating 

position; parents who want to install 

their child restraint in that position 

must therefore use a seat belt. Another 

major reason is that CRS market trends 

towards higher-weight harnessed seats 

suggest that in the coming years there 

will be an increased move to install 

child restraints using vehicle seat belts 

after children exceed the manufacturer 

weight limits of the lower anchors.38 For 

these reasons, the agency believes the 

program should consider assessment 

criteria that relate to vehicle seat belts. 

The CPST curriculum teaches that a 

child restraint is securely installed only 

if it does not move more than one inch 

side-to-side or front-to-back when 

pulled at the belt path. The pilot study 

revealed numerous instances in which 

the subject CRS could not meet this 

requirement when installed using the 

vehicle seat belts. To better restrain 

older children, teenagers, and adults, 

seat belt buckle stalks may be very long 

or may be anchored forward with 

respect to the seat bight. Unfortunately, 

these two seat belt characteristics can 

have an adverse effect on one’s ability 

to achieve a sufficiently tight child 

restraint installation (i.e., enable not 

more than one inch side-to-side 

movement), especially if the belt path 

on that child restraint is very long. In 

some instances, the buckle rests at the 

entrance to the belt path; this is 

expressly prohibited in some child 

restraint manuals as it may adversely 

affect the stability of the restraint. When 

positioned in a similar manner, a latch 

plate equipped with its own locking 

mechanism may not lock properly due 

to the angle at which it is resting. 

The agency acknowledges that the 

CPST curriculum permits caregivers to 

twist buckle stalks in order to achieve 

a tight installation or to prevent buckles 

from resting against the entrance to the 

belt path, as long as the CRS and vehicle 

manufacturers both allow the practice. 

The agency has received data from 

Indiana Mills & Manufacturing, Inc. 

(IMMI) that indicates no considerable 

reduction in the strength of the seat belt 

webbing is observed if a flexible seat 

belt buckle is twisted three times; 

therefore, twisting the seat belt buckle 


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39This information was received in a letter from 

Jerry Thompson, an Engineering Manager at IMMI 

Child Division, dated September 28, 1998. 

40This mounting location is sometimes referred 

to as the ‘‘D-ring’’ location. 

41For those vehicles having two or more rows of 

seats, assessments will be made only for rear seating 

positions. Assessments will be made for the right 

front passenger seat and also for the front middle 

seat, if available, for vehicles having only one row 

of seats. 

three or less times is considered 

acceptable practice and is often 

necessary to achieve a tight fit.39 The 

agency believes, however, that this 

practice is not well-known to the 

average parent or caregiver. In addition, 

many buckle stalks in the vehicle fleet 

cannot be twisted due to rigid plastic 

coverings. Some child restraints have 

higher belt paths than others, which can 

eliminate the need for twisting the seat 

belt. Therefore, for the purposes of the 

pilot study, twisting buckle stalks was 

not permitted to achieve proper fit in a 

seating location. NHTSA has tentatively 

decided it will not twist buckle stalks in 

assessing the fit of CRSs in vehicles. 

In some vehicles, the agency observed 

instances in which seat belt latch plate 

buttons interfered with belt-locking 

hardware outfitted on some infant 

restraints. The latch plate button is 

installed by the vehicle manufacturer to 

keep the latch plate in an accessible 

location for occupants to use. In a few 

instances throughout the pilot study, 

this interference was such that the seat 

belt could not be sufficiently tightened. 

In other cases, the seat belt button 

inhibited the proper use of the rearfacing child restraints’ built-in seat belt 

lock-offs. Although it was not observed 

during the pilot study, given the wide 

range of child restraints and vehicles 

available in the marketplace, it is 

feasible that such buttons could 

interfere with lock-off hardware on 

forward-facing restraints and beltpositioning hardware on booster seats, 

as the pilot study revealed several 

occasions where the seat belt buttons in 

certain vehicles nearly caused such 

interference with installation for the 

selected CRS. 

Some child restraints are designed 

with multiple belt paths for caregivers 

to route the seat belt through. 

Sometimes a certain belt path must be 

used when the child is of a particular 

size or weight. Due to various vehicle 

characteristics, there are cases in which 

only one belt path can be used. For 

example, CPSTs in the pilot study 

observed that some vehicle seat belts are 

not long enough to properly install some 

child restraints using all of the available 

belt paths. Other times, one path may 

result in a more stable installation than 

the other. Although these instances 

were rare, and this issue is not 

suspected to be a widespread problem, 

it is a possibility in the field and, 

NHTSA tentatively believes, is worth 

noting. 

Though it is not a common practice in 

the U.S., some child restraint 

manufacturers give caregivers the option 

of routing the shoulder belt portion of 

the seat belt around an infant seat 

carrier rather than feeding it through the 

belt path. It is likely that some vehicle 

seat belts will not be long enough to be 

used with child restraints in this 

manner. NHTSA has tentatively decided 

to assess the belt’s ability to be routed 

around the CRS if the CRS manual 

recommends or allows such a belt 

routing option. If the belt is not long 

enough to be used in this manner, 

NHTSA will deem the CRS as not fitting 

that seating location or vehicle. 

During the pilot study, evaluators 

noted that certain seat belt anchors were 

too narrowly spaced to accommodate 

some booster seats. This creates a 

situation where the seat belt buckle may 

actually sit behind or underneath the 

child and the restraint. Buckling the 

child can be difficult, if not impossible, 

and may not allow for proper routing of 

the lap belt portion of the seat belt 

across the child’s upper legs. Narrow 

anchorage points for seat belts may also 

limit the ability to properly use them to 

install any type of child restraint, not 

just boosters, although this was not 

specifically observed in the pilot study. 

There may be other times, for example, 

when a child restraint (particularly at its 

belt path) is too wide and actually rests 

on top of the seat belt buckle. In such 

cases, proper routing and tightening of 

the seat belt are unlikely and the child 

restraint would therefore be deemed 

incompatible with that particular 

seating location or vehicle. 

In one pilot study vehicle, the seat 

belt was found to be incompatible with 

the belt positioning hardware on a highback booster. In this case, the seat belt, 

when pulled from its retractor, could 

not move freely though the belt guide 

hardware because of incompatible 

geometry between the two.40 This 

condition can create unwanted slack in 

the shoulder belt portion of the seat belt, 

and present a dangerous situation since 

a loose seat belt may not restrain a 

child’s upper body properly in the event 

of a crash. However, the pilot study 

participants found it somewhat difficult 

to quantify this condition with objective 

criteria. Depending on the weight of the 

child using the booster, the height to 

which the booster’s head restraint is 

raised, and the force with which the seat 

belt is pulled from its retractor, different 

conclusions may be made as to the 

potential for unwanted shoulder belt 

slack. Our experience with the pilot 

study found that the majority of seat belt 

slack is generally preventable if the 

installer exercises due care; however, 

there can also be vehicle seat beltbooster seat combinations that are 

overly prone to the creation of slack and 

should thus be avoided. In light of this, 

the agency is seeking comment on the 

frequency and severity of this issue in 

the field, as well as any information 

about how we may develop an objective 

method for determining whether slack 

exists between a particular booster seat 

shoulder belt guide and the vehicle seat 

belt. The agency proposes to include an 

evaluation criterion for whether seat 

belt slack is created between a booster 

and vehicle seat belt on the final 

Vehicle-CRS Fit forms. 

Based on the above observations from 

the pilot study, NHTSA proposes to add 

the following criteria to its Vehicle-CRS 

Fit assessment forms in order to identify 

compatibility issues specific to child 

restraints and vehicle seat belts: 

—Does the distance between the Type II 

seat belt’s lap belt anchor and buckle 

allow the child restraint to be 

installed properly (rear-facing and 

forward-facing CRS) or the booster to 

be positioned properly? 

—Is the seat belt length sufficient to 

properly install the CRS using all 

possible belt paths permitted by the 

CRS manufacturer and in all rearfacing (rear-facing CRS) modes of use 

or forward-facing (forward-facing 

CRS) modes of use? 

—Does the seat belt buckle interfere 

with proper CRS installation (rearfacing and forward-facing CRS)? 

—Does the seat belt latch plate button 

limit the use of any lock-off or other 

hardware on the CRS or otherwise 

prohibit proper installation (rearfacing and forward-facing CRS)? 

NHTSA has tentatively determined 

that all criteria must be met to establish 

that a child restraint meets the fit 

assessment conditions for a given 

vehicle. Assessments should be made 

for forward-facing CRS and rear-facing 

CRS, and also for booster seats, if 

applicable. NHTSA is also proposing 

that if proper installation of the child 

restraint cannot be achieved with the 

seat belt designated for each applicable 

seating location within the vehicle, it 

should be determined that the child 

restraint does not meet the fit 

assessment conditions for seat belt 

installation for the subject vehicle.41


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42See http://www.cpsboard.org/pdf/techmanual/ 

StudentManual_R0108_ch6.pdf. 43Here, the minimum distance required is equal 

to the length of the tether hook plus the reinforced 

stitching length on the tether strap webbing. 

44 Decina, L.E., Lococo, K.H., Doyle, C.T., Child 

Restraint Use Survey: LATCH Use and Misuse, 

NHTSA Publication No. DOT HS 810 679, National 

Highway Traffic Safety Administration, December 

2006. 

45A CRS installed with lower anchorage 

attachments was considered securely installed if the 

lower attachment connectors were installed right 

side up, the lower attachment straps were flat and 

routed to the correct anchors, and the installation 

was tight. 

The agency tentatively believes that it is 

important that parents have the option 

to move a child restraint to a different 

seating position within the vehicle if 

necessary in order to accommodate 

adult passengers or additional children. 

Comments are requested on this issue. 

B. Top Tether Anchorages 

A child restraint’s top tether 

attachment strap is an important feature 

because it can reduce head excursion for 

children positioned in forward-facing 

CRS in frontal crashes, thus reducing 

the likelihood that a child will 

experience head contact with the 

vehicle interior.42 It can not only 

provide stability by reducing the 

amount of forward and side movement 

during travel, but can also help achieve 

a tight installation. Although not 

required by NHTSA’s standards, some 

manufacturers provide top tethers for 

their rear-facing child restraints. 

Accordingly, NHTSA identified the 

attachment and proper tightening of a 

CRS top tether as important assessments 

of child restraint fit in a vehicle. To the 

extent that a parent or caregiver is 

unable to attach a child restraint’s top 

tether to the tether anchor in the vehicle 

or improperly installs the top tether 

because of vehicle-CRS incompatibility, 

and the CRS manufacturer or vehicle 

manufacturer recommends use of the 

tether with the particular CRS in that 

rear- or forward-facing orientation, 

NHTSA tentatively believes the child 

restraint should not be identified as one 

that meets the fit assessment conditions 

for that vehicle. 

The agency’s pilot study revealed that 

the location of the top tether anchor in 

relation to the head restraint and vehicle 

seat belt can be a prominent factor in 

determining vehicle-CRS compatibility. 

When some child restraints were 

properly positioned forward-facing on 

the vehicle seats in two passenger cars, 

the distance between the top of the CRS 

and tether anchor, which was located on 

the vehicle’s rear shelf, was insufficient 

to permit the tether to be tightened. In 

these cases, the vehicles were not 

designed with regards to the minimum 

tether distance required for the 

installation of the subject CRS.43 Had 

the tether anchor been located more 

rearward on the vehicle shelf, or had the 

rear head restraint been higher, or in 

some cases adjustable, it is possible that 

the top tether attachment strap from the 

subject child restraints could have been 

adequately tightened. This was not a 

problem for other child restraints 

installed in the forward-facing mode in 

these same vehicles because the backs of 

the other child restraints did not extend 

as high as those from the child restraints 

previously mentioned. The shorter 

height of these CRS permitted a greater 

distance between the top of the child 

restraint and the tether anchor, and 

consequently permitted proper tether 

adjustment and tightening. 

Additionally, the agency is also aware 

of instances in which a vehicle’s tether 

anchor is located too far away from the 

respective seating location to permit 

attachment of a top tether. This is most 

commonly observed in SUVs and 

hatchbacks. 

Vehicle seat and head restraint 

designs can also pose top tether use 

problems. Non-adjustable head 

restraints that are smaller in size or that 

are extremely rounded on top may 

permit the top tether strap(s) to slip off 

of the head restraint during travel. 

Additionally, geometry differences 

between the CRS and the vehicle seat 

can sometimes permit the reinforced 

portion of the top tether webbing to 

catch on the vehicle seat or head 

restraint upon tightening. Consequently, 

a loose tether may result without the 

parent or caregiver’s knowledge. 

To identify compatibility issues 

specific to child restraints and vehicle 

tether anchors, NHTSA has decided to 

propose the following criteria on its 

Vehicle-CRS Fit assessment forms: 

—Can the rear-facing tether be attached 

to the appropriate vehicle tether 

anchor (forward-facing CRS and 

boosters, if applicable) or location in 

the vehicle (rear-facing CRS, if 

applicable)? 

—Can the top tether be properly 

tightened (forward-facing CRS and 

boosters, if applicable) or can the rearfacing tether be properly tightened 

(rear-facing CRS, if applicable)? 

NHTSA is proposing that assessments 

should include whether or not the top 

tether on the child restraint can be 

attached to the vehicle’s top tether 

anchorages and tightened. If the top 

tether cannot be attached, we would 

determine that the CRS does not meet 

the fit assessment conditions for the 

given vehicle. If the top tether can be 

attached, a further assessment of 

whether or not it can be tightened 

would then be made. If, upon 

tightening, the tether strap begins to 

slide off of the head restraint or catches 

on any part of the vehicle seat such that 

the tether seems taut, yet loosens or 

shifts position upon pulling the CRS 

from side-to-side at the belt path, the 

child restraint does not meet the 

aforementioned criteria. Assessments 

would be made for forward-facing CRS 

and also for rear-facing CRS and booster 

seats, if so equipped. For CRS equipped 

with a top tether and designed to be 

installed rear-facing, the agency is 

proposing to assess whether the tether 

can be properly attached to the vehicle 

when the CRS is installed in the rearfacing mode. Such assessments will be 

made only if the CRS user’s manual 

instructs that tether attachment is either 

acceptable or required for the rear-facing 

mode and the vehicle owner’s manual 

does not explicitly prohibit attachment 

of a rear-facing tether. The top tether 

assessment would also only be made for 

convertible child restraints placed in the 

rear-facing mode if the CRS user’s 

manual explicitly states that tether 

attachment is either acceptable or 

required for the rear-facing mode. 

C. Lower Anchorages 

As mentioned previously, the intent 

of the LATCH system was to introduce 

a user-friendly system that would make 

CRS installation independent of the seat 

belts. When using the lower anchor 

portion of LATCH, there is no need to 

lock the vehicle’s seat belt when 

installing the CRS, use a locking clip, 

twist long belt buckle stalks to achieve 

a tight fit, or combat seat belts that are 

anchored forward of the seat belt 

buckles. Therefore, it was expected that 

LATCH would be less prone to incorrect 

routing and loose fit, two sources of 

misuse often associated with seat belt 

installations, and accordingly, would 

reduce misuse and incorrect installation 

of child restraints. This was evidenced 

by the 2006 NHTSA CRS misuse study. 

This study found that the lower 

attachment strap was routed through the 

correct path for 93 percent of the CRS 

surveyed and a tight installation was 

achieved for 70 percent of the CRS.44 45

Accordingly, real world experience 

demonstrates that LATCH, and in 

particular, the lower attachments, 

provides safety benefits to many parents 

and caregivers who experience 

difficulty attaching a child restraint 

correctly in a vehicle or find that the 

vehicle’s seat belts are incompatible 

with a child restraint. However, as 

mentioned previously, the agency also 

recognizes that LATCH, although 


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46NHTSA tentatively believes that it should 

assess the attachment and proper tightening of the 

CRS lower LATCH attachments of a CRS when the 

CRS manufacturer or the vehicle manufacturer 

recommends or specifies use of the lower LATCH 

anchorages with that CRS. To illustrate, although 

FMVSS No. 213 does not require lower LATCH 

attachments on booster seats, if the booster seat has 

such attachments and the vehicle manufacturer 

identifies the booster seat as one that fits its vehicle, 

then NHTSA will assess the fit of the booster on the 

vehicle seat using the lower LATCH attachments. 

47Specific tightness requirements for CRS 

installation are outlined in Section IX E. of this 

document. 

effective, has not addressed all vehicleCRS compatibility problems. 

The agency’s pilot study suggested 

that, like seat belt anchor points, the 

design of a vehicle’s lower anchorages 

can also present compatibility issues. 

The overwhelming majority of child 

restraints in the U.S. employ flexible 

lower attachments. In these systems, the 

lower attachments must first be 

connected to the vehicle’s lower 

anchorages. Then, the additional 

webbing must be tightened to eliminate 

system slack and achieve a tight fit. The 

majority of child restraints have at least 

one push-button or tilt-lock adjustment 

mechanism on their lower attachment 

straps that provides tension and then 

eventually allows for that tension to be 

released if the CRS needs to be removed 

from the vehicle. 

In some vehicles assessed during the 

pilot study, incompatibilities were 

observed between the lower attachment 

strap adjusters and the CRS lower 

attachment path. In most cases, this 

occurred because the location of the 

vehicle’s lower anchorages was high in 

relation to the resting surface of the 

CRS, thus minimizing the distance 

between the CRS lower attachment path 

and the vehicle’s lower anchorages. In 

some cases, this was complicated by 

lower anchorages that protruded from 

the seat bight, which served to further 

decrease this distance. Similar to, as 

mentioned previously, when a seat belt 

buckle rests on the edge of the child 

restraint’s belt path, it is undesirable for 

the lower attachment strap adjusters to 

contact the frame or edge of the CRS belt 

path. A proper fit could not be achieved 

in these cases. 

High seat bights were also observed to 

have compatibility issues with LATCHequipped backless booster seats as well. 

Though booster seats are not required to 

have components that attach to LATCH 

anchors, a number of products have 

entered the market in recent years that 

use components that attach to lower 

LATCH anchors to stabilize the booster 

on the vehicle seat. When installed 

using its rigid lower anchors, one 

backless booster seat was unable to sit 

flat on the vehicle seat pan because the 

vehicle’s lower anchors were located in 

the seat back rather than in its bight. A 

similar observation was made when 

attempting to position the same booster 

seat without trying to attach the lower 

rigid attachments to the vehicle anchors 

in that same position within the vehicle. 

Because the vehicle did not have a gap 

at its seat bight and the booster 

manufacturer required that the rigid 

attachments be inserted into the seat 

bight if they were not being used, the 

booster was once again not able to be 

properly positioned on the vehicle 

seat.46

Other incompatibility issues were 

identified when attempting to install a 

LATCH-equipped backless booster seat 

using the rigid lower attachments. It was 

observed that if a vehicle’s lower 

anchors were too far forward or exposed 

in relation to the seat bight, the LATCHequipped backless booster seat may be 

positioned forward on the vehicle seat 

pan and away from the vehicle seat 

back. In such instances, a large gap was 

created between the booster and the seat 

back. This may result in children being 

unable to sit flat against the seat back 

and leaning forward. Such a position 

can lead to increased head excursion 

during a crash. In addition, this 

condition may also allow children to 

slouch, whereby the lap portion of the 

seat belt may sit over the occupant’s soft 

abdominal region instead of over the 

pelvis. If the seat belt is resting on soft 

tissue instead of bone, internal organs 

are more at risk in the event of a crash. 

The pilot study also revealed that a 

similar phenomenon can occur when 

traditional backless booster seats that 

are void of lower attachments are 

positioned against raised or prominent 

seat bights that essentially push the 

booster away from the seat back. 

To establish that a child restraint is 

compatible with a vehicle’s lower 

anchors, the following criteria should be 

met: 

—Can the lower attachments on the CRS 

(rear-facing and forward-facing CRS) 

or booster (if so equipped) be properly 

attached to the vehicle’s lower 

anchorages? 

—Can the lower attachments on the CRS 

(rear-facing and forward-facing CRS) 

or booster (if so equipped) be 

tightened, if necessary, after the initial 

connection to the lower anchorages? 

—When the CRS is installed (rear-facing 

and forward-facing CRS) or the 

booster is positioned (booster, if so 

equipped) using lower anchorages, is 

there access to the vehicle’s adjacent 

seat belt buckles? 

For the Lower Anchorages category, 

NHTSA is proposing to assess whether 

the CRS can be attached to the vehicle’s 

lower anchorages. It would be 

permissible to move a seat belt buckle 

out of the way to do so. If the lower 

attachment straps on the CRS can be 

successfully attached to the vehicle’s 

lower anchorages, it would then be 

assessed whether the lower attachment 

straps on the CRS could be adequately 

tightened to provide a secure fit and 

permit limited movement.47

Additionally, once the CRS is attached 

to the vehicle’s lower anchors, it must 

be determined whether the vehicle’s 

adjacent seat belt buckles can be 

accessed and used. However, if a 

vehicle manufacturer permits sharing of 

inboard lower anchorages from the 

outboard vehicle seating positions to 

create a center LATCH position, or if a 

manufacturer permits a center LATCH 

position that is offset from the center 

designated seating position, NHTSA 

reasons that it would be impractical to 

use the seat belt buckles from the 

adjacent seat positions when a child 

restraint is installed with LATCH in the 

created center position. Therefore, for 

such center LATCH positions, the 

agency is not proposing to assess 

whether there is access to the adjacent 

seat belts as long as the vehicle 

manufacturer specifies in the owner’s 

manual that the seat belt buckles related 

to the adjacent seating locations cannot 

be used when the created center LATCH 

position is utilized. This aims to 

minimize the possibility that a 

consumer may improperly use or route 

the seat belt in adjacent seating 

locations that would be considered nonuse positions, and would therefore be 

exempt from the aforementioned 

assessment. The agency is 

distinguishing between outboard and 

center LATCH positions because some 

consumers may want to install a child 

restraint in the center position, even if 

the vehicle does not offer a dedicated 

LATCH position at the center seat. 

Accordingly, the agency does not want 

to discourage vehicle manufacturers 

from including center LATCH positions, 

particularly in smaller vehicles where a 

dedicated center LATCH position may 

be impractical. If a vehicle manufacturer 

permits the sharing of inboard lower 

anchorages from outboard seating 

positions to create a center LATCH 

position in any one vehicle model, 

NHTSA will also confirm that the CRS 

user’s manual does not prohibit 

installation of the given child restraint 

in such positions. For vehicles having a 

fold-down armrest in the center rear 

seating location, the agency will verify 

that the CRS manufacturer permits 

installation of the child restraint at such 


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locations. All assessments will be made 

for rear-facing and forward-facing child 

restraints and also for LATCH-equipped 

booster seats. 

Although the pilot study did not 

reveal instances in which a CRS could 

not be installed using LATCH if the 

adjacent seat belt was in use, the 

possibility may exist. The agency 

recognizes that using the seat belt in a 

position adjacent to a CRS installed 

with LATCH may be necessary or 

desirable for parents and caregivers 

transporting other adults or older 

children in booster seats. Therefore, the 

agency is requesting comments on 

whether an additional requirement 

should be added to address access to a 

vehicle’s lower anchorages when a CRS 

is installed using the seat belt in an 

adjacent seating position. If the addition 

of such a requirement is deemed 

necessary, the agency would make this 

assessment for LATCH seating positions 

adjacent to a seat belt-installed CRS as 

long as the vehicle owner’s manual does 

not prohibit the use of LATCH in that 

position when the adjacent seat belt is 

in use. Similar to the previous criterion 

to assess seat belt access when LATCH 

is in use, the agency is proposing that 

this additional LATCH access criterion 

would be applicable to created center 

LATCH positions and overlapping 

center LATCH positions, if permissible, 

as well as designated LATCH positions. 

In other words, the agency is proposing 

to apply this LATCH access requirement 

to every LATCH position in the vehicle 

when a CRS is installed using the 

vehicle seat belts in the adjacent seating 

position(s). 

This program will not assess how 

easily a child restraint’s lower 

connectors can be either attached to or 

detached from a vehicle’s lower 

anchors, nor will this program evaluate 

the likelihood that one will be able to 

misuse a vehicle’s LATCH hardware. 

The agency recognizes that connector 

attachment may be difficult if the 

vehicle’s lower anchors are recessed 

deep within the vehicle seat bight, if the 

vehicle seat cushion is stiff, or if 

clearance around the vehicle’s lower 

anchors is inadequate; however, the 

agency tentatively concludes that 

evaluating the ease of attachment or 

detachment would lead to subjective, 

rather than objective, fit assessments. As 

the agency’s intent is to provide a 

robust, repeatable evaluation of CRS fit 

in vehicles, the agency will not 

incorporate criteria that focus on ease of 

installation at this time. The agency 

hopes, however, that as child restraint 

and vehicle manufacturers work 

together to address compatibility, they 

will recognize and address such issues. 

Because the agency’s misuse studies 

have shown that there is a greater 

likelihood that a child restraint will be 

securely installed with LATCH lower 

attachments than with a vehicle seat 

belt, the agency hopes that vehicle 

manufacturers will also make it easier 

for parents and caregivers to locate a 

vehicle’s LATCH anchors within a 

vehicle so that they may be more 

intuitive to use. 

D. Head Restraints 

Prominent, fixed head restraints can 

present incompatibilities between 

vehicle seats and some child restraints, 

especially forward-facing restraints and 

high-back boosters. In some vehicles, a 

forward-facing CRS was only able to 

make contact with the vehicle at the seat 

bight and at the head restraint and 

evaluators were not able to achieve a 

tight installation. In other vehicles, the 

installation was secure but the child 

restraint manufacturer required a 

specific amount of contact between the 

seat back and the restraint. In such 

cases, the head restraint’s geometry 

prevented the child restraint from 

contacting the back of the vehicle seat, 

which violated the child restraint 

manufacturer’s instructions. This 

problem may have been eliminated for 

some high-back booster seats if the head 

restraint was removable or adjustable 

instead of fixed. As mentioned 

previously, pilot study evaluators also 

observed instances where top tethers 

could not be sufficiently tightened over 

fixed head restraints when there was not 

adequate distance for attachment of the 

tether hook. In all of these cases, the 

child restraint did not meet the 

proposed conditions for proper 

installation. 

In light of these observations, NHTSA 

is proposing to include one head 

restraint-related criterion on its VehicleCRS Fit Assessment forms. In order to 

establish that a child restraint fits in a 

vehicle, the following should be met: 

—Does the vehicle head restraint 

interfere with proper CRS installation 

(forward-facing CRS) or booster 

positioning (high-back booster only)? 

To eliminate incompatibilities 

between head restraints and child 

restraints, all available methods of 

remedy indicated in the vehicle and/or 

CRS owner’s manual may be employed. 

These can include, but are not limited 

to head restraint removal, moving the 

head restraint upward into a locked 

position, and tilting the head restraint 

rearward. If proper installation of the 

child restraint cannot be achieved using 

all listed remedy methods, it would be 

determined that the child restraint does 

not fit in the subject vehicle. 

E. CRS Installation, Use, and Tightness 

In the event of a crash, it is imperative 

that a child restraint be tightly coupled 

to the vehicle so that the child occupant 

is afforded the full benefits of riding 

down the crash with the vehicle. 

Vehicle design factors such as space 

limitations and seat characteristics can 

pose significant challenges for the 

installation of certain types of child 

restraints. Additionally, a variety of CRS 

characteristics, including assorted 

footprint shapes, belt path locations, 

belt positioning features, and overall 

sizes, can create challenges for vehicle 

seat cushions. While it is beneficial for 

parents and caregivers to identify 

vehicle-CRS combinations that have a 

wide variety of options available to meet 

their needs, this diversity may make it 

difficult for parents and caregivers to 

identify vehicle-CRS combinations that 

provide to a proper fit. 

During the agency’s pilot study, it was 

observed that some vehicles were 

simply too small to accommodate 

certain CRS types or certain CRS 

orientations. In two vehicles, the 

roofline of the vehicle limited the height 

to which the head restraints of certain 

combination and high-back booster seats 

could be raised in the outboard seating 

locations. This is especially important 

since the head restraints on most child 

restraints designed for forward-facing 

installation, including many boosters, 

now come with wider and more padded 

side wings in the head area. These are 

typically comprised of energy absorbing 

foam and are intended not only to 

confine the head, but also to attenuate 

lateral loads. If the parent or caregiver 

is unable to fully adjust the headrest, 

the feature of the booster or other 

forward-facing child restraint may not 

be able to be used, and the child’s head 

may still be able to extend above the 

height at which the head restraint on the 

CRS or booster can adjust depending on 

the slope of the roofline. 

Other vehicles did not offer adequate 

space to properly position rear-facing 

child restraints. In newer vehicles, 

certain rear-facing child restraints may 

interfere with a vehicle’s advanced air 

bag sensors if the restraints are allowed 

to rest against the front seat back. In 

several vehicles studied, unless the 

vehicle’s front seats were set forward of 

the fore-aft mid-track seat adjustment 

position, most convertible restraints 

contacted the front seat back when 


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48The mid-track position is indicative of the 

seating location of the mid-sized male driver 

dummy in frontal and side NCAP tests. 

49See http://www.cpsboard.org/techmanual.htm, 

Page 137. 

50See http://www.car-safety.org/guide.html. 

51See http://www.cpsboard.org/techmanual.htm, 

Page 137. 

52SFAD 2 is the static force application device 

used in FMVSS No. 225 testing to test lower 

anchorage and tether anchorage strength when seat 

belts are NOT used to secure a child restraint 

system in the vehicle. 

positioned rear-facing.48 For those 

cases, such contact was prohibited by 

the respective CRS manufacturers. The 

agency recognizes, however, that some 

CRS manufacturers permit their child 

restraints to rest against the back of the 

vehicle seat. The CPST curriculum also 

acknowledges that such contact is 

acceptable if it is not expressly 

prohibited in either the vehicle owner’s 

manual or the CRS user’s manual.49

Accordingly, the agency is proposing to 

adopt criteria to assess whether a CRS 

can be installed rear-facing so as to 

achieve the appropriate distance relative 

to the front seat back, as prescribed by 

the CRS manufacturer in the CRS 

owner’s manual. If the CRS owner’s 

manual does not provide guidance as to 

whether CRS contact with the front seat 

back is permitted or not, the agency is 

proposing to permit such contact. 

Proper installation could also not be 

achieved for several infant restraints 

positioned in the middle rear seating 

location in some vehicles because the 

carrier handle contacted the center 

console of the vehicle when placed in 

its manufacturer-prescribed travel 

position. If the handle is adjusted to the 

wrong position for travel, during a 

crash, it may contact the vehicle seat or 

other vehicle components during 

rebound and may break, injuring the 

child or other occupants.50 Therefore, 

the agency is also proposing to adopt 

criteria to assess whether proper 

placement of the CRS carrier handle can 

be achieved for rear-facing CRS, if 

applicable. 

The CPST curriculum also teaches 

that not only must a CRS not move more 

than one inch from side-to-side or frontto-back when pulled at the belt or lower 

attachment strap path with one hand to 

be properly installed, but further 

specifies that no more than 20 percent 

of the child restraint’s footprint may 

hang over the edge of the vehicle seat.51

We are considering using this criterion 

to assess the CRS stability on the vehicle 

seat pan since it has been included in 

the curriculum and is a familiar metric 

in the child passenger safety 

community. However, as stated earlier 

in this preamble, we request comment 

on the merits of the 20 percent criterion. 

Should a different value be used 

instead? 

In light of the aforementioned 

installation issues, NHTSA is proposing 

that the following criteria are 

considered when assessing fit in the 

‘‘CRS Installation, Use, and Tightness’’ 

category: 

—Does more than 20% of the CRS (rearfacing and forward-facing CRS) or 

booster base/bottom hang over the 

edge of the vehicle seat pan? 

—Can the CRS be installed so that there 

is no more than 1 inch of movement 

side-to-side or front-to-back when 

pulled at the LATCH path or belt path 

(rear-facing and forward-facing CRS)? 

—Can the CRS be installed rear-facing 

so as to achieve the appropriate 

distance relative to the front seat back, 

as stated in the CRS owner’s manual, 

if applicable? Must also be able to 

achieve proper placement of CRS 

carrier handle, if applicable (rearfacing CRS only). 

—If the harness is intended to be 

accessed when the CRS is installed, 

can it be tightened (rear-facing and 

forward-facing CRS)? 

—Does the positioning prohibit full 

adjustment of the booster’s head 

restraint or the use of any belt 

positioning hardware (booster only)? 

Although this program will not be 

evaluating vehicle-CRS combinations 

for ease of fit at this time, the agency is 

adopting certain criteria that should 

help ensure that the installation and use 

of recommended child restraints will be 

less difficult for parents and caregivers. 

The vast majority of harnessed child 

restraints currently in the U.S. market 

use a ‘‘continuous’’ or ‘‘one-pull’’ 

mechanism to tighten the harness onto 

the child once s/he has been secured in 

the restraint. This style of harness 

tightening mechanism is for use while 

the CRS is installed in the vehicle, so 

that the parent or caregiver can 

appropriately adjust the harness to fit 

snugly on their child prior to each and 

every trip. The agency is proposing that 

in order to meet the fit recommendation 

conditions, child restraints with harness 

tightening systems that are intended to 

be accessed and used while the CRS is 

installed must actually be able to be 

accessed and used. If the harness 

tightening mechanism is not intended to 

be accessible according to the CRS 

owner’s manual when the CRS is 

installed in the vehicle, this would not 

be a proposed requirement for vehicle 

fit. 

The agency is also proposing a 

criterion that promotes CRS 

installations without the use of items 

that did not come from their 

manufacturers. For example, for proper 

installation, a rear-facing CRS must 

achieve a proper recline on the vehicle 

seat and must achieve proper tightness 

without the use of after-market objects 

such as pool noodles or rolled towels. 

Although it is common practice in the 

field to use such items, the items are 

used to solve incompatibility problems. 

Thus, the agency does not believe that 

a child seat fit recommendation within 

this program should depend upon the 

use of items to fix incompatibility 

between the CRS and the vehicle. 

We believe, in most cases, requiring 

no more than 20 percent of the CRS 

bottom to overhang the vehicle seat pan 

and less than one inch of movement at 

the belt path when installed should 

result in a proper, tight installation. 

However, though not explicitly stated, it 

is often the case that a child restraint 

must rest securely on the vehicle seat 

pan and against the seat back to achieve 

no more than one inch of movement 

when installed. As indicated previously, 

vehicle features such as fixed head 

restraints may position larger forwardfacing restraints or high-back boosters 

away from the vehicle’s seat back, 

generating large gaps behind the CRS. 

High seat bights and severe vehicle seat 

pan contours can also create gaps 

behind or under a CRS. In addition, 

some child restraint manufacturer 

instructions stipulate that proper 

installation requires a certain amount of 

contact between the vehicle seat back 

and the rear of a child restraint when 

installed forward-facing. The agency is 

unsure as to the specific reasons for this 

requirement and is seeking comment on 

this issue. 

It should be noted that the agency is 

proposing to permit the adjustment of 

vehicle seat backs, if possible, to 

achieve appropriate CRS contact with 

the vehicle seat back. This proposal is 

aligned with S7(a) of FMVSS No. 225, 

‘‘Child restraint anchorage systems,’’ 

which currently permits seat back 

adjustment in order to attach the SFAD 

2 to a vehicle’s lower anchorages during 

testing.52 Further, adjusting the seat 

back so that the child restraint would 

rest securely against the seat back is a 

reasonable step that a parent or 

caregiver may take. For forward-facing 

and high-back booster seats, the agency 

will also permit evaluators to use all 

available remedy methods indicated in 

the vehicle owner’s manual to adjust 

head restraints that may cause gaps. 

Prior to the pilot study, the agency 

was unsure not only as to whether there 

was a need to develop a criterion to 

address CRS stability on the vehicle seat 

back, but also as to what would qualify 


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53 During the pilot study, the agency made an 

attempt to develop an objective criterion for contact 

between the CRS and the vehicle seat and felt 50 

percent contact was a reasonable starting point for 

evaluation. 

54Mid-position for these fit assessments is taken 

to be the midpoint between the full-forward and 

full-rear position of the seat on its mid-track, using 

only the primary seat fore-aft controls. If a 

particular vehicle is available with different front 

seat options, the manufacturer should exercise due 

care by assessing fit in the vehicle seat whose midtrack seat position would be rear-most with respect 

to the child restraint. During all assessments, the 

front seat back should be set to the vehicle 

manufacturer’s nominal seat back angle. 

as an objective criterion. Accordingly, 

the agency used the pilot study to both 

assess the need for a criterion, and also 

to evaluate a potential objective 

criterion. In particular, the agency 

assessed whether requiring a minimum 

of 50 percent contact between the CRS 

and the vehicle seat back was needed to 

ensure proper fit. That is, if a forward 

facing CRS or a booster could not be 

installed such that at least 50 percent of 

its rear surface was in contact with the 

vehicle seat back, then a note to that 

effect was made on the pilot study 

evaluation forms, as shown in Appendix 

C. 

The agency also evaluated whether 

this criterion, if needed, was both 

sufficient and objective. For the 

purposes of the pilot study, it was not 

necessary for a child restraint to meet 

this requirement to achieve acceptable 

fit.53 Although the agency observed 

several instances during the pilot study 

in which child restraints could not be 

installed in certain vehicles to meet this 

requirement, with the exception of one 

vehicle-CRS combination, each of these 

vehicle-CRS combinations also failed to 

meet an additional fit requirement. 

Some of the restraints that did not meet 

the seat back contact requirement could 

not be installed to meet the CRS 

manufacturer’s installation instructions; 

others, when installed, could be moved 

more than one inch side-to-side or frontto-back. For these reasons, and since the 

agency could not find data regarding an 

appropriate amount of surface area 

contact between a child restraint and 

the vehicle seat back or seat pan, 

NHTSA is specifically seeking comment 

on whether a vehicle seat back-to-CRS 

contact criterion is necessary and 

should be included on the final set of 

evaluation forms. If such a criterion is 

deemed necessary, the agency is also 

seeking comment on what the 

appropriate, objective criteria should be. 

Similarly, the agency is also seeking 

comment on whether it should adopt a 

requirement that assesses CRS stability 

on a vehicle seat pan. Although such a 

criterion was not evaluated during the 

pilot study, the agency did observe 

several instances in which large gaps 

could be seen under an installed CRS 

due to CRS incompatibility with vehicle 

seat bights or seat pan contours. The 

agency is also seeking comment on what 

an appropriate, objective seat pan 

contact criterion would be, should it be 

deemed necessary. 

The agency is proposing an additional 

assessment that pertains to whether a 

rear-facing CRS contacts the vehicle seat 

in front of it when installed. Certain 

vehicle manufacturers prohibit rearfacing child restraints from touching the 

front seat back because of potential 

interference with advanced air bag 

sensors. Similarly, child restraint 

manufacturers may also require that an 

installed child restraint may not come 

within a specified distance of the front 

seat back. NHTSA tentatively believes 

that, if the CRS user’s manual or the 

vehicle owner’s manual specifies that 

either the child restraint may not 

contact the seat back in front or that a 

certain distance must be maintained 

between the CRS and the back of the 

front seat, we should take this into 

consideration. The child restraint 

should be installed and assessed for fit 

in the vehicle such that the specified 

distance (if any) is maintained. For fit 

assessments under the vehicle-CRS 

program, the agency is proposing that 

manufacturers make two assessments 

with respect to the front seat position— 

one with the front seat set to its midposition on its seat track and one with 

the front seat set to its forward-most 

position on its seat track.54 The agency 

acknowledges that not all front seats 

will be able to be positioned in their 

mid-track position when a CRS is 

installed rear-facing in the seat behind 

it. As long as the front seat can be 

placed in any lockable position with its 

seat back at the vehicle manufacturer’s 

nominal seat back angle, a CRS can be 

considered to meet the fit assessment 

conditions in that vehicle. While it may 

be impractical to move the driver’s seat 

to its full forward position while 

operating the vehicle, the consumer has 

the option of moving the front passenger 

seat of a vehicle to that location to 

accommodate a rear-facing CRS, even if 

that means other adult passengers may 

also have to sit in the rear seat. The 

agency expects manufacturers to note 

any fit recommendations that require a 

front seat to be placed forward of the 

mid-track location. We intend to 

disseminate that information to 

consumers. 

The agency understands that vehicles 

of the same make and model can have 

different upholstery and options that 

may affect the installation of a child 

restraint. In the agency’s experience, 

however, these variations have not been 

severe enough to affect the ability to 

install the same child restraint within 

variations of one vehicle make and 

model. That said, the agency expects 

vehicle manufacturers to exercise due 

care; if a particular trim line or vehicle 

option will have an effect on the 

consumer’s ability to achieve proper 

vehicle-CRS fit, the manufacturer 

should not recommend that vehicle-CRS 

combination for this program. 

F. Vehicle Owner’s Manual 

Proper installation of a child restraint 

requires that the parent or caregiver read 

and follow all the requirements of both 

the vehicle owner’s manual and the 

child restraint user’s manual. However, 

NHTSA is aware of some cases in which 

the vehicle cannot accommodate the 

child restraint properly due to 

constraints imposed by either the child 

restraint manufacturer or the vehicle 

manufacturer. As such, NHTSA has 

decided to propose the following 

criterion in the ‘‘Vehicle Owner’s 

Manual’’ category for rear-facing CRS, 

forward-facing CRS, and boosters: 

—Can the CRS be installed (rear-facing 

and forward-facing CRS) or booster be 

positioned to meet both the restraint 

manufacturer’s and the vehicle 

manufacturer’s instructions? 

It is important for parents and 

caregivers to follow all instructions from 

both child restraint and vehicle 

manufacturers, to ensure that the 

maximum protection possible is 

afforded. If a child restraint’s user’s 

manual advises that the CRS should not 

be used in a vehicle having a particular 

type of seating arrangement, this 

restraint would not meet the assessment 

conditions. That is, NHTSA would 

deem this CRS as not fitting a vehicle 

with that type of seating arrangement, 

even if the vehicle manufacturer had 

identified the CRS as one that fits the 

vehicle. Such an instance may arise if a 

vehicle manufacturer recommended a 

child restraint for a particular vehicle 

that has a specific type of side air bag 

and the CRS manufacturer’s instructions 

prohibit the installation of that 

particular CRS next to that type of side 

air bag. 

A lack of information can be 

challenging for parents and caregivers. It 

is prudent for both vehicle and child 

restraint manufacturers to provide 

sufficient information regarding proper 

use. As observed in the pilot study, 

there are instances in which specific 

features cannot be used or in which the 

full use of features on the restraint 


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cannot be realized. Not only can this be 

a disappointment to caregivers, but it 

can also result in consumers improperly 

installing the child restraint. For 

example, suppose a vehicle 

manufacturer established a maximum 

weight for children who should be using 

CRSs with the LATCH system, but did 

not include the LATCH anchor limit 

information in the vehicle owner’s 

manual. The harnessed restraint 

installed with LATCH should be 

reinstalled with the seat belt when the 

vehicle’s LATCH anchor weight limits 

are exceeded. However, a parent who 

was not aware of the weight limit might 

fail to reinstall the CRS with the vehicle 

belt after his or her child’s weight 

exceeded the vehicle’s LATCH anchor 

weight limit. 

Along similar lines, the vehicle 

should accommodate the child restraint 

so that the CRS may be installed to meet 

the child restraint manufacturer’s 

instructions. For example, for rearfacing infant seats, the carry handle’s 

proper travel position must be reached. 

If the carry handle makes contact with 

the vehicle’s front seat backs or center 

console when placed in this position 

and either the vehicle owner’s manual 

or the child restraint user’s manual 

prohibits such contact, the child seat 

should not be installed for use in this 

position in the subject vehicle. A similar 

rationale should be applied for 

convertible seats and/or all-in-one seats 

for which seat back contact is prohibited 

when positioned rear-facing. Another 

example may be when a forward-facing 

child restraint’s user’s manual states 

that the restraint’s seat back must make 

full contact with the vehicle seat back, 

but this condition cannot be achieved 

because of the seat back or seat pan 

contour, a high seat bight, or head 

restraint interference. The restraint 

should have the ability to be properly 

utilized in every mode of use and in 

every adjustment position as described 

in the manual so that parents and 

caregivers can properly adjust the child 

restraint to accommodate the growth of 

their child(ren). 

G. Weight Limits 

Most forward-facing child restraints 

are equipped with internal harness 

systems that are designed for children 

weighing 40 pounds or less; however, 

many child restraint manufacturers now 

make forward-facing child restraints 

that are designed for heavier, taller 

children. These child restraints come 

with an internal harness system that can 

be used for children weighing up to 65 

pounds, and in some cases, 80 pounds. 

As mentioned previously, these 

restraints are informally known as 

‘‘high-weight harness’’ restraints. For 

vehicles that have established child 

weight limits for their LATCH anchors 

and those weight limits are lower than 

the upper child weight limits of these 

high-weight harness restraints, parents 

and caregivers should not install or 

continue to use these CRSs using the 

LATCH system when children surpass 

the upper weight range allowed by the 

vehicle LATCH anchors. In most cases, 

when the child’s weight exceeds the 

vehicle manufacturer’s LATCH child 

weight limit, the child restraint’s lower 

attachments and/or top tether may have 

to be detached from the vehicle, and the 

vehicle seat belt is then used to install 

the child restraint. In some instances, 

however, the weight limit established by 

the vehicle manufacturer for the 

vehicle’s top tether anchor may be 

higher than that for the vehicle’s lower 

anchors and the top tether may continue 

to be used after the CRS transitions from 

LATCH to a seat belt, until a new weight 

threshold is reached. Regardless of 

whether the CRS is installed with lower 

attachments or seat belts, many vehicle 

and child restraint manufacturers 

require that the tether also be 

disconnected once the child reaches a 

certain weight. 

As some vehicle manufacturers do not 

include information pertaining to the 

child weight limits for LATCH use in 

the vehicle owner’s manuals, NHTSA is 

concerned that many parents and 

caregivers are not given information as 

to whether they may have to disconnect 

the child restraint from the LATCH 

anchors and use the vehicle seat belts as 

their child gets heavier. There can also 

be confusion if the weight limits of the 

CRS and the vehicle LATCH system do 

not match. To ensure that parents and 

caregivers are provided with adequate 

information for proper restraint use and 

to improve the fit of CRSs in vehicles, 

NHTSA is proposing the following 

scenarios to assist vehicle 

manufacturers in their fit assessment 

process. In the following scenarios, the 

LATCH lower anchors and the top 

tether anchor have the same child 

weight limit or a LATCH weight limit is 

not provided by the vehicle 

manufacturer. 

• If the recommended CRS has a 

maximum child weight limit that is 40 

pounds or less, NHTSA will evaluate fit 

using LATCH lower anchors (with 

tether) or using seat belts (with tether), 

at each applicable seating position; 

• If the recommended CRS has a 

maximum child weight limit that is 

greater than 40 pounds and the vehicle 

manufacturer does include a child 

weight limit for LATCH use in the 

vehicle owner’s manual, NHTSA will 

evaluate fit at each applicable seating 

position as follows: 

(1) If the recommended CRS’s 

maximum child weight limit is less than 

or equal to the child weight limit 

specified in the vehicle owner’s manual 

for LATCH use, vehicle-CRS fit may be 

assessed using LATCH lower anchors 

(with tether) or using seat belts (with 

tether); 

(2) If the recommended CRS’s 

maximum child weight limit is greater 

than the child weight limit specified in 

the vehicle owner’s manual for LATCH 

use, vehicle-CRS fit may be assessed 

using: 

(a) LATCH lower anchors (with 

tether) or seat belts (with tether)—for 

children weighing up to the child 

weight limit specified in the vehicle 

owner’s manual for LATCH use; and 

(b) Seat belts only—for children 

weighing above the child weight limit 

specified in the vehicle owner’s manual 

for LATCH use. 

• If the recommended CRS has a 

maximum child weight limit that is 

greater than 40 pounds and the vehicle 

manufacturer does NOT include a child 

weight limit for LATCH use in the 

vehicle owner’s manual, NHTSA will 

evaluate fit at each applicable seating 

position using: 

(1) LATCH lower anchors (with 

tether) or seat belts (with tether)—for 

children weighing up to 40 pounds; and 

(2) Seat belts only—for children 

weighing more than 40 pounds. 

The agency believes the situation can 

exist where a vehicle manufacturer 

could specify a child weight limit for 

the LATCH system in which the lower 

anchors have a limit that differs from 

the weight limit of the top tether. In 

those situations, we believe the below 

scenarios would be appropriate for 

determining whether the lower anchors 

and top tether should be used. With 

regard to the lower anchors, we propose 

that NHTSA will attach the lower 

anchors if the CRS child weight limit is 

less than or equal to the anchor’s child 

weight limit provided by the vehicle 

manufacturer. If the CRS child weight 

limit is greater than the vehicle’s 

anchors child weight limit, we would 

not attach lower anchors and would use 

seat belts instead when assessing the fit 

of the CRS as the CRS is configured for 

children weighing above the child 

weight limit specified in the vehicle’s 

owner manual for LATCH lower 

anchors. With regard to the top tether, 

we propose that NHTSA will attach the 

tether if the CRS child weight limit is 

less than or equal to the tether child 

weight limit provided by the vehicle 

manufacturer. If the CRS child weight 

limit is greater than the vehicle’s tether 


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55See http://www.car-safety.org/rearface.html. 

56To limit inertia-induced rotation of a rearfacing child restraint upon rebound in a frontal or 

rear impact crash, many CRS come equipped with 

an anti-rebound bar. This device serves not only to 

transmit rotational forces seen by the CRS into the 

vehicle seat back during sudden changes in 

velocity, but also may reduce the chance of injuries 

resulting from a child’s contact with the vehicle 

seat during rebound. 

weight limit, we would not attach the 

top tether. That is, we would assess fit 

without using the tether. A summary of 

the above scenarios is shown in 

Appendix E. 

If NHTSA finds that a CRS does not 

fit a vehicle seating position when 

attached by the LATCH system or the 

seat belt system as described here, 

NHTSA plans to take action as proposed 

in the ‘‘Program Distribution’’ section 

(VII–C). 

H. Rear-Facing CRS 

Frontal crashes are the most 

frequently occurring types of crashes. In 

a frontal crash, a rear-facing CRS acts to 

cradle the child, prevents the child’s 

head from snapping backward with 

respect to its body, and helps distribute 

crash forces over the child’s head, neck, 

and back, thereby reducing the potential 

for injury to any one body region. It is 

especially important to face infants 

(children under one year old AND 

under 20 lbs) rear-facing, as the child’s 

neck has not yet matured to support the 

child’s head in a frontal crash. 

To balance safety and comfort for 

children restrained rear-facing, it is also 

imperative that parents and caregivers 

achieve the appropriate recline angle for 

rear-facing restraints.55 This angle, 

which is recommended by the CRS 

manufacturer, is typically specified to 

be between 30 and 45 degrees from 

vertical, and must be determined when 

the vehicle is on a level surface. Child 

restraint manufacturers often equip rearfacing child restraints with a level 

indicator so that caregivers can install 

the CRS at the appropriate angle. The 

prescribed angle must be especially 

maintained for newborns to prevent 

their airways from being restricted. As 

evidenced by the agency’s pilot study, 

parents and caregivers may find it 

particularly difficult to achieve the 

appropriate recline angle when 

installing a rear-facing CRS in a vehicle 

that has an extreme seat pan contour. 

NHTSA’s pilot study revealed several 

instances in which anti-rebound bars, 

equipped on some child restraints, 

increased stability on the vehicle seat, 

particularly for the rear center seating 

position.56 The agency also observed 

that these devices can actually help 

parents and caregivers to achieve and 

maintain the recommended recline 

angle for the CRS. 

With these considerations in mind, 

the agency is proposing the following 

additional assessment criteria for rearfacing CRS: 

—Can the CRS be installed to the recline 

angle specified by the manufacturer? 

—Can the anti-rotational device, if 

applicable, be adjusted/operated/ 

installed properly? 

A rear-facing child restraint should be 

able to be installed at the manufacturer’s 

prescribed angle (using any level 

indicators included) when the vehicle is 

on level ground. The agency is not 

proposing to permit the use of pool 

noodles, towels, or other objects to 

achieve the proper angle for the reasons 

specified previously. NHTSA is also 

proposing that an assessment of the 

installation, operation, and adjustment 

of anti-rotational devices be made for 

applicable CRS when installed rearfacing. If the device cannot be used, or 

if using it prohibits a tight fit, the 

restraint would not meet the assessment 

conditions for fit. 

XI. Conclusions and Effective Date 

For the reasons described above, the 

agency believes that there is a need to 

address vehicle-CRS fit via a consumer 

information program. We are proposing 

that a voluntary Vehicle-CRS Fit 

assessment program would be an 

effective method of meeting this need, 

as our pilot study showed it to be a 

viable option. To fulfill the participation 

conditions for the program, the agency 

is proposing that vehicle manufacturers 

follow a list of criteria, similar to those 

the agency is proposing in Appendix D, 

to determine CRS that fit in various 

vehicle models. 

Comments are requested on the 

program, including the criteria 

described in this document to assess a 

proper fit of a CRS in a vehicle, and the 

conditions we are considering setting 

for participation in the program 

(conditions that vehicle manufacturers 

have to meet to have their information 

listed on Safercar.gov). 

We are proposing that the program 

begin with vehicle model year 2012. 

However, we are requesting comments 

on the appropriate lead time for vehicle 

manufacturers to prepare for and 

participate in the program. Under our 

proposed program, vehicle 

manufacturers will submit 

recommendations of CRS that fit in their 

vehicle models to the agency via the 

Buying a Safer Car submission, which is 

collected annually. Although 

recommendations will be valid only for 

vehicle-CRS pairs, vehicle 

manufacturers need not provide data for 

all of their vehicle models in order to 

participate. The agency hopes that over 

time, a wealth of information will be 

generated. 

As discussed, in the interest of time 

and simplicity, the proposed program 

only includes objective fit criteria. Such 

objective criteria quantify fit in a clear 

manner, which vehicle manufacturers 

can quickly comprehend and use to start 

providing accurate assessments. The 

agency plans to reevaluate the program 

after its inception to ensure that 

consumers are receiving useful and 

complete information. If the agency 

determines that it is warranted and 

practical, additional CRS ease of fit 

criteria could be added. The agency also 

expects to revisit other aspects of the 

program, such as the number and type 

of fit suggestions being made by vehicle 

manufacturers. In particular, if the 

program is adopted, as proposed, the 

agency may reevaluate whether vehicle 

manufacturers may continue to claim 

vehicle-CRS fit for either LATCH or 

vehicle belts, or decide if the 

manufacturer must instead claim fit for 

both systems of attachment. 

While vehicle manufacturers will be 

expected to report CRS fit under the 

proposed program, we expect there to be 

motivation for CRS manufacturers to 

share in the process by identifying 

vehicles that their products can fit and 

reporting their findings to vehicle 

manufacturers. This serves both the 

vehicle manufacturers’ needs, the CRS 

manufacturers’ needs, and consumers’ 

needs. At this time, the agency does not 

plan to collect CRS fit information from 

CRS manufacturers directly. The agency 

believes that, in the interest of time, 

requesting this information from the 

vehicle manufacturers is the most 

appropriate approach. As mentioned, 

NCAP’s Buying a Safer Car information 

request should permit NHTSA to gather 

this information from the vehicle 

manufacturers in an organized and 

efficient manner. Furthermore, the 

agency does not currently have a means 

to collect similar information from the 

CRS manufacturers. That being said, in 

the interest of providing consumers 

with a greater number and variety of 

CRS from which to choose from, the 

agency is requesting comments on an 

alternative or additional approach to 

collecting this information. 

XII. Paperwork Reduction Act 

Before a Federal agency can collect 

certain information from the public, it 

must receive approval from the Office of 

Management and Budget (OMB). Under 

the Paperwork Reduction Act of 1995, a 

person is not required to respond to a 


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collection of information by a Federal 

agency unless the collection displays a 

valid OMB control number with an 

expiration date. Before seeking OMB 

approval, Federal agencies must publish 

a document in the Federal Register 

providing a 60-day public comment 

period and otherwise consult with 

members of the public and affected 

agencies concerning each proposed 

collection of information. 

NHTSA believes that the consumer 

information program described in this 

request for comments, if implemented, 

may result in a collection of information 

burden on motor vehicle manufacturers, 

even if the manufacturers provide the 

information voluntarily. In a separate 

Federal Register document, NHTSA 

will provide a full description of the 

proposed collection of information, 

including: (1) A discussion of the need 

for the information and the proposed 

use of the information; (2) a description 

of the likely respondents (including 

estimated number and proposed 

frequency of response to the collection 

of information); and (3) an estimate of 

the total annual reporting and 

recordkeeping burden resulting from the 

collection of information. A 60-day 

public comment period will be provided 

when the description of the proposed 

collection of information is published. 

XIII. Public Participation 

How do I prepare and submit 

comments? 

Your comments must be written and 

in English. To ensure that your 

comments are correctly filed in the 

Docket, please include the docket 

number of this document in your 

comments. 

Your comments must not be more 

than 15 pages long. (49 CFR 553.21). We 

established this limit to encourage you 

to write your primary comments in a 

concise fashion. However, you may 

attach necessary additional documents 

to your comments. There is no limit on 

the length of the attachments. 

Comments may also be submitted to 

the docket electronically by logging onto 

the Docket Management System Web 

site at http://www.regulations.gov. 

Follow the online instructions for 

submitting comments. 

Please note that pursuant to the Data 

Quality Act, in order for substantive 

data to be relied upon and used by the 

agency, it must meet the information 

quality standards set forth in the OMB 

and DOT Data Quality Act guidelines. 

Accordingly, we encourage you to 

consult the guidelines in preparing your 

comments. OMB’s guidelines may be 

accessed at http://www.whitehouse.gov/ 

omb/fedreg/reproducible.html. 

How do I submit confidential business 

information? 

If you wish to submit any information 

under a claim of confidentiality, you 

should submit three copies of your 

complete submission, including the 

information you claim to be confidential 

business information, to the Chief 

Counsel, NHTSA, at the address given 

above under FOR FURTHER INFORMATION

CONTACT. In addition, you should 

submit two copies, from which you 

have deleted the claimed confidential 

business information, to Docket 

Management at the address given above 

under ADDRESSES. When you send a 

comment containing information 

claimed to be confidential business 

information, you should include a cover 

letter setting forth the information 

specified in our confidential business 

information regulation. (49 CFR part 

512.) 

Will the agency consider late 

comments? 

We will consider all comments that 

Docket Management receives before the 

close of business on the comment 

closing date indicated above under 

DATES. To the extent possible, we will 

also consider comments that Docket 

Management receives after that date. If 

Docket Management receives a comment 

too late for us to consider in developing 

a final decision, we will consider that 

comment as an informal suggestion for 

future action. 

How can I read the comments submitted 

by other people? 

You may read the comments received 

by Docket Management at the address 

given above under ADDRESSES. The 

hours of the Docket are indicated above 

in the same location. You may also see 

the comments on the Internet. To read 

the comments on the Internet, go to 

http://www.regulations.gov. Follow the 

online instructions for accessing the 

dockets. 

Please note that even after the 

comment closing date, we will continue 

to file relevant information in the 

Docket as it becomes available. Further, 

some people may submit late comments. 

Accordingly, we recommend that you 

periodically check the Docket for new 

material. 

Issued on: February 18, 2011. 

Joseph S. Carra, 

Acting Associate Administrator for 

Rulemaking. 

Appendix A: Worldwide Child 

Restraint Consumer Information 

Programs 

In developing NHTSA’s Vehicle-CRS 

Fit program, the agency considered 

other international consumer 

information programs for child 

restraints. Some of the most prominent 

are briefly explained below. 

A. Child Restraints Evaluation Program 

(CREP) 

The New South Wales Roads and 

Traffic Authority joined with the 

National Roads and Motorists 

Association and the Royal Automobile 

Club of Victoria to establish a joint 

program to assess both the relative 

performance and the ease of using child 

restraints available in Australia. The 

resulting program, which began in 1994, 

is known as CREP, or the Child 

Restraints Evaluation Program. In 

addition to frontal and side impact sled 

testing of child restraints based on the 

Australian Standard AS 1754, CREP 

covers installation and compatibility 

with vehicles and features specific to 

the child restraint itself. The CREP 

criteria assess how easily child 

restraints can be installed as well as 

how easily a child can be secured. They 

also include an evaluation of the 

instructions, the clarity and quality of 

labeling and packaging, and vehicle 

compatibility. CREP does not address 

CRS compatibility as it relates to 

specific vehicles; therefore, the agency 

is not proposing this approach. 

B. Consumers Union 

Consumers Union (CU), publisher of 

Consumer Reports magazine, is a 

nonprofit membership organization that 

evaluates child restraints in dynamic 

sled tests, assesses their ease of use, and 

evaluates their compatibility with 

vehicles. In the United States, CU rates 

child restraints by evaluating the ease of 

using installation and harness features 

as well as the ease of placing and 

removing the child in the restraint. To 

evaluate compatibility, a few vehicles 

are selected from each model year that 

span a variety of body types and 

features related to child restraint 

installation. CU raters perform CRS 

installations in each of these vehicles to 

generally assess ease of installation. 

They do not, however, publish specific 

combinations or suggestions for fit 

between child restraints and vehicles. In 

addition, CU conducts sled testing to 

assign a dynamic performance rating to 


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57The EuroNCAP primarily provides consumers 

with crash safety ratings for vehicles sold 

throughout Europe. The program is funded by 

various European governments and private 

motoring clubs. EuroNCAP has traditionally rated 

vehicles for crashworthiness based on an offset 

frontal crash test at 40 mph (64 km/h) and a 90 

degree side impact crash test at 31 mph (50 km/h). 

Beginning in 2009, a previously optional side 

impact pole test became a mandatory part of the 

crashworthiness rating. 

58However, the child restraints tested in each 

vehicle are still displayed on the EuroNCAP Web 

site. 

59To be sold in Japan, child restraints may be 

certified to ECE R44, U.S. FMVSS No. 213, or 

Japan’s own regulation, JIS D 0401. The number of 

child restraints tested each year varies, but in April 

2009, results were published for five CRS that were 

deemed ‘‘currently available.’’ 

the child restraint. All of the items are 

evaluated on a five-part scale using the 

following rankings: ‘‘Excellent,’’ ‘‘Very 

good,’’ ‘‘Good,’’ ‘‘Fair,’’ and ‘‘Poor.’’ The 

ease of use, installation, and dynamic 

performance ratings are all combined 

into an overall rating for consumers 

based on the same five-part scale. 

Because the agency is primarily focused 

on proposing a program that addresses 

vehicle-CRS compatibility as it relates to 

specific vehicle and restraint pairs, CU’s 

method of evaluating CRS was not 

selected. 

C. EuroNCAP 

The European New Car Assessment 

Program, or EuroNCAP, also provides 

consumers with child occupant 

protection ratings for its vehicles. 

Vehicle manufacturers recommend 

child restraints suitable for installation 

in their products during their offset 

frontal and 90-degree side impact crash 

tests.57 Each vehicle’s rear seat is fitted 

with two child restraints: One suitable 

for a 3-year-old child and another 

suitable for an 18-month-old infant. 

Technicians evaluate the installation of 

the child restraints prior to the crash 

tests, and they assess the quality and 

completeness of the child restraint’s 

labeling information. The dynamic 

performance of the child restraint is 

determined by evaluating injury 

readings from child dummies placed in 

these child restraints. It is then 

combined with the installation and 

labeling evaluation as part of a vehicle’s 

overall child protection rating. Points 

earned during the evaluation are 

converted into a star rating. The overall 

child protection ratings are attributed to 

the vehicle in question rather than the 

particular child restraint.58 In addition, 

the ratings are specific to that 

combination of vehicle and CRS and do 

not necessarily indicate the safety 

performance of other child restraints in 

that vehicle. At this time, there are no 

stand-alone evaluations of child 

restraints conducted by EuroNCAP. Due 

to the fact that only a small portion of 

EuroNCAP’s approach is related to 

vehicle-CRS fit, the agency is not 

proposing to use this method. 

D. Japan NCAP (JNCAP) 

The Japanese Ministry of Land, 

Infrastructure and Transport, in 

cooperation with the National 

Organization for Automotive Safety & 

Victims’ Aid, tests and evaluates the 

safety of automobiles as part of its New 

Car Assessment Program (JNCAP). In 

2002, the JNCAP began rating child 

restraints for crash protection as well as 

usability. 

JNCAP dynamically rates Japan’s most 

popular child restraints by conducting a 

frontal sled test in excess of the 

country’s minimum child restraint 

performance requirements.59 Child 

restraints containing age-appropriate 

dummies are subjected to a 35 mph (56 

km/h) sled pulse which is based on the 

characteristics of the European child 

restraint safety standard, Economic 

Commission for Europe’s Regulation 44 

(ECE R44). The child restraints are 

installed on a sled buck based on the 

Toyota Estima, a popular family vehicle 

similar to the Toyota Sienna in the U.S. 

The rating is comprised of an evaluation 

of dummy readings and kinematics, the 

level of physical damage (if any) to the 

child restraint, and the release (if any) 

of child restraint buckles or other 

hardware. A four-tier rating system is 

used: ‘‘Excellent,’’ ‘‘Good,’’ ‘‘Normal,’’ 

and ‘‘Not Recommended.’’ 

JNCAP’s usability ratings are very 

similar to the structure and content of 

NHTSA’s Ease of Use (EOU) program for 

child restraint usability. Five child 

restraint specialists rate each child 

restraint chosen for dynamic testing 

across five categories of usability, each 

of which contains a number of different 

features for evaluation. The specialists 

in this program rate each feature on a 

scale of 1 to 5, with ‘‘3’’ representing an 

‘‘average’’ feature. The ratings given by 

all five specialists for each of the five 

categories of usability are averaged; all 

of the features within each category are 

then averaged as well. No overall rating 

is provided, but the five usability 

category scores are presented to the 

consumer as a numerical value from 1 

to 5. Because JNCAP’s ratings system 

does not address vehicle-to-CRS 

compatibility, this approach is not being 

proposed. 

E. New Program for the Assessment of 

Child Restraint Systems (NPACS) and 

the Child Seat Rating Scheme 

On August 3, 2009, the United 

Kingdom Transport Research Laboratory 

(TRL) announced it would launch a new 

five-star rating scheme for child 

restraints in 2010. In its inception, TRL 

relied heavily on the NPACS (New 

Programme for the Assessment of Childrestraint Systems) protocol published by 

the U.K. Department for Transport. 

Though all child restraints sold in the 

U.K. must meet the minimum 

performance standards of ECE R44, 

TRL’s new program will subject 

products to the NPACS testing protocol, 

which goes above and beyond the 

minimum performance standards set 

forth by ECE R44. The NPACS protocol 

(as well as the new TRL CRS program) 

includes a side impact sled test as well 

as a usability assessment, neither of 

which TRL felt were addressed 

sufficiently in ECE R44. The rating 

scheme that was developed under these 

efforts will present individual products’ 

safety in terms of an overall star rating, 

which is based on frontal and side sled 

test performance as well as a usability 

assessment. TRL hopes that the ratings 

will be useful to consumers seeking 

information on the comparative 

performance of child restraints as well 

as provide a new promotional tool for 

manufacturers and retailers. Again, 

because the NPACS protocol does not 

address CRS-to-vehicle compatibility as 

it relates to specific product pairs, the 

agency is not proposing to use this 

protocol. 

BILLING CODE P 


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Appendix B: Pilot Study Evaluation 

Form 


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Appendix C: Observations From 

Vehicle-CRS Pilot Study 

CRS Model 

Mitsubishi Eclipse Pontiac 5 Chevrolet Impala Chrysler Sebring Dodge Charger Ford Focus 

Seat 

belt LATCH Seat belt LATCH Seat belt LATCH Seat belt LATCH Seat belt LATCH Seat belt LATCH 

Combi Shuttle EX .... N(b) ..... N(f) ........ N(i) ...... Y ........... N(b)(i) .. N(c) ....... N(c)(r) .. N(r) ....... N(b) ................... Y ........... Y .......... Y 

Graco Snugride 32 .. N(b) ..... Y* .......... N(i) ...... Y ........... N(b) ..... Y ........... Y .......... N(c) ....... N(b) ................... N(l) ........ Y .......... Y 

Safety 1st Designer 

22.

N(b) ..... N(f) ........ N(b)(r) .. N(l) ........ N(b) ..... Y ........... N(f) ...... N(l) ........ N(b)(c) .............. N(c) ....... N(m) .... Y 

Graco ComfortSport N(b) ..... Y* .......... Y* ........ Y* .......... Y .......... Y ........... N(c)(f) .. N(c) ....... N(b)(r) ............... N(r) ....... N(t) ...... N(t) 

Britax Boulevard CS N(b) ..... Y* .......... Y* ........ Y* .......... N(b) ..... Y ........... Y .......... Y ........... N(b) ................... Y* .......... Y* ........ N(l) 

Sunshine Kids Radian XT.N(b) ..... Y* .......... Y* ........ Y* .......... N(b) ..... Y* .......... N(b)(c) N(c) ....... N(b) ................... N(l) ........ Y* ........ Y* 

Safety 1st Summit ... N(b) ..... Y ........... N(b)(c) N(l) ........ N(b) ..... Y ........... N(b)(c) N(c) ....... N(b) ................... Y ........... Y .......... Y 

Britax Frontier .......... N(b) ..... Y ........... N(b)(h) N(h) ....... N(b) ..... Y ........... N(b) ..... Y ........... N(b)(c) .............. N(c)(f) ... N(b) ..... Y 

Learning Curve B505 N(h)(s) n/a ......... Y(c) ...... n/a ......... Y .......... n/a ......... Y .......... n/a ......... N(b) ................... n/a ......... N(b) ..... n/a 

Magna Clek Olli ....... Y .......... N(l) ........ Y .......... Y ........... Y .......... Y ........... Y .......... Y ........... N(b) ................... N ........... N(b) ..... Y 

Evenflo Amp ............ Y .......... n/a ......... N(b)(c) n/a ......... Y .......... n/a ......... N(c) ..... n/a ......... N(b) ................... n/a ......... N(b) ..... n/a 

Safety 1st All in One N(c)(r) .. N(l) ........ N(b)(r) .. N(l) ........ N(b)(r) .. N(r) ....... N(b)(r) .. Y* .......... N(c) ................... N(c)(f) ... N(t) ...... N(l)(t) 

Evenflo Symphony ... N(b) ..... Y* .......... N(c)(h) N(f) ........ N(b) ..... Y ........... Y .......... Y ........... N(b)(c)(r) ........... N(f) ........ N(t) ...... N(t) 

N—Proper fit could not be achieved in every allowable seating position and mode of CRS use for this combination. 

Y—Proper fit was achieved for this vehicle-CRS combination in every allowable seating positioning and mode of use for this combination. 

*—Front seat may need to be positioned in front half of seat track to accommodate CRS installed rear-facing. 

(b)—Seat belt and child restraint are incompatible. 

(c)—Seat or seat back contour creates instability and does not allow for a proper install. 

(f)—Could not achieve 1′′ or less of movement at the belt/LATCH path for this installation. 

(h)—Height of roofline prevents the use of this CRS in its highest position. 

(i)—Seat belt latch plate button interfered with belt lock-off hardware. 

(l)—Lower anchors and child restraint are not compatible. 

(m)—Instructions in the CRS or vehicle owner’s manual prohibited this installation. 

(r)—Proper recline could not be achieved without use of a towel or pool noodle. 

(s)—Unwanted slack is created between the vehicle seat belt and the belt guide on this CRS. 

(t)—Tether cannot be properly tightened. 

CRS Model 

Hyundai Elantra Mazda Protege Toyota Yaris Subaru Forester Nissan Murano Toyota RAV4 

Seat 

belt LATCH Seat belt LATCH Seat belt LATCH Seat belt LATCH Seat belt LATCH Seat belt LATCH 

Combi Shuttle EX .... N(b) ..... Y ........... Y .......... Y ........... N(b)(c)(r)(m) ...... Y ........... N(i) ...... Y ........... Y .......... Y ........... N(b) ..... Y 

Graco Snugride 32 .. Y .......... Y ........... Y .......... Y ........... N(b)(m) ............. Y* .......... Y .......... Y ........... Y .......... Y ........... N(b) ..... Y 

Safety 1st Designer 

22.

Y .......... Y ........... N(b) ..... Y* .......... N(b)(c) .............. Y ........... N(i) ...... Y ........... N(b) ..... Y ........... N(b) ..... Y 

Graco ComfortSport Y .......... Y ........... N(b) ..... Y* .......... N(b)(c) .............. N(c)(l) .... Y .......... Y ........... Y .......... Y ........... N(b) ..... Y 

Britax Boulevard CS Y .......... Y ........... N(b) ..... Y* .......... N(b)(c) .............. Y* .......... Y .......... Y ........... Y .......... Y ........... N(b) ..... Y 

Sunshine Kids Radian XT.N(b) ..... Y ........... N(b) ..... N(l) ........ N(b) ................... N(l) ........ N(f) ...... Y ........... N(b) ..... Y ........... N(b) ..... N(l) 

Safety 1st Summit ... N(f) ...... N(f) ........ N(b) ..... N(l) ........ N(b)(c) .............. N(l) ........ Y .......... Y ........... Y .......... Y ........... N(b) ..... Y 

Britax Frontier .......... N(b) ..... Y ........... N(b) ..... Y ........... N(b)(h)(c) .......... N(h)(l) ... Y .......... Y ........... N(b) ..... Y ........... N(b) ..... Y 

Learning Curve B505 Y .......... n/a ......... Y .......... n/a ......... N(b) ................... n/a ......... Y .......... n/a ......... Y .......... n/a ......... Y .......... n/a 

Magna Clek Olli ....... Y .......... N(l) ........ Y .......... Y ........... N(b) ................... N(b)(l) ... Y .......... Y ........... Y .......... Y ........... Y .......... Y 

Evenflo Amp ............ Y .......... n/a ......... Y .......... n/a ......... N(b)(c) .............. n/a ......... Y .......... n/a ......... Y .......... n/a ......... Y .......... n/a 

Safety 1st All in One N(r) ...... Y ........... N(r) ...... N(r) ....... N(c)(r) ............... N(c)(r) ... Y .......... Y ........... N(b)(r) .. N(r) ....... N(b) ..... Y 

Evenflo Symphony ... Y .......... Y ........... N(b) ..... Y* .......... N(b)(c) .............. N(l) ........ Y .......... Y ........... Y .......... Y ........... N(b) ..... Y 

N—Proper fit could not be achieved in every allowable seating position and mode of CRS use for this combination. 

Y—Proper fit was achieved for this vehicle-CRS combination in every allowable seating positioning and mode of use for this combination. 

*—Front seat may need to be positioned in front half of seat track to accommodate CRS installed rear-facing. 

(b)—Seat belt and child restraint are incompatible. 

(c)—Seat or seat back contour creates instability and does not allow for a proper install. 

(f)—Could not achieve 1′′ or less of movement at the belt/LATCH path for this installation. 

(h)—Height of roofline prevents the use of this CRS in its highest position. 

(i)—Seat belt latch plate button interfered with belt lock-off hardware. 

(l)—Lower anchors and child restraint are not compatible. 

(m)—Instructions in the CRS or vehicle owner’s manual prohibited this installation. 

(r)—Proper recline could not be achieved without use of a towel or pool noodle. 

(s)—Unwanted slack is created between the vehicle seat belt and the belt guide on this CRS. 

(t)—Tether cannot be properly tightened. 


srobinson on DSKHWCL6B1PROD with NOTICES
10660 Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 

Appendix D: Proposed Vehicle-CRS Fit 

Assessment Forms 


srobinson on DSKHWCL6B1PROD with NOTICESEN25FE11.031</GPH>
Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 10661 


srobinson on DSKHWCL6B1PROD with NOTICESEN25FE11.032</GPH>
10662 Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 

Appendix E: Installation Methods for 

Assessing Vehicle-CRS Fit 

OVERALL CHILD WEIGHT LIMIT IS 40 LBS OR LESS

Is vehicle lower anchor 

child weight limit in 

vehicle manual? 

Is vehicle top tether 

anchor child weight limit 

in vehicle manual? 

CRS child weight limit 

≤ vehicle lower anchor 

child weight limit 

CRS child weight limit 

≤ vehicle top tether anchor child weight limit 

Methods of installation that NHTSA 

will evaluate 

Yes ................................. Yes ................................ Yes ................................ Yes ................................ Evaluations Conducted for Children 

Up to 40 lbs: 

• Lower Anchors w/Tether or 

• Seat belts w/Tether. 

No ................................. Yes ................................ N/A ................................ Evaluations Conducted for Children 

Up to 40 lbs: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

No .................................. Yes ................................ N/A ................................ Yes ................................ Evaluations Conducted for Children 

Up to 40 lbs: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

No ................................. N/A ................................ N/A ................................ Evaluations Conducted for Children 

Up to 40 lbs: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 


srobinson on DSKHWCL6B1PROD with NOTICESEN25FE11.033</GPH>
Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 10663 

OVERALL CHILD WEIGHT LIMIT IS GREATER THAN 40 LBS

Is vehicle lower anchor 

child weight limit in 

vehicle manual? 

Is vehicle top tether 

anchor child weight limit 

in vehicle manual? 

CRS child weight limit 

≤ vehicle lower anchor 

child weight limit 

CRS child weight limit 

≤ vehicle top tether anchor child weight limit 

Methods of installation that NHTSA 

will evaluate 

Yes ................................. Yes ................................ Yes ................................ Yes ................................ Evaluations Conducted for Children 

Up To 40 lbs: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

....................................... ....................................... No ................................. Evaluations Conducted for Children 

Up To Vehicle Tether Anchor 

Child Weight Limit: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

Evaluations Conducted for Children 

Over Vehicle Tether Anchor Child 

Weight Limit: 

• Lower Anchors or 

• Seat Belts. 

....................................... No ................................. Yes ................................ Evaluations Conducted for Children 

Up To Vehicle Lower Anchor Child 

Weight Limit: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

Evaluations Conducted for Children 

Over Vehicle Tether Anchor Child 

Weight Limit: 

• Seat Belts w/Tether. 

....................................... ....................................... No ................................. Evaluations Conducted for Children 

Up To Vehicle Lower Anchor Child 

Weight Limit: 

• Lower Anchors or 

• Seat Belts. 

Evaluations Conducted for Children 

Over Vehicle Lower Anchor Child 

Weight Limit but Under Vehicle 

Tether Anchor Child Weight Limit: 

• Seat Belts w/Tether. 

Evaluations Conducted for Children 

Over Vehicle Lower Anchor Child 

Weight Limit: 

• Seat Belts Only. 

No ................................. Yes ................................ N/A ................................ Evaluations Conducted for Children 

Up To 40 lbs: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

Evaluations Conducted for Children 

Over 40 lbs: 

• Lower Anchors or 

• Seat Belts. 

....................................... No ................................. N/A ................................ Evaluations Conducted for Children 

Up To 40 lbs: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

Evaluations Conducted for Children 

Over 40 lbs and Under or Equal to 

Vehicle Lower Anchor Child 

Weight Limit: 

• Lower Anchors or 

• Seat Belts. 

Evaluations Conducted for Children 

Over Vehicle Lower Anchor Child 

Weight Limit: 

• Seat Belts Only. 

No .................................. Yes ................................ N/A ................................ Yes ................................ Evaluations Conducted for Children 

Up To 40 lbs: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

Evaluations Conducted for Children 

Over 40 lbs: 

• Seat Belts w/Tether. 


srobinson on DSKHWCL6B1PROD with NOTICES
10664 Federal Register / Vol. 76, No. 38 / Friday, February 25, 2011 / Notices 

OVERALL CHILD WEIGHT LIMIT IS GREATER THAN 40 LBS—Continued 

Is vehicle lower anchor 

child weight limit in 

vehicle manual? 

Is vehicle top tether 

anchor child weight limit 

in vehicle manual? 

CRS child weight limit 

≤ vehicle lower anchor 

child weight limit 

CRS child weight limit 

≤ vehicle top tether anchor child weight limit 

Methods of installation that NHTSA 

will evaluate 

....................................... ....................................... No ................................. Evaluations Conducted for Children 

Up To 40 lbs: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

Evaluations Conducted for Children 

Over 40 lbs and Under or Equal to 

Vehicle Tether Anchor Child 

Weight Limit: 

• Seat Belts w/Tether. 

Evaluations Conducted for Children 

Over Vehicle Tether Anchor Child 

Weight Limit: 

• Seat Belts Only. 

No ................................. N/A ................................ N/A ................................ Evaluations Conducted for Children 

Up To 40 lbs: 

• Lower Anchors w/Tether or 

• Seat Belts w/Tether. 

Evaluations Conducted for Children 

Over 40 lbs: 

• Seat Belts Only. 

[FR Doc. 2011–4212 Filed 2–24–11; 8:45 am] 

BILLING CODE C 

DEPARTMENT OF THE TREASURY 

Submission for OMB Review; 

Comment Request 

February 18, 2010. 

The Department of the Treasury will 

submit the following public information 

collection requirement to OMB for 

review and clearance under the 

Paperwork Reduction Act of 1995, 

Public Law 104–13 on or after the date 

of publication of this notice. A copy of 

the submission may be obtained by 

calling the Treasury Bureau Clearance 

Officer listed. Comments regarding this 

information collection should be 

addressed to the OMB reviewer listed 

and to the Treasury PRA Clearance 

Officer, Department of the Treasury, 

1750 Pennsylvania Avenue, NW., Suite 

11010, Washington, DC 20220. 

DATES: Written comments should be 

received on or before March 28, 2011 to 

be assured of consideration. 

Internal Revenue Service (IRS) 

OMB Number: 1545–2081. 

Type of Review: Extension of a 

currently approved collection. 

Title: REG–148867–03 (Final) 

Disclosure of Returns and Return 

Information in Connection with Written 

Contracts or Agreements for the 

Acquisition of Property and Services for 

Tax Administration. 

Abstract: The regulations clarify that 

redisclosures of returns and return 

information by contractors to agents or 

subcontractors are permissible, and that 

the penalty provisions, written 

notification requirements, and safeguard 

requirements are applicable to these 

agents and subcontractors. Section 

301.6103 (n)–1(d) of the proposed 

regulations require that contractors, 

agents, and subcontractors who receive 

returns or return information under the 

proposed regulations must provide 

written notice to their officers and 

employees of the purposes for which 

returns or return information may be 

used and of the potential civil and 

criminal penalties for unauthorized 

inspections or disclosures, including 

informing them of the imposition of 

punitive damages in the case of a willful 

inspection or disclosure or an 

inspection or disclosure which is the 

result of gross negligence. Section 

301.6103(n)–1(e)(3) of the proposed 

regulations require that before the 

execution of a contract or agreement for 

the acquisition of property or services 

under which returns or return 

information will be disclosed, the 

contract or agreement must be made 

available to the IRS. 

Respondents: Private sector: 

Businesses or other for-profits. 

Estimated Total Burden Hours: 250 

hours. 

OMB Number: 1545–1916. 

Type of Review: Extension of a 

currently approved collection. 

Title: REG–159824–04 (NPRM) 

Regulations Governing Practice before 

the Internal Revenue Service. 

Abstract: These regulations set forth 

minimum standards for State or local 

bond options. 

Respondents: Individuals or 

households. 

Estimated Total Burden Hours: 30,000 

hours. 

OMB Number: 1545–1774. 

Type of Review: Extension of a 

currently approved collection. 

Title: TD 9187 (Final) Extensions of 

Time To Elect Method for Determining 

Allowable Loss; 

Abstract: The information is 

necessary to allow the taxpayer to make 

certain elections to determine the 

amount of allowable loss under Section 

1.337(d)–2T, Section 1.1502–20 as 

currently in effect or under Section 

1.1502–20 as modified; to allow the 

taxpayer to waive loss carryovers up to 

the amount of the Section 1.150–20(g) 

election and to ensure that loss is not 

disallowed under Section 1.337(d)–2T 

and basis is not reduced under Section 

1.337(d)–2T to the extent the taxpayer 

establishes that the loss or basis is not 

attributable to the recognition of built in 

gain on the disposition of an asset. 

Respondents: Private sector: 

Businesses or other for-profits. 

Estimated Total Burden Hours: 36,720 

hours. 

OMB Number: 1545–1612. 

Type of Review: Extension of a 

currently approved collection. 

Title: REG–209830–96 (TD 8779— 

Final) Estate and Gift Tax Marital 

Deduction. 

Abstract: The information requested 

in regulation section 20.2056(b)– 

7(d)(3)(ii) is necessary to provide a 

method for estates of decedents whose 

estate tax returns were due on or before 

February 18, 1997, to obtain an 

extension of time to make the qualified 


srobinson on DSKHWCL6B1PROD with NOTICES