DOT HS 809 834 December 2004

Technical Report

This document is available to the public from the National Technical Information Service, Springfield, Virginia 22161

Cost and Weight Added by the Federal

Motor Vehicle Safety Standards for Model

Years 1968-2001 in Passenger Cars and

Light Trucks
The United States Government does not endorse products or 

manufacturers. Trade or manufacturers’ names appear only 

because they are considered essential to the object of this report. 
 Technical Report Documentation Page 

1. Report No. 

DOT HS 809 834

2. Government Accession No. 3. Recipient’s Catalog No. 

5. Report Date 

December 2004

4. Title and Subtitle 

Cost and Weight Added by the Federal Motor Vehicle Safety 

Standards for Model Years 1968-2001 in Passenger Cars and Light 

Trucks

6. Performing Organization Code 

7. Author(s) 

Marcia J. Tarbet

8. Performing Organization Report No. 

9. Performing Organization Name and Address 10. Work Unit No. (TRAIS) 

Evaluation Division; National Center for Statistics and Analysis 

National Highway Traffic Safety Administration 

Washington, DC 20590

11. Contract or Grant No. 

13. Type of Report and Period Covered 

NHTSA Technical Report

12. Sponsoring Agency Name and Address 

Department of Transportation 

National Highway Traffic Safety Administration 

Washington, DC 20590

14. Sponsoring Agency Code 

15. Supplementary Notes 

 

16. Abstract 

The National Highway Traffic Safety Administration (NHTSA) began to evaluate the cost of its Federal 

Motor Vehicle Safety Standards (FMVSS) in 1975. The agency’s contractors perform detailed 

engineering “teardown” analyses, for representative samples of vehicles, to estimate how much specific 

FMVSS add to the weight and the retail price of a vehicle. This process is also known as “reverse 

engineering.” By July 2004, NHTSA and its contractors had evaluated virtually all the cost-and weightadding technologies introduced by 2001 in passenger cars and light trucks (including pickup trucks, sport 

utility vehicles, minivans, and full-size vans) in response to the FMVSS. The agency is now ready to 

estimate the cost and weight added by all the FMVSS, and by each individual FMVSS, to model year 

2001 passenger cars and light trucks, and also in all earlier model years, back to 1968. NHTSA estimates 

that the FMVSS added an average of $839 (in 2002 dollars) and 125 pounds to the average passenger car 

in model year 2001. Approximately four percent of the cost and four percent of the weight of a new 

passenger car could be attributed to the FMVSS. An average of $711 (in 2002 dollars) and 86 pounds 

was added to the average light truck in model year 2001. Approximately three percent of the cost and 

two percent of the weight of a new truck could be attributed to the FMVSS. 

17. Key Words 

FMVSS; cost analysis; teardown; reverse 

engineering

18. Distribution Statement 

Document is available to the public through the 

National Technical Information Service, 

Springfield, Virginia 22161

19. Security Classif. (Of this report) 

Unclassified

20. Security Classif. (Of this page) 

Unclassified

21. No. of Pages 

 168

22. Price 

Form DOT F 1700.7 (8-72) Reproduction of completed page authorized

TABLE OF CONTENTS 

 Page

Acknowledgements....................................................................................................................v 

Executive Summary............................................................................................................... vii 

Section 1 – Background and Methodology................................................................................1 

Section 2 – FMVSS 100 Series............................................................................................. 15 

Section 3 – FMVSS 200 Series............................................................................................. 43 

Section 4 – FMVSS 300, 400 and 500 Series .......................................................................131 

Section 5 – Final Summary and Tables ................................................................................ 137 

References............................................................................................................................. 159 

iii
iv
ACKNOWLEDGEMENTS 

In 1975, NHTSA proposed to evaluate the costs as well as the benefits of existing Federal Motor 

Vehicle Safety Standards (FMVSS). Warren LaHeist, under the general direction of Frank 

Ephraim, planned to estimate costs based on “teardown” or “reverse engineering.” The first 

contract to evaluate costs of specific FMVSS was awarded in 1977 and completed in 1978. 

During 1978-2001, Robert Lemmer, Bruce Spinney, Gregory Rymarz, or Mr. LaHeist managed 

the cost-analysis program. Mr. Spinney also developed NHTSA’s “macro-analysis” for 

computing mark-ups from direct costs to final consumer costs. 

A report summarizing the cost analyses and estimating the overall consumer cost of the FMVSS 

was proposed first in NHTSA’s 1998-2002 Evaluation Plan and again in the 2004-2007 plan. 

Mr. LaHeist outlined the report in 1998-1999 and drafted text for some of the FMVSS. After 

Mr. LaHeist retired, Mr. Rymarz worked up initial spreadsheets and/or text for many of the 

remaining FMVSS in 1999-2001. I was assigned to the cost-analysis program, as well as this 

report, when I joined NHTSA in 2002. 

 

v
vi
EXECUTIVE SUMMARY

The National Highway Traffic Safety Administration (NHTSA) issues Federal Motor Vehicle 

Safety Standards (FMVSS) for new motor vehicles and equipment to reduce the number of 

crashes and the risk of deaths and injuries. The 100-series FMVSS are crash avoidance 

standards, the 200-series regulates crashworthiness, while the 300-, 400- and 500-series address 

the risk of fires, hazards during normal operation, and certain special vehicles. Manufacturers of 

new vehicles and equipment must conform and certify compliance to the FMVSS. The initial 

FMVSS went into effect on January 1, 1968. 

NHTSA began to evaluate the cost of the FMVSS in 1975. The agency’s contractors perform

detailed engineering “teardown” analyses, for representative samples of vehicles, to estimate 

how much specific FMVSS add to the weight and the retail price of a vehicle. These analyses 

employ a process known as “reverse engineering.” Whereas conventional engineering proceeds 

from design and raw materials to mass-produced product, reverse engineering includes a step-bystep teardown or disassembly of each finished item into sub-assemblies and finally into 

individual component parts. The contractor weighs the components, identifies the type, unit cost 

and amount of raw material needed, and estimates the labor, variable burden, and tooling 

required to produce individual components and assemble them. In addition to these direct 

variable costs, the contractor estimates the mark-ups to the consumer’s full cost. 

By July 2004, NHTSA and its contractors had evaluated virtually all the cost- and weight-adding 

technologies introduced by 2001 in passenger cars and light trucks (including pickup trucks, 

sport utility vehicles, minivans, and full-size vans) in response to the FMVSS. The agency is 

now ready to estimate the cost and weight added by all the FMVSS, and by each individual 

FMVSS, to model year 2001 passenger cars and light trucks, and also in all earlier model years, 

back to 1968. All costs are estimated in 2002 dollars. Upon publication of this report, NHTSA 

will also make available to the public all the contractor studies completed to date. 

The cost of a FMVSS, in this report, includes the cost of all equipment added or modified 

primarily for the purpose of meeting (or even exceeding) the requirements of the standard, 

provided these modifications took place on or after the effective date, or even before the 

effective date if NHTSA had a rulemaking process underway and there was a clear anticipation 

of the standard. (But if safety equipment was already in place well before any rulemaking 

process, and was not modified in response to any FMVSS, its cost will not be attributed to the 

FMVSS.) The cost of a FMVSS is the incremental cost over the equipment that was there before 

the standard and likely would have remained there without the standard. In addition, the cost of 

a FMVSS may change over time, as a result of more efficient design, new types of materials, or 

vehicle downsizing (if the weight of the equipment is proportional to the weight of the vehicle). 

The report does not include technologies so recent that NHTSA has not yet completed its cost 

analysis, such as side air bags and head air bags. Furthermore, the report is limited to passenger 

cars and light trucks; the cost of FMVSS in heavy trucks, buses or motorcycles has not been 

estimated. 

vii
The Cost and Weight Added by the FMVSS in Model Year 2001. NHTSA estimates that the 

FMVSS added an average of $839 (in 2002 dollars) and 125 pounds to the average passenger car 

in model year 2001. Since passenger cars cost an average of $21,217 (in 2002 dollars) and 

weighed 3,148 pounds in model year 2001, approximately four percent of the cost and four 

percent of the weight of a new passenger car could be attributed to the FMVSS. An average of 

$711 (in 2002 dollars) and 86 pounds was added to the average light truck in model year 2001. 

With light trucks costing an average of $23,995 (in 2002 dollars) and weighing 4,238 pounds in 

model year 2001, approximately three percent of the cost and two percent of the weight of a new 

truck could be attributed to the FMVSS.1

 Table 1 itemizes the cost and weight added by the 

FMVSS, or by specific safety technologies associated with these FMVSS, to passenger cars and 

light trucks in model year 2001. 

TABLE 1

COST (IN 2002 DOLLARS) AND WEIGHT (IN POUNDS) 

ADDED BY THE FMVSS IN MODEL YEAR 20012

PASSENGER CARS LIGHT TRUCKS 

FMVSS DESCRIPTION COST WEIGHT COST WEIGHT

104 Windshield Wipers and Washers 

Dual speed wipers, washers $15.05 2.10

105 Hydraulic Brake System

Dual master cylinders $10.88 0.95 11.00 0.96

108 Lamps

Side marker lamps 29.37 1.95 29.37 1.95

Center high mounted stop lamps 9.74 0.85 9.74 0.85

118 Power-Operated Window

Circuit breaker 0.78 0.03 0.77 0.03

124 Accelerator Control System 0.47 0.02 0.47 0.02

201 

Occupant Protection in Interior

Impact (1968/1981 Standard)

Seat back padding 4.44 0.66 11.25 3.15

202 Head Restraints 30.89 5.63 30.97 3.98

203/204

Occupant Protection from the 

Steering Control System 27.45 1.89 27.45 1.89 

207 Seating Systems

Seat back locks 3.22 0.79

208 Occupant Crash Protection 

Safety belts 124.63 18.38 137.57 18.41

Dual air bags 396.72 26.76 382.52 26.40

On/off switches 8.75 0.20

214 Side Impact Protection

Static test 51.21 24.81 29.44 23.76

Dynamic test 129.35 37.31

216 Roof Crush Resistance 3.47 2.93 

301 Fuel System Integrity 16.51 2.48 16.51 2.48 

TOTAL $839.13 125.44 $710.86 86.18

 1

 The average cost of the 2001 passenger cars and light trucks are based on the Manufacturer’s Suggested Retail 

Price (MSRP). The MSRP cost for the 2001 passenger car and light truck does not include price reductions such as 

rebates or incentives offered by the dealer and/or the manufacturer, nor does it include price additions such as added 

charges and optional features. 2

 Average cost and weight per model year 2001 vehicle. For example, if a safety device costs $100 and 50% of 

the vehicles are equipped with it; the average cost per vehicle is $50. 

viii
Those technologies that contributed most significantly to the cost and weight of a passenger car 

and light truck in 2001 are: 

• Safety Belts. The primary component of the occupant protection system is the safety 

belt. They are highly effective in saving lives and preventing serious injuries in rollovers, 

frontal crashes, and many types of side impacts. Safety belts evolved from lap belts with 

manual adjustments to manual 3-point belts that combine the lap belt and shoulder 

harness into a single device with locking retractors. All front and rear outboard seats are 

now equipped with manual 3-point belts. These technologies add $124.63 and 18.38 

pounds to passenger cars and $137.57 and 18.41 pounds to light trucks. 

 

• Frontal Air Bags. By the late 1990’s, passenger cars and light trucks were equipped 

with a frontal air bag and a manual lap/shoulder belt at both the driver’s and right front 

passenger’s seating position. The air bags are designed to save lives and prevent injuries 

by cushioning occupants as they move forward in a frontal crash, reducing the likelihood 

of injury to an occupant’s head, neck, face, chest, and abdomen. Dual air bags add 

$396.72 and 26.76 pounds to passenger cars and $382.52 and 26.40 pounds to light 

trucks. 

• Side Impact Protection. Vehicle side structures are substantially reinforced and padded 

to meet NHTSA’s static crush tests and dynamic crash tests and reduce the risk of serious 

and fatal injury to occupants in side impact crashes. These changes add $180.56 and 

62.12 pounds to passenger cars and $29.44 and 23.76 pounds to light trucks. 

• Lamps. Side marker lamps and center high mounted stop lamps (CHMSL) are two new 

lighting systems required by FMVSS 108. Side marker lamps make it easier to see the 

side of another vehicle in the dark. CHMSL send an additional message to following 

vehicles that they must slow down. These lamps add a total of $39.11 and 2.80 pounds to 

passenger cars and light trucks. 

• Head Restraints. Adjustable or fixed head restraints are required at the front outboard 

seat positions to reduce the frequency and severity of neck injuries, specifically 

“whiplash”, in rear-end and other collisions. Implementation of the head restraints adds

$30.89 and 5.63 pounds to passenger cars and $30.97 and 3.98 pounds to light trucks. 

• Energy Absorbing Assemblies. FMVSS 203 requires that the steering control systems 

yield forward to cushion the impact of a front-end crash on the driver’s chest and FMVSS 

204 limits the rearward displacement of the steering column into the passenger 

compartment after a frontal impact. These changes add $27.45 and 1.89 pounds to 

passenger cars and light trucks. 

ix
Historical trend of the cost and weight added by the FMVSS for model years 1968-2001. The 

initial FMVSS of 1968 added $169 and 18 pounds to the average passenger car in model year 

1968. By model year 2001, the cost had grown to $839 (in constant, 2002 dollars) and the 

weight to 125 pounds. In light trucks, the cost and weight of the FMVSS grew from $107 and 11 

pounds in 1968 to $711 and 86 pounds in 2001. Table 2 shows the cost and weight added by the 

FMVSS in vehicles of each model year from 1968 to 2001. 

TABLE 2

COST (IN 2002 DOLLARS) AND WEIGHT (IN POUNDS) 

ADDED BY THE FMVSS FOR MODEL YEARS 1968-2001

MODEL PASSENGER CARS LIGHT TRUCKS 

YEAR COST WEIGHT COST WEIGHT

1968 $169.24 18.39 $106.58 10.51 

1969 $216.05 33.15 $106.64 10.52 

1970 $236.02 40.21 $115.95 11.07 

1971 $241.47 43.35 $116.24 11.10 

1972 $268.24 49.82 $142.26 15.90 

1973 $291.23 63.09 $154.61 16.75 

1974 $301.97 70.48 $160.79 17.59 

1975 $299.54 68.64 $160.87 17.61 

1976 $312.58 69.07 $162.27 17.71 

1977 $306.66 66.68 $173.14 19.02 

1978 $302.85 64.41 $189.14 21.46 

1979 $299.58 62.33 $191.06 21.59 

1980 $298.26 62.33 $195.96 21.96 

1981 $297.87 61.33 $196.63 22.02 

1982 $297.25 60.72 $206.92 23.68 

1983 $297.61 60.38 $212.12 24.35 

1984 $297.66 60.42 $214.28 24.61 

1985 $298.29 60.24 $216.33 24.88 

1986 $299.50 60.20 $216.81 24.94 

1987 $338.32 63.14 $233.52 27.23 

1988 $380.42 66.84 $232.58 27.12 

1989 $421.31 70.18 $232.42 27.20 

1990 $596.71 82.02 $236.15 27.70 

1991 $593.10 80.13 $250.26 30.45 

1992 $607.59 79.76 $294.29 34.70 

1993 $650.01 82.76 $308.55 36.81 

1994 $752.09 93.66 $389.49 60.69 

1995 $777.93 99.96 $547.71 72.67 

1996 $782.84 104.50 $612.52 77.53

1997 $838.81 125.34 $658.58 81.79

1998 $839.18 125.47 $705.27 85.73

1999 $839.16 125.46 $708.22 85.93

2000 $839.29 125.51 $709.39 86.04

2001 $839.13 125.44 $710.86 86.18

x
The safety technologies installed in passenger cars by model year 1968, responding to the initial 

FMVSS of January 1, 1968, included lap/shoulder or lap belts at all seat positions, energyabsorbing steering assemblies, dual master cylinders, and seat back locks, among others. In 

addition, model year 1968 passenger cars were equipped with side marker lamps, anticipating a 

requirement that would take effect on January 1, 1969. These technologies added $169 (in 2002 

dollars) and 18 pounds to model year 1968 passenger cars. 

By model year 1974, cost had increased to $302 and weight to 70 pounds. Side door beams were 

installed in response to the original static crush requirement of FMVSS 214. Front-outboard 

seats were equipped with head restraints. Safety belts were substantially upgraded: drivers and 

right-front passengers received integral 3-point belts with locking retractors, and rear-outboard 

lap belts were equipped with retractors. 

Cost and weight in passenger cars changed little from 1974 to 1986, as no major new FMVSS 

went into effect. 

Cost increased from $300 in 1986 to $752 in 1994, and weight from 60 to 94 pounds, primarily 

due to the automatic occupant protection requirements of FMVSS 208. The increase was 

gradual over that time period. Automatic protection was phased in from model year 1987 to 

1990. Then, especially in 1991-94, manufacturers shifted to more effective, but more expensive 

types of automatic protection: from automatic belts, to driver air bags, to dual frontal air bags. 

The dynamic crash test requirement of FMVSS 214 phased in a substantial upgrading and 

padding of side structures during 1994-97. The total cost of the FMVSS increased to $839, and 

their weight to 125 pounds by 2001. 

Most of the FMVSS were extended from passenger cars to light trucks, but only after they had 

been in effect on passenger cars for some years. Many safety technologies were installed in light 

trucks later than in passenger cars, typically after they had been required in passenger cars but 

before the FMVSS were extended to light trucks. In model year 1968, safety equipment added 

$107 and 11 pounds to light trucks. However, most of this equipment, including lap belts and 

dual master cylinders, was not actually required by the FMVSS in trucks at that time, only in 

passenger cars. 

Cost had increased to $189 by 1978 and weight to 21 pounds. By then, most light trucks had 

been equipped with 3-point belts and retractors at the front-outboard positions and energyabsorbing steering assemblies. Cost continued to increase gradually to $250 in 1991, and weight 

to 30 pounds, as more of the basic FMVSS were extended to light trucks. 

The installation of frontal air bags for drivers in 1992-96, and the addition of passenger air bags 

in 1994-98 increased the total cost of the FMVSS in light trucks to $711 and their weight to 86 

pounds by 2001.

xi
xii
FEDERAL MOTOR VEHICLE SAFETY STANDARDS 

SECTION 1 – BACKGROUND AND METHODOLOGY

The National Highway Traffic Safety Administration (NHTSA) has a legislative mandate under 

Title 49 of the United States Code, Chapter 301, Motor Vehicle Safety, to issue Federal Motor 

Vehicle Safety Standards (FMVSS) and Regulations to which manufacturers of motor vehicles 

and equipment must conform and certify compliance. Chapter 301 defines a FMVSS as a 

“minimum standard for motor vehicle performance or motor vehicle equipment performance that 

is practicable, meets the need for motor vehicle safety, and provides objective criteria.1

” The 

requirements are specified in such a manner “that the public is protected against unreasonable 

risk of crashes occurring as a result of the design, construction, or performance of motor vehicles 

and is also protected against unreasonable risk of death or injury in the event crashes do occur.2

” 

NHTSA has a comprehensive program to evaluate existing motor vehicle regulations to 

determine their effectiveness, benefits, and costs.3

 The program includes evaluation of the 

weight and initial consumer cost of components that have been modified or added to motor 

vehicles in order to comply with the performance requirements of existing regulations. Since the 

late 1970’s, NHTSA has sponsored cost studies of automotive safety equipment, and contractors 

have performed detailed engineering “teardown” analyses to provide definitive cost and weight 

estimates of this equipment. Results from these various analyses have been scattered among 

many hard-copy contractor’s reports, using different economic years and sometimes-inconsistent 

methods of averaging costs across models. 

The objective of this report is to estimate the overall cost of the FMVSS and the cost of each 

standard with a uniform methodology. Cost and weight data for the major components of the 

motor vehicle equipment will be extracted from contractor and NHTSA reports and compiled 

into a summary report. Care will be taken to determine the economic year used for the cost data 

in each study. All cost data will then be brought to the most recent full economic year using the 

gross domestic product implicit price deflator from the Bureau of Economic Analysis. The 

report will also describe what vehicle modifications were made in response to the various 

FMVSS and explain how the cost estimates were derived. In addition, the report will estimate 

the total cost of meeting the FMVSS in passenger cars and light trucks, with the year-by-year 

breakdown of the cost and weight per passenger car and light truck from 1968 thru 2001. 

Finally, previously unreleased contractor studies will be made available and accessible to the 

public. 

This report is limited to initial consumer costs of FMVSS, i.e., the likely effect of the FMVSS on 

the initial purchase price of a vehicle. Lifetime costs for maintaining or, when necessary, 

replacing components are not included; however, these costs tend to be negligible for most 

FMVSS. 

 1

 Legal citation: 49 Code of Federal Regulations (CFR) 1.50 (2004). 2

 Ibid. 3 National Highway Traffic Safety Administration Evaluation Program Plan Calendar Years 2004-2007, 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, January 2004 

(DOT HS 809 699). 

1
The Cost of a FMVSS. The cost of a FMVSS includes the cost of all equipment added or 

modified primarily for the purpose of complying with the standard, provided these modifications 

took place on or after the effective date, or even before the effective date if there was a 

rulemaking process underway and there was a clear anticipation of the standard. The following 

factors are considered when determining the cost of a FMVSS: 

• If a standard essentially did not change vehicles (i.e., if the equipment was already in 

place well before any rulemaking process was underway and the standard essentially 

mandated what had already long been there), this standard does not add cost to the 

vehicle, and the cost of the equipment that was already there will not be attributed to the 

FMVSS. For example, every passenger vehicle that came under FMVSS 103 had already 

been equipped with a windshield defrosting and defogging system long before the 

standard went into effect, nor is there any evidence that these systems were upgraded to 

meet the standard. 

• If manufacturers voluntarily put the equipment in a few years before the effective date, 

but after NHTSA announced plans to issue a standard, these costs will be attributed to the 

standard. For example, manufacturers voluntarily installed side door beams from 1969-

1972 even though FMVSS 214 did not take effect until January 1973. Nevertheless, 

because NHTSA announced its intention to regulate side door strength in October 1968, 

it would appear that these “voluntary” installations were in fact undertaken in response 

to, or anticipation of, FMVSS 214. 

• Even if the equipment or modification exceeded the minimum requirements of the 

standard, these costs will nevertheless be attributed to the standard. For example, if a 

model year 1987-1996 passenger car has air bags, the cost of the air bags will be fully

attributed to FMVSS 208 even though at that time they could have also complied with the 

standard using less expensive automatic belts. 

• We have only estimated costs of FMVSS that have permanent costs. If a FMVSS causes 

momentary redesign costs but ultimately does not result in any new equipment, we have 

not estimated a cost. For example, the requirements of FMVSS 101 resulted in simply 

relocating and changing the visual appearance of the controls and displays. 

The possibility exists that manufacturers could have eventually added some of the safety 

equipment currently required by FMVSS even if NHTSA had never issued those FMVSS. 

Similarly, if an existing FMVSS were to be rescinded, manufacturers might well choose not to 

stop installing the safety equipment previously required by the FMVSS. However, this report 

will not speculate on what manufacturers might have added to or deleted from their vehicles in 

these purely hypothetical scenarios. If the safety equipment was originally installed during or 

immediately after the rulemaking process, this report will continue to attribute to that FMVSS 

the cost of that safety equipment, or its successors, in subsequent model years. 

The cost of a FMVSS is the incremental cost over the equipment that was there before the 

FMVSS and likely would have remained there without the FMVSS. For example, a cost of 

FMVSS 105 is the difference between the costs of dual master cylinders and the single master 

cylinders that existed in pre-standard vehicles. 

2
However, in the special case where a standard puts in an entirely new type of equipment, the cost 

of the FMVSS is the full cost of the new equipment. For example, the center high mounted stop 

lamp was an added-on device and little, if any, change was made to any other part of the vehicle 

to accommodate the lamp. 

The cost of a FMVSS may change over time, as a result of more efficient design, new types of 

materials, or vehicle downsizing (if the weight of the equipment is proportional to the weight of 

the vehicle). For example, head restraints became less expensive due to more efficient design, 

and side door beams due to all of these factors, including vehicle downsizing. We are interested 

in tracking the costs over time when possible, but in doing so we must also keep in mind what 

might have happened to the vehicle over time if the FMVSS had never been issued. For 

example, dual master cylinders became less expensive over time, but we should note that single 

master cylinders might also have become less expensive. 

A FMVSS can only result in added cost or no cost, never a savings. If the new equipment is less 

expensive, manufacturers could presumably have installed it even without the standard. 

Cost and Weight Analysis Methodology. The “teardown” or “reverse engineering” methodology 

typically used by a NHTSA contractor for the collection of cost and weight data is described 

below. 

• Cost Study Sampling Plan. An integrated cost sampling plan is developed to provide for 

the selection of a group of comparable makes and models that are representative of 

vehicle systems prior to and after the effective date of the standards. The plan is 

designed to identify a representative cross-section of vehicle sizes and models, plus 

design and manufacturing cultural approaches, without the need to individually examine 

every make-model passenger vehicle produced in the affected years. Make-models of 

passenger vehicles are selected, and system components purchased, for cost analysis. 

These make-models should: 

o have over 50,000 annual sales volume 

o include matching pre- and post-standard vehicles of the same make-model (unless 

the FMVSS resulted strictly in add-on equipment, in which case it is only 

necessary to sample the post-standard vehicles) 

o represent the variety of designs or differences in the types of parts used to meet 

the FMVSS 

o represent the major domestic and import auto manufacturers 

o represent vehicle weights or sizes ranging from small to large 

o represent the vehicle types (passenger car, SUV, van, or pickup truck) 

3
• Teardown Process. The cost and weight estimates are based on detailed engineering 

analysis of the individual pieces and assemblies of which the system is composed, 

employing a process known as “reverse engineering”. Whereas conventional engineering 

proceeds from design to mass-produced product and proceeds back through the various 

manufacturing processes to the design, this procedure includes a step-by-step teardown or 

disassembly of each item into sub-assemblies and finally into individual component parts. 

The teardown sequence is the reverse of the assembly sequence. The components and 

parts are carefully cataloged and tagged as they are being disassembled. The parts are 

gauged, measured, manufacturing method determined, and, if possible, the vendor for 

outsourced parts identified. Even parts that were welded or irreversibly attached are 

carefully disassembled. The system components are physically torn down into their most 

elemental parts to identify the process operation by which each elemental part is made in 

terms of: 

o labor minutes 

o direct materials and scrap 

o machine occupancy hours or station times 

o machinery, equipment, and tooling utilized 

The components are laid out on a pegboard, with one-inch squares, and photographed next to 

appropriate identification labels so the photos can be compared with the cost estimates. 

• Technical Analysis. The parts from the comparable vehicle systems are analyzed (in 

some contractor reports) to determine: 

o changes between the pre- and post-standard make-models 

o reasons for the changes, i.e., differentiate between changes for meeting the 

FMVSS and changes for unrelated reasons such as: 

♣ styling 

♣ cost reduction 

♣ product improvement (functional improvements not related to the 

requirements of the FMVSS) 

The net result of the analysis is the accurate and complete identification of all changes in the 

component parts of the selected systems that are attributable to the requirements of the

specified FMVSS. 

• Cost Analysis. Costs are determined by production decisions, whereas, prices are the 

results of marketing decisions based on an assessment of what the traffic will bear when 

faced with a competitive environment of substitutes. To arrive at a price that will “pass 

in the trade”, the vehicle manufacturer engages in a form of cost/price arbitrage across his 

entire model lineup. At the low end of the pricing scale, competition from other 

manufacturers may prevent a company from charging a price sufficient to cover the full 

cost of producing a vehicle line at planned volumes. However, the company can cover 

this shortfall in other market segments where competition is less intense by charging 

prices that, on a volume basis, generate sufficient margins to cover the full costs of a 

4
vehicle line plus a contribution to overall corporate overhead and profit that offsets the 

shortfall. 

In developing cost estimates for proposed and existing safety standards, all components 

identified in the technical analysis that changed because of the implementation of the 

FMVSS are cost analyzed to determine their consumer price. The cost comparison is 

performed in two stages. The first (micro-analysis) considers the elements of cost that 

vary from one part to another, and the second (macro-analysis) considers those elements 

of cost that do not vary. 

o Micro-analysis. The micro-analysis consists of the teardown process itself and 

the identification of the following costs for each elemental part where applicable: 

♣ Variable Manufacturing Costs 

• Direct material cost is estimated by judging the weight of the 

component in the rough state and multiplying that weight by its 

cost per pound factor appropriate to the material, gauge, grade, etc. 

• Direct labor costs are determined by time and motion analysis of 

each labor input per cycle or operation. Each labor input or

operation is timed in terms of labor minutes or fraction thereof. 

The hourly rate is divided by 60 minutes to obtain labor cost per 

minute. Labor cost is determined by multiplying labor minutes

(usually a fraction) by labor cost per minute 

• Variable manufacturing burden. This accounting classification 

includes all costs that vary directly with production volume but 

cannot be specifically attached to each unit of end product. 

Examples would include electric power, indirect labor such as 

materials handling, and perishable tools. 

♣ Fixed Burden (Fixed Factory Overhead) 

• Depreciation per Unit (Allocated) 

• Amortization of Special Tooling per Unit (Allocated) 

Using prevailing labor and material costs, the variable manufacturing costs and 

total manufacturing costs for each elemental part, component, subassembly, and 

complete assemblies that constitute each system under study are determined. 

Specific cost elements that must be isolated and identified include the following: 

5
♣ direct labor dollars per unit 

♣ direct material costs and scrap allowances per unit 

♣ variable burden cost per unit, including indirect labor and other costs that 

vary with production volume

♣ fixed burden per unit 

♣ capital investments required at prevailing annual sales volumes – property, 

plant, equipment, and tooling 

♣ depreciation schedules for property, plant, and equipment 

♣ amortization schedules for special tooling 

Cost estimation is performed using operation worksheets, which identify raw 

materials, labor, and machine utilization for each operation of the manufacturing 

process. The worksheets are used to record the component, subassembly, and 

assembly processing methods. A worksheet is prepared for each part and 

subassembly. The following items of information are collected on each operation 

worksheet: 

♣ identifying numbers 

♣ material type, gauge, quality, blank size 

♣ finished weight 

♣ rough weight 

♣ percent scrap 

♣ production volume

♣ tooling cost and amortization 

♣ number of parts per safety system

♣ operations 

♣ type of equipment pieces per hour 

♣ number of machines 

♣ made in-house or purchased 

The manufacturing operations are determined, their operation numbers are listed, 

and the operations described on the worksheet. Various equipment stations in the 

manufacturing plan are associated with each operation. Their codes are listed, as 

well as the pieces per hour, for the equipment. Next the estimator must determine 

the number of machines required for the operation. There is an interaction 

between the number of people and the number of machines a person can operate. 

To determine the labor per part requires estimating this interaction. In addition to 

estimating the cost of individual parts, the cost of assembling parts into 

subassemblies and assemblies, where appropriate, is developed by determining 

the operations necessary to achieve the assemblies. The variable cost includes 

only those costs associated with the manufacture of the part or assembly, i.e., 

direct labor and direct material costs associated with making the part or assembly. 

Also included in the variable cost is the variable burden, which includes such 

things as set-up costs, inbound freight, perishable production tools, and other 

miscellaneous costs that vary with production volume changes. 

6
o Macro-analysis. The macro-analysis develops the pricing template used to derive 

the estimated retail price impact of safety requirements imposed by NHTSA. The 

teardown process described above does not isolate all of the elements that must be 

accounted for in order to arrive at a price that covers full cost plus profit margin. 

Discretionary costs such as Selling, General, and Administration; Research and 

Development; Taxes Other Than Income; Pension Expense; and Plant 

Maintenance and Repair must be allocated to each unit of product. Furthermore, 

after covering Discretionary Costs, there should be sufficient residual for Income

Taxes and a bottom line Net Profit.4

Accounting Basis for the Macro-Analysis5

Over the last 30 years, NHTSA has developed and refined a technique for approximating the 

pricing structure of automotive manufacturers. This technique involves the derivation of markup 

factors from financial analysis of company income statements and consists of isolating the major 

corporate cost and expense accounts and rearranging them according to a template that reflects 

cost behavior rather than Generally Accepted Accounting Principles (GAAP). Under the 

behavioral approach, costs and expenses are defined as variable, fixed, or discretionary. 

Variable costs (or variable manufacturing costs) are defined as costs that are constant per unit of 

input but vary 6directly in total with changes in production volume. Direct labor, direct material, 

and variable burden all fit this definition. Fixed costs are constant in total regardless of volume. 

The only true fixed costs are depreciation and amortization. Most factory and corporate 

overhead accounts costs have a fixed component and a variable component that can increase or 

decrease at management’s discretion—hence the name discretionary costs. 

Variable manufacturing costs are engineered into the production process and cannot be changed 

to an appreciable degree on a per unit basis at planned production volumes. On the other hand, 

fixed costs and discretionary costs can be allocated on a per unit basis according to a rationale of 

management’s choosing. It is this allocation process that establishes the pricing structure of the 

company. In order to approximate this allocation process, variable costs must be isolated to the 

degree possible from fixed and discretionary costs. 

Income statements prepared according to GAAP do not segregate cost and expense accounts 

based on behavior. The “Cost of Sales” account, for example, includes both variable and 

discretionary costs. In order to approximate the cost/price arbitrage process, the variable 

manufacturing costs must be segregated from fixed and discretionary costs. Through analysis of 

Form 10-K Corporate Annual Reports filed annually with the Securities Exchange Commission 

by domestic manufacturers, NHTSA has isolated three discretionary cost accounts to be 

subtracted from “Costs of Sales”: 

 4

 Spinney, B.C., Development of Markup Rates for Regulatory Cost Analysis that Approximate Industry Pricing 

Practices, Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration 

Internal Document, February 1989, 1-2. 5 Ibid. 

7
• Maintenance and Repairs 

• Research and Development 

• Taxes Other Than Income 

Upon subtraction, the three accounts are reclassified under the general head of 

Fixed/Discretionary Costs. The remainder of “Costs of Sales” constitutes estimated Variable 

Manufacturing Costs. 

Each manufacturer’s income statement is reformatted according to this methodology and the 

process is called common sizing. The result is a template that enables the analyst to study a 

company’s cost structure and compare it against competitors. The completed template is shown 

below: 

SAMPLE COST/PRICE CORPORATE TEMPLATE 

(Manufacturing Operations Exclusive of Financing Subsidiaries) 

Net Sales $100,000,000 100.0%

Variable Manufacturing Costs 74,000,000 74.0%

Contribution Margin $ 26,000,000 26.0%

Fixed/Discretionary Costs:

Maintenance and Repairs $ 3,500,000 3.5%

Research and Development 3,000,000 3.0%

Taxes other than Income 2,000,000 2.0%

Selling, General, & Administration 7,000,000 7.0%

Pension Costs 2,000,000 2.0%

Depreciation 3,500,000 3.5%

Amortization of Special Tooling 2,500,000 2.5%

Amortization of Intangibles 500,000 0.5%

Total Fixed/Discretionary Costs $ 24,000.000 24.0%

Income from Continuing Operations $ 2,000,000 2.0%

Other Income (Expense)-Net 1,000,000 1.0%

Income before Interest and Taxes $ 3,000.000 3.0%

Interest Income (Expense)-Net (500,000) 0.5%

Income before Income Taxes $ 2,500,000 2.5%

Income Tax Expense (Credit) 875,000 0.9%

Net Income $ 1,625,000 1.6%

(Note: The dollar amounts are hypothetical, however, the percentages of sales for each account reflect long-run

weighted averages of the “Big Three”) 

The key to NHTSA’s pricing template lies in the relationship between net sales, variable costs, 

and contribution margin. Net sales represents total wholesale revenue less returns and 

allowances. Variable costs have been defined above and account for 74% of net sales. The 

8
contribution margin rate of 26% on sales represents the remainder left for fixed/discretionary 

cost coverage. Since the template reflects company-wide operations, by definition it reflects the 

fixed/discretionary cost/price recovery arbitrage process across all product lines whereby a 

manufacturer meets its profit objectives at expected volumes. 

Thus, the pricing formula used by NHTSA to approximate wholesale price for a new safety 

feature only includes variable costs, which are determined by detailed analysis of the production 

process, and a markup percentage on variable costs equal to the corporate wide contribution 

margin rate. If variable costs account for 74% of sales and contribution margin accounts for 

26%, then the markup rate on variable costs to wholesale price would be 35% (26% / 74%). The 

markup factor would be 1.35. 

To arrive at MSRP, wholesale price needs to be marked up to cover the dealer margin. 

Currently, dealer margin is about 11% on wholesale on a fleet-wide weighted average basis. The 

completed pricing formula is: 

Variable costs * 1.35 * 1.11 OR Variable costs * 1.50 

 

Inconsistencies and Variations in Contractors’ Approaches to Estimating the Cost and Weight 

of a FMVSS

• Selection of Vehicles/Definition of “Effect of the FMVSS” 

o The contractor tore down pre-, as well as, post-standard vehicles. Costs attributed 

to the standard are allocated based on the following criteria: 

♣ Without further analysis, the contractor attributed the entire difference in 

the cost and weight of the pre- and post-standard subsystems to the 

standard. For example, with FMVSS 216, some motor vehicles were 

redesigned in the year the standard took effect. The cost of styling-related 

changes was included in the cost of the standard. 

♣ Only part of the difference is attributed to the standard, while the rest of 

the difference is attributed to styling, product improvement, or other 

factors unrelated to the FMVSS. For example, with FMVSS 201, a 

comparison of various interior structures in pre- and post-standard 

passenger cars indicated that costs in some structures might be 

consistently higher for the post-standard specimens, which probably 

indicates they were modified because of the standard. However, costs in 

other structures went up in some specimens and down in others, which 

indicates the modifications were merely for styling or production efficient 

and not needed for meeting the standard. 

o The contractor only performed the physical teardown of post-standard vehicles’ 

subsystems believed to be affected by a FMVSS. This approach works best for a 

standard that added on an entire subsystem, with no other change in pre-existing 

9
equipment on other subsystems. However, contractors have also used this 

approach on other occasions, such as when contract funding was insufficient to 

study pre-standard vehicles. Costs attributed to the standard are allocated based 

on the criteria listed below: 

♣ The full cost of the new equipment is attributed to the FMVSS, because 

the cost in the pre-standard vehicle is zero. For example, with FMVSS 

108, center high mounted stop lamps were added as standard equipment in 

model year 1986 to reduce rear-impact crashes, but did not result in 

changes to any other rear lighting system. 

♣ The contractor does not attribute the full cost of the equipment to the 

FMVSS, because the contractor asserts or assumes that some of this 

equipment either already existed in the pre-standard vehicle (although no 

such vehicles were torn down) or was not added because of the FMVSS, 

but for some other reason. For example, with the FMVSS 214 upgrade 

dynamic test requirement, some of the components partially contributed to 

both pre- and post-revision requirements of FMVSS 214. The contractor 

used engineering evaluation and judgment to assign a percentage of the 

identified costs as a contribution towards the additional requirements 

imposed by the revised standard. 

♣ The contractor limited the teardowns to post-standard vehicles, even 

though the equipment was not strictly an add-on, and did not even discuss 

what parts were there before the standard was implemented, or if the new 

equipment was safety related. For example, with FMVSS 201, a study of 

the interior components of 1982 model year trucks was conducted to 

determine the impact of the standard on light trucks. No pre-standard 

make-models were studied to serve as a baseline. Since some of the 

make-models were extensively redesigned in 1982, the contractor was 

unable to directly compare the components of the pre- and post-standard 

light trucks and did not estimate the average cost increase. 

 

• Teardown Sample Selection. Some contractors selected a sample of motor vehicles too 

small to make a meaningful sales-weighted average. To calculate a sales-weighted 

average, six or more vehicles should be in the sample selection; otherwise, an arithmetic 

average will be calculated on five vehicles or less. In addition, even a larger sample size 

can be too small if it does not adequately represent a cross-section of vehicle sizes, body 

styles, and manufacturers. For example, with FMVSS 214, an analysis of the impact of 

the dynamic requirements on two-door passenger cars was conducted on only two import 

cars representing the compact and midsize categories. 

• Inconsistency in Vehicle Sales Data. Contractors sales-weighted their data using 

calendar year production, calendar-year sales, or model-year registrations. 

10
• Averaging the Costs Across Make-Models. Contractors sometimes computed salesweighted averages of the costs of the make-models they tore down in order to produce a 

single estimate of the cost of the FMVSS. Sales data by make-model were obtained from

various sources, and “makes-models” sometimes, but not always, included vehicles of 

similar design but with different names (e.g., Ford Taurus and Mercury Sable). In some

cases, these sales-weighted averages were based on too few models (e.g., two or three) to 

be statistically meaningful. 

• Follow-Up Cost Studies. NHTSA sometimes awarded follow-up contracts to determine 

if the cost of safety equipment had changed after a number of model years due to factors 

such as: more efficient design, vehicle downsizing, availability of new materials. These 

analyses were limited to teardowns of the recent model year vehicles, and did not include 

teardowns of pre-standard vehicles for comparison purposes. 

• Definition of Pre- and Post-FMVSS. Some contractor reports used the model year 

immediately before the FMVSS as the “pre-standard” model year. Their rationale was 

that if manufacturers complied with the standard in that year, their modifications were 

“voluntary” and should not be attributed to the standard. Other contractors used a model 

year several years before the standard as the “pre-standard” model year. 

• Different Economic Years. All estimated costs were based on specific U.S. model 

production year economics that, of course, depended on when the contractor did the 

study. 

Methods Used in This Report to Make the Estimates More Uniform

• Criteria for Averaging Costs Across the Make-Models in the Teardown Sample

o If the teardown sample is reasonably large (six or more vehicles) and reasonably 

representative of the vehicles on the road, we will use only sales-weighted

averaging. Otherwise, we will take a simple arithmetic average of the costs in the 

teardown sample. 

o A sales-weighted average for the cost and weight figures of the make-models 

studied is calculated to provide a more accurate representation of the average 

price differentials. This is accomplished by multiplying the cost and weight 

figures of each make-model by a “weight” relevant to its importance, adding the 

results, and dividing the total by the sum of the weights. The “weight” in this 

instance is the volume figures based on the new passenger vehicle registrations 

for each make-model studied. The volume figures for the 1965-1974 model years 

were obtained from Ward’s Automotive Yearbook7

 and the volume figures for the 

1975 model year on up were obtained from the R.L. Polk National Vehicle 

Population Profile.8

 

 7 Ward’s Automotive Yearbook, Annual Publication, Detroit: Ward’s Communications. 8 National Vehicle Population Profile, Annual Publication, Detroit: R.L. Polk & Company. 

11
o If we can reasonably expect the same type of equipment in two make-models of 

similar design with different names (e.g., Ford Taurus and Mercury Sable), we 

will do sales-weighted averaging by fundamental car groups. This method was 

used for the FMVSS 214 side door beams. 

Fundamental car/truck groups are composed of passenger vehicles that have the 

same automotive manufacturer, belong to the same functional class, and have the 

same wheelbase. NHTSA staff has defined the fundamental car/truck groups, and 

have used these classifications in several evaluation reports. The criterion to use 

the fundamental car/truck group for the volume figures is based on the premise 

that the make-models from the same manufacturer utilize common structure and 

mechanisms for all make-models sharing a common body size. However, these 

vehicles are not necessarily “identical” except for the nameplate and may vary to 

some extent in weight or appearance. 

o If the equipment, however, might not be the same because it is tied into the 

appearance of the vehicle or for others reasons (consumer preference, vehicle 

manufacturer design choices), we will sales-weight by sales for the specific makemodel in the tear down sample. For example, with FMVSS 202, vehicle 

manufacturers installed adjustable or nonadjustable (integral or fixed) head 

restraints in response to the standard. 

o If the contractor has looked at a number of pre- and post-standard vehicles, we 

will take a sales-weighted average of only the make-models where there are 

matching pre- and post-standard vehicles. We will then weight the difference 

between the pre- and post-standard costs in each of these matched pairs by the 

sales of the post-standard vehicles. If we can’t do all of this, we will just take the 

simple arithmetic averages, otherwise we run the risk of getting spurious costs 

due to shifts in the sales mix. 

o In general, if the contractor has looked at pre- and post-standard vehicles, we will 

take the incremental cost difference between the two. However, there are certain 

cases where this gives too low an estimate, because even the equipment in the 

“pre-standard” vehicle was added after the rulemaking process began. In those 

cases, we will use the full cost of the equipment in the post-standard vehicles like 

we did for FMVSS 214 side door beams in light trucks. 

• FMVSS Modifications vs. Redesigns Unrelated to FMVSS 

o If the contractor has attributed to the FMVSS costs that are plainly due to other 

redesign reasons, we will deduct those costs if that is simple to do. For example, 

with FMVSS 214, changes in the body pillars of 1973 make-model passenger cars 

were a result of model redesign and not directly related to the standard; therefore, 

the weight and consumer cost for them were not included in the side door strength 

calculations.

12
o If there is no simple way to do it, we may limit ourselves to the make-models in 

the contractor’s sample that we know were not redesigned in the year the FMVSS 

went into effect. For example, by singling out only the pre- and post-standard 

FMVSS 216 make-models that did not receive any overall redesign, it is plausible 

that any changes were specifically due to standard. 

• Linear Interpolation When Costs Change Over Time. If we have two cost estimates for 

the standard, i.e., $20 in 1980 and $10 in 1990; and, unless we have additional 

information that pinpoints the time of the cost reduction, we will assume a standard cost 

of $20 each year until 1980, a declining linear rate (in this case, $1 per year) from 1980 to 

1990, and then a cost of $10 each year from 1990 onward. 

• Adjusting for Inflation: The labor and material rates used by contractors to estimate the 

costs were compiled from publicly available sources such as the U.S. Department of 

Labor, Bureau of Labor (under Employment, Hours, and Earning), and from union 

contracts. Material costs were determined from the contemporary market price for the 

appropriate material. These costs are based on U.S. automotive (Detroit, Michigan area) 

manufacturing practices, labor rates, material costs, and tooling/equipment costs. This 

information is publicly available in the Commodity Research Bureau (CRB) 

Commodities Yearbook as well as automotive union contracts. The labor and material 

rates were updated periodically, and each cost study was based on a given economic year. 

In this report, all cost data have been inflated to 2002 dollars. Even though a particular 

standard may have been studied in an earlier economic year, using the gross domestic 

product implicit price deflator adjustments can bring the original cost data to 2002 

economics. For example, the first study done for Planning, Evaluation, and Budget was 

in 1978 economics. The implicit price deflator for 1978 is 45.757 and 103.945 for 2002. 

To bring the 1978 data to 2002 economics, the original cost estimates are multiplied by 

the factor of 103.945/45.757 (the ratio of the implicit price deflator for 2002 relative to 

that of 1978).9

 The indexes for 1976-2002 are listed on the next page: 

 9

 Bureau of Economic Analysis [online]; available from http://www.bea.doc.gov/bea/dn/nipaweb/AllTables.asp. 

. 

13
 

GROSS DOMESTIC PRODUCT

IMPLICIT PRICE DEFLATOR 

(2000 BASE)

YEAR PRICE DEFLATOR

1976 40.196

1977 42.752

1978 45.757

1979 49.548

1980 54.043

1981 59.119

1982 62.726

1983 65.207

1984 67.655

1985 69.713

1986 71.250

1987 73.196

1988 75.694

1989 78.556

1990 81.590

1991 84.444

1992 86.385

1993 88.381

1994 90.259

1995 92.106

1996 93.852

1997 95.414

1998 96.472

1999 97.868

2000 100.000 

2001 102.373 

2002 103.945 

14
SECTION 2 - FMVSS 100 SERIES 

The FMVSS 100 series specify design and/or performance requirements for vehicles and vehicle 

subsystems that pertain to crash avoidance. The design-based standards require the presence of 

certain vehicle subsystems, specify design characteristics (size, shape, color, etc.), and describe 

how particular subsystems are to function. Thereby, they provide a large degree of uniformity in 

the operation of all make-models of vehicles. The performance-based standards outline specific 

capabilities that a vehicle or vehicle subsystem must demonstrate when actively tested. Several 

of the FMVSS 100 series contain a set of both design-based and performance-based criteria. 

FMVSS 101 - CONTROLS AND DISPLAYS

FMVSS 101 became effective on January 1, 1968 and specifies requirements for the location, 

identification, and illumination of motor vehicle hand-operated controls (steering wheel, horn, 

ignition, etc.), foot-operated controls (service brake, accelerator, clutch, etc.), and displays 

(speedometer, turn signal, gear position indicator, etc.). The purpose of this standard is to ensure 

the accessibility and visibility of motor vehicle controls and displays and to facilitate their 

selection under daylight and nighttime conditions. The intent of the standard is to reduce the 

safety hazards caused by the diversion of the driver’s attention from the driving task and by 

mistakes in selecting controls. Furthermore, drivers can more easily operate an unfamiliar 

vehicle if the controls and displays are in uniform locations with uniform labels. This standard 

applies to passenger cars, multipurpose passenger vehicles, trucks, and buses.10

Most motor vehicles had some form of controls and displays prior to the standard. The 

requirements resulted in simply relocating and changing the visual appearance of the display. 

While there may have been a one-time cost in some cases, there is little long-term cost associated 

with complying with the standard. No cost studies have been performed, and none are planned 

by the agency. 

FMVSS 102 - TRANSMISSION SHIFT LEVER SEQUENCE, STARTER INTERLOCK, 

AND TRANSMISSION BRAKING EFFECT

FMVSS 102 became effective on January 1, 1968 and specifies the requirements for the 

transmission shift lever sequence, a starter interlock, and a braking effect of automatic 

transmissions. The purpose of this standard is to prevent shifting errors in unfamiliar vehicles, or 

when drivers change from one vehicle to another. It requires a starter interlock to prevent drivers 

from engaging the starter with the vehicle in a driving gear. It also requires automatic 

transmissions to have a low gear selection to provide a supplemental braking effect at speeds 

below 25 miles per hour. For vehicles equipped with manual transmissions, the standard 

requires a display of the shift pattern that is in the driver’s field of view. This standard applies to 

passenger cars, multipurpose passenger vehicles, trucks, and buses.11 

 10 Legal citation: 49 (CFR) 571.101 (2004). 11 Legal citation: 49 CFR 571.102 (2004). 

15
The standard requires that all shift levers for automatic transmissions have the same clockwise 

sequence: park, reverse, neutral, drive, and low gear(s). This will reduce the likelihood of

shifting errors when drivers change from one vehicle to another. Effective September 23, 1991 

the identification of shift lever positions shall be displayed in view of the driver in a single 

location. Identification of the shift lever pattern for manual transmissions shall be displayed in 

view of the driver at all times when a driver is present in the driver’s seating position. Vehicles 

with a 3-speed manual transmission that has the standard “H” pattern shift sequence are not 

required to have a shift pattern display. 

While there may have been a one-time cost in some cases, there is little long-term cost associated 

with complying with the standard. No cost studies have been performed, and none are planned 

by the agency. 

FMVSS 103 - WINDSHIELD DEFROSTING AND DEFOGGING SYSTEMS

FMVSS 103 became effective on January 1, 1968 and specifies requirements for windshield 

defrosting and defogging systems. The purpose of this standard is to establish minimum

capability for all vehicles to assure that windshields will remain clear under conditions in which 

moisture could adhere to the inside or outside of the windshield. It is based on passenger cars 

meeting the requirements of the Society of Automotive Engineers (SAE) recommended practices 

established in 1964. The other vehicle classes under this standard are required to have 

windshield defrosting and defogging systems; however, no performance requirements are 

specified. The defrosting and defogging system includes the necessary ducts, baffles, cables, 

levers, and grilles to direct heated or dehumidified air onto the windshield. This standard applies 

to passenger cars, multipurpose passenger vehicles, trucks, and buses.12

A study of seven pre-standard make-model passenger cars, and their corresponding post-standard 

systems, revealed minimal design changes resulting in a reduction of average weight and a slight 

increase of average consumer cost. However, NHTSA has no evidence that these changes were 

specifically made to meet performance requirements in the standard.13 Table 103-1 shows the 

sales-weighted average for the weight and consumer cost of windshield defrosting and 

defogging systems in pre- and post-standard passenger cars. 

TABLE 103-1 

AVERAGE WEIGHT AND CONSUMER COST 

OF WINDSHIELD DEFROSTING AND DEFOGGING SYSTEMS 

IN PASSENGER CARS

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

1965 (Pre-Standard) 1.23 $9.01 

1969 (Post-Standard) 1.01 $9.75 

 12 Legal citation: 49 CFR 571.103 (2004). 13 Gilmour, J.L., Consumer Cost Evaluation of Federal Motor Vehicle Safety Standards – FMVSS 103 and 104,

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, June 1982. (DOT

HS 806 205:21-81). 

16
A study of seven 1969 make-model light trucks indicated that the sales-weighted average weight 

and consumer cost of the defrosting and defogging systems was 3.05 pounds and $10.01 in 2002 

dollars.14 Although not studied, earlier model light trucks were also equipped with these 

systems. 

Since every passenger vehicle that came under the standard was equipped with a windshield 

defrosting and defogging system before the standard went into effect and NHTSA has no 

evidence that the minimal design changes between 1965 and 1969 were made to meet the 

performance tests of the standard, any changes in the weight and consumer cost are not attributed 

to FMVSS 103. 

 

FMVSS 104 - WINDSHIELD WIPING AND WASHING SYSTEMS 

FMVSS 104 became effective on January 1, 1968 and specifies requirements for windshield 

wiping and washing systems. The standard requires that each vehicle have a power-driven 

windshield wiping system with two speeds, with the speed of the wiping system independent of 

the vehicle engine speed and engine load. It essentially mandated electric-powered wiper motors 

and precluded the early design of wiper systems that were driven by the vehicle’s engine 

vacuum. In addition, each vehicle shall have a windshield washing system that meets the 

requirements based on SAE recommended practices established in 1965. This standard applies 

to passenger cars, multipurpose passenger vehicles, trucks, and buses.15

Passenger Car Studies 

When FMVSS 104 was issued, all passenger cars were equipped with both windshield wiping 

and washing systems. After studying seven pre-standard 1965 make-model passenger cars, the 

contractor concluded that the vehicles already complied with the standard.16 Since every 

passenger car that came under the standard was equipped with a windshield defrosting and 

defogging system before the standard went into effect, their weight and consumer cost are not 

attributed to FMVSS 104. 

 

Light Truck Studies 

Seven 1969 make-model light trucks were also studied.17 The windshield wiping and washing 

systems, which were not on pre-standard light trucks, were analyzed. The cost of implementing 

the windshield wiper requirements was determined by comparing the single and multi-speed 

motors, an additional wire from the switch to the motor, and a switch that was changed from two 

positions to three positions. In the case of the variable speed motors, a variable switch was 

substituted for the two-position switch. Table 104-1 shows the sales-weighted average weight 

 14 Gladstone, R., Harvey, M.R., and Lesczhik, J.A., Estimation of Weight and Consumer Price Relating to the 

Implementation of FMVSS 201 in Passenger Cars and FMVSS 103 and 104 in Light Trucks, Washington: U.S.

Department of Transportation, National Highway Traffic Safety Administration, November 1982. (DOT HS 806

367:2-1 thru 2-6). 15 Legal citation: 49 CFR 571.104 (2004). 16 Gilmour, DOT HS 806 205:82-144 (1982). 17 Gladstone, DOT HS 806 367:3-1 thru 3-23 (1982).

17
and consumer cost of each system, with the difference being the cost of implementing the 

windshield wiper requirements. 

FMVSS 104-1 

AVERAGE WEIGHT AND CONSUMER COST 

OF WINDSHIELD WIPER SYSTEMS IN LIGHT TRUCKS 

MOTOR TYPE WEIGHT IN POUNDS CONSUMER COST ($2002) 

Single Speed 2.23 $19.41

Multi-Speed 2.72 $23.43

DIFFERENCE 0.49 $ 4.02

For the washing systems analysis, the baseline was established as a vehicle without the system, 

with the components (reservoir, pump, hoses, switch and knob assembly) for the washing system 

directly related to the implementation of the standard. The sales-weighted average weight and 

consumer cost was 1.61 pounds and $11.03 in 2002 dollars. 

Implementation of the windshield wiper and washer requirements of FMVSS 104 increased the 

average weight and consumer cost per vehicle. Table 104-2 shows the total weight and 

consumer cost attributable to FMVSS 104 in light trucks. 

FMVSS 104-2 

AVERAGE WEIGHT AND CONSUMER COST 

OF WINDSHIELD WIPING AND WASHING SYSTEMS 

ATTRIBUTABLE TO FMVSS 104 IN LIGHT TRUCKS

SYSTEM WEIGHT IN POUNDS CONSUMER COST ($2002) 

Windshield Wiping 0.49 $ 4.02

Windshield Washing 1.61 $11.03

TOTAL 2.10 $15.05

 

FMVSS 105 - HYDRAULIC AND ELECTRIC BRAKE SYSTEMS 

FMVSS 105 became effective on January 1, 1968 and specifies requirements for vehicles 

equipped with hydraulic and electric service brake systems, and associated parking brake 

systems. The purpose of this standard is to ensure safe braking performance under normal and 

emergency conditions. This standard applies to: 

 

• hydraulically-braked passenger cars manufactured before September 1, 2000 

• hydraulically-braked multipurpose passenger vehicles, trucks, and buses with a Gross

Vehicle Weight Rating (GVWR) of 7,716 pounds or less that were manufactured before

September 1, 2002 

• hydraulically-braked vehicles with a GVWR greater than 7,716 pounds18

All hydraulically-braked passenger cars manufactured after September 1, 2000 and 

hydraulically- braked multipurpose passenger vehicles, trucks, and buses with a GVWR of 7,716 

pounds or less that were manufactured after September 1, 2002 are part of FMVSS 135 

(Passenger Car Brake Systems). 

 18 Legal citation: 49 CFR 571.105 (2004). 

18
Passenger Car Studies 

Brake System Components 

The brake system components specifically required by FMVSS 105 are a dual or split hydraulic 

service brake system, parking brake system, and brake system indicator lamp. Particular design 

characteristics of these components are also governed by this standard. The performance 

requirements for brake systems consist of a series of stopping tests simulating normal and 

emergency braking, fade and recovery, water recovery, and partial system failure. 

The most important indication of brake performance is the distance in which a brake system can 

stop a vehicle from a given speed. The performance requirements for the service brake system

are expressed in terms of stopping distance and/or deceleration rates from specific vehicle speeds 

using a specific range of brake pedal apply forces by the vehicle driver. Brake pedal apply force 

is measured in pounds per foot and is an indication of how hard the vehicle driver’s leg pushes 

against the brake pedal. 

Fade and recovery requirements are also included in the standard to assure that a vehicle’s 

braking performance is satisfactory when exposed to the high brake temperatures caused by 

prolonged or severe use or during the time that the brakes are cooling off after severe use. Fade 

is the inability of friction material to maintain its normal effectiveness when it is forced to work 

at elevated temperatures. Recovery is the rate at which the lining returns to its original friction 

level after having been exposed to a fade condition. Light fade occurs in vehicles even in low 

speed applications such as in heavy traffic. Moderate to severe fade is a condition that may 

occur when vehicles are used on hilly or mountainous roads, especially when heavy loads are 

carried. In addition, water recovery requirements are included in the standard to assure that a 

vehicle’s braking system performs adequately after immersion in water. Finally, partial system

failure requirements are included to ensure that a vehicle’s brakes are capable of bringing the 

vehicle to a controlled stop in a reasonable distance if a part of the service brake system should 

fail. 

Each vehicle shall be capable of completing all performance requirements without: 

• detachment or fracture of any component of the braking system 

• any visible brake fluid or lubricant on the friction surface of the brake or leakage at the 

master cylinder or brake power unit reservoir cover, seal, and filler openings 

FMVSS 105, effective in January 1968, represented the initial Federal effort to specify braking 

requirements for motor vehicles and required that passenger cars be equipped with a split service 

brake system and have stopping ability based upon deceleration rates specified in the SAE 

Recommended Practice J937, June 1966. Requirements for fade and recovery, water recovery, 

and stability while braking were also included in this standard. These requirements did not 

represent the full capabilities of modern braking technology; therefore, a new standard (105a) 

was established in September 1972 specifying requirements for motor vehicle hydraulic brake 

systems and parking brake systems. Manufacturers had extensive advance knowledge of the 

upgrade because a Notice of Proposed Rulemaking (NPRM) was issued as early as November 

1970. FMVSS 105a was redesignated to 105-75 in February 1974, and with only minor changes 

in the portion applicable to passenger cars, evolved into the January 1976 requirements. 

19
The principal difference between the 1968 and 1976 standards is that the new regulation 

specifies the straight-line stopping distances within which a car must stop under good conditions. 

The older rule merely specified the deceleration rate a car had to attain at some point during 

braking. Moreover, the stopping distances were set at a level that only half of the 1972 models 

appeared to be capable of meeting, according to consumer information data submitted to NHTSA 

by the manufacturers. In other words, it was felt that the new regulation would significantly 

improve stopping distances over 1972 levels in a large portion of the vehicle fleet. The new 

regulation requires more stringent partial failure, fade recovery, and water recovery tests than the 

older rule. In addition, the following requirements for improved handling and stability are added: 

• wheel lockup is permitted at a speed below 10 miles per hour

• lockup of only one wheel, not controlled by an antilock system, is permissible at speeds 

in excess of 10 miles per hour 

It is difficult to determine what costs should be attributed to FMVSS 105 because changes in 

vehicle size, customer preferences, and development of superior materials and designs have all 

enhanced or changed braking performance, cost, and weight over the years. The four major 

changes to the braking systems that have occurred during 1965-2001 are dual master cylinders, 

front disc brakes, brake power assist units, and antilock brake systems (ABS). Only the cost of

dual master cylinders is unequivocally attributable to FMVSS 105. 

Table 105-1 shows the percentage of domestic cars with these technologies for selected model 

years. 

 

TABLE 105–1 

PERCENT OF DOMESTIC CARS WITH DUAL MASTER CYLINDERS, 

FRONT DISC BRAKES, POWER BRAKES, AND ABS BY MODEL YEAR

PERCENT OF DOMESTIC CARS 

MODEL 

YEAR 

DUAL MASTER 

 CYLINDERS 

FRONT DISC

BRAKES 

POWER 

BRAKES ABS 

1960 0 0 26 0 

1962 9 0 26 0 

1964 7 0 29 0 

1966 unknown 3 35 0

1967 100 6 41 0 

1968 100 13 unknown 0

1970 100 41 unknown 0

1972 100 74 68 0

1974 100 84 67 0

1976 100 99 81 0

1978 100 100 88 0 

1980 100 100 unknown 0

1982 100 100 90 0 

1984 100 100 96 0 

20
TABLE 105–1 (CONTINUED)

PERCENT OF DOMESTIC CARS WITH DUAL MASTER CYLINDERS, 

FRONT DISC BRAKES, POWER BRAKES, AND ABS BY MODEL YEAR

PERCENT OF DOMESTIC CARS 

MODEL 

YEAR 

DUAL MASTER 

CYLINDERS 

FRONT DISC

BRAKES 

POWER 

BRAKES ABS 

1986 100 100 99 1 

1988 100 100 100 3

1990 100 100 100 8

1992 100 100 100 32

1994 100 100 100 57

1996 100 100 100 58

1998 100 100 100 59

2000 100 100 100 62

2001 100 100 100 62

Dual Master Cylinders. Dual master cylinders were explicitly required by FMVSS 105 

beginning on January 1, 1968 and were already implemented in all 1967 passenger cars. Dual 

master cylinders are the chief component of a split or dual brake system. A typical passenger car 

or light truck has a friction brake at each of its four wheels. These brakes are actuated through 

hydraulic pressure provided by the master cylinder as the brake pedal is depressed. A single 

brake system provides hydraulic fluid from one reservoir source to all four wheels. A typical 

split or dual brake system has two separate hydraulic circuits with a reservoir for the front brakes 

and one for the rear brakes. There are other dual braking systems that use a diagonal 

arrangement that has two circuits, each with one front wheel and one rear wheel on the opposite 

side of the vehicle. Without dual master cylinders, a failure in the brake hydraulic system can 

lead to a complete loss of braking capability. With dual brakes, however, if one of the circuits 

fails, the vehicle will retain braking capability with the other circuit. FMVSS 105 requires that 

vehicles must be able to stop within a specified distance from 60 miles per hour when one of the 

brake hydraulic circuits is disabled. Furthermore, a brake warning light is required to illuminate 

whenever there is a gross loss of hydraulic pressure in one of the circuits. 

Forty-one make-model passenger cars representing pre-standard, post-standard, and trend 

systems were studied19, along with thirteen downsized make-model passenger cars.20 Table 105-

2 shows the sales-weighted average for the weight and consumer cost of master cylinders in 

2002 dollars. 

 19 Harvey, M.R., Lesczhik, J.A., and McLean, R.F., Cost Evaluation for Nine Federal Motor Vehicle Standards, 

Volume 1, FMVSS 105, Washington: U.S. Department of Transportation, National Highway Traffic Safety

Administration, November 1979. (DOT HS 805 315). 20 Gladstone, R., et.al., Estimation of Weight and Consumer Price Relating to the Implementation of FMVSS 105,

108, 202, 205, & 216, in Passenger Cars and 201, 203, & 204 in Light Trucks, Washington: U.S. Department of 

Transportation, National Highway Traffic Safety Administration, August 1982. (DOT HS 806 769:2-1 thru 2-19). 

21
TABLE 105-2 

AVERAGE WEIGHT AND CONSUMER COST 

OF MASTER CYLINDERS IN PASSENGER CARS

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Single (Pre-Standard) 4.38 $26.53

Dual (Post-Standard) 6.12 $38.67

Dual (Trend) 7.97 $35.95

Dual (Downsized) 3.33 $34.66

Table 105-2 suggests that master cylinders decreased significantly in weight in the downsized 

passenger cars. The decrease was the result of a new, smaller cast-iron design and a new twopiece master cylinder unit with an aluminum-alloy bore and either a stamped steel or plastic 

reservoir. 

To accurately allocate the average weight and consumer cost attributable to the standard in any 

given model year, it is necessary to separate the master cylinders into three time periods. Two 

conditions exist for the calculations. First, we assume that the average weight and consumer cost 

decreased at a linear rate from 1976 to 1982 and leveled off after that. Second, it is necessary to 

calculate what the weight and cost of master cylinders would have been if they had remained 

single instead of dual (because, presumably, the weight-saving technologies described above 

could also have been applied to a single master cylinder). The weight and cost figures are 

calculated using the following formulas. 

1. Average Cost of Master Cylinders (1966-1976) = 

Cost of Post-Standard Dual Master Cylinders – Cost of Pre-Standard Single Master Cylinders 

= $38.67 - $26.53 = $12.14 

2. Average Cost of Master Cylinders (if they had remained single) = 

(Cost of Downsized Dual Master Cylinders/Cost of Post-Standard Dual Master Cylinders) * 

Cost of Pre-Standard Single Master Cylinders = ($34.66/$38.67) * $26.53 = $23.78 

3. Average Cost of Master Cylinders (1982-2002) = 

Cost of Downsized Dual Master Cylinders – Cost of Master Cylinders (if they had remained 

single) = $34.66 – $23.78 = $10.88 

4. Average Cost of Master Cylinders (CY), where 1977 < CY < 1981, = 

 

[CY –1976] * 10.88 + [1982-CY] * 12.14 

22
5. Average Weight of Master Cylinders (1966-1976) = 

Weight of Post-Standard Dual Master Cylinders – Weight of Pre-Standard Single Master 

Cylinders = 6.12 – 4.38 = 1.74 

6. Average Weight of Master Cylinders (if they had remained single) = 

(Weight of Downsized Dual Master Cylinders/Weight of Post-Standard Dual Master 

Cylinders) * Weight of Pre-Standard Single Master Cylinders = (3.33/6.12) * 4.38 = 2.38 

7. Average Weight of Master Cylinders (1982-2002) = 

Weight of Downsized Dual Master Cylinders – Weight of Master Cylinders (if they had 

remained single) = 3.33 – 2.38 = 0.95 

8. Average Weight of Master Cylinders (CY), where 1977 < CY < 1981, = 

 [CY –1976] * 0.95 + [1982-CY] * 1.74 

Table 105-3 shows the average weight and consumer cost of master cylinders attributable to 

FMVSS 105 in passenger cars by model year. 

TABLE 105-3 

AVERAGE WEIGHT AND CONSUMER COST 

OF MASTER CYLINDERS 

ATTRIBUTABLE TO FMVSS 105 

IN PASSENGER CARS BY MODEL YEAR 

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

1966-1976 1.74 $12.14

1977 1.61 $11.93

1978 1.48 $11.72

1979 1.34 $11.51

1980 1.21 $11.30

1981 1.08 $11.09

1982-2001 0.95 $10.88

Front Disc Brakes. A change in the brake systems that was encouraged, although not required 

because of FMVSS 105, was the conversion of front brakes from a drum to a disc design. Disc 

brakes require less time to recover braking ability after being partially or fully submerged in 

water, plus they dissipate heat faster and are less likely to fade after repeated applications (e.g., 

on a long downhill grade). Furthermore, consumers prefer the superior feel of the car’s braking 

power. Disc brakes experience linear relationships between brake pedal apply force and vehicle 

deceleration, without the tendency to grab like drum brakes. Manufacturers were encouraged by 

the capability of front disc brakes to meet the fade and recovery and water recovery requirements 

contained in FMVSS 105. These requirements started in 1976 about the same time as the 

automotive industry shifted to disc brakes; however, some cars continued to have drum brakes 

and still met the new requirements of FMVSS 105-75. 

23
The test for fade and recovery involved a repeated series of brake stops from a specific speed 

where the vehicle had to slow at a specific rate each time falling within minimum and maximum 

limits for brake pedal apply force. The test for water recovery ability involved driving a vehicle 

in any combination of forward and reverse directions through a trough having a water depth of 

six inches and then immediately performing a series of stops from 30 mph at a specified 

deceleration rate. 

The sales-weighted average for the weight and consumer cost of front drum brakes from a 

sample of 1966 and 1968 model year vehicles was 57.47 pounds and $162.01 in 2002 dollars. 

The front drum brake system included the brake drum, brake shoes with lining material, 

hydraulic wheel cylinder, brake adjuster, backing plate, springs, and miscellaneous hardware 

pieces. Early front disc brake systems (model year 1968 and 1976 passenger cars) weighed 

70.99 pounds and cost $147.24 in 2002 dollars. In other words, the early disc brake systems 

weighed more but cost less than drum brakes. The front disc brake system included the brake 

disc rotor, caliper, mounting bracket and bolts, backing plate, and brake pads with friction lining 

material. By 1977-1982, various cost- and weight-reducing technological improvements had 

significantly lowered the cost of disc brakes. Downsizing of the entire vehicle, resulting in 

opportunities to use less massive braking systems, also contributed to the cost and weight 

reduction for brakes. The weight dropped to an average of 50.36 pounds, while the consumer 

cost dropped to an average of $75.40 in 2002 dollars. The role of FMVSS 105 in the shift to disc 

brakes is somewhat uncertain, but is a moot point since disc brakes, in the long term, had lower 

weight and cost than drum brakes. 

Table 105-4 shows the overall weight and consumer cost of front brakes for the 1966/1968, 

1968/1976, and 1977-1982 make-models years. 

TABLE 105-4 

AVERAGE WEIGHT AND CONSUMER COST 

OF FRONT BRAKES IN PASSENGER CARS 

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Overall 

Drum (1966/68) 57.47 $162.01 

Disc (1968/76) 70.99 $147.24 

Disc (1977-1982) 50.36 $ 75.40

Power Boosters. While power boosters are not explicitly required to meet FMVSS 105, power 

brakes do help vehicles to stop quickly, especially under high speed or hazardous conditions. 

The stopping distance requirements, in conjunction with the brake pedal apply force 

requirements of FMVSS 105, encouraged manufacturers to use power boosters. It was difficult 

to stop cars within the distance and at the pedal pressure specified in FMVSS 105 unless they 

had power brakes. Furthermore, consumers like power boosters because they amplify the force 

applied by the driver to the brake pedal and allow even small drivers to achieve high levels of 

vehicle braking on all sizes of vehicles. Installation of power boosters should not be attributed to 

the standard because (1) 81% of the passenger cars already had the factory-installed power 

brakes by 1976, (2) the power brakes were clearly something the consumers wanted, and (3) 

non-power brakes continued to exist after 1976 and were meeting FMVSS 105. 

24
Table 105-5 shows the sales-weighted average weight and consumer cost of power boosters for 

the 1966, 1968, 1976, and 1977-1982 make-model passenger cars. 

TABLE 105-5 

AVERAGE WEIGHT AND CONSUMER COST 

OF POWER BOOSTERS IN PASSENGER CARS 

MODEL 

YEAR 

WEIGHT IN 

POUNDS 

CONSUMER COST ($2002) 

PER POWER BRAKE 

% OF CARS WITH 

POWER BRAKES 

CONSUMER COST

($2002) PER CAR 

1966 7.61 $45.28 35.31 $46.26

1968 9.27 $45.46 31.50 $41.89

1976 11.60 $54.78 80.90 $55.21

1977-1982 7.86 $40.17 84.24 $39.81

Total Brake System. The total brake system includes the front and rear brake assembly, master 

cylinder, foot pedal and linkage, power booster, warning light, proportional valve, and parking 

brake system. Table 105-6 shows the sales-weighted average weight and consumer cost of the 

total brake system for the 1966, 1968, 1976, and 1978-1982 make-models. Again, the 

substantial drop in the weight and consumer cost of 1977-1982 brake systems is the result of 

specific new weight- and cost-saving brake technologies as well as the downsizing of the overall 

vehicle. Except for the cost impact of dual master cylinders in 1967, there is little evidence that 

any of these major cost changes over the years are directly related to FMVSS 105 or that these 

costs would have been different in the absence of the standard. 

TABLE 105-6 

AVERAGE WEIGHT AND CONSUMER COST 

OF THE TOTAL BRAKE SYSTEM IN PASSENGER CARS

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

1966 132.60 $474.67

1968 147.33 $504.70

1976 166.69 $525.25

1977-1982 117.21 $353.24

Antilock Brake Systems 

Antilock Brake Systems (ABS) were developed by the motor vehicle industry and voluntarily 

installed by manufacturers beginning in the mid 1980's on passenger cars and light trucks. They 

have become accepted by consumers and are standard equipment in most new passenger cars and 

most light trucks. ABS was developed to prevent wheel lockup during hard braking on wet 

roads and during combination turning and braking maneuvers. When wheels lock up, the vehicle 

cannot respond correctly to steering maneuvers. When braking on low friction surfaces, standard 

brakes are not as effective in stopping the vehicle because the braking force is uniform to all 

wheels, even the ones that have little or no traction. ABS works by constantly measuring wheel 

speed; and, when it senses that a wheel is locking up, it decreases the braking force to that wheel. 

ABS also enables the driver to steer the vehicle in a controlled manner while stopping. Given 

the potential safety benefits of ABS, the Highway Safety Act of 1991 instructed NHTSA to 

contemplate requiring ABS in all passenger vehicles. NHTSA published an Advance Notice of 

Proposed Rulemaking (ANPRM) at the end of 1993. Since many of the light trucks and 

passenger cars had already been equipped with ABS, the agency and others gathered crash data 

25
and evaluated the effectiveness of ABS in light trucks and passenger cars.21,22 These studies 

concluded that ABS had mixed effectiveness results, and the agency subsequently decided not to 

go forth with rulemaking to require ABS for passenger vehicles. 

In 1991, NHTSA analyzed the cost of five different ABS systems in make-model passenger cars 

from 1988-1990.23 Table 105-7 shows the sales-weighted average weight and consumer cost of 

ABS in these five models. These are the incremental weights and costs of ABS, above and 

beyond the pre-ABS hydraulic brake system (see Table 105-6). 

TABLE 105-7 

AVERAGE WEIGHT AND CONSUMER COST 

OF ABS IN PASSENGER CARS

MODEL YEAR COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

Sensors/Rings 3.83 $ 45.46 

Control Unit 2.33 $166.62

Modulator Unit 20.81 $326.23 

Wiring Harness 3.95 $ 59.25

1988-90

Average of

five models

TOTAL 30.92 $597.56

The major ABS components shown in Table 105-7 are the wheel speed sensors and rings, the 

control unit, the modulator unit, and the wiring harness. The wheel speed sensors and rings 

provide an electrical signal to the ABS controller that is proportional to the wheel speed. The 

ABS controller is a computer that interprets and compares the signal from all the wheel speed 

sensors and sends control signals to the ABS modulator. The ABS modulator controls the 

hydraulic brake fluid pressure for each wheel. When the ABS controller interprets a signal from

a wheel speed sensor as a wheel lock-up condition, a signal is sent to the modulator to rapidly 

pulse the hydraulic pressure at that particular wheel releasing the brake until the proper wheel 

speed has been restored. The wiring harness provides electrical power to the ABS controller and 

connects the speed sensors and the modulator to the controller. 

In 1994, NHTSA looked at the ABS systems in one 1992 and one 1993 passenger car.24 Since 

the analysis was based on only two systems and passenger cars that were not the same makemodels as any in the previous study, it is difficult to draw conclusions on cost trends. A review 

of 2004 make-model passenger vehicles was conducted to determine the cost of ABS as optional 

equipment. The prices of the ABS systems ranged from $300 to $950, with an average price of 

$546. Typically in the past, the sales price of performance, convenience, or luxury optional 

equipment widely desired by consumers has been marked up 200 to 300 percent over what it 

would be if it were standard equipment (i.e., over the “consumer cost” as computed by the 

 21 Kahane, C.J., Preliminary Evaluation of the Effectiveness of Rear-Wheel Antilock Brake Systems for Light

Trucks, Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, 

December 1993. (NHTSA Docket No. 70-27-GR-026). 22 Kahane, C.J., Preliminary Evaluation of the Effectiveness of Antilock Brake Systems for Passenger Cars, 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, December 1994. 

(DOT HS 808 206). 23 Fladmark, G.L. and Khadilkar, A.V., Evaluation of Costs of Antilock Brake Systems, Volumes I and II, 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, April 1991. 

(DOT HS 809 794-795: Sections 4,6,8-10). 24 Fladmark, G.L. and Khadilkar, A.V., Cost Estimates of Head Restraints in Light Trucks/Vans (Volume I) and 

Cost Estimates of Lower Cost Antilock Brake Systems (Volume II), Washington: U.S. Department of Transportation,

National Highway Traffic Safety Administration, July 1994. (DOT HS 809 797: Sections 13,15)

26
methods of this report). If the markups for ABS are consistent with these past trends, the 

average consumer costs of ABS could range from $182 to $273 and possibly indicate that the 

actual cost of ABS has reduced substantially since 1988-1990. 

Light Truck Studies 

Brake System Components 

NHTSA extended FMVSS 105, effective in September 1983, for the 1984 model year pickup 

trucks, vans, sports utility vehicles (SUV), and other vehicle classes equipped with hydraulic 

brake systems. Essentially the same types of requirements that applied to passenger cars and 

school buses were now required for these other vehicles with hydraulic brake systems. Since 

1975 or earlier, many manufacturers had gradually improved the braking capability of some of 

their light trucks to FMVSS 105 levels. 

Dual Master Cylinders. FMVSS 105 explicitly requires a dual braking system – i.e., dual 

master cylinders – in all vehicles it regulates, including light trucks. For that reason, the cost of 

dual master cylinders in light trucks will be attributed to FMVSS 105. Even though most light 

trucks received dual master cylinders well before the September 1983 effective date, quite 

probably even as early as 1967, the regulatory process for the original FMVSS 105 was getting 

underway at that time. Since NHTSA has not performed any teardowns of truck master 

cylinders, we will assume the same cost for dual master cylinders in trucks as in passenger cars 

(although it is conceivable that truck systems could cost more to the extent that light trucks are 

usually heavier vehicles than passenger cars). Table 105-8 shows the average weight and 

consumer cost of dual master cylinders attributable to FMVSS 105 in light trucks. 

TABLE 105-8 

AVERAGE WEIGHT AND CONSUMER COST 

OF DUAL MASTER CYLINDERS 

ATTRIBUTABLE TO FMVSS 105 IN LIGHT TRUCKS

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

1982-2001 0.95 $10.88

Brake Subsystem Components. A study was conducted on eight pre-standard (1983), and their 

corresponding post-standard (1984), make-model light trucks from the three-major U.S. 

Manufacturers.25 Costs were estimated only for those subsystems of the brake systems of light 

trucks that were a new or changed design in 1984. The front brake pads, rear brake systems, 

brake power assist, emergency brake warning switch, and variable proportioning valve 

subsystems of Dodge, Ford, and GM trucks were studied. 

The front brake pads and rear brake shoes on the pre-standard and post-standard light truck 

make-models were compared. The major change was in the brake pad, shoe lining material, and 

size. Pre-standard pads or linings were often made from asbestos-based or inorganic materials; 

whereas, post-standard pads or linings are made of non-asbestos or semi-metallic materials. The 

 25 Adams, G.J., Carlson, L.E., and Firth, B.W., Cost Evaluation of Federal Motor Vehicle Safety Standard 105-

83, Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, August 1985. 

(DOT HS 807 016). 

27
elimination of the asbestos-based materials in the post-standard pads or linings was a result of 

the health hazards associated with its use in the manufacture of friction brake lining material and 

the maintenance of the brake systems. It was not a requirement of FMVSS 105. The semimetallic materials were used to improve brake system fade performance and durability 

characteristics. 

Power-booster units became standard in most trucks in 1984 at the latest, largely in response to 

consumer demand, but conceivably also to meet stopping distance requirements of FMVSS 105 

within the allowable pedal pressures. An emergency brake warning switch was added to the 

Ford trucks in order to comply with the brake system indicator lamp requirements. Vehicle 

height-sensitive variable rate proportioning valves were employed on the rear brakes to perhaps 

improve stopping distance performance when the light trucks were tested in a lightly loaded 

condition. 

 

Table 105-9 shows the sales-weighted average weight and consumer cost of front brake pads, 

rear brakes, rear shoes, proportioning valves, and emergency brake warning switch for the 1983 

and 1984 make-models. 

TABLE 105-9 

AVERAGE WEIGHT AND CONSUMER COST 

OF BRAKE SYSTEM COMPONENTS IN LIGHT TRUCKS

MAKE/MODEL COMPONENT 

MODEL

YEAR 

WEIGHT IN

POUNDS 

CONSUMER COST 

($2002)

Front Pads 1983 1.21 $13.47

1984 2.10 $20.20

Rear Brakes 1983 50.29 $85.14

1984 64.51 $96.81

Dodge 150 

Servo 1984 8.54 $36.10

Dodge 350 Front Pads 1983 1.63 $18.06

1984 2.81 $27.09

Dodge MPV Variable Valve 1984 1.50 $28.45

Ford – All Trucks Warning Light Emergency Brake 1984 0.03 $ 0.40

Ford F-150 Rear Shoes 1983 1.48 $16.46

1984 1.77 $18.11

Front Pads 1983 1.03 $11.48

1984 1.23 $12.62

Rear Shoes 1983 1.75 $19.45

1984 1.80 $19.99

Ford F-250 

Variable Valve 1984 2.90 $11.17

Ford F-350 Front Pads 1983 2.44 $27.34

1984 2.91 $30.08

GMC 1500 Front Pads 1983 1.14 $12.62

1984 1.36 $18.93

Front Pads 1983 1.14 $12.62

1984 1.36 $18.93

GMC 2500 

Variable Valve 1984 3.04 $15.19

Front Pads 1983 1.37 $15.26

1984 1.64 $22.89

GMC 3500 

Variable Valve 1984 3.04 $12.51

28
Except for the emergency brake warning switch in Ford trucks, NHTSA does not have strong 

evidence that any of these changes were directly motivated by FMVSS 105, or actually needed to 

assure compliance with the standard. Therefore, only the cost and weight of the warning light 

emergency brake switch is attributed to FMVSS 105. Since Ford accounted for 30 percent of 

truck sales in 1984, the 0.03 pounds and $0.40 in Ford trucks averages out to 0.01 pounds and 

$0.12 in all trucks. This is added to the cost and weight of dual master cylinders. Table 105-10 

shows the average weight and consumer cost of brake system components attributable to 

FMVSS 105 in light trucks. 

TABLE 105-10

AVERAGE WEIGHT AND CONSUMER COST 

OF BRAKE SYSTEMS COMPONENTS 

ATTRIBUTABLE TO FMVSS 105 IN LIGHT TRUCKS

COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

Dual Master Cylinder 0.95 $10.88

Warning Light 

Emergency Brake Switch 0.01 $ 0.12

TOTAL 0.96 $11.00

Antilock Brake Systems 

NHTSA analyzed the weight and consumer cost of four-wheel ABS systems in two SUVs.26,27 

During 1987 through 1992, ABS systems controlled only the rear wheels and were typically 

standard equipment on light trucks. Since 1993, it has become increasingly common for ABS 

systems to control all four wheels on light trucks, similar to passenger cars. The total weight and 

consumer cost of an ABS system in a 1990 Jeep Cherokee 4-wheel drive was calculated at 41.17 

pounds and $750.88 in 2002 dollars; whereas, the total weight and consumer cost of an ABS in a 

1994 Ford Explorer 4-wheel drive was calculated at 20.48 pounds and $426.68 in 2002 dollars. 

From this study of just two vehicles, it is not possible to compute an industry-wide average or to 

deduce if the lower cost for the more recent vehicle represents an industry-wide trend. 

Table 105-11 shows the average weight and consumer cost of the ABS and its subsystems in 

these two SUVs. 

 26 Fladmark, DOT HS 809 795:Section 7 (1991). 27 Fladmark, DOT HS 809 797:Section 14 (1994). 

29
TABLE 105-11

AVERAGE WEIGHT AND CONSUMER COST 

OF ABS IN TWO SUVs

MODEL YEAR COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

Sensors/Rings 3.85 $ 55.02 

Control Unit 2.10 $ 95.69 

Hydraulic Unit 30.72 $547.16 

Wiring Harness 4.50 $ 53.01

1990

Jeep Cherokee

4-wheel drive 

TOTAL 41.17 $750.88

Sensors/Rings 2.75 $ 44.61 

Control Unit 0.85 $ 98.50 

Hydraulic Unit 15.46 $218.48 

Wiring Harness 1.41 $ 65.09

1994

Ford Explorer 

4-wheel drive 

TOTAL 20.47 $426.68

The cost of ABS is, of course, not attributable to FMVSS 105 because the standard neither 

explicitly requires ABS nor implicitly encourages it by including performance tests that are 

easier to pass with ABS than without it. 

FMVSS 106 - BRAKE HOSES 

FMVSS 106 became effective on January 1, 1968 and specifies labeling and performance 

requirements for motor vehicle brake hoses, brake hose assemblies, and brake hose end fittings. 

The purpose of this standard is to reduce deaths and injuries occurring because of brake system

failure from pressure or vacuum loss due to hose or hose assembly rupture. The standard applies 

to passenger cars, multipurpose passenger vehicles, trucks, buses, trailers, and motorcycles and 

to hydraulic, air, and vacuum brake hoses, brake hose assemblies, and brake hose end fittings for 

use in those vehicles.28 No cost studies of brake hoses have been performed, and none are 

planned by the agency. 

FMVSS 107 - [Does not currently exist] 

FMVSS 108 - LAMPS, REFLECTIVE DEVICES, AND ASSOCIATED EQUIPMENT

FMVSS 108 became effective on January 1, 1968 for vehicles with 80 or more inches of overall 

width and January 1, 1969 for all other vehicles. It specifies the requirements for original and 

replacement lamps, reflective devices, and associated equipment. The purpose of this standard is 

to reduce traffic accidents, deaths, and injuries by providing adequate illumination of the 

roadway and by enhancing the conspicuity of motor vehicles on the public roads so that their 

presence is perceived and their signals understood in daylight, darkness, or other conditions of 

reduced visibility. The standard applies to: 

• passenger cars, multipurpose passenger vehicles, trucks, buses, trailers, and motorcycles 

 28 Legal citation: 49 CFR 571.106 (2004). 

30
• retro reflective sheeting and reflex reflectors 

• lamps, reflective devices, and associated equipment for replacement of like equipment on 

vehicles to which this standard applies29

FMVSS 108 has been amended many times; however, the most important regulations have been 

(1) the original standard, (2) the side marker lamp requirement, and (3) the center high mounted 

stop lamp (CHMSL) requirement. While this standard covers all types of lighting and reflective 

devices, side marker lamps and CHMSL are the only lighting developments whose cost is readily 

attributable to FMVSS 108 because they were added to vehicles in anticipation of, or in response 

to, the standard. 

Passenger Car Studies 

Side Marker Lamps. Prior to 1968, passenger cars did not have side marker lamps. That made 

it very difficult to see them from the side at night, especially when they crossed into intersections 

or pulled out of a driveway. Beginning with the 1970 model year, FMVSS 108 required a red 

lamp (as far to the rear of the vehicle as practicable) and an amber lamp (as far to the front of the 

vehicle as practicable) on each side of the vehicle. Most 1968 and 1969 model year passenger 

cars already had lamps or at least reflectors, and SAE Recommended Practice J592 discussed 

them as early as 1964. Nevertheless, the extent that the lamps were installed within two years of 

the effective date and while rulemaking was underway, we might judge that the lamps were 

installed “in anticipation of FMVSS 108” and attribute the full cost of the lamps to FMVSS 108. 

A study of the side marker lamps or reflectors was conducted on twenty-six make-model 

passenger cars representing pre-standard, post-standard, and late-model systems.30,31 The salesweighted average for the weight and consumer cost of the pre-standard 1969 model year 

passenger cars was calculated at 1.46 pounds and $20.90 in 2002 dollars, which is attributed to 

the standard for model years 1968-69. Implementation of the side marker lamps in the poststandard 1970 model year passenger cars increased the weight to 1.95 pounds and the consumer 

cost to $29.37 in 2002 dollars, which is attributed to the standard for model years 1970-2001. 

The late model (1979-1981) passenger cars decreased in weight to 1.30 pounds and increased in 

consumer cost to $31.13 in 2002 dollars. 

Center High Mounted Stop Lamps. CHMSL have been standard equipment on all new 

passenger cars sold in the United States since model year 1986 and all new light trucks since 

model year 1994, as required by FMVSS 108. The purpose of CHMSL is to safeguard a vehicle 

from being struck in the rear by another vehicle. When the brakes are applied, the CHMSL 

sends a conspicuous signal to drivers of following vehicles that they must slow down. Since 

 29 Legal citation: 49 CFR 571.108 (2004). 30 Harvey, M.R., Lesczhik, J.A., and McLean, R.F., Cost Evaluation for Nine Federal Motor Vehicle Standards, 

Volume II, FMVSS 108, Washington: U.S. Department of Transportation, National Highway Traffic Safety

Administration, November 1979. (DOT HS 805 316). 31 Gladstone, R., Harvey, M.R., and Lesczhik, J.A., Estimation of the Weight and Consumer Price of Late Model 

Vehicle Components Relating to the Implementation of FMVSS 108, 202, 208, and 214, Washington: U.S. 

Department of Transportation, National Highway Traffic Safety Administration, March 1982. (DOT HS 806 257:5-

1 thru 5-21). 

31
nearly two-thirds of all rear impact crashes involve pre-impact braking by the lead vehicle, the 

CHMSL can be a significant countermeasure to deter rear-impact crashes of all types. 

A study was conducted on thirty passenger cars of model years 1986 and 1987 to determine the 

weight and consumer cost of CHMSL.32,33 The sales-weighted average for the weight and 

consumer cost for the 1986 and 1987 model year passenger cars were calculated at 0.85 pounds 

and $9.74 in 2002 dollars, which are attributed to the standard. 

Table 108-1 shows the average weight and consumer cost of lamps attributable to FMVSS 108 in 

passenger cars. 

TABLE 108-1 

AVERAGE WEIGHT AND CONSUMER COST 

OF LAMPS ATTRIBUTABLE TO FMVSS 108 

IN PASSENGER CARS 

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Side Marker (1968-1969) 1.46 $20.90

Side Marker (1970-2001) 1.95 $29.37

CHMSL (1986-2001) 0.85 $ 9.74 

Headlamp Concealment Devices. Headlamp concealment devices were a popular design feature 

for passenger cars during the 1960's. These devices were primarily cosmetic; however, an 

unsafe driving situation could arise if the concealment devices were frozen shut when headlamps 

were needed. FMVSS 112 became effective on January 1, 1969 and required that the devices 

remain fully open when there is a power loss or system failure, or they be manually operable 

without the use of tools. In addition, the device could not be involved in either the mounting or 

the aiming of the headlamps. FMVSS 112 was canceled on October 24, 1996 and the 

requirements were incorporated into FMVSS 108 (Lamps, Reflective Devices, and Associated 

Equipment under Section 12). 

A study conducted on four make-model passenger cars, representing pre-standard and poststandard systems, indicated that the headlamp concealment devices met the requirements of the 

standard before its effective date.34 None of the changes in the headlamp concealment devices 

between 1966 and 1969 was related to the standard. The arithmetic average for the weight and 

consumer cost of headlamp concealment devices for the pre-standard 1966 model year passenger 

cars was calculated at 12.20 pounds and $114.42 in 2002 dollars. By 1969, the average weight 

for the post-standard passenger cars had increased to 14.01 pounds while the consumer cost 

decreased to $98.59 in 2002 dollars. The main reason for the decreased cost was the change in 

operating system from an electrical system to a vacuum system for reasons unrelated to the 

 32 Carlson, L.E. and Leonard, P., Cost Evaluation of Federal Motor Vehicle Safety Standard 108 and 207, 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, May 1986. (DOT 

HS 807 017:15-55). 33 Khadilkar, A.V. and Fladmark, G.L., Cost Estimates of Center High Mounted Stop Lamps and Passenger Car

Red/Amber Rear Turn Signal Lamps, Washington: U.S. Department of Transportation, National Highway Traffic 

Safety Administration, November 1988. (DOT HS 809 793:32-68). 34 Adams, G.J., et.al., Cost Evaluation of Federal Motor Vehicle Safety Standards 111, 112, 118, and 124,

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, November 1983. 

(DOT HS 806 774:31,124-134). 

32
regulation. No cost is attributed to FMVSS 108 because most concealment devices met the 

requirements of the standard before its effective date of January 1,1969. 

Light Truck Studies 

Side Marker Lamps and CHMSL. Side marker lamps were required on light trucks at the same

time as passenger cars, while CHMSL became effective on September 1, 1993 for light trucks 

(i.e., model year 1994). Because NHTSA has not performed teardown analyses for these 

systems on light trucks, and because they are similar to the systems on passenger cars, we will 

assume the same costs on light trucks as on passenger cars. Table 108-2 shows the average 

weight and consumer cost of lamps attributable to FMVSS 108 in light trucks. 

TABLE 108-2 

AVERAGE WEIGHT AND CONSUMER COST 

OF LAMPS ATTRIBUTABLE TO FMVSS 108 

IN LIGHT TRUCKS 

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Side Marker (1968-1969) 1.46 $20.90

Side Marker (1970-2001) 1.95 $29.37

CHMSL (1994-2001) 0.85 $ 9.74 

Other Lighting System Developments. Technological advances have resulted in changes to 

vehicle lighting systems. Manufacturers are offering quartz-halogen headlamps, composite 

headlamps with replaceable bulbs, high intensity discharge (HID) lights, light-emitting diode 

(LED) lights, and daytime running lamps (DRL). Since FMVSS 108 did not require these 

changes, no cost studies have been performed, and none are planned by this agency. 

 

FMVSS 109 - NEW PNEUMATIC BIAS PLY AND CERTAIN SPECIALTY TIRES 

FMVSS 109 became effective on January 1, 1968 and specifies tire dimensions and laboratory 

test requirements for bead unseating resistance, strength, endurance, and high-speed 

performance; defines tire load rating; and specifies labeling requirements for passenger car tires. 

This standard applies to new pneumatic tires for use on passenger cars manufactured after 1948. 

However, it does not apply to any tire that has been altered to render impossible its use, or its 

repair for use, as motor vehicle equipment.35 No cost studies of new pneumatic tires have been 

performed, and none are planned by this agency. 

FMVSS 110 - TIRE SELECTION AND RIMS FOR MOTOR VEHICLES

FMVSS 110 became effective on April 1, 1968 and specifies requirements for original 

equipment tire and rim selection on new cars to prevent tire overloading. These include placard 

requirements relating to load distribution as well as rim performance requirements under 

conditions of rapid tire deflation. This standard applies to passenger cars and to non-pneumatic 

 35 Legal citation: 49 CFR 571.109 (2004). 

33
spare tire assemblies for use on passenger cars.36 No cost studies have been performed, and none 

are planned by this agency. 

FMVSS 111 - REARVIEW MIRRORS

FMVSS 111 became effective on January 1, 1968 and specifies requirements for the 

performance and location of inside and outside rearview mirrors. The purpose of this standard is 

to reduce the number of deaths and injuries that occur when the driver of a motor vehicle does 

not have a clear and reasonably unobstructed view to the rear. This standard applies to passenger 

cars, multi-purpose passenger vehicles, trucks, buses, school buses, and motorcycles. 

Furthermore, FMVSS 111 requires passenger cars to have a mounting system for the inside 

rearview mirror that would break away upon impact, and an outside rearview mirror. The 

purpose of breakaway mirrors is to reduce fatalities and injuries in frontal collisions to front seat 

occupants who contact the rearview mirror.37

A study of inside rearview mirrors was conducted on sixteen pre-standard make-model passenger 

cars and their corresponding post-standard and trend systems.38 Because most states required 

outside rearview mirrors before the implementation of FMVSS 111, they were not in the study. 

The sales-weighted average for the weight and consumer cost of the pre-standard 1966 model 

year passenger cars was calculated at 0.97 pounds and $7.67 in 2002 dollars. Implementation of 

the inside rearview mirrors in the post-standard 1968 model year passenger cars increased the 

weight to 1.12 pounds and the consumer cost to $10.81. However, estimation of the weight and 

consumer price in the 1982 model year passenger cars indicated a decrease in weight to 0.71 

pounds and in consumer cost to $6.70 in 2002 dollars. Since the average weight and consumer 

cost decreased by 0.26 pounds and $0.97 in 2002 dollars between the pre-standard and long-term

trend results, no cost is attributed to FMVSS 111. 

FMVSS 112 – [Does not currently exist] 

FMVSS 113 - HOOD LATCH SYSTEM 

FMVSS 113 became effective on January 1, 1969 and specifies the requirement for providing a 

hood latch system or hood latch systems. Each hood must be provided with a hood latch system, 

and a front opening hood must be provided with a second latch position on the hood latch system

or with a second hood latch system. The purpose of the standard is to prevent the incidence of 

hoods flying open and partially or completely obstructing the driver’s view through the 

windshield while the vehicle is moving. This standard applies to passenger cars, multipurpose 

passenger vehicles, trucks, and buses.39

 36 Legal citation: 49 CFR 571.110 (2004). 37 Legal citation: 49 CFR 571.111 (2004). 38 Adams, DOT HS 806 774:23,25-30 (1983). 39 Legal citation: 49 CFR 571.113 (2004). 

34
A study of thirty-seven make-model passenger cars representing pre-standard, post-standard, and 

trend systems was conducted. The sales-weighted average for the weight and consumer cost of 

the pre-standard 1968 model year passenger cars was calculated at 3.19 pounds and $19.05 in 

2002 dollars. In 1970, the weight and consumer cost in the post-standard model year passenger 

cars had decreased to 3.06 pounds and $15.53 in 2002 dollars. By 1971, the weight and 

consumer cost for the trend systems had increased slightly to 3.37 pounds and $16.90 in 2002 

dollars. Since all manufacturers met the requirements of FMVSS 113 by the 1968 model year at 

the very latest, and likely initiated the development of dual latch systems before the FMVSS 113 

rulemaking process, no cost was attributed to the standard. In fact, examination of cars for 

several years prior to 1968 showed that the safety standard provisions were met in all cases by 

the domestic industry. It was determined that there were three major reasons for hood latch 

design changes among the sample:40

• the hood lock environment changed due to styling changes or other modifications. 

• the trend to inside hood releases, as either an option or standard feature, required a 

change from a safety catch integral with the latch mechanism to a separate safety catch. 

• the designs were revised for cost reduction and simplification.

The Volkswagen Beetle was the only vehicle in the sample whose change in hood latch design 

was definitely safety related. The Volkswagen Beetle would not have complied with the 

standard in 1966 because no safety catch was provided; it had dual latch systems. However, a 

design change was made in 1968, and a push button actuated safety catch was added. Because 

the safety catch was already included in the 1968 model 11/2 years before the effective date, its 

development may well have been initiated before the FMVSS 113 rulemaking process; therefore, 

no cost was attributed to the standard. 

FMVSS 114 - THEFT PROTECTION

FMVSS 114 became effective on January 1, 1970 and specifies the requirements for a lock 

system that prevents the activation of the engine ignition and starting systems, movement of the 

steering wheel, and movement of the automatic transmission gear selector out of the “park” 

position when the key is removed. The purpose of this standard is to: 

• reduce thefts and enhance safety by reducing the incidence of crashes resulting from

unauthorized operation of a motor vehicle, and 

• prevent the rollaway of parked vehicles because of children moving the automatic shift 

mechanism out of the “park” position. 

This standard applies to passenger cars and to trucks and multipurpose passenger vehicles having 

a GVWR of 10,000 pounds or less. It does not apply, however, to walk-in van-type vehicles.41 

 40 McVetty, T.N., Cross, A.J., and Parr, L.W., Cost Evaluation for Two Federal Motor Vehicle Safety Standards

– FMVSS 113 Hood Latch – Passenger Cars – FMVSS 219 Windshield Zone Intrusion – Passenger Cars, 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, April 1982. 

(DOT HS 806 187:9-18). 41 Legal citation: 49 CFR 571.114 (2004). 

35
While this standard would initially have had some cost implications, no cost studies have been 

performed, and none are planned by this agency. 

FMVSS 115 - [Does not currently exist] 

FMVSS 116 - MOTOR VEHICLE BRAKE FLUIDS

FMVSS 116 became effective on January 1, 1968 and specifies requirements for fluids for use in 

hydraulic brake systems of motor vehicles, containers for these fluids, and labeling of the 

container. The purpose of this standard is to reduce failures in the hydraulic braking systems of 

motor vehicles that may occur because of the manufacture or use of improper or contaminated 

fluid. Each passenger car, multipurpose passenger vehicle, truck, bus, trailer, and motorcycle 

that has a hydraulic brake system shall be equipped with fluid that has been manufactured and 

packaged in conformity with the requirements of this standard.

42 FMVSS 116 would initially 

have had some cost implications, along with each time it was updated; however, no cost studies 

have been performed, and none are planned by this agency. 

FMVSS 117 - RETREADED PNEUMATIC TIRES 

FMVSS 117 became effective January 1, 1972 and specifies performance, labeling, and 

certification requirements for retreaded pneumatic passenger car tires. The purpose of this 

standard is to require retreaded pneumatic passenger car tires to meet safety criteria similar to 

those for new pneumatic passenger car tires. This standard applies to retreaded pneumatic tires 

for use on passenger cars manufactured after 1948.43 Since FMVSS 117 does not regulate 

components of new passenger cars or light trucks, it is outside the scope of this report. No cost 

studies have been performed, and none are planned by this agency. 

FMVSS 118 - POWER-OPERATED WINDOW, PARTITION, AND ROOF PANEL 

SYSTEMS

FMVSS 118 became effective on February 1, 1971 (passenger cars and multipurpose vehicles) 

and on July 25, 1988 (trucks). This standard specifies requirements for power-operated window, 

partition, and roof panel systems to minimize the likelihood of death or injury from their 

accidental operation. This standard applies to passenger cars, multipurpose passenger vehicles, 

and trucks with a GVWR of 10,000 pounds or less. The standard’s requirements for poweroperated roof panel systems need not be met for vehicles manufactured before September 1, 

1993.44

Originally, this standard did not allow the power windows to be operational unless a vehicle’s 

ignition or electrical accessory system was energized via the ignition key. In other words, the 

 42 Legal citation: 49 CFR 571.116 (2004). 43 Legal citation: 49 CFR 571.117 (2004). 44 Legal citation: 49 CFR 571.118 (2004) 

36
opening and closing of the power windows in a parked vehicle without the ignition turned on 

(potential safety hazard to children or other unsuspecting persons) would not be possible under 

the standard. In 1975, the standard was amended to add restrictions on the operation of power 

windows while the passenger doors were ajar. 

A study was conducted on six make-model passenger cars from two major domestic 

manufacturers that represented pre-standard, post-standard, and trend systems.45 The small 

sample was due to the limited number of vehicles and the model years affected by the standard 

for these specialty items. 

Implementation of the standard involved moving the window system supply wire to a different 

location and adding a circuit breaker. Since the block fuse mounting was part of the pre-standard 

make-models, it was decided to base the weight and consumer cost on the addition of the circuit 

breaker to the post-standard and trend systems. Due to the small sample size, the simple 

arithmetic average was used instead of the sales-weighted average. 

FMVSS 118 was extended to light trucks effective July 25, 1988, however, voluntary 

installations of the power windows were appearing in light trucks as early as 1978. Because 

NHTSA has not performed teardown analyses of the power window components on light trucks, 

and because they are similar to the components on passenger cars, we will assume the same costs 

on light trucks as on passenger cars. 

Table 118-01 shows the average weight and consumer cost of power window components 

attributable to FMVSS 118 in passenger cars and light trucks. 

TABLE 118-01

AVERAGE WEIGHT AND CONSUMER COST 

OF POWER WINDOW COMPONENTS 

ATTRIBUTABLE TO FMVSS 118 

IN PASSENGER CARS AND LIGHT TRUCKS 

COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

Circuit Breaker 0.04 $0.92 

Based on information in the Ward’s Automotive Yearbook, approximately 14% of the 1970 

model year domestic passenger cars were equipped with power windows. By the 1982 model 

year, the number had increased to 33%. The popularity of power windows was growing, and the 

manufacturers had focused more attention on the cost on these systems as they filtered down 

from luxury cars to the intermediate range. 

 45 Adams, DOT HS 806 774:24,32 (1983). 

37
FMVSS 119 - NEW PNEUMATIC TIRES FOR VEHICLES OTHER THAN PASSENGER 

CARS 

FMVSS 119 became effective on March 1, 1975 and establishes performance and marking 

requirements for tires for use on vehicles other than passenger cars. The purpose of this standard 

is to: 

• provide safe operational levels for tires used on motor vehicles other than passenger cars 

• place sufficient information on the tires to permit their proper selection and use 

This standard applies to new pneumatic tires designed for highway use on multipurpose 

passenger vehicles, trucks, buses, trailers, and motorcycles manufactured after 1948.46 

Since this standard does not regulate components of new passenger cars or light trucks, it is 

outside the scope of this report. No cost studies have been performed, and none are planned by 

this agency.

FMVSS 120 - TIRE SELECTION AND RIMS FOR MOTOR VEHICLES OTHER THAN 

PASSENGER CARS

FMVSS 120 became effective on August 1, 1976 and specifies tire and rim selection 

requirements and rim marking requirements. The purpose of this standard is to provide safe 

operational performance by ensuring that vehicles to which it applies are equipped with tires of 

adequate size and load rating and with rims of appropriate size and type designation. This 

standard applies to tires, rims, and non-pneumatic spare tire assemblies on multipurpose 

passenger vehicles, trucks, buses, trailers, and motorcycles.47 Since this standard does not 

regulate components of new passenger cars or light trucks, it is outside the scope of this report. 

No cost studies have been performed, and none are planned by this agency. 

 

FMVSS 121 - AIR BRAKE SYSTEMS

FMVSS 121 became effective on January 1, 1975 and establishes performance and equipment 

requirements for braking systems on vehicles equipped with air brake systems. The purpose of 

this standard is to insure safe braking performance under normal and emergency conditions.48 

The Intermodal Surface Transportation Efficiency Act (ITSEA) of 1991 enacted by U.S. 

Congress required the Department of Transportation to initiate and enact rulemaking to improve 

braking performance of new commercial motor vehicles. Consequently, FMVSS 121 was 

amended in March 1997 and 1998 to require ABS systems on new air brake truck-tractors (Class 

7 and 8) and new air brake trailers (greater than 10,000 pounds GVWR). It is important to note 

that even before the standard went into effect, the manufacturers of truck-tractors, trailers, and 

other heavy vehicles were offering ABS in different configurations as optional equipment. 

 46 Legal citation: 49 CFR 571.119 (2004). 47 Legal citation: 49 CFR 571.120 (2004). 48 Legal citation: 49 CFR 571.121 (2004). 

38
Since FMVSS 121 does not regulate components of new passenger cars or light trucks, it is 

outside the scope of this report. However, a study was conducted in 2000 and Table 121-1 

shows the arithmetic average weight and consumer cost of two air-braked truck-tractor ABS, two 

air-braked trailer ABS, and one tractor-trailer connection.49 The connections between the 

tractors and the trailers are standardized by industry practice and by applicable standards and 

guidelines, which allows for interchangeability between various trailers and the towing tractors. 

(Of course, none of the costs of FMVSS 121 apply to passenger cars or light trucks because they 

are equipped with hydraulic brakes, not air brakes.) 

TABLE 121-1 

AVERAGE WEIGHT AND CONSUMER COST 

OF ABS IN AIR-BRAKED TRUCK-TRACTORS AND TRAILERS

ABS WEIGHT IN POUNDS CONSUMER COST ($2002) 

Truck-Tractor

2000 Navistar International 

Class 7 

Bendix ABS 31.71 $612.45 

2000 Freightliner 

Class 8 

Meritor/Wabco ABS 18.76 $496.36 

Trailer 

2000 Great Dane 

Meritor/Wabco ABS 31.74 $494.85 

2000 Utility International 

Haldex ABS 33.19 $396.06 

Tractor-Trailer Connection 

 9.54 $ 96.79

FMVSS 122 - MOTORCYCLE BRAKE SYSTEMS 

FMVSS 122 became effective on January 1, 1974 and specifies performance requirements for 

motorcycle brake systems. The purpose of the standard is to insure safe motorcycle braking 

performance under normal and emergency conditions. This standard only applies to 

motorcycles.

50 Since this standard does not regulate components of new passenger cars or light 

trucks, it is outside the scope of this report. No cost studies have been performed, and none are 

planned by this agency. 

 49 Khadilkar, A.V., Fladmark, G.L., and Khadilkar, J., Teardown Cost Estimates of Automotive Equipment

Manufactured to Comply with Motor Vehicle Standards, FMVSS 121 (Air Brake Systems) and FMVSS 105

(Hydraulic Brake Systems), Antilock Brake Features, Washington: U.S. Department of Transportation, National

Highway Traffic Safety Administration, November 2002. (DOT HS 809 808). 50 Legal citation: 49 CFR 571.122 (2004). 

39
FMVSS 123 - MOTORCYCLE CONTROLS AND DISPLAYS

FMVSS 123 became effective on September 1, 1974 and specifies requirements for the location, 

operation, identification, and illumination of motorcycle controls and displays and requirements 

for motorcycle stands and footrests. The purpose of this standard is to minimize accidents 

caused by operator error in responding to the motoring environment by standardizing certain 

motorcycle controls and displays. This standard applies to motorcycles equipped with 

handlebars, except for motorcycles that are designed and sold exclusively for use by law 

enforcement agencies.51 Since this standard does not regulate components of new passenger cars 

or light trucks, it is outside the scope of this report. No cost studies have been performed, and 

none are planned by this agency. 

FMVSS 124 - ACCELERATOR CONTROL SYSTEMS

FMVSS 124 became effective on September 1, 1973 and establishes requirements for the return 

of a vehicle’s throttle to the idle position when the driver removes his or her foot from the 

accelerator control or in the event of a severance or disconnection in the accelerator control 

system. The purpose of this standard is to reduce deaths and injuries resulting from engine overspeed when the accelerator fails to return to the up position. This standard applies to passenger 

cars, multipurpose passenger vehicles, trucks, and buses.52 

Accelerator control systems were difficult to analyze because changes were being made to the 

carburetor systems to meet EPA fuel conservation and emissions systems standards at the same

time FMVSS 124 went into effect. However, the standard was met by having two energy 

sources, an inner and outer accelerator return spring, which were capable of returning the throttle 

to the idle position. 

A study was conducted on eighteen make-model passenger cars from four major manufacturers 

that represented pre-standard, post-standard, and trend systems.53 Analysis of each system

identified an increase in the weight and consumer cost from the six pre-standard make-models to 

the six post-standard make-models. While a comparison of the post-standard and trend systems 

indicated that four out of the six make-models decreased in cost, three out of those four makemodels were from the same manufacturer (GMC). The lack of evidence to support a significant 

trend, therefore, justifies the use of the simple arithmetic average instead of the sales-weighted 

average for the weight and consumer cost. The arithmetic average for the weight and consumer 

cost of the pre-standard make-models was calculated at 0.02 pounds and $0.45 in 2002 dollars; 

the post-standard was calculated at 0.04 pounds and $0.91; the trend systems were calculated at 

0.03 pounds and $0.74. 

NHTSA has not performed teardown analyses of the accelerator control systems on light trucks; 

however, because they are similar to the systems on passenger cars, we will assume the same

costs on light trucks as on passenger cars. 

 51 Legal citation: 49 CFR 571.123 (2004). 52 Legal citation: 49 CFR 571.124 (2004). 53 Adams, DOT HS 806 774:24,33-38 (1983). 

40
Table 124-1 shows the actual weight and cost increments of accelerator control systems 

attributable to FMVSS 124 in passenger cars and light trucks. 

 

TABLE 124-1 

AVERAGE WEIGHT AND CONSUMER COST 

OF ACCELERATOR CONTROL SYSTEMS 

ATTRIBUTABLE TO FMVSS 124 

IN PASSENGER CARS AND LIGHT TRUCKS 

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Pre-Standard 0.02 $0.45

Post-Standard 0.04 $0.91

DIFFERENCE 0.02 $0.47

FMVSS 125 - WARNING DEVICES

FMVSS 125 became effective on January 1, 1974 and establishes shape, size, and performance 

requirements for reusable day and night warning devices that can be erected on or near the 

roadway to warn approaching motorists of the presence of a stopped vehicle. The purpose of this 

standard is to reduce deaths and injuries due to rear-end collisions between moving traffic and 

disabled vehicles. This standard applies to devices that do not have self-contained energy 

sources and are designed to be carried in buses and trucks that have a GVWR greater than 10,000 

pounds.54 Since this standard does not regulate components of new passenger cars or light 

trucks, it is outside the scope of this report. No cost studies have been performed, and none are 

planned by this agency. 

FMVSS 129 - NEW NON-PNEUMATIC TIRES FOR PASSENGER CARS

FMVSS 129 became effective on August 20, 1990 and specifies tire dimensions and laboratory 

test requirements for lateral strength, endurance, and high-speed performance; defines the tire 

load rating; and defines labeling requirements for non-pneumatic spare tires. This standard 

applies to new temporary spare non-pneumatic tires for use on passenger cars.55 Since this 

standard does not require new passenger cars or light trucks to have the optional non-pneumatic 

tires, no cost studies have been performed, and none are planned by this agency. 

FMVSS 131 - SCHOOL BUS PEDESTRIAN SAFETY DEVICES

FMVSS 131 became effective on May 3, 1991 and establishes requirements for devices (stop 

signal arms) that can be installed on school buses to improve the safety of pedestrians near 

stopped school buses. The purpose of this standard is to reduce deaths and injuries by 

minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians near 

the bus.56 Since this standard does not regulate components of new passenger cars or light 

 54 Legal citation: 49 CFR 571.125 (2004). 55 Legal citation: 49 CFR 571.129 (2004). 56 Legal citation: 49 CFR 571.131 (2004). 

41
trucks, it is outside the scope of this report. No cost studies have been performed, and none are 

planned by this agency. 

FMVSS 135 – LIGHT VEHICLE BRAKE SYSTEMS 

This standard specifies requirements for vehicles equipped with hydraulic and electric service 

brakes and parking brake systems. The purpose of the standard is to ensure safe braking 

performance under normal conditions and emergency conditions. This standard applies to 

passenger cars manufactured on or after September 1, 2000 and to multipurpose passenger 

vehicles, trucks, and buses with a GVWR of 7,716 pounds or less, manufactured on or after 

September 1, 2002. In addition, at the option of the manufacturer, passenger cars manufactured 

before September 1, 2000 and multipurpose passenger vehicles, trucks, and buses with a GVWR 

of 7,716 pounds or less manufactured before September 1, 2002, may meet the requirements of 

this standard instead of FMVSS 105.57 No cost studies have been performed. 

FMVSS 138 – TIRE PRESSURE MONITORING SYSTEMS 

FMVSS 138 became effective on August 5, 2002 and specifies performance requirements for tire 

pressure monitoring systems. The purpose of the standard is to prevent significant underinflation of tires and the resulting safety problems by warning the driver when a tire is 

significantly under-inflated. This standard applies to passenger cars, multipurpose passenger 

vehicles, trucks, and buses with a GVWR of 10,000 pounds or less, except those vehicles with 

dual wheels on an axle.58 No cost studies have been performed. 

FMVSS 139 – NEW PNEUMATIC RADIAL TIRES FOR LIGHT VEHICLES 

FMVSS 139 became effective on June 5, 2003 and specifies tire dimensions, test requirements, 

labeling requirements, and defines load ratings. The purpose of the standard is to create more 

stringent tire performance requirements and require improved labeling of tires to assist 

consumers in identifying tires that may be the subject of a safety recall. This standard applies to

new pneumatic tires for use on motor vehicles (other than motorcycles and low speed vehicles) 

that have a GVWR of 10,000 pounds or less and that were manufactured after 1975.59 No cost 

studies have been performed. 

 57 Legal citation: 49 CFR 571.135 (2004). 58 Legal citation: 49 CFR 571.138 (2004). 59 Legal citation: 49 CFR 571.139 (2004). 

42
SECTION 3 – FMVSS 200 SERIES 

The FMVSS 200 series of “crashworthiness” standards specify performance requirements for 

motor vehicles intended to reduce the fatality risk or injury severity of people involved in 

crashes. Performance specifications are more easily related to specific hardware modifications 

than in the FMVSS 100 series of standards. Furthermore, most crashworthiness standards result 

in modification to equipment that requires no action by the driver or passenger. A noted 

exception of this condition is the use of safety belts that often requires the occupant to “buckle 

up”. 

FMVSS 201 - OCCUPANT PROTECTION IN INTERIOR IMPACT 

Original Standard. FMVSS 201 became effective on January 1, 1968 (passenger cars) and on 

September 1, 1981 (multipurpose passenger vehicles, trucks, and buses) and specifies 

requirements on the design and performance of instrument panels, seat backs, interior 

compartment doors, sun visors, and armrests. The purpose of this standard is to afford head 

impact protection for occupants. Therefore, in order to meet the requirements, certain parts of 

the vehicle interior have to be padded, and no sharp or pointed parts can be placed in the vehicle 

interior that an occupant can come in contact with during a frontal crash. This standard applies to 

passenger cars, multipurpose passenger vehicles, trucks, and buses with a GVWR of 10,000 

pounds or less.60

Unlike some of the FMVSS 200-series standards, there are few specific, self-contained vehicle 

modifications (i.e., head restraints or air bags) associated with the 1968 version of FMVSS 201. 

Instead, the standard established impact test requirements for various interior surfaces, which 

may or may not have required some degree of modification to meet the tests. As a result, the 

cost analysis for FMVSS 201 was sometimes exploratory in nature. Since we did not know in 

advance if anything was changed to meet FMVSS 201, we had to discover this during the 

analysis. 

Several pre- and post-standard specimens were compared for each of the various interior 

structures addressed by the standard. In some structures, costs might be consistently higher for 

the post-standard specimens, as evidenced by a statistically significant average cost increase for 

the study sample. That probably indicates they were modified because of the standard. In other 

structures, costs went up in some specimens and down in others, and the average change in cost

was not statistically significant. That probably indicates the modifications were merely for 

styling or production efficiency, and not needed for meeting the standard. Of course, in those 

cases where a specific modification was already known to be associated with FMVSS 201 (e.g., 

the change from friction to mechanical latches on glove compartment doors), the exploratory 

approach was unnecessary and we were able to cost those modifications directly. 

In general, few costs are attributed to FMVSS 201 because manufacturers began padding interior 

surfaces well before the rulemaking process, as early as 1956. By 1964, padding that 

presumably could have met FMVSS 201 was already standard equipment on most cars. The 

 60 Legal citation: 49 CFR 571.201 (2004). 

43
practical effect of the standard was at most a selective improvement or an extension of earlier 

developments. 

Actually, the most important development from 1967 through 1971 (i.e., during and after the 

FMVSS 201 rulemaking period) was the reduction in the rigidity of the middle and lower 

instrument panels. The middle and lower panels were redesigned to deform at a controlled rate 

during an impact to reduce peak loads on an occupant’s chest and legs. Coincidentally, the 

availability of plastics, coupled with the desire to substitute them for steel to lighten vehicles, 

also led to less rigid panels. These improvements significantly reduced fatality and injury risk of 

right-front passengers in crashes.61 Since none of these modifications were necessitated or even 

addressed by FMVSS 201, their costs were not studied by NHTSA. 

Passenger Car Studies 

Thirty make-model passenger cars representing pre-standard (1967), standard (1968), and poststandard (1969) systems were studied to determine the weight and consumer cost impact of 

FMVSS 201.

62 The following items were studied: 

Glove Compartment Doors. These were required by FMVSS 201 to remain in the closed 

position when subjected to an inertial load of 10g in the lateral and vertical directions, 30g in the 

longitudinal direction, or a head-on vehicle impact into a fixed barrier at 30 mph. A mechanical 

latch and striker with a release knob/button and mechanism was employed by the vehicle 

manufacturers to keep the door closed. Most vehicles were already in compliance in the prestandard 1967 model year, and their door locks were identical in design and manufacturing 

processing for the pre-standard, implementation, and post-standard model years. Those vehicles 

not in compliance in 1967 used a friction latch, which was nothing more than a tab or tang mount 

to the inside of the door that pressed against an indentation on the inside of the glove 

compartment. The friction force was enough to keep the door closed during normal operation of 

the vehicle but not during a crash. Those vehicles with the friction latch in 1967 switched to a 

positive mechanical latch in 1968. The arithmetic average weight and consumer cost increase 

from the pre-standard to the post-standard vehicles was 0.05 pounds and $0.72 in 2002 dollars in 

the cars that changed from friction to mechanical latches. When these amounts are averaged 

with the rest of the fleet (unchanged), the average weight and consumer cost increases for the 

entire fleet are 0.01 pounds and $0.12 in 2002 dollars and are attributed to the standard. 

Protruding Components (Interior Door Release Handles, Window Regulators, and Vent Window 

Locks and Regulators). These were considered “protrusions” according to the original proposed 

FMVSS 201. The underlying concept of the proposed requirement was to re-contour, soften 

(change material or add padding), recess, or move the interior items that protruded into possible 

head, knee, or leg impact areas. This requirement was later removed in an amendment in the 

summer of 1967. Even though the protrusion requirement was dropped, vehicle manufacturers 

made changes to comply with the proposed requirements. 1968 was a transitional stage that 

 61 Kahane, C.J., An Evaluation of Occupant Protection in Frontal Interior Impact for Unrestrained Front Seat

Occupants of Cars and Lights Trucks, Washington: U.S. Department of Transportation, National Highway Traffic 

Safety Administration, 1988. (DOT HS 807 203) 62 Gladstone, DOT HS 806 367:4-1 thru 4-88 (1982).

44
reflected some uncertainty on design changes. By 1969, the average cost of these systems was, 

on the average, lower (but not significantly lower) than in 1966. Window regulators were recontoured with larger radii, using more pliable plastic or rubber knobs in place of the smaller 

metal knobs. This resulted in a decrease in consumer cost of $1.46 in 2002 dollars. Interior door 

release handles were reshaped with fewer sharp edges and corners and built into either the 

armrest or flush with the door inner trim panel, which decreased the consumer cost by $0.83 in 

2002 dollars. Vent window locks were either eliminated or reshaped to be smaller and rounder, 

with many vehicles eliminating the vent window on the 1968 and 1969 make-models. Since the 

changes to the protruding components were not required, the weight and consumer cost 

difference is not attributed to the standard. Even if FMVSS 201 had required this modification, 

this report would not have credited the cost reduction to the standard because the same costsaving modifications could presumably have been implemented without it. 

Armrests. These were required to deflect or collapse laterally upon impact at least 2 inches 

without contacting any underlying rigid material or have no unpadded areas that a passenger 

could contact in a collision. Many armrests were redesigned to be longer and shallower in order 

to protrude less into the pelvic impact area. Additional padding, support structure, and softer 

cover materials were also employed for the 1968 and 1969 model years. However, the cost of 

these additions was in some cases more than offset by the reduction in the overall size of the 

armrest. The average change in weight and consumer cost from the pre-standard to the poststandard vehicles was an increase of 0.06 pounds and a decrease of $0.33 in 2002 dollars. These 

weight and cost changes were not statistically significant since half of the armrests studied 

increased and half decreased. Since no consistent trend was demonstrated, the changes in the 

weight and cost of armrests are not attributed to the standard. 

Sun Visors. FMVSS 201 required two sun visors be provided that were constructed of, or 

covered with, energy absorbing materials. No rigid material edge radii less than 0.125 inches 

would be present on the sun visor mounting. The manufacturers made the required design and 

material changes, but these did not necessarily lead to increased costs. In fact, the average 

weight and consumer cost decreased from the pre-standard to the post-standard vehicles by 0.15 

pounds and $0.46 in 2002 dollars. Since approximately half of the sun visors studied decreased 

in weight and cost while the other half increased, the difference between the 1967 and 1969 

model years is not statistically significant. Since no consistent trend was demonstrated, the 

changes in the weight and cost of sun visors are not attributed to the standard. 

 

Instrument Panels. These were required to have adequate energy absorption capabilities in head 

impact areas (primarily the top surface and edges of the panel) so that when a 15-pound, 6.5-inch 

diameter head form is impacted at a velocity of 15 miles per hour the deceleration rate does not 

exceed 80g continuously for more than 3 milliseconds. Changes to the padding and the 

instrument panel cover were made for the 1968 and 1969 model years. The average weight 

increased from the pre-standard to the post-standard vehicles by 0.87 pounds while the consumer 

cost decreased by $0.83 in 2002 dollars. Just over half of the instrument panels studied increased 

in weight and decreased in cost. The average weight and consumer cost difference between the 

1967 and 1969 model years are not statistically significant. Since no consistent trend was 

45
demonstrated, the changes in the weight and cost of instrument panels are not attributed to the 

standard. 

Seat Back Padding. Similar to instrument panels, the head impact areas of the front seat backs 

are required to pass a headform impact test. The requirement applies to the top and backside of 

the front seatback, which are impact areas for the back-seat occupant in a frontal crash. The 

upper six inches of the front seat back padding was studied. The average weight and consumer 

cost increased in the ten specimen make-models from 1967 to 1968 and in seven specimen 

make-models from 1968 to 1969. The average weight and consumer cost increase from 1967 to 

1969 was 0.65 pounds and $4.32 in 2002 dollars and is attributed to the standard. 

Table 201-1 shows the total average weight and cost increase of occupant protection attributable 

to FMVSS 201 in passenger cars. 

TABLE 201-1 

AVERAGE WEIGHT AND CONSUMER COST 

OF OCCUPANT PROTECTION 

ATTRIBUTABLE TO FMVSS 201 IN PASSENGER CARS 

COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

Glove Box Door Latch 0.01 $0.12 

Seat Back Padding 0.65 $4.32 

TOTAL 0.66 $4.44

An additional study was conducted in the 1980s to determine the cost effect (trend cost) that 

FMVSS 201 had on 1983 passenger cars plus the effect that downsizing, weight reduction, and 

front-wheel drive may have had on the cost of implementing the standard.63 The basis for the 

price determinations was the teardown and analysis of system components from selected vehicles 

representing comparable make-models prior to and after the effective date of the standard. Since 

the trend-system sample did not measure the same items or car designs as the pre- and poststandard sample, the costs cannot be used for comparison. 

Light Truck Studies 

A study was conducted in the late 1970’s to determine the effects of extending the passenger car 

requirements of FMVSS 201 to light trucks and vans.64 An estimate of the additional weight and 

consumer cost imposed by the standard on light trucks was calculated in 1979 to support the 

regulatory analysis process; however, these estimates were not based on a “teardown” analysis. 

All 1978 model year U.S. light trucks were inspected to determine their state of compliance. 

Cost and weight estimates were prepared for all items that were in noncompliance. 

 63 Osen, W.R and Ludtke, N.F., Cost Evaluation of Federal Motor Vehicle Safety Standard 210 – Passenger 

Cars and Evaluation of Cost and Weight Trends for Standards 201, 203, and 204 – Passenger Cars, Volume I , 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, April 1985. 

(DOT HS 806 770), 64 McLean, R.F., Study of the Effects of Applying Federal Motor Vehicle Safety Standard 201 to Light Trucks and

Vans, Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, May 1979. 

(DOT HS 805 162). 

46
Additional padding was required on some instrument panels and on all seat backs. Pickups 

equipped to carry rear passengers would require added seat back padding on the front seat. 

Passenger vans, fitted with one or more seats behind the front seats, would require the forwardmost seat backs to be padded. Table 201-2 shows the arithmetic average weight and consumer 

cost increase of padding for light trucks. These figures are the best estimates, based on the 

contractor’s judgment. The increases in interior impact protection are attributable to FMVSS 

201 in light trucks. 

TABLE 201-2 

AVERAGE WEIGHT AND CONSUMER COST 

OF OCCUPANT PROTECTION 

ATTRIBUTABLE TO FMVSS 201 IN LIGHT TRUCKS

WITH TWO OR MORE ROWS OF SEATS 

COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

Padding 3.78 $13.48

A study of the interior components on seven 1982 model year light trucks was conducted to 

determine the consumer cost and weight of the glove box latches, dashboard padding, armrests, 

and sun visors.65 No pre-standard make-models were studied to serve as a baseline. The 1982 

specimen vehicles were leased for visual inspection, detailed measurements, and photographic 

documentation, but components were not removed and torn down. A review of the prior year 

models and parts books indicated that the components related to interior impact protection were 

being used in advance of the implementation date. However, because some of the make-models 

were extensively redesigned in 1982, the contractor was unable to directly compare the 

components of pre- and post-standard light trucks and did not estimate the average cost increase. 

 

Head Impact Protection Upgrade. FMVSS 201 was substantially upgraded in the 1990’s. In 

August 1995, a final rule was issued requiring passenger cars and light trucks to provide 

protection when an occupant’s head strikes upper interior components during a crash, including 

pillars, side rails, headers, and the roof. The rule significantly expanded the scope of the 

standard. Previously, the standard applied mainly to the portion of the vehicle interior in front of 

the front seat occupants, i.e., the instrument panel. By September 1998, the standard was 

amended to permit, but not require, the installation of dynamically deploying upper interior head 

protection systems that provide added head protection in lateral crashes.66 

Specific areas of the upper interior are required to absorb energy to protect the occupant’s head 

in an impact. A free motion head form is impacted into target locations on the A-pillar, B-pillar, 

side headers, front windshield header, and other potential interior locations. The additional 

upper interior protection requirements can be met with either head air bag or non air bag head 

protection systems or both, which are being phased in starting with the 1999 model year and 

concluding with the 2003 model year. 

 

A study was conducted in 2003 to determine the changes made by the automotive industry to 

meet the standard’s non air bag criteria. Ten make-model pre-standard passenger vehicles (six 

passenger cars, one pickup, one SUV, and two vans), and their corresponding post-standard 

systems, were studied to determine the weight and consumer cost impact of adding non air bag 

 65 Gladstone, DOT HS 806 769:4-1 thru 4-41 (1982). 66 Federal Register, Vol.67, No. 117, pg. 41348. 

47
components.67 The type of approaches used to meet the standard consist of foam padding, ridges 

molded from composite materials, injection molded “egg-crate” or honeycomb parts, and 

injection molded ribs in parallel on the interior side of trim pieces. All these approaches are used

in the A and B pillar trim, header, and headliner locations. 

Table 201-3 shows the sales-weighted average weight and consumer cost of the non air bag 

protection systems. Passenger cars and light trucks were combined to identify the preliminary 

costs for head impact protection. With the automotive manufacturers transitioning to head air 

bag protection systems, a study on head air bags is currently being conducted. When completed, 

NHTSA will have a more comprehensive estimate of the costs. 

 

TABLE 201-3 

AVERAGE WEIGHT AND CONSUMER COST 

OF HEAD IMPACT PROTECTION SYSTEMS WITHOUT AIR BAGS 

IN PASSENGER VEHICLES

SYSTEM WEIGHT IN POUNDS CONSUMER COST ($2002) 

Without Air Bags 1.89 $11.99

This cost is inherently attributable to FMVSS 201. However, because NHTSA’s cost analysis of 

the head impact protection upgrade, including head air bags, has not been completed, we will not 

include it at this time in our accounting of the total costs of the FMVSS (Section 5 of this report). 

FMVSS 202 – HEAD RESTRAINTS 

FMVSS 202 became effective on January 1, 1969 (passenger cars) and September 1, 1991 

(multipurpose passenger vehicles, trucks, and buses) and specifies requirements for head 

restraints at the front outboard seat positions. The purpose of this standard is to reduce the 

frequency and severity of neck injuries in rear-end and other collisions, specifically “whiplash”, 

a painful and sometimes disabling syndrome that is all too common in these crashes. This 

standard applies to passenger cars, multipurpose passenger vehicles, trucks, and buses with a 

GVWR of 10,000 pounds or less.68 

Vehicle manufacturers installed adjustable or nonadjustable (integral or fixed) head restraints in 

response to FMVSS 202. Adjustable head restraints can be added to bench as well as bucket 

seats. They can be shifted up and down through a finite range to suit the occupant, and some can 

also be rotated about their lateral axis to change the distance from the face of the restraint to the 

back of the occupant’s head. Integral head restraints are built into a bucket seat, or in rare cases, 

a bench seat. They are not adjustable. Essentially the seat back is raised high enough to act as a 

head restraint, and seats with integral head restraints are commonly referred to as “high-back” 

seats. They require additional framing, padding, and seat covering as compared to a pre-standard 

seat back without a head restraint. Fixed head restraints are rigidly attached to the seat back, are 

 67 Ludtke, N.F., et.al., Perform Cost and Weight Analysis, Non Air Bag Head Protection Systems, FMVSS 201,

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, December 2003. 

(DOT HS 809 810). 68 Legal citation: 49 CFR 571.202 (2004). 

48
not adjustable, and are typically composed of a metal frame that is covered with padding that 

allows the vehicle operator to see through the open areas of the framework. 

The advantage of adjustable restraints is that short drivers can push them down to avoid vision 

obstructions; the disadvantage is that taller occupants may neglect to adjust them up to an 

adequate height. Integral restraints avoid the problem of improper adjustment and sometimes 

cost less than adjustable restraints; however, they have been criticized because they might 

obstruct a driver’s vision or create a “wall” that makes rear-seat passengers feel isolated from the 

people in front of them. Fixed “see-through” restraints try to avoid the shortcomings of the 

adjustable and the integral types, although not all consumers, researchers, or manufacturers 

would agree they are successful. Fixed head restraints have similar bulk and costs as adjustable 

head restraints. 

FMVSS 202 requires a head restraint be provided at each front outboard seating position. The 

performance requirements of the standard can be met in either of two ways. The first option is to 

undergo a dynamic test where a 95th percentile male test dummy is belted into the subject seat 

and subjected to a forward acceleration of 8g. If the dummy’s head is displaced angularly 

rearward no greater than 45 degrees during the acceleration, the requirements are met. The 

second option outlines specific dimensional requirements such as the extended restraint height 

from the seat reference point and the restraint width. It also requires that the head restraint 

withstand a force, applied with a head form, 2.5 inches below the top of the restraint that 

produces a moment of 275 pound feet at the seating reference point until the seat back fails or the 

apply force reaches 200 pounds. To date, manufacturers have always certified compliance by the 

second option. 

Head restraints are an addition to vehicles; therefore, a baseline was not used to determine the 

additional consumer cost and weight. The head restraint portion of the integral “high-back” seats 

was estimated by considering only the additional material and labor necessary to provide the 

increase in seat-back height necessary to meet the requirements for a head restraint. For the 

purposes of analysis, head restraints were divided into adjustable and nonadjustable categories. 

The nonadjustable restraints include integral and fixed head restraints. 

Passenger Car Studies 

The vast majority of American passenger cars were fitted with adjustable head restraints in 1969. 

During the 1970’s, nonadjustable head restraints reached their peak market share. Starting in 

1983, the percentage of nonadjustable head restraints started to drop dramatically. Table 202-1 

shows the average percentage of nonadjustable and adjustable head restraints from 1969-2001. 

TABLE 202-1 

AVERAGE PERCENTAGE OF 

NONADJUSTABLE/ADJUSTABLE HEAD RESTRAINTS 

IN PASSENGER CARS FROM 1969 TO 2001

MODEL YEAR % NONADJUSTABLE % ADJUSTABLE 

1969-1981 31 69

1982-2001 13 87

49
Three separate studies of nonadjustable and adjustable headrests were conducted to determine 

the weight and consumer cost of the head restraint systems in 1969-1981 model-year passenger 

cars.69,70,71 There were a total of eight nonadjustable (integral or fixed) head restraints in various 

model year passenger cars, eleven adjustable head restraints in 1969 model year passenger cars, 

and five adjustable head restraints in 1979-1981 model year passenger cars. Table 202-2 shows 

the sales-weighted average weight and consumer cost of head restraints per passenger car (i.e., 

the cost of two head restraints) in 2002 dollars. 

TABLE 202-2 

AVERAGE WEIGHT AND CONSUMER COST 

OF HEAD RESTRAINTS IN PASSENGER CARS

CATEGORY MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

Nonadjustable 1969-1981 6.18 $27.57

Adjustable 1969 9.94 $43.07

Adjustable 1979-1981 5.55 $31.39

Table 202-2 suggests that adjustable head restraints decreased significantly in weight and 

consumer cost between 1969 and 1979-1981. NHTSA believes the reductions are due to two 

factors: 

• initial “over design” (extra wide and bulky restraints) 

• vehicle downsizing that resulted in smaller, narrower seats and elimination of full-bench 

seats 

For simplicity, let us assume that the average consumer cost decreased at a linear rate from 1969 

to 1981 and leveled off after that (since no further downsizing has occurred). Therefore, the 

average weight and consumer cost of passenger car head restraints attributable to the standard in 

any given model year is calculated using the following formulas: 

1. Average Cost of Head Restraints (1969-1981) = 

a. For MY 1969 

(% 1969-1981 Nonadjustable HR/100 * Cost of Nonadjustable HR) + 

(% 1969-1981 Adjustable HR/100 * Cost of 1969 Adjustable HR) 

 

b. For MY 1970 through 1980 

(% 1969-1981 Nonadjustable HR/100*Cost of Nonadjustable HR) + 

 % 1969-1981 Adjustable HR/100*((Cost of 1979-81 Adjustable HR*(MY-1969))/12 + 

(Cost of 1969 Adjustable HR*(1981-MY))/12)) 

c. For MY 1981 

(% 1969-1981 Nonadjustable HR/100 * Cost of Nonadjustable HR) + 

(% 1969-1981 Adjustable HR/100 * Cost of 1979-1981 Adjustable HR)) 

 69 Harvey, M.R., Lesczhik, J.A., and McLean, R.F., Cost Evaluation for Nine Federal Motor Vehicle Standards

Volume IV, FMVSS 202 & 207, Washington: U.S. Department of Transportation, National Highway Traffic Safety

Administration, November 1979. (DOT HS 805 318:12-15). 70 Gladstone, DOT HS 806 257:2-1 thru 2-14 (1982). 71 Gladstone, DOT HS 806 769:6-1 thru 6-2 (1982). 

50
2. Average Cost of Head Restraints (1982-2001) = 

(% 1982-2001 Nonadjustable HR/100 * Cost of Nonadjustable HR) + 

(% 1982-2001 Adjustable HR/100 * Cost of 1979-1981 Adjustable HR) 

3. Average Weight of Head Restraints (1969-1981) = 

 

a. For MY 1969 

(% 1969-1981 Nonadjustable HR/100 * Weight of Nonadjustable HR) + 

(% 1969-1981 Adjustable HR/100 * Weight of 1969 Adjustable HR) 

b. For MY 1970 through 1980 

(% 1969-1981 Nonadjustable HR/100*Weight of Nonadjustable HR) + 

 % 1969-1981 Adjustable HR/100*((Weight of 1979-81 Adjustable HR*(MY-1969))/12 + 

(Weight of 1969 Adjustable HR*(1981-MY))/12)) 

c. For MY 1981 

(% 1969-1981 Nonadjustable HR/100 * Weight of Nonadjustable HR) + 

(% 1969-1981 Adjustable HR/100 * Weight of 1979-1981 Adjustable HR) 

4. Average Weight of Head Restraints (1982-2001) = 

(% 1982-2001 Nonadjustable HR/100 * Weight of Nonadjustable HR) + 

(% 1982-2001 Adjustable HR/100 * Weight of 1979-1981 Adjustable HR) 

Table 202-3 shows the results of equations 1-4, the average weight and consumer cost of head 

restraints attributable to FMVSS 202 in passenger cars by model year. 

TABLE 202-3 

AVERAGE WEIGHT AND CONSUMER COST 

OF HEAD RESTRAINTS ATTRIBUTABLE TO FMVSS 202

IN PASSENGER CARS BY MODEL YEAR

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

1969 8.77 $38.27

1970 8.52 $37.59

1971 8.27 $36.92

1972 8.02 $36.25

1973 7.76 $35.58

1974 7.51 $34.91

1975 7.26 $34.24

1976 7.01 $33.56

1977 6.76 $32.89

1978 6.50 $32.22

1979 6.25 $31.55

1980 6.00 $30.88

1981 5.75 $30.21

1982-2001 5.63 $30.89

 

51
Light Truck Studies 

Head restraints have been required since September 1, 1991 (model year 1992) in pickup trucks, 

vans, and SUVs with a GVWR of 10,000 pounds or less. Nevertheless, head restraints or other 

devices capable of meeting FMVSS 202 (e.g., high-backed “captain’s chairs”) were already 

installed in most vans, SUVs, and some pickup trucks well before 1992, even before the 

rulemaking process that extended the standard to light trucks. That raises a question whether the 

full cost of head restraints in light trucks is attributable to FMVSS 202. To the extent that the 

standard for cars set an example for light trucks (e.g., in product liability litigation); and, since 

there was much discussion of extending the standard as early as the mid-1970’s, it seems 

appropriate to attribute all costs of head restraints in light trucks to FMVSS 202. 

Table 202-4 shows the average percentage of nonadjustable and adjustable light truck head 

restraints between 1992 and 2001. 

TABLE 202-4 

AVERAGE PERCENTAGE OF 

NONADJUSTABLE/ADJUSTABLE HEAD RESTRAINTS 

IN LIGHT TRUCKS FROM 1992 TO 2001

MODEL YEAR % NONADJUSTABLE % ADJUSTABLE 

1992-2001 55 45

A study of nine light truck head restraints was conducted to determine the weight and consumer 

cost of the head restraint systems in 1992-1994 make-model light trucks and vans.72 Four of the 

head restraints were nonadjustable while five were adjustable. Table 202-5 shows the salesweighted average weight and consumer cost of the head restraint systems. 

TABLE 202-5 

AVERAGE WEIGHT AND CONSUMER COST 

OF HEAD RESTRAINTS IN LIGHT TRUCKS 

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Nonadjustable 4.40 $29.83

Adjustable 3.47 $32.36

 

The average weight and consumer cost of light truck head restraints attributable to the standard 

was calculated using the following formulas: 

1. Average Cost of Head Restraints (1992-2001) = 

(% 1992-2001 Nonadjustable HR/100 * Cost of Nonadjustable HR) + 

(% 1992-2001 Adjustable HR/100 * Cost of Adjustable HR) 

2. Average Weight of Head Restraints (1992-2001) = 

 (% 1992-2001 Nonadjustable HR/100 * Weight of Nonadjustable HR) + 

 (% 1992-2001 Adjustable HR/100 * Weight of Adjustable HR) 

 72 Fladmark, DOT HS 809 796 (1994). 

52
Table 202-6 shows the average weight and consumer cost of head restraints attributable to 

FMVSS 202 in light trucks. 

TABLE 202-6 

AVERAGE WEIGHT AND CONSUMER COST 

OF HEAD RESTRAINTS 

ATTRIBUTABLE TO FMVSS 202 IN LIGHT TRUCKS

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

1992-2001 3.98 $30.97

FMVSS 203 – IMPACT PROTECTION FOR THE DRIVER FROM THE STEERING 

 CONTROL SYSTEM 

FMVSS 204 – STEERING CONTROL REARWARD DISPLACEMENT 

Passenger Car Studies 

FMVSS 203/204 became effective on January 1, 1968 (passenger cars) and September 1, 1981 

(multipurpose passenger vehicles, trucks, and buses). FMVSS 203 specifies requirements for 

steering control systems that yield forward, cushioning the impact of the driver’s chest by 

absorbing much of his or her impact energy in front-end crashes. FMVSS 204 specifies 

requirements limiting the rearward displacement of the steering column into the passenger 

compartment. The purpose of these standards is to provide basic occupant protection for the 

unbelted or lap-belted driver in a frontal crash and minimize chest, neck, head, or facial injuries 

from an impact. This standard applies to passenger cars, multipurpose passenger vehicles, 

trucks, and buses with a GVWR of 10,000 pounds or less.73 Since the changes made to steering 

columns typically satisfied both of these standards, this analysis is combined into one section. 

The requirements of FMVSS 203 and 204 address the hazards of a steering column in two 

different ways. FMVSS 203 requires that the impact force developed on the chest not to exceed 

a safe level of 2500 pounds from the steering column during an impact of 15 mph. This is 

accomplished by designing the column to collapse at a controlled rate upon impact. FMVSS 204 

specifies a limit of 5 inches horizontal steering column intrusion toward the driver during a headon crash into a fixed barrier at 30 mph. Essentially, FMVSS 203 addresses the driver impacting 

the steering wheel/column and FMVSS 204 is concerned with the steering column being driven 

into the interior as the front of the vehicle is crushed during a crash. A collapsible steering 

column typically satisfied both requirements. It should be noted that FMVSS 203 does not apply 

as a separate requirement to vehicles that conform to the barrier crash standards of FMVSS 208 

by means of air bags. Nevertheless, today’s vehicles equipped with air bags still have collapsible 

steering columns since this device is an important component of the safety system that makes air 

bags effective. 

Manufacturers replaced the rigid steering columns with different collapsible designs. American 

Motors, Chrysler, and General Motors had installed steering columns with the energy absorbing 

features on their 1967 models; whereas Ford, Toyota, Volkswagen, and, probably other foreignbased manufacturers introduced them in 1968. Three main components were modified to create 

 73 Legal citation: 49 CFR 571.203/204 (2004).

53
a collapsible column: the outer jacket tube, the shift tube, and the steering shaft. The outer 

jacket is the visible external tube mounted to the firewall and instrument panel that contains the 

shift tube, the steering shaft, a wiring harness, and any internal energy absorbing components. 

The shift tube transfers the rotational input from the column mounted shift lever to the bottom of 

the steering column where linkage from the transmission is connected. The shift tube is oriented 

concentrically inside the outer jacket tube. The steering shaft transfers the rotational input from

the steering wheel to the bottom of the steering column where it connects with the steering 

gearbox or an intermediate shaft. The steering shaft typically passes through the center of the 

column. 

The outer jackets were weakened by cutting longitudinal slots in them (Ford), or by replacing a 

lower part of the jacket with a tube-shaped, basket-weave section of metal mesh (GM, Chrysler,

AMC, VW, and Toyota). Later in 1969, AMC and GM started using an outer jacket composed 

of two concentric tubes, with the lower tube of a smaller diameter like a telescope. Between the 

outer diameter of the smaller tube and the inner diameter of the larger tube was a bearing sleeve 

that contained small hardened steel balls. During an impact, this outer jacket would collapse and 

absorb energy at a controlled rate as the steel balls cut grooves into the tubes. Chrysler 

maintained the basket-weave mesh design until the mid 1970’s when they started placing a 

tapered collar/mandrel at the base of the outer jacket. As the column was loaded, the outer jacket 

would peel apart as it was pressed against the outer diameter of the collar and collapse at a 

controlled rate. Chrysler also introduced a wheel canister absorption device starting with the 

1970 Dodge Challenger and Plymouth Barracuda in place of the energy-absorbing column. 

Volvo has also used wheel canisters. In 1973, Ford started installing an internally grooved 

column that uses friction between the column tubes to absorb energy. 

 

The shift tube and the steering shaft were redesigned to collapse under impact. The shift tubes 

were designed to telescopically collapse with the outer jacket. The steering shaft was changed 

from a single rigid shaft to a two or three-piece shaft. The lower section on the two-piece shaft 

and the middle section on the three-piece shaft were hollow to allow the upper shaft to collapse 

into it. 

One modification that could be attributed to FMVSS 204 was the change to the steering 

gearbox’s intermediate shafts from a rigid to a collapsible design. These intermediate shafts 

span the distance from the lower end of the steering shaft to the steering gearbox mounted on the 

front sub-frame. Initially, a coaxial design where a smaller shaft slides into a larger hollow shaft 

was used to create a collapsible intermediate shaft. With the advent of rack and pinion steering, 

when the intermediate shaft usually became too short and too vertical to accommodate the 

coaxial design, two or more universal joints were used on the intermediate shaft to allow it to 

fold upon impact. The manufacturers of the vehicles studied, in order to comply with FMVSS 

204, made no major front structural changes. 

The shear capsule, which is a bracket designed to prevent rearward movement of the column but 

to allow forward movement, is a vital partner to the steering column energy-absorbing device 

(EAD). When the lower part of the column is forced backward due to vehicle damage, the shear 

capsule holds the upper column in place while the column EAD collapses. On the other hand, 

54
when the driver contacts the steering wheel, the shear capsule freely allows the upper part of the 

column to move forward while the EAD collapses.

74 

The steering assemblies and front structures of 1969-1976 post-standard passenger cars and their 

corresponding 1966 pre-standard make-models were examined to determine the weight and 

consumer cost of equipment changes in response to FMVSS 203/204.75 Examination of the front 

structures indicated that the post-standard structures and their pre-standard counterparts were 

identical; no structural changes were made in response to the standard. Therefore, the weight 

and consumer cost estimates were based on the steering column assemblies. Three of the makemodel passenger cars in the study (Rambler American, Volkswagen Beetle, and Toyota Corona) 

were not included in these estimates because there were no corresponding pre-standard model by 

the same manufacturer, so the weight and consumer cost added by the standard could not be 

accurately estimated. Furthermore, the steering column assembly of the 1968 Volkswagen 

Beetle used a simple mesh design that was soon modified and not a “typical” mesh-type column. 

The cost analysis is subdivided into two sections: 

• the steering assembly within the passenger compartment 

• the steering assembly within the engine compartment 

The best estimate of the weight and consumer cost changes within the passenger compartment 

are obtained by subtracting the weight and consumer cost of the corresponding pre-standard 

steering column assembly from the weight and consumer cost of the post-standard steering 

column assembly. This cost analysis is based on six make-models where teardowns were 

performed on the 1969 and 1966 steering assemblies. The average incremental weight and 

consumer cost attributed to the standard is 1.89 pounds and $24.00 in 2002 dollars. 

Within the engine compartment, an intermediate shaft is used between the steering column

assembly and the steering gearbox in some cars with a forward-mounted steering gearbox. The 

engine compartment telescoping device, which was installed for the purpose of complying with 

FMVSS 204, was sometimes located on the intermediate shaft. Telescoping post-standard and 

rigid pre-standard intermediate shafts were examined. The post-standard shaft was found to cost 

$8.85 more in 2002 dollars and weigh about the same as the pre-standard design. This device is 

used in 39 percent of all passenger cars76, so the average cost per car is $3.45 in 2002 dollars. 

Table 203/204-1 shows the average weight and consumer cost of steering assemblies attributable 

to FMVSS 203/204 in passenger cars. 

 74 Kahane, C.J., An Evaluation of Federal Motor Vehicle Safety Standards for Passenger Car Steering 

Assemblies, Standard 203 – Impact Protection for the Driver, Standard 204 – Rearward Column Displacement, 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, January 1981. 

(DOT HS 805 705:90). 75 McLean, R.F., Eckel, C.E.B., and Lesczhik, J.A., Cost Evaluation for Three Federal Motor Vehicle Standards 

FMVSS 203, 204, and 212, Washington: U.S. Department of Transportation, National Highway Traffic Safety

Administration, May 1980. (DOT HS 805 602:5-32). 76 Kahane, DOT HS 805 705:90 (1981).

55
TABLE 203/204-1

AVERAGE WEIGHT AND CONSUMER COST 

OF STEERING ASSEMBLIES IN PASSENGER CARS 

ATTRIBUTABLE TO FMVSS 203/204

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Passenger 1.89 $24.00

Engine 0.00 $ 3.45

TOTAL 1.89 $27.45

An additional study was conducted on model-year 1983 passenger cars to determine the trend in 

weight and consumer cost of their steering column systems.77 The entire sample of passenger 

cars studied had made extensive changes since the original post-standard vehicles. Unlike the 

1968 and 1969 vehicles studied, every 1983 model-year passenger car studied used an 

intermediate steering shaft and two universal joints, which are necessary components of a rack 

and pinion steering system. 

The design of the trend steering columns was affected in several ways by “downsizing”. Eight 

of the twelve 1983 vehicles studied used rack and pinion steering in place of the traditional worm

and re-circulating ball gearbox type steering system. The downsized cars of 1983 were shorter in 

length from the windshield base to the front of the car; consequently, they had less room to 

package a steering system. Rack and pinion steering systems were mounted much closer to the 

firewall than the older systems with the steering gearbox located ahead of the front axle 

centerline. A steep angle resulted when the intermediate shaft was linked from the end of the 

steering column to the drive flange on the steering rack. This steep angle necessitated the use of 

universal joints on the ends of the intermediate shafts to allow the intermediate shaft to fold 

under impact. The universal joints added considerable cost to the intermediate shaft. A cheaper 

coaxial shaft would not function at these steep angles. The cost of the trend steering column was 

also affected by the increased use of floor shifts. Four of the vehicles studied used a floor shift 

for the transmission, eliminating the column shift tube altogether. The modest net overall 

decrease in weight and consumer cost of the trend steering columns, as compared to those of the 

standard year, are primarily the result of the trend steering columns being simpler and smaller. 

The various cost increasing and cost-savings factors essentially cancelled each other out, 

resulting in about the same net cost as in earlier years. 

Table 203/204-2 shows the sales-weighted average weight and consumer cost of steering column

assemblies for the pre-standard, standard, post-standard, and trend system passenger cars. It is 

important to note that there has been relatively little change to the weight and consumer cost 

between 1967 and 1983. Unlike Table 203/204-1, Table 203/204-2 computes the average total 

weight and consumer cost for all specimen vehicles in each model year group rather than the 

average incremental weight and consumer cost for matching make-models only (because the 

1983 specimens did not match the earlier make-models). 

 77 Osen, DOT HS 806 771 (1985). 

56
TABLE 203/204-2

AVERAGE TOTAL WEIGHT AND CONSUMER COST 

OF STEERING COLUMN ASSEMBLIES 

IN PASSENGER CARS BY MODEL YEAR 

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

1966 (Pre-Standard) 9.94 $24.37

1967-1968 (Standard) 10.90 $43.49

1969-1976 (Post-Standard) 12.41 $47.16

1983 (Trend) 11.90 $44.42

Table 203/204-3 shows the breakout of the weight and consumer cost of the different steering 

column designs. All six major energy absorbing design types are represented, as are the three 

largest U.S. auto manufacturers (Chrysler, Ford, and GM). Furthermore, there are multiple data 

points for the three most common energy absorbing design types (mesh, ball, and slotted 

columns)78. Based on limited study samples, it appears that the costs of the various alternative 

collapsible column designs were fairly similar. 

TABLE 203/204-3

AVERAGE INCREMENTAL WEIGHT AND CONSUMER COST 

BY STEERING COLUMN DESIGN FOR

STEERING COLUMN ASSEMBLIES IN PASSENGER CARS 

(INCREASE RELATIVE TO MATCHING 1966 PRE-STANDARD ASSEMBLIES)

DESIGN TYPE WEIGHT IN POUNDS CONSUMER COST ($2002) 

Mesh 1.59 $23.27

Ball 1.06 $16.27

Slotted 1.30 $17.01

Grooved 0.53 $19.92

Slotted/Mandrel 0.62 $24.12

Wheel Canister 1.52 $21.24

Light Truck Studies 

FMVSS 203 and 204 were effective for light trucks on September 1, 1981. However, collapsible 

steering columns had already been installed in pickup trucks and multipurpose passenger 

vehicles from AMC, Chrysler, and GM at least three years before the standard was effective (as 

early as 1973 in Jeeps and GM pickup trucks). Collapsible steering columns were lacking 

mostly in full-sized vans with “forward control” steering systems where the more vertical angle 

of the column made it difficult to implement an energy-absorbing system. 

Unlike passenger cars, NHTSA has not performed teardowns of complete steering assemblies in 

post-standard and matching pre-standard make-models of light trucks. However, steering 

columns with intermediate shafts from seven 1982 post-standard make-model light trucks and 

vans were torn down to determine their weight and consumer cost.79 The contractor also 

 78 Kahane, DOT HS 805 705:90 (1981). 79 Gladstone, DOT HS 806 769:5-1 thru 5-13 (1982). 

57
estimated (without actual teardown) how much these columns would have cost if they had been 

rigid one-piece designs typical of pre-standard vehicles. 

Table 203/204-4 shows the sales-weighted average weight and consumer cost of a steering 

column without energy absorbing columns (hypothetical estimate) and one with energy 

absorbing columns (actual teardown). The figures include the complete steering column and 

intermediate shaft, but not the steering wheel. 

TABLE 203/204-4

ESTIMATED AVERAGE WEIGHT AND CONSUMER COST 

OF STEERING COLUMNS IN LIGHT TRUCKS

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Without Energy Absorbing Columns 10.13 $24.86

With Energy Absorbing Columns 10.76 $35.25

Estimated Incremental Weight & Cost 0.63 $10.39

 

The estimate in Table 203/204-4 is lower than the estimate for passenger cars (1.89 pounds and 

$27.45 in Table 203/204-1). The estimate for passenger cars is based on actual teardowns of 

matching pre- and post-standard specimens and considers the entire steering assembly; therefore, 

we believe it to be a more reliable estimate than Table 203/204-4, and we shall use it as our 

estimate for light trucks as well. 

Even though collapsible steering columns and intermediate shafts had been in some pickup 

trucks and SUVs well before model year 1982, it is appropriate to attribute their weight and 

consumer cost to FMVSS 203 and 204 because the installation of these components took place 

after the standards became effective for passenger cars. With light truck steering columns being 

very similar to those of passenger cars, some of the manufacturers went ahead with the 

installation of these components to increase the safety of their light trucks. Therefore, one 

impetus for installing collapsible columns and intermediate shafts in light trucks was the earlier 

requirement of FMVSS 203 and 204 for passenger cars. Table 203/204-5 shows the salesweighted average weight and consumer cost of steering column assemblies attributable to 

FMVSS 203 and 204 in light trucks. 

TABLE 203/204-5

AVERAGE WEIGHT AND CONSUMER COST 

OF STEERING COLUMN ASSEMBLIES 

ATTRIBUTABLE TO FMVSS 203/204 IN LIGHT TRUCKS 

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

1982-2001 1.89 $27.45

 

FMVSS 205 – GLAZING MATERIALS 

FMVSS 205 became effective on January 1, 1968 and specifies requirements for glazing 

materials for use in motor vehicles and motor vehicle equipment. The purpose of this standard is 

to: 

• reduce injuries resulting from impact to glazing surfaces 

• ensure a necessary degree of transparency in motor vehicle windows for driver visibility 

58
• minimize the possibility of occupants being thrown through the vehicle windows in 

collisions. 

This standard applies to glazing materials for use in passenger cars, multipurpose passenger 

vehicles, trucks, buses, motorcycles, slide-in campers, and pickup covers designed to carry 

persons while in motion.80

Essentially, FMVSS 205 required that glazing materials used for windshields, windows, and 

interior partitions meet the requirements outlined in the industry’s American National Standard 

Institute (ANSI) Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating 

on Land Highways, Z-26.1 as issued in 1966. (The requirements were subsequently revised in 

Z26.1-1977, January 26, 1977, as supplemented by Z26.1a, July 3, 1980.) ANSI Z26.1 outlines 

the requirements for all vehicle safety glazing materials, which include safety glass, safety 

plastic, multiple glazed units (two or more sheets of glazing separated by an air space), and 

bullet-resistant glazing. The standard specifies which type of glazing material can be in vehicle 

locations where driving visibility is required and not required. For passenger cars and light 

trucks, the industry used tempered glass for side and rear windows and laminated glass for 

windshields, although the standard allowed the use of other glazing materials in these locations 

as long as they met the material test requirements described in the standard. 

ANSI Z26.1 defines tempered glass as a single sheet of specially treated (heat or chemically 

treated) plate, sheet, or float glass. It cannot be cut, drilled, or polished after treatment. When it 

is broken at any point, the entire piece immediately breaks into innumerable small pieces, which 

may be described as granular, usually with no large jagged edges. Tempered glass for use in 

locations other than windshields must pass tests for light stability, luminous transmittance, 

humidity, boil, ball impact, fracture, shot bag impact, and abrasion resistance. Tempered glass 

had been in use for many years before FMVSS 205, and the standard has not imposed any cost 

increases with its use. 

ANSI Z26.1 defines laminated glass as two or more sheets of glass held together by a layer(s) of 

plastic material. Under impact, laminated glass will crack or break but the pieces do not fly and 

the edges of holes are less jagged than ordinary glass. In addition to the tests required of 

tempered glass, laminated glass must also pass tests for deviation/distortion and penetration 

resistance. 

Before model year 1966, the standard windshield for domestic cars was composed of a 0.015-

inch layer of polyvinyl butyral tightly bonded between two 0.125-inch layers of plate glass. 

Tests in the industry indicated that the plastic interlayer did not stretch more than the glass before 

the tight bond between the plastic and the glass caused tearing. Consequently, the plastic 

interlayer was easily torn by broken glass, allowing an occupant’s head to tear through the 

windshield in low speed crashes causing disfiguring or disabling head injuries associated with 

windshield contact. In the early 1960’s, it was discovered that a looser bond between the plastic 

and glass layers could be obtained by increasing the moisture content of the polyvinyl butyral, 

which set the stage for the development of improved windshields. In 1962, SAE requested glass 

companies develop a safer windshield, and the High Penetration Resistant (HPR) windshield was 

 80 Legal citation: 49 CFR 571.205 (2004). 

59
the response to that request.81 The penetration resistance requirement was SAE standard J938, 

and first published in October 1965. FMVSS 205, effective in January 1968, was based largely 

on earlier SAE and ANSI standards; the installation of HPR windshields was the primary vehicle 

modification associated with those standards. 

High Penetration Resistant Windshield (HPR). The new HPR windshield consisted of a 0.030-

inch advanced plastic interlayer bonded to two glass plies by a special adhesive that permitted 

the plastic to slide along the glass and not delaminate or discolor. In 1965, the domestic 

manufacturers installed HPR windshields, on an experimental basis, in a few models. By 1966, 

every automobile manufacturer in the United States and Canada adopted the new HPR 

windshield with the 1966 model-year passenger car. These windshields remained unchanged 

until 1977 when thinner lights of glass (0.105-0.115 inch) were used to support vehicle 

downsizing.82

A study was conducted to determine the weight and consumer price differential between the pre1966 glazing and the FMVSS 205 HPR windshield and tempered side and rear windows of 1969 

model-year passenger cars. The only variance in the windshield between the pre-standard and 

the HPR standard was the increase in thickness of the plastic interlayer from 0.015-inch to 0.030-

inch and the use of an improved adhesive bonding material.83 A representative sample of major 

domestic and foreign manufacturers was examined, and the sales-weighted average weight and 

consumer cost increase of an HPR windshield was calculated at 1.07 pounds and $7.57 in 2002 

dollars. It is understood that the increase in weight and consumer cost is proportional with the 

surface area of the windshield; i.e., as vehicle size increases, the weight and consumer cost of the 

HPR windshield increases. 

HPR windshields were installed in all domestic vehicles for the 1966 model year in response to 

industry and SAE initiatives that preceded any Federal regulatory process, plus the majority of 

imported cars used an HPR windshield starting with the 1967 model year. Therefore, the added 

weight and consumer cost is not attributed to FMVSS 205. The Federal standard essentially 

codified existing industry practices, and these practices were developed before the Federal 

government began to regulate motor vehicle safety. 

Glass-Plastic Windshields. FMVSS 205 was amended in 1983 to permit, but not require, the use 

of glass-plastic glazing material at the option of the motor vehicle manufacturer. Glass-plastic 

windshields were thought to further reduce (over HPR windshields) occupant lacerations from

impact with the windshield. This new windshield was essentially an HPR windshield with a 

layer of polyurethane bonded to the glass surface that faces the vehicle interior. This layer 

would provide a barrier that would prevent an occupant from contacting the broken shards of 

glass 

 81 Kahane, C.J., An Evaluation of Windshield Glazing and Installation Methods for Passenger Cars, 

Washington: Department of Transportation, National Highway Traffic Safety Administration, 1985. (DOT HS 806

693). 

82 Gladstone, DOT HS 806 769:7-1 thru 7-14 (1982). 83 Ibid. 

60
during an impact.84 At the time of the amendment, the potential drawbacks of a glass-plastic 

windshield were thought to be: 

• The lower abrasion resistance of the inside plastic layer could lead to degraded visibility 

and a shorter windshield “lifespan”, which would increase vehicle operation cost. 

• The windshield is stiffer (four plies) and could contribute to a higher incidence of blunt 

impact injuries. 

• The additional cost of a glass-plastic windshield on a new vehicle was estimated to be 

between $38 and $45 as compared to an HPR windshield.85

• Attachment of the rearview mirror to the plastic with adhesive was not practical. Other 

mounting schemes were needed. 

• Attachments and removal of decals to the inside of the windshield may result in localized 

scratches and haze. 

In the early 1980’s, Ford and GM installed glass-plastic windshields in rental vehicles for fieldtesting; however, the durability of these windshields in the real world was less than expected. 

The plastic inner liner was susceptible to damage (i.e., cuts, scratches) from the everyday 

operating environment. In 1984, GM installed the glass-plastic windshields as standard 

equipment in one of its luxury car models, the Cadillac Seville Elegante. By model years 1986 

and 1987, GM had made these windshields standard equipment on approximately 210,000 cars.86

The actual cost of glass-plastic windshields in use was greater than estimated in the 1983 

amendment. The estimated cost increase of a glass-plastic windshield in 1983 was between $63 

and $75 in 2002 economics. This estimate was from the sole supplier of glass-plastic glazing at 

the time and was based on a production volume of 500,000 to 1,000,000 units annually. In 

reality, much lower production volumes resulted in higher costs. After the 1987 model year, GM 

no longer installed glass-plastic windshields in any vehicles due to high warranty and 

replacement costs, and no other domestic or import automaker has used them in their U.S. 

market vehicles since. 

FMVSS 206 – DOOR LOCKS AND DOOR RETENTION COMPONENTS 

FMVSS 206 became effective on January 1, 1968 (passenger cars), January 1, 1970 

(multipurpose passenger vehicles), and January 1, 1972 (trucks) and specifies requirements for 

door locks and door retention components including latches, hinges, and other supporting means. 

The purpose of this standard is to minimize the likelihood of occupants being thrown from the 

vehicle as a result of impact. This standard applies to passenger cars, multipurpose passenger 

vehicles, and trucks.87

 84 Parsons, G.G., An Evaluation of the Effects of Glass-Plastic Windshield Glazing in Passenger Cars, 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, November 1993. 

(DOT HS 808 062). 85 Final Regulatory Evaluation Anti-Lacerative Glazing FMVSS 205, Washington: U.S. Department of

Transportation, National Highway Traffic Safety Administration, September 1983, pg. IV-2. 86 Parsons, DOT HS 808 062, (1983). 87 Legal citation: 49 CFR 571.206 (2004). 

61
Side Door Components. Door latches were required to have a fully latched position and a 

secondary latched position, which were required to withstand a 2,500-pound longitudinal load in 

the fully latched position and 1,000 pounds in the secondary latched position. In the transverse 

direction, the latch must withstand a 2,000-pound load when fully engaged and a 1.000-pound 

load in the secondary latched position. Door latches were also required not to move from the 

fully engaged position when a longitudinal or transverse inertial load of 30g was applied to the 

door latch system. Similarly, door hinges were required to sustain loads of 2,500 pounds 

longitudinal and 2,000 pounds transverse without failure. 

FMVSS 206 had a regulatory history that began before NHTSA was founded. Specifically, it 

incorporated two SAE standards developed by the domestic auto industry. The standard 

gradually evolved and became stronger throughout 1962-1969. The manufacturers who often 

anticipated the regulations and steadily improved their door locks throughout 1956-1969 

voluntarily implemented most of these improvements.88 Therefore, no cost studies have been 

performed on door latches, hinges, and other retention components for side doors, and none are 

planned by the agency. 

Back Door Components. In 1995, a final rule amending FMVSS 206 was published that 

extended the side door requirements to the back doors of passenger cars and multipurpose 

passenger vehicles. This ruling affected hatchbacks, stations wagons, SUVs, and passenger vans 

with a GVWR of 10,000 pounds or less. Sixty percent of the affected vehicles were required to 

comply by September 1, 1997, with 100 percent by September 1, 1998. The 

intent of the amendment is to prevent occupant ejections from vehicles equipped with back 

doors. 

In March 1994, NHTSA published a press release warning owners of minivans and other 

vehicles with hatchbacks that these doors can open unexpectedly in a crash and unbelted 

occupants can be ejected. A cost and weight analysis was performed on latch/striker assemblies 

from the back doors of two 1993 (pre-standard) minivans.89 One of the assemblies met the side 

door latch strength requirements of FVMSS 206 while the other did not. The latch/striker 

assembly that passed the 206 testing weighed 0.86 pounds and cost an estimated $3.31 in 2002 

dollars, while the latch/striker assembly that failed weighed 0.90 pounds and cost an estimated 

$4.56 in 2002 dollars. A comparison of the test results and cost analysis leads to the conclusion 

that a latch/striker that meets the requirements of FMVSS 206 in this case did not cost more than 

a latch/striker that does not meet the standard. Therefore, an increase in the weight and 

consumer cost of back door latches has not been attributed to the standard. However, a more 

detailed teardown analysis of a representative sample of pre- and post-standard make-models 

would be needed to confirm this initial “no-cost” estimate. 

 88 Kahane, C.J., An Evaluation of Door Locks and Roof Crush Resistance of Passenger Cars – Federal Motor

Vehicle Safety Standards 206 and 216, Washington: U.S. Department of Transportation, National Highway Traffic 

Safety Administration, November 1989. (DOT HS 807 489:3-4). 89 Rutland, K.W. and Spinney, B.C., A Cost and Weight Analysis of MY93 Minivan Rear Door Latch and Striker 

Sets, Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, May 1994.

62
FMVSS 207 – SEATING SYSTEMS 

FMVSS 207 became effective on January 1, 1968 (passenger cars) and January 1, 1972 

(multipurpose passenger vehicles, trucks, buses) and specifies requirements for seats, their 

attachment assemblies, and their installation. The purpose of this standard is to minimize the 

possibility of their failure by forces acting on them as a result of vehicle impact. This standard 

applies to passenger cars, multipurpose passenger vehicles, trucks, and buses.90

The standard requires that each occupant seat installation, except for folding auxiliary jump seats 

and side-facing seats, shall withstand a load of twenty times the weight of the seat in a forward 

and rearward longitudinal direction and withstand a 3,300 inch pound moment about the seat’s 

“H” point (location, when viewed from the side, where an occupant’s hips would reside when 

sitting in the seat). Folding and hinged seats are required to have a self-locking restraining 

device for the seatback with a release control to allow the seatback to be folded forward. The 

restraining device must preclude inertial release when subjected to a 20g longitudinal load. 

Additionally, the restraining device must withstand a forward longitudinal load of twenty times 

the weight of the seatback applied to the center of gravity of the seatback without failing or 

releasing. 

FMVSS 207 is essentially associated with one tangible vehicle modification: the introduction of 

seat back locks in the folding front seatbacks of passenger cars with two doors. Folding and 

hinged seats were not necessary in four-door vehicles. On average, 41 percent of the vehicles 

sold in the United States from 1968 to 2001 were two-door vehicles. On a model year basis, the 

percentage of two-door cars sold has ranged from a high of 66 percent in 1974 to a low of 19.5 

percent in 2001. 

Seat mounting assemblies and floor panels on twelve 1969 model year U.S. manufactured 

passenger cars were examined to determine the impact of FMVSS 207. There were no apparent 

modifications to the seat mounting assemblies or the floor panels under the seats on any of the 

vehicles examined. The manual seat back locks from four 1969 model year two-door passenger 

cars (Ford Mustang, Ford Thunderbird, Chevrolet Nova, and Pontiac Firebird) were examined to 

determine their cost and weight.91 The results of the first three cars were reasonable and 

consistent, especially since the Mustang had a simpler lever for operating the seat back lock than 

did the Thunderbird and Nova. The much lower results for the Firebird were anomalous, 

especially since the photographs suggested it had almost the same hardware as the Mustang. In 

addition, the report gave two conflicting values for added weight intimating that the cost 

estimates for the Firebird were incorrectly calculated or transcribed in several categories. Only

the results for the first three vehicles were used for computing the average. Automatic (inertial) 

seat back locks from three 1986 model year passenger cars (Chevrolet Camaro, Dodge 400, and 

Ford Tempo) were also studied.92 

 

Seat back locks were implemented at General Motors in 1967 and at Ford and Chrysler in 1968. 

In addition, Volkswagen and Opel contained seat back locks by 1966 and Fiat, Renault, Datsun, 

 90 Legal citation: 49 CFR 571.207 (2004). 91 Harvey, DOT HS 805 318:16-19 (1979). 92 Carlson, DOT HS 807 017:56-67 (1986). 

63
and Sunbeam by 1967.93 Initially all seat back locks were the manual type. Persons desiring to 

enter the back seat of a two-door car could not fold over the front seatback until they disengaged 

the lock by operating a lever or pressing a button. Around 1980, the domestic manufacturers 

switched to automatic inertial seatback locks, which operate much like inertial safety belt 

retractors. The front seatback folds over freely except during the moments when the car is 

subjected to decelerations by impacts, road bumps, or emergency braking. During a frontal 

crash, an inertial mechanism automatically locks the seatback in place. 

Table 207-1 shows the arithmetic average weight and consumer cost of manual and automatic 

seat back locks for two-door passenger cars. On average, the automatic seat back locks weighed 

more than, and cost about the same as, the manual locks. Since seat back locks were an addition 

to the seat, their weight and consumer cost is attributed to FMVSS 207 but only in two-door 

passenger cars. The cost of manual seat back locks will be used for model years 1968-1979, 

while the cost of automatic seat back locks will be used for model years 1980-2001. 

TABLE 207-1 

AVERAGE WEIGHT AND CONSUMER COST 

OF SEAT BACK LOCKS IN TWO-DOOR PASSENGER CARS 

ATTRIBUTABLE TO FMVSS 207

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Manual (1968-1979) 3.07 $16.53

Automatic (1980-2001) 3.96 $16.13

FMVSS 208 – OCCUPANT CRASH PROTECTION 

FMVSS 209 – SEAT BELT ASSEMBLIES 

FMVSS 210 – SEAT BELT ASSEMBLY ANCHORAGES 

FMVSS 208 became effective on January 1, 1968 (passenger cars) and July 1, 1971 

(multipurpose passenger vehicles, trucks, buses). It was the basic crash protection standard and 

initially defined the requirements for the installation of safety belts in passenger cars. The 

standard was amended to specify performance requirements for anthropomorphic test dummies 

seated in the front, outboard seats of passenger cars and certain multipurpose passenger vehicles, 

trucks, and buses for manual and automatic restraint systems. It subsequently required and set 

performance levels for automatic crash protection, especially air bags. 

FMVSS 209 became effective on January 1, 1968 and specifies requirements for safety belt 

assemblies. The requirements apply to: 

• straps, webbing, or similar material, 

• all necessary buckles and other fasteners, 

• all hardware designed for installing the assembly in a motor vehicle, and 

• installation, usage, and maintenance instructions for the assembly. 

 93 Costenoble, K. and Northrop, G.M., Review of Nine Federal Motor Vehicle Safety Standards. Report No. 

4238/4239-601. Hartford: Center for the Environment and Man, 1978, pp.49-50. 

64
FMVSS 210 became effective on January 1, 1968 (passenger cars) and July 1, 1971 

(multipurpose passenger vehicles, trucks, and buses) and establishes requirements for safety belt 

assembly anchorages. The purpose of this standard is to ensure proper location for effective 

occupant restraint and to reduce the likelihood of failure. The requirements apply to any 

component, other than the webbing or straps, involved in transferring safety belt loads to the 

vehicle structure. 

The purpose of FMVSS 208/209/210 is to reduce the number of fatalities and the number and 

severity of injuries to occupants involved in frontal crashes. These standards apply to passenger 

cars, multipurpose passenger vehicles, trucks, and buses.94 Since FMVSS 209 and 210 support 

the hardware requirements of FMVSS 208, these standards have been combined into this 

analysis with FMVSS 208. 

The following technologies have been employed over the years to meet the requirements of 

FMVSS 208: 

• Manual belts are safety belts that will provide protection in a crash if occupants buckle 

up.95 Manual belts can be lap belts that fit around the pelvic region or combined/separate 

lap and shoulder belts. Manual lap/shoulder belts are now equipped with inertia reels that 

allow the belt webbing to play out so that the occupant can reach forward freely in the 

occupant compartment under normal conditions, but lock the belt in place in a crash. To 

remind occupants to use their belts, FMVSS 208 requires the installation of a brief (4-8 

seconds) audible and visible reminder. The following are types of manual belts: 

o Manual lap belts with manual adjustment (airline style), simple retractors, or 

locking retractors 

o Separate manual lap belts and shoulder harnesses, with manual adjustment or 

simple retractors on the lap belt, and manual adjustment on the shoulder harness 

o Manual 3-point belts, combining the lap belt and shoulder harness into a single 

device, with locking retractors 

• Automatic belts are similar in many respects to manual belts but differ in that they are 

attached at one end between the seats in a two front-seat car and at the other end to the 

interior of the door, or in the case of a belt with a motorized anchorage, to the doorframe. 

The belt moves out of the way when the door is opened and automatically moves into 

place around the occupant when the door is closed. Thus, the occupant need take no 

action to gain the protective benefits of the belt. The following are types of automatic 

belts: 

o Motorized torso belts with manual lap belts 

o Non-motorized automatic torso belts with manual lap belts and/or knee bolsters 

o Door-mounted, automatic 3-point belts 

 94 Legal citation: 49 CFR 571.208/209/210 (2004). 95 In some of the earlier literature, manual belts are called “active” restraints, while automatic belts and air bags

are called “passive” restraints. 

65
• Frontal air bags are fabric cushions that are very rapidly filled with gas to cushion the 

occupants against colliding with the vehicle interior when a crash occurs that has a frontal 

deceleration strong enough to register on a sensor device in the vehicle. When such a 

crash is sensed, there is rapid generation or release of gas to inflate the bag. After the 

crash, the bag quickly deflates to permit emergency egress. Beginning in 1996, other 

types of air bags such as side air bags or head curtains have been installed, but FMVSS 

208 regulates only frontal air bags. Frontal air bags are broken down into two categories: 

o Driver air bags 

o Dual air bags (driver and right-front passenger) 

The weight and consumer cost of the various safety belt systems, along with safety belt assembly 

anchorages, in passenger cars were studied and are presented in the following sections. 

Passenger Car Studies 

Safety Belts 

Manual Front Outboard Safety Belts Without Retractors. Passenger cars employed lap belts as 

the occupant protection system for many years prior to the implementation of FMVSS 208. 

Safety belt systems prior to 1968 were manually adjusted, airline style. Manual lap belts were 

believed to be highly effective not only for preventing occupant ejection from the vehicle in 

crashes but also for preventing harmful occupant contacts with interior vehicle components. 

They were installed initially at the front-outboard positions. 

Crash investigation and biomechanics research demonstrated that a lap belt alone was 

insufficient for restraining an occupant’s head and upper torso from injurious contact with the 

vehicle’s interior, especially in frontal crashes, and might even result in a harmful concentration 

of force on the abdomen. A shoulder harness was needed in addition to the lap belt to limit the 

forward motion of the upper body. 

The original FMVSS 208 required a lap (Type 1) safety belt at all designated seating positions

and a lap/shoulder safety belt at the front outboard seating positions if the windshield header was 

a potential head impact area for a lap-belted dummy. Vehicle manufacturers began installing 

lap/shoulder belts in the front outboard positions by January 1, 1968 or earlier. The domestic 

and Japanese manufacturers largely used separate lap belts and torso belts for these front 

outboard positions. Crash data and observational surveys soon indicated that few occupants 

fastened both belts, and most did not bother using the shoulder harness. This shortcoming was 

remedied with the development of integral 3-point (Type 2) belts, which were used primarily by 

the European manufacturers. These safety belts were manually adjustable. The integral 3-point 

belts became, and are still today, the primary component of the occupant protection system. 

They are highly effective in saving lives and preventing serious injuries in rollovers, frontal 

crashes, and many types of side impacts. 

66
A cost and weight analysis was performed on three lap belt systems and one separate 

lap/shoulder belt without retractors.96 NHTSA did not cost analyze any of the early European 

integral 3-point belt systems, which were present in fewer than ten percent of new cars in the 

United States. They are assumed to have approximately the same weight and consumer cost as 

the early separate lap/shoulder belts. Since the lap belt systems studied ranged over several 

model years, we took the arithmetic average of their weights and costs. 

A cost and weight analysis was also performed on safety belt assembly anchorages in passenger 

cars.97 Table 208-1 shows the average weight and consumer cost per seat for the manual front 

outboard safety belts without retractors, plus the seat belt assembly anchorages. 

TABLE 208-1 

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

OF MANUAL FRONT OUTBOARD SAFETY BELTS 

WITHOUT RETRACTORS IN PASSENGER CARS 

BELT ASSEMBLIES WEIGHT IN POUNDS CONSUMER COST ($2002) 

Lap Belt Only 2.38 $20.99

Separate Lap/Shoulder Belt 2.95 $22.61

3-Point Belt (1966-1971) 2.95 $22.61

Manual Front Outboard Safety Belts With Retractors. Manually adjusting the belt systems was 

considered inconvenient, especially when people of different sizes took turns driving the same

car. The belt was not adjusted to fit the size of the person driving, which in many cases resulted 

in a loose-fitting belt making it less effective. In order to eliminate the loose fit and the 

inconvenience of manual adjustment, retractors were added to the safety belt systems. Retractors 

are a device for storing part or all of the webbing in a safety belt assembly. However, the belts 

became uncomfortably tight and restricted the freedom of motion needed for driving. A major 

improvement was the inertia reel or emergency locking retractor. It allowed the belt to spool out 

freely and retract when an occupant moved forward and backward in the seat during normal 

vehicle operation, but it locked the belt in place upon sensing a crash. 

Beginning in January 1972, FMVSS 208 offered three options to meet its requirements for an 

occupant restraint system.98

 

• Option 1 – Meet the injury protection criteria of the standard by automatic means in 

frontal and front angular crash test, or provide either (1) automatic crash protection in a 

lateral and rollover crash test or (2) manual lap belt or combination of a manual 

lap/shoulder belt at each seating position. 

• Option 2 – Meet the injury protection criteria of the standard by automatic means in a 

frontal crash test, and provide a manual lap belt or a combination of a manual 

lap/shoulder belt for each seating position. 

 

 96 McLean, R.F., Eckel, C.E., and Cowan, D., Cost Evaluation of Four Federal Motor Vehicle Standards,

Volume I, Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, 

October 1978. (DOT HS 803 871:88-103) 97 Osen, DOT HS 806 772 (1985). 

98 Federal Register, Vol. 36, No. 47, pg. 4600. 

67
• Option 3 – Provide, at each front outboard-designated seating position, a Type 2 belt and 

at other seating positions either a Type 1 or Type 2 belt. 

In addition, each belt system must have a belt warning system that operates a continuous or 

flashing light and a buzzer for 4-8 seconds when the car is started and the driver’s belt is not 

used.99 All belts must have an emergency release mechanism that is readily accessible to an 

occupant. Manual belts must be equipped with a push button release. 

Vehicle manufacturers chose the third option by employing Type 2 belts in the front outboard 

positions and Type 1 belts in the other positions. The domestic and Japanese manufacturers kept

the lap/detachable torso belts for the front outboard positions and added retractors. The 

European manufacturers stayed with the integral lap/shoulder belts for the front outboard 

positions and added retractors. 

Starting with model year 1974, the detachable torso belt was no longer allowed for the front 

outboard seating positions under the third option. Only a Type 2 belt, with integral lap and 

shoulder belt was allowed.100 By model year 1978, features like dual retractors (one for the lap 

belt and one for the torso belt) were introduced to improve the ease-of-use and performance of 

front safety belts. 

A series of cost and weight analyses were performed on two separate lap/shoulder belts and 20 

integral 3-point safety belts used to satisfy the third option in FMVSS 208.101,102,103,104,105

 99 From January 1, 1972 to August 31, 1973, a continuous light and buzzer were required. From September 1, 

1973 to October 29, 1974, an ignition interlock system was required, whereby front outboard belts had to be buckled 

before a car could be started. The ignition interlock requirement was revoked on October 29, 1974, and the 4-8

second warning system replaced the persistent warning system. We did not obtain a cost estimate for the ignition 

interlock system. 100 Under the first two options, a Type 1 belt was permissible if the vehicle could meet the frontal crash test

requirement. 101 McLean, DOT HS 803 871:88-103 (1978). 102 Gladstone, DOT HS 806 257:3-1 thru 3-59 (1982). 103 Fladmark, G.L. and Khadilkar, A.V., Cost Estimates of Manual & Automatic Crash Protection Systems (CPs) 

in Selected 1988-1992 Model Year Passenger Cars Brake Systems, Volumes I-IV. Washington: U.S. Department of 

Transportation, National Highway Traffic Safety Administration, September 1992. (DOT HS 807 949-952). 104 Fladmark, G.L. and Khadilkar, A.V., Cost Estimates of (1) Side Impact Crash Protection of 1994-95 vs. 1993-

94 Model Year Passenger Cars; (2) Automatic Crash Protection of 1995 Model Year Pickup Trucks, Vans, and

Multipurpose Passenger Vehicles; and (3) Automatic Crash Protection of Two 1995 Model Year Passenger Cars, 

Volume I, Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, 

September 1996. (DOT HS 809 798). 105 Fladmark, G.L. and Khadilkar, A.V., Cost Estimates of (1) Side Impact Crash Protection of 1993-95 vs. 1996

Model Year Passenger Cars; (2) Automatic Crash Protection of 1996 Model Year Pickup Trucks, Vans, and

Multipurpose Passenger Vehicles; and (3) Automatic Crash Protection of Two 1996 Model Year Passenger Cars, 

Volumes I-II, Washington: Department of Transportation, National Highway Traffic Safety Administration, 

September 1997. (DOT HS 809 801: Section 4 and DOT HS 809 802: Section 6). 

68
Table 208-2 shows the arithmetic average weight and consumer cost per seat for the manual 

front outboard safety belts with retractors. 

TABLE 208-2 

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

OF MANUAL FRONT OUTBOARD SAFETY BELTS 

WITH RETRACTORS IN PASSENGER CARS 

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

Separate Lap/Shoulder Belt

1972-1973 4.52 $32.42

Integral 3-Point Belt 

1974 4.60 $36.60

1979-1981 5.82 $36.50

1988-1996 4.99 $31.68

GRAND AVERAGE OF 

INTEGRAL 3-POINT BELT 5.18 $33.35

The sample of integral 3-point safety belts represented different eras in passenger cars. The 

weight and consumer cost has remained fairly steady over the years. Consequently, a grand 

average of the weight and consumer costs of the integral 3-point safety belts in the five studies of 

1974-1996 passenger cars has been calculated and used for the integral 3-point safety belts from

1972-2001. 

Automatic Front Outboard Safety Belts With Retractors. The requirements for automatic 

restraints in the front seating positions of passenger cars were issued in 1984 in response to the 

persistent low usage rate of manual belts. Two systems that qualified as automatic restraints 

were air cushion restraints (air bags) and automatic safety belts (belts that automatically move 

into place around the occupant when the door is closed). 

The 1984 rule required that some type of automatic restraint be installed in passenger cars, but 

provided the manufacturers the choice of a variety of methods of providing automatic protection, 

including automatic safety belts and air bags, as long as certain specified performance 

requirements were met. The final rule required automatic occupant protection in all passenger 

automobiles based on a phased-in schedule beginning September 1986, with full implementation 

being required by September 1989. The front center seat of passenger cars was exempt from, 

and rear seats were not covered by, the requirements. 

Most vehicle manufacturers initially chose to comply with the requirements by installing 

automatic belts in many of their vehicles. The fact that the rule did not include design 

specifications gave them broad flexibility in selecting the design and performance characteristics 

of their automatic belts. For example, the motorized two-point torso belts required the occupant 

to manually fasten the lap belt for full protection, while the door-mounted non-motorized 3-point 

belts were often detached by occupants from their anchorage in the middle of the car and 

subsequently used in the same manner as manual 3-point belts. And, one of the non-motorized 

2-point torso belt systems had an automatic shoulder belt used in combination with a knee 

bolster. This was the only shoulder belt system specifically designed for use without a lap belt 

because the knee bolster took the place of the lap belt. 

69
A series of cost and weight analyses were performed on automatic motorized and non-motorized 

safety belts.106,107,108 Table 208-3 shows the average weight and consumer cost per seat for the 

automatic front outboard safety belts with retractors and anchors. Since these estimates are 

based on at most nine systems, arithmetic averages of the costs and weights were used. 

TABLE 208-3 

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

OF AUTOMATIC FRONT OUTBOARD SAFETY BELTS 

IN PASSENGER CARS 

BELT ASSEMBLIES WEIGHT IN POUNDS CONSUMER COST ($2002) 

Non-Motorized 

2-point (1975-1984) 11.88 $ 72.19 

2-point (1987-1990) 17.72 $128.50 

2-point (1991-1995) 5.34 $ 51.08

3-point 15.12 $164.92 

Motorized 

2-point 16.01 $182.10

The estimate for 1987-1990 non-motorized 2-point belts is substantially higher than the estimates 

for the 1975-1984 and 1991-1995 systems primarily because structural modifications were made 

to the existing vehicle. The costs would probably be lower if the 2-point belts had been built in 

as an overall redesign of the vehicle like it was in the 1975-1984 and 1991-1995 systems. 

NHTSA does not know if these extra costs were characteristic of most of the systems in the first 

years of the automatic protection requirement, or only of the one system we analyzed. Similarly, 

we do not know if the low cost of the 1991-1995 system relative to 1987-1990 represents typical 

across-the-board savings as manufacturers gain experience with new technologies, or merely the 

difference between the two systems we selected for analysis. Likewise, we do not know if the 

costs for the non-motorized 3-point belts and the motorized 2-point belts, each based on analyses 

of three 1987 systems, were reduced in subsequent years. Since all automatic belts were phased 

out by the mid 1990’s, NHTSA is not planning any further cost analyses. 

Successful enactment of buckle-up laws in most of the states, and the demonstrated superior 

performance and customer preference for manual 3-point belts with air bags, soon eliminated 

interest in the various types of automatic belts. FMVSS 208 was subsequently modified to 

require dual air bags plus manual 3-point belts effective September 1, 1997 in passenger cars. In 

1986-1996, vehicles equipped with air bags usually had manual belts, but some had automatic 

belts at one or both of the front outboard positions. 

Rear Outboard Safety Belts. From January 1, 1968 to December 10, 1989, FMVSS 208 only 

required Type 1 (lap) belts at the rear-outboard positions of passenger cars. In model years 

1966-1970, 100 percent of rear-outboard seats were equipped with Type 1 belts. Type 2 

(integral 

 106 McLean, DOT HS 803 871:88-103 (1978). 107 Khadilkar, A.V., Fladmark, G.L.L., and Firth, B.W., Cost Estimates of Automatic Crash Protection in 1987

Model Year Passenger Cars – Volumes I-IV, Washington: Department of Transportation, National Highway Traffic 

Safety Administration, June 1988. (DOT HS 807 319-322). 108 Fladmark, DOT HS 807 950:Section 8 (1992).

 

70
3-point) belts were voluntarily installed in a small number of European make-models starting in 

1971, and subsequently in a gradually increasing list of models. Retractors were added in 1972. 

Three-point belts are more effective than lap only belts because they are highly effective in 

saving lives and preventing serious injuries in rollovers, frontal crashes, and many types of side 

impacts. In June 1989, the agency issued a final rule mandating lap/shoulder belts for forwardfacing rear outboard seating positions in all passenger cars, other than convertibles, with a 

GVWR of 10,000 pounds or less. 

 

A series of cost and weight analyses were performed on rear outboard safety belts with and 

without retractors.109,110,111 NHTSA did not cost analyze any of the early European integral 3-

point belt systems without retractors, which were present in fewer than one percent of new cars 

in the United States. They are assumed to have approximately the same weight and consumer 

cost as the lap belt only. Table 208-4 shows the average weight and consumer cost per seat for 

the rear outboard safety belts. 

TABLE 208-4 

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

OF REAR OUTBOARD SAFETY BELTS 

IN PASSENGER CARS

BELT ASSEMBLIES WEIGHT IN POUNDS CONSUMER COST ($2002) 

Without Retractors

Lap Only (1968) 1.83 $16.45

3-Point Belt 1.83 $16.45

With Retractors

Lap Only (1972-1974) 2.73 $18.29

Lap Only (1979-1981) 3.09 $26.46

Lap Only (1988-1989) 2.84 $19.41

Lap Only Average 

(1972-74 & 1988-89) 2.61 $18.57

3-Point Belt 3.56 $22.00

The sample of the lap only safety belts represented three different eras in passenger cars. The 

average weight and consumer costs of the 1972-1974 samples and the 1988-1989 samples are 

nearly equal. There is no obvious explanation why the 1979-1981 costs are substantially higher, 

in fact, even higher than the cost estimate for 3-point belts. It is perhaps a consequence of the 

specific make-models selected. At all the other seat positions, the 1979-1981 estimates were 

consistent with the earlier and later estimates. We will use the arithmetic average over the 1972-

1974 and 1988-1989 samples as our estimate for the weight and consumer cost of lap belts. 

There appears to be a reasonable cost and weight increase from this average to the estimated cost 

and weight of 3-point belts. 

 109 McLean, DOT HS 803 871:88-103 (1978). 110 Gladstone, DOT HS 806 257:3-1 thru 3-59 (1982). 111 Fladmark, DOT HS 807 952:Sections 12-15 (1992).

71
Front and Rear Center Safety Belts. From January 1, 1968 through 2003, FMVSS 208 has only 

required Type 1 (lap) belts at the front and rear center seat positions. They are airline-style belts 

without retractors. 

“Anton’s Law”, signed on December 4, 2002, directs NHTSA to issue a final rule, no later than 

December 2004, requiring a lap/shoulder belt assembly for each rear designated seating position 

in a passenger motor vehicle with a GVWR of 10,000 pounds or less including the center rear 

position. It further specifies that the final rule be implemented in stages, starting no later than 

September 1, 2005 and be fully implemented no later than September 1, 2007. This rule will 

extend the superior protection of 3-point belts to the rear center seat. 

Since the late 1980s, manufacturers have begun voluntarily installing lap/shoulder belts in the 

rear center seating position. By model year 2002, approximately 120 vehicle models were 

equipped with rear center lap/shoulder belts. 

A series of cost and weight analyses were performed on front and rear center lap belts.112,113,114 

Table 208-5 shows the average weight and consumer cost per seat for the front and rear center 

belts. 

TABLE 208-5 

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

OF FRONT AND REAR CENTER LAP BELTS 

WITHOUT RETRACTORS IN PASSENGER CARS

BELT ASSEMBLIES WEIGHT IN POUNDS CONSUMER COST ($2002) 

Front Center 

Lap Only (1968-1974) 0.90 $14.42

Lap Only (1979-1981) 0.79 $13.35

AVERAGE 0.85 $13.95

Rear Center 

Lap Only (1968-1974) 1.02 $14.10

Lap Only (1979-1981) 0.75 $12.46

Lap Only (1992-1993) 1.09 $11.34

AVERAGE 0.92 $12.96

While it appears that the costs are becoming slightly lower for the rear center safety belts without 

retractors, we do not see a similar trend in the front center belts or in other seat positions. 

Consequently, the difference for the rear center seats may be attributed to the vehicle sample or 

the estimation methods. Therefore, we are using a simple arithmetic average of all the samples 

at each position. 

A preliminary weight and consumer cost estimate of rear center 3-point safety belts of 3.03 

pounds and $22.28 in 2002 dollars was calculated on the teardown of three existing systems.115 

 112 McLean, DOT HS 803 871:88-103 (1978). 113 Gladstone, DOT HS 806 257:3-1 thru 3-59 (1982). 114 Khadilkar, A.V., Fladmark, G.L., and Khadilkar, J., Teardown Cost Estimates of Automotive Equipment

Manufactured to Comply with Motor Vehicle Standards, FMVSS 208 – Occupant Protection, Volume II, 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, January 2001. 

(DOT HS 809 807:Sections 20,23). 115 Ibid. 

72
The cost of the shoulder belt upper anchor was not included. These figures may not necessarily 

be representative of the true cost of 3-point belts. 

Summary Calculations for Safety Belts. The total weight and consumer cost of safety belt 

assemblies and anchorages for model years 1966-2001 were calculated. The calculations were 

based on the weight and consumer cost per seat and the percent market share of safety belt 

assemblies per number of seating positions in a passenger car by model year (average “N”). The 

model years were divided into four groups, i.e., 1966-1976, 1977-1984, 1985-1994, and 1995-

2001. The percent market share for each group was based on data from the following sources: 

1. 1966-1976 – National Crash Severity Study (NCSS), which was a 1976-1978 predecessor 

of the National Automotive Sampling System (NASS) file. NCSS had a variable 

indicating how many seats were in the vehicle. 

2. 1977-1984 – NASS file. In 1982-1986, NASS had a variable indicating how many seats 

were in a car. 

3. 1985-1994 – 1990 Polk registration file and Branham Automobile Reference Book.116 

The Polk file provides the sales figures of all 1990 passenger vehicles broken out by 

make and model, while the Branham book identifies the number of seating positions in

each of the 1990 make-models. The sales figures for each seating position are divided by 

the overall sales figures to determine the percent market share per position. For example, 

170,491 two-seat passenger cars were sold in 1990, with overall passenger car sales of 

8,669,395. Therefore, the percent market share for two seating positions = 170,491 / 

8,669,395 or 0.0197. 

4. 1995-2001 – 1999 Polk registration file and Branham Automobile Reference Book. 

The summary calculations were determined through a series of steps. 

• Step 1. Determine the average N of front-outboard, rear-outboard, rear-outboard third 

row, front-center, and rear- or third-row center seats per car. 

o Multiply the percent market share per position (Column A) for the number of

seating positions per car by the number of safety belt assemblies required for each 

seating location (Columns B,C,D,E,F). For example, a car from 1966-1976 with 

five seating positions has a percent market share of 0.1344. Five safety belt 

assemblies are required (two at the front outboard, two at the rear outboard, and 

one at the rear center locations). The percent market share would be 0.2688 

(0.1344 * 2) for each front and rear outboard location and 0.1344 (0.1344 * 1) for 

the rear center location. 

o Sum the individual market share calculations in each seating location to arrive at 

the total percent market share for each seating location. Table 208-6A shows that 

the average car had 2.000 front-outboard seats, 1.9508 rear-outboard seats, 0.0336 

rear outboard third row seats, 0.4718 front-center seats, and 0.6166 rear- or third-

 116 Branham Automobile Reference Book, Branham Publishing Company, Santa, Monica, CA, 1985-2001. 

73
row center seats. 

o Tables 208-6A thru D show the breakout of the possible number of seating 

positions in passenger cars, the percent market share for those seating positions, 

the number of safety belt assemblies required at each seating location, the 

corresponding percent market share at each seating location for the number of 

seating positions per car, and the total percent market share for each seating 

location for the four year groups. 

TABLE 208-6A 

PERCENT MARKET SHARE (AVERAGE N) FOR SEATING POSITIONS 

 IN PASSENGER CARS FROM 1966-1976

FRONT 

OUTBOARD 

REAR 

OUTBOARD 

REAR 

OUTBOARD 

THIRD ROW

FRONT 

CENTER 

REAR OR 

THIRD 

# OF ROW CENTER 

SEATING 

POSITIONS 

PER CAR 

% 

MARKET 

SHARE 

PER 

POSITION 

(A) 

# 

OF 

BELTS

(B) 

% 

MKT 

SHARE 

(A*B) 

# 

OF 

BELTS

(C) 

% 

MKT 

SHARE 

(A*C) 

# 

OF 

BELTS

(D) 

% 

MKT 

SHARE 

(A*D) 

# 

OF 

BELTS

(E) 

% 

MKT 

SHARE 

(A*E) 

# 

OF 

BELTS

(F) 

% 

MKT 

SHARE 

(A*F) 

2 0.0246 2 0.0492 0 0.0000 0 0.0000 0 0.0000 0 0.0000

4 0.3692 2 0.7384 2 0.7384 0 0.0000 0 0.0000 0 0.0000

5 0.1344 2 0.2688 2 0.2688 0 0.0000 0 0.0000 1 0.1344

6 0.4550 2 0.9100 2 0.9100 0 0.0000 1 0.4550 1 0.4550

8 0.0064 2 0.0128 2 0.0128 2 0.0128 1 0.0064 1 0.0064

9 0.0104 2 0.0208 2 0.0208 2 0.0128 1 0.0104 2 0.0208

TOTAL 1.0000 2.0000 1.9508 0.0336 0.4718 0.6166

TABLE 208-6B 

PERCENT MARKET SHARE (AVERAGE N) FOR SEATING POSITIONS 

 IN PASSENGER CARS FROM 1977-1984

FRONT 

OUTBOARD 

REAR 

OUTBOARD 

REAR 

OUTBOARD 

THIRD ROW

FRONT 

CENTER 

REAR OR 

THIRD 

# OF ROW CENTER 

SEATING 

POSITIONS 

PER CAR 

% 

MARKET 

SHARE 

PER 

POSITION 

(A) 

# 

OF 

BELTS

(B) 

% 

MKT 

SHARE 

(A*B) 

# 

OF 

BELTS

(C) 

% 

MKT 

SHARE 

(A*C) 

# 

OF 

BELTS

(D) 

% 

MKT 

SHARE 

(A*D) 

# 

OF 

BELTS

(E) 

% 

MKT 

SHARE 

(A*E) 

# 

OF 

BELTS

(F) 

% 

MKT 

SHARE 

(A*F) 

2 0.0237 2 0.0474 0 0.0000 0 0.0000 0 0.0000 0 0.0000

4 0.3614 2 0.7228 2 0.7228 0 0.0000 0 0.0000 0 0.0000

5 0.2826 2 0.5652 2 0.5652 0 0.0000 0 0.0000 1 0.2826

6 0.3262 2 0.6524 2 0.6524 0 0.0000 1 0.3262 1 0.3262

8 0.0039 2 0.0078 2 0.0078 2 0.0078 1 0.0039 1 0.0039

9 0.0022 2 0.0044 2 0.0044 2 0.0044 1 0.0022 2 0.0044

TOTAL 1.0000 2.0000 1.9526 0.0122 0.3323 0.6171

74
TABLE 208-6C 

PERCENT MARKET SHARE (AVERAGE N) FOR SEATING POSITIONS 

 IN PASSENGER CARS FROM 1987-1994

FRONT 

OUTBOARD 

REAR 

OUTBOARD 

REAR 

OUTBOARD 

THIRD ROW

FRONT 

CENTER 

REAR OR 

THIRD 

# OF ROW CENTER 

SEATING 

POSITIONS 

PER CAR 

% 

MARKET 

SHARE 

PER 

POSITION 

(A) 

# 

OF 

BELTS

(B) 

% 

MKT 

SHARE 

(A*B) 

# 

OF 

BELTS

(C) 

% 

MKT 

SHARE 

(A*C) 

# 

OF 

BELTS

(D) 

% 

MKT 

SHARE 

(A*D) 

# 

OF 

BELTS

(E) 

% 

MKT 

SHARE 

(A*E) 

# 

OF 

BELTS

(F) 

% 

MKT 

SHARE 

(A*F) 

2 0.0197 2 0.0394 0 0.0000 0 0.0000 0 0.0000 0 0.0000

4 0.1236 2 0.2472 2 0.2472 0 0.0000 0 0.0000 0 0.0000

5 0.6260 2 1.2520 2 1.2520 0 0.0000 0 0.0000 1 0.6260

6 0.2265 2 0.4530 2 0.4530 0 0.0000 1 0.2265 1 0.2265

8 0.0003 2 0.0006 2 0.0006 2 0.0006 1 0.0003 1 0.0003

9 0.0039 2 0.0078 2 0.0078 2 0.0078 1 0.0039 2 0.0078

TOTAL 1.0000 2.0000 1.9606 0.0084 0.2307 0.8606

TABLE 208-6D

PERCENT MARKET SHARE (AVERAGE N) FOR SEATING POSITIONS 

 IN PASSENGER CARS FROM 1995-2001

FRONT 

OUTBOARD 

REAR 

OUTBOARD 

REAR 

OUTBOARD 

THIRD ROW

FRONT 

CENTER 

REAR OR 

THIRD 

# OF ROW CENTER 

SEATING 

POSITIONS 

PER CAR 

% 

MARKET 

SHARE 

PER 

POSITION 

(A) 

# 

OF 

BELTS

(B) 

% 

MKT 

SHARE 

(A*B) 

# 

OF 

BELTS

(C) 

% 

MKT 

SHARE 

(A*C) 

# 

OF 

BELTS

(D) 

% 

MKT 

SHARE 

(A*D) 

# 

OF 

BELTS

(E) 

% 

MKT 

SHARE 

(A*E) 

# 

OF 

BELTS

(F) 

% 

MKT 

SHARE 

(A*F) 

2 0.0161 2 0.0322 0 0.0000 0 0.0000 0 0.0000 0 0.0000

4 0.0894 2 0.1788 2 0.1788 0 0.0000 0 0.0000 0 0.0000

5 0.6808 2 1.3616 2 1.3616 0 0.0000 0 0.0000 1 0.6808

6 0.2068 2 0.4136 2 0.4136 0 0.0000 1 0.2068 1 0.2068

8 0.0007 2 0.0014 2 0.0014 2 0.0014 1 0.0007 1 0.0007

9 0.0062 2 0.0124 2 0.0124 2 0.0124 1 0.0062 2 0.0124

TOTAL 1.0000 2.0000 1.9678 0.0138 0.2137 0.9007

• Step 2. When more than one technology is used, determine the percent distribution of the 

safety belt types at the front and rear outboard seating locations for each model year. For 

example, in 1968 the distribution of front outboard safety belts in passenger cars was 

50% for lap belts only, 45.5% for separate lap/shoulder belts, and 5.5% for 3-point belts. 

• Step 3. Determine the “n” of belts of each type of safety belt technology per car. 

Multiply the average N from Step 1 by the percent distribution from Step 2. For 

example, the “n” of belts for a front outboard lap only belt in 1968 would be 1.00 (2 * 

0.50). 

• Step 4. Calculate the cost and weight per seat for each safety belt assembly. Multiply the 

“n” of belts by the cost or weight (from Tables 208-1 thru 5) of each type of safety belt. 

 

• Step 5. Calculate the total cost and weight per car of safety belt assemblies and 

anchorages for model years 1966-2001. Sum the individual market share calculations in 

75
each seating location to arrive at the total percent market share for each seating location. 

Table 208-7 shows the calculations of the total cost for model year 1968. 

TABLE 208-7 

TOTAL CONSUMER COST PER PASSENGER CAR 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEAR 1968

SAFETY BELT ASSEMBLY COST PER SEAT 

(A) 

“n” 

 OF BELTS

PER CAR 

(B) 

TOTAL COST

PER SAFETY

BELT ASSEMBLY 

(A * B)

Manual Front Outboard Without Retractor 

Lap Belt Only $20.99 1.00 $20.99

Separate Lap/Shoulder Belt $22.61 0.89 $20.12

3-Point Belt $22.61 0.11 $ 2.49

Rear Outboard Without Retractor 

Lap Belt Only $16.45 1.95 $32.08

Rear Outboard Third Row Without Retractor 

Lap Belt Only $16.45 0.03 $ 0.49

Front Center 

Lap Belt Only $13.95 0.47 $ 6.56

Rear/Third Row Center

Lap Belt Only $12.96 0.62 $ 8.03

TOTAL CONSUMER COST $90.76 

Summary calculations of the total consumer cost per car of safety belt assemblies and anchorages 

for model year 1966-2001 are provided in Tables 208-8A thru 8E with the calculations for the 

total weight provided in Tables 208-9A thru 9E. 

76
TABLE 208-8A 

AVERAGE CONSUMER COST (IN 2002 DOLLARS) PER PASSENGER CAR 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1966-1973

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘66-67 ‘68 ‘69 ‘70 ‘71 ‘72 ‘73 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $ 20.99 1.99 1.00 

Separate Lap/Shoulder Belt $ 22.61 0.01 0.89 1.80 1.82 1.81

3-Point Belt $ 22.61 0.11 0.20 0.18 0.19

Manual With Retractor 

Separate Lap/Shoulder Belt $ 32.42 1.86 1.85

3-Point Belt $ 33.35 0.14 0.15

Automatic 

2-Point Non-Motorized 

(1975-1984) $ 72.19 

2-Point Non-Motorized 

(1987-1990) $128.50 

2-Point Non-Motorized 

(1991-1995) $ 51.08 

3-Point Non-Motorized $164.92 

2-Point Motorized $182.10 

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $ 16.45 1.95 1.95 1.95 1.95 1.94

3-Point Belt $ 16.45 0.01 

With Retractor 

Lap Belt Only $ 18.57 1.94 1.94

3-Point Belt $ 22.00 0.01 0.01

REAR OUTBOARD THIRD ROW

Without Retractor

Lap Belt Only $ 16.45 0.03 0.03 0.03 0.03 0.03

With Retractor 

Lap Belt Only $ 18.57 0.03 0.03

CENTER 

Front (lap) $ 13.95 0.47 0.47 0.47 0.47 0.47 0.47 0.47

Rear/Third Row (lap) $ 12.96 0.62 0.62 0.62 0.62 0.62 0.62 0.62

TOTAL COST PER CAR $89.16 $90.76 $92.38 $92.38 $92.38 $116.41 $116.37

77
TABLE 208-8B 

AVERAGE CONSUMER COST PER PASSENGER CAR 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1974-1980

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘74 ‘75 ‘76 ‘77 ‘78 ‘79 ‘80 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $ 20.99 

Separate Lap/Shoulder Belt $ 22.61 

3-Point Belt $ 22.61 

Manual With Retractor 

Separate Lap/Shoulder Belt $ 32.42 

3-Point Belt $ 33.35 2.00 1.99 1.99 1.99 1.99 1.98 1.98 

Automatic 

2-Point Non-Motorized 

(1975-1984) $ 72.19 0.01 0.01 0.01 0.01 0.02 0.02 

2-Point Non-Motorized 

(1987-1990) $128.50 

2-Point Non-Motorized 

(1991-1995) $ 51.08 

3-Point Non-Motorized $164.92 

2-Point Motorized $182.10 

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $ 16.45 

3-Point Belt $ 16.45 

With Retractor

Lap Belt Only $ 18.57 1.94 1.93 1.94 1.94 1.94 1.94 1.94 

3-Point Belt $ 22.00 0.01 0.02 0.01 0.01 0.01 0.01 0.01 

REAR OUTBOARD THIRD ROW

Without Retractor 

Lap Belt Only $ 16.45 

With Retractor 

Lap Belt Only $ 18.57 0.03 0.03 0.03 0.01 0.01 0.01 0.01 

CENTER 

Front (lap) $ 13.95 0.47 0.47 0.47 0.33 0.33 0.33 0.33 

Rear/Third Row (lap) $ 12.96 0.62 0.62 0.62 0.62 0.62 0.62 0.62 

TOTAL COST PER CAR $118.09* $118.52* $118.48 $116.16 $116.16 $116.55 $116.55

* Does not include additional cost of ignition interlock system for front-outboard seats.

78
TABLE 208-8C 

AVERAGE CONSUMER COST PER PASSENGER CAR 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1981-1987

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘81 ‘82 ‘83 ‘84 ‘85 ‘86 ‘87 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $ 20.99 

Separate Lap/Shoulder Belt $ 22.61 

3-Point Belt $ 22.61 

Manual With Retractor 

Separate Lap/Shoulder Belt $ 32.42 

3-Point Belt $ 33.35 1.98 1.99 1.99 1.99 1.99 1.99 1.80

Automatic 

2-Point Non-Motorized 

(1975-1984) $ 72.19 0.01 0.005 

2-Point Non-Motorized 

(1987-1990) $128.50 0.02 

2-Point Non-Motorized 

(1991-1995) $ 51.08 

3-Point Non-Motorized $164.92 0.08 

2-Point Motorized $182.10 0.01 0.005 0.01 0.01 0.01 0.01 0.10

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $ 16.45 

3-Point Belt $ 16.45 

With Retractor 

Lap Belt Only $ 18.57 1.92 1.88 1.85 1.85 1.85 1.84 1.80

3-Point Belt $ 22.00 0.03 0.07 0.10 0.10 0.10 0.11 0.16

REAR OUTBOARD THIRD ROW

Without Retractor 

Lap Belt Only $ 16.45 

With Retractor 

Lap Belt Only $ 18.57 0.01 0.01 0.01 0.01 0.01 0.01 0.01

CENTER 

Front (lap) $ 13.95 0.33 0.33 0.33 0.33 0.33 0.33 0.23

Rear/Third Row (lap) $ 12.96 0.62 0.62 0.62 0.62 0.62 0.62 0.86

TOTAL COST PER CAR $117.71 $116.91 $117.57 $117.57 $117.57 $117.60 $145.49

79
TABLE 208-8D

AVERAGE CONSUMER COST PER PASSENGER CAR 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1988-1994

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘88 ‘89 ‘90 ‘91 ‘92 ‘93 ‘94 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $ 20.99 

Separate Lap/Shoulder Belt $ 22.61 

3-Point Belt $ 22.61 

Manual With Retractor 

Separate Lap/Shoulder Belt $ 32.42 

3-Point Belt $ 33.35 1.51 1.30 0.53 0.61 0.86 0.95 1.07

Automatic 

2-Point Non-Motorized 

(1975-1984) $ 72.19 

2-Point Non-Motorized 

(1987-1990) $128.50 0.04 0.02 0.13 

2-Point Non-Motorized 

(1991-1995) $ 51.08 0.15 0.18 0.06 0.06 

3-Point Non-Motorized $164.92 0.25 0.39 0.68 0.55 0.49 0.45 0.46

2-Point Motorized $182.10 0.20 0.29 0.66 0.69 0.47 0.54 0.41

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $ 16.45 

3-Point Belt $ 16.45 

With Retractor 

Lap Belt Only $ 18.57 1.39 0.64 

3-Point Belt $ 22.00 0.57 1.32 1.96 1.96 1.96 1.96 1.96

REAR OUTBOARD THIRD ROW 

Without Retractor 

Lap Belt Only $ 16.45 

With Retractor 

Lap Belt Only $ 18.57 0.01 0.01 

CENTER 

Front (lap) $ 13.95 0.23 0.23 0.23 0.23 0.23 0.23 0.23

Rear/Third Row (lap) $ 12.96 0.86 0.86 0.86 0.86 0.86 0.86 0.86

TOTAL COST PER CAR $186.04 $218.52 $324.19 $301.83 $261.75 $264.77 $246.75

80
TABLE 208-8E 

AVERAGE CONSUMER COST PER PASSENGER CAR 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1995-2001

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘95 ‘96 ‘97 ‘98 ‘99 ‘00 ‘01 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $ 20.99 

Separate Lap/Shoulder Belt $ 22.61 

3-Point Belt $ 22.61 

Manual With Retractor 

Separate Lap/Shoulder Belt $ 32.42 

3-Point Belt $ 33.35 1.62 1.79 2.00 2.00 2.00 2.00 2.00

Automatic 

2-Point Non-Motorized 

(1975-1984) $ 72.19 

2-Point Non-Motorized 

(1987-1990) $128.50 

2-Point Non-Motorized 

(1991-1995) $ 51.08 0.01 

3-Point Non-Motorized $164.92 0.22 0.14 

2-Point Motorized $182.10 0.15 0.07 

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $ 16.45 

3-Point Belt $ 16.45 

With Retractor 

Lap Belt Only $ 18.57 

3-Point Belt $ 22.00 1.97 1.97 1.97 1.97 1.97 1.97 1.97

REAR OUTBOARD THIRD ROW 

Without Retractor 

Lap Belt Only $ 16.45 

With Retractor 

Lap Belt Only $ 18.57 

CENTER 

Front (lap) $ 13.95 0.21 0.21 0.21 0.21 0.21 0.21 0.21

Rear/Third Row (lap) $ 12.96 0.90 0.90 0.90 0.90 0.90 0.90 0.90

TOTAL COST PER CAR $176.07 $153.47 $124.63 $124.63 $124.63 $124.63 $124.63

81
TABLE 208-9A 

AVERAGE WEIGHT (IN POUNRDS) PER PASSENGER CAR 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1966-1973

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

WEIGHT 

PER 

SEAT ‘66-67 ‘68 ‘69 ‘70 ‘71 ‘72 ‘73 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.38 1.99 1.00 

Separate Lap/Shoulder Belt 2.95 0.01 0.89 1.80 1.82 1.81 

3-Point Belt 2.95 0.11 0.20 0.18 0.19

Manual With Retractor 

Separate Lap/Shoulder Belt 4.52 1.86 1.85

3-Point Belt 5.18 0.14 0.15

Automatic 

2-Point Non-Motorized 

(1975-1984) 11.88 

2-Point Non-Motorized 

(1987-1990) 17.72 

2-Point Non-Motorized 

(1991-1995) 5.34

3-Point Non-Motorized 15.12 

2-Point Motorized 16.01 

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.83 1.95 1.95 1.95 1.95 1.94 

3-Point Belt 1.83 0.01 

With Retractor 

Lap Belt Only 2.61 1.94 1.94

3-Point Belt 3.56 0.01 0.01

REAR OUTBOARD THIRD ROW 

Without Retractor 

Lap Belt Only 1.83 0.03 0.03 0.03 0.03 0.03 

With Retractor

Lap Belt Only 2.61 0.03 0.03

CENTER 

Front (lap) 0.85 0.47 0.47 0.47 0.47 0.47 0.47 0.47 

Rear/Third Row (lap) 0.92 0.62 0.62 0.62 0.62 0.62 0.62 0.62 

TOTAL WEIGHT PER CAR 9.36 9.92 10.49 10.49 10.49 15.28 15.29

82
TABLE 208-9B 

AVERAGE WEIGHT PER PASSENGER CAR 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1974-1980

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

WEIGHT 

PER 

SEAT ‘74 ‘75 ‘76 ‘77 ‘78 ‘79 ‘80 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.38

Separate Lap/Shoulder Belt 2.95

3-Point Belt 2.95

Manual With Retractor 

Separate Lap/Shoulder Belt 4.52

3-Point Belt 5.18 2.00 1.99 1.99 1.99 1.99 1.98 1.98 

Automatic 

2-Point Non-Motorized 

(1975-1984) 11.88 0.01 0.01 0.01 0.01 0.02 0.02 

2-Point Non-Motorized 

(1987-1990) 17.72 

2-Point Non-Motorized 

(1991-1995) 5.34

3-Point Non-Motorized 15.12 

2-Point Motorized 16.01 

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.83

3-Point Belt 1.83

With Retractor 

Lap Belt Only 2.61 1.94 1.93 1.94 1.94 1.94 1.94 1.94 

3-Point Belt 3.56 0.01 0.02 0.01 0.01 0.01 0.01 0.01 

REAR OUTBOARD THIRD ROW 

Without Retractor 

Lap Belt Only 1.83

With Retractor

Lap Belt Only 2.61 0.03 0.03 0.03 0.01 0.01 0.01 0.01 

CENTER 

Front (lap) 0.85 0.47 0.47 0.47 0.33 0.33 0.33 0.33 

Rear/Third Row (lap) 0.92 0.62 0.62 0.62 0.62 0.62 0.62 0.62 

TOTAL WEIGHT PER CAR 16.51 16.58 16.57 16.40 16.40 16.47 16.47

83
TABLE 208-9C 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

AVERAGE WEIGHT PER PASSENGER CAR 

FOR MODEL YEARS 1981-1987

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

WEIGHT 

PER 

SEAT ‘81 ‘82 ‘83 ‘84 ‘85 ‘86 ‘87 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.38

Separate Lap/Shoulder Belt 2.95

3-Point Belt 2.95

Manual With Retractor 

Separate Lap/Shoulder Belt 4.52

3-Point Belt 5.18 1.98 1.99 1.99 1.99 1.99 1.99 1.80

Automatic 

2-Point Non-Motorized 

(1975-1984) 11.88 0.01 0.005 

2-Point Non-Motorized 

(1987-1990) 17.72 0.02 

2-Point Non-Motorized 

(1991-1995) 5.34

3-Point Non-Motorized 15.12 0.08 

2-Point Motorized 16.01 0.01 0.005 0.01 0.01 0.01 0.01 0.10

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.83

3-Point Belt 1.83

With Retractor 

Lap Belt Only 2.61 1.92 1.88 1.85 1.85 1.85 1.84 1.80 

3-Point Belt 3.56 0.03 0.07 0.10 0.10 0.10 0.11 0.16

REAR OUTBOARD THIRD ROW 

Without Retractor 

Lap Belt Only 1.83

With Retractor 

Lap Belt Only 2.61 0.01 0.01 0.01 0.01 0.01 0.01 0.01 

CENTER 

Front (lap) 0.85 0.33 0.33 0.33 0.33 0.33 0.33 0.23

Rear/Third Row (lap) 0.92 0.62 0.62 0.62 0.62 0.62 0.62 0.86 

TOTAL WEIGHT PER CAR 16.53 16.48 16.53 16.53 16.53 16.54 18.77

84
TABLE 208-9D

AVERAGE WEIGHT PER PASSENGER CAR 

SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1988-1994

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

WEIGHT 

PER 

SEAT ‘88 ‘89 ‘90 ‘91 ‘92 ‘93 ‘94 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.38

Separate Lap/Shoulder Belt 2.95

3-Point Belt 2.95

Manual With Retractor 

Separate Lap/Shoulder Belt 4.52

3-Point Belt 5.18 1.51 1.30 0.53 0.61 0.86 0.95 1.07 

Automatic 

2-Point Non-Motorized 

(1975-1984) 11.88 

2-Point Non-Motorized 

(1987-1990) 17.72 0.04 0.02 0.13 

2-Point Non-Motorized 

(1991-1995) 5.34 0.15 0.18 0.06 0.06 

3-Point Non-Motorized 15.12 0.25 0.39 0.68 0.55 0.49 0.45 0.46

2-Point Motorized 16.01 0.20 0.29 0.66 0.69 0.47 0.54 0.41 

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.83

3-Point Belt 1.83

With Retractor 

Lap Belt Only 2.61 1.39 0.64 

3-Point Belt 3.56 0.57 1.32 1.96 1.96 1.96 1.96 1.96 

REAR OUTBOARD THIRD ROW 

Without Retractor 

Lap Belt Only 1.83

With Retractor 

Lap Belt Only 2.61 0.01 0.01 

CENTER 

Front (lap) 0.85 0.23 0.23 0.23 0.23 0.23 0.23 0.23 

Rear/Third Row (lap) 0.82 0.86 0.86 0.86 0.86 0.86 0.86 0.86 

TOTAL WEIGHT PER CAR 22.18 25.01 33.86 31.29 28.31 28.66 27.35 

85
TABLE 208-9E 

AVERAGE WEIGHT PER PASSENGER CAR 

SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1995-2001

“n” OF BELTS PER CAR 

SAFETY BELT

ASSEMBLY

WEIGHT 

PER 

SEAT ‘95 ‘96 ‘97 ‘98 ‘99 ‘00 ‘01 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.38

Separate Lap/Shoulder Belt 2.95

3-Point Belt 2.95

Manual With Retractor 

Separate Lap/Shoulder Belt 4.52

3-Point Belt 5.18 1.62 1.79 2.00 2.00 2.00 2.00 2.00 

Automatic 

2-Point Non-Motorized 

(1975-1984) 11.88 

2-Point Non-Motorized 

(1987-1990) 17.72 

2-Point Non-Motorized 

(1991-1995) 5.34 0.01 

3-Point Non-Motorized 15.12 0.22 0.14 

2-Point Motorized 16.01 0.15 0.07 

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.83

3-Point Belt 1.83

With Retractor 

Lap Belt Only 2.61

3-Point Belt 3.56 1.97 1.97 1.97 1.97 1.97 1.97 1.97 

REAR OUTBOARD THIRD ROW 

Without Retractor 

Lap Belt Only 1.83

With Retractor 

Lap Belt Only 2.61

CENTER 

Front (lap) 0.85 0.21 0.21 0.21 0.21 0.21 0.21 0.21 

Rear/Third Row (lap) 0.92 0.90 0.90 0.90 0.90 0.90 0.90 0.90 

TOTAL WEIGHT PER CAR 22.19 20.53 18.38 18.38 18.38 18.38 18.38

86
Pretensioners, Load Limiters, and Adjustable Anchors 

While safety belts reduce the risk of fatal and serious injuries, rib and abdominal injuries may be 

suffered in high-speed collisions especially if the safety belt is not correctly positioned. These 

risks are minimized with safety belt pretensioners, load limiters, and adjustable anchors. 

Although they are not mandatory for meeting NHTSA standards, the agency regards them with 

favor and provides consumer information on their availability. 

Pretensioners. In a crash, pretensioners retract the safety belt almost instantly to remove excess 

slack and keep the occupant restrained. Whereas the conventional locking mechanism in a 

retractor keeps the belt from extending any farther, the pretensioner actually pulls in on the belt 

and reduces the risk of “submarining” (where the car occupant slips under a loosely tightened 

safety belt). This force helps move the passenger into the optimum crash position in his or her 

seat so that the air bag can more effectively deploy.

The three types of pretensioners in use today are mechanical, electrical, and pyrotechnic. 

Mechanical pretensioners use an inertial wheel with a pendulum device that moves under the 

rapid deceleration of the crash to lock the belt into place and prevent excessive safety belt slack. 

Excessive slack allows too much occupant motion during a crash, thus increasing the chance of 

contact with components such as the steering wheel, dashboard, or windshield and the possibility 

of increased potential of injury in an accident. Electrical pretensioners replace the mechanical 

means of sensing the deceleration with an electrical device that may or may not be tied into the 

airbag ignition circuits. Pyrotechnic pretensioners use electrically triggered pyrotechnics that 

tighten the safety belt a prescribed amount upon sensing a crash event. This keeps the occupant 

travel to a minimum and also helps optimize occupant position for effective use of the restraint 

capabilities of the airbag systems. 

Load Limiters. In severe crashes where a car collides with an obstacle at extremely high speed, a 

safety belt can inflict serious damage. As a passenger’s inertial speed increases, it takes a greater 

force to bring the passenger to a stop, i.e., the faster you are going on impact, the harder the 

safety belt will push on you. The purpose of a load limiter is to limit the forces imparted to the 

occupant by the safety belt during the crash event. The forces are prevented from exceeding a 

predetermined level by allowing the safety belt webbing to yield when the forces reach this level.

Adjustable Anchors. An adjustable upper belt anchorage improves the safety belts’ protective 

effect by letting the occupant change the position of the shoulder strap to accommodate that 

person’s size, which increases the ease and comfort of safety belt use for car occupants of above 

or below average height.

 

A study was conducted in 2000 on fourteen 1992-1999 make-model passenger vehicles, 

including nine vehicles equipped with pretensioners, load limiters, adjustable anchors, or a 

combination of these technologies and five baseline vehicles, to determine the weight and 

consumer cost of pretensioners, load limiters, and adjustable anchors.117 Table 208-10 shows the 

arithmetic average weight and consumer cost of the pretensioners, the load limiters and 

adjustable anchors (the contractor did not break these out), and all three technologies. Since 

these technologies are voluntarily installed in passenger vehicles by the automotive 

117 Khadilkar, DOT HS 809 806-807 (2001). 

87
manufacturers and not required by NHTSA, their costs are not attributed to FMVSS 208.

TABLE 208-10

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

OF PRETENSIONERS, LOAD LIMITERS, AND ADJUSTABLE ANCHORS 

COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

Pretensioners 0.22 $10.94

Load Limiters & 

Adjustable Anchors 0.98 $ 8.88

TOTAL FOR ALL THREE 1.20 $19.82 

Since conventional 3-point belts in passenger cars cost $33.35 per seat (Table 208-2), the 

addition of pretensioners, load limiters, and adjustable anchors increases the total cost by

$19.82 or 59 percent. 

Frontal Air Bags 

Air bags are designed to save lives and prevent injuries by cushioning occupants as they move 

forward in a frontal crash. Air bags reduce the likelihood of injury to an occupant’s head, neck, 

face, chest, and abdomen. It is important to note, however, that the air bags are supplemental 

restraints. The presence of an air bag does not mean it is less important for occupants to use their 

safety belts. The safety belt, which provides protection in all kinds of crashes, is the primary 

means of occupant restraint. Air bags provide significant supplemental protection in frontal 

crashes. Today’s air bag requirements have been evolving for more than 30 years. NHTSA 

issued its first public notice concerning air bags in 1969. Starting in 1972, vehicle manufacturers 

had the option of installing air bags in passenger cars as a means of complying with FMVSS 208. 

General Motors installed driver and passenger air bags in approximately 10,000 passenger cars in 

the mid 1970s. 

A final rule, issued in July 1984, required automatic restraint systems for the front outboard seats 

in passenger cars in response to the persistent low usage rate of manual belts. The requirement 

was phased in starting September 1, 1986 with full implementation by September 1, 1989. The 

front center seat of passenger cars was exempt from, and rear seats were not covered by, the 

requirements. 

To encourage the development and introduction of non-belt automatic restraint systems, the 

requirement also provided that manufacturers that installed a non-belt system, such as an air bag, 

at the driver’s seating position could install a manual lap/shoulder belt rather than an automatic 

system at the front right seating position. A further amendment in March 1987 extended this 

option until September 1, 1993 to expedite the introduction of driver air bags while allowing 

adequate lead-time for introduction of passenger bags. 

 

In 1991, Congress directed NHTSA to issue a final rule requiring that automatic crash protection 

must be provided by an inflatable restraint (i.e., an air bag) in passenger cars, light trucks, 

multipurpose vehicles, and buses with a GVWR of 8,500 pounds or less. In addition, the seating 

positions protected by an air bag must also be equipped with a manual lap/shoulder belt. The 

final rule was published in the Federal Register on September 2, 1993118 requiring at least 95 

118 Federal Register, Vol. 58, No. 169, pg. 46551. 

88
percent of each manufacturer’s passenger cars manufactured on or after September 1, 1996 and 

before September 1, 1997 must be equipped with an air bag and a manual lap/shoulder belt at 

both the driver’s and right front passenger’s seating position. Every passenger car manufactured 

on or after September 1, 1997 must be so equipped. The vehicle manufacturers, however, were 

ahead of the implementation schedule. Nearly every 1996 model year passenger car was 

equipped with both driver- and passenger-side air bags as standard equipment.

Like the automatic restraint requirements issued in 1984, the air bag requirements were 

performance requirements that did not specify the design of an air bag system. Instead, vehicles 

must meet specified injury criteria, including criteria for the head and chest, measured on test 

dummies during a barrier crash test at speeds up to 30 mph. These criteria must be met for air 

bag equipped vehicles both when the dummies are belted and when they are unbelted. These 

requirements apply to the performance of the vehicle as a whole, and not to the air bags as a 

separate item of motor vehicle equipment. This permits vehicle manufacturers to “tune” the 

performance of the air bag to the crash pulse and other specific attributes of each of their 

vehicles and leaves them free to select specific attributes for their air bags, such as dimensions, 

actuation time, etc. 

TABLE 208-11

A series of cost and weight analyses were performed on air bags from twelve passenger cars. 

119,120,121,122 Table 208-11 shows the arithmetic average weight and consumer cost for driver air 

bags and dual air bags.

AVERAGE WEIGHT AND CONSUMER COST 

OF AIR BAGS IN PASSENGER CARS 

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

Driver Air Bags 

1988 25.93 $414.38 

1992 13.46 $284.09

Dual Air Bags

1992-1996 26.76 $396.72 

The high estimate of driver air bags in 1988 probably reflects the inefficiencies of initial 

implementation, while the 1992 estimate is a more reasonable long-term cost. Consequently, the 

$284.09 estimate for driver air bags will be used for the consumer cost for model years 1985-

1996, while the $396.72 estimate for dual air bags will be used for the consumer cost from 1987-

2001. 

 119 Khadilkar, DOT HS 807 321-322 (1988). 120 Fladmark, DOT HS 949-951 (1992). 121 Fladmark, DOT HS 809 798 (1996). 122 Fladmark, DOT HS 809 801-802 (1997).

89
The main components of an air bag system are the: 

• Air Bag Module. The air bag module contains both an inflator unit and the lightweight 

fabric air bag. The driver air bag module is located in the steering wheel hub, and the 

passenger air bag module is located in the instrument panel.

• Igniter/Inflator. The igniter assemblies are electrical devices that ignite a chemical gas 

generator that uses a sodium azide/sodium nitrate generant. Upon ignition, the generant 

produces nitrogen gas that fills the bag assemblies, creating a “cushion” effect. Some 

vehicles use a cylinder of compressed Argon gas rather than/in addition to an ignitable 

propellant. 

• Control Module/Sensors. The control module is usually installed in the middle of the car 

between the passenger and engine compartment. The sensors continuously monitor the 

acceleration and deceleration of the vehicle and send this information to a microprocessor 

where the “crash pulse” of a vehicle is stored. When the microprocessor “recognizes” the 

crash pulse from the sensor, an electrical current is sent to the inflator of the airbag(s) that 

should be deployed.

• Clock Spring. The clock spring, or SIR coil, is located in the steering column and has 

several wraps of wire that look much like the spring in a clock. This assembly allows for 

one end to be connected to the wiring harness for the air bag system and the other end to 

be connected to the air bag in the steering wheel. The wraps of wire wind in and out as 

the steering wheel is turned, which allows the steering wheel to move while maintaining 

the electrical connection to the airbag module.

• Wiring Harness. The wiring harness is a collection of wires that is designed to control 

electrical functions in one section of a vehicle. Most wiring harnesses feature simple 

plug-in connectors, so components can be changed without the need to splice wires.

• Knee Bolster. The knee bolster is a padded bar on the lower part of the dashboard that is 

deployed in conjunction with frontal air bags to reduce lower limb injury and the risk of

gliding under the safety belt during a crash.

Table 208-12 shows the arithmetic average weight and consumer cost of the principal 

components of dual air bags for 1992-1996. 

90
TABLE 208-12

AVERAGE WEIGHT AND CONSUMER COST 

OF PRINCIPAL COMPONENTS IN DUAL AIR BAGS 

IN PASSENGER CARS FROM 1992-1996

PRINCIPAL COMPONENTS WEIGHT IN POUNDS CONSUMER COST ($2002) 

Driver Air Bag and 

Inflator Assembly 3.60 $ 65.03 

Passenger Air Bag and 

Inflator Assembly 11.58 $128.14 

Knee Bolster 7.37 $ 29.55

Control Module and Sensors 2.87 $133.88 

Clock Spring Assembly 0.41 $ 13.52 

Wiring Harness 0.93 $ 26.60

TOTAL 26.76 $396.72 

In 1998, Congress directed NHTSA to issue a final rule mandating the use of advanced air bags 

to improve occupant protection for occupants of different sizes, belted and unbelted, while 

minimizing the risk to infants, children, and other occupants from injuries and deaths caused by 

air bags. The issuance of this rule will ensure that advanced air bag technologies are installed 

across the full spectrum of future fleets of motor vehicles. As a result, the air bags in those 

vehicles will be even more effective in saving lives and reducing serious injuries. NHTSA will 

analyze advanced air bags in future cost studies.

Light Truck Studies 

Safety Belts 

Manual Front Outboard Safety Belts Without Retractors. FMVSS 208/209/210 were effective 

for light trucks on January 1, 1968. Prior to 1976, light trucks were equipped with lap belts. 

Manual 3-point belts were equipped in low volumes on light trucks as well. From 1966 through 

1971, the proportion of light trucks installed with 3-point belts averaged two percent based on 

data from NASS and other crash files. The remaining 98 percent were equipped with lap belts in 

the front outboard positions.

It is assumed that manually adjusted lap belts without retractors were installed through 

December 31, 1971. Although no cost or weight analysis was performed on manual front 

outboard safety belts in light trucks for this time period, the safety belts used in light trucks are 

assumed to be very similar to those in passenger cars for the same time frame. Consequently, the 

weight and cost numbers from the passenger car study are used to determine the light truck 

figures123. The safety belt and shoulder belt anchorages in light trucks, however, differed from

those in the passenger cars. Therefore, the figures from a study of belt assembly anchorages in 

light trucks are used.124 Table 208-13 shows the arithmetic average weight and consumer cost 

per seat for the manual front outboard safety belts without retractors, including the safety belt 

and shoulder belt assembly anchorages.

 123 McLean, DOT HS 803 871 (1978). 124 Osen, DOT HS 806 772 (1985). 

91
TABLE 208-13

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

OF MANUAL FRONT OUTBOARD SAFETY BELTS 

WITHOUT RETRACTORS IN LIGHT TRUCKS 

BELT ASSEMBLIES WEIGHT IN POUNDS CONSUMER COST ($2002) 

Lap Belt Only 2.25 $20.67

3-Point Belt (1966-1971) 2.54 $22.03

Manual Front Outboard Safety Belts With Retractors. Beginning January 1, 1972, front 

lap/shoulder safety belts, safety belt retractors, and safety belt warning systems were required on 

passenger cars. It is assumed that the safety belt retractors and safety belt warning systems were 

added to the light truck outboard safety belt assemblies at this time. The figures for the 3-point 

belts were derived from a cost and weight analysis performed on six light trucks,125,126 however, 

there was no analysis performed on the lap belts. Since there was little difference in the cost 

and weight of the lap belt and 3-point belts without retractors (Table 208-13), the cost of the lap 

belt with retractor was determined by subtracting 0.29 from the weight and $1.36 from the cost 

of the 3-point belts with retractors. Table 208-14 shows the average weight and consumer cost 

per seat for the manual front outboard safety belts with retractors. These figures include the 

safety belt and shoulder belt assembly anchorages. 

TABLE 208-14

 

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

OF MANUAL FRONT OUTBOARD SAFETY BELTS 

WITH RETRACTORS IN LIGHT TRUCKS

BELT ASSEMBLIES WEIGHT IN POUNDS CONSUMER COST ($2002) 

Lap Belt Only 4.49 $33.46

3-Point Belt (1972-2001) 4.78 $34.82 

After January 1, 1976, the FMVSS 208 requirements for light trucks were similar to those for 

passenger cars, offering three possible options that were discussed earlier in this paper. 

Manufacturers avoided the automatic protection options. However, certain types of trucks were 

still exempt from 3-point belts. The proportion of light trucks installed with 3-point belts 

increased over the years until 1981 when 100 percent of light trucks were equipped with 3-point

belts in the front outboard seating positions. 

Rear Outboard Safety Belts. From 1966 to 1986 rear-outboard seats were equipped with lap 

only belts. Integral 3-point belts were voluntarily installed in light trucks starting in 1987, and 

subsequently in a gradually increasing list of models. In November 1989, NHTSA published a 

final rule that extended the requirements for rear lap/shoulder belts to convertibles, light trucks, 

multipurpose vehicles, and small buses other than school buses. As in the earlier final rule, 

center seating positions and non forward-facing seating positions were excluded from the 

requirements. By 1992, 100 percent of light trucks were equipped with integral 3-point belts in 

all forward-facing rear outboard-seating positions. Rear seat lap/shoulder belts are estimated to

 125 Fladmark, DOT HS 809 798 (1996). 126 Fladmark, DOT HS 809 801-802 (1997). 

92
be even more effective than rear-seat lap only belts in reducing fatalities and moderate-to-severe 

injuries. 

Although no cost or weight analysis was performed on manual rear outboard safety belts in light 

trucks for this time period, the safety belts used in light trucks are assumed to be very similar to 

those in passenger cars for the same time frame. Consequently, the weight and cost numbers 

from the passenger car study are used to determine the light truck figures.127,128 The safety belt 

and shoulder belt anchorages in light trucks, however, differed from those in the passenger cars. 

Therefore, the figures from a study of belt assembly anchorages in light trucks are used.129 Table 

208-15 shows the arithmetic average weight and consumer cost per seat for the manual rear 

outboard safety belts with and without retractors, plus the safety belt and shoulder belt assembly 

anchorages. 

OF REAR OUTBOARD SAFETY BELTS IN LIGHT TRUCKS

TABLE 208-15

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

BELT ASSEMBLIES WEIGHT IN POUNDS CONSUMER COST ($2002) 

Without Retractors 

Lap Only 1.35 $15.97

With Retractors 

Lap Only 2.24 $18.29

3-Point Belt 3.45 $22.34

Front and Rear Center Safety Belts. From January 1, 1968 through 2003, FMVSS 208 has only 

required lap only belts at the front and rear center seat positions. They are airline-style belts 

without retractor. Again, no cost or weight analysis was performed on front and rear center lap 

belts in light trucks for this time period; consequently, the weight and cost numbers from the 

passenger car studies are used to determine the light truck figures.130,131 Table 208-16 shows the 

arithmetic average weight and consumer cost per seat for the front and rear center lap belts 

without retractors. No cost is included for anchorages, since they are shared with the outboard 

seats.

TABLE 208-16

AVERAGE WEIGHT AND CONSUMER COST PER SEAT 

OF FRONT AND REAR CENTER LAP BELTS 

WITHOUT RETRACTORS IN LIGHT TRUCKS

BELT ASSEMBLIES WEIGHT IN POUNDS CONSUMER COST ($2002) 

Front Center 0.85 $13.95

Rear Center 0.92 $12.96

Summary Calculations for Safety Belts. The total weight and consumer cost of safety belt 

assemblies and anchorages for model years 1966-2001 were calculated. The calculations were 

based on the weight and consumer cost per seat and the percent market share of safety belt 

assemblies per number of seating positions in a passenger car by model year (average “N”). The 

 127 McLean DOT HS 803 871 (1978). 128 Khadilkar, DOT 807 952 (1992). 129 Osen, DOT HS 806 772 (1985). 130 McLean, DOT HS 803 871 (1978). 131 Gladstone, DOT HS 803 871 (1982). 

93
summary calculations were determined through the same series of steps as the passenger cars. 

The model years were divided into four groups, i.e., 1966-1976, 1977-1984, 1985-1994, and 

1995-2001. The percent market share for each group was based on data from the following 

sources: 

1. 1966-1976 – National Crash Severity Study (NCSS), which was a 1976-1978 predecessor 

of the National Automotive Sampling System (NASS) file. NCSS had a variable 

indicating how many seats were in the vehicle.

2. 1977-1984 – 1985 Polk registration file and Branham Automobile Reference Book. The 

Polk file provides the sales figures of all 1985 light trucks broken out by make and 

model, while the Branham book identifies the number of seating positions in each of the 

1985 make/models. In cases where the Branham book did not provide the number of 

seating positions, certain assumptions based on body type were used to determine the 

number of seating positions, i.e., pickups with no backseats had three, pickups with king 

cab had five, and pickups with crew cab had six. The sales figures for each seating 

position are divided by the overall sales figures to determine the percent market share per 

position. For example, 927,833 two-seat light trucks were sold in 1985, with overall light 

truck sales of 3,925,577. Therefore, the percent market share for two seating positions = 

927,833 / 3,925,577 or 0.2364.

3. 1985-1994 – 1990 Polk registration file and Branham Automobile Reference Book.

4. 1995-2001 – 1999 Polk registration file and Branham Automobile Reference Book.

Tables 208-17A thru D show the breakout of the possible number of seating positions in light 

trucks, the percent market share for those seating positions, the number of safety belt assemblies 

required at each seating location, the corresponding percent market share at each seating location 

for the number of seating positions per light truck, and the total percent market share for each 

seating location for 1966-2001. 

94
 

TABLE 208-17A 

PERCENT MARKET SHARE (AVERAGE N) FOR SEATING POSITIONS 

IN LIGHT TRUCKS FROM 1966-1976 

FRONT 

OUTBOARD 

REAR 

OUTBOARD 

FRONT 

CENTER 

REAR 

CENTER 

# OF 

SEATING 

PER LIGHT 

TRUCK 

SHARE 

(A*D) 

POSITIONS MARKET 

 % 

MARKET 

PER 

POSITION 

(A) 

# 

OF 

BELTS 

(B) 

% 

MARKET 

SHARE 

(A*B) 

# 

OF 

BELTS 

(C) 

% 

MARKET 

SHARE 

(A*C) 

# 

OF 

BELTS 

(D) 

% 

MARKET 

SHARE 

# 

OF 

BELTS 

(E) 

% 

SHARE 

(A*E) 

2 0.3272 2 0.6544 0 0.0000 0 0.0000 0 0.0000

3 0.4959 2 0.9918 0 0.0000 1 0.4959 0 0.0000

4 0.0488 2 0.0976 2 0.0976 0 0.0000 0 0.0000

5 0.1057 2 0.2114 2 0.2114 0.5 0.0529 0.5 0.0529

6 0.0081 2 0.0162 2 0.0162 1 0.0081 1 0.0081

7 0.0041 2 0.0082 4 0.0164 0 0.0000 1 0.0041

8 0.0081 2 0.0162 4 0.0324 0 0.0000 2 0.0162

12 0.0021 2 0.0042 6 0.0126 1 0.0021 3 0.0063

TOTAL 1.0000 2.0000 0.3866 0.5590 0.0876

TABLE 208-17B 

PERCENT MARKET SHARE (AVERAGE N) FOR SEATING POSITIONS 

IN LIGHT TRUCKS FROM 1977-1986 

FRONT FRONT 

OUTBOARD CENTER CENTER 

REAR 

OUTBOARD 

REAR 

# OF 

POSITION 

(A) 

OF 

BELTS 

MARKET 

SHARE 

(A*C) 

OF 

BELTS 

MARKET 

(A*D) 

SEAT # ING 

POSITIONS 

PER LIGHT 

TRUCK 

 % 

MARKET 

SHARE 

PER 

# 

OF 

BELTS 

(B) 

% 

MARKET 

SHARE 

(A*B) 

# 

(C) 

% # 

(D) 

% 

SHARE 

OF 

BELTS 

(E) 

% 

MARKET 

SHARE 

(A*E) 

2 0.2364 2 0.4728 0 0.0000 0 0.0000 0 0.0000

3 0.4310 2 0.8620 0 0.0000 1 0.4310 0 0.0000

4 0.1105 2 0.2210 2 0.2210 0 0.0000 0 0.0000

5 PU132 0.1245 2 0.2490 2 0.2490 1 0.1245 0 0.0000

5 S/V133 0.0014 2 0.0028 2 0.0028 1 0.0014 0 0.0000

6 0.0227 2 0.0454 2 0.0454 1 0.0227 1 0.0227

7 0.0378 2 0.0756 4 0.1512 0 0.0000 1 0.0378

8 0.0103 2 0.0206 4 0.0412 0 0.0000 2 0.0206

9 0.0189 2 0.0378 4 0.0756 1 0.0189 2 0.0378

12 0.0043 2 0.0086 6 0.0258 1 0.0043 3 0.0129

15 0.0022 2 0.0044 8 0.0176 1 0.0022 4 0.0088

TOTAL 1.0000 2.0000 0.8296 0.6050 0.1406

 132 PU = pickup 133 S/V = SUV or Van 

95
TABLE 208-17C 

PERCENT MARKET SHARE (AVERAGE N) FOR SEATING POSITIONS 

IN LIGHT TRUCKS FROM 1987-1994 

FRONT 

OUTBOARD 

REAR 

OUTBOARD 

FRONT 

CENTER 

REAR 

CENTER 

# OF 

SEATING 

PER LIGHT 

TRUCK 

SHARE 

PER 

POSITION 

OF 

BELTS 

MARKET 

(E) 

SHARE 

POSITIONS 

 % 

MARKET 

(A) 

# 

(B) 

% 

SHARE 

(A*B) 

# 

OF 

BELTS 

(C) 

% 

MARKET 

SHARE 

(A*C) 

# 

OF 

BELTS 

(D) 

% 

MARKET 

SHARE 

(A*D) 

# 

OF 

BELTS 

% 

MARKET 

(A*E) 

2 0.1393 2 0.2786 0 0.0000 0 0.0000 0 0.0000

3 0.3501 2 0.7002 0 0.0000 1 0.3501 0 0.0000

4 0.0656 2 0.1312 2 0.1312 0 0.0000 0 0.0000

5 PU 0.1933 2 0.3866 2 0.3866 1 0.1933 0 0.0000

5 S/V 0.0313 2 0.0626 2 0.0626 1 0.0313 0 0.0000

6 0.0843 2 0.1686 2 0.1686 1 0.0843 1 0.0843

7 0.1052 2 0.2104 4 0.4208 0 0.0000 1 0.1052

8 0.0036 2 0.0072 4 0.0144 0 0.0000 2 0.0072

9 0.0210 2 0.0420 4 0.0840 1 0.0210 2 0.0420

12 0.0039 2 0.0078 6 0.0234 1 0.0039 3 0.0117

15 0.0024 2 0.0048 8 0.0192 1 0.0024 4 0.0096

TOTAL 1.0000 2.0000 1.3108 0.6863 0.2600

TABLE 208-17D

PERCENT MARKET SHARE (AVERAGE N) FOR SEATING POSITIONS 

IN LIGHT TRUCKS FROM 1995-2001 

FRONT REAR 

OUTBOARD OUTBOARD 

FRONT 

CENTER 

REAR 

CENTER 

# OF 

SEATING 

POSITIONS 

PER LIGHT 

TRUCK 

(A*B) (C) (A*D) 

 % 

MARKET 

SHARE 

PER 

POSITION 

(A) 

# 

OF 

BELTS 

(B) 

% 

MARKET 

SHARE 

# 

OF 

BELTS 

% 

MARKET 

SHARE 

(A*C) 

# 

OF 

BELTS 

(D) 

% 

MARKET 

SHARE 

# 

OF 

BELTS 

(E) 

% 

MARKET 

SHARE 

(A*E) 

2 0.0466 2 0.0932 0 0.0000 0 0.0000 0 0.0000

3 0.1188 2 0.2376 0 0.0000 1 0.1188 0 0.0000

4 0.0636 2 0.1272 2 0.1272 0 0.0000 0 0.0000

5 PU 0.0388 2 0.0776 2 0.0776 1 0.0388 0 0.0000

5 S/V 0.1735 2 0.3470 2 0.3470 1 0.1735 0 0.0000

6 0.2975 2 0.5950 2 0.5950 1 0.2975 1 0.2975

7 0.1340 2 0.2680 4 0.5360 0 0.0000 1 0.1340

8 0.0802 2 0.1604 4 0.3208 0 0.0000 2 0.1604

9 0.0404 2 0.0808 4 0.1616 1 0.0404 2 0.0808

12 0.0021 2 0.0042 6 0.0126 1 0.0021 3 0.0063

15 0.0045 2 0.0090 8 0.0360 1 0.0045 4 0.0180

TOTAL 1.0000 2.0000 2.2138 0.6756 0.6970

The calculations of the total cost for LTVs in model year 1969 are shown in Table 208-18. 

96
TABLE 208-18

TOTAL CONSUMER COST PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEAR 1969

SAFETY BELT ASSEMBLY

 OF BELTS PER 

LIGHT TRUCK 

(A * B)

COST PER SEAT 

(A) 

“n” 

(B) 

WEIGHTED COST 

PER SAFETY

BELT ASSEMBLY 

Manual Front Outboard Without Retractor 

Lap Belt Only $20.67 1.95 $40.31

3-Point Belt $22.03 0.05 $ 1.10

Rear Outboard Without Retractor 

Lap Belt Only $15.97 0.39 $ 6.23

Front Center 

Lap Belt Only $13.95 0.56 $ 7.81

Rear Center 

Lap Belt Only $12.96 0.09 $ 1.16

TOTAL CONSUMER COST $56.61 

Summary calculations of the total consumer cost per light truck of safety belt assemblies and 

anchorages for models 1966-2001 are provided in Tables 208-19A thru E with the calculations 

for the total weight provided in Tables 208-20A thru E. 

TABLE 208-19A 

AVERAGE CONSUMER COST PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1966-1973

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘66-67 ‘68 ‘69 ‘70 ‘71 ‘72 ‘73 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $20.67 2.00 2.00 1.95 1.94 1.93

3-Point Belt $22.03 0.05 0.06 0.07

Manual With Retractor 

Lap Belt Only $33.46 1.87 1.87

3-Point Belt $34.82 0.13 0.13

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $15.97 0.39 0.39 0.39 0.39 0.39

With Retractor 

Lap Belt Only $18.29 0.39 0.39

3-Point Belt $22.34 

CENTER 

Front (lap) $13.95 0.56 0.56 0.56 0.56 0.56 0.56 0.56 

Rear (lap) $12.96 0.09 0.09 0.09 0.09 0.09 0.09 0.09

TOTAL COST PER LIGHT TRUCK $56.55 $56.55 $56.61 $56.63 $56.64 $83.21 $83.21

97
TABLE 208-19B 

AVERAGE CONSUMER COST PER LIGHT TRUCK 

FOR MODEL YEARS 1974-1980

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘74 ‘75 ‘76 ‘77 ‘78 ‘79 ‘80 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $20.67 

3-Point Belt $22.03 

Manual With Retractor 

Lap Belt Only $33.46 1.00 0.94 0.92 0.24 0.23 0.24 0.08

3-Point Belt $34.82 1.00 1.06 1.08 1.76 1.77 1.76 1.92

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $15.97 

With Retractor 

Lap Belt Only $18.29 0.39 0.39 0.39 0.83 0.83 0.83 0.83

3-Point Belt $22.34 

CENTER 

Front (lap) $13.95 0.56 0.56 0.56 0.61 0.61 0.61 0.61 

Rear (lap) $12.96 0.09 0.09 0.09 0.14 0.14 0.14 0.14

TOTAL COST PER LIGHT TRUCK $84.39 $84.47 $84.50 $94.82 $94.83 $94.82 $95.04

TABLE 208-19C 

AVERAGE CONSUMER COST PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1981-1987

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘81 ‘82 ‘83 ‘84 ‘85 ‘86 ‘87 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $20.67 

3-Point Belt $22.03 

Manual With Retractor 

Lap Belt Only $33.46 

3-Point Belt $34.82 2.00 2.00 2.00 2.00 2.00 2.00 2.00

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $15.97 

With Retractor 

Lap Belt Only $18.29 0.83 0.83 0.83 0.83 0.83 0.83 1.308

3-Point Belt $22.34 0.003 

CENTER 

Front (lap) $13.95 0.61 0.61 0.61 0.61 0.61 0.61 0.69

Rear (lap) $12.96 0.14 0.14 0.14 0.14 0.14 0.14 0.26

TOTAL COST PER LIGHT TRUCK $95.14 $95.14 $95.14 $95.14 $95.14 $95.14 $106.63 

98
TABLE 208-19D

AVERAGE CONSUMER COST PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1988-1994

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘88 ‘89 ‘90 ‘91 ‘92 ‘93 ‘94 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $20.67 

3-Point Belt $22.03 

Manual With Retractor 

Lap Belt Only $33.46 

3-Point Belt $34.82 2.00 2.00 2.00 2.00 2.00 2.00 2.00

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $15.97 

With Retractor 

Lap Belt Only $18.29 1.28 1.13 1.09 0.99

3-Point Belt $22.34 0.03 0.18 0.22 0.32 1.31 1.31 1.31

CENTER 

Front (lap) $13.95 0.69 0.69 0.69 0.69 0.69 0.69 0.69

Rear (lap) $12.96 0.26 0.26 0.26 0.26 0.26 0.26 0.26

TOTAL COST PER LIGHT TRUCK $106.72 $107.32 $107.49 $107.89 $111.90 $111.90 $111.90

TABLE 208-19E 

AVERAGE CONSUMER COST PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1995-2001

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY

COST 

PER 

SEAT ‘95 ‘96 ‘97 ‘98 ‘99 ‘00 ‘01 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only $20.67 

3-Point Belt $22.03 

Manual With Retractor 

Lap Belt Only $33.46 

3-Point Belt $34.82 2.00 2.00 2.00 2.00 2.00 2.00 2.00

REAR OUTBOARD 

Without Retractor 

Lap Belt Only $15.97 

With Retractor 

Lap Belt Only $18.29 

3-Point Belt $22.34 2.21 2.21 2.21 2.21 2.21 2.21 2.21

CENTER 

Front (lap) $13.95 0.68 0.68 0.68 0.68 0.68 0.68 0.68

Rear (lap) $12.96 0.70 0.70 0.70 0.70 0.70 0.70 0.70 

TOTAL COST PER LIGHT TRUCK $137.57 $137.57 $137.57 $137.57 $137.57 $137.57 $137.57

99
TABLE 208-20A 

AVERAGE WEIGHT PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1974-1980

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY

WEIGHT 

PER 

SEAT ‘66-67 ‘68 ‘69 ‘70 ‘71 ‘72 ‘73 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.25 2.00 2.00 1.95 1.94 1.93

3-Point Belt 2.54 0.05 0.06 0.07

Manual With Retractor 

Lap Belt Only 4.49 1.87 1.87

3-Point Belt 4.78 0.13 0.13 

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.35 0.39 0.39 0.39 0.39 0.39

With Retractor 

Lap Belt Only 2.24 0.39 0.39

3-Point Belt 3.45 

CENTER 

Front (lap) 0.85 0.56 0.56 0.56 0.56 0.56 0.56 0.56

Rear (lap) 0.92 0.09 0.09 0.09 0.09 0.09 0.09 0.09

TOTAL WEIGHT PER LIGHT TRUCK 5.59 5.59 5.60 5.60 5.61 10.45 10.45

TABLE 208-20B 

AVERAGE WEIGHT PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1974-1980

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY

WEIGHT 

PER 

SEAT ‘74 ‘75 ‘76 ‘77 ‘78 ‘79 ‘80 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.25 

3-Point Belt 2.54 

Manual With Retractor 

Lap Belt Only 4.49 1.00 0.94 0.92 0.24 0.23 0.24 0.08

3-Point Belt 4.78 1.00 1.06 1.08 1.76 1.77 1.76 1.92

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.35 

With Retractor 

Lap Belt Only 2.24 0.39 0.39 0.39 0.83 0.83 0.83 0.83

3-Point Belt 3.45 

CENTER 

Front (lap) 0.85 0.56 0.56 0.56 0.61 0.61 0.61 0.61

Rear (lap) 0.92 0.09 0.09 0.09 0.14 0.14 0.14 0.14

TOTAL WEIGHT PER LIGHT TRUCK 10.70 10.72 10.73 12.00 12.00 12.00 12.04

100
TABLE 208-20C 

AVERAGE WEIGHT PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1981-1987

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY

WEIGHT 

PER 

SEAT ‘81 ‘82 ‘83 ‘84 ‘85 ‘86 ‘87 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.25 

3-Point Belt 2.54 

Manual With Retractor 

Lap Belt Only 4.49 

3-Point Belt 4.78 2.00 2.00 2.00 2.00 2.00 2.00 2.00

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.35 

With Retractor 

Lap Belt Only 2.24 0.83 0.83 0.83 0.83 0.83 0.83 1.308 

3-Point Belt 3.45 0.003 

CENTER 

Front (lap) 0.85 0.61 0.61 0.61 0.61 0.61 0.61 0.69

Rear (lap) 0.92 0.14 0.14 0.14 0.14 0.14 0.14 0.26

TOTAL WEIGHT PER LIGHT TRUCK 12.07 12.07 12.07 12.07 12.07 12.07 13.33 

TABLE 208-20D

AVERAGE WEIGHT PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1988-1994

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY

WEIGHT 

PER 

SEAT ‘88 ‘89 ‘90 ‘91 ‘92 ‘93 ‘94 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.25 

3-Point Belt 2.54 

Manual With Retractor 

Lap Belt Only 4.49 

3-Point Belt 4.78 2.00 2.00 2.00 2.00 2.00 2.00 2.00

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.35 

With Retractor 

Lap Belt Only 2.24 1.28 1.13 1.09 0.99 

3-Point Belt 3.45 0.03 0.18 0.22 0.32 1.31 1.31 1.31

CENTER 

Front (lap) 0.85 0.69 0.69 0.69 0.69 0.69 0.69 0.69

Rear (lap) 0.92 0.26 0.26 0.26 0.26 0.26 0.26 0.26

TOTAL WEIGHT PER LIGHT TRUCK 13.36 13.54 13.59 13.71 14.91 14.91 14.91

101
TABLE 208-20E 

AVERAGE WEIGHT PER LIGHT TRUCK 

OF SAFETY BELT ASSEMBLIES AND ANCHORAGES 

FOR MODEL YEARS 1995-2001

“n” OF BELTS PER LIGHT TRUCK 

SAFETY BELT

ASSEMBLY SEAT ‘95 ‘97 ‘99 ‘01 

WEIGHT 

PER 

‘96 ‘98 ‘00 

FRONT OUTBOARD 

Manual Without Retractor 

Lap Belt Only 2.25 

3-Point Belt 2.54 

Manual With Retractor 

Lap Belt Only 4.49 

3-Point Belt 4.78 2.00 2.00 2.00 2.00 2.00 2.00 2.00

REAR OUTBOARD 

Without Retractor 

Lap Belt Only 1.35 

With Retractor 

Lap Belt Only 2.24 

3-Point Belt 3.45 2.21 2.21 2.21 2.21 2.21 2.21 2.21

CENTER 

Front (lap) 0.85 0.68 0.68 0.68 0.68 0.68 0.68 0.68 

Rear (lap) 0.92 0.70 0.70 0.70 0.70 0.70 0.70 0.70

TOTAL WEIGHT PER LIGHT TRUCK 18.41 18.41 18.41 18.41 18.41 18.41 18.41

Frontal Air Bags 

 

Although FMVSS 208 has long required the installation of safety belts at all designated seating 

positions in light trucks, it did not originally require those vehicles to provide automatic crash 

protection. A final rule issued in September 1991 extended the requirements for automatic crash 

protection, which currently applied to front outboard seats in passenger cars, to front outboard 

seats in trucks and multipurpose passenger vehicles with a GVWR of 8,500 pounds or less. The 

rule provided that the automatic restraint requirement would be phased into light trucks over a 

three-year period starting on September 1, 1994. The two types of automatic crash protection 

available to manufacturers for installation in their vehicles were air bags and automatic belts. 

However, in September 1993, NHTSA amended FMVSS 208 to require that all passenger cars 

and light trucks provide automatic protection by means of air bags. Every light truck (with a 

GVWR of 8,500 pounds or less) manufactured on or after September 1, 1998 would have to be 

equipped with an air bag and a manual lap/shoulder belt at both the driver’s and right front 

passenger’s seating positions. The vehicle manufacturers were far ahead of the implementation 

schedule, and a large number of model year 1996 light trucks were equipped with air bags. 

A series of cost and weight analyses were performed on air bags from six light trucks.134,135

Table 208-21 shows the arithmetic average weight and consumer cost for driver air bags and 

dual air bags.

134 Fladmark, DOT HS 809 799 (1996). 135 Fladmark, DOT HS 809 801:Section 5 and DOT HS 809 802:Sections 7,8 (1997). 

102
TABLE 208-21

AVERAGE WEIGHT AND CONSUMER COST 

OF AIRBAGS IN LIGHT TRUCKS 

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

Driver Air Bags 

1996 14.31 $265.78 

Dual Air Bags

1995-1996 26.48 $383.75

The main components of an air bag system are the air bag module, igniter/inflator, control 

module/sensors, clock spring, wiring harness, and knee bolster. Table 208-22 shows the average 

costs of the principal components of dual air bags for 1995-1996. The total cost and weight of 

air bags, and the cost of the main components, is about the same as in passenger cars. 

TABLE 208-22

OF PRINCIPAL COMPONENTS IN DUAL AIR BAGS 

IN LIGHT TRUCKS FROM 1995-1996 

AVERAGE WEIGHT AND CONSUMER COST 

PRINCIPAL COMPONENTS WEIGHT IN POUNDS CONSUMER COST ($2002) 

Driver Air Bag and 

Inflator Assembly 3.50 $ 57.11 

Passenger Air Bag and 

Inflator Assembly 10.39 $105.41 

Knee Bolster 7.82 $ 31.36

Control Module and Sensors 3.00 $137.42 

Clock Spring Assembly 0.43 $ 13.62 

Wiring Harness 1.34 $ 38.83

TOTAL 26.48 $383.75

On-Off Switches 

While air bags were providing significant overall safety benefits, NHTSA was very concerned 

that current designs had adverse effects, especially on children in rear-facing child seats installed 

in front passenger positions. To address this dilemma, NHTSA published a final rule in May 

1995 allowing manufacturers the option of installing a manual device that motorists could use to 

deactivate the front passenger-side air bag in vehicles manufactured on or after June 22, 1995, 

that cannot accommodate rear-facing child seats anywhere except in the front seat. The manual 

on/off switch had to use an ignition key to turn off the passenger air bag and to turn on the air 

bag. In addition, the manufacturer had to install a warning light that was separate from the air 

bag readiness indicator, which would indicate when the air bag was turned off. The light had to 

be visible to both the driver and the passenger. By model year 1998, switches for the passenger 

bag had become standard equipment in all pickup trucks with a GVWR of 8,500 pounds or less 

that could not accommodate a rear-facing infant seat in the rear seat. That basically includes all 

conventional cabs (no rear seats) and extended cabs (small rear seats) and only excludes certain 

full crew cabs. 

103
A cost and weight analysis was performed on air bag on/off switch systems.136 The sample 

vehicles each had two switches that were independent of each other; consequently, the cost of the 

two switches was double the cost of one switch. Table 208-23 shows the arithmetic average 

weight and consumer cost of one on/off switch for a pickup truck. 

TABLE 208-23

AVERAGE WEIGHT AND CONSUMER COST PER SWITCH 

OF PASSENGER SIDE ON/OFF SWITCHES 

COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

On/Off Switches 0.65 $28.12

In 1998, Congress directed NHTSA to issue a final rule mandating the use of advanced air bags 

to improve occupant protection for occupants of different sizes, belted and unbelted, while 

minimizing the risk to infants, children, and other occupants from injuries and deaths caused by 

air bags. The issuance of this rule will ensure that advanced air bag technologies are installed 

across the full spectrum of future fleets of motor vehicles. As a result, the air bags in those 

vehicles will be even more effective in saving lives and reducing serious injuries. NHTSA will 

analyze advanced air bags in future cost studies.

Summary Tables for FMVSS 208/209/210

Tables 208-24A and 24B summarize the total consumer cost and weight of the occupant 

protection systems installed in passenger cars for model years 1966-2001. In general, all these 

weights and costs should be attributed directly to the standards because installation of occupant 

protection systems was in response to, or in anticipation of, the regulatory requirements of these 

standards. The summary calculations are a compilation of the total cost and weight per vehicle 

of safety belts, driver air bags, and dual bags. An explanation of the tables follows: 

• Column (a): The total cost of safety belts was obtained from Tables 208-8A thru E, 

with its corresponding total weight obtained from Tables 208-9A thru E.

• Column (b): The unit cost/weight of driver air bags was obtained from Table 208-11.

• Column (c): The percent of passenger cars that had driver air bags in a specific model 

year was obtained from NHTSA crash data files and Polk registration files. 

• Column (d): The total cost/weight per vehicle for driver air bags was calculated by 

multiplying column (b) by column (c).

• Column (e): The unit cost/weight of dual air bags was obtained from Table 208-11. 

• Column (f): The percent of passenger cars that had dual air bags in a specific model 

year was obtained from NHTSA crash data files and Polk registration files. 

 136 Fladmark, G.L. and Khadilkar, A.V., Cost Estimates of One (1) Side Impact Crash Protection for 1998 Model 

Year Passenger Car and Two (2) Automatic Crash Protection On/Off Switches for 1998 Model Year Passenger Car, 

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, December 1998. 

(DOT HS 809 805). 

104
Column (g): The total cost/weight per vehicle for dual air bags was calculated by 

multiplying column (e) by column (f).

• 

• Column (h): The total cost/weight per vehicle of FMSVSS 208/209/210 in passenger 

cars was calculated by adding column (a) plus column (d) plus column (g). 

105
TABLE 208-24A 

SUMMARY TABLE FOR THE TOTAL CONSUMER COST 

ATTRIBUTABLE TO FMVSS 208/209/210 

 IN PASSENGER CARS BY MODEL YEAR 

SAFETY AIR BAGS

BELTS DRIVER DUAL 

FMVSS 

208-210

YEAR COST 

% OF 

(d) 

TOTAL 

COST 

PER CAR PER CAR 

(h) 

MODEL TOTAL 

(a) 

TOTAL 

(b) 

UNIT 

COST 

(c) 

CARS 

(e) 

UNIT 

COST 

(f) 

% OF 

CARS 

(g) 

TOTAL 

COST COST 

 PER CAR 

1966-67 $ 89.16 $ 89.16 

1968 $ 90.76 $ 90.76 

1969 $ 92.38 $ 92.38 

1970 $ 92.38 $ 92.38 

1971 $ 92.38 $ 92.38 

1972 $116.41 $116.41 

1973 $116.37 $116.37 

1974 $118.09 $118.09 

1975 $118.52 $118.52 

1976 $118.48 $118.48 

1977 $116.16 $116.16 

1978 $116.16 $116.16 

1979 $116.55 $116.55 

1980 $116.55 $116.55 

1981 $117.71 $117.71 

1982 $116.91 $116.91 

1983 $117.57 $117.57 

1984 $117.57 $117.57 

1985 $117.57 $284.09 0.13 $ 0.37 $117.94 

1986 $117.60 $284.09 0.75 $ 2.13 $119.73 

1987 $145.49 $284.09 1.17 $ 3.32 $396.72 0.05 $ 0.20 $149.01 

1988 $186.04 $284.09 1.66 $ 4.72 $396.72 0.02 $ 0.08 $190.84 

1989 $218.52 $284.09 3.62 $ 10.28 $396.72 0.72 $ 2.86 $231.66 

1990 $324.19 $284.09 26.51 $ 75.31 $396.72 2.00 $ 7.93 $407.43 

1991 $301.83 $284.09 35.18 $ 99.94 $396.72 0.55 $ 2.18 $403.95 

1992 $261.75 $284.09 48.42 $137.56 $396.72 4.89 $ 19.40 $418.71

1993 $264.77 $284.09 49.42 $140.40 $396.72 14.08 $ 55.86 $461.03 

1994 $246.75 $284.09 25.38 $ 72.10 $396.72 58.36 $231.53 $550.38

1995 $176.07 $284.09 9.14 $ 25.97 $396.72 89.51 $355.10 $557.14

1996 $153.47 $284.09 4.93 $ 14.01 $396.72 94.60 $375.30 $542.78

1997 $124.63 $396.72 100.00 $396.72 $521.35

1998 $124.63 $396.72 100.00 $396.72 $521.35

1999 $124.63 $396.72 100.00 $396.72 $521.35

2000 $124.63 $396.72 100.00 $396.72 $521.35

2001 $124.63 $396.72 100.00 $396.72 $521.35

106
TABLE 208-24B 

SUMMARY TABLE FOR THE TOTAL WEIGHT 

ATTRIBUTABLE TO FMVSS 208/209/210 

IN PASSENGER CARS BY MODEL YEAR 

SAFETY AIR BAGS

BELTS DRIVER DUAL

FMVSS 

208-210

MODEL

YEAR 

UNIT 

(d) 

CARS 

(a) 

TOTAL 

WEIGHT 

(b) 

WEIGHT 

(c) 

% OF 

CARS 

TOTAL 

WEIGHT 

PER CAR 

(e) 

UNIT 

WEIGHT 

(f) 

% OF 

(g) 

TOTAL 

WEIGHT 

PER CAR 

(h) 

TOTAL 

WEIGHT 

 PER CAR 

1966-67 9.36 9.36

1968 9.92 9.92

1969 10.49 10.49 

1970 10.49 10.49 

1971 10.49 10.49 

1972 15.28 15.28 

1973 15.29 15.29 

1974 16.51 16.51 

1975 16.58 16.58 

1976 16.57 16.57 

1977 16.40 16.40 

1978 16.40 16.40 

1979 16.47 16.47 

1980 16.47 16.47 

1981 16.53 16.53 

1982 16.48 16.48 

1983 16.53 16.53 

1984 16.53 16.53 

1985 16.53 13.46 0.13 0.02 16.55 

1986 16.54 13.46 0.75 0.10 16.64 

1987 18.77 13.46 1.17 0.16 26.76 0.05 0.01 18.94 

1988 22.18 13.46 1.66 0.22 26.76 0.02 0.005 22.41

1989 25.01 13.46 3.62 0.49 26.76 0.72 0.19 25.69 

1990 33.86 13.46 26.51 3.57 26.76 2.00 0.54 37.97 

1991 31.29 13.46 35.18 4.74 26.76 0.55 0.15 36.18 

1992 28.31 13.46 48.42 6.52 26.76 4.89 1.31 36.14 

1993 28.66 13.46 49.42 6.65 26.76 14.08 3.77 39.08 

1994 27.35 13.46 25.38 3.42 26.76 58.36 15.62 46.39

1995 22.19 13.46 9.14 1.23 26.76 89.51 23.95 47.37

1996 20.53 13.46 4.93 0.66 26.76 94.60 25.31 46.50

1997 18.38 26.76 100.00 26.76 45.14

1998 18.38 26.76 100.00 26.76 45.14

1999 18.38 26.76 100.00 26.76 45.14

2000 18.38 26.76 100.00 26.76 45.14

2001 18.38 26.76 100.00 26.76 45.14

107
Tables 208-25A and 25B summarize the total consumer cost and weight of the occupant 

protection systems installed in light trucks for model years 1966-2001. The summary 

calculations are a compilation of the total cost and weight per vehicle of safety belts, driver air 

bags, dual air bags, and on/off switches. An explanation of the tables follows: 

• Column (a): The total cost of safety belts was obtained from Tables 208-19A thru E, 

with its corresponding total weight obtained from Tables 208-20A thru E.

• Column (b): The unit cost/weight of driver air bags was obtained from Table 208-21.

• Column (c): The percent of light trucks that had driver air bags in a specific model year 

was obtained from NHTSA crash data files and Polk registration files.

• Column (d): The total cost/weight per vehicle for driver air bags was calculated by 

multiplying column (b) by column (c).

• Column (e): The unit cost/weight of dual air bags was obtained from Table 208-21.

• Column (f): The percent of light trucks that had dual air bags in a specific model year 

was obtained from NHTSA crash data files and Polk registration files.

• Column (g): The total cost/weight per vehicle for dual air bags was calculated by 

multiplying column (e) by column (f).

• Column (h): The unit cost/weight of passenger side on/off switches was obtained from

Table 208-23.

• Column (i): The percent of light trucks that had passenger side on/off switches in a 

specific model year was obtained from NHTSA crash data files and Polk registration 

files.

• Column (j): The total cost/weight per vehicle for passenger side on/off switches was 

calculated by multiplying column (h) by column (i).

• Column (k): The total cost/weight per vehicle of FMSVSS 208/209/210 in light trucks 

was calculated by adding column (a) plus column (d) plus column (g) plus column (j).

108
TABLE 208-25A 

SUMMARY TABLE FOR THE TOTAL CONSUMER COST 

ATTRIBUTABLE TO FMVSS 208/209/210 

IN LIGHT TRUCKS (LTVs) BY MODEL YEAR 

SAFETY AIR BAGS

BELTS DRIVER DUAL

ON/OFF 

SWITCHES

FMVSS 

208-210

MODEL 

YEAR 

(a) 

TOTAL 

COST 

(b) 

UNIT 

COST 

(c) 

% 

OF 

LTVS 

(d) 

TOTAL 

COST 

PER 

 LTV 

(e) 

UNIT 

COST 

(f) 

% 

 OF 

LTVS 

(g) 

TOTAL 

COST 

PER 

LTV 

(h) 

% 

COST 

UNIT 

COST 

(i) 

OF 

LTVS 

(j) 

TOTAL 

PER 

LTV 

(k) 

TOTAL 

COST 

PER 

LTV 

1966-67 $ 56.55 $ 56.55 

1968 $ 56.55 $ 56.55 

1969 $ 56.61 $ 56.61 

1970 $ 56.63 $ 56.63 

1971 $ 56.64 $ 56.64 

1972 $ 83.21 $ 83.21 

1973 $ 83.21 $ 83.21 

1974 $ 84.39 $ 84.39 

1975 $ 84.47 $ 84.47 

1976 $ 84.50 $ 84.50 

1977 $ 94.82 $ 94.82 

1978 $ 94.83 $ 94.83 

1979 $ 94.82 $ 94.82 

1980 $ 95.04 $ 95.04 

1981 $ 95.14 $ 95.14 

1982 $ 95.14 $ 95.14 

1983 $ 95.14 $ 95.14 

1984 $ 95.14 $ 95.14 

1985 $ 95.14 $ 95.14 

1986 $ 95.14 $ 95.14 

1987 $106.63 $106.63 

1988 $106.72 $106.72 

1989 $107.32 $107.32 

1990 $107.49 $107.49 

1991 $107.89 265.78 3.08 $ 8.19 $116.08 

1992 $111.90 265.78 14.75 $ 39.20 $151.10 

1993 $111.90 265.78 19.30 $ 51.30 $163.20 

1994 $111.90 265.78 26.78 $ 71.18 383.75 7.56 $ 29.01 $212.09 

1995 $137.57 265.78 66.30 $176.21 383.75 13.58 $ 52.11 $365.89 

1996 $137.57 265.78 55.56 $147.67 383.75 37.69 $144.64 28.12 2.80 $ 0.79 $430.67 

1997 $137.57 265.78 22.25 $ 59.14 383.75 71.34 $273.77 28.12 22.14 $ 6.23 $476.71`

1998 $137.57 383.75 97.84 $375.46 28.12 36.64 $10.30 $523.33

1999 $137.57 383.75 98.61 $378.42 28.12 36.52 $10.27 $526.26

2000 $137.57 383.75 99.08 $380.22 28.12 34.23 $ 9.63 $527.42

2001 $137.57 383.75 99.68 $382.52 28.12 31.10 $ 8.75 $528.84

109
TABLE 208-25A 

SUMMARY TABLE FOR THE TOTAL WEIGHT 

ATTRIBUTABLE TO FMVSS 208/209/210 

IN LIGHT TRUCKS (LTVs) BY MODEL YEAR 

SAFETY AIR BAGS

BELTS DRIVER DUAL

ON/OFF 

SWITCHES

FMVSS 

208-210

MODEL 

YEAR

(a) 

TOTAL 

WEIGHT

LTVS

(b) (j) 

UNIT 

WEIGHT

(c) 

% 

OF 

LTVS

(d) 

TOTAL 

WEIGHT 

PER 

 LTV

(e) 

UNIT 

WEIGHT

(f) 

% 

 OF 

LTVS

(g) 

TOTAL 

WEIGHT 

PER 

LTV

(h) 

UNIT 

WEIGHT

(i) 

% 

OF 

TOTAL 

WEIGHT 

PER 

LTV

(k) 

TOTAL 

WEIGHT 

PER 

LTV

1966-

67 5.59 5.59

1968 5.59 5.59

1969 5.60 5.60

1970 5.60 5.60

1971 5.61 5.61

1972 10.45 10.45 

1973 10.45 10.45 

1974 10.70 10.70 

1975 10.72 10.72 

1976 10.73 10.73 

1977 12.00 12.00 

1978 12.00 12.00 

1979 12.00 12.00 

1980 12.04 12.04 

1981 12.07 12.07 

1982 12.07 12.07 

1983 12.07 12.07 

1984 12.07 12.07 

1985 12.07 12.07 

1986 12.07 12.07 

1987 13.33 13.33 

1988 13.36 13.36 

1989 13.54 13.54 

1990 13.59 13.59 

1991 13.71 14.31 3.08 0.44 14.15 

1992 14.91 14.31 14.75 2.11 17.02 

1993 14.91 14.31 19.30 2.76 17.67 

1994 14.91 14.31 26.78 3.83 26.48 7.56 2.00 20.74 

1995 18.41 14.31 66.30 9.49 26.48 13.58 3.60 31.50 

1996 18.41 14.31 55.56 7.95 26.48 37.69 9.98 0.65 2.80 0.02 36.36 

1997 18.41 14.31 22.25 3.18 26.48 71.34 18.89 0.65 22.14 0.14 40.62 

1998 18.41 26.48 97.84 25.91 0.65 36.64 0.24 44.56

1999 18.41 26.48 98.61 26.11 0.65 36.52 0.24 44.76

2000 18.41 26.48 99.08 26.24 0.65 34.23 0.22 44.87 

2001 18.41 26.48 99.68 26.40 0.65 31.10 0.20 45.01

110
FMVSS 211 – [Does not currently exist] 

FMVSS 212 – WINDSHIELD MOUNTING 

 

FMVSS 212 became effective on January 1, 1970 (passenger cars) and September 1, 1978 

(multipurpose passenger vehicles, trucks, buses) and establishes windshield retention 

requirements for motor vehicles during crashes. The purpose of this standard is to reduce crash 

injuries and fatalities by providing for retention of the vehicle windshield during a crash, thereby 

utilizing fully the penetration-resistance and injury-avoidance properties of the windshield 

glazing material and preventing the ejection of occupants from the vehicle. This standard applies 

to passenger cars, multipurpose passenger vehicles, trucks, and buses having a GVWR of 10,000 

pounds or less. However, it does not apply to forward control vehicles, walk-in van-type 

vehicles, or to open-body type vehicles with fold-down or removable windshields.137

The standard requires that a vehicle traveling longitudinally forward at any speed up to and 

including 30 miles per hour impacts a fixed collision barrier that is perpendicular to the line of

travel of the vehicle, the windshield mounting of the vehicle shall retain not less than the 

minimum portion of the windshield periphery specified in the following: 

• Vehicles equipped with automatic restraint systems shall retain not less than 50 percent 

of the portion of the windshield periphery on each side of the vehicle longitudinal 

centerline. 

• Vehicles not equipped with automatic restraint systems shall retain not less than 75 

percent of the windshield periphery. 

Before 1963, windshields were sealed inside a rubber gasket or molding that in turn was attached 

and sealed to the frame. It was a relatively loose attachment. In low speed impacts, the rubber 

gasket had some energy absorbing “give”. At higher speeds, the gasket could partly or 

completely tear away from the frame, beginning during the initial vehicle collision and 

deformation and continuing as occupants impacted the windshield. 

Bonding of the windshield directly to its frame with adhesives gradually (1963-1985) superseded 

the earlier method of first enclosing the windshield in a rubber gasket and then attaching the 

gasket to the frame. Adhesive bonding resembles HPR windshields in that it is primarily a 

technical advance, the synthesis of resilient sealing materials, than an addition of hardware to the 

car. The new bonding materials allowed the elimination of rubber gaskets in return for an 

inexpensive sealant and a minor increase in labor costs. Thus, the shift to adhesive bonding 

began in some vehicles well before anybody anticipated FMVSS 212, but rubber gaskets 

persisted in other make-models for quite a few years after the standard. Although rubber gaskets 

are generally a looser installation than adhesive bonding, they can readily be designed to meet 

FMVSS 212. Each installation method has advantages, and the gradual shift from one to the 

other was motivated by various factors, sometimes including FMVSS 212. However, vehicle 

manufacturers could meet the standard with either method. 

Pickup trucks, vans, and SUVs also kept rubber gaskets during most of the 1970’s, and in many 

cases after FMVSS 212 was extended to light trucks (September 1, 1978). Manufacturers may 

137 Legal citation: 49 CFR 571.212 (2004). 

111
have been especially concerned that operation on rough roads could accelerate deterioration of 

adhesive bonds, as compared to rubber gaskets. Adhesive bonding was gradually phased in from 

1978 to approximately 1985. The final transition to adhesive bonding may have been spurred by 

anticipation of safety benefits, cost advantages with the second-generation sealants, and a 1976 

rule allowing NHTSA to conduct the FMVSS 212 test in a wider range of temperatures, from 15 

to 110 degrees Fahrenheit. 

FOR WINDSHIELD MOUNTINGS IN PASSENGER VEHICLES 

A 1980 study compared rubber gaskets to adhesive bonding in one passenger car and three light 

trucks.138 Table 212-1 shows the arithmetic average weight and consumer cost for the 

windshield mountings.

TABLE 212-1 

AVERAGE WEIGHT AND CONSUMER COST 

MATERIAL WEIGHT IN POUNDS CONSUMER COST ($2002) 

Rubber Gasket 5.92 $35.51

Adhesive Bonding 0.69 $12.61

The substantial decrease in weight and consumer cost, when using adhesive bonding, cannot be 

attributed to the standard. Manufacturers could have moved to the use of the less costly adhesive 

bonding even without the standard. Furthermore, adhesive bonding was in common use on 

windshields long before the standard was proposed and rubber gaskets continued to be used for 

some years after the standard took effect. 

Ford Motor Company in comments on the NHTSA evaluation report of FMVSS 205/212 

questioned whether the preceding cost analysis realistically accounted for the full cost of 

adhesive bonding. Ford stated “to achieve an acceptable appearance with adhesive bonding, 

interior and exterior moldings must be added to hide the bond area. In addition, a blackout paint 

band is generally added to the periphery of the glazing to block vision of the bond area and the 

underside of the trim moldings. As a result, adhesive bonding results in a cost and weight 

penalty, except on some luxury models and convertibles that have interior and exterior trim

moldings installed for other reasons.”139 

FMVSS 213 became effective on April 1, 1971 and specifies requirements for child restraint 

systems used in motor vehicles and aircraft. The purpose of this standard is to reduce the 

number of children killed or injured in motor vehicle crashes and in aircraft. This standard 

applies primarily to equipment that may be purchased for use in a vehicle, rather than to the 

vehicle itself.140 No cost studies of this standard have been done, and none are planned by the 

agency. 

 

FMVSS 213 – CHILD RESTRAINT SYSTEMS 

138 McLean, DOT HS 805 602:33-40 (1980). 139 Ford Motor Company Letter, Request for Comment on Evaluation Report on Federal Motor Vehicle Safety 

Standards 205/212, July 23, 1985. 140 Legal citation: 49 CFR 571.213 (2004). 

112
FMVSS 214 – SIDE IMPACT PROTECTION

FMVSS 214 became effective on January 1, 1973 and specified performance requirements for 

protection of occupants in side impact crashes. The purpose of this standard is to reduce the risk 

of serious and fatal injury to occupants of passenger cars, multipurpose passenger vehicles, 

trucks, and buses in side impact crashes by: 

• specifying vehicle crashworthiness requirements in terms of accelerations measured on 

anthropomorphic dummies in test crashes, 

• specifying strength requirements for side doors, and 

• other means141

Passenger Car Studies 

Side Door Beams. FMVSS 214 originally specified performance requirements, effective 

January 1, 1973, for each side door in a passenger car to mitigate occupant injuries in side 

impacts by reducing the extent to which the side structure of a car is pushed into the passenger 

compartment during a side impact. The standard initially specified three-stage static crush test 

(initial, intermediate, and peak) to measure the crush resistance of the side doors, and required 

each door to resist crush forces that are applied by a piston pressing a 12-inch diameter steel 

cylinder inward against the door’s outside surface in a laboratory test.

Early studies concerning side impact protection demonstrated that in fatal side collisions most 

occupants die because of the door structures collapsing inward on them. The static crush tests 

were intended to ensure that there were strong door structures to limit this intrusion. Under the 

peak crush test, the vehicle door may not be deformed more than 18 inches inward when the door 

is subjected to a force of 7,000 pounds or two times the curb weight of the vehicle, whichever is 

less.142 The standard, however, does not attempt to regulate directly the level of crash forces on 

an occupant who strikes or is struck by the car’s interior during a side impact crash. Since the 

standard became effective on January 1, 1973, vehicle manufacturers have generally chosen to 

meet its performance requirements by reinforcing the side doors with metal beams. The added 

side door beam helps to make a pole, tree, guardrail, or other fixed object slide by the occupant’s 

position, thus reducing intrusion into the passenger compartment. 

Three cost and weight analyses were performed on side door beams and body pillars from

twenty-three make-model two-door passenger cars and fourteen make-model four-door 

passenger cars representing implementation and trend systems from 1973 to 1981.143,144,145 

 141 Legal citation: 49 CFR 571.214 (2004). 142 The standard was amended on March 17, 1980 to add a new door crush test (a 3-stage crush test) allowing the

seats to be installed during the test. In this test, the peak force is 3.5 times the curb weight or 12,000 pounds, 

whichever is smaller. 143 McLean, DOT HS 803 871:22-37 (1978). 144 Harvey, M.R. and Eckel, C.E., Cost Evaluation for Nine Federal Motor Vehicle Safety Standards, Task IX: 

Side Door Strength, Identification and Cost Evaluation of Design and Manufacturing Changes, Washington: U.S.

Department of Transportation, National Highway Traffic Safety Administration, November 1979. (DOT HS 805

450). 

145 Gladstone, DOT HS 806 257:4-1 thru 4-4 (1982). 

113
(Changes in the body pillars discussed in the October 1978 study were a result of model redesign 

and not directly related to the standard, therefore, the weight and consumer cost for them were 

not included in the side door strength calculations.) Table 214-1 shows the sales-weighted 

average weight and consumer cost for the side door beams in two- and four-door passenger cars. 

TABLE 214-1 

AVERAGE WEIGHT AND CONSUMER COST PER VEHICLE 

OF SIDE DOOR BEAMS IN 

TWO- AND FOUR-DOOR PASSENGER CARS 

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

Two-Door 

1973 33.39 $49.50

1975-1978 23.90 $38.45

1979-1981 28.17 $45.02

Four-Door 

1973 43.53 $88.55

1975-1979 26.60 $73.02

1979-1981 23.98 $52.76

Assuming that the average consumer cost decreased at a linear rate from 1973 to 1979-81 and 

leveled off after that, the average weight and consumer cost of the side impact protection 

attributable to the static requirements of the standard in any given model year are shown in Table 

214-2. 

For model years 1975-1979, some design refinement had occurred with the door beams for the 

four-door models, with more refinement occurring with the 1980 models. All through the late 

1970’s and early 1980’s, downsizing was occurring and vehicle designs were incorporating 

design features into the vehicle bodies to cope with requirements and relying less on just door 

beams, consequently, door beams were becoming lighter and less costly. 

In the four-door passenger cars, the refinements and downsizing resulted in a 45 percent decrease 

in weight from 1973 to 1979-1981, with the 1979-1981 weight less than the weight for the twodoor models. The cost for the four-door models decreased 40 percent in the same time period; 

however, the 1979-1981 costs were still greater than the two-door models. The costs and 

weights of the 1975-1979 models are lower than in 1973 and higher than in 1979-1981. 

While the two-door models saw a decrease of 28 percent in weight and 22 percent in cost from

1973 to 1975-1978, there was in increase of 18 percent in weight and 17 percent in cost from

1975-1978 to 1979-1981. This may be an artifact of the specific make-models selected for the 

1975-1978 study. Notwithstanding this exception, there appears to be a general downward trend 

from 1972 to 1979-1981 in both the two- and four-door passenger cars. 

114
TABLE 214-2 

IN PASSENGER CARS BY MODEL YEAR

AVERAGE WEIGHT AND CONSUMER COST 

OF SIDE IMPACT PROTECTION

ATTRIBUTABLE TO STATIC REQUIREMENTS 

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

Two-Door 

1973 33.39 $49.50

1974 32.52 $48.75

1975 31.65 $48.01

1976 30.78 $47.26

1977 29.91 $46.51

1978 29.04 $45.77

1979-2001 28.17 $45.02

Four-Door 

1973 43.53 $88.55

1974 40.27 $82.59

1975 37.01 $76.62

1976 33.76 $70.66

1977 30.50 $64.69

1978 27.24 $58.73

1979-2001 23.98 $52.76

FMVSS 214 Upgrade – Dynamic Test Requirement. NHTSA’s analysis of real-world crash 

data showed that strengthening the side doors with metal beams was indeed effective in single 

car side impacts but had little effect on reducing fatalities in multi-car crashes. Consequently, 

FMVSS 214 was amended in October 1990 to upgrade its test procedures and performance 

requirements for passenger cars.

The amendments required that each passenger car, in addition to the static crush performance 

requirements, must protect its occupants in a full-scale dynamic crash test in which the passenger 

car is struck on either side by a moving deformable barrier simulating another vehicle. 

Instrumented test dummies are positioned in the target car to measure the potential for injuries to

an occupant’s thorax and pelvis. Accelerations at the dummy’s upper rib, lower rib, and lower 

spine are measured, and a Thoracic Trauma Index, TTI(d) is calculated from these accelerations. 

Four-door passenger cars must score 85 or less, while two-door passenger cars must score 90 or 

less. In addition, the pelvis acceleration must be less than 130 g’s. However, the safety benefits 

are mainly from chest injury reduction. The requirements were phased in with 10% of new 

passenger cars in model year 1994, 25% in 1995, 40% in 1996, and 100% in 1997 (i.e., after 

September 1, 1996).

Manufacturers initially relied on one or more of the following strategies to ensure their vehicles 

met the dynamic test: 

• No changes necessary to meet the dynamic test 

• Major structure changes applied to the A-pillars, the front and rear door or rear panel 

(two-door models), the B-pillar, the C-pillar, or other components

115
• Minor structure changes such as additional or strengthened door beams and some

additional steel plates

• Padding added to inside of door skin or inner door structure

NHTSA sent information requests to vehicle manufacturers asking them to identify any 

components that were added or redesigned to meet the dynamic performance requirements. The 

requests were reviewed to determine which alternative the vehicle manufacturers chose, and it is 

our belief that an estimated 56% of the vehicles certified to comply with this requirement had 

substantial structural reinforcement changes and added padding, 21% had minor structural 

changes and added padding, 6% just added padding to comply, while 17% of the vehicles had no 

structural changes or added padding.146 Of course, all vehicles continued to have side door 

beams and other equipment previously installed to meet the original, static requirement of 

FMVSS 214. 

Since our teardown cost analysis was limited to a sample of vehicles that all had major structure 

changes, a simple average of these teardowns would be a substantial overestimate of the cost of 

FMVSS 214. Therefore, to calculate a realistic cost of the standard, it was necessary to generate 

estimates for the vehicles that did not have major structure changes, append those estimates to 

the contractor’s costs, and average the results. 

• 

Here is a more detailed discussion of the cost implications of the alternative methods to secure 

compliance with FMVSS 214. 

No Structural Changes or Padding. Some vehicles did not have to incorporate any 

structural changes or added padding to their vehicles to meet the dynamic standard. Of

course, even in these vehicles, the equipment used to meet the static requirement would 

continue to be in place. Therefore, the full cost and weight of FMVSS 214 would be 

equal to the weight and consumer cost from the study of the two- and four-door 

passenger cars from 1979-1981. These results for these static requirements are shown in 

Table 214-3.

 

TABLE 214-3 

AVERAGE WEIGHT AND CONSUMER COST 

OF FMVSS 214 IN TWO- AND FOUR-DOOR 

 PASSENGER CARS THAT REMAINED UNCHANGED 

CAR TYPE WEIGHT IN POUNDS CONSUMER COST ($2002) 

Two-Door 28.17 $45.02

Four-Door 23.98 $52.76

• Major Structure Changes with Padding. Substantial structural changes were applied to 

the A-pillars, the front and rear door or rear panel (two-door models), the B-pillar, and 

the C-pillar. The changes to the pillars were to help support the loads on the door hinges 

and latches and provide additional structural rigidity so that impact loads could be 

transferred to the rest of the vehicle body without buckling. In some cases, a dashboard 

 146 Kahane, C.J., Evaluation of FMVSS 214 Side Impact Protection, Dynamic Performance Requirement,

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, October 1999. 

(DOT HS 809 004:141-142).

116
level cross-member between left and right A-pillars was added. Floor cross-members 

linking the left and right B-pillars were added or strengthened and the same was done for 

the C-pillars. Changes to the doors and rear panels (two-door models) typically consisted 

of additional door beams and energy absorbing designs in the inner door structure. Three 

cost and weight analyses comprised two make-model two-door passenger cars and seven 

make-model four-door passenger cars representing systems from 1994-1998.147,148,149 

These contractor reports attempted to estimate separately the cost and weight of 

equipment needed only to meet the dynamic standard versus equipment needed to meet 

the static requirement. However, we have added these costs and weights to produce a 

single, more reliable estimate of the total cost and weight of FMVSS 214. Table 214-4 

shows the arithmetic average total weight and consumer cost of the side impact 

protection system (dynamic and static requirements) in two- and four-door passenger 

cars.

TABLE 214-4 

AVERAGE WEIGHT AND CONSUMER COST 

OF FMVSS 214 (DYNAMIC PLUS STATIC REQUIREMENTS) 

IN TWO- AND FOUR-DOOR PASSENGER CARS 

WITH MAJOR STRUCTURE CHANGES 

CAR TYPE WEIGHT IN POUNDS CONSUMER COST $2002 

Two-Door 70.33 $222.58 

Four-Door 90.59 $271.58

• Cost and Weight of Padding. Padding was typically affixed to the inside of the door skin 

or inner door structure. The foam padding was strategically placed with one piece to 

protect the upper and lower rib cage of the occupant and other piece located to protect the 

pelvis. As stated above, the contractor did not tear down any vehicles whose 

modifications were limited to padding. Therefore, we reviewed the contractor’s nine

teardowns of vehicles that received padding plus major structure and isolated the costs

specifically related to padding. Next, we compared the padding in these vehicles to 

padding in vehicles that did not receive major structure, and found them quite similar in 

size and shape. The component cost summaries, with corresponding photographs from 

the sample vehicles in the teardown cost studies, were analyzed and the padding 

information was extracted. The arithmetic average for the padding incorporated into the 

front door, rear door, and in some cases the B pillar was calculated from the three cost 

and weight analyses for the 1994-1998 model year passenger cars. Table 214-5 shows 

the average weight and consumer cost of just the padding in the two- and four-door 

passenger cars.

 147 Fladmark, DOT HS 809 800 (1996). 148 Fladmark, DOT HS 809 803 (1997). 149 Fladmark, DOT HS 809 805:Section 6 (1998).

117
TABLE 214-5 

AVERAGE WEIGHT AND CONSUMER COST 

OF PADDING IN TWO- AND FOUR-DOOR PASSENGER CARS 

CAR TYPE WEIGHT IN POUNDS CONSUMER COST $2002

Two-Door 0.91 $ 9.85

Four-Door 1.27 $13.94

• Cost and Weight of Minor Structure Changes. Minor structure changes usually consisted 

of additional or strengthened door beams and some additional steel plates added to 

strengthen areas on the pillars around the door latches and hinges. As stated above, 

teardowns were limited to vehicles with major structure changes. In order to estimate the 

cost of new structure in the 21 percent of vehicles that had only minor changes, we 

needed to: (1) establish some kind of ratio of the cost of “minor” to “major” structural 

changes; (2) isolate in the teardown sample the FMVSS 214 costs specifically associated 

with major structural changes, as opposed to, padding or continuation of the equipment 

needed to meet the static requirement; and (3) multiply the ratio of “minor” to “major”

structure by the cost of major structure.

1) In the seven teardown vehicles for which we also had clear diagrams or enumerations 

of the new structure, we found an average of 4.43 relatively massive and costly new 

structural components per vehicle, such as large-size pillar stiffeners, cross members, 

beams, and sill reinforcements. Information requests to the manufacturers furnished 

detailed diagrams or enumerations of new structure in six make-models that we 

described above as receiving only “minor” structure. For the most part, these new 

structures were limited to a few very low-cost items such as small, localized beams 

and sills, but some models received one or even two massive and costly components. 

In all, these six make-models received an average of 0.83 massive and costly 

components per vehicle. Therefore, we estimate that the cost ratio of “minor” to 

“major” structure must have been close to 0.83/4.43 = 19 percent. 

2) The top section of Table 214-6 shows the average cost and weight of major new 

structure in the teardown vehicles. From the total cost or weight of FMVSS 214 (e.g., 

$271.58 in four-door passenger cars from Table 214-4), deduct the cost or weight of 

padding (e.g., $13.94 from Table 214-5) and the cost or weight of the existing 

structures used for meeting the static requirements of FMVSS 214 (e.g., $52.76 from

Table 214-3). Whatever remains (e.g., $204.88 in the four-door passenger cars) is the 

cost of the added structures. 

3) Multiply the cost or weight of added “major” structures in the teardown sample by 19 

percent to obtain an estimate of the cost or weight of added “minor” structures, as 

shown in the lower section of Table 214-6. 

118
TABLE 214-6 

DETERMINATION OF THE 

AVERAGE WEIGHT AND CONSUMER COST 

OF MINOR STRUCTURE CHANGES 

IN TWO- AND FOUR-DOOR PASSENGER CARS 

 TWO-DOOR FOUR-DOOR

CATEGORY WEIGHT COST WEIGHT COST

214 Teardown Studies 70.33 $222.58 90.59 $271.58 

- Padding 0.91 $ 9.85 1.27 $ 13.94 

- Static Requirements 28.17 $ 45.02 23.98 $ 52.76 

= Major Structure 41.25 $167.71 65.34 $204.88 

* Percentage Change 0.19 0.19 0.19 0.19 

= Minor Structure 7.84 $ 31.86 12.41 $ 38.93 

Table 214-7 shows the average weight and consumer cost of the side impact protection system in 

two- and four-door passenger cars, broken out by the changes incorporated by the vehicle 

manufacturers. It is necessary to add the cost of static protection, padding, and or minor 

structures in the vehicles that have more than one of those items.

TABLE 214-7 

AVERAGE WEIGHT AND CONSUMER COST 

OF FMVSS 214 (DYNAMIC PLUS STATIC REQUIREMENTS) 

IN ALL PASSENGER CARS

CHANGED TO MEET WEIGHT IN

DYNAMIC STANDARD POUNDS 

CONSUMER COST

($2002)

PERCENT 

 OF CARS 

Two-Door 

Major Structure Changes

+ Padding + Static 70.33 $222.58 56 

Minor Structure Changes

+ Padding + Static 36.92 $ 86.73 21 

Padding + Static 29.08 $ 54.87 6 

Static Only 28.17 $ 45.02 17 

WEIGHTED AVERAGE 53.67 $153.80 

Four-Door 

Major Structure Changes

+ Padding + Static 90.59 $271.58 56 

Minor Structure Changes

+ Padding + Static 37.66 $105.63 21 

Padding + Static 25.25 $ 66.70 6 

Static Only 23.98 $ 52.76 17 

WEIGHTED AVERAGE 64.23 $187.24 

Summary Tables for FMVSS 214

Tables 214-8A and 8B summarize the total weight and cost of the side impact protection systems 

installed in passenger cars for model years 1969-2001. That includes the cost of side door beams 

installed by manufacturers voluntarily before the effective date of January 1, 1973. Even though 

these installations predated FMVSS 214, their weights and costs should be attributed to the 

standard because installation of side door beams was in response to, or in anticipation of, the 

regulatory requirements of this standard. NHTSA announced its intention to regulate side door 

119
strength with an ANPRM in October 1968, followed by several NPRMs. The Final Rule, issued 

in October 1970, became effective on January 1, 1973. The summary calculations are a 

compilation of the total cost and weight per vehicle of static and dynamic requirements in twoand four-door passenger cars. An explanation of the tables follows: 

• Column (a): The unit cost/weight of side impact protection for two-door passenger cars 

were determined as follows:

o Model Years 1969-1993 – Cost/Weight Attributable to Static Requirements from

Table 214-2 

o Model Years 1994-1996 – Phase in of Dynamic Requirements 

♣ 90% * 1993 Unit Cost/Weight + 10% * 1997 Unit Cost/Weight = 

1994 Unit Cost/Weight 

♣ 75% * 1993 Unit Cost/Weight + 25% * 1997 Unit Cost/Weight = 

♣ 60% * 1993 Unit Cost/Weight + 40% * 1997 Unit Cost/Weight = 

1996 Unit Cost/Weight 

• 

1995 Unit Cost/Weight 

o Model Years 1997-2001 – Cost/Weight Attributable to Dynamic Requirements 

from Table 214-7 

Column (b): The percent of two-door passenger cars in a specific model year was 

obtained from NHTSA crash data files and Polk registration files. The percents for 

model years 1969-1973 were determined by multiplying the proportion of two-door 

passenger cars that met FMVSS 214 in 1969-1973 by the percent of two-door passenger 

cars in 1969-1973.

• Column (c): The unit cost/weight of side impact protection for four-door passenger cars 

were determined as follows:

o Model Years 1969-1993 – Cost/Weight Attributable to Static Requirements from

Table 214-2 

o Model Years 1994-1996 – Phase in of Dynamic Requirements 

♣ 90% * 1993 Unit Cost/Weight + 10% * 1997 Unit Cost/Weight = 

1994 Unit Cost/Weight 

♣ 75% * 1993 Unit Cost/Weight + 25% * 1997 Unit Cost/Weight = 

1995 Unit Cost/Weight 

♣ 60% * 1993 Unit Cost/Weight + 40% * 1997 Unit Cost/Weight = 

1996 Unit Cost/Weight 

o Model Years 1997-2001 – Cost/Weight Attributable to Dynamic Requirements 

from Table 214-7 

• Column (d): The percent of four-door passenger cars in a specific model year was 

obtained from NHTSA crash data files and Polk registration files. The percents for 

model years 1969-1973 were determined by multiplying the proportion of four-door 

passenger cars that met FMVSS 214 in 1969-1973 by the percent of four-door passenger 

cars in 1969-1973.

• Column (e): The total cost/weight per vehicle of FMVSS 214 in passenger cars = 

(a * b) + (c *d) 

120
TABLE 214-8A 

SUMMARY TABLE FOR THE TOTAL CONSUMER COST 

OF SIDE IMPACT PROTECTION

ATTRIBUTABLE TO FMVSS 214 

PER PASSENGER CAR BY MODEL YEAR

TWO-DOOR FOUR-DOOR

MODEL

YEAR 

(a) 

UNIT COST

(b) 

% OF 

CARS 

(c) 

UNIT COST

(d) 

% OF 

CARS 

(e) 

TOTAL COST

PER VEHICLE 

1969 $ 49.50 9.32 $ 88.55 7.68 $ 11.41

1970 $ 49.50 20.28 $ 88.55 14.72 $ 23.07 

1971 $ 49.50 25.71 $ 88.55 18.29 $ 28.92 

1972 $ 49.50 27.51 $ 88.55 21.49 $ 32.65 

1973 $ 49.50 49.12 $ 88.55 35.88 $ 56.09 

1974 $ 48.75 64.32 $ 82.59 35.68 $ 60.82 

1975 $ 48.01 61.32 $ 76.62 38.68 $ 59.08 

1976 $ 47.26 60.91 $ 70.66 39.09 $ 56.41 

1977 $ 46.51 59.15 $ 64.69 40.85 $ 53.94 

1978 $ 45.77 58.51 $ 58.73 41.49 $ 51.15 

1979 $ 45.02 59.96 $ 52.76 40.04 $ 48.12 

1980 $ 45.02 58.06 $ 52.76 41.94 $ 48.27 

1981 $ 45.02 49.72 $ 52.76 50.28 $ 48.91 

1982 $ 45.02 45.83 $ 52.76 54.17 $ 49.21 

1983 $ 45.02 41.07 $ 52.76 58.93 $ 49.58 

1984 $ 45.02 41.56 $ 52.76 58.44 $ 49.54 

1985 $ 45.02 38.59 $ 52.76 61.41 $ 49.77 

1986 $ 45.02 37.42 $ 52.76 62.58 $ 49.86 

1987 $ 45.02 34.93 $ 52.76 65.07 $ 50.06 

1988 $ 45.02 37.78 $ 52.76 62.22 $ 49.84 

1989 $ 45.02 38.32 $ 52.76 61.68 $ 49.79 

1990 $ 45.02 32.97 $ 52.76 67.03 $ 50.21 

1991 $ 45.02 31.77 $ 52.76 68.23 $ 50.30 

1992 $ 45.02 27.78 $ 52.76 72.22 $ 50.61 

1993 $ 45.02 28.35 $ 52.76 71.65 $ 50.57 

1994 $ 55.90 27.95 $ 66.21 72.05 $ 63.31 

1995 $ 72.22 26.03 $ 86.38 73.97 $ 82.69 

1996 $ 88.53 23.50 $106.55 76.50 $102.32

1997 $153.80 21.57 $187.24 78.43 $180.03

1998 $153.80 19.61 $187.24 80.39 $180.68 

1999 $153.80 19.73 $187.24 80.27 $180.64

2000 $153.80 19.08 $187.24 80.92 $180.86

2001 $153.80 19.99 $187.24 80.01 $180.56

121
TABLE 214-8B 

SUMMARY TABLE FOR THE TOTAL WEIGHT 

OF SIDE IMPACT PROTECTION

ATTRIBUTABLE TO FMVSS 214 

PER PASSENGER CAR BY MODEL YEAR

TWO-DOOR FOUR-DOOR

MODEL

YEAR 

(c) 

UNIT WEIGHT

(a) 

UNIT WEIGHT

(b) 

% OF 

CARS 

(d) 

% OF 

CARS 

(e) 

TOTAL WEIGHT

PER VEHICLE 

1969 33.39 9.32 43.53 7.68 6.46

1970 33.39 20.28 43.53 14.72 13.18

1971 33.39 25.71 43.53 18.29 16.55

1972 33.39 27.51 43.53 21.49 18.54 

1973 33.39 49.12 43.53 35.88 32.02 

1974 32.52 64.32 40.27 35.68 35.29

1975 31.65 61.32 37.01 38.68 33.72

1976 30.78 60.91 33.76 39.09 31.94

1977 29.91 59.15 30.50 40.85 30.15

1978 29.04 58.51 27.24 41.49 28.29

1979 28.17 59.96 23.98 40.04 26.49

1980 28.17 58.06 23.98 41.94 26.41

1981 28.17 49.72 23.98 50.28 26.06

1982 28.17 45.83 23.98 54.17 25.90

1983 28.17 41.07 23.98 58.93 25.70

1984 28.17 41.56 23.98 58.44 25.72

1985 28.17 38.59 23.98 61.41 25.60

1986 28.17 37.42 23.98 62.58 25.55

1987 28.17 34.93 23.98 65.07 25.44

1988 28.17 37.78 23.98 62.22 25.56

1989 28.17 38.32 23.98 61.68 25.59

1990 28.17 32.97 23.98 67.03 25.36

1991 28.17 31.77 23.98 68.23 25.31 

1992 28.17 27.78 23.98 72.22 25.14

1993 28.17 28.35 23.98 71.65 25.17

1994 30.72 27.95 28.01 72.05 28.77

1995 34.55 26.03 34.04 73.97 34.17 

1996 38.37 23.50 40.08 76.50 39.68

1997 53.67 21.57 64.23 78.43 61.95 

1998 53.67 19.61 64.23 80.39 62.16

1999 53.67 19.73 64.23 80.27 62.15

2000 53.67 19.08 64.23 80.92 62.22

2001 53.67 19.99 64.23 80.01 62.12

Having calculated the total cost and weight of the standard for two- and four-door passenger 

cars, a breakout by static and dynamic requirements is presented in Tables 214-9A and B. It is 

important to note that the mix of two- and four-door passenger cars is changing every year. With 

the trend toward more four-door passenger cars, costs are rising very slightly. 

122
ATTRIBUTABLE TO FMVSS 214 

TABLE 214-9A 

SUMMARY TABLE FOR THE TOTAL CONSUMER COST 

OF SIDE IMPACT PROTECTION

PER PASSENGER CAR BY MODEL YEAR

STATIC DYNAMIC

MODEL

YEAR 

UNIT 

COST 

% OF 

CARS 

STATIC

COST 

UNIT 

COST 

% OF 

CARS 

DYNAMIC 

COST 

TOTAL 

COST 

1969 $67.12 17 $11.41 $11.41

1970 $65.91 35 $23.07 $23.07

1971 $65.73 44 $28.92 $28.92

1972 $66.63 49 $32.65 $32.65

1973 $65.99 85 $56.09 $56.09

1974 $60.82 100 $60.82 $60.82

1975 $59.08 100 $59.08 $59.08

1976 $56.41 100 $56.41 $56.41

1977 $53.94 100 $53.94 $53.94

1978 $51.15 100 $51.15 $51.15

1979 $48.12 100 $48.12 $48.12

1980 $48.27 100 $48.27 $48.27

1981 $48.91 100 $48.91 $48.91

1982 $49.21 100 $49.21 $49.21

1983 $49.58 100 $49.58 $49.58

1984 $49.54 100 $49.54 $49.54

1985 $49.77 100 $49.77 $49.77

1986 $49.86 100 $49.86 $49.86

1987 $50.06 100 $50.06 $50.06

1988 $49.84 100 $49.84 $49.84

1989 $49.79 100 $49.79 $49.79

1990 $50.21 100 $50.21 $50.21

1991 $50.30 100 $50.30 $50.30

1992 $50.61 100 $50.61 $50.61

1993 $50.57 100 $50.57 $50.57

1994 $50.60 100 $50.60 $127.10 10 $ 12.71 $63.31

1995 $50.75 100 $50.75 $127.76 25 $ 31.94 $82.69

1996 $50.94 100 $50.94 $128.45 40 $ 51.38 $102.32 

1997 $51.09 100 $51.09 $128.94 100 $128.94 $180.03

1998 $51.24 100 $51.24 $129.44 100 $129.44 $180.68

1999 $51.23 100 $51.23 $129.41 100 $129.41 $180.64

2000 $51.28 100 $51.28 $129.58 100 $129.58 $180.86

2001 $51.21 100 $51.21 $129.35 100 $129.35 $180.56

123
TABLE 214-9B 

SUMMARY TABLE FOR THE TOTAL WEIGHT 

OF SIDE IMPACT PROTECTION

ATTRIBUTABLE TO FMVSS 214 

PER PASSENGER CAR BY MODEL YEAR

STATIC DYNAMIC

MODEL

YEAR 

UNIT 

WEIGHT 

% OF 

CARS 

STATIC 

WEIGHT 

UNIT 

WEIGHT 

% OF 

CARS 

DYNAMIC 

WEIGHT 

TOTAL 

WEIGHT 

1969 38.00 17 6.46 6.46

1970 37.66 35 13.18 13.18 

1971 37.61 44 16.55 16.55 

1972 37.84 49 18.54 18.54 

1973 37.67 85 32.02 32.02 

1974 35.29 100 35.29 35.29 

1975 33.72 100 33.72 33.72 

1976 31.94 100 31.94 31.94 

1977 30.15 100 30.15 30.15 

1978 28.29 100 28.29 28.29 

1979 26.49 100 26.49 26.49 

1980 26.41 100 26.41 26.41 

1981 26.06 100 26.06 26.06 

1982 25.90 100 25.90 25.90 

1983 25.70 100 25.70 25.70 

1984 25.72 100 25.72 25.72 

1985 25.60 100 25.60 25.60 

1986 25.55 100 25.55 25.55 

1987 25.44 100 25.44 25.44 

1988 25.56 100 25.56 25.56 

1989 25.59 100 25.59 25.59 

1990 25.36 100 25.36 25.36 

1991 25.31 100 25.31 25.31 

1992 25.14 100 25.14 25.14 

1993 25.17 100 25.17 25.17 

1994 25.15 100 25.15 36.20 10 3.62 28.77 

1995 25.06 100 25.06 36.44 25 9.11 34.17 

1996 24.96 100 24.96 36.80 40 14.72 39.68

1997 24.88 100 24.88 37.07 100 37.07 61.95

1998 24.79 100 24.79 37.37 100 37.37 62.16 

1999 24.80 100 24.80 37.35 100 37.35 62.15

2000 24.77 100 24.77 37.45 100 37.45 62.22

2001 24.81 100 24.81 37.31 100 37.31 62.12

124
Side Air Bags. Some of the dangers of motor vehicle side-impact collisions are injuries to the 

head, neck, and upper extremities; ejection through the door; and ejection through windows. To 

help reduce occupant injuries and fatalities, side air bags were introduced in an increasing 

number of new vehicles in the late 1990’s. Side air bags are designed to deploy from either the 

doors or the outboard side of the seat to reduce the risk of injury in moderate to severe side 

impact crashes. Seat- and door-mounted air bags all provide upper thorax protection, with some

also extending upwards to provide head protection.

Unlike frontal air bags, side air bags are neither required nor regulated by NHTSA as of 

February 2004. At NHTSA’s request, a Technical Working Group representing automakers, air 

bag suppliers, and independent safety organizations has developed comprehensive uniform test 

procedures related to out-of-position occupant testing for side air bags. All vehicle 

manufacturers have agreed to utilize these tests when designing future side air bag systems. 

A study conducted in 2003 looked at the side air bag safety systems of five make-model 

passenger vehicles, including two passenger cars and three LTVs.150 Four of these systems were 

designed to provide torso protection only, while one also extends to provide head protection.151 

One passenger car and three LTVs had driver-side and passenger-side air bags, while one 

passenger car had the driver-side and passenger side air bags plus side air bag modules in the 

rear on the left and right side. Table 214-10 shows the arithmetic average weight and consumer 

cost of the principal components of side impact air bags for the 2001 passenger vehicles.152

TABLE 214-10

AVERAGE WEIGHT AND CONSUMER COST PER VEHICLE 

OF SIDE IMPACT AIR BAGS IN 2001 PASSENGER VEHICLES

COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

Sensors 0.73 $ 77.90

Air Bags 3.60 $ 68.69 

Wire Harness (Sensor)153 0.44 $ 15.07

TOTAL 4.77 $161.66

Two types of separate head air bags, known as inflatable tubular structures and inflatable 

curtains, are specifically designed to reduce the risk of head injury and/or help keep the head and 

upper body inside the vehicle. Additional studies on head air bags, some of which combine side 

and head air bags, will be conducted by NHTSA. After these studies are completed, NHTSA 

will have more comprehensive estimates of the cost of side and head air bags. 

 150 Khadilkar, A.V., Fladmark, G.L., and Khadilkar, J., Teardown Cost Estimates of Automotive Equipment

Manufactured to Comply with Motor Vehicle Standard – FMVSS 214(D) – Side Impact Protection, Side Air Bag

Features, Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, April

2003. (DOT HS 809 809) 151 2001 Used Car Reviews, Head and Side Airbag Safety Features, (accessed 5 March 2004) available from

http://www.edmunds.com; Internet. 152 The contractor’s report also included an electronic control module (ECM) pro-rated at 30% of total cost,

which has not been included with the side impact airbags. This cost, in its entirety, would be needed for the frontal 

air bags in FMVSS 208. 153 Only the wire harness for the sensors was included in the weight and consumer cost of the side impact air 

bags. The wire harness for the control module was excluded because appears to be shared with the frontal air bag. 

125
Light Truck Studies 

The number of light truck occupant fatalities increased during the 1980’s primarily due to the 

greatly increasing sales of these vehicles and their use for passenger transportation. Side impacts 

were a significant cause of these fatalities. Consequently, NHTSA extended the side door 

strength requirements of FMVSS 214 to light trucks with a GVWR of 10,000 pounds or less 

starting September 1, 1993. 

Side Door Beams. Prior to this time, some door reinforcement was already present. However, 

manufacturers responded by adding reinforcement beams to the doors along with very minor 

strengthening of the A and B pillars around the door hinge and door latch areas. A study 

conducted in 1998 looked at the side safety systems from five pre-standard (1987) make models 

and five corresponding post-standard (1994) make-model light trucks.154 The cost teardown 

analysis determined that the A and B pillar in both the pre- and post-standard light trucks had the 

same weight and cost; consequently, changes made to meet the standard were incorporated into 

the door only.

Table 214-11 shows the arithmetic average weight and consumer cost of the safety equipment 

such as side door beams and supporting structures contained in pre- and post-standard side doors. 

Other functional and cosmetic components of the doors, such as sheet metal, window systems, 

and interior decoration are not included. Our customary methodology would be to attribute only 

the difference between pre- and post-standard, 15 pounds and $14.70, to FMVSS 214. However, 

in this case, we prefer to attribute the full weight and cost of the safety equipment in the poststandard vehicles, 23.76 pounds and $29.44, to FMVSS 214. Because FMVSS 214 was already 

in effect for passenger cars (1973) long before the 1987 model year of the pre-standard trucks, it 

could be argued that manufacturers were already anticipating the extension of the standard to 

light trucks when they were installing safety equipment in the side doors of pre-standard trucks. 

TABLE 214-11

AVERAGE WEIGHT AND CONSUMER COST 

OF SIDE IMPACT PROTECTION

ATTRIBUTABLE TO FMVSS 214 IN LIGHT TRUCKS 

COMPONENT WEIGHT IN POUNDS CONSUMER COST ($2002) 

Front Side Door 23.76 $29.44

 

Starting September 1, 1998, light trucks with a GVWR of 6,000 pounds or less were subject to 

the same dynamic requirements as the passenger cars. No teardown studies have been performed 

on the changes made as a result of this requirement. These light trucks would have a much 

greater probability than passenger cars of meeting the dynamic requirement without any changes. 

FMVSS 215 – [Does not currently exist] 

154 Fladmark, G.L. and Khadilkar, A.V., Cost Estimates of Side Impact Crash Protection of 1994 vs. PreStandard 214 (Static Test – Side Impact) Light Trucks, Washington: U.S. Department of Transportation, National

Highway Traffic Safety Administration, September 1998. (DOT HS 809 804). 

126
FMVSS 216 – ROOF CRUSH RESISTANCE 

TABLE 216-1 

FMVSS 216 became effective on September 1, 1973 (passenger cars) and September 1, 1994 

(multipurpose passenger vehicles, trucks, and buses) and establishes strength requirements for 

the passenger compartment roof. The purpose of this standard is to reduce deaths and injuries 

due to the crushing of the roof into the occupant compartment in rollover crashes. This standard 

applies to passenger cars, multipurpose passenger vehicles, trucks, and buses with a GVWR of 

6,000 pounds or less. It does not apply to school buses, vehicles that conform to the rollover test 

requirements of FMVSS 208 by means that require no action by vehicle occupants, and 

convertibles (except for optional compliance with the standard as an alternative to the rollover 

test requirements of FMVSS 208).155

Most passenger cars built since September 1, 1973 have easily complied with FMVSS 216, and 

it is also believed most cars built before that date could have met the standard.156 It was 

primarily full-sized hardtops of the late 1960’s and early 1970’s that had typically borderline or 

worse performance. This body style was phased out (redesigned as a pillared hardtop or sedan) a 

few years before or after FMVSS 216 took effect. Although some true hardtops were built after 

1973 and did meet FMVSS 216, they were pretty much gone by the late 1970’s. These changes 

did not have any direct cost because it was cheaper to build a sedan than a hardtop. However, 

there is an indirect cost of lost sales. Hardtops were attractive for sales, which meant higher 

prices. Unfortunately, these intangible costs cannot be determined by cost teardown analysis.

Whereas the phasing out of true hardtops was the most visible design change, it is also possible 

that pillars or roof structure were strengthened, without major redesign, in selected vehicles. A 

study was conducted in 1982 to determine the implementation consumer price and weight 

variance of FMVSS 216 in 1974 model year vehicles from a baseline of the 1973 model year 

vehicles.157 Twenty-four passenger cars from 1974, along with comparable 1973 make-models, 

were reviewed. The changes were analyzed upward from the belt line and included a review of 

the A, B, and C pillars and the roof structure. From this study, we singled out twenty-one makemodels that did not receive any overall redesign in 1974. For these make-models, it is plausible 

that any change from 1973 to 1974 is specifically due to FMVSS 216. Table 216-1 shows the 

estimated increase in weight and consumer cost of roof crush attributable to FMVSS 216 in 

passenger cars.

AVERAGE WEIGHT AND CONSUMER COST 

OF ROOF CRUSH ATTRIBUTABLE TO FMVSS 216

IN PASSENGER CARS 

MODEL YEAR WEIGHT IN POUNDS CONSUMER COST ($2002) 

1974-2001 2.93 $3.47

NHTSA believes that light trucks met FMVSS 216 well before the September 1, 1993 

requirement, with no substantial changes in roof design around that time. Consequently, no cost 

studies of roof crush in light trucks have been performed, and none are planned by the agency. 

 155 Legal citation: 49 CFR 571.216 (2004). 156 Kahane, DOT HS 807 489:50-51 (1989). 157 Gladstone, DOT HS 806 769:8-1 thru 8-22 (1982).

127
 

FMVSS 217 became effective on September 1, 1973 and establishes minimum requirements for 

bus window retention and release to reduce the likelihood of passenger ejection in crashes and 

for emergency exits to facilitate passenger exit in emergencies.158 Since this standard does not 

regulate components of new passenger cars or light trucks, it is outside the scope of this report. 

No cost studies of this standard have been done, and none are planned by the agency. 

FMVSS 218- MOTORCYLE HELMETS 

FMVSS 218 became effective on March 1, 1974 and establishes minimum performance 

requirements for helmets designed for use by motorcyclists and other motor vehicle users to 

reduce deaths and injuries resulting from head impacts.159 Since this standard does not regulate 

components of new passenger cars or light trucks, it is outside the scope of this report. No cost 

studies of this standard have been done, and none are planned by the agency. 

FMVSS 219 – WINDSHIELD ZONE INTRUSION 

FMVSS 219 became effective on September 1, 1976 (passenger cars) and September 1, 1977 

(multipurpose passenger vehicles, trucks, and buses) and specifies limits for the displacement 

into the windshield area of motor vehicle components during a crash. The purpose of this 

standard is to reduce crash injuries and fatalities that result from occupants contacting vehicle 

components displaced near or through the windshield. This standard applies to passenger cars 

and to multipurpose passenger vehicles, trucks, and buses with a GVWR of 10,000 pounds or 

less. However, it does not apply to forward control vehicles, walk-in van-type vehicles or to 

body-type vehicles with fold-down or removable windshields.160 

A study was conducted in 1982 on twelve make-model pre-standard (1976) passenger cars, and 

their corresponding implementation (1977) and post-standard (1978) systems.161 From that 

study, we singled out ten make-models that did not receive an overall redesign in 1977. Those 

ten make-models had no changes in weight and cost from 1976 to 1978. Because our teardowns 

did not show any added weight or cost in the standards implementation year, we will not 

attribute any weight or cost to FMVSS 219. However, it is conceivable that a more thorough 

teardown study including vehicles a year or two before 1976 could have revealed costs of 

changes made in anticipation of FMVSS 219, if there were any.

158 Legal citation: 49 CFR 571.217 (2004). 159 Legal citation: 49 CFR 571.218 (2004). 160 Legal citation: 49 CFR 571.219 (2004). 161 McVetty, DOT HS 806 187:19-36 (1982). 

128

FMVSS 217 – BUS EMERGENCY EXITS AND WINDOW RETENTION AND RELEASE 
FMVSS 220 – SCHOOL BUS ROLLOVER PROTECTION

FMVSS 221 – SCHOOL BUS BODY JOINT STRENGTH

 

FMVSS 220 became effective on April 1, 1977 and establishes performance requirements for 

school bus rollover protection to reduce the number of deaths and the severity of injuries that 

result from failure of the school bus body structure to withstand forces encountered in rollover 

crashes.162 A cost study was completed in 1979.163 Since this standard does not regulate 

components of new passenger cars or light trucks, it is outside the scope of this report.

FMVSS 221 became effective on April 1, 1977 and establishes requirements for the strength of 

the body panel joints in school bus bodies to reduce deaths and injuries resulting from the 

structural collapse of school bus bodies during crashes.164 A cost study was completed in 

1979.165 Since this standard does not regulate components of new passenger cars or light trucks, 

it is outside the scope of this report.

FMVSS 222 – SCHOOL BUS PASSENGER SEATING AND CRASH PROTECTION 

FMVSS 222 became effective on April 1, 1977 and establishes occupant protection requirements 

for school bus passenger seating and restraining barriers to reduce the number of deaths and the 

severity of injuries that result from the impact of school bus occupants against structures within 

the vehicle during crashes and sudden driving maneuvers.166 A cost study was completed in 

1979.167 Since this standard does not regulate components of new passenger cars or light trucks, 

it is outside the scope of this report.

FMVSS 223 – REAR IMPACT GUARDS 

FMVSS 223 became effective on January 26, 1998 and specifies requirements for rear impact 

guards for trailers and semi-trailers to reduce the number of deaths and serious injuries that occur 

when light duty vehicles collide with the rear end of trailers and semi-trailers.168 Since this 

standard does not regulate components of new passenger cars or light trucks, it is outside the 

scope of this report.

162 Legal citation: 49 CFR 571.220 (2004). 163 Harvey, DOT HS 805 320:12-13 (1979). 164 Legal citation: 49 CFR 571.221 (2004). 165 Harvey, DOT HS 805 320:13-19 (1979). 166 Legal citation: 49 CFR 571.222 (2004). 167 Harvey, DOT HS 805 320:19-23 (1979). 168 Legal citation: 49 CFR 571.223 (2004). 

129
FMVSS 224 – REAR IMPACT PROTECTION 

 

FMVSS 224 became effective on January 26, 1998 and establishes requirements for the 

installation of rear impact guards on trailers and semi-trailers with a GVWR of 10,000 pounds or 

more to reduce the number of deaths and serious injuries occurring when light duty vehicles 

impact the rear of trailers and semi-trailers of 10,000 pounds or more.169 Since this standard 

does not regulate components of new passenger cars or light trucks, it is outside the scope of this 

report.

FMVSS 225 – CHILD RESTRAINT ANCHORAGE SYSTEMS 

FMVSS 225 became effective on September 1, 1999 and establishes requirements for child 

restraint anchorage systems to ensure their proper location and strength for the effective securing 

of child restraints, to reduce the likelihood of the anchorage systems’ failure, and to increase the 

likelihood that child restraints are properly secured and thus more fully achieve their potential 

effectiveness in motor vehicles. This standard applies to passenger cars; to trucks and 

multipurpose passenger vehicles with a GVWR of 8,500 pounds or less, except walk-in van-type 

vehicles and vehicles manufactured to be sold exclusively to the U.S. Postal Service; and to 

buses (including school buses) with a GVWR of 10,000 pounds or less, except shuttle buses.170 

A cost study of this standard is included in NHTSA’s 2004-2007 Evaluation Plan.171

169 Legal citation: 49 CFR 571.224 (2004). 170 Legal citation: 49 CFR 571.225 (2004). 171 National Highway Traffic Safety Administration, DOT HS 809 699:9-10 (2004). 

130
SECTION 4 – FMVSS 300, 400, AND 500 SERIES 

The FMVSS 300, 400, and 500 series specify requirements for vehicles and components to 

prevent or reduce the severity of fires, protect occupants from hazards during vehicle operation, 

and provide safety for low-speed vehicles. 

• passenger cars 

• 

• school buses that have a GVWR greater than 10,000 pounds and use fuel with a boiling 

point above 0 oC172

• Effective September 1, 1975

FMVSS 301 – FUEL SYSTEM INTEGRITY

FMVSS 301 became effective on January 1, 1968 (passenger cars), in January 1976 

(multipurpose passenger vehicles, trucks, and buses with a GVWR of 10,000 pounds or less), 

and on April 1, 1977 (school buses with a GVWR greater than 10,000 pounds). The standard 

specifies requirements for the integrity of motor vehicle fuel systems. The purpose of this 

standard is to reduce deaths and injuries occurring from fires that result from fuel spillage during 

and after motor vehicle crashes and from ingestion of fuels during siphoning. This standard 

applies to: 

multipurpose passenger vehicles, trucks, and buses that have a GVWR of 10,000 pounds 

or less and use fuel with a boiling point above 0 o

C

Originally, cars only had to pass a front impact test into a rigid barrier at 30 mph. Fuel spillage 

after the impact was not allowed to exceed one ounce while the car was still in motion and five 

ounces during the first five minutes after the car came to a stop. During the next 25 minutes, fuel

spillage could not exceed one ounce during any one-minute interval.173

During the 1970’s, FMVSS 301 was significantly upgraded over a three-year phase-in period. 

. Passenger cars had to meet a static rollover test. 

Immediately after the frontal test, the damaged vehicle was slowly rotated 90 degrees, 

180 degrees (up-side down), and 270 degrees, holding at each of these positions for five 

minutes. Fuel spillage could not exceed one ounce during any one-minute interval in this 

process. 

• Effective September 1, 1976. Passenger cars had to meet 30 mph frontal, oblique frontal 

and rear-impact tests, plus a 20 mph lateral test, with each test followed by a static 

rollover test. The cars had the same limits on fuel spillage as in the original frontal test. 

LTVs with GVWR less than or equal to 6,000 pounds had to meet 30 mph frontal and 

rear-impact tests followed by the static rollover. LTVs with GVWR of 6,000-10,000 

 172 Legal citation: 49 CFR 571.301 (2004). 173 Parsons, G.G., Motor Vehicle Fires in Traffic Crashes and the Effects of the Fuel System Integrity Standard,

Washington: U.S. Department of Transportation, National Highway Traffic Safety Administration, 1990 (DOT HS

807 675:xvii; 3-25 thru 3-28). 

131
(including small LTV-based school buses) had to meet the frontal test without static 

rollover. 

• Effective September 1, 1977. All LTVs up to 10,000 pounds (including small school 

buses) had to meet the same requirements as passenger cars: frontal, oblique frontal, 

rear-impact and lateral tests with subsequent rollover. 

• relocating parts of the fuel system further away from other parts of the vehicle or areas 

likely to be damaged during impacts 

• relocating other parts of the vehicle further away from the fuel system, or reshaping them

to make them less likely to damage the fuel system

The type and extent of modifications near the time of the 1975-77 upgrade varied greatly by 

make-model. Strategies used by the manufacturers included.174

• strengthening the fuel tank or other components of the fuel delivery system 

• strengthening the structures that hold the fuel tank in place 

• shielding the fuel tank and delivery system from other parts of the vehicle 

In November 2003, NHTSA issued a final rule upgrading the rear impact test that simulates 

being struck in the rear by another vehicle. The final rule replaces the full rear impact test 

procedure with an offset rear impact test procedure specifying that only a portion of the width of 

the rear of the test vehicle be impacted at 50 mph. Under the new rear impact procedure, a 

lighter deformable barrier is used. The barrier is very similar to the one used for dynamic testing 

of the side impact protection standard, except that the rear impact barrier’s face is mounted 

slightly lower to simulate the diving of the front end of a vehicle during pre-crash braking. The 

new requirements will phase in between September 1, 2006 and September 1, 2008.

Passenger Car Studies 

Fuel system elements of twelve post-standard (1976) passenger cars and their corresponding prestandard (1967) make-models were examined to determine the weight and consumer cost of 

equipment changes in response to FMVSS 301.175 Table 301-1 shows the sales-weighted 

average weight and consumer cost of implementing the 1976 requirement, with the difference 

attributable to FMVSS 301 in passenger cars.

TABLE 301-1 

AVERAGE WEIGHT AND CONSUMER COST 

OF THE FUEL TANK AND FUEL TANK FILLER TUBE

ATTRIBUTABLE TO FMVSS 301 IN PASSENGER CARS 

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Pre-Standard 24.14 $45.91

Post-Standard 26.62 $62.42

DIFFERENCE 2.48 $16.51

 174 Ibid, 4-11 thru 4-22. 175 McLean, DOT HS 803 871:63-87 (1978). 

132
Light Truck Studies

FMVSS 301 was extended to light trucks in January 1976. To determine the weight and 

consumer cost of the equipment changes in response to FMVSS 301 requirements of September 

1, 1976 and September 1, 1977, fuel system elements of two pre-standard (1976) light trucks and 

their corresponding post-standard (1977) make-models were examined.176

Examination of the 1976 and 1977 model year light trucks did not make a clearly defined 

conclusion on the implementation of the standard. One selected vehicle indicated an increase in 

weight of 11.73 pounds and cost of $9.43 in 2002 dollars, while the other vehicle exhibited no 

cost or weight increase from 1976 to 1977. Because of the small sample size and the possibility 

that the vehicle with no change could have made the equipment changes a year earlier, we prefer 

to attribute the full weight and cost imposed for passenger cars to light trucks. 

Table 301-2 shows the sales-weighted average weight and consumer cost of implementing the 

1976 requirement, with the difference attributable to FMVSS 301 in light trucks. 

TABLE 301-2 

AVERAGE WEIGHT AND CONSUMER COST 

OF THE FUEL TANK AND FUEL TANK FILLER TUBE

ATTRIBUTABLE TO FMVSS 301 IN LIGHT TRUCKS

CATEGORY WEIGHT IN POUNDS CONSUMER COST ($2002) 

Pre-Standard 24.14 $45.91

Post-Standard 26.62 $62.42

Difference 2.48 $16.51

FMVSS 302 – FLAMMABILITY OF INTERIOR MATERIALS 

 

FMVSS 302 became effective on September 1, 1972 and specifies burn resistance requirements 

for materials used in the occupant compartments of motor vehicles. The purpose of the standard 

is to reduce the deaths and injuries to motor vehicle occupants caused by vehicle fires, especially 

those originating in the interior of the vehicle from sources such as matches or cigarettes. This 

standard applies to passenger cars, multipurpose passenger vehicles, trucks, and buses.

177 No 

cost studies of this standard have been done, and none are planned by the agency.

FMVSS 303 – FUEL SYSTEM INTEGRITY OF COMPRESSED NATURAL GAS 

VEHICLES

FMVSS 303 became effective on April 25, 1994 and specifies requirements for the integrity of 

motor vehicle fuel systems using compressed natural gas (CNG), including the CNG fuel 

systems of bi-fuel, dedicated, and dual fuel CNG vehicles. The purpose of the standard is to 

reduce deaths and injuries occurring from fires that result from fuel leakage during and after 

motor vehicle crashes. This standard applies to passenger cars, multipurpose passenger vehicles, 

trucks, and buses that have a GVWR of 10,000 pounds or less and school buses regardless of 

176 McLean, DOT HS 803 871:63-87 (1978). 177 Legal citation: 49 CFR 571.302 (2004). 

133
weight that use CNG as a motor fuel.178 No cost studies of this standard have been done, and 

none are currently planned by the agency.

FMVSS 304 – COMPRESSED NATURAL GAS FUEL CONTAINER INTEGRITY

 

FMVSS 304 became effective March 27, 1995 and specifies requirements for the integrity of 

CNG, motor vehicle fuel containers. The purpose of this standard is to reduce deaths and 

injuries occurring from fires that result from fuel leakage during and after motor vehicle crashes. 

This standard applies to each passenger car, multipurpose passenger vehicle, truck, and bus that 

uses CNG as a motor fuel and to each container designed to store CNG as motor fuel on-board 

any motor vehicle.179 No cost studies of this standard have been done, and none are currently 

planned by the agency.

FMVSS 305 – ELECTRIC-POWERED VEHICLES: ELECTROLYTE SPILLAGE AND 

ELECTRICAL SHOCK PROTECTION 

FMVSS 305 became effective on September 27, 2000 and specifies requirements for limitation 

of electrolyte spillage, retention of propulsion batteries during a crash, and electrical isolation of 

the chassis from the high-voltage system to be met by vehicles that use electricity as propulsion. 

The purpose of this standard is to reduce deaths and injuries during a crash that occur because of 

electrolyte spillage from propulsion batteries, intrusion of propulsion battery system components 

into the occupant compartment, and electrical shock. This standard applies to passenger cars and 

to multipurpose passenger vehicles, trucks, and buses with a GVWR of 10,000 pounds or less, 

that use more than 48 nominal volts of electricity as propulsion power and whose speed 

attainable in 1.6 km on a paved level surface is more than 40 km/h.180 No cost studies of this 

standard have been done, and none are currently planned by the agency.

FMVSS 401 – INTERIOR TRUNK RELEASE 

FMVSS 401 became effective on August 17, 2001 and establishes the requirements for providing 

a trunk release mechanism that makes it possible for a person trapped inside the trunk 

compartment of a passenger car to escape from the compartment. This standard applies to 

passenger cars that have a trunk compartment. This does not apply to passenger cars with a back 

door.181 No cost studies of this standard have been done, and none are currently planned by the 

agency.

FMVSS 402 - (Does not currently exist) 

178 Legal citation: 49 CFR 571.303 (2004). 179 Legal citation: 49 CFR 571.304 (2004). 180 Legal citation: 49 CFR 571.305 (2004). 181 Legal citation: 49 CFR 571.401 (2004). 

134
FMVSS 403 – PLATFORM LIFT SYSTEMS FOR MOTOR VEHICLES 

 

FMVSS 403 becomes effective on December 27, 2004 and specifies requirements for platform

lifts used to assist persons with limited mobility in entering or leaving a motor vehicle. The 

purpose of this standard is to prevent injuries and fatalities to passengers and bystanders during 

the operation of platform lifts installed in motor vehicles. This standard applies to platform lifts 

designed to carry passengers into and out of motor vehicles.182 No cost studies of this standard 

have been done, and none are currently planned by the agency.

FMVSS 404 – PLATFORM LIFT INSTALLATIONS IN MOTOR VEHICLES 

FMVSS 404 becomes effective on December 27, 2004 and specifies requirements for vehicles 

equipped with platform lifts used to assist persons with limited ability in entering or leaving a 

motor vehicle. The purpose of this standard is to prevent injuries and fatalities to passengers and 

bystanders during the operation of platform lifts installed in motor vehicles. This standard 

applies to motor vehicles equipped with a platform lift to carry passengers into and out of the 

motor vehicle.183 No cost studies of this standard have been done, and none are currently 

planned by the agency.

FMVSS 500 – LOW-SPEED VEHICLES 

FMVSS 500 became effective on June 17, 1998 and specifies requirements for low-speed 

vehicles to ensure that low-speed vehicles operated on the public streets, roads, and highways are 

equipped with minimum motor vehicle equipment appropriate for motor vehicle safety.184 A 

low-speed vehicle is a four-wheeled motor vehicle, other than a truck, whose top speed is greater 

than 20 mph, but not greater than 25 mph. A possible cost study of this standard is included in 

NHTSA’s 2004-2007 Evaluation Plan.185

182 Legal citation: 49 CFR 571.403 (2004). 183 Legal citation: 49 CFR 571.404 (2004). 184 Legal citation: 49 CFR 571.500 (2004). 185 National Highway Traffic Safety Administration, DOT HS 809 699:31-32 (2004).

135
136
SECTION 5 – FINAL SUMMARY AND TABLES 

The cost and weight added by all the FMVSS, and by each individual FMVSS to passenger cars 

and light trucks from 1968 to 2001 have grown over the years with the addition of new standards 

and amendments to existing standards, the introduction of new technologies, and the percentage 

of passenger cars and light trucks meeting the standard in a particular model year – offset by 

subsequent reductions in the costs of some technologies. 

 

NHTSA estimates that the FMVSS added an average of $839 (in 2002 dollars) and 125 pounds 

to the average passenger car in model year 2001. Since passenger cars cost an average of 

$21,217 (in 2002 dollars) and weighed 3,148 pounds in model year 2001, approximately four 

percent of the cost and four percent of the weight of a new passenger car could be attributed to 

the FMVSS. An average of $711 (in 2002 dollars) and 86 pounds was added to the average light 

truck in model year 2001. With light trucks costing an average of $23,995 (in 2002 dollars) and 

weighing 4,238 pounds in model year 2001, approximately three percent of the cost and two 

percent of the weight of a new truck could be attributed to the FMVSS. The average cost of the 

2001 passenger cars and light trucks are based on the Manufacturer’s Suggested Retail Price 

(MSRP).186

The final summary tables provide a breakout of the cost and weight attributable to each FMVSS 

for passenger cars and light trucks in each model year. All cost data have been inflated to 2002 

dollars using the gross domestic product implicit price deflator adjustments from the Bureau of 

Economic Analysis. 

Tables 5A through 5D summarize the consumer cost and weight of each FMVSS for passenger 

cars and light trucks for model years 1968-2001 and subdivide costs and weights into 

“voluntary” and “mandatory” categories. The voluntary (shaded) category accounts for the cost 

and weight of all equipment added or modified before the effective date in clear anticipation of 

the standard; whereas, the mandatory category accounts for additions or modifications that took 

place on or after the effective date. An explanation of the tables follows: 

• The unit cost and weight of each FMVSS was obtained from their respective tables 

within the report. 

• The percent of passenger cars and light trucks that met the standard in a particular model 

year was obtained from Polk registration files. 

• The total cost and weight of each FMVSS was calculated by multiplying the unit cost by 

the percent of passenger cars and light trucks that met the standard. 

186 The MSRP cost for the 2001 passenger car and light truck does not include price reductions such as rebates or

incentives offered by the dealer and/or the manufacturer, nor does it include price additions such as added charges 

and optional features. 

 Abeles, E.C., Analysis of Light-Duty Vehicle Price Trends in the U.S., How Vehicle Prices Change Relative to 

Consumers, Compliance Costs and a Baseline Measure for 1975-2001, University of California at Davis, June 2004

(UCD-ITS-RR-04-15:10,12). 

137
• The total voluntary cost and weight of all FMVSS was calculated by adding the voluntary 

cost and weight of each FMVSS. 

• The total mandatory cost and weight of all FMVSS was calculated by adding the 

mandatory cost and weight of each FMVSS. 

• The total FMVSS cost and weight was calculated by adding the total voluntary cost and 

weight and the total mandatory cost and weight. 

• The tables include only the FMVSS that are believed to have added cost or weight to 

passenger cars or light trucks and that have been studied as of September 2004. 

More detailed descriptions of the technologies and cost estimation procedures associated with 

each FMVSS may be found in the preceding chapters. However, here are some brief notes on 

the salient features of Tables 5A through 5D: 

Passenger Cars:

• FMVSS 105: the upgrade from single to dual master cylinders was the principal costand weight-increasing safety technology. Follow-up studies showed that the cost and 

weight of dual master cylinders decreased somewhat between 1976 and 1982. 

• FMVSS 108: side marker lamps were installed in all passenger cars, and center high 

mounted stop lamps (CHMSL) in some passenger cars a few years before the effective 

date, but after a rulemaking process was underway. These are shown as “voluntary” 

costs (shaded). Side marker lamps cost and weighed less in 1968-1969 because some

cars had fixtures of simpler design that, subsequently, would not have met the standard. 

• FMVSS 118 involved electrical changes to prevent the operation of power windows 

when the ignition or electrical accessory systems are off. Unit costs per passenger car 

have not changed, but total cost rose as the proportion of new passenger cars equipped 

with power windows has increased. 

• FMVSS 124 resulted in an extra spring to assure the throttle returns to idle when the 

driver’s foot is not on the accelerator. 

• FMVSS 201 includes secure glove compartment doors and seat back padding to protect 

occupants in interior impact, as specified in the original standard. No costs are shown 

for the head impact protection upgrade, phased in during model years 1999-2003, 

because NHTSA has not completed the cost evaluation. 

• FMVSS 202 resulted in head restraints being added to passenger cars. The cost and 

weight of head restraints decreased between 1969 and 1982. 

138
• FMVSS 203 and 204 resulted in energy absorbing, telescoping steering assemblies to 

protect drivers in frontal crashes. 

• FMVSS 207: seat back locks for the front seat added cost and weight in two-door 

passenger cars. The industry shifted from manual to inertial locks circa 1980. The total 

cost has declined as the market share of two-door passenger cars decreased from 64 

percent in 1974 to 20 percent in 2001. 

• FMVSS 208: safety belts are required at all designated seating positions, including rear 

seats, and the tables show the sum of the costs and weights of all the safety belts in the 

passenger car. The cost of manual belts increased from 1968 to 1974 due to 

improvements such as integral 3-point belts and locking retractors. Automatic protection 

was phased into passenger cars in model years 1987-1990. Cost and weight of safety 

belts increased substantially in 1987-1990 as automatic belts were phased in, and 

returned to earlier levels in 1991-1996 as manual 3-point belts returned. Driver air bags, 

and subsequently dual air bags, were increasingly used to meet the automatic protection 

requirement. In model years 1997-2001, all passenger cars had dual air bags and manual 

3-point belts. The table does not include the cost of pretensioners, load limiters or 

adjustable anchors since they are not required, or proposed, as a requirement of FMVSS 

208. 

• FMVSS 214: the initial static crush requirement for side doors went into effect for 

passenger cars on January 1, 1973, although NHTSA had announced it was planning 

such a requirement as early as October 1968. Side door beams provided the crush 

strength needed to meet the standard. The cost of side door beams in some 1969-1972 

cars is included because the rulemaking process was underway by then. Cost and weight 

decreased substantially from 1973 to 1979, partly because passenger cars were 

downsized. In the FMVSS 214 section of Chapter 3, all costs and weights are computed 

separately for two-door and four-door passenger cars; however, Tables 5A and 5B show 

sales-weighted averages for all passenger cars. As a result, these averages change 

slightly from year to year, usually upward, as the market has shifted to more four-door 

passenger cars. The phase-in of the dynamic crash test requirement in model years 

1994-1997 substantially increased the cost and weight added by FMVSS 214. 

• FMVSS 216: roofs and supporting pillars were strengthened in some passenger cars 

circa 1974. 

• FMVSS 301: the original fuel integrity standard, effective January 1, 1968, apparently 

did not add cost or weight to passenger cars. However, a significant upgrade in 1975-

1976 resulted in strengthening, shielding or relocating the fuel tank, fuel delivery system, 

and supporting structures. 

139
Light Trucks:

• FMVSS 104: light trucks were equipped with multi-speed windshield wipers and 

windshield washing systems. 

• FMVSS 105 was extended to light trucks effective September 1, 1983. However, it had 

been in effect for passenger cars since 1968 and its extension to light trucks proposed by 

1972. Therefore, installations of dual master cylinders in model years 1968-1983 have 

been included as “voluntary” costs. 

• FMVSS 108: side marker lamps were installed in all light trucks, and center high 

mounted stop lamps (CHMSL) in some of them a few years before the effective date, but 

after a rulemaking process was underway. These are shown as “voluntary” costs. 

• FMVSS 118 was extended to light trucks effective July 25, 1988, but was already in 

effect for passenger cars by the time power windows began to appear on trucks. Thus, a 

voluntary cost is tabulated for model years 1978-1988. 

• FMVSS 124 is assumed to have the same cost in light trucks as in passenger cars. 

• FMVSS 201 went into effect on September 1, 1981. Seat backs were padded if there 

was another row of seats behind them. Unit costs stayed the same, but the total cost has

increased as the light truck fleet shifted from conventional-cab pickup trucks to SUVs, 

minivans and crew-cab pickup trucks. 

• FMVSS 202: head restraints were not required in light trucks until September 1, 1991. 

However, many trucks were equipped with head restraints or high-back seats during the 

years that FMVSS 202 was in effect, or in process, for passenger cars. These are shown 

as voluntary costs. 

• FMVSS 203 and 204 went into effect on September 1, 1981. Energy absorbing, 

telescoping steering assemblies began to appear in light trucks on a voluntary basis in 

1970, a few years after they became a requirement in passenger cars. 

• FMVSS 208: safety belts were required at all designated seating positions, including rear 

seats, effective July 1, 1971 but were already there on a voluntary basis in model years 

1968-1971, when FMVSS 208 was in effect for passenger cars. The cost of safety belts 

increased from 1971 to 1982 as all light trucks received integral 3-point belts and 

locking retractors. Cost and weight continued to increase after 1987, as the truck market 

shifted to vehicles with more seats, and as 3-point belts superseded lap belts at rear 

outboard seats. The automatic protection requirement was phased into light trucks up to 

8,500 GVWR in model years 1995-1998, but the shift to driver air bags, and 

subsequently dual air bags began several years earlier, shortly after air bags were 

introduced in cars. Effective June 22, 1995, light trucks that could not accommodate 

rear-facing child seats 

140
anywhere except the front seat were allowed to have an on-off switch for the passenger 

air bag. That facilitated the implementation of dual air bags in pickup trucks. 

• FMVSS 214: the static crush requirement for side doors was extended to light trucks on 

September 1, 1993, with some voluntary installations in preceding years. Side door 

beams provided the crush strength needed to meet the standard. The dynamic crash test 

requirement went into effect on September 1, 1998, but apparently has not added any 

significant cost or weight. 

• FMVSS 216 was extended to light trucks effective September 1, 1994, but apparently 

has not added any significant cost or weight. 

• FMVSS 301: the original fuel integrity standard, effective January 1, 1968, apparently 

did not add cost or weight to light trucks. However, a significant upgrade in model year 

1978 resulted in strengthening, shielding or relocating the fuel tank, fuel delivery system, 

and supporting structures. 

141
142

TABLE 5A

AVERAGE CONSUMER COST PER PASSENGER CAR FOR

 IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 105 - BRAKES FMVSS 108 - LAMPS FMVSS 118 F

DUAL MASTER CYL. SIDE MARKER CHMSL POWER WINDOWS ACCELER

Model Unit % 105 Unit % Unit % 108 Unit % 118 Unit 

Year Cost of Cars Cost Cost of Cars Cost Cost of Cars Cost Cost Cost of Cars Cost Cost 

1968 12.14 100% 12.14 20.90 100% 20.90 20.901969 12.14 100% 12.14 20.90 100% 20.90 20.901970 12.14 100% 12.14 29.37 100% 29.37 29.371971 12.14 100% 12.14 29.37 100% 29.37 29.37 0.92 20.6% 0.191972 12.14 100% 12.14 29.37 100% 29.37 29.37 0.92 26.6% 0.241973 12.14 100% 12.14 29.37 100% 29.37 29.37 0.92 25.7% 0.241974 12.14 100% 12.14 29.37 100% 29.37 29.37 0.92 18.9% 0.17 0.47 1975 12.14 100% 12.14 29.37 100% 29.37 29.37 0.92 24.5% 0.23 0.47 1976 12.14 100% 12.14 29.37 100% 29.37 29.37 0.92 23.1% 0.21 0.47 1977 11.93 100% 11.93 29.37 100% 29.37 29.37 0.92 27.0% 0.25 0.47 1978 11.72 100% 11.72 29.37 100% 29.37 29.37 0.92 23.8% 0.22 0.47 1979 11.51 100% 11.51 29.37 100% 29.37 29.37 0.92 25.0% 0.23 0.47 1980 11.30 100% 11.30 29.37 100% 29.37 29.37 0.92 20.3% 0.19 0.47 1981 11.09 100% 11.09 29.37 100% 29.37 29.37 0.92 23.4% 0.22 0.47 1982 10.88 100% 10.88 29.37 100% 29.37 29.37 0.92 28.4% 0.26 0.47 1983 10.88 100% 10.88 29.37 100% 29.37 29.37 0.92 39.0% 0.36 0.47 1984 10.88 100% 10.88 29.37 100% 29.37 29.37 0.92 40.3% 0.37 0.47 1985 10.88 100% 10.88 29.37 100% 29.37 9.74 4.8% 0.47 29.84 0.92 44.4% 0.41 0.47 1986 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 43.0% 0.40 0.47 1987 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 42.5% 0.39 0.47 1988 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 46.9% 0.43 0.47 1989 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 49.4% 0.45 0.47 1990 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 57.6% 0.53 0.47 1991 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 54.9% 0.51 0.47 1992 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 61.8% 0.57 0.47 1993 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 67.7% 0.62 0.47 1994 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 73.2% 0.67 0.47 1995 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 73.7% 0.68 0.47 1996 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 79.6% 0.73 0.47 1997 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 79.6% 0.73 0.47 1998 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 83.0% 0.76 0.47 1999 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 83.0% 0.76 0.47 2000 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 85.0% 0.78 0.47 2001 10.88 100% 10.88 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 85.0% 0.78 0.47 

NO COSTVOLUNTARY COSTMANDATORY COST
143

TABLE 5A

AVERAGE CONSUMER COST PER PASSENGER CAR FOR

 IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 201- INTERIOR PROTECTION FMVSS 202 FMVSS 203/204 F

GLOVE COMP. DOORS SEAT BACK PADDING HEAD RESTRAINTS STEERING ASSEMBLY SEAT 

Model Unit % Unit % 201 Unit % 202 Unit % 203-4 Unit 

Year Cost of Cars Cost Cost of Cars Cost Cost Cost of Cars Cost Cost of Cars Cost Cost 

1968 0.12 100% 0.12 4.32 100% 4.32 4.44 38.27 12% 4.59 27.45 100% 27.45 16.53 1969 0.12 100% 0.12 4.32 100% 4.32 4.44 38.27 100% 38.27 27.45 100% 27.45 16.53 1970 0.12 100% 0.12 4.32 100% 4.32 4.44 37.59 100% 37.59 27.45 100% 27.45 16.53 1971 0.12 100% 0.12 4.32 100% 4.32 4.44 36.92 100% 36.92 27.45 100% 27.45 16.53 1972 0.12 100% 0.12 4.32 100% 4.32 4.44 36.25 100% 36.25 27.45 100% 27.45 16.53 1973 0.12 100% 0.12 4.32 100% 4.32 4.44 35.58 100% 35.58 27.45 100% 27.45 16.53 1974 0.12 100% 0.12 4.32 100% 4.32 4.44 34.91 100% 34.91 27.45 100% 27.45 16.53 1975 0.12 100% 0.12 4.32 100% 4.32 4.44 34.24 100% 34.24 27.45 100% 27.45 16.53 1976 0.12 100% 0.12 4.32 100% 4.32 4.44 33.56 100% 33.56 27.45 100% 27.45 16.53 1977 0.12 100% 0.12 4.32 100% 4.32 4.44 32.89 100% 32.89 27.45 100% 27.45 16.53 1978 0.12 100% 0.12 4.32 100% 4.32 4.44 32.22 100% 32.22 27.45 100% 27.45 16.53 1979 0.12 100% 0.12 4.32 100% 4.32 4.44 31.55 100% 31.55 27.45 100% 27.45 16.53 1980 0.12 100% 0.12 4.32 100% 4.32 4.44 30.88 100% 30.88 27.45 100% 27.45 16.13 1981 0.12 100% 0.12 4.32 100% 4.32 4.44 30.21 100% 30.21 27.45 100% 27.45 16.13 1982 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1983 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1984 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1985 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1986 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1987 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1988 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1989 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1990 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1991 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1992 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1993 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1994 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1995 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1996 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1997 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1998 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 1999 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 2000 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 2001 0.12 100% 0.12 4.32 100% 4.32 4.44 30.89 100% 30.89 27.45 100% 27.45 16.13 

NO COSTVOLUNTARY COSTMANDATORY COST
144

TABLE 5A

AVERAGE CONSUMER COST PER PASSENGER CAR FOR

 IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 208/209/210 FMVSS 214 - SIDE IMPA

SAFETY BELTS DRIVER AIR BAGS DUAL AIR BAGS STATIC TEST DYNAMIC 

Model Unit % Unit % Unit % 208 Unit % Unit % 

Year Cost of Cars Cost Cost of Cars Cost Cost of Cars Cost Cost Cost of Cars Cost Cost of Ca

1968 90.76 100% 90.76 90.761969 92.38 100% 92.38 92.38 67.12 17% 11.41 1970 92.38 100% 92.38 92.38 65.91 35% 23.07 1971 92.38 100% 92.38 92.38 65.73 44% 28.92 1972 116.41 100% 116.41 116.41 66.63 49% 32.65 1973 116.37 100% 116.37 116.37 65.99 85% 56.09 1974 118.09 100% 118.09 118.09 60.82 100% 60.82 1975 118.52 100% 118.52 118.52 59.08 100% 59.08 1976 118.48 100% 118.48 118.48 56.41 100% 56.41 1977 116.16 100% 116.16 116.16 53.94 100% 53.94 1978 116.16 100% 116.16 116.16 51.15 100% 51.15 1979 116.55 100% 116.55 116.55 48.12 100% 48.12 1980 116.55 100% 116.55 116.55 48.27 100% 48.27 1981 117.71 100% 117.71 117.71 48.91 100% 48.91 1982 116.91 100% 116.91 116.91 49.21 100% 49.21 1983 117.57 100% 117.57 117.57 49.58 100% 49.58 1984 117.57 100% 117.57 117.57 49.54 100% 49.54 1985 117.57 100% 117.57 284.09 0.1% 0.37 117.94 49.77 100% 49.77 1986 117.60 100% 117.60 284.09 0.8% 2.13 119.73 49.86 100% 49.86 1987 145.49 100% 145.49 284.09 1.2% 3.32 396.72 0.1% 0.20 149.01 50.06 100% 50.06 1988 186.04 100% 186.04 284.09 1.7% 4.72 396.72 0.0% 0.08 190.84 49.84 100% 49.84 1989 218.52 100% 218.52 284.09 3.6% 10.28 396.72 0.7% 2.86 231.66 49.79 100% 49.79 1990 324.19 100% 324.19 284.09 26.5% 75.31 396.72 2.0% 7.93 407.43 50.21 100% 50.21 1991 301.83 100% 301.83 284.09 35.2% 99.94 396.72 0.6% 2.18 403.95 50.30 100% 50.30 1992 261.75 100% 261.75 284.09 48.4% 137.56 396.72 4.9% 19.40 418.71 50.61 100% 50.61 1993 264.77 100% 264.77 284.09 49.4% 140.40 396.72 14.1% 55.86 461.03 50.57 100% 50.57 1994 246.75 100% 246.75 284.09 25.4% 72.10 396.72 58.4% 231.53 550.38 50.60 100% 50.60 127.10 101995 176.07 100% 176.07 284.09 9.1% 25.97 396.72 89.5% 355.10 557.14 50.75 100% 50.75 127.76 251996 153.47 100% 153.47 284.09 4.9% 14.01 396.72 94.6% 375.30 542.78 50.94 100% 50.94 128.45 401997 124.63 100% 124.63 396.72 100% 396.72 521.35 51.09 100% 51.09 128.94 1001998 124.63 100% 124.63 396.72 100% 396.72 521.35 51.24 100% 51.24 129.44 1001999 124.63 100% 124.63 396.72 100% 396.72 521.35 51.23 100% 51.23 129.41 1002000 124.63 100% 124.63 396.72 100% 396.72 521.35 51.28 100% 51.28 129.58 1002001 124.63 100% 124.63 396.72 100% 396.72 521.35 51.21 100% 51.21 129.35 100

NO COSTVOLUNTARY COSTMANDATORY COST
145

TABLE 5A

AVERAGE CONSUMER COST PER PASSENGER CAR FOR

 IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 216 FMVSS 301

ROOF CRUSH FUEL SYSTEM INTEGRITY TOTAL TOTAL TOTAL

Model Unit % 216 Unit % 301 VOL MAND FMVSS

Year Cost of Cars Cost Cost of Cars Cost COST COST COST

1968 25.49 143.75 169.24

1969 32.31 183.74 216.05

1970 23.07 212.95 236.02

1971 28.92 212.55 241.47

1972 32.65 235.59 268.24

1973 291.23 291.231974 3.47 100% 3.47 301.97 301.971975 3.47 100% 3.47 299.54 299.541976 3.47 100% 3.47 16.51 100% 16.51 312.58 312.581977 3.47 100% 3.47 16.51 100% 16.51 306.66 306.661978 3.47 100% 3.47 16.51 100% 16.51 302.85 302.851979 3.47 100% 3.47 16.51 100% 16.51 299.58 299.581980 3.47 100% 3.47 16.51 100% 16.51 298.26 298.261981 3.47 100% 3.47 16.51 100% 16.51 297.87 297.871982 3.47 100% 3.47 16.51 100% 16.51 297.25 297.251983 3.47 100% 3.47 16.51 100% 16.51 297.61 297.611984 3.47 100% 3.47 16.51 100% 16.51 297.66 297.661985 3.47 100% 3.47 16.51 100% 16.51 0.84 297.45 298.29

1986 3.47 100% 3.47 16.51 100% 16.51 2.13 297.37 299.50

1987 3.47 100% 3.47 16.51 100% 16.51 338.32 338.321988 3.47 100% 3.47 16.51 100% 16.51 380.42 380.421989 3.47 100% 3.47 16.51 100% 16.51 421.31 421.311990 3.47 100% 3.47 16.51 100% 16.51 596.71 596.711991 3.47 100% 3.47 16.51 100% 16.51 593.10 593.101992 3.47 100% 3.47 16.51 100% 16.51 607.59 607.591993 3.47 100% 3.47 16.51 100% 16.51 650.01 650.011994 3.47 100% 3.47 16.51 100% 16.51 752.09 752.091995 3.47 100% 3.47 16.51 100% 16.51 777.93 777.931996 3.47 100% 3.47 16.51 100% 16.51 782.84 782.841997 3.47 100% 3.47 16.51 100% 16.51 838.81 838.811998 3.47 100% 3.47 16.51 100% 16.51 839.18 839.181999 3.47 100% 3.47 16.51 100% 16.51 839.16 839.162000 3.47 100% 3.47 16.51 100% 16.51 839.29 839.292001 3.47 100% 3.47 16.51 100% 16.51 839.13 839.13

NO COSTVOLUNTARY COSTMANDATORY COST
146

TABLE 5B

AVERAGE WEIGHT PER PASSENGER CAR FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 105 - BRAKES FMVSS 108 - LAMPS FMVSS 118 F

DUAL MASTER CYL. SIDE MARKER CHMSL POWER WINDOWS ACCELER

Model Unit % 105 Unit % Unit % 108 Unit % 118 Unit 

Year Weight of Cars Weight Weight of Cars Weight Weight of Cars Weight Weight Weight of Cars Weight Weight 

1968 1.74 100% 1.74 1.46 100% 1.46 1.461969 1.74 100% 1.74 1.46 100% 1.46 1.461970 1.74 100% 1.74 1.95 100% 1.95 1.951971 1.74 100% 1.74 1.95 100% 1.95 1.95 0.04 20.6% 0.011972 1.74 100% 1.74 1.95 100% 1.95 1.95 0.04 26.6% 0.011973 1.74 100% 1.74 1.95 100% 1.95 1.95 0.04 25.7% 0.011974 1.74 100% 1.74 1.95 100% 1.95 1.95 0.04 18.9% 0.01 0.02 1975 1.74 100% 1.74 1.95 100% 1.95 1.95 0.04 24.5% 0.01 0.02 1976 1.74 100% 1.74 1.95 100% 1.95 1.95 0.04 23.1% 0.01 0.02 1977 1.61 100% 1.61 1.95 100% 1.95 1.95 0.04 27.0% 0.01 0.02 1978 1.48 100% 1.48 1.95 100% 1.95 1.95 0.04 23.8% 0.01 0.02 1979 1.34 100% 1.34 1.95 100% 1.95 1.95 0.04 25.0% 0.01 0.02 1980 1.21 100% 1.21 1.95 100% 1.95 1.95 0.04 20.3% 0.01 0.02 1981 1.08 100% 1.08 1.95 100% 1.95 1.95 0.04 23.4% 0.01 0.02 1982 0.95 100% 0.95 1.95 100% 1.95 1.95 0.04 28.4% 0.01 0.02 1983 0.95 100% 0.95 1.95 100% 1.95 1.95 0.04 39.0% 0.02 0.02 1984 0.95 100% 0.95 1.95 100% 1.95 1.95 0.04 40.3% 0.02 0.02 1985 0.95 100% 0.95 1.95 100% 1.95 0.85 4.8% 0.04 1.99 0.04 44.4% 0.02 0.02 1986 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 43.0% 0.02 0.02 1987 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 42.5% 0.02 0.02 1988 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 46.9% 0.02 0.02 1989 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 49.4% 0.02 0.02 1990 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 57.6% 0.02 0.02 1991 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 54.9% 0.02 0.02 1992 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 61.8% 0.02 0.02 1993 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 67.7% 0.03 0.02 1994 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 73.2% 0.03 0.02 1995 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 73.7% 0.03 0.02 1996 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 79.6% 0.03 0.02 1997 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 79.6% 0.03 0.02 1998 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 83.0% 0.03 0.02 1999 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 83.0% 0.03 0.02 2000 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 85.0% 0.03 0.02 2001 0.95 100% 0.95 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 85.0% 0.03 0.02 

NO WEIGHTVOLUNTARY WEIGHTMANDATORY WEIGHT
147

TABLE 5B

AVERAGE WEIGHT PER PASSENGER CAR FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 201 - INTERIOR PROTECTION FMVSS 202 FMVSS 203/204 

GLOVE COMP. DOORS SEAT BACK PADDING HEAD RESTRAINTS STEERING ASSEMBLY SE

Model Unit % Unit % 201 Unit % 202 Unit % 203-4 Uni

Year Weight of Cars Weight Weight of Cars Weight Weight Weight of Cars Weight Weight of Cars Weight Weig

1968 0.01 100% 0.01 0.65 100% 0.65 0.66 8.77 12% 1.05 1.89 100% 1.89 3.1969 0.01 100% 0.01 0.65 100% 0.65 0.66 8.77 100% 8.77 1.89 100% 1.89 3.1970 0.01 100% 0.01 0.65 100% 0.65 0.66 8.52 100% 8.52 1.89 100% 1.89 3.1971 0.01 100% 0.01 0.65 100% 0.65 0.66 8.27 100% 8.27 1.89 100% 1.89 3.1972 0.01 100% 0.01 0.65 100% 0.65 0.66 8.02 100% 8.02 1.89 100% 1.89 3.1973 0.01 100% 0.01 0.65 100% 0.65 0.66 7.76 100% 7.76 1.89 100% 1.89 3.1974 0.01 100% 0.01 0.65 100% 0.65 0.66 7.51 100% 7.51 1.89 100% 1.89 3.1975 0.01 100% 0.01 0.65 100% 0.65 0.66 7.26 100% 7.26 1.89 100% 1.89 3.1976 0.01 100% 0.01 0.65 100% 0.65 0.66 7.01 100% 7.01 1.89 100% 1.89 3.1977 0.01 100% 0.01 0.65 100% 0.65 0.66 6.76 100% 6.76 1.89 100% 1.89 3.1978 0.01 100% 0.01 0.65 100% 0.65 0.66 6.50 100% 6.50 1.89 100% 1.89 3.1979 0.01 100% 0.01 0.65 100% 0.65 0.66 6.25 100% 6.25 1.89 100% 1.89 3.1980 0.01 100% 0.01 0.65 100% 0.65 0.66 6.00 100% 6.00 1.89 100% 1.89 3.1981 0.01 100% 0.01 0.65 100% 0.65 0.66 5.75 100% 5.75 1.89 100% 1.89 3.1982 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1983 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1984 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1985 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1986 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1987 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1988 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1989 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1990 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1991 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1992 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1993 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1994 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1995 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1996 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1997 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1998 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.1999 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.2000 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.2001 0.01 100% 0.01 0.65 100% 0.65 0.66 5.63 100% 5.63 1.89 100% 1.89 3.

NO WEIGHTVOLUNTARY WEIGHTMANDATORY WEIGHT
148

TABLE 5B

AVERAGE WEIGHT PER PASSENGER CAR FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 208/209/210 FMVSS 214 - SIDE IMPA

SAFETY BELTS DRIVER AIR BAGS DUAL AIR BAGS STATIC TEST DYNAMIC 

Model Unit % Unit % Unit % 208 Unit % Unit % 

Year Weight of Cars Weight Weight of Cars Weight Weight of Cars Weight Weight Weight of Cars Weight Weight of Ca

1968 9.92 100% 9.92 9.921969 10.49 100% 10.49 10.49 38.00 17% 6.46 1970 10.49 100% 10.49 10.49 37.66 35% 13.18 1971 10.49 100% 10.49 10.49 37.61 44% 16.55 1972 15.28 100% 15.28 15.28 37.84 49% 18.54 1973 15.29 100% 15.29 15.29 37.67 85% 32.02 1974 16.51 100% 16.51 16.51 35.29 100% 35.29 1975 16.58 100% 16.58 16.58 33.72 100% 33.72 1976 16.57 100% 16.57 16.57 31.94 100% 31.94 1977 16.40 100% 16.40 16.40 30.15 100% 30.15 1978 16.40 100% 16.40 16.40 28.29 100% 28.29 1979 16.47 100% 16.47 16.47 26.49 100% 26.49 1980 16.47 100% 16.47 16.47 26.41 100% 26.41 1981 16.53 100% 16.53 16.53 26.06 100% 26.06 1982 16.48 100% 16.48 16.48 25.90 100% 25.90 1983 16.53 100% 16.53 16.53 25.70 100% 25.70 1984 16.53 100% 16.53 16.53 25.72 100% 25.72 1985 16.53 100% 16.53 13.46 0.1% 0.02 16.55 25.60 100% 25.60 1986 16.54 100% 16.54 13.46 0.8% 0.10 16.64 25.55 100% 25.55 1987 18.77 100% 18.77 13.46 1.2% 0.16 26.76 0.1% 0.01 18.94 25.44 100% 25.44 1988 22.18 100% 22.18 13.46 1.7% 0.22 26.76 0.0% 0.01 22.41 25.56 100% 25.56 1989 25.01 100% 25.01 13.46 3.6% 0.49 26.76 0.7% 0.19 25.69 25.59 100% 25.59 1990 33.86 100% 33.86 13.46 26.5% 3.57 26.76 2.0% 0.54 37.97 25.36 100% 25.36 1991 31.29 100% 31.29 13.46 35.2% 4.74 26.76 0.6% 0.15 36.18 25.31 100% 25.31 1992 28.31 100% 28.31 13.46 48.4% 6.52 26.76 4.9% 1.31 36.14 25.14 100% 25.14 1993 28.66 100% 28.66 13.46 49.4% 6.65 26.76 14.1% 3.77 39.08 25.17 100% 25.17 1994 27.35 100% 27.35 13.46 25.4% 3.42 26.76 58.4% 15.62 46.39 25.15 100% 25.15 36.20 101995 22.19 100% 22.19 13.46 9.1% 1.23 26.76 89.5% 23.95 47.37 25.06 100% 25.06 36.44 251996 20.53 100% 20.53 13.46 4.9% 0.66 26.76 94.6% 25.31 46.50 24.96 100% 24.96 36.80 401997 18.38 100% 18.38 26.76 100% 26.76 45.14 24.88 100% 24.88 37.07 1001998 18.38 100% 18.38 26.76 100% 26.76 45.14 24.79 100% 24.79 37.37 1001999 18.38 100% 18.38 26.76 100% 26.76 45.14 24.80 100% 24.80 37.35 1002000 18.38 100% 18.38 26.76 100% 26.76 45.14 24.77 100% 24.77 37.45 1002001 18.38 100% 18.38 26.76 100% 26.76 45.14 24.81 100% 24.81 37.31 100

NO WEIGHTVOLUNTARY WEIGHTMANDATORY WEIGHT
149

TABLE 5B

AVERAGE WEIGHT PER PASSENGER CAR FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 216 FMVSS 301

ROOF CRUSH FUEL SYSTEM INTEGRITY TOTAL TOTAL TOTAL

Model Unit % 216 Unit % 301 VOL MAND FMVSS

Year Weight of Cars Weight Weight of Cars Weight WEIGHT WEIGHT WEIGHT

1968 2.51 15.87 18.391969 7.92 25.23 33.151970 13.18 27.03 40.21

1971 16.55 26.80 43.35

1972 18.54 31.27 49.82

1973 63.09 63.091974 2.93 100% 2.93 70.48 70.481975 2.93 100% 2.93 68.64 68.641976 2.93 100% 2.93 2.48 100% 2.48 69.07 69.071977 2.93 100% 2.93 2.48 100% 2.48 66.68 66.681978 2.93 100% 2.93 2.48 100% 2.48 64.41 64.411979 2.93 100% 2.93 2.48 100% 2.48 62.33 62.331980 2.93 100% 2.93 2.48 100% 2.48 62.33 62.331981 2.93 100% 2.93 2.48 100% 2.48 61.33 61.331982 2.93 100% 2.93 2.48 100% 2.48 60.72 60.721983 2.93 100% 2.93 2.48 100% 2.48 60.38 60.381984 2.93 100% 2.93 2.48 100% 2.48 60.42 60.421985 2.93 100% 2.93 2.48 100% 2.48 0.06 60.19 60.241986 2.93 100% 2.93 2.48 100% 2.48 0.10 60.10 60.201987 2.93 100% 2.93 2.48 100% 2.48 63.14 63.141988 2.93 100% 2.93 2.48 100% 2.48 66.84 66.841989 2.93 100% 2.93 2.48 100% 2.48 70.18 70.181990 2.93 100% 2.93 2.48 100% 2.48 82.02 82.021991 2.93 100% 2.93 2.48 100% 2.48 80.13 80.131992 2.93 100% 2.93 2.48 100% 2.48 79.76 79.761993 2.93 100% 2.93 2.48 100% 2.48 82.76 82.761994 2.93 100% 2.93 2.48 100% 2.48 93.66 93.661995 2.93 100% 2.93 2.48 100% 2.48 99.96 99.961996 2.93 100% 2.93 2.48 100% 2.48 104.50 104.501997 2.93 100% 2.93 2.48 100% 2.48 125.34 125.341998 2.93 100% 2.93 2.48 100% 2.48 125.47 125.471999 2.93 100% 2.93 2.48 100% 2.48 125.46 125.462000 2.93 100% 2.93 2.48 100% 2.48 125.51 125.512001 2.93 100% 2.93 2.48 100% 2.48 125.44 125.44

NO WEIGHTVOLUNTARY WEIGHTMANDATORY WEIGHT
150

TABLE 5C

AVERAGE CONSUMER COST PER LIGHT TRUCK FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 104 - WINDSHIELD WIPING/WASHING SYSTEMS FMVSS 105 - HYDRAULIC BRAKES

WIPERS WASHERS DUAL MASTER CYLINDER WARNING LIGHT

Model Unit % Unit % 104 Unit % Unit % 

Year Cost of LTs Cost Cost of LTs Cost Cost Cost of LTs Cost Cost of LTs Cost 

1968 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1969 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1970 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1971 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1972 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1973 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1974 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1975 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1976 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1977 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1978 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1979 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1980 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1981 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1982 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1983 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 1984 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1985 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1986 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1987 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1988 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1989 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1990 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1991 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1992 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1993 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1994 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1995 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1996 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1997 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1998 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 1999 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 2000 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 2001 4.02 100% 4.02 11.03 100% 11.03 15.05 10.88 100% 10.88 0.12 100% 0.12 

NO COSTVOLUNTARY COSTMANDATORY COST
151

TABLE 5C

AVERAGE CONSUMER COST PER LIGHT TRUCK FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 108 - LAMPS FMVSS 118 FMVSS 124 FMVSS 2

SIDE MARKER CHMSL POWER WINDOWS ACCELERATOR CONTROLS SEA

Model Unit % Unit % 108 Unit % 118 Unit % 124 Unit 

Year Cost of LTs Cost Cost of LTs Cost Cost Cost of LTs Cost Cost of LTs Cost Cost 

1968 20.90 100% 20.90 20.901969 20.90 100% 20.90 20.901970 29.37 100% 29.37 29.371971 29.37 100% 29.37 29.371972 29.37 100% 29.37 29.371973 29.37 100% 29.37 29.371974 29.37 100% 29.37 29.37 0.47 100% 0.471975 29.37 100% 29.37 29.37 0.47 100% 0.471976 29.37 100% 29.37 29.37 0.47 100% 0.471977 29.37 100% 29.37 29.37 0.47 100% 0.471978 29.37 100% 29.37 29.37 0.92 2.3% 0.02 0.47 100% 0.471979 29.37 100% 29.37 29.37 0.92 3.6% 0.03 0.47 100% 0.471980 29.37 100% 29.37 29.37 0.92 5.5% 0.05 0.47 100% 0.471981 29.37 100% 29.37 29.37 0.92 7.9% 0.07 0.47 100% 0.471982 29.37 100% 29.37 29.37 0.92 12.2% 0.11 0.47 100% 0.47 13.48 1983 29.37 100% 29.37 29.37 0.92 15.4% 0.14 0.47 100% 0.47 13.48 1984 29.37 100% 29.37 29.37 0.92 19.0% 0.17 0.47 100% 0.47 13.48 1985 29.37 100% 29.37 29.37 0.92 22.4% 0.21 0.47 100% 0.47 13.48 1986 29.37 100% 29.37 29.37 0.92 24.6% 0.23 0.47 100% 0.47 13.48 1987 29.37 100% 29.37 29.37 0.92 27.5% 0.25 0.47 100% 0.47 13.48 1988 29.37 100% 29.37 29.37 0.92 29.6% 0.27 0.47 100% 0.47 13.48 1989 29.37 100% 29.37 29.37 0.92 37.4% 0.34 0.47 100% 0.47 13.48 1990 29.37 100% 29.37 29.37 0.92 46.2% 0.43 0.47 100% 0.47 13.48 1991 29.37 100% 29.37 9.74 28.9% 2.82 32.19 0.92 48.3% 0.44 0.47 100% 0.47 13.48 1992 29.37 100% 29.37 9.74 24.7% 2.40 31.77 0.92 47.2% 0.43 0.47 100% 0.47 13.48 1993 29.37 100% 29.37 9.74 28.0% 2.73 32.10 0.92 54.9% 0.50 0.47 100% 0.47 13.48 1994 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 56.4% 0.52 0.47 100% 0.47 13.48 1995 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 61.6% 0.57 0.47 100% 0.47 13.48 1996 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 65.5% 0.60 0.47 100% 0.47 13.48 1997 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 67.5% 0.62 0.47 100% 0.47 13.48 1998 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 74.1% 0.68 0.47 100% 0.47 13.48 1999 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 77.1% 0.71 0.47 100% 0.47 13.48 2000 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 77.7% 0.71 0.47 100% 0.47 13.48 2001 29.37 100% 29.37 9.74 100% 9.74 39.11 0.92 83.5% 0.77 0.47 100% 0.47 13.48 

NO COSTVOLUNTARY COSTMANDATORY COST
152

TABLE 5C

AVERAGE CONSUMER COST PER LIGHT TRUCK FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 202 FMVSS 203/204 FMVSS 208/209/210

HEAD RESTRAINTS STEERING ASSEMBLY SAFETY BELTS DRIVER AIR BAGS DUAL AIR BAGS 

Model Unit % 202 Unit % 203-4 Unit % Unit % Unit % 

Year Cost of LTs Cost Cost of LTs Cost Cost of LTs Cost Cost of LTs Cost Cost of LTs Cost 

1968 30.97 10.3% 3.20 56.55 100% 56.55 1969 30.97 10.3% 3.20 56.61 100% 56.61 1970 30.97 10.3% 3.20 27.45 3% 0.82 56.63 100% 56.63 1971 30.97 10.3% 3.20 27.45 4% 1.10 56.64 100% 56.64 1972 30.97 10.3% 3.20 27.45 2% 0.55 83.21 100% 83.21 1973 30.97 10.3% 3.20 27.45 47% 12.90 83.21 100% 83.21 1974 30.97 24.1% 7.46 27.45 48% 13.18 84.39 100% 84.39 1975 30.97 24.1% 7.46 27.45 48% 13.18 84.47 100% 84.47 1976 30.97 24.1% 7.46 27.45 53% 14.55 84.50 100% 84.50 1977 30.97 24.1% 7.46 27.45 55% 15.10 94.82 100% 94.82 1978 30.97 24.1% 7.46 27.45 53% 14.55 94.83 100% 94.83 1979 30.97 24.1% 7.46 27.45 60% 16.47 94.82 100% 94.82 1980 30.97 24.1% 7.46 27.45 77% 21.14 95.04 100% 95.04 1981 30.97 24.1% 7.46 27.45 79% 21.69 95.14 100% 95.14 1982 30.97 24.1% 7.46 27.45 100% 27.45 95.14 100% 95.14 1983 30.97 40.8% 12.63 27.45 100% 27.45 95.14 100% 95.14 1984 30.97 47.2% 14.63 27.45 100% 27.45 95.14 100% 95.14 1985 30.97 53.8% 16.65 27.45 100% 27.45 95.14 100% 95.14 1986 30.97 55.3% 17.11 27.45 100% 27.45 95.14 100% 95.14 1987 30.97 64.3% 19.91 27.45 100% 27.45 106.63 100% 106.63 

1988 30.97 60.9% 18.85 27.45 100% 27.45 106.72 100% 106.72 

1989 30.97 58.2% 18.02 27.45 100% 27.45 107.32 100% 107.32 

1990 30.97 69.4% 21.51 27.45 100% 27.45 107.49 100% 107.49 

1991 30.97 70.5% 21.84 27.45 100% 27.45 107.89 100% 107.89 265.78 3.1% 8.19 

1992 30.97 100% 30.97 27.45 100% 27.45 111.90 100% 111.90 265.78 14.8% 39.20 1993 30.97 100% 30.97 27.45 100% 27.45 111.90 100% 111.90 265.78 19.3% 51.30 

1994 30.97 100% 30.97 27.45 100% 27.45 111.90 100% 111.90 265.78 26.8% 71.18 383.75 7.6% 29.01 1995 30.97 100% 30.97 27.45 100% 27.45 137.57 100% 137.57 265.78 66.3% 176.21 383.75 13.6% 52.11 1996 30.97 100% 30.97 27.45 100% 27.45 137.57 100% 137.57 265.78 55.6% 147.67 383.75 37.7% 144.64 1997 30.97 100% 30.97 27.45 100% 27.45 137.57 100% 137.57 265.78 22.3% 59.14 383.75 71.3% 273.77 1998 30.97 100% 30.97 27.45 100% 27.45 137.57 100% 137.57 383.75 97.8% 375.46 1999 30.97 100% 30.97 27.45 100% 27.45 137.57 100% 137.57 383.75 98.6% 378.42 2000 30.97 100% 30.97 27.45 100% 27.45 137.57 100% 137.57 383.75 99.1% 380.22 2001 30.97 100% 30.97 27.45 100% 27.45 137.57 100% 137.57 383.75 99.7% 382.52 

NO COSTVOLUNTARY COSTMANDATORY COST
153

TABLE 5C

AVERAGE CONSUMER COST PER LIGHT TRUCK FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 214 - SIDE IMPACT FMVSS 301

STATIC TEST FUEL SYSTEM INTEGRITY TOTAL TOTAL TOTAL

Model Unit % 214 Unit % 301 VOL MAND FMVSS

Year Cost of LTs Cost Cost of LTs Cost COST COST COST

1968 91.53 15.05 106.581969 91.59 15.05 106.641970 71.53 44.42 115.951971 71.82 44.42 116.241972 14.63 127.63 142.261973 26.98 127.63 154.611974 31.51 129.28 160.791975 31.51 129.36 160.871976 32.88 129.39 162.271977 33.43 139.71 173.141978 16.51 100% 16.51 32.91 156.23 189.141979 16.51 100% 16.51 34.84 156.22 191.061980 16.51 100% 16.51 39.52 156.44 195.961981 16.51 100% 16.51 40.09 156.54 196.631982 16.51 100% 16.51 18.45 188.47 206.921983 16.51 100% 16.51 23.65 188.47 212.121984 16.51 100% 16.51 14.80 199.47 214.281985 16.51 100% 16.51 16.86 199.47 216.331986 16.51 100% 16.51 17.34 199.47 216.811987 16.51 100% 16.51 20.16 213.36 233.521988 16.51 100% 16.51 19.12 213.45 232.581989 16.51 100% 16.51 18.02 214.40 232.421990 16.51 100% 16.51 21.51 214.65 236.151991 29.44 8% 2.36 16.51 100% 16.51 35.19 215.07 250.26

1992 29.44 9% 2.65 16.51 100% 16.51 44.26 250.04 294.29

1993 29.44 15% 4.42 16.51 100% 16.51 58.44 250.11 308.55

1994 29.44 100% 29.44 16.51 100% 16.51 100.19 289.30 389.491995 29.44 100% 29.44 16.51 100% 16.51 547.71 547.711996 29.44 100% 29.44 16.51 100% 16.51 612.52 612.521997 29.44 100% 29.44 16.51 100% 16.51 658.58 658.581998 29.44 100% 29.44 16.51 100% 16.51 705.27 705.271999 29.44 100% 29.44 16.51 100% 16.51 708.22 708.222000 29.44 100% 29.44 16.51 100% 16.51 709.39 709.392001 29.44 100% 29.44 16.51 100% 16.51 710.86 710.86

NO COSTVOLUNTARY COSTMANDATORY COST
154

TABLE 5D

AVERAGE WEIGHT PER LIGHT TRUCK FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 104 - WINDSHIELD WIPING/WASHING SYSTEMS FMVSS 105 - HYDRAULIC BRAKES

WIPERS WASHERS DUAL MASTER CYLINDER WARNING LIGHT

Model Unit % Unit % 104 Unit % Unit % 

Year Weight of LTs Weight Weight of LTs Weight Weight Weight of LTs Weight Weight of LTs Weight 

1968 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1969 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1970 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1971 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1972 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1973 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1974 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1975 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1976 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1977 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1978 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1979 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1980 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1981 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1982 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1983 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 1984 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1985 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1986 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1987 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1988 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1989 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1990 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1991 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1992 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1993 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1994 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1995 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1996 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1997 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1998 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 1999 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 2000 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 2001 0.49 100% 0.49 1.61 100% 1.61 2.10 0.95 100% 0.95 0.01 100% 0.01 

NO WEIGHTVOLUNTARY WEIGHTMANDATORY WEIGHT
155

TABLE 5D

AVERAGE WEIGHT PER LIGHT TRUCK FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 108 - LAMPS FMVSS 118 FMVSS 124 FMVSS 2

SIDE MARKER CHMSL POWER WINDOWS ACCELERATOR CONTROLS SEA

Model Unit % Unit % 108 Unit % 118 Unit % 124 Unit 

Year Weight of LTs Weight Weight of LTs Weight Weight Weight of LTs Weight Weight of LTs Weight Weight 

1968 1.46 100% 1.46 1.461969 1.46 100% 1.46 1.461970 1.95 100% 1.95 1.951971 1.95 100% 1.95 1.951972 1.95 100% 1.95 1.951973 1.95 100% 1.95 1.951974 1.95 100% 1.95 1.95 0.02 100% 0.021975 1.95 100% 1.95 1.95 0.02 100% 0.021976 1.95 100% 1.95 1.95 0.02 100% 0.021977 1.95 100% 1.95 1.95 0.02 100% 0.021978 1.95 100% 1.95 1.95 0.04 2.3% 0.00 0.02 100% 0.021979 1.95 100% 1.95 1.95 0.04 3.6% 0.00 0.02 100% 0.021980 1.95 100% 1.95 1.95 0.04 5.5% 0.00 0.02 100% 0.021981 1.95 100% 1.95 1.95 0.04 7.9% 0.00 0.02 100% 0.021982 1.95 100% 1.95 1.95 0.04 12.2% 0.00 0.02 100% 0.02 3.78 1983 1.95 100% 1.95 1.95 0.04 15.4% 0.01 0.02 100% 0.02 3.78 1984 1.95 100% 1.95 1.95 0.04 19.0% 0.01 0.02 100% 0.02 3.78 1985 1.95 100% 1.95 1.95 0.04 22.4% 0.01 0.02 100% 0.02 3.78 1986 1.95 100% 1.95 1.95 0.04 24.6% 0.01 0.02 100% 0.02 3.78 1987 1.95 100% 1.95 1.95 0.04 27.5% 0.01 0.02 100% 0.02 3.78 1988 1.95 100% 1.95 1.95 0.04 29.6% 0.01 0.02 100% 0.02 3.78 1989 1.95 100% 1.95 1.95 0.04 37.4% 0.01 0.02 100% 0.02 3.78 1990 1.95 100% 1.95 1.95 0.04 46.2% 0.02 0.02 100% 0.02 3.78 1991 1.95 100% 1.95 0.85 28.9% 0.25 2.20 0.04 48.3% 0.02 0.02 100% 0.02 3.78 

1992 1.95 100% 1.95 0.85 24.7% 0.21 2.16 0.04 47.2% 0.02 0.02 100% 0.02 3.78 

1993 1.95 100% 1.95 0.85 28.0% 0.24 2.19 0.04 54.9% 0.02 0.02 100% 0.02 3.78 

1994 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 56.4% 0.02 0.02 100% 0.02 3.78 1995 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 61.6% 0.02 0.02 100% 0.02 3.78 1996 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 65.5% 0.03 0.02 100% 0.02 3.78 1997 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 67.5% 0.03 0.02 100% 0.02 3.78 1998 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 74.1% 0.03 0.02 100% 0.02 3.78 1999 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 77.1% 0.03 0.02 100% 0.02 3.78 2000 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 77.7% 0.03 0.02 100% 0.02 3.78 2001 1.95 100% 1.95 0.85 100% 0.85 2.80 0.04 83.5% 0.03 0.02 100% 0.02 3.78 

NO WEIGHTVOLUNTARY WEIGHTMANDATORY WEIGHT
156

TABLE 5D

AVERAGE WEIGHT PER LIGHT TRUCK FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 202 FMVSS 203/204 FMVSS 208/209/210

HEAD RESTRAINTS STEERING ASSEMBLY SAFETY BELTS DRIVER AIR BAGS DUAL AIR BAGS 

Model Unit % 202 Unit % 203-4 Unit % Unit % Unit % 

Year Weight of LTs Weight Weight of LTs Weight Weight of LTs Weight Weight of LTs Weight Weight of LTs Weight W

1968 3.98 10.3% 0.41 5.59 100% 5.59 

1969 3.98 10.3% 0.41 5.60 100% 5.60 

1970 3.98 10.3% 0.41 1.89 3% 0.06 5.60 100% 5.60 

1971 3.98 10.3% 0.41 1.89 4% 0.08 5.61 100% 5.61 

1972 3.98 10.3% 0.41 1.89 2% 0.04 10.45 100% 10.45 

1973 3.98 10.3% 0.41 1.89 47% 0.89 10.45 100% 10.45 

1974 3.98 24.1% 0.96 1.89 48% 0.91 10.70 100% 10.70 

1975 3.98 24.1% 0.96 1.89 48% 0.91 10.72 100% 10.72 

1976 3.98 24.1% 0.96 1.89 53% 1.00 10.73 100% 10.73 

1977 3.98 24.1% 0.96 1.89 55% 1.04 12.00 100% 12.00 

1978 3.98 24.1% 0.96 1.89 53% 1.00 12.00 100% 12.00 

1979 3.98 24.1% 0.96 1.89 60% 1.13 12.00 100% 12.00 

1980 3.98 24.1% 0.96 1.89 77% 1.46 12.04 100% 12.04 

1981 3.98 24.1% 0.96 1.89 79% 1.49 12.07 100% 12.07 

1982 3.98 24.1% 0.96 1.89 100% 1.89 12.07 100% 12.07 1983 3.98 40.8% 1.62 1.89 100% 1.89 12.07 100% 12.07 1984 3.98 47.2% 1.88 1.89 100% 1.89 12.07 100% 12.07 1985 3.98 53.8% 2.14 1.89 100% 1.89 12.07 100% 12.07 1986 3.98 55.3% 2.20 1.89 100% 1.89 12.07 100% 12.07 1987 3.98 64.3% 2.56 1.89 100% 1.89 13.33 100% 13.33 1988 3.98 60.9% 2.42 1.89 100% 1.89 13.36 100% 13.36 1989 3.98 58.2% 2.32 1.89 100% 1.89 13.54 100% 13.54 1990 3.98 69.4% 2.76 1.89 100% 1.89 13.59 100% 13.59 1991 3.98 70.5% 2.81 1.89 100% 1.89 13.71 100% 13.71 14.31 3.1% 0.44 1992 3.98 100% 3.98 1.89 100% 1.89 14.91 100% 14.91 14.31 14.8% 2.11 

1993 3.98 100% 3.98 1.89 100% 1.89 14.91 100% 14.91 14.31 19.3% 2.76 

1994 3.98 100% 3.98 1.89 100% 1.89 14.91 100% 14.91 14.31 26.8% 3.83 26.48 7.6% 2.00 

1995 3.98 100% 3.98 1.89 100% 1.89 18.41 100% 18.41 14.31 66.3% 9.49 26.48 13.6% 3.60 1996 3.98 100% 3.98 1.89 100% 1.89 18.41 100% 18.41 14.31 55.6% 7.95 26.48 37.7% 9.98 1997 3.98 100% 3.98 1.89 100% 1.89 18.41 100% 18.41 14.31 22.3% 3.18 26.48 71.3% 18.89 1998 3.98 100% 3.98 1.89 100% 1.89 18.41 100% 18.41 26.48 97.8% 25.91 1999 3.98 100% 3.98 1.89 100% 1.89 18.41 100% 18.41 26.48 98.6% 26.11 2000 3.98 100% 3.98 1.89 100% 1.89 18.41 100% 18.41 26.48 99.1% 26.24 2001 3.98 100% 3.98 1.89 100% 1.89 18.41 100% 18.41 26.48 99.7% 26.40 

NO WEIGHTVOLUNTARY WEIGHTMANDATORY WEIGHT
157

TABLE 5D

AVERAGE WEIGHT PER LIGHT TRUCK FOR

IMPLEMENTATION OF THE FMVSS FOR MODEL YEARS 1968-2001

FMVSS 214 - SIDE IMPACT FMVSS 301

STATIC TEST FUEL SYSTEM INTEGRITY TOTAL TOTAL TOTAL

Model Unit % 214 Unit % 301 VOL MAND FMVSS

Year Weight of LTs Weight Weight of LTs Weight Weight Weight Weight

1968 8.41 2.10 10.51

1969 8.42 2.10 10.52

1970 7.02 4.05 11.07

1971 7.05 4.05 11.10

1972 1.40 14.50 15.90

1973 2.25 14.50 16.75

1974 2.82 14.77 17.59

1975 2.82 14.79 17.61

1976 2.91 14.80 17.71

1977 2.95 16.07 19.02

1978 2.48 100% 2.48 2.91 18.55 21.46

1979 2.48 100% 2.48 3.04 18.55 21.59

1980 2.48 100% 2.48 3.37 18.59 21.96

1981 2.48 100% 2.48 3.40 18.62 22.02

1982 2.48 100% 2.48 1.91 21.77 23.68

1983 2.48 100% 2.48 2.58 21.77 24.35

1984 2.48 100% 2.48 1.89 22.73 24.61

1985 2.48 100% 2.48 2.15 22.73 24.88

1986 2.48 100% 2.48 2.21 22.73 24.94

1987 2.48 100% 2.48 2.57 24.66 27.23

1988 2.48 100% 2.48 2.43 24.69 27.12

1989 2.48 100% 2.48 2.32 24.89 27.20

1990 2.48 100% 2.48 2.76 24.94 27.70

1991 23.76 8% 1.90 2.48 100% 2.48 5.39 25.06 30.45

1992 23.76 9% 2.14 2.48 100% 2.48 4.46 30.24 34.70

1993 23.76 15% 3.56 2.48 100% 2.48 6.56 30.24 36.81

1994 23.76 100% 23.76 2.48 100% 2.48 5.83 54.85 60.69

1995 23.76 100% 23.76 2.48 100% 2.48 72.67 72.671996 23.76 100% 23.76 2.48 100% 2.48 77.53 77.531997 23.76 100% 23.76 2.48 100% 2.48 81.79 81.791998 23.76 100% 23.76 2.48 100% 2.48 85.73 85.731999 23.76 100% 23.76 2.48 100% 2.48 85.93 85.932000 23.76 100% 23.76 2.48 100% 2.48 86.04 86.042001 23.76 100% 23.76 2.48 100% 2.48 86.18 86.18

NO WEIGHTVOLUNTARY WEIGHTMANDATORY WEIGHT
158
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