US. Department

of Transportation

National Highway

Traffic Safety

Administration

© Final

Regulatory

Impact Analysis

Amendment to Federal Motor

Vehicle Safety Standard 208

Passenger Car Front Seat

Occupant Protection
FINAL REGULATORY IMPACT ANALYSIS

AMENDMENT TO FMVSS NO. 208

PASSENGER CAR FRONT SEAT

OCCUPANT PROTECTION

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

PLANS AND PROGRAMS

OFFICE OF PLANNING AND ANALYSIS

JULY 11, 1984
TABLE OF CONTENTS

I.

II.

III.

-

SUMMARY

INTRODUCTION

BACKGROUND

ISSUES

A. AIR BAG ISSUES

1. Small Cars

2. Sodium Azide

3. Product Liability

4. Breed System

PAGE NO.

1

1-1

B. OTHER ISSUES

1. Passive Interiors

2. Test Procedures Repeatability

IV. EFFECTIVENESS

A. MANUAL LAP AND LAP/SHOULDER BELTS

B. AUTOMATIC BELTS

C. AIR BAGS

V. USAGE

A. SEAT BELT USAGE DATA

B. RESTRAINT USAGE LEVEL ESTIMATION

VI. SAFETY BENEFITS

A. PASSENGER CAR OCCUPANT FATALITIES

B. PASSENGER CAR OCCUPANT INJURIES

C. RANGE OF IMPACTS ON FATALITIES AND INJURIES

D. BREAKEVEN POINT ANALYSIS OF SAFETY BENEFITS

E. TIME PHASE ANALYSIS OF FATALITY BENEFITS

F. CENTRAL SEATING POSITION

G. RISK COMPENSATION HYPOTHESIS

H. BENEFITS OF A GRADUAL INTRODUCTION

OF AUTOMATIC OCCUPANT PROTECTION

I. BENEFITS OF MANDATORY USE LAWS

111-12

111-32

111-40

111-45

111-48

IV-3

IV-17

IV-36

V-2

V-26

VI-2

VI -6

VI-1O

VI-20

VI-23

VI-30

VI-42

VI-45

VI-45
1 1

VII. INSURANCE

A. AUTOMOBILE INSURANCE VII-3

1. Personal Injury Premium Reduction VII-A

2. Physical Damage Premium Increases VII-17

B. HEALTH AND OTHER INSURANCE VI1-43

C. LIFE INSURANCE VII-47

VIII. COST AND LEADTIME

A. SYSTEM DESCRIPTIONS VIII-3

B. AUTOMATIC RESTRAINT COST ANALYSIS VIII-12

C. LEADTIME VIII-55

D. ENERGY COSTS VIII-60

IX. COST IMPACTS

A. DEMAND FOR AUTOMOBILES IX-2

B. MICRO-ECONOMIC EFFECTS IX-9

C. MACRO-ECONOMIC EFFECTS IX-26

D. SYNTHESIS IX-32

X. SMALL BUSINESS CONSIDERATIONS

A. SEAT BELT MANUFACTURERS X-2

B. AIR BAG MANUFACTURERS X-9

C. NEW CAR DEALERS AND AUTO REPAIR ESTABLISHMENTS X-16

D. AUTOMOBILE MANUFACTURERS . X-20

E. CONCLUSION X-22

X I . PUBLIC OPINION AND MARKET ACCEPTANCE

A. AWARENESS/KNOWLEDGE XI-1O

B. GOVERNMENT'S ROLE XI-13

C. WILLINGNESS TO PAY XI-20

D. ATTITUDES TOWARD ALTERNATIVE RESTRAINT SYSTEMS XI-25

E. PUBLIC ATTITUDES TOWARD A MANDATORY SAFETY

BELT USE LAW XI-49

F. MARKETING AIR BAGS AS OPTIONAL EQUIPMENT XI-55

G. DOCKET SUBMISSIONS XI-59

XII. ALTERNATIVES XII-1
iii

XIII. NET IMPACTS OF AUTOMATIC RESTRAINT DEVICES XIII-1

XIV. CONCLUSIONS XIV-1
SUMMARY

In October 1983, the Department of Transportation published a Notice of

Proposed Rulemaking (NPRM) which proposed several alternative amendments to

FMVSS No. 208, Occupant Crash Protection. The Preliminary Regulatory Impact

Analysis (PRIA) accompanying the NPRM discussed the uncertainty involved in

determining the effectiveness of restraint systems, safety benefits,

insurance savings/costs, as well as consumer and other costs that could be

anticipated under various alternatives and solicited comments on this

subject. In response to the NPRM, over 7,800 commenters offered their views

about various aspects of the proposed rulemaking, including the automobile

manufacturers, insurance companies, consumer groups, and other interested

parties. In May 1984, the Department published a Supplemental Notice of

Proposed Rulemaking (SNPRM) asking for comments on four additional

alternatives, as well as other issues. There were over 130 comments to the

SNPRM. In preparation for this rulemaking, the Department of Transportation

conducted comprehensive analyses of pertinent comments and of all accident

data and other material available in its files. On the basis of these

analyses, the agency sought to determine the effects on benefits and costs of

the proposed alternatives to improve passenger car occupant protection.

While many of the uncertainties still remain, notably the uncertainty

surrounding the precise level of potential usage of automatic belts, the

summary data below are based on the best currently available estimates.
Effectiveness

Effectiveness of an occupant restraint system is defined as the percentage

reduction in fatalities or injuries for restrained occupants as compared to

unrestrained occupants. In this analysis, the agency reviewed all pertinent

accident data in order to develop a range of estimates of the effectiveness

for air bags without belts, with lap belts, and with three point belts;

manual lap belts, manual lap and shoulder belts; and automatic belts. The

results of the effectiveness evaluation are as follows:

Fatalities

AIS 2-5

Injuries

AIS 1

Injuries

Manual

Lap Belt

30-40

25-35

10

PERCENT

Manual

Lap/

Shoulder

Belt

40-50

45-55

10

TABLE 1

EFFECTIVENESS

Automatic Air Bag

Belt Alone

35-50

40-55

10

20-40

25-45

10

Air Bag

With

Lap Belt

40-50

45-55

10

Air Bag

With Lap/

Shoulder

Belt

45-55

50-60

10

According to these estimates, there is no single system more effective than

the manual lap/shoulder belt when used; but using this system with an air bag

as a supplement provides the most effective system for both fatalities and

AIS 2-5 injuries.

Throughout the analysis, the safety benefits and insurance premium changes

will be presented as a range of values. These ranges reflect the low and

high effectiveness estimates.
Safety Benefits

Based on projected fatalities and injuries and -using the range of

effectiveness estimates and a range of automatic and manual seat belt usage,

estimates were made of the incremental reductions in fatalities, AI5 2-5

injuries, and AIS 1 injuries for all automatic restraint systems (air bags

without seat belts, air bags with lap belts, air bags with lap/shoulder belts

and automatic belts) and for mandatory use laws if they are effective in all

states. Estimates are provided across a broad range of usage (20-70 percent)

for automatic belts and a narrower range (40-70 percent) for mandatory use

laws because the precise level of future usage is uncertain. Below are the

results of this analysis:

TABLE 2

INCREMENTAL REDUCTION IN

Fatalities AIS 2-5 Injuries AIS 1 Injury

Air Bags Only (No 3,780-8,630 73,660-147,560 255,770

Lap Belt Usage)

Air Bags With Lap

Belt (12.5% Usage) 4,410-8,960 83,480-152,550 255,770

85,930-155,030 255,770

8,740-15,650 22,760

24,370-37,440 52,640

39,990-59,220 82,510

55,610-81,000 112,380

71,240-102,790 142,250

86,860-124,570 172,120

Mandatory Belt Use

Laws (in all states)

40% Usage 2,830-3,590 47,740-59,220 82,510

50% 3,860-4,900 65,300-81,000 112,380

60% 4,890-6,200 82,860-102,790 142,250

70% 5,920-7,510 100,430-124,570 172,120

Air Bags With Lap

Shoulder Belt

(12.5% Usage)

Automatic Belts

20% Usage

30%

40%

50%

60%

70%

4,570-9,110

520-980

1,420-2

2,320-3

3,230-4

4,130-6

5.030-7

,280

,590

,900

,200

.510
Insurance Premium Changes

Based on the projected loss experience of the insurance industry resulting

from an automatic occupant protection requirement, insurance premiums should

change for various automobile insurance coverages, as well as for health

insurance and life insurance. These results are summarized below:

TABLE 3

SUMMARY OF POTENTIAL EFFECTS

ON INSURANCE PREMIUMS FROM

AUTOMATIC RESTRAINT REQUIREMENTS

Air Bags

Automobile Insurance

Savings-Safety

Loss-Deployment

Health Insurance

Life Insurance

Total

Automatic Belts

(For 20 Percent Assumed

Automobile Insurance

Health Insurance

Life Insurance

Total

Automatic Belts

(For 70 Percent Assumed

Automobile Insurance

Health Insurance

Life Insurance

Total

Per Vehicle

Annual

Savings ($)

9-17

(3)

4-8

0-1

T0^2T

Usage)

1-2

0-1

0

1^3

Usage)

10-14

5-7

1

T6I22

Per Vehicle

Lifetime

Savings ($)

62-115

(18)

29-54

3-7

76-158

5-14

2-7

0-1

"7^22

65-94

31-44

4-6

100-144

Total

Annual

Savings

1990 Fleet

Equivalent ($M)

1,108-2,046

(312)

521-962

62-136

1,379-2,832

89-243

42-114

7-14

138-371

1,146-1,676

539-788

71-106

1,756-2,^70
Consumer Cost

The following table presents current estimates of the consumer cost of

different automatic restraints (air bags and automatic belts) as well as the

incremental fuel cost over the lifetime of the vehicle resulting from the

additional weight of such restraints.

TABLE 4

PER VEHICLE COST IMPACTS

Automatic Belt

System (2-pt. or

Non-Power, High

Driver and Front

Air Bag -

Driver Only

(High Volume)

Air Bag -

Full Front

(High Volume)

Net Dollar Costs

3-pt.

Volume,

Right)

Incremental

Cost

$40

$220

$320

Lifetime

Energy

Costs

$11

$12

$44

Total

Incremental

Cost

Increase

$51

$232

$364

The results of a lifetime net dollar cost analysis for air bags and automatic

belts are shown in the following table. The analysis considers only the

costs related to motor vehicle ownership; it does not include economic costs

to society, or values for the pain and suffering experienced by the victims

of motor vehicle accidents. Thus, lifetime dollar costs include retail price

increases and fuel cost increases and lifetime dollar benefits include only

insurance premium reductions. The range of lifetime net dollar costs is

$206-$288 per car for air bags at 12.5 percent lap belt usage. For automatic
TABLE 5

SUMMARY OF SAFETY BENEFITS AND NET DOLLAR

COSTS OR BENEFITS FOR AIR BAGS AND AUTOMATIC BELTS

(COSTS ON A PER CAR BASIS)

SAFETY BENEFITS

FATALS

AIS 2-5

INJURIES

INCREMENTAL

LIFETIME

COSTS

LIFETIME LIFETIME

INSURANCE NET DOLLAR

PREMIUM COST OR

REDUCTIONS (BENEFITS)

Full Front Air Bag With Lap Belt

No Usage of Lap Belt 3,780-8,630

12.5% Usage of Lap Belt 4,410-8,960

Driver and Front Right

Air Bag with Lap Belt

(Center Seat Exempt)

No Usage of Lap Belt 3,710-8,490

12.5% Usage of Lap Belt 4,340-8,810

Driver Air Bag

with Lap Belt

73,660-147,560

83,480-152,550

$364

364

72,480-145,408

82,260-150,370

354

354

No Usage of Lap Belt 2,680-6,250 56,330-114,370

14.0% Usage of Lap Belt 3,200-6,520 64,820-118,680

232

232

$66-154

76-158

64-151

74-155

36-100

44-104

$210-298

206-288

203-290

199-280

132-196

128-188

Driver and Right Front

Automatic Belt

(Center Seat Exempt)

20% Usage

70% Usage

Driver Automatic Belt

20% Usage

70% Usage

520-980

5,030-7,510

270-580

3,610-5,440

8,740-15,650

86,860-124,570

5,260-10,370

67,160-96,770

51

51

26

26

7-22

100-144

0-8

65-99

29-44

(49)-(93)

18-26

(39)-(73)

Note: ( ) means dollar benefits (insurance premium reductions) exceed dollar costs.
belts, net dollar costs vary by belt usage rates because the insurance

benefits vary by belt usage rates. At 20 percent usage, lifetime insurance

benefits range between $7-$22 per car resulting in a lifetime net cost per

car of $29-$44, while at 70 percent usage lifetime insurance benefits are

$100-$144 per car, resulting in a net dollar savings of $49-$93 per car.

Breakeven Points

Several breakeven points were calculated throughout the analysis. The

breakeven points indicate where benefits of one alternative equal another, or

where costs equal benefits, etc.

Figure I shows the fatality reduction breakeven points between automatic

belts and air bags for a variety of combinations within the ranges of usage

and effectiveness as they apply to these two restraint systems.

For example, the combination of the high level of effectiveness for automatic

belts (50 percent) and the low effectiveness for air bags (20 percent) result

in a breakeven point at a usage level of 44 percent. That is, with 44

percent automatic belt usage, the safety benefits provided by these two

systems are equal.

Figure 2 shows breakeven points for costs related to automatic belts using

low and high effectiveness estimates. The breakeven point occurs when

lifetime costs (retail price increases and additional fuel costs) equal

lifetime insurance premium reductions. At the high effectiveness level, the
breakeven point occurs at the 32 percent usage level. At the low

effectiveness level, the breakeven point occurs at the 44 percent usage

level.

Air bag systems do not attain similar breakeven points. The estimated

lifetime cost of a full front air bag system is $364, while lifetime

insurance premium reductions range from $76-$158 at 12.5 percent lap belt

usage for low and high estimates of effectiveness respectively. Based on

these estimates, there is no point at which air bag insurance savings would

equal air bag costs. This is true for all air bag configurations—full

front, driver only, and driver and front right seats (center seat exempt).

It should be noted, however, that these are not "societal" breakeven points

as they do not include lost productivity and other costs to society.


11

Benefits of the Final Rule

The Final Rule calls for a gradual introduction of automatic restraints

during model years 1987-89 and a full implementation of the automatic

occupant protection requirement of FMVSS 208 effective September 1, 1989,

unless two-thirds of the U.S. population are covered by mandatory safety belt

use laws. Tables 6 and 7 show the reductions in fatalities and AIS 2-5

injuries, respectively, over the life of cars sold during model years

1987-89. Reductions are shown for two possible scenarios that satisfy the

Final Rule's implementation schedule: under the first scenario automatic

belts would be used in 10, 25 and 40 percent of the fleet, respectively, for

the first, second and third year; under the second scenario air bags would be

used in 6.67, 16.67 and 26.67 percent of the fleet, respectively (the Final

Rule allows an extra credit of 1.5 for each car that provides automatic

protection with a system other than seat belts for the purpose of meeting the

percentage requirements of the Final Rule). These benefits should be added

to those that accrue under full implementation (see Table 2) which begins in

model year 1990.
12

Air Bags Only

Air Bags with Lap Belt

(12.5* Usage)

Air Bags with Lap/

Shoulder Belts

(12.558 Usage)

Automatic Belts

(20% Usage to

70% Usage)

TABLE 6

INCREMENTAL REDUCTION IN FATALITES

OVER THE LIFETIME OF THE MODEL YEAR FLEET

CENTER SEAT EXEMPT

BASED ON LOW-HIGH EFFECTIVENESS ESTIMATES

MY 1987 MY 1988 MY 1989

10% Automatic Belts, 25% Automatic Belts; 40% Automatic Belts;

6.67% Air Bags 16.67% Air Bags 26.67% Air Bags

250-570

290-590

300-600

50-100

500-750

620-1,420

720-1,470

750-1,500

130-250

1,260-1,880

990-2,260

1,160-2,350

1,200-2,390

210-390

2,010-3,000

Air Bags Only

Air Bags with Lap Belt

(12.5% Usage)

Air Bags with Lap/

Shoulder Belts

(12.5% Usage)

Automatic Belts

(20% Usage to

70% Usage)

TABLE 7

INCREMENTAL REDUCTION IN AIS 2-5 INJURIES

OVER THE LIFETIME OF THE MODEL YEAR FLEET

CENTER SEAT EXEMPT

BASED ON LOW-HIGH EFFECTIVENESS ESTIMATES

MY 1987 MY 1988 MY 1989

10% Automatic Belts, 25% Automatic Belts; 40% Automatic Belts;

6.67% Air Bags 16.67% Air Bags 26.67% Air Bags

4,830-9,700

5,490-10,030

5,650-10,200

870-1,570

8,690-12,460

12,080-24,240

13,710-25,070

14,120-25,480

2,190-3,910

21,720-31,140

19,330-38,780

21,940-40,100

22,590-40,770

3,500-6,260

34,740-49,830
13

Table 8 shows the reductions of fatalities and AIS 2-5 injuries that would

occur if states containing a total of 67 percent of the Nation's population

enacted mandatory use laws, without the implementation of the automatic

restraint requirements of Standard 208. Of course, benefits would be higher

if additional states passed mandatory use laws.

USAGE

40%

70%

TABLE 8

ANNUAL SAFETY BENEFITS OF

MANDATORY USE LAWS

AFFECTING 67% OF THE POPULATION

40%

70%

LOW

1,

3,

LOW

31,

67,

(40%)

900

970

(45%)

990

290

INCREMENTAL FATALITY REDUETION

EFFECTIVENESS

MID-POINT (45%)

2,160

4,500

INCREMENTAL AIS 2-5 INJURY REDUCTION

MID-POINT (50%)

35,800

75,310

HIGH (50%)

2,410

5,030

HIGH (55%)

39,680

83,460
1-1

I. INTRODUCTION

This Final Regulatory Impact Analysis (FRIA) represents the Department of

Transportation's assessment of the benefits and costs of various

alternative approaches to automatic occupant protection. It addresses

issues that were raised in the PRIA and the subsequent rulemaking hearings

and docket comments.

In October 1983, the Department published a Notice of Proposed Rulemaking

(NPRM) as part of the further review of the occupant crash protection

standard required by the Supreme Court decision. Accordingly, the agency

outlined a range of regulatory actions (amend, retain, or rescind FMVSS

208) and potential alternative proposals if the decision was to amend the

current standard; e.g. air bags only, air bags or non-detachable automatic

belts, etc. The NPRM sought public response on 91 specific questions on

various aspects of the occupant protection issue.1 In addition, it called

for three public meetings to gather nationwide response to the issues and

questions raised in the NPRM. These public meetings were held in Los

Angeles, California, on November 28-29, 1983, in Kansas City, Kansas on

December 1-2, and in Washington, D.C. on December 5, 6, and 7. The public

docket for this NPRM (Docket No. 74-14, Notice 32) formally closed on

December 19, 1983, but the Department accepted comments received after that

date and considered more than 7,800 docket comments.

For the reader interested in the specific questions outlined in the NPRM,

see 48 FR 48622-41.
1-2

Subsequently, the Department issued a Supplemental Notice of Proposed

Rulemaking (SNPRM) on May 10, 1984, seeking additional comment on several

issues and proposing four other alternatives. Over 130 comments were

received. All timely comments have been considered in preparing this FRIA.

After a brief review of the background of FMVSS 208, the FRIA outlines the

significant issues raised by the Supreme Court in its June 1983 decision

-an all air bag requirement and usage of non-detachable automatic safety

belts, as well as other issues resulting from agency analyses and docket

comments. The following sections contain the main body of the analysis,

including estimates of effectiveness, usage rates, safety benefits,

insurance premium changes, cost and leadtime of the various restraint

systems, impacts of increased costs on vehicle manufacturers, and possible

small business impacts. Also included is an analysis of recent major

public opinion surveys. Each of the alternatives considered in this

analysis — amend, retain, rescind the standard, as well as demonstration

programs and mandatory seat belt use laws — is discussed in the

alternatives section of the analysis.

The Conclusions section draws all the information within the FRIA and its

referenced material into a concise statement. The Conclusions section

reflects the intense review conducted on a subject that has been

controversial for over a decade and highlights the significant findings of

the FRIA. Additional material relevant to the analysis has been included

in appropriate Appendices.
II. BACKGROUND

FMVSS 208 was one of the initial standards of the agency, issued in 1967 as

a standard for seat belt installation in passenger cars. Since that time,

there have been a number of actions relative to automatic occupant

restraints. From 1970 (rule establishing automatic restraint

systems for passenger cars) to 1983 (temporary suspension of the 1977

automatic restraint requirements) issuance of an automatic occupant

protection rule has been debated, proposed, revised, promulgated, and

rescinded. Alternatives such as starter interlock options were proposed

(1971), established (1972), and eventually overturned by congressional

legislation (1974). Test criteria and demonstration programs were

established and changed (1971 and 1977). The courts were also involved in

the process, rendering decisions in 1972, 1979, and 1982. (These events

are summarized in Table II-1 of the October 1983 Preliminary Regulatory

Impact Analysis. They are also described in detail in the October 1981

Final Regulatory Impact Analysis concerning the rescission of the automatic

occupant protection requirements of the standard.) The most recent actions

concerning FMVSS 208 follow-
II-2

In January 1977, Secretary William Coleman negotiated agreements which

would have resulted in an air bag and passive seat belt demonstration

program, the purpose of which was to show the effectiveness of these

devices, and thereby counter possible public resistance to this new

technology and familiarize the public with the overall benefits of occupant

restraints.

Ford, General Motors, Mercedes-Benz, and Volkswagen agreed to participate

in the voluntary program. Ford agreed to manufacture 140,000 air bag

equipped cars, GM 300,000, and Mercedes 900 driver only air bag cars. VW

agreed to manufacture no fewer than 125,000 cars equipped with a passive

belt system in both front seating positions between model years 1975 and

1980, with at least 60,000 of these cars manufactured between model years

1978 and 1980. The anticipated incremental consumer price to be negotiated

was $100 for full front air bags and $50 for a driver only air bag.

In addition to the agreements by the automobile manufacturers, three

insurance companies (Allstate, Nationwide, and Volkswagen Insurance

Company) agreed to provide 30 percent discounts on medical coverage premiums

for those consumers purchasing passive restraint cars.

The demonstration program was subsequently voided and abandoned by the

manufacturers in June 1977, when, as a result of a reassessment of

Secretary Coleman's decision, his successor, Secretary Brock Adams, issued

a rule requiring automatic restraints in all front seating positions on a

phased-in schedule depending on vehicle size: large cars to small cars

with all cars having to comply in Model Year 1984.
II-3

Although the 1977 demonstration program contained a provision which

released the automobile companies from their responsibilities if automatic

restraints were to be mandated, the manufacturers were asked by

Secretary Adams to continue their voluntary agreements to produce

automobiles with automatic crash protection in Model Year 1980. Volkswagen

continued to offer automatic belts in the U.S. and does so to this date. GM

offered two-point automatic belts in Model Years 1978 and 1979 and

three-point automatic belts in Model Year 1980 on all Chevettes. A small

number of Cadillacs were offered with three-point detachable automatic

belts and, over the last few years, Toyota Cressidas have come' equipped

with a motorized automatic belt. In Europe, approximately 25,000 Mercedes

Benz cars have been sold with a supplemental (i.e., in addition to the

three-point manual belt) driver side air bag coupled with a pyrotechnic

pre-tensioning reel for the right front passenger 3-point belt, which in

the case of the S-class cars sold in Germany, represents 17 percent of

sales (9.6 percent worldwide.)1 Mercedes Benz began to offer such a system

in the U.S. on certain 1984 models. No other manufacturer has offered air

bags to the U.S. public since GM discontinued the air bag as an option on

some cars in 1976.

In February 1981, the Department issued an NPRM which proposed a 1-year

postponement of the effective date of the automatic restraint requirement.

This permitted further study of that requirement in light of changed

circumstances since the standard's promulgation, such as the decision by

virtually all major manufacturers to elect to use automatic belts rather

1 Daimler-Benz Docket Comment No. 74-14-N32-5886, p. 3.
II-A

than air bags as the means of compliance and the dramatic shift in the

market toward small cars resulting from changes in fuel price and

availability. In April 1981, the agency issued a final rule delaying from

September 1, 1981 to September 1, 1982, the date on which large cars had to

begin complying with the requirement, and also issued an NPRM setting forth

three alternative amendments to the automatic restraint requirement: (1)

reversal of the phase-in sequence to require compliance by small cars

first; (2) simultaneous compliance by all cars; (3) rescission of the

requirement; and in addition, a sub-alternative proposed the deletion of

the requirement for automatic restraints in the front center seating

position for the first two alternatives.

On October 23, 1981, the agency issued a final rule rescinding the

provisions which would have required front seating positions in all new

cars to be equipped with automatic restraints.

The rationale for this decision was based on the belief that compliance

would be by detachable automatic belt, that such belts might only result in

a marginal increase in belt usage and resultant safety benefits, that the

compliance costs associated with the standard were high, and that the

public might have an adverse reaction to these belts, which could have an

adverse effect on overall motor vehicle safety efforts.

In June 1983, the Supreme Court held that the agency's rescission of the

automatic restraint requirement was arbitrary and capricious, that the

agency had failed to present an adequate basis and explanation for
II-5

rescinding the requirement, and that the agency must either consider the

matter further or adhere to or amend the standard along the lines which its

analysis supports.

The Supreme Court remanded the case to the Court of Appeals with

directions to remand the matter to the Department for further consideration

consistent with the Supreme Court's opinion.

On August 31, 1983, the Department issued an interim final rule which

suspended the passive restraint requirement while it re-examined the issue

as required by the court. The 1-year suspension was issued to preclude

any possibility that manufacturers might be in technical violation of a

requirement that, as a practical matter, could not be met.

In October 1983, the Department published an NPRM and a Preliminary

Regulatory Impact Analysis. The analysis presented the Department's

assessment of the benefits and costs of various approaches to automatic

occupant protection and examined the overall safety and economic effects of

these approaches. The NPRM invited comment on the proposed automatic

protection requirements. Comments were received in the docket from a wide

variety of individuals and organizations, ranging from automobile

manufacturers and insurance companies to private citizens. More than 7,800

comments have been received to date.

Public meetings were held in Los Angeles, Kansas City, and Washington, D.C.

during the period November 28 to December 7, 1983. More than 155

individuals presented testimony. The testimony in these meetings and the
II-6

comments to the docket raised complex issues or led to the identification

of other alternatives that were not specifically addressed in the NPRM.

For these reasons, the Department issued a Supplemental Notice of Proposed

Rulemaking (SNPRM) on May 10, 1984. The Notice solicited comments on the

above issues and proposed four additional alternatives. More than 130

comments were received, primarily from automobile manufacturers, the

insurance industry, public interest groups, and several states.
III. ISSUES

This section examines several issues raised in testimony at the public

hearings and in comments to the docket. A number of these concern air

bags, including the applicability of air bags to small cars, the use of

sodium azide, product liability concerns associated with air bag use and

repair, and the introduction of new technology which could lower the cost

of air bags. Other issues discussed include the potential use of passive

interiors to provide automatic occupant protection and test procedures

repeatability.

A. Air Bag Issues

1. Provision for Air Bags in Small Cars

Air bags have been designed and installed in 12,000 production vehicles in

the early and middle 1970's. Mercedes-Benz has sold more than 20,000 air

bag equipped vehicles in Europe over the past two years and plans to sell

5,000 in the U. S. this year. However, these vehicles were all large and

intermediate sized cars. Small cars present particular problems in the

near term for designers of air bag systems. In the most general terms, the

smaller the car, the shorter the "crush distance" and the greater the

collision severity. For smaller cars, the time available for crash sensing

and bag inflation is shorter. This necessitates an air bag system that

uses greater force and inflation speed to produce adequate and timely

occupant protection.
III-2

Several issues have been raised concerning air bag use in small cars. The

issues fall into two basic categories—technical feasibility and

out-of-position occupants. Specifically, is it technically feasible to

design small car air bags? If it is feasible, what are the cost and

leadtime implications? Are there significant differences due to car size

in driver versus passenger systems? Do air bags cause injuries to out of

position occupants, especially children?

a. Technical Feasibility

While most of the real world air bag experience has involved large and

intermediate sized cars, laboratory tests on small cars indicate that air

bags are technically feasible of being applied to small cars. Ford, in a

response to Representative Dingell's questions on air bags in small cars

(Docket response 74-14-N32-3115) stated that air bag technology is safe for

use as a supplement to manual three-point belt systems for drivers in all

sizes of cars. The Motor Vehicle Manufacturers Association's (MVMA)

technical report on air bag use in small cars provided a summary of frontal

barrier crash test results with air bags installed in small cars.'' Those

test results (see Table III-1A) indicate that driver and front passenger

occupant protection as defined by FMVSS 208 is possible with air bags in

small cars based on laboratory experiments. The report concludes that "the

use of air bags in small cars shows promise in providing occupant

"Air Bag Use in Small Cars-Literature Review", Technical Report by David 3.

Segal, November 1983. Prepared for Motor Vehicle Manufacturers Association

by MGA Research Corporation, Buffalo, N.Y., p.27. (Docket 74-14-N32-1674).
III-3

Table III-1A

SUMMARY OF "SMALL" CAR AIRBAG CRASH TEST RESULTS

Vehicle

Pinto

Pinto

Pinto

Pinto

Pinto

Pinto

Chevette

Chevette

Omni

Omni

Vega

Honda Accord

Datsun 260Z

Datsun 260Z

Citation

Citation

DeLorean

DeLorean

Volvo

Volvo

Blbliography

l+em

1

1

1

1

81

82

65

66

66

66

65

53

76

76

67

67

35

35

69

69

Seat

Position*

D

P

D

P

D

P*#

D

P

D

P

D

D

D

P

D

P

D

P

D

P

Crash Speed

(MPH)

34.9

34.9

30

30

31.2

31.2

30

30

30

30

31.9

35

30

30

36.9

36.9

40.6

40.6

40.0

40.3

HIC

474

702

320-510

277-357

617

278

443

189

279

492

353

264-859

424-558

284-540

398

554

336

684

440

204

Chest G

61

53

49-68

46-65

43

44

50

27

42

45

45

47-59

44-52

33-44

40

44

46

53

58

50

Femur

Loads-LBS

2060

1590

570-2000

810-1560

1039-1343

1550

600

1300

700

1520

1416-1854

568r870

356-687

1760

1150

1220

2110

2100

1580

* D - Driver, P - Passenger

**95th Male durrmy
111-4

protection levels consistent with FMVSS 208." However, it was pointed out

that more developmental work was necessary prior to mass production. Thus,

the issue appears to be one of leadtime rather than technical feasibility.

The agency has also previously looked at the small car-air bag situation.

Agency data from a computer simulated crash test of a typical small car

showing the movement of the 5th, 50th and 95th percentile dummies and air

bag over time in a 30 mph crash are shown in Table III—1. These data show

that the bag is fully inflated before the dummy has any substantial

movement in a vehicle substantially smaller than the 1974 model GM

vehicles equipped with air bags. Before the dummy has moved, the sensor

has detected the crash and initiated bag deployment. The bag begins to

inflate at about 14ms2 and it is at 10ms that the dummy's H point3

begins to move from the rest position at the back of the seat. H point

movement is still less than 1 inch after 30ms, and by 35ms the bag is fully

inflated. By 40ms, the dummy movement is just over 2 inches. The dummy's

first contact area is the femur, which contacts the small car dash at 50ms

for all dummy sizes. H-point movement at this time is nearly 5 inches.

Maximum H-point movement of around 8 to 10 inches occurs in the range of

70-80ms.

2 ms=milliseconds.

-* H point means the mechanically hinged hip point of a manikin which

simulates the actual point center of the human torso and thigh, described

in SAE Recommended Practice 3826, Manikins for Use in Defining Vehicle

Seating Accomodation," November, 1962.
III-5

TABLE III-1

DUMMY MOVEMENT AND AIR BAG INFLATION

IN 30 MPH CRASH

Time From Onset

of Initial Crash

(MS)

0

10

20

30

35

40

45

50

60

70

75

80

H-Point Movement

5th Percentile

Dummy

(in.)

0

.01

.17

.81

2.29

4.08****

6.99

7.88 (Max)

H-Point Movement

50th Percentile

Dummy

(in.)

0

.01

.17

.81

2.29

4.72****

7.32

8.95

9.21 (Max)

H-Point Movement

95th Percentile Bag

Dummy Movement

(in.)

0 *

.01 **

.17

.81

**#

2.29

4.83****

7.79

10.04

10.90 (Max)

* Sensor detects impact

** Bag starts to inflate (14 ms)

***Bag fully inflated (35 ms)

•*•*•** (femurs hit)

Note: Data taken from simulated crash test of a typical small car.

NHTSA has also evaluated the performance of current air bag systems and

conducted lab tests to demonstrate that air bags could meet FMV5S 208

requirements at speeds up to 40 mph in small cars. Vehicles in which air

bags have been evaluated include the Chevrolet Chevette, Dodge Omni,

Chevrolet Citation, Volvo 244, and the Delorean. Each of these vehicles is

smaller than the previous and current production vehicles which were

equipped with air bags.
III-6

The results^ of the NHTSA sled tests and bar ier crash tests of the above

vehicles lead to the conclusion that there is no technical reason why air

bags meeting the injury prevention criteria of FMVSS 208 cannot be used in

small cars. In addition, NHTSA has developed research safety vehicles

which have provided occupant protection below the FMVSS 208 criteria at

speeds up to 50 mph. For example, the Minicars RSV is a small car which

has demonstrated this level of performance.

However, the agency recognizes that a manufaturer's concerns extend far

beyond the test requirements of a Federal Motor Vehicle Safety Standard.

Manufacturers need be concerned about air bag performance in other

situations, such as in pole crashes,.and with out-of-position occupants, as

discussed in the next section. Thus, developmental work, to fine-tune

sthe air bag system to account for the above type situations in specific

vehicles, still needs to be done. Since little work has been done by

manufacturers in developing and producing air bags for small cars, the

development time must necessarily be longer than for large cars.

DOT-HS-805-943 "Small Car Front Seat Passenger Inflatable Restraint

Systems," April 1981.

DOT-HS-805-944 "Small Car Front Seat Pusssnger Inflatable Restraint

Systems, Volume II-Citation Air Bag System," April 1981.

DOT-HS-805-960 "Upgrade Volvo Production Restraint Systems,"

April 1981.

DOT-HS-806-312 "Systems Analysis Approach to Integrating Air Bags into a

Production Ready Small Car," November 1981.
III-7

In summary, based on a review of the docket comments, manufacturers' tests,

and agency evaluations of small car air bag installation, it is believed

that there is no technical reason why air bags cannot be installed in any

car, regardless of the size although all manufacturers who commented on the

small car issue stated that technical issues remain. GM, in comments to

the NPRM, also stated that challenges remain in developing air bags for

small cars and that additional leadtime is required for such development.

However, GM concluded by saying that "It should not be inferred . . . that

General Motors does not believe that air bag technology can be developed

for small cars. "The agency has determined that additional leadtime is

required to field test and final design air bag systems for current and •

future small production vehicles. It is expected that up to 5 years may be

needed to design and gain experience with small car air bags.-*

b. Dut-of-Position Occupant

While it appears technically feasible to install air bags in small cars,

the issue of occupant interaction with the air bag system in small cars

merits review. GM, in particular, has addressed the two fold problem ofdesigning air bags for small cars to 1) meet the FMVSS 208 30 mph criteria,

and 2) at the same time avoid potential hazards from air bag induced injury

to out-of-position occupants.^

5 Docket Comment 74-14-N32-5299, AMC, P.4-5; Docket Comment 74-14-N32-1666,

GM, Appendix A, p.7; and others.

6 Docket comment 74-14-N32-1666, Appendix D, p.2.
III-8

The problem described by the manufacturers is that small cars have less

available front end crush space and less occupant spacing from injury

producing sources in the passenger compartment (such as the steering

column, instrument panel or A pillar) than larger cars. In effect, this

reduces the permissible time to sense and inflate the air bag to safely

cushion the occupant. The small car air bag must therefore inflate quicker

and utilize a thicker bag to withstand the greater inflation pressures. The

effect of the necessarily more "aggressive" small car air bags on out of

position occupants, particularly passengers, continues to pose a problem

for vehicle manufacturers. (Drivers tend to have about the same amount of

space behind the steering column independent of car size).

Most danger to out of position occupants occurs when they are located near

the instrument panel at the time of bag inflation and, therefore, contact

the bag when it is rapidly expanding. The agency has analyzed the effect

of air bag systems on various ages and sizes of occupants, with a

particular emphasis on the small child.? The result of that analysis

indicates children would only be at the instrument panel relatively

infrequently at the time of air bag deployment. Further, the fact that

these small children are near the instrument panel does not necessarily

mean that they would be injured. In order to be injured by a deploying air

bag the child would likely not only have to be near the instrument panel

but would have to be struck in such a manner as to produce injury or be

thrown into another component of the vehicle interior which would produce

"Protection of Children and Adults in Crashes with Automatic

Restraints," Ralph Hitchcock and Carl Nash, NHTSA, October 1980, presented

at the Eighth International Technical Conference on Experimental Safety

Vehicles, Wolfsburg, Germany, p. 317-325.
III-9

injury. Another point to be considered is whether the child would have been

injured in the absence of an air bag. Nevertheless, a small number of

children could in fact be at greater risk from the air bag induced trauma

than that from the effects of the crash itself.

A large part of the research and development effort on air bags through the

years has focused on designing an air bag system that has location, size,

and deployment characteristics (e.g., pressure, time, etc.) such that

vehicle occupants are protected in as high a crash speed as possible

without creating an unreasonable risk to an occupant who is out-of-position

(i.e., near the stored bag at the time of deployment). The automobile

industry, the research community, and NHTSA have done a tremendous amount

of work over the years in trying to assess the air bag's potential for

injury to out-of-position occupants, and to assess the probability of those

injuries occurring in the real world.8 9

At this time, air bag technology could be likened to a drug with great

potential lifesaving and injury reducing capability, but with some limited

adverse side effects for some ( out-of-position children). In the past

few years child restraint legislation has been enacted in nearly all of the

states. This has the effect of reducing the probability that a child would

be out-of-position to levels below that used in previous studies.

8 GM comments to 74-14-N32-1666.

Hitchcock/Nash Paper referenced in footnote 7.
111-10

Nontheless, any air bag design should attempt to minimize the probability

of a child being injured, regardless of position, while maintaining the

large potential lifesaving benefits for children and other occupants.

In summary , the agency concludes that although air bags, on isolated

occasions, may cause injuries that may not have otherwise occurred, their

overall safety benefits far outweigh this chance occurrence. Air bags are

no different from other safety devices in this regard.

c. Cost of Dut-of-Position Technical Features

In many of the NHTSA studies, concepts have been evaluated that address the

concern over out-of-position occupants. One method of addressing the

out-of position occupant problem is the use of a dual level inflation

system. The dual level system has two inflators; the main inflator is

fired at any speed above the threshold of 12 mph; the booster inflator only

at speeds above 30 mph. Another possibility is to sense an out-of-position

occupant with a switch in the seat or elsewhere that measures occupant size

or weight. If the seat is unoccupied or a child is out of position, then

the low level system will fire; if the seat is occupied, then the high

level system will actuate. It has been estimated that a seat switch would

add less than $10 to the total cost of an air bag system. Similarly, a

simple electronic device in the instrument panel can sense if an occupant

is close and deploy the low inflation mode, etc. Further, many other

techniques are available to address this problem such as bag shape and

size, instrument panel contour, aspiration, inflation technique, etc.
111-11

d. Summary and Conclusions

It is technically feasible to produce small car air bag systems, however,

these systems will require additional lead time to design and test to

assure a reduction in the potential for injury to out-of-position children.

The agency has already proposed several designs that appear to reduce the

out-of-position occupant problem. These techniques, if adopted, will

require 2 to 5 years leadtime to bring to production feasibility
111-12

and will result in some increase in air bag costs. The out-of-position

child problem would affect a small number that should become smaller as the

usage rates of child restraints continues to climb.

2. Sodium Azide - The Air Bag Solid Propellant

One of the main ingredients of the solid propellant used in the gas

generators of air bag systems is a compound primarily based on the

inorganic chemical sodium azide, NaN3. Sodium azide in its natural state

is a poisonous, colorless crystal, soluble in water and liquid ammonia,

which decomposes at 300 degrees centigrade. It is used in the

pharmaceutical industry, in herbicides and wood preservatives, and in

the intermediate manufacture of lead azide for the explosives industry.

The use of sodium azide as a solid propellant gas generant must not be

confused with its explosive applications. In the air bag system,

sodium azide, as a solid propellant hermetically sealed inside a steel or

aluminum cartridge, is ignited by the pressure and high temperature created

by the igniter charge. What occurs then is not an explosion, but a

programmed expansion of a predetermined amount of generated gases. Instead

of exploding, the pelletized solid propellant begins a relatively slow

(approximately 50 ms) burning process, generating non-toxic nitrogen gas

which in turn inflates the air bag. These characteristics are what makes

sodium azide ideally suited as an air bag gas generant.
111-13

a. Background

Since the Environmental Impact Statement for FMVSS No. 208 was issued in

1977, a number of questions have been raised regarding the use of sodium

azide based gas generants in air bag systems. The issues of concern which

relate to the toxicity, including carcinogenicity, flammability and

disposition of the gas generants have been investigated by both the

industry and Federal government agencies. The primary industry

investigators include Ford, General Motors (GM), the Motor Vehicle

Manufacturers Association (MVMA), Pittsburgh Plate Glass Industries, Inc.

(PPG), Thiokol, Battelle, Arthur D. Little, Automobile Dismantlers and

Recyclers of America (ADRA), and the Institute of Scrap Iron and Steel

(ISIS). Government agencies include the National Highway Traffic Safety

Administration (NHTSA), the Environmental Protection Agency (EPA), the

Occupantional Safety & Health Administration (OSHA) and the National

Institute of Health (NIH). The investigations have resulted in the
111-14

resolution of most of the initial concerns.'"-' However, some issues

related to the final disposal of non-deployed air bags remain to be

resolved.

'Q For a better understanding of the issues, investigations, research, and

conclusions reached by the various industries and government agencies, the

reader is referred to the following sources of information:

a. Talley Industries of Arizona, Inc., "The Facts About the Use of Sodium

Azide in Air Bag Inflators,: Sept. 1977.

b. Buckheit, B. and Fan, W., "Sodium Azide in Automotive Air Bags," NHTSA

report, draft March 1978, update Feb. 1981, by Milleron, M. and Stucki,

S.L.

c. Thiokol, "Sodium Azide Investigation Program — Ford Motor Company,"

P.O. No. 47-2-594035-GM, May 1978.

d. Battelle Columbus Laboratories, "Gas Generants Research," report to

MVMA, Nov. 1978.

e. Arthur D. Little, Inc., "An Investigation of the Potential Human and

Environment Impacts Associated with Motor Vehicle Air Bag Restraint

Systems," report to MVMA, Dec. 1978.

f. Buckheit, B. and Fan, W., "Sodium Aizde — The Federal Responsibility,"

SAE paper, June 1979.

g. Gratch, S. and McConnell, C. C , "The MVMA Gas Generants

Investigation," SAE paper, June 1979.

h. Herridge, 0. T., "Selected Aspects of Gas Generants Research," SAE

paper, 3une 1979.

i. Partridge. L. H. and Young, S., "An Investigation of the Potential

Human Environment Impact Associated with Motor Vehicle Air Bag Restraint

Systems," SAE paper, Oune 1979.

j. Arthur D. Little, Inc., "Identification of Approaches for the Control

of Health, Environmental, and Safety Hazards Associated with Air Bag Use

and Disposal," August 1979, DOT HS-805-184.
111-15

b. Toxicity

Sodium azide is classified as a Class B poison by the Materials Transportation Bureau under Title 49, CFR, Parts 100-199. The chemical is a

broad-spectrum, metabolic poison that interferes with oxidation enzymes and

inhibits nuclear phosphorylation. Phosphorylation is the process by which

chemical compounds are converted to phosphates. Although the effects of

these systems are complex, there is general agreement that the major effect

of exposure to this chemical is a profound reduction in blood pressure. An

oral dose of 0.014 mg/kg has a rapid hypotensive effect (i.e., it lowers

blood pressure) that persists for 10 to 15 minutes. When this dose was

administered to a group of patients with high blood pressure for a period

of up to two years, it produced a substantial lowering of blood pressure to

normal levels, without a noticeable side effect.^

The toxicity of sodium azide has long been a controversial issue. In the

recent Public Hearings on FMVSS No. 208, a number of commentors raised the

toxicity argument. A brief discussion on the subject follows.

c. Acute Exposure

Data on humans are limited and are mainly from accident records.

Considerable information is available on acute toxicity of sodium azide in

animals. According to the Registry of Toxic Effects of Chemical Substance

^1 Dodge, C. H., "The Toxicity of Sodium Azide," Congressional Research

Service, unpublished report, 1977.
111-16

(RTECS) published by NIOSH, the oral TDLo for sodium azide is 0.71

The definition for TDLo is the lowest dose of substance introduced by any

route, other than inhalation, over any period of time and reported to

produce any toxic effect in humans. According to the Registry, it takes at

least 70 mg of sodium azide for a 220 pound person, by oral administration,

to produce any serious toxic effect. However, when a researcher accidently

swallowed a 5 to 10 mg sodium azide tablet, it resulted in a substantial

lowering of blood pressure for 15 minutes, violent heart stimulation for 5

minutes, loss of consciousness for 10 minutes, followed by rapid recovery.^

In another instance, a woman accidently drank 1.5 cc of 10 percent sodium

azide solution (150 mg). This 150 mg dose is three times the TDLo for an

average adult. In five minutes, she experienced nausea, diarrhea, violent

headache and other symptoms. Ten days later, she continued to feel weak

and dizzy.^

Based on the incidents cited above, the agency believes that toxic symptoms

can be expected for an oral dose lower than that noted in the Registry. The

agency believes such symptoms will occur at doses greater than 0.05 mg/kg

(3 mg for an average person).

The lethal dose of sodium azide has not been established officially for

humans. Based on actual experience, at least one person has survived a one

time dose of up to 150 mg. This figure is probably the maximum non-lethal

12 NIOSH, "Registry of Toxic Effects of Chemical Substances," Volume 3,

1981 — 1982 issue.

'* Buckheit, B., and Fan, W., "Sodium Azide in Automotive Air Bags," NHTSA

report, draft March 1978, update Feb. 1981, by Milleron, M., and Stucki,

S.L.

'4 Canadian Industries Limited, "Toxicity of Azides," report prepared for

companies using sodium azide in lumber industry, unpublished.
111-17

dose that has been recorded. Based on the available information, the low

lethal dose for an adult human is estimated to be 5 mg/kg.^ This implies

that sodium azide is probably not as toxic as some substances found in

common household materials, such as nicotine concentrate for use in

insecticides.

d. Long Term Exposure

Long term effects of sodium azide are not nearly as well known. However,

very mild toxic symptoms first appear when repeated exposure is in the

range of 0.01 mg/kg, and it appears that it would be desirable to limit

long term exposure to levels substantially less than 0.01 mg/kg. In acid

solution, sodium azide will hydrolyze to form hydrazoic acid which will

vaporize into air. Therefore, the hydrazoic acid concentration in air is

another problem of concern in the chemical or inflation manufacturing

facility or vehicle shredding facility. It is noted that RTECS recommends

a TCLo level of 0.3 ppm.16 The definition for TCLo is the lowest

concentration of a substance in air which, having been exposed for any

given period of time, has introduced any toxic effect in humans. Although

there is no specific TCLo for sodium azide, this 0.3 ppm limit appears

appropriate for sodium azide dust concentration in air. Canadian Industries

Limited, a large manufacturer of sodium azide, suggests a soduim azide

concentration below 0.1 ppm for persons who perform heavy work because

15 "An Investigation of the Potential Human and Environmental Impacts

Associated with Motor Vehicle Air Bag Restraint Systems," prepared by

Arthur D. Little, Inc., for the MVMA, Dec. 1978, p.4-11, and Table 4-1.

16 NIOSH, "Registry of Toxic Effects of Chemical Substances," Volume 3, 1981

1982 issue.
Ill-IB

those people breathe three times more air than an ordinary person.17

Although OSHA does not have specific standards or requirements for sodium

azide, the American Conference of Governmental Industrial Hygienists^

has published a Threshold Limit Value (TLV) of 0.1 ppm. The TLV refers to

airborne concentrations of substances and represents conditions to which

nearly all workers may repeatedly be exposed day after day without adverse

effect.

The gas generant used in air bag inflators is pressed into various pellet

forms. Typically, a driver bag requires approximately 0.2 pounds (0.09kg)

of pellets, while a passenger bag needs two to four times that amount

depending upon the size of the vehicle.

Since the gas generant is hermetically sealed, the potential for motorists

being exposed to a critical dose of sodium azide is remote. It has been

noted that extremely low dosage exposure would be expected if the hermetic

seal failed. However, there does not appear to be a real concern on the

basis of the toxicity level because the results of the air bag effluent

analysis (see footnotes 10b and 10c) indicate that, with the advanced

filtering techniques, the concentration of sodium azide can be controlled

below the 0.1 ppm level.

Canadian Industries Limited, "Toxicity of Azides", report prepared for

companies using sodium azide in lumber industry, unpublished.

ACGIH, "Threshold Limit Values for Chemical Substances and Physical Agents

in the Workroom Environment with Intended Changes for 1979."
111-19

Sodium azide is known to be a potent mutagen in a number of plant species

and bacteria. However, the mutagenic effects on animal species and

cellular cultures are considerably less."19 20 21 22 23 24 25 M 0

mutagenic effects have been detected in tests of sodium azide and hydrogen

azide on cultures of human cells. Since the vast majority of mutagens are

carcinogens, of particular concern is the suggestion that sodium azide may

be carcinogenic. In the past, several studies on carcinogenicity of sodium

azide in vivo were conducted. In each study, the results were negative or

at least inconclusive.26 27 The most recent investigation at NIH by

Dr. Weisburger, shows that there is no indication that sodium azide is a

potent carcinogen.28 Dr. Weisburger's belief is that it is doubtful that .

the chemical is carcinogenic at all in vivo because sodium azide is

19 Owais, W. M., Kleinhofs, A. and Nilan, R. A., "Effects of L-Cysteine and

0-Acetyl-L-5erine in the Synthesis and Mutagenicity of Azide metabolite,"

Mutation Research, 1980.

2 0 Kleinhofs, A., Owais, W. M. and Nilan, R. A., "Azide Mutation

Research, 55, 165-195, 1978.

21 Nilan, R. A., Klienhofs, A. and Konzak, R. A., "Nature and Mechanism of

Induction of Mutations," Annual Progress Report, Department of Energy,

DOE/EV/72002-5, October 1, 1981.

22 De Flora, A. and Boido, V., "Effect of Human Gastric Juice on the

Mutagenicity of Chemicals," Mutation Res., 77, 307-315, 1980.

2:5 Kamura, 0. P.1 and Gollapudi, B., "Mutagenic Effects of Sodium Azide in

Drosophila Melanogaster," Mutation Res., 66, 381-384, 1979.

2^ Kleinhofs, A. et al," "Induction and Selection of Specific Gene Mutations

in Hordeum and Pisum," Mutation Research, 51, 29-53, 1978.

2^ Jones, 3. A. et al, "Toxicity and Mutagenicity of Sodium Azide in Mammalian

Cell Cultures," Mutation Research, 77, 293-299, 1980.

26 See footnote 10b for discussion of Carcinogenicity of sodium azide.

27 See the "Final Report on Gas Generants Research," by Battelle, Columbus

Laboratory, for the MVMA, November 30, 1978, p 1-41, for discussion of

Carcinogenicity of sodium azide.

2f3 Weisburger, E. K., et al, "Carcinogenicity Tests of Certain Environmental

and Industrial Chemicals," NCI, Vol. 67, No. 1, July 1981.
111-20

rapidly inactivated by the liver. This agrees with the results of

Professor Nilan's work that sodium azide is weakly mutagenic and is not

carcinogenic in mammalian systems due to the absence of metabolites in

humans.

e. Flammability

Sodium azide is technically not an explosive since it will not detonate. It

is a low energy pyrotechnic propellant possessing only one third the energy

of rifle powder and 1/30 that of gasoline. Moreover, sodium azide produces

nearly pure nitrogen gas (which is inert) when burned. The gas generant,

when properly formulated and hermetically sealed in air bag inflators, is

safe and stable.

The gas generants to be used in air bag inflators consist mainly of sodium

azide and oxidizers. Other chemicals are used as binders, coolants and

stabilizers. This chemical mixture is not explosive and cannot be

detonated even by a blasting cap. Therefore, the air bag inflators cannot

produce highly explosive results because the burning rate is controlled and

the sodium azide based gas generant has a low energy content. Therefore,

it is not likely that vandals and terrorists would choose the sodium azide

based gas generant as a weapon because powerful gun powder is available in

sporting goods stores. In addition, a simple Molotov cocktail made of a

bottle of gasoline and a rag is a much more powerful bomb.
111-21

Possible abuses of air bag inflators were investigated by both Thiokol

and Battelle. The air bag inflator units have been tested for resistance

to shock by dropping them from a height of 12 feet and 40 feet onto a

steel plate and by impacting them with a bullet fired from a 30.06 rifle.

While the drop had no effect at all, the shock of the bullet was sufficient

to ignite the gas generant. In addition to these tests, the inflator units

were subjected to bonfire tests. The units would not ignite until the

temperature exceeded 700 degrees Fahrenheit. The units were also subjected

to drill and saw tests. The units would not ignite when the tests were

conducted at ambient temperature. In the tests at 212 degrees Fahrenheit,

one of the passenger units ignited when the saw cut into the squib

initiator (i.e., firing mechanism). During product development, an

inflator was placed in a burning bed of sawdust soaked with diesel fuel.

Ignition occurred after 11 minutes but no explosion occurred and the unit

did not fragment. The inflators are designed to produce a non-directional

thrust and remain intact when the gas generant burns.29 Therefore, the

air bag inflators are classified by DOT for transport purposes as a Class-C

explosive which makes them equivalent to such items as highway flares.

In acidic water, sodium azide will hydrolyze to form hydrazoic acid. Many

people think that hydrazoic acid, like hydrogen azide, is very unstable and

highly explosive. It must be pointed out that although both hydrogen azide

and hydrazoic acid have the same chemical formula-HN3, they have different

29 See the following three reports for a description of shock and burn tests:

Thiokol/Wasatch Division, "Sodium Azide Investigation Program — Ford Motor

Company — P.O. No. 47-2-594035 — GM, "Final Report, Publication No. 7844,

May 26, 1978, and Battelle Columbus Laboratory, "Final Report on Gas

Generants Research," prepared for the Motor Vehicle Manufacturers

Association of the U.S., Inc., November 30, 1978, 2 vols.
111-22

properties. Hydrogen azide is very unstable and highly explosive. When

this chemical dissolves in water, the aqueous solution is hydrazoic acid.

Hydrazoic acid is quite safe in dilute solution, but it may become

explosive in aqueous solution in concentrations from about 17-50% and

above. However, it requires more than two pounds of sodium azide per gallon

of water to make a 17 percent hydrazoic acid solution. Therefore,

hydrazoic acid, formed from sodium azide under the expected condition, is

not explosive.

f. Disposal of Sodium Azide

The use of the sodium azide based gas generant in air bag inflators has

aroused many controversial arguments over the final disposal phase. In

1978, the automotive industry sponsored three studies (Ford-Thiokol,

MVMA-Battelle and Arthur D. Little, Inc.) to investigate these

problems.30 NHTSA reviewed these studies and with the help of comments

from the public, industry and other Federal agencies, concluded that

abandoned vehicles should not present a long term environmental problem,

but that potential problems associated with the disposal of air bag

equipped cars could surface in the auto recycling process. Basic concerns

to auto dismantlers and shredders are the potential hazardous exposure to

workers and toxic waste in land fills. The scrap melting industry fears

that a large amount of nitrogen emission during the melting process would

affect the steel quality and could damage melting furnaces. However, the

general consensus is that sodium azide should not pose any problems to a

facility and its surrounding environment when the working conditions are

30 See footnotes 10c, 10d, and 10e.
111-23

properly controlled. For instance, steel scraps can be pre-heated to burn

out sodium azide before feeding them into furnaces. This can be done by

directing the exhaust heat from furnaces to scrap loads.

In 1979, the agency contracted with Arthur D. Little, Inc., to study

possible solutions for these potential problems.31 A practical solution to

the recycling problem recommended by the study is to discharge air bags at

the beginning of the recycling process. Simple and safe means do exist to

dispose of the sodium azide. The problem is to assure that the automotive

salvage industry becomes aware of these methods just as they pay special

attention to the disposal of gasoline tanks and batteries.

The agency has worked with the members of ADRA (Automobile Dismantlers and

Recyclers of America) and ISIS (Institute of Scrap Iron and Steel). They have

frequently expressed their concern about areas that have not been fully

explored regarding the disposal of sodium azide. They have stated that they

would support any practical means by which the safety of their workers can be

guaranteed. In 1979, ADRA urged that a remote triggering device, such as a

unique electric plug, be required on all vehicles equipped with air bag

restraints. This would enable the auto recycling industry to discharge the

air bag from a remote location rendering it nontoxic and harmless both to

the workers and to the environment. In November 1979, a remote triggering

method was demonstrated by NHTSA at the ADRA annual convention. The ADRA

"Identification of Approaches for the Control of Health, Environmental, and

Safety Hazards Associated with Air Bag Use and Disposal," prepared for

NHTSA by Arthur D. Little, Inc., August 1979, DOT HS-805 184.
111-24

Safety Committee agreed that the remote triggering device would alleviate

all but a small percentage of non-deployed inflators entering a shredder or

baler.32

Once again, both ADRA and ISIS expressed their concerns in the recent

Public Hearing on FMVSS No. 208. The ISIS indicates that the shredder is

the main consumer of auto hulks and thus the major generator of potential

sodium azide related problems. Shredders insist that non-deployed air bag

inflators be discharged early in the recycling process because they have no

way to conduct visual inspections for non-deployed inflators in flattened

auto hulks. Several approaches can be employed to solve this problem. One

approach is to utilize the Tagged Material Detector (Piezoelectric

resonator) techniques which enable the shredders to detect non-deployed

inflator modules in flattened auto hulks prior to the shredding process. An

alternative is to build in a self-ignition mechanism that will deploy

automatically during the shredding operation. Several self-ignition

techniques are available; however, this approach may require additional

research on hardware modifications. The ADRA wants to make sure that

passive restraint regulations do not compromise the safety of their

workers. Consequently, the ADRA recommends that the following items be

provided to auto dismantlers.

1, A positive, discernible identification for air bag cars.

2. A unique device for remote triggering of air bag inflators.

Parsons, B., Safety Committee Chairman, ADRA, Letters dated 11/13/79 and

12/4/79 to NHTSA Administrator Claybrook.
111-25

3. Some financial incentives for discharging inflators prior to the

dismantling and recycling process.

The Breed Corporation is developing a retrofit driver air bag system.

The system consists of a modified inflator which includes a mechanical

sensing and actuation device. Therefore, the remote, electric triggering

method cannot be applied to this system. However, the application of heat,

mechanical impacts, or magnetic impulses to this system can cause the

deployment of the inflator module. Fortunately, many effective approaches

are available which involve the application of physical, mechanical,

chemical and electrical stimuli to deploy the retired air bag inflators

(see footnote 10). Furthermore, the recycling industry may want to

retrieve the air bag units since they can be easily installed and removed

and should have a reasonably high salvage value due to their self-contained

design. The proposed Breed units do not appear to pose any particular

problems in final disposal.

The sodium azide disposal problem can be better understood by analyzing the

magnitude of the problem. Let us assume that 50 percent of the cars

scrapped in the year 2000 would have air bag restraints using sodium azide

based gas generants, and a total of 10,000,000 cars would be scrapped

annually. Up to 93 percent of the cars originally equipped with air bags

would have non-deployed units when scrapped or abandoned. This 93 percent

rate includes cars scrapped immediately after accidents and cars retired

after normal use. The number of scrapped vehicles after air bag deployment

is 550,000 to 700,000, as shown and derived in Chapter VII (see p. VII-31).

This estimate is mainly for cost evaluation purposes and is based on the
111-26

assumption that in the late 1990's, all cars will have air bag restraints.

Also, we assume that at least 97 percent of the air bag systems in

scrapped cars would be discharged by auto dismantlers prior to final

disposal process. This 97 percent rate is actually lower than the rate at

which batteries, radiators and gasoline tanks are routinely removed prior

to shredding (See footnote 10b). A tagged material detector or financial

incentives could reduce this even further.

On average, each pair of air bag restraints will contain 0.8 pounds of gas

generant which is approximately half sodium azide. Based on the above

assumptions, about 139,500 cars (5,000,000 • 0.93 * 0.03) delivered to

shredders in 2000 would have non-deployed air bag inflators, and about 230

pounds of sodium a'zide would be released nationally each working day. This

amounts to less than one pound of sodium azide, or about two pairs of

undeployed inflators per shredder per working day. Although some big

shredders may have to handle as much as three times the average load, it is

still a very small quantity that can be controlled with proper management.

The above analysis is based on the assumption that half of cars have air

bags using sodium azide based gas generants, which is neither being

required nor is likely to occur in the near future voluntarily.

The distribution and the fate of sodium azide in shredder facilities were

studied by both Thiokol and Battelle (see footnotes 10c and 10d). Thiokol

shredded three cars consecutively with live air bag inflators which

contained a total of 2.3 pounds of sodium azide. The important results

were: (1) 60 percent of the sodium azide was burned or dispersed during

the shredding operation, (2) 30 percent was trapped in wholly or partially
111-27

intact inflators, (3) the remaining was found in fluff, nonferrous scraps,

and scrubber water, and (4) sodium azide concentration in the air in some

areas exceeded the TCLo limit of 0.3 ppm. In the Battelle study, three

pairs of readily frangible, thin walled air bag inflators were shredded.

The results were: (1) about 60 percent of the sodium azide was burned or

dispersed, (2) only 1 percent was found in ferrous products, (3) the

remaining sodium azide was found in fluff, nonferrous concentrate and

scrubber water, and (4) no measureable amount of sodium azide was ejected

to the environment via the air discharge stack. However, the Battelle

study indicates that the test conducted by Thiokol is more realistic

because the production inflator hardwares were used for the test.

Therefore, the 10% distribution in the fluff and nonferrous concentrate and

the airborne sodium azide should be acknowledged.

Based on the above results, we can estimate that, since, on average, a

shredder would handle one pound of sodium azide per working day and 10

percent of this amount might be passed through the shredder, a shredder in

the year 2000 would dispose approximately 0.1 pound of sodium azide in land

fills per working day. Again, these values are based on the assumption

that half of cars have air bags using sodium azide based gas generants.

Sodium azide concentration in the air would not be a problem except for

some big shredders that should closely monitor locations near the scrubber

exhaust and the nonferrous product discharge areas. However, the

concentration in the air should not exceed the 0.3 ppm limit because it is

not likely that three consecutive cars with non-deployed inflators would be

shredded as simulated in the Thiokol and the Battelle tests. Although

sodium azide in nonferrous concentrate and in scrubber water could be
111-28

exposed to lead, copper and other metal and in theory could form explosive

materials, this is unlikely to happen. For instance, cuprous azide can be

formed if copper metal is exposed to hydrazoic acid with the presence of

water and carbon dioxide. Also, sodium azide will form copper azide with

copper salts to the extent of the copper salts' solubility in water.

However, these chemical reactions occur in a controlled laboratory

condition and it is unlikely that metallic azides would form in significant

quantities in scrubber water or in nonferrous concentrate under an

unattended, natural condition. The agency believes there is no danger in

this regard because the pH value of scrubber water may inhibit the

formation of metallic azides, even if they do form concentrations they are

likely to be weak because the water is constantly circulated, and impacts

necessary to cause difficulties are unlikely in such a system. In

addition, copper azide is very unstable and must be concentrated to

detonate. Dilution with sodium azide-copper salts inhibits the

detonation.^

Given the above disposal rate, high concentrations of sodium azide in land

fills are not likely because the chemical will decompose completely within

several weeks when exposed to the natural environment. In addition, in

acid solution, sodium azide will hydrolyze to form hydrazoic acid, which

will then either vaporize, auto-oxidize, or be broken down organically into

harmless substances if the condition exists.

33 Talley Industries of Arizona, Inc., "Use of Sodium Azide for Air Cushion

Inflators," unpublished report.
111-29

In summary, some concerns may be associated with the disposal of sodium

azide, but these concerns appear resolvable and manageable. Control

strategies for disposal of vehicles should recognize that sodium azide is

not the only toxic chemical that may be present in vehicles. Efforts must

be made to protect workers and the environment from hazardous exposure to

other chemicals as well. It should be pointed out that the potential

hazards pertinent to the disposal of air bag inflators are similar to the

general problems that industrial workers must deal with daily and the

problem should be viewed in this larger context. Nevertheless, additional

work is now underway to further mitigate any potential hazards.

g. Conclusions

After reviewing all available information, the agency concludes

that the manufacture of sodium azide and the normal use of air bag

restraints would not pose any particular problems to motorists or the

community. The only areas of concern with the use of sodium azide based

gas generants are in the final disposal phase of cars with non-deployed air

bag inflators. The primary potential hazards associated with the disposal

of these cars are manifested within the automobile recycling operations.

Many controversial arguments were raised on the disposal issue. These

issues have been studied extensively and all indications are that the

magnitude of the potential problems is manageable. Importantly, both Ford

and GM indicated in the recent Public Hearings on FMVSS No. 208 that the

potential risks associated with the use of soduim azide based gas generants

in air bag inflators are manageable. In reviewing the NHTSA's draft
111-30

Environmental Impact statement on "Alternative Proposals Concerning

Occupant Crash Protection," EPA has not identified any problems related to

their areas of expertise and jurisdiction.

With the help from the public, industry and other Federal agencies, the

agency (NHTSA) has drawn the following conclusions:

1. Several approaches could be employed to ensure that the non-deployed

inflator modules will deploy automatically during operations such as

shredding, shearing or baling. However, these approaches require

additional research on hardware modifications because current air bag

systems are designed to prevent inadvertent deployment. According to

estimates of A. D. Little, based on typical times needed for development of

automotive equipment, a minimum time of 2 years is required to assess

various new designs in order to ensure that the retired air bag systems can

be safely deployed during the shredding process without compromising the

reliability of the systems in normal use.

2. The results of a countermeasure analysis indicate that the risks

associated with air bag systems can be minimized by employing a series of

options at the beginning of recycling operations. The effective approaches

involve the application of physical, chemical, mechanical and electrical

stimuli to deploy the retired air bag systems. However, the use of a

12-volt dc source to deploy the system is the only approach that is

immediately available for application. NHTSA demonstrated this method at

the 1979 ADRA annual convention.
111-31

3. It is recognized that the most effective approach for the safe disposal

of air bag inflators is to deploy those non-deployed inflator modules at

the beginning of the recycling phase. An optimal result can be anticipated

if the following items would be provided to auto dismantlers in cars

equipped with air bag restraints:

- A positive, discernible identification for air bag cars.

- Tagged Material Detectors.

- A unique device, such as special electric plugs, for remote triggering

mechanisms.

- Some financial incentives for discharging inflators prior to the

dismantling and recycling process. Recently, ADRA is suggesting $15.00 per

car. ADRA is the one to discharge air bag restraints before the auto

recycling process.

4. The recently developed Breed retrofit driver air bag system does not

pose any particular problems in the final disposal process.

5. The agency will continue, in consultation with EPA and OHSA, to work

with ADRA and ISIS to resolve the issues.
111-32

3. Automatic Restraint Product Liability

a. Sources of Potential Manufacturer Liability

A manufacturer's liability for product related injuries may arise from

instances in which the product failed to meet the manufacturer's own

specifications (manufacturing defects), from instances where the product

met all the manufacturer's specifications, but the design still did not

provide sufficient protection (design defects), and from instances where a

manufacturer did not warn purchasers of the dangers associated with the

product (failure to warn). Regardless of which theory of recovery (negligence, warranty, or strict liability in tort) is used, the nature of a

manufacturer's liability for automatic restraint-related injuries is no

different from its current liability for injuries caused by manufacturing

or design defects in such existing vehicle features as fuel systems,

batteries, energy-absorbing steering assemblies, manual seat belts (most of

which have many of the same mechanisms as automatic belts), and braking

systems.

Several questions have been raised about a manufacturer's liability for

automatic restraint-related product liability claims. One basis for

possible liability involves the failure of the automatic restraint to

perform properly in a crash. In the case of an air bag, the alleged defect

could be the failure of the bag to deploy, or the premature, late or

improper deployment of the bag. In the case of an automatic belt, a

defective retractor could fail to lock up in a crash, or the belt could

break. However, the limited field experience of the current automatic
111-33

restraint equipped fleet and laboratory tests have shown those systems to

be very reliable. Manufacturer statements to the docket also indicate that

their automatic restraints systems have performed as designed.

Another argument is that even if an automatic restraint functions as

intended, manufacturers and/or dealers may still be held liable for

any injuries that occur in the crash because of "unreasonable expectations"

about the performance of automatic restraints.^ However, a manufacturer

is not absolutely liable for any crash related injuries associated with its

product. Thus, manufacturers have not been held liable in instances where

current manual belts have performed as intended, but an occupant still was

injured.35 However, manufacturers have been found liable when it can be

demonstrated that a manufacturing or design defect caused a belt to break

during a crash, allowing the driver to be thrown from the car and killed.^6

Another potential source of liability arises from a manufacturer's decision, in the absence of a Federal mandate, not to install an automatic

restraint. During the public hearings, Mr. Stephen Teret, representing the

National Association for Public Health Policy, argued that:

If a reasonable means of protection is being denied to the motoring

public, that denial should lead to liability, even if the liability

can be imposed on each and every car manufacturer. People whose

34 Submission of General Motors, December 19, 1983, p. 3. Docket

74-14-N32-1664.

35 Hurt v. General Motors Corporation, 553 F.2d 1181 (8th Cir. 1977).

36 Engberg v. Ford Motor Co., 205 NW 2d 104 (S.D. 1973).
111-34

crash injury would have been averted had the car been equipped with

an air bag can sue the car manufacturer to recover the dollar value

of that injury. 37

Although, according to Teret, such product liability suits have been or are

about to be brought, the agency is not aware of any court that has adopted

this theory of liability as yet.

Another potential liability concern involves providing automatic

restraints for the driver and not for front seat passengers. The issue is

whether those passengers could bring suit against the manufacturer if they

were injured in a crash in which the driver was uninjured because of the

automatic restraints. If driver only automatic restraints were mandated by

Standard No. 208, manufacturers do not have an absolute defense against

such claims because section 108(c) of the National Traffic and Motor

Vehicle Safety Act provides, in effect, that compliance with a Federal

standard is not a defense to a civil liability suit. However, while

compliance with a Federal standard is not a defense, it is usually given

substantial weight by a court in determining whether a manufacturer has

acted reasonably. Therefore, the agency believes that the risk of

liability would be minimal.

Finally, one commenter raised the issue of spurious suits being filed. He

said that General Motors' experience with its 1973-1974 Air Cushion

Restraint System program was that there was a "tendency for those involved

in accidents in these ACRS cars to sue in any situation."^8

Transcript of Public Hearing on Federal Motor Vehicle Safety Standard No.

208, Washington, D.C., December 5, 1983, p. 154.

Jack Ridenour, letter of Dune 4, 1984, Docket 74-14-N35-069.
111-35

introduction of automatic restraints, as with the introduction of many new

products may be initially accompanied by a number of spurious suits.

However, because of the extensive crash testing and research done by

manufacturers on automatic restraints, compared to the testing done on most

new automotive products, manufacturers will be in a better than usual

position to defend against such suits.

D> Manufacturer Product Liability Costs

The most recent comprehensive review of product liability costs and

experiences of manufacturers available to the agency was conducted by the

interagency task force on Product Liability chaired by the Department of

Commerce. The final report of the task force shows that the automotive

industry, in comparison to the other industries studied, is in a good

position with regard to product liability costs. The task force found that

between 1975 and 1976, the absolute number of automotive personal injury

product liability cases in Federal District Courts decreased and the

percentage of automotive personal injury product liability cases to all

personal injury product liability cases dropped from 18 percent to 13

percent.^ The interagency study also found that the average settlement and

judgment for product liability claims not only declined for the automotive

industry between 1972 and 1976, but declined at a much greater rate than

the average of all industries studied.40

Interagency Task Force on Product Liability, Final Report of the Legal

Study, Volume III, Table A, p. 10.

Interagency Task Force, Final Report of the Industry Study, Volume I, Table

IV-29, p. IV-56.
111-36

An important finding of the task force was that the average product

liability insurance cost for companies represents somewhat less than one

percent of their gross sales.41 The report found that for the automotive

industry, the average cost per $1,000 of sales for comprehensive general

liability insurance (which provides coverage for a number of different

types of liability including product liability) is well below the average

for most industries and is at the average for industries with gross sales

exceeding $100 million. Where companies were able to report the proportion

of their insurance costs directly related to product liability coverage,

the report found that the average cost per $1,000 of sales for product

liability insurance for automotive firms is far below average.42

c. Availability of Product Liability Insurance

During prior rulemaking on Standard No. 208, insurance companies have

consistently stated that automatic restraints should decrease, not increase, product liability claims and that insurance is available to cover

possible automatic restraint-related product liability claims.43 During

the current proceeding, insurers reiterated that position. For example, at

the Los Angeles public hearing, Allstate Insurance Group addressed the

potential of automatic restraints to reduce product liability claims and

41 Interagency Task Force, Final Report, p. III-3.

42 Interagency Task Force, Final Report of the Industry Study, Volume I, Table

IV-II, p. IV-31, and Table IV-13, p. IV-34.

43 American Mutual Insurance Alliance letter of May 25, 1978, to Secretary

Adams, Docket 74-14-N8-188; American Insurance Association letter of

3une 27, 1977, to Secretary Adams, Docket 74-14-N8-231.
111-37

the availability and cost of manufacturer product liability insurance. Mr.

Donald Schaffer, Senior Vice President, Secretary, and General Counsel of

Allstate, testified that:

Our product liability people believe that the air bag equipped

cars, if you insure the total vehicle, will produce better experience than the non air bag cars because the air bag reliability

factors are much higher than anything on the car. They are much

higher than the brake failure rates or anything else.44

Mr. Schaffer also testified that, at the time of Secretary Coleman's

proposed demonstration program, Allstate was Ford Motor Company's product

liability insurer and had informed Ford that there would be no increase in

its product liability insurance costs if Ford built an air bag fleet. He

also testified that Allstate entered into a written agreement with General

Motors that "we would write all of their product liability cars in the

Coleman demonstration fleet at the same price they were getting from their

regular product liability insurer per unit for non air bag cars of the same

make and model year."45

The National Association of Independent Insurers (NAII) also addressed the

product liability concerns raised by manufacturers and dealers. NAII said

that:

The potential for product liability suits is always present

for any manufacturer or seller of consumer goods. That threat is

present at the current time for anyone in the distribution chain.

We in the insurance industry expect that savings (not increased

costs) would accrue to manufacturers and dealers, as a result of

44 Transcript of the Public Hearing on Federal Motor Vehicle Safety Standard

No. 208, Los Angeles, CA, November 28, 1983, p. 60.

Los Angeles Public Hearing Transcript, p. 59-60.
111-38

automatic crash protection systems being installed in all cars, as

lives are saved and injuries are reduced, thus reducing potential

litigation over safety deficiencies.46

d. Sources of Potential Dealer and Repair Shop Liability

During the public hearings and in written comments submitted to the docket,

individual dealers^? and the National Automobile Dealers Association

(NADA) raised the issue of whether the use of automatic restraints will

increase a dealer's product liability costs. Likewise, the Automotive

Service Council of Michigan raised the issue of of the potential liability

of independent repair shops that would service automatic restraint equipped

vehicles.48 William C. Turnbull, President of NADA, testified that:

The reliability of passive restraint systems, particularly

air bags, has been a matter of grave concern to dealers and

consumers alike. No mass-produced product can ever be "fail-safe."

Components deteriorate due to passage of time, usage and climate.

There are reports of inadvertent air bag deployments in the past.

We fear that, with any widespread usage of air bags, incidences of

inadvertent deployments and system failure will occur, with perhaps

tragic consequences to vehicle occupants. In such cases, dealers

may be the innocent victims of product liability lawsuits.49

The primary source of potential liability for both dealers and repair shops

arises from the servicing of a vehicle. If the vehicle is subsequently

involved in a crash and the automatic restraint system does not perform,

46 Docket submission of National Association of Independent Insurers,

December 19, 1983, Docket 74-14-N32-1672, answer to question three.

47 E.g., Statement of John 0. Pohanka before the Public Hearing on Federal

Motor Vehicle Safety Standard No. 208, Washington, DC, December 7, 1983,

Docket 74-14-N33-131.

48 Transcript of Public Hearing on Federal Motor Vehicle Safety Standard No.

208, Overland Park, Kansas, December 2, 1983, pp. 334-340.

49 Statement of William C. Turnbull before the Public Hearing on Federal Motor

Vehicle Safety Standard No. 208, Washington, DC, December 5, 1983, p. 5,

Docket 74-14-N33-100.
111-39

the dealer or the repair shop is potentially liable if it can be shown that

the cause of the failure is the result of the dealer's or repair shop's

negligent servicing of the vehicle. To minimize such problems, dealers and

repair shops will have to make sure that their service personnel are

adequately trained and institute appropriate quality control measures in

their service operations. Those training and quality control measures are

no different from actions a dealer or repair shop owner would have to take

any time a new device is installed on a vehicle. For example, if dealers

or repair shops do not properly train their service personnel about the new

computer control systems on vehicle engines, the faulty repair of the

system could lead to engine stalling and a possible accident.

If a dealer or repair shop is involved in a suit alleging both a design

defect and dealer or repair shop negligence, the dealer or repair shop has

the right to indemnification from the manufacturer for design or manufacturing related defects. Chrysler, Ford, and General Motors currently have

a program to indemnify their dealers in suits based on defects in the

design, and manufacture of their vehicles. According to NADA, at least

eight other vehicle manufacturers (Datsun, Fiat, Peugeot, Porsche-Audi,

Saab, Toyota, Volkswagen, and Volvo) also have similar product liability

indemnification programs for their dealers.50 Dr. Willi Reidelbach of

Mercedes-Benz, which is currently marketing an air bag-equipped vehicle in

Europe and in the U.S., testified that he was not aware of any product

liability concerns expressed by Mercedes dealers over the system.51

50 Cars & Trucks, July 1978, p. 29.

51 Transcript of Public Hearing on Federal Motor Vehicle Safety Standard No.

208, Washington, DC, December 7, 1983, p. 45.
111-40

e. Conclusions

Based on its review of the product liability issues, the agency has

concluded that manufacturers and dealers do not face an increased risk of

liability because of the use of automatic restraints. In fact, the

installation of automatic restraints should decrease the number of product

liability claims. Many people previously injured or killed in crashes

allegedly caused by vehicle manufacturing or design problems, such as

stalling engines, locking brakes, collapsing wheels, blown out tires and

jamming throttles, will be protected by automatic restraints.

In addition, information provided by insurers indicates that product

liability insurance is available to cover the automatic restraint related

claims experienced by vehicle manufacturers. Also, the indemnification

programs offered by vehicle manufacturers may eliminate many of the product

liability problems faced by vehicle dealers as a result of factors beyond

their control. Both dealers and independent garages will have to ensure

that their repair personnel are adequately trained on servicing automatic

restraints and follow appropriate quality control measures in their service

operations to minimize product liability problems.

4. Breed All Mechanical Air Bag System

The Breed Corporation of Lincoln Park, New Gersey, is developing an

all-mechanical air bag system in which the sensor is integral with the gas

generator. If this system proves to have production feasibility and

performs according to its design, it holds promise for increased
111-41

reliability, simplicity and most importantly, substantially reduced cost.

The all mechanical modular Breed concept would potentially eliminate the

multiple up-front electric switch sensors, all wiring leading from the

sensors to both the diagnostic package and the gas generator, the steering

wheel slip ring, the electric squib, the auxiliary capacitor power supply

and the electronic diagnostic module of a conventional air bag system; (a

complete description of the system is included in Chapter VIII). Since

the entire unit, including sensors is located completely within the

occupant compartment, it should not be affected directly by the elements

and other hostile aspects of the automotive environment such as road salt,

high underhood temperatures, etc.

Breed currently estimates the cost to consumer of a driver air bag system

to be $47 and one for the driver and passenger to be $141 installed, based

upon an initial production rate of one million units annually. Other

annual production rate estimates submitted by Breed for the driver and one

passenger system were $199 for 100,000 production, $170 for 300 thousand

production, and $130 for 2.5 million production. Breed states that their

cost estimates have been independently verified by technical experts

familiar with auto industry practices, procedures and pricing mechanisms.

If this cost proves out through development, then this is a rather dramatic

reduction from the air bag system cost of $320, as currently estimated by

the agency. It should be pointed out, however, that the Breed estimate

does not include necessary vehicle modifications such as the knee bolster.

A preliminary agency cost estimate of a Breed system for driver only is $95

and one for the driver and one passenger is $206 at the million unit level,

(see Chapter VIII). Other agency annual production rate estimates of a
111-42

Breed system for the driver and one passenger are $225 and $198 for

production volumes of 300 thousand and 2.5 million, respectively. These

estimates include vehicle modification costs and manufacturers' overhead

appropriate for purchased components.

While the Breed concept appears to be fundamentally sound, David Breed, the

company's research director, admits that the system still requires "a good

year" of research before it can be put into production.^2 Allen Breed, the

company president, speaking at the December 6, 1983 public hearing in

Washington, stated that an accelerated program lasting 1 year and costing

an estimated $5 million, including equipping 10,000 vehicles with a driver

air bag, is necessary to prove and make ready for production the design of

the Breed Air Bag Module.^ General Motors, Ford, and Mercedes-Benz are all

interested in the concept and each company is independently evaluating the

system in their labs. Mercedes-Benz has ordered two of the units for

testing but no test results have been released yet. Ford considers the

Breed concept "not yet fully developed . . . but worth exploring." GM is

interested in the concept, but has doubts about its ability to perform as

quickly as needed on pole impacts, such as a light pole or tree or some

other narrow, immovable object. GM is still evaluating the Breed system.

NHTSA is also interested in evaluating the Breed system. The agency

recently awarded a contract for a two phase study of a driver only

all-mechanical air bag system. The first phase of this contract involves

"Fuse Firm Offers Idea on Air Bags" John E. Peterson, Detroit, Michigan

News, December 3, 1983. Company comments are taken from this article.

FMVSS No. 208 Occupant Crash Protection Public Hearing, December 6, 1983,

p. 208.
111-43

crash testing of three Ford LTD's at various impact speeds. The crash

testing is being supplemented with computer simulation. The object of this

first phase of the study is determination of product feasibility — can the

all-mechanical system detect and actuate in sufficient time to protect the

driver while not being overly sensitive in low speed collisions? If the

limited crash testing and computer simulation confirm timely air bag

deployment and reveal no other problems, phase two will be implemented. Two

vehicles of different makes will be selected for air bag retrofit and will

be subjected to a series of fifty sled tests and eight full scale crash

tests. After completion of this development, Breed will be expected to

fabricate approximately 500 kits for retrofit on selected police fleets. A

complete evaluation of this test fleet is expected to answer some of the

questions concerning real world operation of these all-mechanical retrofit

type air bag systems. However, this effort is directed toward answering

the question of the practicability of the system for large cars. A

separate study would be required to determine the practicability of the

system for other classes of cars, especially small cars. Honda stated that

they had concluded that the all-mechanical system cannot be used in a small

car; however, no data were supplied in support of this conclusion.

Allen Breed recommended at the December 6 public meeting that the

Government require auto makers to design air bag cavities in steering

wheels and dashboards. According to Breed, if auto manufacturers agreed to

this design change, it would put air bags on the same par as radios that

are purchased separately for automobiles and placed in the cavity left for
111-44

them by the manufacturer. Thus, car owners who prefer the additional crash

protection afforded by air bags could purchase a conforming Breed unit at

auto supply stores and install them in pre-designed cavities.

In summary, an alternative to the conventional electro-mechanical air bag

system is under development and test results from industry and government

programs should be available at some future date. The most significant

feature of this new system is its projected lower cost compared to other

systems. Its most important drawback at this time is its lack of full

scale test and field data. Specifically, can the system detect a crash

early enough to actuate the system properly? Is the crash pulse sensed on

the steering column so different in various crash modes that the sensor

cannot be tuned properly? Will it be possible to design a passenger side

system and when could it be done? Can a steering wheel assembly be made to

accept and structurally maintain a retrofit air bag system but also provide

adequate occupant protection if no air bag is fitted in the cavity by the

owner? In addition to these technical questions is the question of

manufacturers' liability and willingness or desire to design into vehicles

a cavity for a retrofit air bag that could be manufactured by other

vendors.

These and other questions on the all-mechanical air bag system may be

answered by Breed research, GM, Ford, and Mercedes testing, and the agency

testing program. At this point, however, many questions remain. Until

these questions can be answered, the agency can not base its 208 decision

on this technology.
111-45

B. Other Issues

1. Passive Interiors

a. Comments to the Docket

Modifying the design of vehicle interiors to offer increased occupant

protection through passive interiors was addressed by two commenters to the

docket. GM (Docket Comment No. 74-14-N32-1666 and 74-14-N35-068A) cited

its Vehicle Safety Improvement Program (VSIP) results as an example of an

alternative technology that should be investigated. According to GM, the,,•

accelerated use of the computer in the design of GM vehicles has allowed

them to "build in" safety. The VSIP process has accelerated design

changes to improve vehicle structural integrity, the energy absorption

of vehicle interiors, steering columns, windshields, door

structures and latch mechanisms. GM proposed an additional compliance

option for Standard 208, namely, that unrestrained Hybrid III dummies not

exceed the existing injury criteria in a 25 mph frontal test, while dummies

using manual restraints pass a 30 mph test. This would allow for passive

interiors in combination with existing manual belt systems.

MCR Technology, Inc. (Docket Comment No. 74-14-N32-583) stated that "recent

research has shown that it is now possible to automatically protect

occupants by making minor modifications to vehicle interiors and pass the

FMVSS 208 injury criteria in compact or larger vehicles without the use of

restraints at all." MCR Technology suggests that the agency emphasize

public information, discovered through crash testing, about the degree of
111-46

real world protection afforded unrestrained occupants so that people would

have some appreciation of the relative merit of unrestrained versus

restrained occupant protection.

Thus, these two docket comments intimate that passive interior design can

provide occupant protection without restraints, protection possibly

equivalent to that indicated by passing the 3D mph perpendicular barrier

test requirements of the current FMVSS 208 standard. GM provided data

showing that two of their production vehicles - the 1982 X-Car and the new

1984 Pontiac Fiero - when tested in the 30 mph barrier crash using the GM

Hybrid III test dummy and without the use of seat belts or air bags,showed

very favorable test results compared to the current standard's injury

criteria limits.54 However, GM also stated that even using its

dummy and assuming no test variability, it could not certify

to the 30 mph requirement. But they felt that a 25 mph

requirement for unrestrained dummies in combination with a 30 mph

requirement for dummies using manual restraints would be within their near

term capabilities and could result in safety benefits as great or greater

than those projected for the existing 208 standard.

b. GM Presentation on the Vehicle Safety Improvement Program

GM presented an overview and some detailed discussions of its Vehicle

Safety Improvement Program to the agency on January 26, 1984 and 3une 8,

1984, and supplemented them with their June 13, 1984, submission (Docket

GM Docket Comment 74-14-N32-1666, Appendix C, Figure 1 and Figure 2,

p. 3-4.
111-47

74-14-N35-068A). GM stated that originally they had set a goal to reduce

total harm" to occupants by a factor of 2 with various passive interior

projects. However, upon a closer review by GM's project managers involved

with the VSIP program, it was determined that 50 percent effectiveness was

not possible with vehicle changes alone because over 50 percent of the

accidents were not affected by these changes. A long-term goal of 25

percent total harm reduction in crashes was therefore established, with a

near term goal of approximately 12 percent. GM claims that the latter

would achieve benefits as great as a 35-40 percent level of automatic

restraint usage.

The VSIP strategy consists of making improvements to vehicle structures and

interior design and evaluating their effect. Improvements are contemplated

for the steering assembly, windshield, instrument panel, etc. Their net

effect is evaluated by performing frontal crash tests with unrestrained

Hybrid III dummies at speeds such as 25 or 30 mph. Crash test results are

then equated to injury risk in highway accidents as follows: injuries

reported in the National Crash Severity Study which are due to occupant

contacts with frontal components are tabulated by Delta V and AIS severity

level. Next, GM hypothesizes that if the cars in NCSS were replaced with a

fleet that could meet the Standard 208 criteria, with unrestrained dummies

in 25 mph crash tests, then all of the AIS 2-6 frontal contact injuries in

the sub-25 mph crashes would be reduced in severity by one AIS level.

This, in turn, would reduce harm by 12.6 percent.

55 Harm is a concept put forth in SAE 820242, "A Search for Priorities in

Occupant Crash Protection," as the sum of injuries from vehicle points

contacted by injured body regions, weighted by societal costs per AIS

level.
111-48

The agency can not accept GM's proposal for unrestrained occupant

protection at 25 mph as it could

 De a diminution of the potential benefits

expected with 30 mph automatic protection. However, the GM approach, which

is also the subject of agency research (see "Planning For Safety

Priorities, 1983 Safety Priorities Plan," NHTSA, April 1983, pgs. 129-140),

is to be encouraged. The agency believes that with adequate leadtime GM,

as well as other manufacturers, can develop 30 mph passive interiors. It

is also believed that such an approach is likely to be less costly than air

bags as well as less obtrusive than automatic belts, resulting in perhaps

greater public acceptability than those means of compliance. The Department

has structured its decision to help foster this, as well as other,

innovative technologies.

2. Test Procedures Repeatability

a. Background

Recently, the agency conducted the 35 mph frontal barrier crash

Repeatability Test Program (RTP). The RTP resulted from concerns over the

significance of New Car Assessment Program (NCAP) data derived from a

single crash test. The fundamental question to be addressed in the RTP was

the repeatability of crash test data, especially the dummy injury

measurements. The program consisted of four frontal barrier impacts of

1982 Chevrolet Citations at each of three different test sites. The

Citations were manufactured consecutively, on the same production line, in

the same assembly plant, in an attempt to achieve maximum possible vehicle
111-49

uniformity. The agency test sites were Calspan Corporation, Buffalo, New

York; Dynamic Science, Inc., Phoenix, Arizona; and the Transportation

Research Center, East Liberty, Ohio.

The RTP was designed to assess the repeatability (can crash test results be

replicated at the same test site?) and reproducibility (can different test

sites produce the same crash test results?) of the dummy injury measures.

It was recognized that the RTP would not be able to identify and quantify

the sources of any repeatability or reproducibility variances.

Substantial engineering and statistical analysis of the RTP data has been

performed. These analyses provided information which led to changes in the

NCAP test procedure. The analyses also identified a number of research

programs to reduce crash test variability.

b. Docket Comments—Notice of Proposed Rulemaking Docket 74-14, Notice 32

Three automobile manufacturers and the Automobile Importers of America

(AIA) submitted comments to the docket referencing the RTP and/or

repeatability tests they have conducted. AIA questioned the adequacy of

the test dummies, specifically the alleged imprecision with which the dummy

will record when compared to a real-world human response to the same

trauma. They also claimed that the limitations of the dummy are more

apparent when used with a belt restraint system, as compared to an air bag

restraint system.
111-50

Ford Motor Company (Ford) stated that repeatability crash testing provides

sound data which demonstrates that the results obtained from a single crash

test are influenced by the large variability which remains undefinable and

uncontrollable. Ford also reported the conclusions from its repeatability

testing of thirty-three 1972 Mercury air bag equipped vehicles, which

underwent 30 mph frontal barrier impacts. The objective of their program

was to determine variability among Part 572 test dummies, test sites and

crash tests themselves. Ford concluded that: (1) there was a great amount

of variability in the test results; (2) the largest source of differences

in the test results was due to test-to-test variability; (3) the

variability in the results due to the dummy is small for HIC measurements,

and nil for chest g's and femur load measurements; and (4) the considerable

variation in test results suggests that there may be limited confidence in

meeting the performance criteria of a standard.

General Motors Corporation (GM) stated that the Safety Act requires that

standards issued by NHTSA should be practicable, i.e., capable of being

used, and therefore a standard which is based on test procedures which do

not assure repeatable results is not practicable. Furthermore, to be

practicable, repeatable test results must be attainable from test methods

which are identical, or which differ only in minor detail. GM also

mentioned the Paccar decision on FMVSS No. 121, wherein the Court concluded

that "Manufacturers are entitled to testing criteria that they can rely

upon with certainty." GM cited the Repeatability Test Program's results

which indicated a significant coefficient of variation (COV) of 21 percent

and noted that the testing was based on FMVSS No. 208 criteria. They also

referenced the Uniform Tire Quality Grading Standard (UTQGS), in which the
111-51

treadwear grading was suspended, and pointed out that it had a COV of only

5 percent. GM's conclusion was that the FMVS5 No. 208 compliance tests are

subject to significantly more variation than the UTQGS treadwear tests, and

therefore, would appear to be even more unacceptable. (The suspension of

the treadwear grading requirements were subsequently overturned by a court

decision, in which the court stated that the variability in UTQGS was

insufficient to rescind the standard). GM stated that the need to consider

experimental data in establishing safety standards is specifically set

forth in the Safety Act. Finally, GM stated that vehicle (crash) testing

can be instructional in establishing directional correctness of design

changes under consideration.

Volkswagen of American (VWOA) stated that the current test procedure is

simply not appropriate, particularly for the testing of vehicles equipped

with seat belts.

In their comments, GM and VWOA reflected the belief that the test

procedures are the cause for much of the variability which exists in the

RTP results. AIA questions the adequacy of the test dummy. Ford stated

that the variability due to the test dummy is small; however, they believe

the reasons for the variability are undefinable and uncontrollable. In

summary, the industry suggested different reasons for test result

variability, those being the test dummy, the test procedure, or unknown.

It is important to note that in their comments to the NPRM, the industry,

except for GM, Ford, and Volvo, provided little data to demonstrate that

the test vehicle was not a significant cause of the variability of the

results.
111-52

c. Docket Comments — Supplementary Notice of Proposed Rulemaking (SNPRM)

74-14, Notice 35

In the SNPRM, repeatability was included in the general topic of "Test

Procedures." Fourteen automobile manufacturers and four private

organizations referenced the RTP and/or repeatability testing.

Specifically, the SNPRM requested comments on: a) the relevance of the RTP

results (35 mph) to FMVSS 208 compliance tests (30 mph); and (b) the

applicability of the RTP Citation results to all other vehicles.

Ford Motor Company (Ford)

Ford stated that the variability observed in the RTP would be expected in

all vehicle models. They based this statement on driver HIC data from

three repeatability test programs; Citation (RTP), Volvo, and Mercury. In

discussing test procedures, Ford questioned the repeatability of the test

dummy. They believe that NHTSA has not incorporated results of the

proposed repeatability research programs and are projecting conclusions

prior to the completion of research it initiated to resolve the variability

issues. They know of no data which prove that changes in the NCAP test

procedure will reduce the variability of the test results. Ford believes

that the test dummy and test procedure contribute to the high level of

variability, and, in fact, stated that it is irreducible. They stated that

the current coefficient of variation in the barrier crash test measurement
111-53

is 21 percent. They also referred to the Part 572 dummy as the "rubber

yardstick" that can be stretched or compressed at the whim of the measurer.

Ford concluded, based on calculation of Mercury, Citation and Volvo

repeatability results, that there is a large and unacceptable amount of

variability no matter what type of vehicle is crash tested.

In discussing test procedures, other commenters mentioned the subject of

repeatability.

American Motors Corporation (AMC)

AMC believes "the agency must modify the test procedure to increase

repeatability before any automatic restraint portion of FMVSS 208 is

adopted". Because the proposed modifications to the test procedure were

minor, AMC does not expect them to reduce the variability. They stated

that tests have shown that a slight change in the placement of the

passenger right foot or a slight revision in the method of applying the

force used in positioning the upper torso of the dummy in the seat produces

significant differences in HIC as shown in the RTP data.

They stated that it is "unrealistic to believe that dummy placement

procedures will have any significant affect in eliminating test

variability" since there are other variables (belt tension and actual dummy

position just prior to impact) that are not controlled.
111-54

AMC finds that the test procedures for the automatic restraint portion of

the standard do not meet the criteria of "practicable" and "objective",

which is supported by NHTSA's and GM's repeatability crash test results. If

the agency continues to use the revised test procedure then, AMC would have

to "overdesign" to a level that approximates half the specified injury

criteria values.

Chrysler Corporation

Chrysler stated that the range of the results of the RTP demonstrate

that the procedures are not "capable of producing identical results" and

are not "practicable" within the meaning of two previous court decisions.

They stated that "the test procedures measure the ability of the

manufacturer to conduct the test and not the restraint system performance".

Chrysler stated that "a major source of non-repeatability is the inherent

crash variability of the vehicle itself" and, therefore, "NHTSA must design

a test which, when vehicle crash-to-crash variability is considered, will

produce repeatable results".

General Motors Corporation (GM)

GM does not agree that the proposed test procedure modification will

provide a reasonable range of test variability. They cite that the changes

were used in NHTSA's RTP with little improvement in variability. GM stated

that, based on sled tests, a major portion of the variability in the RTP

was test related, not vehicle related. GM states that "vehicle
111-55

variability is a fact of life and cannot be dismissed as a manufacturer's

concern". GM argues that vehicle variability impacts the practicality of

any safety standard. Additionally, "design compensations to overcome the

effects of variability can be contrary to the need for safety".

BL Technology Ltd.(BL)

BL does not believe the subject of test procedures is "supremely important"

for discussion and, since it is so involved, it would require a period of

longer than 30 days to comment.

BMW of North America, Inc. (BMW)

BMW states only that there are a "number of reproducibility problems

regarding HIC". BMW also states that "our experience is that impacts of 30

degrees impose less severe forces on dummies and increase testing

variables."

Honda

Honda believes the test procedure for NCAP is "inadequate and many things

need to be improved with regard to repeatability". Details will be

supplied later (by Honda).
111-56

Mazda North America, Inc. (Mazda)

Mazda recommended conducting a repeatability program testing a subcompact

vehicle to examine the variability of the test results. They recommended

performing an analyses of the impact of the proposed modifications of the

test procedure to examine the variability issue.

Mercedes-Benz (M-B)

M-B stated that neither the Hybrid II nor Hybrid III permit repeatable

compliance test results. They believe that the "design to conform" as

practiced in FMVSS 108 is a solution to this problem and should be adopted.

Nissan Motor Company, Ltd. (Nissan)

Nissan believes that "the ability to demonstrate repeatability of the

injury criteria is the key point in NHTSA's vehicle assessment testing

program". They stated that the NCAP test result variability from the 1982

and 1984 Nissan Stanza was due to varied dummy positioning. Maintaining

the same relative dummy position is difficult and Nissan recommends using

the same dummy-to-vehicle interior dimensions for the same car models

tested. They also proposed positioning the shoulder belt to design

measurements submitted by the manufacturers. They recommended positioning

the seat in a track position which accurately represents real world usage

as opposed to the specified mid-seat track position in the procedure. If a

car model has limited interior size, then the seat should be placed in the

"rearmost position".
111-57

Peugeot/U.S. Technical Research Company (Peugeot)

Peugeot states that "a manufacturer can but reluctantly accept as valid

a test procedure which produces a coefficient of variation of 21 percent

with substantially similar vehicles. Vehicle likeness will remain what it

is and as long as the variability of parameters (test procedures, dummy,

measuring method) which are responsible for such variations are not

mastered, the requested level of performance should be raised by the amount

of variations".

Peugeot further states that "the current Hybrid II dummy is one cause of

variability, and consequently it cannot be said to meet the statutory

criteria. Nevertheless, in the present situation and considering that it

is absolutely necessary for manufacturers to dispose of a reference, even

questionable, it must be maintained and imposed".

Renault USA, Inc. (Renault)

Renault believes the coefficient of variation "must not exceed a

maximum of 10?o" for crash test results. If the coefficient remains at 21*,

"the admissible limits for HIC should be increased by 635o or else the

manufacturer is to anticipate an overdesign of 63%".
111-58

Toyota Motor Corporation (Toyota)

Toyota believes that major problems exist in the test procedure, such as,

influence of the Part 572 dummy on crash results, unresolved electronic

measurement problems, incompleteness of the proposed modified test

procedures, and exclusion of data points from the statistical analysis of

the RTP without an explanation.

Volkswagen of America, Inc. (VW)

VW stated that the RTP demonstrated variability "was much too high to yield

an acceptable certification procedure". VW stated that they have "no

confidence that the changes in the modified test procedure will cause a

significant reduction in the test variability" or that "those changes will

solve the problem." VW alleged that the manufacturers must "overdesign"

the system only for the purpose of compensating for deficiencies in the

compliance test procedure.

Volvo North American Car Operations (Volvo)

Volvo disagreed that after certain modifications to the NCAP test

procedures, the "remaining test variability would be due largely to

vehicle-to-vehicle differences". They agreed that the modifications to the

procedure were a step in the right direction. They stated that the total

random error in a crash test includes: (a) vehicle-to-vehicle parameters;

(b) test procedure related parameters; (c) dummy related parameters; (d)

electronic parameters; and (e) data processing.
111-59

They believe that the modifications to the NCAP procedures only address

some of the parameters which influence that procedure. The parameters

which influence the dummy, electronic data gathering and data processing

have not been addressed at all.

They stated that the present procedure allows a large degree of

subjectivity in attaching and routing seat belts, knowing that the seat

belt geometry is of great importance to the variability of the test

results. Volvo recommended checking the placement and installation of the

same dummy in the same vehicle at various laboratories to determine

differences in seating locations.

They also questioned the unreliability in the signals obtained from

accelerometers and believe that there are cases where disturbed signals are

not discovered because they do not appear as "obviously abnormal". In

addition, data filtering can cause variability. Volvo also provided data

from 10 sled tests which demonstrated a scatter of data about the mean HIC

of 466. The coefficient of variation for the sled tests was 12.5%.

Allstate Insurance Company (Allstate)

Allstate questioned the great concern about minute details of the test

procedure for automatic restraints, when there are no dynamic crash test

requirements or injury prevention criteria for present manual belts. They

believe the answer is to move to automatic crash data protection with test

procedures based on present knowledge and data, and update them as more
111-60

data and experience become available. They stated that in the case of

Public Citizen vs. Steed, the D.C. Court of Appeals cited the case of

Goodrich vs DOT for the proposition that "no test procedures...are going

to approach perfection".

The D.C. Court went on to say "NHTSA's approach to fulfilling an undisputed

statutory mandate is to withhold any regulation until every i is dotted and

t is crossed. That is not what Congress commanded the agency to do, nor is

it reasonable behavior by an agency established to execute policy, rather

than achieve quantitative perfection in its execution". Allstate claimed

"it would be the height of absurdity to refuse to implement a passive

restraint standard because of concern over minor test details, when such

action would leave us with a manual belt system and no test procedure

whatsoever."

Motor Vehicle Manufacturers Association (MVMA)

MVMA stated that before action is taken to incorporate the modified NCAP

procedure into FMVSS 208, NHTSA must provide additional technical data

supporting variability reduction for improved test procedure practicability

and objectivity. They stated that proposed changes to the test procedure

were used in the RTP, and that the variability in the test results was

unacceptably high.
111-61

Insurance Institute for Highway Safety (IIHS)

IIHS discussed the need to retain the 1000 HIC number. They state that all

regulations which specify a value which can not be exceeded involve

overdesign. Thus, overdesign is not only reasonable, but is a standard

industry practice. They also stated that the degree of vehicle overdesign

needed to meet a HIC of 1000 is "easily achievable."

State Farm Mutual Automobile Insurance Co. (State Farm)

State Farm stated that NCAP tests at 35 mph involve 36% more force than

crash tests at 30 mph, the speed required under FMVSS 208. The reduced

speed "should result in less variability and fewer cars with HIC levels

over 1000". They cited a recent decision by the Court of Appeals for the

District of Columbia in Public Citizen v. Steed which held that "the

variability in the tire quality grading program was insufficient to

justify the recisson of that standard". Also, they believe that nothing

in the NCAP should alter rulemaking in FMVSS 208.

d. Discussion

With respect to repeatability, the comments to the SNPRM provided little

new information or analyses beyond what was submitted to the NPRM. It

should be noted, however, that in Ford's analysis of the Citation, Volvo,

and Mercury repeatability crash test results, Ford provided no data to

support their claim that the variability in dummy injury criteria for each

data set was essentially the same. The agency does not agree with Ford's
111-62

approach of combining two different data sets of Volvo crash test results.

In discussions with the agency, Volvo said they could not confirm that

MIRA, the other conductor of Volvo crash tests, had followed the NCAP test

procedures. Thus, without this assurance, treating the two data sets as

one is unfounded. Additionally, the agency is not aware of any rationale

whereby statistical measures of variability (be they standard deviations or

coefficients of variation) derived from a single model vehicle at a single

test speed can be assumed to be directly applicable to all other model

vehicles and at a different test speed. Ford, in its comments to the

SNPRM, used a "scaling" factor to change the standard deviation obtained in

30 mph crash tests to one for 35 mph tests. Although Ford did not explain

what its "scaling" factor was nor how it was derived, it supports the

agency's argument that statistical variations of injury

prevention/measurements can not be made across test speeds.

The agency recognizes that a certain level of variability exists in dummy

test results and has acknowledged its efforts to identify, quantify, and,

where possible, reduce the amount of variability. It should be noted that

some variability would exist in all areas of testing performed by the

agency or by the manufacturers, from research and development tests to NCAP

tests, and from component tests to full-scale vehicle tests.

Engineering analysis of the RTP data identified four components of

variability in dummy injury measurements — the test site, the test dummy,

the test procedures, and the test vehicle.
111-63

The results of previous studies of both dummy testing and test site

instrumentation provide an indication of the amount of variability which

may be due to each of these components. A test site instrumentation study

indicated that, at some test sites, instrumentation differences could

produce as much as 10 percent variation in HIC values. Regarding dummy

testing, GM and Ford differ in their NPRM submittals. Ford stated that,

based on their 33 air bag car crash program, the variability in results due

to dummies is small for HIC measurements, and nil for chest g's and femur

load measurements. Renault, in comments to the SNPRM, agreed that the

dummy is "not the major cause of dispersion in the results." GM observed

variability when they conducted sled tests utilizing belted dummies.

However, they were not able to isolate the dummy variables from system

variables. They also claimed that the dummy is inappropriately sensitive'

to belt testing and they are not confident that current dummies can

accurately demonstrate belt restraint effectiveness.

As a result of the RTP, the agency has instituted a number of improvements

to the NCAP test procedures. Additionally, a research program has been

defined which will attempt to identify and reduce causes of variation

in crash testing.

The RTP analysis indicates that the vehicle is a major contributor^ to

variability, as evidenced by the significant differences observed in the

structural/occupant compartment behavior in the RTP crash tests.

56 See 'Analysis of NHTSA's Crash Test Repeatability Program," John M. Machey,

October 12, 1983.
111-64

Engineering analyses of the RTP indicate that these differences in vehicle

behavior have a significant effect on the dummy measurements, particularly

the driver dummy. There are many vehicle components that varied when

comparing all the vehicles in the RTP; e.g., steering column movement, belt

spoolout, structural member bending, and passenger compartment floor pan

buckling, all of which can contribute to varied dummy response results.

Specific examples are:

o The steering column angles were measured and varied from 21.5 degrees to

23.5 degrees.

o The dynamic crush ranged from 27.5 inches to 32.0 inches and the

permanent crush varied from 22.7 inches to 24.5 inches.

o An examination of a structural component, the engine cradle member,

revealed that different load paths developed during the crash event. In 10

out of 12 vehicles, the left member buckled at the engine cradle member

cutout, whereas, on the right side, only 6 out of 12 buckled at the cutout.

o Because of the range of driver HIC's that were recorded, and realizing

the importance of the steering column location at the time of driver

contact, the steering column assembly motion was analyzed photographically

and its motion recorded in the X-Z plan. Figures 1 through 3 graphically

demonstrate the movement of the steering column from the onset of the

crash (barrier contact) to the time of dummy contact with either the

steering wheel hub or rim.

111-66

o The driver and passenger HIC were examined separately. For the passenger,

less variability could be expected because no steering column is present to

influence dummy injury measurements. The pooled standard deviation for the

passenger HIC was 77 and the coefficient of variation (CV) was 11%;

approximately 50% less than the CV of 21% for the driver HIC. The average

passenger HIC ranged from 659 to 704 between laboratories and the average

driver HIC ranged from 596 to 699.

The irregular motion of the steering column and its location at the time of

dummy impact vastly affects the point and duration of contact of the driver

dummy's head with the steering wheel hub or rim and the velocity at which the

driver is moving forward. Obviously, this affects the resultant HIC. The

agency is conducting research on methods of reducing test variability due to

test site, test dummy, and test procedures. Clearly, however, it is the

manufacturers' responsibility to account for any test variability which may

be attributable to the test vehicle, and provide accordingly for adequate

allowances in the test criteria through design of the vehicle.

In comparing the Volvo (4 tests of the 1983 Volvo 760 GLE) and Citation data,

(Table III-6) it is evident that the Volvo data is a data set with lower

standard deviation than the Citation data.
111-67

Table III-6

1982 Chevrolet Citation 1983 Volvo 760 GLE

Driver Passenger Driver Passenger"

Mean HIC 655 694 898 731

Standard

Deviation 137 77 71 27

The agency tested a 1983 Volvo 760 in the 1983 NCAP and the driver and

passenger HIC's were 791 and 778, respectively. It should be noted that

the Volvo is a front engine, rear wheel drive vehicle, and the Citation is

a front engine, front wheel drive vehicle. The Citation experienced floor

deformation in the passenger compartment, whereas the Volvo's floor pan was

not buckled.

Another issue concerns the variation in test results at various crash

speeds. The above discussion concerns 35 mph frontal tests, whereas FMVSS

No. 208 would utilize a 30 mph test speed. An analysis of some 30 mph

frontal barrier crash data shown in Table III-7 illustrates means and

standard.

Table III-7

Vehicle

1972 Mercury, Air

Bags

1974-75 General

Motors Air Bags

1975 VW Rabbit.

Driver

Mean

478

418

917

HIC

Standard

Deviation

84

98

218

Passen

Mean

451

362

503

ger HIC

Standard

Deviation

72

101

177

Number of

Cars Tested

15

9

6

Passive Belts
111-68

deviations greater and less than the Citation data. The large standard

deviation in the 1975 VW Rabbit tests for driver HIC appears due to the

fact that the vehicles were not identical (four had non-collapsible

steering columns);the ambient temperature of the dummies varied by 40°;

and two of the vehicles were purchased as used cars, whose previous damage

history was unknown. Although these results do not demonstrate that test

speed has a more significant effect on variability than the other

components mentioned previously, one would expect greater variability at

higher speeds due to exceeding the strength of certain structural members.

More importantly, regardless of variability, if the mean is sufficiently

low then no problem or burden exists. For instance, if the mean is 500 for

HIC, then a ^+-20 percent COV is irrelevant to a manufacturer for assuring

compliance, as its vehicle will clearly always be below the 1000 threshold.

The important statistical factor to compare is the standard deviation,

which represents the variation in the data. The results for HIC obviously

demonstrate greater variation from one vehicle to another. The test

procedures, dummies, and instrumentation were similar in all tests;

however, the major difference in each series is the test vehicle. It is

not possible, however, to quantify the vehicle variability.

The claims made in a number of NPRM docket submissions concerning the

coefficient of variation in the RTP/NCAP and the Uniform Tire Quality

Grading System (UTQGS) are not relevant to FMVSS No. 208. (Since the

closing of the docket for the NPRM the courts have overturned the
111-69

57

suspension of the treadwear part of UTQGS.) The NCAP and

UTQGS are consumer information programs which provide relative performance

data to the public to aid in their purchasing decision. As a result, the

amount of variations among vehicles in the published data provide

information to those interested in determining the usefulness of comparing

one vehicle's data to another.

FMVSS No. 208, on the other hand, is a minimum performance standard, and as

such, it entails the design of a vehicle which will satisfy the test

criterion. In other words, it is a measure of compliance, not a continuous

rating scale. Thus, if a manufacturer knows that the variability of a

particular make/model is "X" percent, then that manufacturer must design

the vehicle to meet the FMVSS' performance criterion by making appropriate

allowance for such variances.

Several commenters to the SNPRM state that there is inherent variability in

vehicle crash test behavior, dummy behavior, and the test procedures.

However, they claim it inappropriate to require the manufacturer to

overdesign to all sources of variability. It is the agency's view that it

is normal design practice (i.e., it is not "overdesign") for a manufacturer

to account, in the vehicle's design, for variation in any

case where a specific test value must be met. The question is whether the

cost and difficulty of the design make it "practicable."

5 7 Public Citizen vs. Steed, District of Columbia Circuit, Case No. 83-1327

(April 24, 1984).
111-70

Figures II1-4 and 5 summarize the trend of driver and passenger HIC values

from NCAP tests of passenger cars from 1979 through 1984 to date. For 1983

and 1984, the mean HIC values are below 1000. It should be noted that

these mean values include a number of vehicles with HIC values of 2000 or

greater. This is quite remarkable considering that the NCAP tests are

approximately 36?o more severe58 than the 30 mph FMVS5 208 tests injury

criteria. Further, these vehicles are equipped with conventional manual

belts. Trends in NCAP test results for chest g's (See Figure II1-6) and

femur loads have also been downward. Since the program's inception, the

mean chest g's have been below 60. Also since 1981, over 90% of the

dummies in NCAP test vehicles have had chest measurements under 60 g's. In

the entire NCAP, only five femur measurements have-exceeded 2,250 pounds.

Tests run with air bags show much lower absolute HIC values (generally

about 400-500) and the levels of variation shown, even in the higher speed

NCAP program, appear to generally pose no compliance problem (compliance is

based on a HIC of 1000). That is, extraordinary quality control or

overdesign (and subsequent higher costs of production) are unnecessary to

assure compliance. It thus appears that manufacturers have considerable

flexibility for insuring that a vehicle would comply with a mandated 30 mph

requirement.

5 ° Crash severity is related to energy which a crashing vehicle is forced to

absorb. Since energy is a function of the square of velocity, the 35 mph

NCAP test is approximately 36% more severe than the 30 mph FMVSS 208 test:

[(35)2_(30)2]/(30)2=.36.


IV-1

IV. EFFECTIVENESS

Safety benefits are a function of both the usage of a restraint system and the

effectiveness of the system when used. Effectiveness of an occupant restraint

system is expressed as a percentage reduction in injuries or deaths for a

restrained occupant when compared to the situation when an occupant is

unrestrained. This section of the analysis considers the fatality and injury

reduction potential of occupant restraint systems used in the front seating

positions of passenger automobiles. The systems considered are present manual

belts (both lap belts and lap/shoulder belts), automatic belts, (both

two-point and three-point), air bags alone, air bags with lap belts, and air

bags with lap/shoulder belts.

After issuance of the NPRM (October 19, 1983), the agency assembled a task

force of NHTSA experts to analyze the available system effectiveness data for

the various restraint systems and to develop estimates of effectiveness to be

used in this FRIA. Table IV-1 shows the results of the work of this task

force; the rationale behind each of these estimates is presented subsequently.
IV-2

TABLE IV-1

SUMMARY OF EFFECTIVENESS ESTIMATES

Fatalities

AIS 2-5

Injuries

AIS 1

Injuries

Manual

Lap Belt

30-40

25-35

10

Manual

Lap/

Shoulder

Belt

40-50

45-55

10

Automatic

Belt

35-50

40-55

10

Air Bag

Alone

20-40

25-45

10

Air Bag

With

Lap Belt

40-50

45-55

10

Air Bag

With Lap/

Shoulder

Belt

45-55

50-60

10

NOTE: A knee restraint is assumed to be an integral part of all air bag

systems and some automatic belt systems.

Abbreviated Injury Scale

The severity of injuries is expressed in terms of the Abbreviated Injury Scale

(AIS). The scale used in this analysis is based on the following AIS 1976

definitions:
IV-3

AI5 INJURY LEVEL

0 No injury

1 Minor (e.g., simple cuts or bruises)

2 Moderate (e.g., simple fracture)

3 Serious (e.g., compound fracture or

dislocated major joints)

' 4 Severe (e.g., amputated limbs, depressed

skull fracture, survivable organ

injuries)

5 Critical (e.g., major spinal cord injury,

critical organ injuries)

6 Maximum, currently untreatable

While virtually all AIS 6 injuries and over 50% of all AIS 5 injuries result

in fatalities, it is not unusual for an AIS 3-4 injury to result in a fatality

to an elderly person or a person with special medical problems. Throughout

this report, fatalities will be considered separately from the non-fatal AIS

1-5 injuries.

A. Manual Lap and Lap/Shoulder Belts

Table IV-2 presents an analysis of data available in the National Crash

Severity Study (NCSS), the 1979 to 1982 National Accident Sampling System

(NASS), and a study called NCSS-NASS. NCSS-NASS was a special study by the

NCSS teams using the NASS forms; it was collected between April 1979 and March

1980. These three sources of data are combined and shown in the table as
IV-4

NCSS/NASS. Table IV-2 also presents data from an earlier study, the Restraint

System Evaluation Project (RSEP)1. Combining these data results in a

reasonably large sample of accidents from which effectiveness estimates can be

determined.2

The effectiveness estimates from the two sets of data are relatively close,

with the exception being lap belt fatalities, which is probably the result of

small sample size in RSEP. The results of the raw data in Table IV-2 are that

lap/shoulder belts are more effective than lap belts in reducing moderate to

fatal injuries; again, the exception is RSEP fatalities. These data are

considered "raw" data because they have not been "controlled" for various

factors. For example, an examination of the data shows that occupants wearing

lap or lap/shoulder belts were generally involved in less severe accidents, in

terms of damage extent zones and Delta V, than unrestrained occupants.

Delta V is the instantaneous velocity change during the impact. Delta V data

are shown in Table IV-3.

RSEP data in Table IV-2 include 783 more cars than were available when the

following reports were completed, and when the controlled estimates which

appear on page IV-7 were made, thus, the effectiveness estimates for the raw

data are slightly different between the two tables for lap/shoulder belts (59%

vs. 61%). "Fact Book: A Summary of Information About Towaway Accidents

Involving 1973-1975 Model Cars," Robert G. Hall, Highway Safety Research

Center, University of North Carolina, May 1976. "A Statistical Analysis of

Seat Belt Effectiveness in 1973-75 Model Cars Involved in Towaway Crashes"

Highway Safety Research Center, University of North Carolina, May 1976.

Data from the Fatal Accident Reporting System (FARS) are not utilized here for

two reasons: 1) FARS only includes fatal accidents, thus the number of

accidents which did not result in a fatality due to seat belt usage would have

to be estimated. 2) Restraint system usage in FARS is not considered as

reliable as in NCSS or NASS. In comments to the SNPRM, Volkswagen

(74-14-N35-046) disagreed with 1) above and provided a formula to calculate

effectiveness from FARS. However, the formula is sensitive to belt usage in a

potentially fatal accident. Given the Department's findings that belted

occupants are included in less serious accidents, one can not use a general

indication of belt usage (e.g. observed usage) as a proxy measure for belt

usage in potentially fatal accidents.
IV-5

TABLE IV-2

FRONT SEAT OCCUPANTS OF TOWED PASSENGER CARS

COMBINED RAW DATA OF

NCSS, NCSS-NASS, AND 1979-82 NASS

PLUS RAW DATA OF RSEP

WEIGHTED — UNKNOWNS DISTRIBUTED

NO INJURY

NON FATAL

AIS 1

AIS 2

AIS 3

AIS 4

AIS 5

FATALITIES

Tota l

AIS 1

AIS 2-5

FATALITIES

UNRESTRAINED

NCSS/NASS

68,696

57,952

8,624

3,602

858

276

1,290

141,298

41.0%

9.5%

0.91%

RSEP

4,232

4,371

840

202

34

7

75

Q T £_ *\

7 « /O 1

INJURY

44.8%

11.1%

0.77%

MANUAL

LAP BELT

NCSS/NASS RSEP

2,577 1 ,

1,654 1 ,

155

70

7

2

22

4*487 %

RATES IN TOWAWAY

36.9% 41

5.2% 7

0.49% 0.

345

107

152

23

9

2

6

W\

ACCIDENTS

.9%

.0%

23%

MANUAL

LAP/SHOULDER BELT

NCSS/NASS

5,026

3,133

187

95

18

8

32

8,499

36.9%

3.6%

0.38%

RSEP

2,307

1,684

153

32

4

2

14

2T7T9S'

40.1%

4.6%

0.33%

AIS 1

AIS 2-5

FATALITIES

CALCULATED EFFECTIVENESS

COMPARED TO UNRESTRAINED OCCUPANTS

10%

45%

46%

6.5%

37%

70%

10%

62%

59%

10%

59%

57%

TABLE IV-3

RESTRAINT USAGE RATES IN CRASHES OF GIVEN SEVERITY3

DELTA V (MPH)

1-10

11-20

21-30

31-40

41-99

NASS

9.5%

7.1

5.6

4.8

3.2

NCSS

10.2%

6.4

5.0

2.7

3.2

"Restraint Use and Effectiveness as Estimated From U.S. Accident Files and

Observational Survey" Van Dyke and Springer, NHTSA, November 1982.
IV-6

Another way to examine Delta V by restraint usage is shown below using NCSS

data.*

PERCENT OF PERCENT OF

UNRESTRAINED RESTRAINED

DELTA V (MPH) OCCUPANTS OCCUPANTS

1-10 50.b% 64.2%

11-20 39.6 30.6

21-30 7.5 4.4

31-40 1.7 0.5

41-99 0.7 0.3

TOTAL 100% 100

Since the effectiveness of belts is believed to be higher in the lower

severity crashes, the effectiveness estimates from the raw data would be

overestimated. One theory is that present belt wearers are a special set

of drivers who are more cautious and less prone to severe accidents. These

factors must be controlled for, since a mandatory seat belt use law or an

automatic belt requirement would result in a new set of belt wearers with

driving characteristics more like the average driver.

In the Restraint System Evaluation Project considerable statistical

analyses were performed by the contractor to control for four factors which

could bias the effectiveness estimates taken from the raw data. These four

factors were: age of occupant, accident severity, impact mode (front, side,

etc.), and size of car. The results were as follows for AIS 2 or greater

injuries, including fatalities.

"Effects Of Different Crash Severities for Restrained vs. Unrestrained

Occupants," Conrad Cooke, Engineering Systems Staff, NHTSA, 12/1/83.
IV -1

RSEP Raw Data

RSEP Controlled Estimate

EFFECTIVENESS

LAP BELT

39%

LAP/SHOULDER BELT

5735

While the agency did not control for all four of the variables in its

in-house, analysis of NCSS/NASS as was done by the contractor with the RSEP

data, a substantial effort went into assessing the impact of damage type

and accident severity on overall effectiveness. Accident severity by

impact mode was found to be significantly different between restrained and

unrestrained occupants.

Initially, the agency examined the impact that Delta V has on

effectiveness. Using the NCSS file, it was found that restrained occupants

were involved in less severe accidents to such an extent that the severity

of the accident by itself could explain most of the apparent fatality

effectiveness of restraints and nearly half of the apparent injury

effectiveness (see footnote 4 on page IV-6). Due to the large number of

cases of unknown Delta V in the file (55 percent of the cases have unknown

Delta V) , it was realized that Delta V, by itself, was not a good control

factor. This is especially true since Delta V is unknown in most rollover

accidents, where seat belts are particularly effective.

The agency then examined two other methodologies to control for accident

severity. The first methodology examined Delta V, when known, and the

collision deformation classification (CDC) or damage extent zone, when

Delta V was unknown, by crash mode using the NCSS data. The results of
IV-8

this analysis are adjustment factors for lap/shoulder belts of 28.4 percent

for fatalities and 18.0 percent for AIS 2-5 injuries. By breaking up the

accidents into 21 categories, this methodology has a problem with sample

size in the severe accident groups (Delta V > 30 mph and CDC > 5) ; thus the

results are somewhat tenuous. Using the formula: (1-Real Effectiveness) =

(1-0bserved Effectiveness)/(1-The Adjustment Factor), and applying this

formula to the NCSS/NASS data in Table IV-2, results in the following

controlled effectiveness estimates:

Manual Manual Lap/

Lap Belts Shoulder Belts

AIS 2-5 Injuries 375K 54

Fatalities 11% 43

The second methodology examines only the collision deformation classification by crash mode and damage extent.5 Three separate analyses were

performed using this methodology on the combined NCSS, NCSS/NASS, and NASS

files. First, unrestrained occupants were adjusted to match the frequency

of damage area and extent that were observed for restrained occupants. This

is the same methodology used in the two previous analyses discussed and

probably best represents the effectiveness for current belt users. Second,

the restrained occupants were adjusted to match the unrestrained occupants.

Third, the restrained and unrestrained occupants were each adjusted to

match the entire population of occupants, restrained and unrestrained.

These last two analyses were performed to see how effectiveness might

change if a mandatory belt use law turned a large proportion of current

non-users into belt users. The results are shown in Table IV-4. This

"Seat Belt Effectiveness Estimates Using Data Adjusted for Damage Type,"

Susan C. Partyka, Mathematical Analysis Division, NHTSA, January 1984.
IV-9

third analysis (restrained adjusted to all occupants) may best represent

the seat belt effectiveness for a group of current non-users who would

accept wearing belts.

Comparing the two right columns shows very little difference between these

two analyses. However, comparing the left column to the two right columns

indicates that restraints are more effective for current users than they

would be for current non-users since the current non-users tend to be in

more severe accidents, where belts are not as effective.

TABLE IV-4

EFFECTIVENESS AFTER ADJUSTMENT FOR CRASH SEVERITY

Lap Belts

AIS 2-5 Injuries

Fatalities

Lap/Shoulder Belts

AIS 2-5 Injuries

Fatalities

(.NC55, NCS5-NA55

Unrestrained

Adjusted to

Restrained

39%

21%

53%

52%

AND NA55;

Restrained

Adjusted to

Unrestrained

30%

22%

47%

38%

Restrained and

Unrestrained

Adjusted to

All Occupants

30%

22%

48%

39%

Finally, the third analysis - where restrained and unrestrained occupant

counts are both adjusted to reflect the damage distribution of the entire

population - was performed on RSEP alone, RSEP adjusted to NCSS/NASS, and

a combination of all of the previous files: RSEP, NCSS, NCSS-NASS and

NASS.6 Moreover, 90 percent confidence bounds were calculated for the

effectiveness estimates (by a technique that generates asymmetric bounds).

"Addendum to Seat Belt Effectiveness Estimates Using Data Adjusted for

Damage Type," Charles 3. Kahane, Office of Program Evaluation, NHTSA,

February 1984.
IV-10

The results, which are shown in Table IV-4a, employ the largest available

probability sample of accident data collected by the agency. Moreover, the

adjustment procedure, as explained in the report, makes RSEP data

comparable with the other files.

TABLE IV-4a

MANUAL BELT EFFECTIVENESS AFTER ADJUSTING FOR CRASH CONDITIONS

RESULTS OF COMBINING DATA FILES

BELT EFFECTIVENESS {%)

LAP BELTS ONLY LAP/SHOULDER BELTS

AIS 2-5 INJURIES

NCSS/NASS ONLY

RSEP ONLY

RSEP ADJUSTED TO

NCSS/NASS/RSEP

NCSS/NASS/RSEP

TASK FORCE

FINAL ESTIMATE

FATALITIES

NCSS/NASS ONLY

RSEP ONLY

RSEP ADJUSTED TO

NCSS/NASS/RSEP

NCSS/NASS/RSEP

TASK FORCE

FINAL ESTIMATE

BE51

ESTIMATE

30

30

26

22

25-35

22

75

72

37

30-40

9058

CONFIDENCE BOUNDS

20-50

16-37

16-46

13-42

-14 to +100

+50 to +93

+47 to +90

-39 to +100

BEST

ESTIMATE

48

53

50

46

45-55

39

55

48

49

40-50

9O5K

CONFIDENCE BOUNDS

38-61

45-61

42-58

40-54

24-67

30-77

23-70

37-68
IV-11

Having examined all of the results of the above analyses, the agency

believes that it is appropriate to rely on the controlled data more heavily

than the raw data in deriving an effectiveness range. The controlled data

give an indication of the direction and possible magnitude of the

adjustment, but the agency does not believe that the controlled data can be

used to pinpoint an exact effectiveness estimate. Instead, an

effectiveness range is seen as the best approach to estimating uncertain

variables. The final estimates of the agency are as follows: lap and

shoulder belts are estimated to reduce fatalities by 40-50 percent and AIS

2-5 injuries by 45-55 percent, with fairly narrow confidence bounds. Lap

belts are estimated to reduce fatalities by 30-40 percent and AIS 2-5

injuries by 25-35 percent, with substantially greater statistical

uncertainty. (See the 90% confidence bounds in Table IV-4a; lap belts have

a wider confidence bound than lap/shoulder belts mainly due to a smaller

sample size, see Table IV-2.)

Several SNPRM commenters, notably Ford (74-14-N35-065), Chrysler

(74-14-N35-036), Renault (74-14-N35-050), the American Seat Belt Council

(74-14-N35-044), and Professor Nordhaus (74-14-N35-079), argued that the

Department's effectiveness estimates for manual belts were too low.

Chrysler stated that the correct range should be 50-70 percent. Renault

stated that according to an analysis of accidents in France, effectiveness

is around 60 percent. Renault supplied a graph showing that Delta V for

unbelted occupants was only slightly higher than Delta V for belted

occupants and stated that belted drivers may feel better protected and

therefore drive faster. However, France has a much higher belt usage rate
IV-12

than the U.S. (see Table IV-4b; data used in the Delta V graph implied 39

percent belt usage). Professor Nordhaus stated that the Department

adjusted the effectiveness estimates too low. He apparently believes the

Department determined the level of adjustment by assuming that all of the

more severe accidents will involve restrained occupants, when no analysis

in the record predicts 100 percent usage. The Department considered this

very point raised by Professor Nordhaus and for that reason Table IV-4

includes the third column — restrained and unrestrained adjusted to all

occupants. This is one of the reasons the Department chose a range of

values for effectiveness.

Ford believes that the Department should rely on the combined

NCSS/NASS/RSEP data that indicate a confidence interval of 37-68 percent

for fatality effectiveness of manual lap/shoulder belts. Ford believes

this indicates a range of 50-60 percent effectiveness rather than 40-50

percent. The Department based its estimates on several analyses, rather

than just the one combined analysis cited by Ford, and took into account

the best estimates and confidence bounds derived from these analyses.

Ford further justified a 50-60 percent range by quoting B. 3. Campbell's

analysis of North Carolina State accident data (Safety Belt Reduction

Related to Crash Severity in Front Seated Position, HSRC-PR129, March 1984,

Docket No. 74-14-N35-065) which found a 62 percent fatality reduction for

belts even after the data had been controlled for differences in TAD Crash

Severity and other factors. Based on NHTSA's extensive experience in

statistically analyzing State data, as for example in the evaluation of
IV-13

several existing standards, the control variables available in state data

are inadequate for adjusting the populations for differences in crash

severity. In other words, analyses of State data using control variables

yield exaggerated effectiveness estimates. . In particular, the 62 percent

estimate in Campbell's study appears to be overstated. Another reason for

selecting the 40-50 percent range for manual lap/shoulder belt

effectiveness was because C. 3. Kahane's study of the potential

effectiveness of air bags and seat belts (Estimates of Fatality Reduction

for Air Bags and Lap/Shoulder Belts, February 1984), examined the

unrestrained front-seat occupant fatalities in NCSS and concluded that 51

percent of those fatalities were likely to have been prevented by belts.

Many of the other fatalities involved circumstances that would have

rendered any restraint system of little value.

Ford further stated that the actual data presented, historical literature

and the Campbell study, indicate lap/shoulder belts are more effective in

preventing fatalities than injuries, not the other way around as estimated

by the Department. The Department's conclusion that injury effectiveness

is 5 percentage points higher than fatality effectiveness for lap/shoulder

belts, was largely based on the NCSS/NASS adjusted data — the latest data

source — which show that AIS 2-5 injury effectiveness is 48 percent while

fatality effectiveness is 39 percent. The RSEP adjusted data indicate the

effectiveness is about the same. While it is true that many historical

estimates and the Campbell study indicate higher fatality effectiveness

than injury effectiveness, these studies are not typically comparable with
IV-14

this analysis because of the AIS 2-5 injury criteria used here. If AIS 1

injuries were included, fatality effectiveness for lap/shoulder belts would

be much higher than injury effectiveness.

The agency also examined the effectiveness of belts as derived from a

review of the experiences in a number of countries after implementation of

mandatory usage laws. Sufficient data are available to compute

effectiveness in 11 locations. The fatality effectiveness of belts ranged

from a low of 20 percent in Quebec, Canada, to a high of 77 percent in

Sweden. The 11 location average effectiveness was 47.1 percent. This

includes some unknown combination of lap belts and lap/shoulder belts,

although most of 'these countries required lap/shoulder belts as of the

early 1970's. While this appears to confirm the results of the NCSS, NASS

and RSEP studies, the agency did not consider these results in its final

determination of belt effectiveness. The agency has no way of verifying

the validity of the data or the statistical techniques employed in the

various locations. The details of the effectiveness computations for each

location are contained in Table IV-4b.
IV-15

TABLE IV-4b

SUMMARY OF MANDATORILY INCREASED SAFETY BELT USAGE EXPERIENCE

Location

Australia 1 >4

France 1>4

Belgium 4

Great Britain 6

Israel ^

Sweden 4,7

Switzerland 1

Canada, Ontario 3

Quebec 3

Saskatchewan '

British Columbia 3

Average all locations

Ref.

Use Rate

Before

30

26

17

40

6

36

32

24

20

13

23

(S)

After

80

75

92

90

70

79

81

58

37

50

50

Fatality

Reduction

(8)

22.5

22

39

24.5

43

46

12

13.7

3.5

21.7

24.2

Belt

Effectiveness

(8)

39.6

40.6

47.8

41.0

64.6

77

22.7

36.7

19.8

54.4

74.3

47.18

1. "Effectiveness of Safety Belt Usage Laws," Dr. Franklin B. Fisher, May

1980 (Peat, Marwick, Mitchell & Co.).

2. "Seat Belts: Effectiveness of Mandatory Use Requirements,"

Roger L. McCarthy, et al., SAE 840329, Failure Analysis Associates.

3. "The Effectiveness of the Canadian Mandatory Seat Belt Use Laws,"

Brian A. Jonah, Transport Canada.

4. "Task Force Report on Safety Belt Usage Laws," Livingston, et al,

NHTSA, 3une 1978.

5. "Patterns of Safety Belt Usage Following Introduction of Safety Belt

Wearing Law", Hakkart, A., Ziedel, D., Technion, Israeli Inst. Tech,

June 1983.

6. "Legislation for Seat Belt Use in Britain," Murray Mackay, University

of Birmingham, SAE 840328.

7. "Seat Belt Use in Sweden and Its Injury Reducing Effect," Hans Norin et

al, SAE 840194. Data on Volvo cars alone indicates a belt

effectiveness of 74.5%.

8. Calculated as follows: E = FR

Ua - TT-FRT

Where E = Effectiveness

FR = Fatality Reduction

Ua = Usage After the Law

Ug = Usage Before the Law
IV-16

For minor injuries (AIS 1), the NCSS/NASS data for towed cars in Table IV-2

indicate an effectiveness estimate of 10% for both lap and lap/shoulder

belts. An analysis of non-towed cars in the 1979-1981 NASS files indicates

about the same effectiveness for lap/shoulder belts (11%) as in towed cars

(10%). However, the effectiveness of lap belts in non-towed cars is -27%.

This is a rather implausible result since all other data indicate one is

safer with a belt than without one. Other sources of data indicate that

lap belts provide roughly the same effectiveness as lap/shoulder belts for

AIS 1 injuries. The RSEP (raw) data indicate lap belts are 6.5 percent

effective and lap/shoulder belts are 10 percent effective in reducing AIS 1

injuries. The combined NCSS/NASS/RSEP data adjusted for crash conditions

indicate both lap and lap/shoulder belts are 4 percent effective in

reducing AIS 1 injuries. A 1974 study of rural accidents in Pennsylvania

indicates for police reported B and C injuries (mostly minor injuries) that

lap belts are 23% effective and lap/shoulder belts are 21% effective.^

In general, the agency has less confidence in effectiveness estimates for

AIS 1 injuries than for more severe injuries due to reporting problems. Many

people don't report minor injuries or don't know they are injured until 'the

next day. While these reporting problems should not impact the relative

effectiveness of lap and lap/shoulder belts, there is some doubt about whether

the overall level of effectiveness is accurate.

Based on the data presented above, the agency estimates the effectiveness of

lap and lap/shoulder belts to be 10 percent in reducing AIS 1 injuries.

"Usage and Effectiveness of .Seat and Shoulder Belts in Rural Pennsylvania

Accidents," C. 3. Kahane, NHTSA, 1974, DOT-HS-801,398.
IV-17

B. Automatic Belts

The agency has five sets of data relating to automatic belt effectiveness.

They are: a) an update of a North Carolina study of state accident data b) a

NHTSA analysis of fatalities in the automatic and manual VW Rabbits; c) a

NHTSA analysis of fatalities in the automatic and manual Toyota Cressidas;

d) frontal crash tests of both automatic and manual belt systems; e) a

Transport Canada report which suggests some reasons why automatic belts may

not be as effective as manual belts.

a) The results of a study comparing the usage and effectiveness of VW

Rabbit belt systems in accidents are presented in Tables IV-5, IV-5a and

IV-6. These data are a further update of the material entered into the

docket in the effectiveness report accompanying the SNPRM. Since that

time, it was learned that there were some problems with the 1980-81 New

York data; corrections have been made to these data and new data for 1982

have been included. In addition, 1975-1979 data from the previous study8

for four states have been corrected using an updated vehicle identification

number (VIN) tape. These new data are all combined in Table IV-5.

Table IV-5 presents the number of serious plus fatal injuries (coded A+K on

the police reports) to front seat occupants of manual and automatic VW

Rabbits. The designation of automatic or manual belt is determined via the

VIN; belt usage is determined via the police report. One question

8 "A Comparison of Automatic Shoulder Belt/Knee Bolster Restraint System with

the Lap and Shoulder Belt Restraint System in VW Rabbits "Highway Safety

Research Center, University of North Carolina, March 1981, DOT HS-805-856.
IV-18

regarding the accuracy of the data is in the ability of the police to

determine accurately whether a belt is used and whether crash victims, when

asked, would provide accurate usage data.

Data are available on over 27,000 front seat occupants in police reported

accidents in the four states, New York 1975-82, North Carolina 1975 to part

of 1983,' Maryland 1975-82, and Colorado 1975-1979.

Table IV-5a presents the serious to fatal injury rates for the four states.

Three interesting points emerge from these data. One, the injury rates for

unrestrained occupants in manual restraint system cars is higher than the

unbelted injury rate in automatic restraint system cars in three of the

four states, although this difference is not statistically significant.

This could occur because a) the knee restraint in the automatic restraint

cars may have some effectiveness for unrestrained occupants, or b)

passengers of the higher priced automatic restraint cars (automatic

restraints were standard equipment on deluxe models of the Rabbit) may be

involved in less serious accidents. Two, when the restraint system is

used, manual belt cars have a lower injury rate than automatic belt cars in

all four states, but this difference is also not statistically significant

at the 95 percent confidence level. Three, combining restrained and

unrestrained occupants, automatic belt cars have a 17.3 percent lower

injury rate than manual belt cars in all states, due to higher usage of

automatic belts. Combining the four states, this 17.3 percent difference

in overall injury rates is statistically significant.
IV-19

The first point leads to a question concerning the appropriate basis for

determining the effectiveness of automatic belts. Taking the combined

results in Table IV-5a, for example, should the .0331 automatic belt

restrained injury rate be compared to the .0582 automatic belt car

unrestrained rate or to the .0629 manual belt car unrestrained rate?

Because the agency believes that the knee bolster has some effectiveness,

the latter comparison is valid and will be used in Table IV-6.

TABLE IV-5

NUMBER OF SERIOUS PLUS FATAL IN3URIES (A+K) TO

VW RABBIT FRONT SEAT OCCUPANTS BY RESTRAINT USE BY STATE

WITH KNOWN INJURY LEVELS AND KNOWN RESTRAINT USAGE

RESTRAINT

TYPE

Manual

Automatic

Manual

Automatic

Manual

Automatic

Manual

Automatic

Manual

Automatic

UNRESTRAINED

A+K NOT A+K

INJURED INJURED

496

108

169

48

156

30

93

22

914

208

NEW

I

TOTAL

RESTRAINED

A+K NOT A+K

INJURED INJURED

YORK 1975-1982

6,112 6,608

1,414 1,522

NORTH CAROLINA 1975 TC

82

64

) PART I

3,751 3,920 14

1,096 1,144 24

MARYLAND 1975-1982

2,832 2,988 29

652 682 37

COLORADO 1975-1979

917 1,010 12

206 228 10

COMBINED RESULTS

13,612

3,368

14,526

3,576

137

135

2,249

1,576

OF 1983

811

1,037

1,296

1,114

364

219

4,720

3,946

TOTAL

2,331

1,640

825

1,061

1,325

1,151

376

229

4,857

4,081
IV-20

TABLE IV-5a

A&K INJURY RATES

(SERIOUS PLUS FATAL INJURIES COMPARED TO TOTAL OCCUPANTS FOR

VW RABBIT FRONT SEAT OCCUPANTS BY RESTRAINT USE BY STATE)

RE5TRAINT TYPE UNRESTRAINED RESTRAINED OVERALL

NEW YORK 1975-1982

Manual .0751

Automatic .0710

NORTH CAROLINA 1975 TO PART OF 1983

Manual .0431

Automatic .0420

MARYLAND 1975-1982

Manual .0522

Automatic .0440

COLORADO 1975-1979

Manual .0921

Automatic .0965

HnMRTNFD RF5III T

Manual .0629

Automatic .0582

.0352

.0390

OF 1983

.0170

.0226

.0219

.0321

.0319

.0437

.0282

.0331

.0647

.0544

.0386

.0327

.0429

.0366

.0758

.0700

.0542

.0448

There is not a statistically significant difference between the

unrestrained injury rates of manual and automatic belt systems, or between

the restrained injury rates of the manual and automatic belt systems.

There is a statistically significant difference in the overall injury

rates, due to the higher usage of automatic restraints.
IV-21

TABLE IV-6

EFFECTIVENESS OF VW RABBIT MANUAL AND

AUTOMATIC BELT SYSTEMS IN REDUCING SERIOUS

TO FATAL INJURIES (A+K) WHEN USED COMPARED

TO UNRESTRAINED MANUAL BELT OCCUPANTSTM

New York 1975-1982

North Carolina 1975 to

MANUAL BELT

EFFECTIVENESS

53%

PERCENTAGE

AUTOMATIC BELT POINT

EFFECTIVENESS DIFFERENCE

48% 5

Part of 1983

Maryland 1975-1982

Colorado 1975-1979

Combined Result —

a) Aggregation of

b) Simple average

states

4 States

Injury Data

of the 4

61%

58%

65%

55%

59%

48%

39%

53%

47%

47%

13

19

12

811

12 12

Table IV-6 presents the effectiveness of the VW Rabbit automatic and manual

belts, when used, in reducing serious to fatal injuries. Manual belt

effectiveness is fairly consistent among the four states, ranging from 53

to 65 percent. Automatic belt effectiveness is also fairly consistent

between the states, ranging from 39 to 53 percent. (None of these State

data have been adjusted for differences in crash severity between the

restrained and unrestrained occupants. Thus, all estimates, especially

those for manual belts, are overstated.)

10 Combining restrained and unrestrained occupants, automatic belts (as used) are

17% more effective than manual belts (as used) due to higher restraint usage

of automatic belts.

11 Not a statistically significant difference.

12 Not a statistically significant difference.
IV-22

Since the agency will estimate automatic belt effectiveness based on a

comparison with manual belt effectiveness, it is important to note that the

difference in effectiveness ranges from 5 to 19 percentage points and the

combined results indicate a difference of 8 to 12 percentage points. The

combined results are examined in two ways: 1) using an aggregation of all

injuries from the four states, and 2) based on a simple average of the

effectiveness estimates from the four states. However, the state data do

not show statistically significant differences in effectiveness between

automatic and manual VW Rabbit restraint systems.

b) An August 1983 NHTSA analysis of Volkswagen Rabbit fatality data by type

of restraint system is presented in Table IV-7. Fatalities were categorized

using Vehicle Identification Numbers (VIN) and the FARS system. Exposure data

were developed from monthly sales data provided by Volkswagen and take into

account scrappage rates.

Since VW automatic belt usage is significantly higher than VW manual belt

usage, cars with automatic belts have a lower fatality rate than cars with

manual belts, the exception being 1980. Combining 1975 through 1982, the

fatality rates in cars with automatic belts (as used) compared to cars with

manual belts (as used) was 19.3 percent lower. A 90 percent confidence

interval, that is a 5 percent tail on either side, indicates the fatality

rate reduction is in the range of 11.0 to 27.6 percent. These percent

reductions reflect the combined effects of belt usage as well as

"effectiveness" when used, the subject of this chapter. The yearly
TABLE 1V-7

V¥ RABBIT FATALITY DATA BY TYPE OF RESTRAINT SYSTEM

(FRONT SEAT OCCUPANT)

MANUAL RESTRAINT SYSTEM AUTOMATIC RESTRAINT SYSTEM

ACCIDENT

YEAR

1975

1976

1977

1978

1979

1980

1981

1982

FATALS

16

29

70

82

124

116

153

121

EXPOSURE

(MILLION

CAR MONTHS)

0.4734

1.457

2.659

3.905

5.401

6.587

7.797

8.776

FATALITY

RATE

33.8

19.9

26.3

21.0

23.0

17.6

19.6

13.8

FATALS

0

4

5

25

41

64

67

48

EXPOSURE

(MILLION

CAR MONTHS)

0.1786

0.4341

0.8154

1.361

2.135

3.173

3.942

4.384

FATALITY

RATE

0

9.2

6.1

18.4

19.2

20.2

17.0

10.9

RESTRAINT

SYSTEM

UNKNOWN

FATALT

0

0

6

4

11

10

12

13

AUTOMATIC BEL

EFFECTIVENESS

COMPARED TO

MANUAL BELTS

AS USEO, (X)

100.0*

53.7

76.7

12.4 ,

16.5

-14.8

13.3

21.0

1975-82 711 37.055 19.2 254 16.423 15.5 19.3

CO

SOURCE: Internal NHTSA Analysis
IV-24

differences in fatality rates show the great variability and uncertainty in

these types of accident statistics. For example, if this analysis had been

done in 1978, using 1975-1977 data, cars with automatic belts would have

been estimated to have an occupant fatality rate 75 percent lower than cars

with manual belts, instead of the 19.3 percent for 1975-1982. However,

taken together these data represent a large fleet of cars and the results

are statistically reliable.

Table IV-8 shows the difference in automatic and manual belt usage from

three separate sources; observations of belt usage in traffic (48

percentage points), state accident data (28 percentage points), and

telephone surveys (42 percentage points). Observed data are believed to be

more reliable than either telephone surveys or police reported state

accident data. As discussed in Section V, one study documented that people

overstate their actual belt usage in telephone surveys. Police reported

usage data is based on after-the-fact police judgment, witness reports, or

accident victim self reporting. None of these are as definitive as actual

observations. However, restraint usage in accidents and effectiveness are

the measures which impact safety benefits.
IV-25

Table IV-8

AUTOMATIC VERSUS MANUAL BELT USAGE

FOR VW RABBITS

Observed Usage

1977-7913

1980-8214

11/82-3/83

5/83-10/83^

1977-83 Average

Observed Usage

Accident Data16

1975-82 New York

1975-83 North Carolina

1975-82 Maryland

1975-79 Colorado

Automatic

Usage (%)

81

86

80

J75

80

52

48

63

50

Number

of

Observations

401

304

240

398

1,343

3,162

2,205

1,833

457

Manual

Usage (V)

36

28

28

21

32

26

17

31

27

Number

of

Observations

1,049

687

552

1,092

3,380

8,939

4,745

4,313

1,386

Percentage

Point

Difference

in Usage

45

50

52

44

48

26

31

32

23

Average Accident Data

Telephone Surveys'?

MY's 1978-79

MY 1980

Average Telephone

Survey

53

89

89

89

7,657

1,010

1,013

2,023

25

46

48

47

19,383

203

222

425

28

43

41

42

13 Opinion Research Corporation, "Safety Belt Usage Among Drivers," May 1980,

DOT-HS-805-398, pg.30.

1^ Opinion Research Corporation, "Restraint System Usage in the Traffic

Population." May 1983, DOT-HS-806-424, collected November 1980 to October

1982.

15 1983 data collected by Goodell-Grivas, Inc.

1

6 Collected for NHTSA by HSRC, see Table IV-5.

1? Opinion Research Corporation, "Automatic Safety Belt System Owner Usage and

Attitudes in GM Chevettes and VW Rabbits, May 1980 and February 1981,

DOT-HS-7-01736.
IV-26

Using the three different sources of automatic and manual VW restraint

usage from Table IV-8, the fatality rate of automatic belts as used

compared to manual belts as used, and the estimate that manual belts when

used are 45 percent effective in reducing fatalities (the mid-point of the

range shown in Table IV-1), then a formula for fatality effectiveness of

the VW automatic belt system when used compared to unrestrained occupants

can be determined.18 In this instance, the VW Rabbit automatic belt

effectiveness for fatalities, compared to unrestrained occupants, would be

39 percent if the usage rates found in observation surveys are inserted in

the effectiveness formula, 41 percent if the usage rates obtained from the

telephone survey are inserted, and 54 percent if the usage rates reported

in the accident data are employed. Thus, the automatic VW Rabbit restraint

system, when used, is estimated to be 39-54 percent effective in reducing

fatalities compared to unrestrained occupants.

c) The agency examined the fatalities in Toyota Cressidas with automatic and

manual belts. Between 1977 and 1980 over 37,000 manual belt Toyota Cressidas

were sold. In 1981 and 1982, over 67,000 automatic belt Toyota Cressidas

were sold. The following table presents the number of fatalities, estimated

exposure, and fatality rate by system.

18 Fa

 = ] ~ Ha .

Ea

Fin 1 - Urn Em

Where F = Fatality Rate, U = Usage Rate,

E = Effectiveness, a = Automatic Belts,

m = Manual Belts
IV-27

Toyota Cressida

Manual Automatic

Belts Belts

1977-1982 Fatalities 29 . 8

Estimated Car Months 1,609,286 560,766

Fatality Rate Per 18.0204 14.2662

Million Car Months

The Toyota Cressida data indicate that automatic belt cars have a lower

fatality rate (20.8% lower) than the manual belt cars.. Automatic belt

effectiveness compared to unrestrained occupants can be roughly estimated

at 40 percent using these fatality rates and belt usage.19 This is

considered a rough estimate because there are few fatalities in the

automatic and manual belt cars, due to limited exposure through 1982,

making the estimates statistically suspect, and the usage estimates for

comparable manual belts were not adequate. Observed usage of automatic

Cressidas (96% usage) is based on 203 observations and agrees very well

with a telephone survey20 that found 92 percent usage. However, the agency

has no specific data on manual Cressida belt usage. Observed data are

available on all Toyota manual belt models (195K usage). This '\9% may be a

low estimate for Cressidas, because they are one of the highest priced

Toyotas and belt usage has been shown to be related to income level. On the

other hand, the telephone survey found 45 percent usage for Toyota Coronas

(manual belt). The 40 percent effectiveness estimate is calculated based

19 14.2662 = 1- (.92)(x)

18.0204 1-(.45)(.45); x=4O5S Effectiveness. One reason that the Toyota

Cressida automatic belt may not be as effective as the manual belt (when used)

is that automatic belt users may not connect the manual lap belt that is

provided with the automatic system.

2 0 "Automatic Safety Belt Usage in 1981 Toyotas," JWK International Corporation,

February 1982, DOT-HS-806-146.
IV-28

on the results of the telephone survey and is a high estimate if the 45

percent manual usage is overestimated. Because of these problems, the 40

percent effectiveness estimate must be considered a very rough estimate.

d) The agency examined the crash tests it has recently performed on automatic

and manual VW Rabbits and Chevrolet Chevettes at 30 mph. These are shown

in Table IV-9. In these frontal crash tests, the automatic restraints

performed better than manual restraints, in terms of lower Head Injury

Criterion (HIC) (HIC is an indicator of the possibility of head injury).
IV-29

TABLE IV-9

VW RABBIT AUTOMATIC VS. MANUAL

30 MPH TEST RESULTS

SYSTEM

Automatic

Automatic

Automatic

Manual

Manual

MODEL

YEAR

1976

1976

1976

1976

1978

CRASH

SPEED

29.3

29.3

30

30

29.58

HIC

DRIVER

604

542

452

1,433

1,552

VALUES

FRONT

PASSENGER

444

255

225

518

661

CHEST G

DRIVER

37

-

40

42

59

•s

FRONT

PASSENGER

31

-

31

43

42

CHEVY CHEVETTE AUTOMATIC VS. MANUAL

30 MPH TEST RESULTS

Automatic21

Manual

Manual

1978

1976

1976

30

28.3

30

475

922

1,024

450

797

936

47

47

43

43

33

43

e) Transport Canada released a paper,22 wn ic h included a discussion which

implies that automatic belts may not be as effective as manual 3-point

belts. For the 2-point automatic belt system and knee bolster, the absence

of a lap belt may result in the 2-point belt being less effective in

preventing ejection. Also, it was claimed that the door mounted belt might

have little capability of restraining an occupant in the event of

accidental door opening during a collision. The agency has performed an

analysis which examines passenger car occupant partial and total ejection

2^ Manual Lap Belt was not attached.

22 "Transport Canada's Policy on Occupant Restraints," G.D. Campbell and E.R,

Weibourne, Transport Canada, June 1981.
IV-30

fatalities through doors.23 In the 1979 FARS file, there are 27,799

passenger car occupant fatalities, of which 6,190 (22 percent) involved

ejection. The FARS files do not record the ejection route, however, the

NCS5 file does. There are 910 fatalities in NCSS of which 210 (23 percent)

involved ejection. Thus, the NCSS file has about the same percent of

ejection fatalities as the FARS file (23 percent vs. 22 percent). Of the

910 NCSS fatalities, 32 (3.5%) were drivers ejected through the left front

door and 13 (1.4 percent) were right front passengers ejected through the

right front door. The agency does not know how effective the 2-point

shoulder belt might be in preventing ejections. If it is assumed that the

2-point system is not effective, then 1,390 ejected fatalities (27,799x4.9

percent) might have been saved if a 3 point manual belt had been used.24 Of

course, the 3-point manual belt would not have prevented all these

fatalities since some fatalities occur as the result of impacting interior

components (side door, armrest, pillars, etc.) before the ejection, while

others occur as a result of occupant contact with objects outside the

vehicle after partial ejection. It should also be pointed out that the

door mounted belt may actually prevent door openings in many instances

because the retractor will lock up on the belt, not allowing it to spool

out, and thus help to hold the door closed. Further, some motorized

automatic belts (e.g. Toyota Cressida) are not attached to the door but

have anchorages on the B-pillar, the same as manual lap/shoulder belts.

"An Analysis of the Ejection Problem Using NCSA Automated Data Files," Nancy

Bondy and Sharon Hart, NHTSA, Dune 1982.

This calculation assumes all cars would have been equipped with 2-point

automatic belts.
IV-31

Transport Canada also suggested that the advantage of eliminating lap belt

abdominal injuries by using a knee bolster instead of a lap belt may be

offset by less control of occupant displacement in collisions involving a

significant transverse component of acceleration. For 3-point automatic

belts, Transport Canada concluded that there is little reason to believe

the effectiveness should not be essentially the same as for 3-point manual

belts, except in cases where the anchorage points on the door are outside

the geometrical zones prescribed by FMVSS 210. It should be noted that

NHTSA has provided a waiver from FMVSS 210 if manufacturers meet the

barrier crash test criteria for automatic protection requirements of FMVSS

208. However, Transport Canada's testing indicated less effective control

of the dummy and markedly higher chest loads.with the automatic 3-point

system.

There were several comments to the docket which compared automatic to

manual belt effectiveness, or compared detachable to non-detachable belt

effectiveness. British Leyland (74-14-N32-5296) and Renault

(74-14-N32-1165) both stated that two-point automatic belts are less

effective than manual lap/shoulder belts in side impacts and rollovers.

Renault also stated that three-point automatic belts afford unsatisfactory

protection in frontal impacts.

The Insurance Institute for Highway Safety (74-14-N35-022) stated that

automatic belt effectiveness was downgraded because of the hypothetically

possible increase in the chance of ejection, when no statistical or other

evidence supports this assumption about ejection. Further, IIHS argues the

Department ignores crash test data that indicate automatic belts might
IV-32

reduce head injuries more than manual belts. The Department based the

lowering of automatic belt effectiveness on the state data that indicate

automatic belts are probably less effective than manual belts and on the

possibility that automatic restraint designs without the lap belt may not

be as effective in side impacts and rollovers — particularly when

ejections are involved. The Department did consider the test data that

indicate automatic belts are as effective or possibly more effective than

manual belts in frontal impacts. However, the state data, which include

all accident modes, still indicate that automatic belts may be less

effective than manual belts. The Department cannot be precise about this

issue until additional field data are available.

Professor Nordhaus argues that the only reliable data the Department should

consider in determining automatic belt effectiveness is the analysis of VW

fatalities and the crash tests. Together, these indicate automatic belt

and manual belt effectiveness should be equivalent. He believes the usage

figures and effectiveness values from the state data, which are dependent

upon the accurate characterization of restraint usage, should be

disregarded. However, the Department fails to see a convincing reason why

automatic belt usage would be mischaracterized any more than manual belt

usage. Thus, the Department believes that the comparison between automatic

and manual belt effectiveness rates remains valid for the state data.

Nordhaus also claims that Transport Canada "concluded" that the

effectiveness of 2-point automatic and 3-point manual belts were

consistent. It is difficult to see how this observation by Transport

Canada is a conclusion. Professor Nordhaus has omitted the first part of
IV-33

the quote, printed here in its complete form. "Although these data [recent

VW Rabbit accident data] do not permit a direct comparison of the

effectiveness of the two systems, the fatality rate in vehicles equipped

with the automatic system is consistent with an effectiveness at least

equal to that of the 3-point belt system" (emphasis added). Transport

Canada's conclusions are evidenced by their statement preceding the

referenced quotation that "the effectiveness of the 2-point automatic belt

is lower overall than that of the conventional 3-point belt system." The

agency does not believe that referencing partial quotes, taken out of

context, can alter the clearly stated conclusions of Transport Canada.

Ford (74-14-N35-065) argued that there is the potential for lower

effectiveness with automatic belts. Ford questions the premise that

3-point automatic belts will be as effective as manual belts, saying there

is no adequate body of data to justify this conclusion; their comment

pointed out also that manual belts can be more securely adjusted than

3-point automatic belts. In addition, Ford discussed the "danger of

attempting to estimate system effectiveness solely from controlled crash

data" by comparing the favorable automatic belt crash tests with the higher

observed injury rates in the state data for the automatic restraint VW

Rabbit versus the manual restraint VW Rabbit.

Volvo (74-14-N30-047) argued that non-detachable automatic belts may be

less effective than detachable automatic belts due to a "film spool

effect." This "film spool effect" may occur in 2-door models if the amount

of webbing in the non-detachable automatic belt must be increased to allow

entrance to the rear seat.
IV-34

NADA (74-14-N32-1680) indicated its concern that a belt fastened to the

door may possibly be less effective than manual lap/shoulder belts. VW

(74-U-N32-1678) and State Farm (74-14-N32-5295), quoting the earlier North

Carolina Study, stated that they believe automatic belts are as effective

as manual lap/shoulder belts. However, none of the above commenters

provided new data to substantiate their statements.

Another issue brought out in the docket comments distinguishing detachable

belts from non-detachable belts is post-accident ease of getting injured,

immobile, belted occupants out of a car. Volkswagen stated that they

specifically designed their automatic belts to have the emergency release

button near the window so that persons assisting an injured belted occupant

could easily find and detach the belt and would not have to reach in,

across the occupant, to release the belt as is the case in today's cars

with manual belts. While the spool-out release mechanism on a

non-detachable belt allows the belt to be elongated and pushed out of the

way, there may be some cases where the belt needs to be cut in order to

extract an injured occupant; also, the spool-out release may be confusing

to those who are not familiar with it. However, the Department does not

believe that this post-accident ease of detachability is a significant

factor.

In conclusion, the effectiveness of automatic belts is less precisely known

than is the effectiveness of manual belts. Most of the agency's data are

on one type of automatic belt system (a two-point belt with a knee

bolster). Some manufacturers may use a 3-point automatic lap-shoulder belt
IV-35

design or a 2-point automatic belt with a manual lap belt that will be worn

by some occupants (based on prior data submitted to NHTSA). Given the

uncertainty regarding actual restraint usage in accidents, the agency can

not precisely estimate the effectiveness, when worn, of the VW Rabbit

automatic belts, compared to unrestrained occupants. The North Carolina

study indicates the VW automatic belt may be less effective than the manual

belt for serious to fatal accidents, however, these differences are not

statistically significant. Assuming manual lap/shoulder belts are 45

percent effective, the agency's analysis of VW Rabbit occupant fatalities,

coupled with various estimates of automatic and manual belt usage,

indicates a fatality effectiveness range of from 39 to 54 percent - i.e.,

about the same as manual belts. Based on these studies and the possibility

that the two-point automatic belt may not be as effective as a manual

lap/shoulder belt in side impacts and rollovers, the agency believes that

two-point automatic belts may be 5 percentage points less effective than

lap/shoulder belts. The agency has no data on 3-point automatic belts or

the extent of manual lap belt usage with 2-point automatic belts. The

agency believes that both the 3-point automatic belt and the 2-point

automatic belt, when a manual lap belt is used, may be as effective as

manual lap/shoulder belts. Thus, the agency's estimate of automatic belt

effectiveness for fatalities is 35-50 percent, and for AIS 2-5 injuries is

40-55 percent. These are the same ranges as for manual lap/shoulder belts

except that the low end of the range has been lowered by 5 percentage

points.
IV-36

The agency has no specific analyses on the effectiveness of the automatic

belt system for AIS 1 injuries. The agency sees no reason why the

effectiveness of automatic belts should not be equivalent to the effectiveness

of the manual 3-point belt for AIS 1 injuries (10 percent).

C. Air Bag

As shown in Table IV-1 the agency is now estimating air bag alone (without

belts) effectiveness as 20-40% for fatalities and 25-45% for AIS 2-5

injuries. Although the ranges are similar to those used in the Preliminary

Regulatory Impact Analysis (PRIA), the current ranges are based principally

on new analyses which the agency has conducted subsequent to the

publication of the PRIA. The following sections will discuss these new

analyses as well as previous estimates, new computation of effectiveness

from ACRS field experience and other issues related to the effectiveness of

air bags.
IV-37

1. Historical Estimates of Effectiveness

In 1974, the agency estimated air bag effectiveness as follows:^

1974 AIR BAG EFFECTIVENESS ESTIMATES

(FULL FRONT SEAT)

IMPACT

MODE

Frontal

Side

Rollover

Rear

Combined

effectiveness

by probability

occurrence

FATALITIES

AIR BAG

WITH LAP BELT

57%

45

50

0

45%

weighted

of

AIR BAG

ONLY

57%

20

15

0

32%

INJURIES

AIR BAG

WITH LAP BELT

64%

40

50

0

39%

AIR BAG

ONLY

64

25

15

0

30%

The effectiveness estimates assumed that air bags would be effective in

frontal impacts up to 35 mph. The effectiveness estimates for side,

rollover, and rear end impacts were based on engineering judgment. It was

also assumed that lap belt usage with air bags would be 60 percent — the

level observed for manual belts with interlocks in 1974.

The agency estimated that 12,000 lives would be saved annually by air bags.

Since seat belts were already saving 3,000 lives a year at that time, the

incremental life savings for air bags over seat belts was 9,000. This

9,000 estimate persisted in later work, even after the substantial

reduction in fatalities brought about by the 1974 energy crisis and the 55

mph speed limit. It was argued by NHTSA that the 1974 national fatality

decrease resulted mainly from a decrease in the number of most severe

accidents, for which no air bag effectiveness was claimed; thus air bags

25

"Analysis of Effects of Proposed Changes to Passenger Car Requirements of

FMVSS 208," NHTSA, August 1974, Docket No. 74-14-N01-104.
IV-38

would have a higher overall effectiveness for the remaining fatal

accidents. However, fewer occupant fatalities also occurred on roads with

lower speed limits and fewer pedestrians were killed, two categories for

which high speed travel was irrelevant. Thus, some reduction, of

undetermined magnitude, in air bag benefits would be expected.

Another factor that led to an increase in estimated air bag effectiveness

after 1976 was the results of the Restraint System Evaluation Project. The

high levels of effectiveness for seat belts, and the belief that air bags

were yet more protective, led the agency to believe that a higher level of

effectiveness should be ascribed to air bags. Further, the agency's

research in air bags was producing systems capable of restraining occupants

in 40 to 45 mph frontal crashes, even in some smaller car sizes.

Finally, given the overall number of passenger car occupant fatalities in

1975-76 and the reduction in seat belt usage, a 40 percent effectiveness,

instead of the previous 32 percent, was attributed to air bags without lap

belts. An estimated 9,000 incremental lives were still saved. In 1977,

the following estimates of air bag effectiveness were published:^

1977 AIR BAG EFFECTIVENESS FOR

AIS 4-6 IN3URIES

Impact Mode

Frontal

Side

Rollover

Rear

Combined effectiveness weighted

by probability of occurrence

Air Bag

with Lap Belt

77S!

50

65

15

66

Air Bag

Only

65%

16

5

10

40

"Standard No. 208 — Passive Restraint Amendment, Explanation of

Rulemaking Action," NHTSA, July 1977, Docket No. 74-14-N10-011,

DOT-HS-802-523.
IV-39

Comparing the 1977 to the 1974 estimates, shows that 1) in 1974, frontal

impact effectiveness was assumed to be the same for air bags with and

without lap belts — this assumption was changed significantly for 1977;27

2) the 1977 effectiveness for side impacts and rollovers went up for air

bags with lap belts, but down for air bags only; 3) in 1977, an

effectiveness level was assumed for rear impacts, where no estimate was

made for rear impacts in 1974. Overall, effectiveness was assumed to be 25

percent higher ((40-32)/32) for air bags only and more than 40 percent

higher ((66-45)/45) for air bags plus lap belts. All these estimates were

based on accident data for belted and unbelted occupants, laboratory

results, some favorable field accidents with air bags, and engineering

judgment.

Table IV-10 shows the 1977 effectiveness estimates, average AIS 2-5 injury

effectiveness estimates weighted by 1982 injuries,28 and average overall air

bag effectiveness, assuming 1983 driver belt usage of 14.0 percent would

continue with air bag cars. Using the 1977 analysis, average air bag

effectiveness for fatalities is 44 percent and for AIS 2-5 injuries is 26

percent for drivers. It is slightly less for the other front seat

passengers.

27

Economic Impact Assessment, Amendment to FMVSS No. 208, Occupant Crash

28 Protection," NHTSA, July 1977, p, 43.

Calculated as follows — for example for air bags only — of all AIS 2-5

injuries, 76.7 percent are AIS 2, 19.6 percent are AIS 3, 2.5 percent are

AIS 4, and 1.2 percent are AIS 5. Thus,

(76.75Kx22)+(19.6Xx30)+(2.5SJx40)+(1.2%x40)=24.2 rounded to 24 percent. This

calculation weights air bag effectiveness by the percent of injuries.
IV-40

TABLE IV-10

AIR BAG EFFECTIVENESS ESTIMATES*9

FROM THE 1977 ASSESSMENT FOR INJURIES

AIS

INJURY

LEVEL

1

2

3

4

5

AIR BAG

0%

22

30

40

40

AIR BAG

WITH

LAP BELT

15&

33

45

66

66

AIS 1

AIS 2-5

Average

effectiveness

weighted by 1981

number of AIS 2-5

injuries

Fatality

effectiveness

2. Field Data

AVERAGE AIR BAG EFFECTIVENESS

ASSUMING CURRENT LAP BELT USAGE

Air Bag

Air Bag With 14.0 Percent

Only Lap Belt (Driver)

24%

40K

5.0 Percent30

(Front Cntr)

265

8.4 Percent

(Front Right)

1

26%

Air bag cars in use consisted of manufacturers' test fleets of 831 1972

Mercurys, 1,000 1973 Chevrolets, and 75 1975 Volvos. In addition, 10,281

1974-76 Buicks, Oldsmobiles, and Cadillacs were sold to the public, for a

total of 12,187 air bag cars in the fleet. The agency has attempted to

keep track of fatalities and injuries in these vehicles and in a national

population of approximately equivalent cars with manual belts. While early

29,_ Compared to unrestrained occupants.

Opinion Research Corporation "Restraint System Usage in the Traffic

Population," May 1983, DOT-HS-806-424, and "Progress Report on Restraint

System Usage in the Traffic Population," Goodel Grivas, Inc., January 1984.
IV-41

estimates of effectiveness were developed in 1976-77 using field data,

there were so few cars equipped with air bags and so few cases of serious

or fatal injuries that the results were meaningless. Even today, there are

so few cases that the results have little statistical meaning.

In 1979 and 1980, the agency published analyses of air bag effectiveness

based on field data.^ In the 1979 report, the agency compared air bag

equipped car fatalities (five fatalities were known at that time) to a

national population of equivalent cars. The results were that air bags

were 41 percent effective in reducing fatalities compared to unrestrained

occupants.

A second analysis performed in 1979 and updated in 1980 compared air bag

fatalities and injuries to a sample of GM cars weighing more than 4,000

pounds found in NHTSA's National Crash Severity Study (NCSS) file. At that

time, there were six known air bag fatalities. Air bag effectiveness

compared to unrestrained occupants was 54 percent for fatalities, 56

percent for AIS 3-4 injuries, and 43 percent for AIS 2 injuries.

New data would necessitate a recalculation of these estimates. Based on a

vehicle identification number (VIN) search of the FARS file, we now know

there were seven fatalities in air bag equipped cars as of December 1978,

rather than the five fatalities used in the 1979 analysis or the six

fatalities used in the 1980 analysis. These additional fatalities would

"Occupant Protection Program Progress Report No. 2," NHTSA, April 1979,

pp. 10-11.

"Automobile Occupant Crash Protection, Progress Report No. 3," NHTSA, Duly

1980, p. 85.
IV-42

have lowered the previously stated effectiveness estimates for the air bag

fleet cars. However, rather than present recalculations of past analyses,

the agency will present its latest analysis, using the most up-to-date data

available.

The Preliminary Regulatory Impact Analysis contained a table comparing the

fatality rates for both the manufacturers' test fleets and the publicly

purchased 1974-76 Buicks, Oldsmobiles, and Cadillacs (ACRS cars). The

experience with the manufacturers' 1972 and 1973 model test fleets (which

have experienced a total of four front-seat fatalities, including two since

the publication of the Preliminary Regulatory Impact Analysis) is being

discounted in this final regulatory impact analysis for several reasons:

1. Many of the air bag systems were prototypes and not representative of

anticipated production systems.

2. Many of the air bag systems were removed during the lives of the

vehicles, complicating exposure calculation.

3. Many vehicles were fleet vehicles and thus underwent an exposure very

different from typical privately owned vehicles (e.g., some of the vehicles

were police vehicles).

The agency has refined its estimates of exposure for the 1974-76 ACRS

equipped cars by utilizing detailed R.L. Polk data to calculate precise

scrappage rates for each of the equivalent make/model combinations in the

ACRS fleet. The agency now knows of ten front seat fatalities which have
IV-43

occurred in the ACRS fleet (as well as four in the manufacturers' test

fleets). Two additional fatalities have occurred since publication of the

Preliminary Regulatory Impact Analysis. Using the refined estimates of

exposure through 12/31/83 and the total front seat fatality count of ten,

the computed air bag effectiveness over regular belt systems as used is now

0 percent as compared to 16 percent in the Preliminary Regulatory Impact

Analysis. (If the test fleets had been included in the calculation, the

effectiveness estimate would have been negative.)

It should be noted that the latest statistical analysis of air bag

fatalities differs from other effectiveness estimates in the chapter in

that it compared all fatalities in air bag cars (including some belt users)

to all fatalities in the control group cars (including some belt users) -

as opposed to "air bag only" versus "unrestrained only." The reason for

this approach was analytic simplicity. It was considered appropriate given

the sparse data on air bag fatalities and problems with unknown safety belt

usage in FARS. It is recognized that the results are not identical to "air

bag only" versus "unrestrained" but the bias should be negligible in

comparison to the -70 to +46 percent confidence bounds due to sampling

error. Further, the benefits of belt usage in the control group are offset

by approximately equal benefits of belt usage in the air bag cars, so the

bias is a second order effect.
IV-44

TABLE IV-11^2

Front Seat

Fatalities

In All

Accidents

10

1,527

Estimated

Exposure

In Car Years

84,008

12,784,000

Fatality Rate

Per Thousand

Car Years

Air Bag

Effectiveness

Over Regular

Belt Systems

As Used

0.119 OSi

0.119

ACRS

National

Population^

of Equivalent

Cars with

Regular Belts

However, even today after 3 more years of exposure, this 0 percent

effectiveness figure has little meaning for a number of reasons:

1. Because of the relatively small sample size, a 90 percent confidence

interval indicates that the effectiveness could be anywhere in the range of

-70 to +46 percent. Thus, the field data are not statistically meaningful

except as supporting evidence for the studies described below which

indicate that effectiveness is unlikely to be on the order of 50 percent or

more.

2. Small changes in the number of air bag fatalities cause drastic changes

in effectiveness estimates. This is further proof that there are too few

air bag cars in the fleet to provide an effectiveness estimate which can be

viewed with confidence:

32 This analysis only includes front seat occupants. It should be noted that

there have been cases where children have been thrown from the rear seat to

, the front seat and have been saved from serious injury by an air bag.

24 Fatalities and exposure through 12/31/83.

Fatalities based on FARS, 1975-81. Exposure based on Polk registration

data Ouly 1, 1975-81.
IV-45

If Air Ba

Had

8

9

10

11

12

ig Fatalities

Been:

(currently

known)

Observed

Air Bag

Effectiveness

Would Be:

20

10

0

-10

-20

90 Percent

Confidence Bounds

Would Be:

-43% to + 60%

-51% to + 5255

-70S to + 46%

-82% to + 38%

-94% to + 30%

3. The effectiveness estimate is "air bags as used" versus "manual belts

as used," not "air bag only" versus "unrestrained." In the ACRS fleet,

there was 17 percent usage of lap belts, while 83 percent of the occupants

were protected by the air bag alone. In the control group of equivalent

1974-76 cars, there was exceptionally high seat belt usage during the first

few years, because many of the cars were equipped with the starter

interlock system. In order to estimate the effectiveness of "air bag only"

versus "unrestrained" it would have been necessary to deduct the belt users

from both the fatalities and the exposure totals, in both the ACRS and

the control group. This would have led to even more imprecise estimates

based on even sparser data. (Because all 10 of the ACRS fatalities did not

use the lap belt, it would actually have led to a negative effectiveness

estimate for "air bag only" versus "unrestrained" and a 100 percent

estimate for "air bag plus lap belt" versus unrestrained.)

4. The air bag and equivalent cars were very large cars, and are not

typical of cars being produced today. These cars had very low fatality

rates to begin with; thus it is more difficult for a restraint device to

show statistically significant effectiveness, with only a small sample, in

these large cars. For example, the front seat fatality rates in the
IV-46

equivalent large cars was 0.119. This was 40% lower than the 0.198 rate

for all cars in 1982, the lowest rate in recent history (21,200 front seat

fatals/106.9 million cars in use).-^

The agency has conducted a new analysis of air bag injury effectiveness

from field data. The injury rates in the air bag equipped cars were

compared to the injury rates of occupants involved in frontal accidents of

similar severity and similar sized vehicles on the NCSS file. The weighted

air bag effectiveness in frontal collisions was 23.9 percent for AIS ^ 2

and 38.2 percent for AIS ^ 3. These 'results are in conflict with the

fatality effectiveness, which was calculated to be zero. The details of

this study are reported in the next section on new analyses.

The Pacific Legal Foundation argues (74-14-N32-1675) that the agency's

position that the effectiveness of air bags is understated in the field

data is incorrect. According to this commenter, the Department cannot know

of all of the fatalities that have occurred in accidents in air bag

equipped cars. The agency now has a tape listing all the vehicle

identification numbers (VIN) of the ACRS cars. This tape was matched

against the FARS file to check for ACRS cars involved in fatal accidents.

All fatal accidents which were previously reported to the agency through

normal reporting channels were found on FARS plus two previously unreported

accidents. The agency thus feels reasonably confident that this system is

yielding all fatal ACRS crashes, since FARS is a census, not a sample, of

all fatal accidents. The agency does not have a VIN tape for the non-ACRS

air bag cars and this along with the previously cited reasons is why

In-Use data based on R. L. Polk Data.
IV-47

analysis of the fatalities in this fleet have been dropped from this

analysis. PLF also questions the premise that the large size of the air

bag car models tends to hide the effectiveness of the air bag. However, in

the PRIA, the Department merely acknowledged that it is more difficult to

show statistically significant effectiveness because the control group cars

already have a very low fatality rate.

Ford suggested that the Department update the fatality rate of the base

population of equivalent cars with safety belt systems to include the 1983

FARS data to eliminate any bias which would be expected to result from the

difference in reporting periods (the ACRS fleet exposure is through 1983,

the control group exposure is through 1981). The Department did not update

the control group exposure because fatality rates per 1000 car years are

relatively stable if sample size is sufficient to minimize sampling error.

3. New Analyses of Air Bag Effectiveness

The best way to estimate the safety effectiveness of any new device is to •

analyze the accident experience of a large fleet of cars equipped with the

device. However, since the existing fleet of cars equipped with air bags

has been too small for statistically meaningful analyses of its accidents,

as was discussed in the preceding section, NHTSA explored other methods.

The restraint effectiveness task force commissioned three separate in-house

studies of air bag fatal effectiveness subsequent to the publication of the

Preliminary Regulatory Impact Analysis. Each of the analyses used a

distinctly different methodology; however, they have two fundamental
IV-48

similarities. First, they all utilize the National Crash Severity Study

(NCSS) file as a fundamental source of accident data. The NCSS was a major

accident data collection program of the agency which began on January 1,

1977 and terminated on March 31, 1979. The combined investigations

represent 12,050 accidents, 25,237 vehicle occupants and 924 fatalities.

The accidents were sampled according to a plan designed to result in a

representative sample of accidents severe enough to require that the

vehicles be towed from the scene. Second, each study arrives at an

estimate of effectiveness inferentially rather than directly, since none of

the fatal accidents in the NCSS file occurred in air bag equipped vehicles.

The small number of actual crashes involving air bag equipped vehicles is

analyzed in the preceding section of this document. Effectiveness is

estimated by partitioning the NCSS accidents into various sub-groups by

distinguishing characteristics and then making judgments about whether an

air bag could prevent or mitigate injury or fatality in that sub-group.

Overall effectiveness is then calculated from a weighted total of the

individual judgments within the various sub-groups. A fourth study

conducted subsequent to the PRIA estimates AIS 2-5 injury effectiveness

from a file containing data on ACRS vehicle crashes by making comparisons

to non-ACRS cars in the NCSS file. The following sections will summarize

the methodology and findings of each of the studies; more detailed

explanations can be found in the actual reports, which have been placed

into the FMVSS 208 docket.

Study #1 - Assessment of the Potential of Air Bags

to Prevent Car Occupant Fatalities Using NCSS Data,

S. Partyka
IV-49

The 846 front-seat occupant fatalities in passenger cars on the NCSS file

were partitioned into subsets according to factors judged to be relevant to

the life-saving potential of air bags. The subsetting process is detailed

in figures IV-1 thru IV-4. The potential of air bags is computed from the

diagram as follows:

1) Of the 924 fatalities, 92.80 percent of the known seating areas were

front.

2) Of these, 84.00 percent of the known forces were horizontal.

3) Of these, 73.27 percent of the known longitudinal delta V's were 12

miles per hour or greater directed towards the back of the vehicle. A

review of extent zone for missing versus completed delta V revealed no

obvious bias among these non-rollover frontal crashes.

4) Of these, 92.30 percent of those with known ejection status were not

totally ejected (or were ejected through the windshield).




IV-54

5) Of these, 66.14 percent, were not trapped, 8.37 percent were unknown if

trapped, and 25.50 percent were trapped. None of these three categories

is discarded as being irrelevant to the effectiveness of air bags, but

each is studied separately. The data used for study are the intrusion

information, collected only for the last year of the NCSS (post-March).

Not trapped:

6a) Of the 82 fatalities not trapped in the post-March data, 78.05 percent

were in non-catastrophic crashes (or catastrophic crashes with less than a

20 percent occupant space reduction).

7a) Of these, only 35 had known injuries.

8a) Of these 65.71 percent probably would have been saved by an air bag,

20.00 percent were killed by side or intrusion forces not protected against

by an air bag, and 14.29 percent might have been saved (there was some

intrusion, but the injuries might have been reduced in severity by an air

bag). Of those with a decision on the air bag potential, (that is,

excluding those who "might have been saved") 76.67 percent would have been

saved.

Unknown if trapped:

6b) Of the 9 fatalities unknown if trapped in the post-March data, 44.40

percent were in non-catastrophic crashes (or catastrophic crashes with less

than a 20 percent occupant space reduction).

7b) Of these, only 1 had known injuries.

8b) This person probably would have been saved by an air bag.

Trapped:

6c) Of the 24 fatalities trapped in the post-March, 54.17 percent were in

non-catastrophic crashes (or catastrophic crashes with less than a 20

percent occupant space reduction).
IV-55

7c) Of these, only 7 had known injuries.

8c) Of these, 14.29 percent probably would have been saved by an air bag,

71.43 percent were killed by side or intrusion forces, and 14.29 percent

might have been saved by an air bag. (Of the cases with a decision of the

probable air bag effectiveness, 16.67 percent would have been saved).

The estimation proceeds backwards, up the chain, accounting for unknown

data. Three figures are calculated, for a range of effectiveness and a

most likely value. The figures are calculated as follows:

MIN — A minimum potential effectiveness is calculated by

putting all of the "might have been saved" in the

"not saved" category.

MID — a most likely potential effectiveness is calculated

by ignoring all of the "might have been saved".

MAX — A maximum potential effectiveness is calculated by

putting all of the "might have been saved" in the

"saved" category.

First, exclude the catastrophic crashes with more tharji 20 percent occupant

space loss (45.83% of the trapped occupants and 21.95$ of the persons not

i

trapped).
IV-56

Trapped:

MIN = 14.29% * 54.17 % = 7.74 % savable

MID = 16.70 % * 54.17 % = 9.05 % savable

MAX = 28.57 % * 54.17 % - 15.48 % savable

Unknown if trapped:

MIN = MID = MAX = 44.40 % * 100.00 % - 44.40 % savable

Not Trapped:

MIN = 65.71 % * 78.05 % = 51.29 % savable

MID = 76.67 % * 78.05 % - 59.84 % savable

MAX = 80.00 SS * 76.05 % = 62.44 % savable

Second, account for the different savable rates for the different

categories of entrapment. The distribution of these categories for front

seat occupants subjected to horizontal forces of at least 12 miles per hour

longitudinally and who are not ejected is as follows:

64 r 25.50 % trapped

21 = 8.37 Si unknown if trapped

166 s 66.14 % not trapped

The three savable rates are averaged according to the distribution of the

entrapment categories for the three levels, as follows:

MIN = 25.50 % * 7.74 % + 8.37 % * 44.40 % + 66.14 * 51.29 % = 39.61 % saved

MID = 25.50 % * 9.05 % + 8.37 % * 44.40 % + 66.14 * 59.84 % = 45.60 % saved

MAX = 25.50 % * 15.48 % + 8.37 % * 44.40 % + 66.14 * 62.44 % = 48.96 % saved
IV-57

Third, to account for the ejection, crash severity, and horizontal forces,

multiply by the factors that represent the rate of these subsetting

criteria.

MIN = 39.61 % * 92.30 % * 73.27 % * 84.00 % = 22.50 % savable

MID = 45.60 % * 92.30 % * 73.27 % * 84.00 % - 25.91 % savable

MAX = 48.96 % * 92.30 % * 73.27 % * 84.00 % = 27.81 % savable

Thus, the range of potential air bag effectiveness computed from this

methodology is 22.5%-to 27.8%. Several members of the restraint

effectiveness task force had reservations regarding some of the judgments

made regarding the ability of the air bag to protect occupants in certain

situations. Rear seat occupants, rollover, frontals with longitudinal

changes in velocity of less than 12 mph, side portal ejection and excessive

intrusion were some of the categories that received particular attention.

In response to these concerns "hard copy" review of a number of cases in

certain cells was conducted with a view toward making judgments about air

bag life saving potential on a case-by-case basis. After this review, it

was suggested that the upper estimate of potential air bag effectiveness be

adjusted upwards to slightly above 30%. Other members of the task force

pointed out that the methodology implied 100% effectiveness in those

situations where the air bag was assumed to be effective. Historically,

even the most promising safety concepts have fallen far short of 100%

effectiveness even when analyzed for those particular kinds of accidents in

which they were supposed to work; the point being that various judgments

could be made in one direction or the other in each of the cells and the
IV-5B

overall effectiveness would shift accordingly. Thus, the analysis must

rest on the assumptions and these assumptions translate into a potential

effectiveness of 22.5% to 27.8%.

Study #2 - Estimates of Fatality Reduction for Air Bags and

Lap/Shoulder Belts - C. Kahane

The technique used in this analysis was to examine a large representative

set of unrestrained fatal accident cases (NCSS). The computerized data

from each individual case was reviewed and judged as to whether an air bag

would have saved the victim. At the end of the review, the number of lives

judged potentially "saved" is divided by the total number of cases to

obtain an estimate of air bag effectiveness.

The technique has the same obvious limitations as Study #1. A judgment

about whether air bags would have been effective had to be made on the

basis of the relatively limited information that the data file provides

about each case. The judgment cannot be directly tested because it is, of

course, impossible to rerun exactly the same crash with air bags.

Therefore, to provide at least an indirect check on the results, the same

technique was also applied for lap/shoulder belts. Here, at least, there

have been enough statistical analyses of accident data to suggest that

effectiveness is in the range of 40-50 percent for belts. Thus, if this

technique produced a radically different estimate for belts, its validity

IV-60

The result of the application of this technique is that air bags were

judged to have been effective in 192 out of 781 unrestrained front-seat

fatalities, which is an effectiveness of 25 percent. Lap/shoulder belts

were judged likely to be effective for 396 of the 781 cases or 51 percent.

Table IV-12 summarizes the effectiveness results by crash mode. Air bag

effectiveness is estimated to be 39 percent in frontal crashes and 7

percent in nonfrontal crashes (including nohdeployments). Belt

effectiveness is 44 percent in frontal crashes and 59 percent in

nonfrentals. The results for belt effectiveness, both overall and by crash

mode, are reasonably consistent with results of statistical analyses of

accident data and provide encouragement that the procedure is relatively

accurate. There are several reasons that air bags are estimated to be

slightly less effective than seat belts in frontal crashes, despite their

superior performance at high Delta V. One is that crashes with side damage

and frontal (11-1:00) principal direction of force (PDOF), which are

included in the frontal group, tend to have occupant injury mechanisms more

characteristic of side impacts than frontals. The other reason is the

incidence of ejection and/or secondary rollover following frontal impacts.
IV-61

TABLE IV-12

AIR BAG AND BELT EFFECTIVENESS BY

CRASH MODE, BASED ON

CASE-BY-CASE ANALYSIS OF NCSS

UNRESTRAINED FRONT-SEAT FATALITIES

FRONTAL CRASHES

(frontal damage or 11-1:00 force)

NONFRONTAL CRASHES WITH LIKELY

OR POSSIBLE DEPLOYMENT

(side, top, back or under

carriage damage with secondary

frontal impact or 2-3:00,

9-10:00 or nonhorizontal force)

NONFRONTAL CRASHES WITH UNLIKELY

DEPLOYMENT

(side or back damage with

4-8:00 force and no secondary

frontal impact)

TOTAL

Percent of NCSS Fatalities

(N=781)

Air Bag Lap/Shoulder Belt

Effective? Effective?

Likely Unlikely Likely Unlikely

167

25

192

2b%

259

294

36

589

188

189

19

238

130

17

396 385

5H

Tables IV-13 and IV-14 run through the entire fault tree analysis for air

bags and seat belts, respectively, but with all crash modes lumped

together. The numbers in the lower sections of the two tables differ

slightly because the air bag analysis excludes nondepioyments but includes

crashes with Delta V between 36 and 45 mph.
IV-62

Approximately 40 percent of the fatalities involve speeds beyond the

capabilities of current production restraints and/or catastrophic intrusion

of vehicle components into the space where the victim was seated. About 15

percent of the victims are ejectees in noncatastrophic crashes. Thus,

about 45 percent of the victims were in survivable crashes and remained in

the car. Between over half and two thirds of them were killed by contacts

with frontal interior surfaces.

Table IV-15 runs through the fault tree analysis separately for the three

crash modes (frontals, nonfrontals with likely or possible deployment,

nondeployments). Moreover, the categories of crashes are defined in a

manner that air bag and seat belt benefits can be shown side by side.

Air bags are likely to be highly effective in frontal crashes that most

closely resemble laboratory tests, i.e., integrity is maintained (no

catastrophic intrusion, ejection, external objects entering the

compartment, or significant secondary impact). As Table IV-15 shows,
IV-63

TABLE IV-13

"FAULT TREE" ANALYSIS FOR AIR BAGS

Air Bag Effective?

Likely Unlikely

N of Case (781)

Nondeployments (36) 36

Likely or possible deployments (745)

Delta V > 45 (95) 95

Delta V < 45 or unknown (650)

Catastrophic intrusion (207) 207

Noncatastrophic (443)

Ejection (112)

Thru windshield (8) 8

Not thru windshield (104)

Killed by frontal contact (1) 1

Killed outside car or nonfrontal contact

(103) 103

No ejection (331)

Killed by secondary nonfrontal impact (8) 8

Killed by primary impact (323)

Fire/immersion 9

External Object 19

Side/top contact 112

Frontal Contact 183

TOTAL 192 589

TABLE IV-14

"FAULT TREE" ANALYSIS FOR LAP/SHOULDER BELTS

Belts Effective?

N of cases (781)

Delta V > 35 (135)

Delta V <: 35 or unknown (646)

Catastrophic intrusion (220)

Noncatastrophic (426)

Ejection (114)

No ejection (312)

Killed by secondary nonfrontal impact (8)

Killed by primary impact (304)

Fire/immersion

External object

Side/top contact

Frontal contact

Likely

114

8

106

168

Unlikely

135

220

9

21

TOTAL 396 385
IV-64

about 57 percent of frontal fatalities with Delta V < 45 occurred without

loss of compartment integrity. There was catastrophic intrusion at the

occupant's seat position in 31 percent of the cases (the majority due to

collisions with large trucks or trains), ejection in 7 percent and

secondary impact or external objects entering the compartment in 5 percent.

These are the reasons that overall air bag effectiveness in frontal crashes

on the highway is estimated to be 39 percent despite the near flawless

performance of air bags in laboratory tests.

Study #3 - Applicability and Effectiveness of Air Bag

Protection for Car Occupants - A. Malliaris

This analysis, like the two preceding analyses, utilizes the NCSS file for

a basic source of accident experience. However, unlike the other two it

only uses a subset of the file wherein there is a known principal direction

of force, known longitudinal delta V, case car injured unrestrained

occupants of known seating position, injuries (severity and source) and

age.

Air bag applicability was defined as the proportion of occupant casualties

that lends itself to air bag mitigation, according to the following three

criteria:
TABLE IV-15

"FAULT TREE" ANALYSIS FOR AIR BAGS AND

LAP/SHOULDFR BELT, BY CRASH MODE

Air Bag Lap/Shoulder Belt

Effective? Effective?

Likely Unlikely Likely Unlikely

A. FRONTAL CRASHES (frontal damage; other

Impacts with 11:00-1:00 Force)

Delta V > 45 mph 83 83

Delta V ^ 45 or unknown

Catastrophic intrusion at occupant's

position by:

Train 3 3

Large Truck 52 52

Other vehicle or fixed object 51 51

Noncatastrophic Crashes with

Ejection <

Thru windshield 4 4 i,

Other portals *"

Killed in car by frontal contact 1 1

(36<AV<45)

Killed outside of Car or by non-frontal Contact

A V < 35 or unknown 18 18

36 <AV « 45 1 1

No Ejection

Killed by secondary non-frontal impact 8 8

Killed by the primary impact (AV4 35

or unknown)

by exterior object entering vehicle 10 10

by fatal burns 5 5

by nonfrontal contact

AV < 35 or unknown 16 16

36 <AV < 45 12 12

by frontal contact

AV 4 35 or unknown 142 142

36 <AV <: 45 20 20

TOTAL 167 259 188 238
TABLE IV-15 (CON'T)

"FAULT TREE" ANALYSIS FOR AIR BAGS AND

LAP/SHOULDER BELT, BY CRASH MODE

Air Bag

Effective?

Lap/Shoulder Belt

Effective?

B. NONFRONTAL IMPACTS WITH LIKELY OR POSSIBLE DEPLOYMENT

(side, top, back or botton damage; secondary frontal

impact of 2-3:00, 9-10:00 as nonhorizontal force)

Delta V > 45 mph

Delta V <: 45 or unknown

Catastrophic intrusion at occupant's position by:

Train

Large Truck

Other vehcle or fixed object

Noncatastrophic Crashes with

Ejection

Thru windshield

Other portals

Killed in car by frontal contact

Killed outside car or by non-frontal

AV < 35 or unknown

36 <AV < 45

No Ejection

Killed by exterior object entering vehicle

Killed by fatal burns or drowning

Killed by nonfrontal contact

A V ^ 35 or unknown

36 < AV < 45

Killed by frontal contact

A V ^ 35 or unknown

36 <AV ^ 45

Likely Unlikely Likely Unlikely

12

10

18

73

12

10

18

73

4

0

21

0

83

1

9

4

81

3

4

0

83

81

21

1

9

4

3

0

I

TOTAL 25 294 189 130
TABLE IV-15, (CON'T)

"FAULT TREE" ANALYSIS FOR AIR BAGS AND

LAP/SHOULDER BELTS, BY CRASH MODE

Air Bag

Effective?

Lap/Shoulder Belt

Effective?

C. NONFRONTAL CRASHES WITH UNLIKELY DEPLOYMENT

- (4-8:00 Force; No secondary Frontal Impact)

Delta V > 45 mph

Delta V < 45 or unknown

Catastrophic intrusion at occupant's position by:

Train

Large Truck

Other vehcle or fixed object

Noncatastrophic Crashes with

Ejection

Thru windshield

Other portals

Killed in car by frontal contact

Killed outside of or by non-frontal

A V >£ 35 or unknown

36 <£tf 4 45

No Ejection

Killed by exterion object entering vehicle

Killed by fatal burns

Killed by nonfrontal contact

A

v

 ^ 35 nr unknown

36 < AY < 45

by frontal contact

AV ^ 35 or unknown

36 <AV < 45

Likely Unlikely Unlikely Unlikely

1 1

0

6

7

0

0

5

0

2

0

9

0

5

1

0

0

5

9

5

0

6

7

0

2

0

0

1

Ien

TOTAL 0 36 19 17
IV-68

Qualified occupants must:

1) Occupy cars experiencing a longitudinal component of delta V larger

than or equal to 10 mph (air bag deployment criterion; runs were also made

for 8 and 12 mph);

2) Have at least one injury assigned to contact with frontal interior

components; and

3) Occupy cars that experience crash severities lower than a total delta V

of 45 mph (protection cutoffs of 40 and 50 mph were also tested).

A novel aspect of this analysis is that it recognizes the existence and

frequency of multiple injuries. It further recognizes that the outcome of

mitigating one or more injuries may be nil if the most severe injury

remains unmitigated. The probability of fatality is projected as a

function of the two most severe injuries according to an agency derived

algorithm.'^

In examining the car occupants, each occupant's injury and source of injury

data set, both before and after the application of the mitigation criteria,

are addressed. Each occupant's overall AIS injury level and each

occupant's probability of fatality are tracked. Thus, a distribution of

occupants according to AIS as well as the projected fatalities, both before

and after mitigation criteria are applied, is derived.

37 P=(6.57 AIS 1* (1.23) AIS 2/43,673, from "A Comparison of AIS and ISS

Predictions of Fatality on NCSS," S. Partyka, American Association for

Automotive Medicine, October 7-9, 1980.
IV-69

Another novel aspect of this analysis is the use of several different

concepts of effectiveness. In the baseline concept, any qualified injury,

after mitigation, is allowed a minimum severity of 1, or 2, or 3 depending

on crash severity. For longitudinal delta V values between 10 mph

(deployment) and 25 mph, the minimum severity of 1 is allowed. The minimum

value is raised to 2 or 3 when the said delta V assumes values in the

ranges 25 to 35 mph and 35 to 45 mph, respectively. This alternative is

judged to give the most likely reflection of the performance of air bags of

the 1970's vintage. State-of-the-art air bags of this era met the FMVSS 208

injury criteria at speeds up to 45 to 50 mph in frontal collisions. These

criteria were met with wide margins at lower crash velocities, but the

margins became very small as the crash speeds approached 45 to 50 mph.

An alternative mitigation concept was to assume full mitigation, that is

all qualified injuries are reduced to AIS 1 and no new injuries are induced

by virtue of deployment and restraint of the occupant during the crash.

A difficulty encountered with this analysis is the requirement for known

delta V and injury contact source since these data are often not available

in the NCSS file. For example, information about delta V is not usually

available in the case of catastrophic crashes (including almost all

collisions with large trucks or trains) or in crashes where the principal

direction of force is non-horizontal, for example, in rollovers.

Conversely, delta V information is usually available in horizontal,

non-catastrophic crashes and predominantly frontal crashes where it is

believed that the air bag is most effective. Thus, requiring the

availability of delta V information is expected to introduce a bias in
IV-70

favor of air bag effectiveness. In an attempt to minimize this bias, the

analysis was stratified by crash mode. In other words, individual

determinations of air bag effectiveness were made by crash mode. Results,

i.e., fatality reduction, are displayed in Table IV-16.

TABLE IV-16

Crash Mode

1

2

3

4

5

All

Catastrophic

Damage

No

No

No

No

Yes

_

Direction

of Force

Horiz

Horiz

Horiz

No-Horiz

Any

Area of

Damage

Front

Side

Rear

Any

Any

—

Fatality

Incidence

Percent

38.0

21.1

1.2

11.6

28.1

100.0

Reduction

Fatalities

Percent

76.0

12.4

0.0

22.9

27.9

42.0

The overall effectiveness is calculated as the sum of the products

(incidence times reduction of casualties) in each mode, summed over all

modes. The most uncertain results in Table IV-16 are those concerning the

last two crash modes, namely rollovers and catastrophic damage regardless

of the type of impact. Since these determinations are made on relatively

few cases for which the needed information is available they are vulnerable

to biases and sampling errors. The conservative view is that in these two

strata the needed information is available more frequently for situations

that involve some form of frontal impact, where the air bag is most

effective. Accordingly, it is believed that the casualty reduction in

these strata may be over estimated. In recognition of the above potential

biases and for simplicity, the author considered two bounds of overall

effectiveness. The lower bound results from an adoption of crash modes 1

and 2 as shown in Table IV-16 and total elimination of modes 3,4, and 5

from any consideration. The resulting overall effectiveness is 31.5

percent. The upper bound adopts the results of Table IV-16 as shown
IV-71

yielding an overall effectiveness of 42 percent for fatality reduction. It

is believed that modes 1 and 2 would be subject to the same biases and

sampling errors, but probably to a lesser degree than modes 3, 4, and 5.

Table IV-17 shows the results of various sensitivity analyses which were

performed. Rows 2 and 3 show results for a deployment threshold of 8 and

12 mph respectively, compared to the baseline value of 10 mph. Air bag

protection cutoffs at 50 and 40 mph are the variations in entries number 4

and number 5 relative to the baseline cutoff of 45 mph.

TABLE IV-17

SUMMARY RESULTS OF SENSITIVITY OF AIR BAG EFFECTIVENESS

ESTIMATES TO VARIOUS INFLUENCING CONDITIONS

Fatality Reduction %

Condition

1. baseline

2. deployment i 8 mph

3. deployment § 12 mph

4. protection cutoff i 50 mph

5. protection cutoff @ 40 mph

6. larger reduction of injury severity

7. driver only

8. front passenger only

The variation displayed in number 6 involves a larger reduction in injury

severity. It assumes that the severity of all injuries qualified for

mitigation are reduced to a severity of AIS=1 throughout the domain of

applicability, from deployment at 10 mph to cutoff at 45 mph. The baseline

assumes that the injury severity increases from AIS=1 to 2 to 3; i.e., the

injury severity reduction decreases as the cutoff severity is approached.

The last two entries resolve the projected effectiveness by seating

position for driver and front seat passenger. The baseline refers to all

occupants.

lower Bound

31.5

33.5

30.6

34.0

27.9

32.5

36.2

23.3

upper bound

42.0

44.7

40.8

45.4

37.2

43.3

48.2

31.1
IV-72

Ford argued (74-14-N35-065) that this study was restricted to that group of

crashes in which air bags would be expected to be most effective. The

agency has already acknowledged that the most uncertain results are in the

rollover and catastrophic damage crash modes due to the absence of all

needed data. On the other hand, there is no basis and it is unreasonable

to assume that no protection at all is offered in these crash modes. An

examination of the NCSS detailed data of crashes with catastrophic damage

reveals the following: These crashes are not as unsurvivable as they are

generally characterized. Based on 313 occupants recorded in NCSS for car

occupants in catastrophic crashes, the survival rate is 64 percent, even

without the benefit of any form of restraint.

Renault expressed the view (74-14-N35-050) that air bag effectiveness could

not exceed 20 percent because the protection is not omnidirectional. They

claimed that protection was poor in the case of successive impacts and is

non-existent in the case of ejection. Renault did not supply any data in

support of their claim. The agency's analysis of unrestrained fatalities

showed enough persons killed by simply striking the object directly in

front of them to justify estimates higher than 20 percent.

Similar considerations hold for crash modes with non-horizontal impact. In

such modes the most severe impact may be non-horizontal, but secondary

impacts exist—either before or after the most severe impact—of sufficient

force to deploy the air bag and provide some protection by cushioning the

occupant and/or by reducing the rattle space during the rollover.
IV-73

The Pacific Legal Foundation and Volkswagen (74-14-N35-046) criticized the

agency's new studies as being subjective and based on the assumption that

air bags work more or less as predicted. Current biomechanics knowledge is

sufficiently adequate to lend confidence to such an assumption, based on

laboratory data and the fact that air bags have at least been deploying

when needed based on field experience and statements made by manufacturers.

Section 4 of this chapter summarizes the results of the extensive testing

of air bags that the agency has conducted over the past 10 years.

Study #4 - Air Bag Injury Effectiveness from Field Data.

The National Center for Statistics and Analysis (NCSA) maintains an

automated data system on air bag vehicles that have been involved in

accidents investigated by NHTSA. For each accident, this data system

contains information regarding the accident severity and level of injury of

occupants. Although this file was developed primarily for case retrieval

and tabular summary purposes, it does have value for certain quantitative

analyses. The file was last up-dated on December 22, 1983 and at that time

contained data on 547 accidents and 778 occupants of air bag equipped

vehicles.

The file was screened for front seat occupants of air bag equipped vehicles

involved in frontal accidents with known delta V and injury level. A

comparable search was made of the NCSS file with the further restrictions

that the occupants were unrestrained and in a standard full size or luxury

car, since the ACRS cars are all large cars. Table IV-18 displays the
IV-74

and AIS>3 injury rates for both the ACRS and NCSS car occupants. The

effectiveness of air bags, calculated for each 10 mph increment of delta V

is also displayed in Table IV-18.

TABLE IV-18

AIR BAG FIELD DATA COMPARISON WITH NCSS - FRONTAL CRASHES

Percentage Distribution of Occupant Injuries and Effectiveness by Delta V

V

1-10

11-20

21-30

31-40

41 +

WEIGHTED

AVERAGE

TOTAL

OCCUPANTS

NCSS

3914

3150

485

79

46

ACRS

73

92

39

8

2

AIS >2

NCSS^B

4.4

15.0

38.7

66.1

91.8

12.08$

ACRS39

1.4

12.0

38.5

50.0

100.0

9.19%

AIS > 3

NCSS

1.0

4.7

21.6

37.3

73.8

4.63%

(*)

ACRS

0

3.3

10.3

25.0

100.0

2.86%

ACRS EFFECTIVENESS

2+

68.2%

20

0.5

22.2

-8.9

23.935

3+

100&

29.8

52.3

33

-35.5

38.2

The effectiveness was calculated for ranges of delta V in an attempt to

normalize the differences in severity distribution between the NCSS and

ACRS files. The agency believes that there has been significant

underreporting of ACRS crashes, particularly at the lower severity levels.

If the less severe ACRS crashes have indeed been underreported this would

lead to a reduction in apparent air bag effectiveness. In any event, the

data in the ACRS file is very sparse, particularly at the higher delta V's

and higher AIS levels, and the results thus have limited statistical

significance. However, several noteworthy trends are evident from Table

IV-18. First, the air bag appears to have a noticeably higher

3 8 NCSS

Standard full size and luxury cars in NCSS file, unrestrained front seat

-to occupants in frontal crashes.

" ACRS FIELD DATA

Full size GM and Ford vehicles equipped with air bags, front seat occupants

in frontal crashes.
IV-75

effectiveness at the higher injury levels (AIS > 3 as compared to AIS ^ 2) .

This trend is consistent with the crash test data and intuitive reasoning.

A case by case review of the air bag crash injury data shows that the AIS>2

injuries include a large number of upper and lower extremity injuries. The

arms and legs of the air bag restrained occupant are not necessarily

contained by the bag and may be free to contact the interior surfaces of

the vehicle.

The second trend evident from Table IV-18 is that the air bag appears to be

most effective in the delta V range of 21-30 mph and tails off in the speed

ranges above and below. Once again this is consistent with the crash test

results and intuitive reasoning.

Third, contrary to a widely held belief that air bags only deploy at

delta V above 10 mph, Table IV-18 shows that 34 percent of the deployments

in frontal crashes occurred below 10 mph and that the bags were apparently

effective at mitigating injuries at those speeds.

The effectiveness results by delta V were weighted according to the

distribution of injuries by delta V within the NCSS file. The weighted sum

of injuries and effectiveness over the entire speed range was calculated to

be 23.9So for AIS >, 2 and 38.23. ^ 3. It must be remembered that these

values are for frontal accidents only and would be lower if side, rear and

rollover crashes could have been included in the calculations. However,

they are interesting particularly because they do show reasonably high
IV-76

effectiveness for the more severe injuries and as such disagree with the

fatality effectiveness from the field data which is now calculated to be

zero.

Ford contends that this study contains serious and discrediting

methodological flaws. The basis for this conclusion appears to be a

belief that the calculated effectiveness values for the 1-10 mph delta V

range are too high. Ford says: "Even if a few air bags do deploy in

accidents below 10 mph delta V, it doesn't seem plausible that those few

deployments could mitigate over two-thirds of the moderate or greater

injuries."

Analysis of the computerized file of the air bag fleet experience indicates

that 29.3 percent of all air bag deployment cases occurred at 10 mph or

below. Thus, Ford's contention that deployments do not occur below sensor

threshold velocity is erroneous. Threshold velocity is defined as the

perpendicular fixed rigid barrier car crash speed below which air bag

deployment will not occur. Certainly it is easily perceived that a crash

engaging less than full frontal cross section of a car might not cause a

longitudinal car delta V reaching threshold, but could impart local vehicle

crush rates at the bumper impulse detector which prematurely anticipates a

delta V sufficient to initiate air bag deployment. The agency does concede

that there is large uncertainty in the 0-10 mph effectiveness figure since

it is based on one injured occupant; however, as Ford points out the

AIS > 2 and AIS ^ 3 effectiveness estimates are 13.8 percent and 50.8

percent even when the 1-10 mph data are excluded. The agency agrees with

Ford that it would be helpful to further match the air bag and NCSS samples
IV-77

using damage pattern, object struck, occupant age, sex and seating

position. However, as Ford points out, there are too few air bag cases

available to allow this more refined estimate.

4. Other Studies of Air Bag Effectiveness

General Motors Safety Research and Development Laboratory conducted an

in-depth case-by-case field accident fatality study of restraint system

effectiveness in 1973.^0 A jury of four engineers, whose backgrounds

included experience in the design, development and testing of both active

and automatic restraint systems, analyzed accident cases involving 706

fatally-injured occupants. After determining the series of events and

complications which led to an occupant's death, each restraint system

considered was rated for its likelihood of fatality prevention. The

restraint systems chosen for evaluation and the resultant fatality

reduction potential were as follows:

lap belt alone - 17%

lap and shoulder belt - 3'\%

air bag -18 %

air bags and lap belt 29%

Methodologically this study appears to be sound and is quite similar to

several of the recent studies performed within the agency. However, all

the results appear to be on the conservative side, particularly the belt

restraint numbers, which we now believe to be higher.

Restraint System Effectiveness — A Study of Fatal Accidents, Richard

Wilson and Carol Savage, Proceedings: Automotive Safety Engineering

Seminar, June 20-21, 1973.
Incidence,

1982 FARS

55.2

26.9

5.0

12.9

—

100.0

Percent

GM File

44.1

27.2

1.0

20.5

7.2

100.0

IV-78

One possible explanation for the different results is that the collection

of 706 fatals may not be a nationally representative sample. Comparing,

for example, the fatals by collision configuration in the GM sample with

the 1982 FARS results shows some rather substantial differences,

particularly for frontal collisions where air bags are expected to be most

effective.

Collision Configuration

Frontal

Side

Rear

Rollover

Other

Total

Pacific Legal Foundation argued (74-14-N35-078) that DOT used precisely the

same type analysis that GM had offered and NHTSA had rejected in the 1977

rulemaking on automatic restraints. The agency agrees that we are now

adopting a methodology on air bags that we previously had reservations

about. However, the agency believes that the new studies offer significant

refinements over prior work. The new studies use the NCSS file as a base

and as such should be more representative of the national accident picture.

Most of the decision making process was done by computer using specific

objective criteria. This is not to say that the process does not involve a

degree of judgment, which it does. Results were reviewed by the Task Force

and other agency personnel representing a wide range of technical expertise

and should reflect a degree of impartiality, which may or may not have been

present in the GM study.
IV-79

Ford Motor Company published a study on restraint system effectiveness in

1971.41 For each of 15 occupant restraint systems studied, mathematical

modeling of the occupant restraint - vehicle system established potential

head and chest decelerations of the occupants in a number of narrowly

categorized crash situations. Human tolerance formulations were used to

then convert these decelerations into effectiveness values for each crash

situation studied. These effectiveness values, which reflect the ability

of a restraint to save lives in each given crash situation, were then

applied to accident data showing the relative frequency of fatalities

occurring in each such situation. Summing the results for all situations

leads to an overall estimate of lives saved by each restraint.

The overall fatality effectiveness estimates derived from this methodology

for passenger car occupants were as follows:

lap belt alone - 40.2%

lap and shoulder belt - 58.2%

front seat air bag - 27.2%

front seat air bag w/lap belt - 45.3?o

The results of the Ford study are of course largely a function of the

mathematical models used, human tolerance levels chosen and the breakout of

accident data that was available (1969 data) at the time of the analysis.

Although much of this data is now rather obsolete, it is interesting that

the estimates of restraint effectiveness are not all that different from

the agency's current estimates.

41

Restraint System Effectiveness, Ernest S. Grush, Shermen E. Henson and

Orville R. Ritterling, Report No. S-71-40, Ford Motor Company, Automotive

Safety Affairs Office, September 21, 1971.
IV-80

Donald F. Huelke and others in a 1979 study^2 estimated the number of deaths

and injuries that could be prevented by various restraint systems. Three

experienced crash investigators reviewed data concerning fatalities of

front seat car occupants that had occurred at high speeds in rural areas.

The researchers investigated these deaths between January 1, 1973 and

December 31, 1977. Fatalities that occurred in vans, pickup trucks, larger

trucks and the rear seats of cars were excluded from the review. Of the

101 people killed (under conditions within the range of the study) only

four were wearing belts.

One significant conclusion of the Huelke 1979 study was that approximately

42-51 percent of the people killed had no chance of survival, regardless of

the type of restraint used. The General Motors 706 case study came to a

similar conclusion. The specific results of the Huelke study with regard

to potential effectiveness of various restraint systems for reducing

fatalities were as follows:

lap belt - 9.2-15.9%

lap shoulder belt - 30.6-32.4

air bags alone - 23.2-27.4

air bag and lap belt - 32.6-35.3

This study suffers from the same deficiency as the General Motors study in

that the representativeness of the sample of accidents is unknown. As the

author points out, the accidents are predominantly high speed and rural and

thus would tend to understate effectiveness.

Donald F. Huelke and others, "Effectiveness of Current and Future Restraint

Systems in Fatal and Serious Injury Automobile Crashes," SAE 790323, 1979.
IV-81

6. Summary and Conclusions — Air Bag Effectiveness

The preceding sections have discussed a number of new analyses and

summarized some prior analyses of air bag effectiveness. The agency based

its latest estimates (as detailed in Table IV-1) principally upon the new

studies that have been conducted. The agency has greater confidence in

these new studies principally because they are based on the NCSS file,

which is a relatively large, representative set of unrestrained fatal

accident cases. However, even the results of the new analyses have some

uncertainty. For the most part they rely heavily on judgments about

whether an air bag would save a victim. This technique has obvious

limitations. Death in highway accidents is very unpredictable; many people

have walked away from seemingly unsurvivable wrecks, while others are found

dead at the scene of a low severity accident with no obvious aggravating

factors to account for the fatality.

There is little disagreement over the conclusion that air bags will likely

function very well in frontal or near frontal collisions up to speeds

approaching 45 mph in which passenger compartment integrity is maintained

and that bags will offer little or no protection in rear end collisions.

However, uncertainty underlines the attempts to estimate air bag

effectiveness in side or angle impacts, in rollover crashes and in

catastrophic frontal crashes. The agency is undecided on the latter and

the wide range of estimated effectiveness is a reflection of that

uncertainty.
IV-82

The lower end of the range (20-25%) is generally consistent with the

assumption that air bags will have fairly low effectiveness in side,

rollover and catastrophic frontal crashes. As progressively more

optimistic assumptions are made regarding their performance in these types

of crashes the overall effectiveness estimate approaches 40".

The earlier studies done outside the agency loosely fit the general

conclusions described above; i.e. conservative estimates of effectiveness

in crashes other than non-catastrophic frontal have led to estimates toward

the lower end of the range. Given the great diversity of analytical

techniques employed and the large time spans among the various studies,

their consistency is quite remarkable.

The field data on air bag effectiveness for fatalities (zero effectiveness,

with upper confidence bound 46 percent) were not used by the agency in

calculating its final determination of air bag fatality effectiveness

except to the extent that they discouraged the agency from contemplating

values of air bag effectiveness substantially above 40 percent. These data

were inconsistent with injury data for the same cars, were too sparse, and

had confidence bounds that were too wide.
V. RESTRAINT USAGE

This section on restraint usage is divided into two parts. The first

presents and discusses data on seat belt usage. The second part presents

the derivation of the usage estimates used in the calculation of benefits

for the several types of restraint systems.

Observed daytime manual belt use by drivers in 19 major cities throughout

the country has been 11-14 percent over the 1978-1983 period. Automatic

belt usage in the relatively few vehicles with automatic systems has been

close to 80 percent. However, many of these systems were purchased •

voluntarily and usage thereof is likely higher than if they were a required

installation. In addition, the great majority of these automatic systems

have ignition interlocks, which prevent the cars from being started without

the belts in place; future systems are not expected to have this feature —

and the Department is prohibited by law from requiring them — and usage

will probably be substantially less.

Given the uncertainty about public acceptance and usage of automatic belts,

a range of automatic belt usage is estimated — Z0%-70%. This estimate is

based on surveys on manual belt usage rates and an analysis which compares

survey data on why people do not use their manual belts with the

characteristics of automatic belts which might obviate these stated

reasons.
V-2

A range of manual belt usage that could be realized under mandatory seat

belt usage laws is also estimated. Based on the experience in the Canadian

provinces and 17 other countries that have enacted mandatory usage laws and

for which data are available^ a range of 40-70 percent manual belt usage is

estimated.

Air bags are not used per se; however, there are factors which might render

the air bag unavailable for protection in certain instances. It has been

estimated that about 2% of all vehicle exposure may be without air bag

protection, resulting in an air bag "readiness factor" of 98*. Three

factors were considered as contributing to reducing the readiness factor:

failure to repair or replace the air bag after a prior deployment,

deliberate disablement or removal, and basic reliability of the system.

A. Seat Belt Usage Data

1. Manual Belts

a. Observational Surveys

The agency has collected safety belt usage data in 19 cities nationwide

since 1978. Observed daytime driver usage of manual safety belts in these

cities was 14.0 percent in 1983 (See Table V-1). Front seat passenger

belt usage is lower than driver usage. In 1983, front center passenger

seat belt usage was 5.0%; front right passenger seat belt usage was 8.4%.
V-3

For this analysis, the ageicy did not adjust the current rate of 14.0So seat

belt usage for drivers, 5>% for front center seat occupants and 8.4% for

front right seat occupants for possible future changes. Higher usage of

manual belts in the future would reduce the estimated benefits for the

several alternatives. Lower manual belt usage than shown would have the

opposite effect.

TABLE V-1

OBSERVED DRIVER USAGE OF SEAT BELTS1

1978 13.OK

1979 10.9%

1980 Not Collected

1981 11.4*

1982 11.33!

1983 14.0%

b. Personal Interview and Telephone Surveys

Several nationwide surveys conducted for NHTSA have included questions on

respondents' seat belt usage. Table V-2 shows the results of 8 surveys

conducted over the 1978-1984 period. In part A, the results of 6 of the

surveys are presented for comparison by aligning usage response categories

as follows: 1) "always or almost always" to include "almost all the time"

and "always;" 2) "more than half the time" to include "most of the time;"

3) "less than half the time" to include "only sometimes" and "sometimes;"

and 4) "never or almost never" to include "rarely" and "never".

1 Source: 1978-1982 --

"Restraint System Usage in the Traffic Population," Opinion Research

Corporation, May 1983, DOT HS-806-424, p.2.

Source: 1983 —

"Progress Report on Restraint System Usage in the Traffic Population,"

Goodell-Grivas, Inc., January 1984.
V-4

TABLE V-2

RESl'.TS OF SURVEYS ON MANUAL

SEAT BELT USAGE

(Percent)

hi.

19782 197fl3 19794 19flP,5 19R?6

Always or Almost 16 24 24 22 19 19

Always

More than Half the

Time 9 8 8 6 14 21

Less than Half the

Time 18 15 18 14 28 30

Never or Almost

Never 59 39 30

Frequent

Sometimes

Infrequent

56

19818

22

38

40

52

1982^

29

30

41

50

JL

19839

33

34

33

Home interview survey, 2,016 respondents; "Public Attitudes Toward Passive

Restraint Systems," DOT-HS-803-570 Peter D. Hart Research Associates, Inc.,

August, 1978.

Telephone survey, 1,500 respondents; "1978 Survey of Public Perceptions on

Highway Safety," DOT-HS-803-179 Teknekron Research, Inc., September, 1978.

Telephone Survey, 1,500 respondents;" 1979 Survey of Public Perceptions on

Highway Safety," DOT-HS-805-165 Teknekron Research, Inc., July, 1979.

Telephone survey, 1,500 respondents; "1980 Survey of Public Perceptions on

Highway Safety," DOT-HS-805-702 Automated Services, Inc., September, 1980.

Telephone survey, 1,020 respondents; "A Study of Demographic, Situational

and Motivational Factors Affecting Restraint Usage in Automobiles,"

DOT-HS-806-402, "Lawrence Johnson and Associates, Inc., February, 1983.

Telephone Survey, 1,000 respondents; "Trends in Public Knowledge and

Attitudes Toward Occupant Restraint Systems," McGinley Marketing Research

Co, Inc., monthly report, January 1984.

Telephone survey, 1,200 respondents; "National Safety Belt Study", F.

Newport and L. Tarrance, September, 1981.

Telephone survey, 1,000 respondents; "Impact of Travel Patterns and Driving

Behavior on Crash Involvement," V. Lance Tarrance and Associates, July

1983, DOT-HS-806-458.
V-5

Part B shows the results of two additional surveys, which derived three

seat belt usage categories — frequent, sometimes, and infrequent. Part B

also includes this classification as reported in the Lawrence Johnson and

Associates survey.

As shown, the results of these surveys are fairly similar. From 16 to 24

percent of the respondents say they use seat belts always or almost always.

Notice, however, that this percentage is somewhat higher than the findings

of observational surveys (Table V-1 ).1° There is a large variance among

surveys in the proportion of those saying they use seat belts never or

almost never; this group comprises 30-59 percent of the respondents (30

percent—January 1984).

c. Surveys on Reasons for Using/Not Using Belts

Many surveys have been conducted to ascertain the reasons that people do or

do not wear seat belts. Table V-3 reports the results of two telephone

surveys sponsored by NHTSA in 1979 and 1980, conducted by Teknekron and

Automated Services, respectively. There have been a few more recent

national surveys on the subject, two of whose results are presented in

section XI. The manner in which the question was asked, the categories

into which responses are summarized, and the percentage distributions

thereof vary somewhat from survey to survey. It is felt that the two

This tendancy for respondents to over report their seat belt use was

documented by Waller and Barry in their 1969 report; "Seatbelts: A

Comparison of Observed and Reported Use;" P. Waller and P. Barry, The

University of North Carolina Highway Safety Research Center, May 1969,

DOT-HS-007-113.
V-6

surveys sponsored by the agency that are presented herein firm a reasonable

basis for estimating a range of future usage rates for automatic belts as

presented later in this section.

TABLE V-3

REASONS FOR NOT WANTING TO USE MANUAL BELTS

(Percent)

Teknekron11 Automated Services12

Reason 1979 1980

Don't want to be bothered, 13.9 21.7

lazy, forgetful

15.5

17.2

8.8

11.0

5.8

6.1

13.8

The surveys indicate that one of the primary reasons that people do not

buckle up is that they do not want to be bothered and are lazy and/or

forgetful. These problems could be negated by automatic belt systems. Other

major considerations that hold down belt usage are lack of comfort and

inconvenience of use. These factors may or may not be influenced by

automatic belts, depending on the specific belt designs and the true

underlying reasons manifest in this particular response. Other reasons

given for non usage — "Don't want to be restrained," "afraid of being

Uncomfortable

Inconvenient to use

Don't want to be restrained

Afraid of being trapped in

car during accident

Doubt value of safety measure

Other

No reason

13.2

15.1

7.7

10.7

4.5

17.9

17.1

11 "1979 Survey of Public Perceptions on Highway Safety," DOT-HS-805-165

Teknekron Research, Inc., Duly 1979, p.34.

12 "1980 Survey of Public Perceptions on Highway Safety," DOT-HS-805-702

Automated Services, Inc., September 1980, p.45.
V-7

trapped in car during accident," and

 lfdoubt value of safety system" a:%e not

likely to be overcome by automatic belt systems but instead may be amenable

to solution through educational programs.

In 1977, General Motors funded a research project conducted by Market

Opinion Research (MOR)1 3 to determine what factors affect seat belt usage

and to devise strategies to increase seat belt usage. The MOR Study found

that the most significant factors affecting belt usage, in their order of

most frequent occurrence, are:

1) Attitude - Overall feelings about necessity of using belts, including

(misplaced) fear of being trapped by belts during an accident.

2) Interaction - Driver or passenger asks them to wear belts. The

respondents also stated that when the source of encouragement was more

remote (media campaign), it was less compelling.

3) Comfort and Convenience - MOR concluded that although inconvenience is

a significant complaint (about one-third of the individuals so complained),

it does not generally affect the decision either to begin using belts or

continue their use. Comfort and convenience are more secondary than

primary factors. However, freedom of movement is a characteristic that can

lead to increased use.

"An Analysis of the Factors Affecting Seat Belt Use, "Market Opinion

Research, 1977.
V-8

4) Belt Design and Car Size - The smaller cars have higher usage. The

more complex the belt system is, the less it is used; the more freedom of

movement it allows, the more often it is used; the more severe the warning

system (starter interlock, continuous buzzer, 4-8 second buzzer, light),

the higher the rate of disconnect; however, these coercive devices result

in higher usage rates.

5) Events - People wear belts more often in adverse weather; people try

belts more often at the time of a new car purchase and during driver

training than at other times. Those who develop the habit of attaching

belts, as part of a check-off system to start the car, habitually wear

them.

6) Demographic Characteristics - A composite sketch of the typical user

reveals a person who is married, with a high education level, and in a

high income range.

MOR found belt usage similar to that found in the studies conducted for

NHTSA — 17% confirmed belt users, 40% moderate belt users, 43% non-users.

MOR believes that at the high end of the range, all moderate belt users

could become confirmed users — making total usage 57%.
V-9

Although MOR did not find comfort and convenience of major importance, an

SAE paper'4 which was based on the MOR study, states that "the comfort and

convenience of the belts, or other safety systems, is the key in

determining the use of that system."

Another outcome of the MOR study is that for non-users of belts, the most

important factor relating to seat belt use is a "new car." This suggests

that people might try the seat belts in a new car.

2. Detachable Automatic Belts

As discussed in the October 1981 Analysis,^ the Department does not have

data which can be used to precisely predict detachable automatic belt

usage. The limited data available were gathered in three ways — (1)

observation of on-road usage, (2) usage from accident reports, and (3)

telephone surveys.

a. Observed Usage

Detachable automatic belts were installed in approximately 390,000

1975-1982 model year VW Rabbits. In 1983, when automatic belts were

marketed by VW as an option rather than standard equipment, fewer than

4,000 Rabbits were sold with the automatic system. A total of 10,000

14 "A Comparative Analysis of Factors Impacting on Seat Belt Use," Timothy 3.

Kuechenmeister (GM), Andrew 3. Morrison (MOR) and Mitchell E. Cohen (MOR),

June 11-15, 1979, SAE 790687.

15 "Final Regulatory Impact Analysis, Amendment to FMVSS No. 208, Occupant

Crash Protection, Rescission of Automatic Occupant Protection

Requirements," NHTSA, October 1981.
atic Belt

Observations

398

17

Manual Belt

Usage

30.6%

15.OS!

Observations

1,092

1,315

V-10

1978/1979 GM Chevettes were sold with detachable automatic belts. The 19B0

Chevette was equipped with a non-detachable belt and will be discussed in

section 3. Goodell-Grivas, Inc. observes and records seat belt usage data

for NHTSA in 19 cities. The most recent data, collected over the

May-October 1983 period, show the following results:

TABLE V-4

BELT USAGE DATA-1983

Usage

VW Rabbit 74.9%

Chevette 82.4%

The preceding table indicates that VW Rabbit drivers are using their

automatic belts about 75 percent of the time and Chevette drivers about 82

percent. However, the number of Chevette observations is too small to be

considered reliable and also may include some observations of 1980 MY

vehicles with the non-detachable belt system. Table V-5 combines data

from all observations from November 1977 to October 1983. Data for 1982 and

earlier years were collected by Opinion Research Corporation. The

aggregated data suggest that VW Rabbit usage may have fallen off

approximately 5% in recent times from the six year average of 80%. Chevette

usage exhibits the opposite trend with recent usage being 15% higher;

however, it must again be pointed out that the recent data are very

limited. While even the combined Chevette data contain too few

observations to draw precise usage estimates, the 95% confidence bounds
V-11

being 54 to 83* usage, usage rates within this confidence interval are from

four to six times the manual belt usage rate of 14 percent, indicating that

the automatic Chevette system substantially increased usage.

TABLE V-5

BELT USAGE DATA-1977-1983

Automatic Belt Manual Belt

Usage Observations Usage Observations

VW Rabbit 80% 1,343 32% 3,380

Chevette 70% 43 14% 4,691

In order to ascertain any change in automatic restraint usage as vehicles

age, observational data on restraint usage in VW Rabbits were collected by

model year from November 1980 to October 1982 (Table V-6).

TABLE V-6

USE OF RESTRAINTS IN VW RABBITS16

Automatic Manual

MY Observation % Usage Observation % Usage Difference

75 6 50.0 75

76 27 70.4 101

77 41 87.8 109

78 77 87.0 158

79 83 89.2 190

80 97 84.5 192

81 63 90.5 97

82 4 100.0 16

Table V-6 indicates that the automatic belt usage rate remains relatively

constant and at a high level for perhaps the first 5 years of vehicle use.

(The midpoint of the observation period was November 1981.) The data

suggest that usage tapers off after roughly the 5 year mark, which may

28.0

25.7

22.9

24.7

27.9

30.2

24.7

31.3

22.0

44.7

64.9

62.3

61.3

54.3

65.8

68.7

16 NHTSA tabulation based on data collected November 1980-October 1982 by

Opinion Research Corporation; reference: "Restraint System Usage in the

Traffic Population," ORC, May 1983, DOT-HS-806-424.
V-12

partly reflect the attitudes of second or third owners, but the number of

observations is too small for the early model years to reach a firm

conclusion in this regard. There is no known reason, however, why usage

would drop dramatically in the sixth year or so.

The automatic restraint system usage rates discussed above cannot be

considered rates likely to be achieved for detachable automatic belts in

the national fleet of vehicles for the following reasons: 1) both the VW

system and the MY 1978-79 automatic belt-equipped Chevettes had ignition

interlocks, which have been shown to greatly increase usage. The

Department cannot require ignition interlocks and it is unlikely that

vehicle manufacturers would voluntarily include them; 2) VW owners appear

to be atypical regarding seat belt usage judging by their manual belt usage

rate of 32%, which is more than twice as high as the observed fleet average

usage. However, this does not obviate the fact that features of the

automatic system itself that brought about substantial increases in usage

over manual belt rates, might increase usage in other vehicles as well,

although automatic belt usage likely would not be as high as in

Volkswagens; 3) both cars were subcompacts, which have higher usage than

larger cars; 4) some Rabbit and Chevette owners opted for (i.e.,

voluntarily purchased) the automatic belt, although as discussed below, the

restraint system appeared to play only a minor role in the purchase

decision (page V-19).

Another possible source of data which might help predict the usage of

detachable automatic belts is a study conducted in 1978-1979 by General

Motors. This study examined the usage rates of several different types of
V-13

restraint systems in rental cars at a Florida airport. In this survey, GM

fitted ninety Chevette rental vehicles with five different restraint

systems and an onboard electronic monitor to record belt use by the driver.

The five restraint systems included three two point automatic systems, one

of which had an interlock, and two manual systems. The results of this

study are shown in the following table:

Description

1. Auto with

interlock

2. Auto w/o

interlock

3. Auto w/o

interlock

4. Manual

Three Point

5. Manual

Three Point

TABLE V-7

CHEVETTE BELT RESTRAINT SYSTEM USE

FINAL DATA

Automatic

Shoulder Belt

Warning System Use Rate

Continuous Light —• 74%

Shoulder Belt

Continuous Buzzer — 57%

Shoulder Belt

Continuous Light — 23%

Shoulder Belt

Continuous Buzzer —

Production 4-8 Second

Light and Buzzer

STUDY

Manual

Belt Ignition

Usage Rate Starts

15%

(Manual Lap

Belt)

12%

(Manual Lap

Belt)

13%

(Manual Lap

Belt)

28%

(Lap/Shoulder

Belt

13%

(Lap/Shoulder

Belt)

TOTAL:

13,600

14,200

13,200

13,160

13,450

67,610

System No. 3 consisted of a 2-point, detachable automatic belt and

continuous light without an ignition interlock. This system had a usage

rate of 23 percent. System No. 1 was the same belt design except that it

came equipped with an interlock. This system showed a 74 percent usage

rate. Thus, it may be inferred that the interlock added 51 percentage
V-14

points to the jsage rate. Since the 74 percent usage rate is similar to

that observed in Rabbits, it could be construed that it is the interlock,

and not the automatic feature, which predominantly accounts for the high

belt usage in those cars. Although telephone survey results for the 1980

Chevettes, which do not have an ignition interlock, show usage rates of 70

percent, the 1980 Chevette system was not detachable.

Because this survey measured only rental vehicles, results may not be

indicative of the usage for privately owned vehicles. For example, long

term defeat measures, such as physically removing the system's automatic

capability, would not be reflected in the survey. Also, some drivers in

the survey may have accepted the automatic systems temporarily, but might

remove them from their personal vehicles or disable the warning and

interlock features. For these reasons, the GM survey seems to be at

best an indicator of the effect of automatic belts and interlocks.

Professor William Nordhaus in a comment to the docket asserts that the

Chevette rental car survey contains three basic flaws — 1) the lack of

public documentation on survey methodology and execution, 2) his

understanding that participants in the survey were informed that they were

involved in a study of seat belt usage, bringing into play the so-called

Hawthorne effect which may change participant behavior, and 3) his concern

over whether the rental agency took suitable steps to ensure that all belts

were attached before a new customer used a car. The agency has requested

clarification of these points from GM. GM stated that agreement was

reached with the rental company that the automatic belts would be attached
V-15

for each new customer, but documentation related to the Hawthorne effect

or the overall survey methodology and execution has not been provided to

the Department.

b. Usage in VW Rabbits Involved in Accidents

What the agency believes are the best and most recent data on seat belt

usage of accident involved VW Rabbits are reported in Table V-8. These

data, collected for NHTSA by the Highway Safety Research Center of the

University of North Carolina, have not previously been published.

TABLE V-8

VW RABBIT RESTRAINT USAGE IN ACCIDENTS

State

New York 1975-82

North Carolina

1975-83

Maryland 1975-82

Colorado 1975-79

Average/Total

Automatic Manual

Usage No. of Usage Number of

(%) Observations (%) Observations

52

48

63

^o

53

3,162

2,205

1,833

457

7,657

26

17

31

11

25

8,939

4,745

4,313

1,386

19,383

Difference

in Usage

(SO

26

31

32

23_

28

There is considerable difference between the observed usage of VW automatic

belts of 80%, as shown in Table V-5, and the usage found in VW's involved

in accidents reported above (53%) (also, in manual belt usage, 32% vs.

25%). This may be due to a number of reasons:
V-16

1) People who detach or otherwise deactivate their automatic belts may be

less safety conscious and more likely to be involved in crashes; thus, they

may be over-represented in the sample,

2) Since the accident data used are state data, which are typically

recorded after the fact by police, they may not accurately reflect actual

usage. There is no evidence to suggest, however, that an inherent bias was

entered that would affect the difference between the automatic and manual

usage. In fact, an analysis made on cases listing usage as "unknown" shows

no bias between the two systems.

3) The observed usage could be too high. While there is no compelling

reason to question the accuracy of the observed usage (since it was

recorded by personnel specifically trained for the task), the observational

data were recorded in 19 cities but do not cover rural area usage, which

might be somewhat lower. It appears highly unlikely, however, that

omission of rural area usage from the observational data accounts for the

large differences in the observational and accident usage data.

c. Telephone Surveys

Two telephone interview studies were conducted by Opinion Research

Corporation" about automatic belt owner usage and attitudes in GM Chevettes

and VW Rabbits. One of the studies covered MY's 1978 and 1979 and the

second covered MY 1980 vehicles. The VW Rabbit system is a 2-point system

"Automatic Safety Belt Systems Owner Usage and Attitudes in GM Chevettes

and VW Rabbits", Opinion Research Corporation, May 1980 and February 1981,

OOT-HS-805-399 and DOT-HS-805-797.
V-17

with a knee bolster and a starter interlock, anc did not change in MY's

1978-1980. In MY's 1978 and 1979, the GM Chevette system was a two-point

automatic shoulder belt with a knee bolster, a starter interlock and a

manual lap belt. However, in MY 1980, the Chevette design was changed to

a 3-point automatic lap shoulder belt. The MY 1980 Chevette design was

coercive in that it was basically non-separable. However, it did not

include a starter interlock. All three of these systems included an

emergency release button. In the case of the VW Rabbit and 1978-79

Chevettes with the 2-point system, the release button fully disconnected

the belt. However, with the starter interlock, the belt must be

reconnected to start the car. In the case of the 1980 Chevette, the

release button only disconnected the lap belt portion of the 3-point belt,

leaving an elongated shoulder belt still connected, which would offer

little safety value. Since the car did not have a starter interlock, the

lap belt could remain disconnected.

Usage of these belt systems compared to manual belt systems in the same

models, according to the telephone surveys, is shown in the following

table. While automatic Rabbit and Chevette usage from the telephone

surveys is in the range of observed usage, the manual system usage in both

telephone surveys is higher than currently observed usage.
V-18

TABLE V-9

MY's 1978-79 MY 1980

Percent who say Observed Data

they wear safety Percent who say from ORC and

belt always or they wore safety Goodell-Grivas

Automatic Rabbit

Manual Rabbit

Automatic Chevette

Manual Chevette

almost aways belt the last time :

89%

46%

72%

34%

89%

48%

70%

31%

studies

81-90%

26-36%

60-82%

11-15%

Factors which might explain why Rabbit owners use their belts more

frequently than Chevette owners as well as a number of other findings of

the surveys, are outlined below:

1) Rabbit owners typically have higher education levels and earn more

money. These demographic characteristics have been positively correlated

with usage.18 This is also shown by the higher usage of manual belts by

Rabbit owners.

2) More Chevette owners than Rabbit owners found the automatic belts

inconvenient and/or uncomfortable.

Opinion Research Corporation, May 1980, Ibid., pp. 50-53. A similar

conclusion was reached in the Market Opinion Research Survey — see page

V-B.
V-19

3) In the MY 1978-79 models, 10% of the 2-point belt Chevette owners and

11% of the Rabbit owners had defeated the interlock system. In the 1980

models, 22% of the 3-point belt Chevette owners and only 5% of the Rabbit

owners had removed the automatic belt or "fixed" it so that it could not be

used.

4) When asked what type of restraint system the owner would like if

purchasing another new car, the owners answered:

Prefer automatic

Prefer Manual

Other/no opinion

MY's

Automatic

Chevette

Owners

41%

49%

10%

1978-79

Automatic

Rabbit

Owners

80%

12%

00/

O/o

MY 1980

Automatic

Chevette

Owners

44%

4;%

7%

Automatic

Rabbit

Owners

74%

20%

6%

5) The restraint system seems to play a very minor role in the purchase of

a car. Only 5% of MY 1980 Chevette owners and 12% of MY 1980 Rabbit owners

specifically requested the automatic belt at the time of purhase. Of the

MY's 1978-79 owners, 55% of the Chevette and 37% of the Rabbit owners did

not know they were getting the automatic belt at the time of purchase.

These numbers declined somewhat in MY 1980 when 37% of Chevette owners and

25% of Rabbit owners were not aware that their cars were equipped with

automatic restraints. Asked why they decided to buy a car with automatic

belt systems, the MY 1980 owners replied:
V-20

Automatic

Chevette

38%

19

Automatic

Rabbit

39%

17

Only car available with all

the other options I wanted.

Only model available for

immediate delivery.

Liked the automatic belt. 12 23

Gave discount because of 3

belt system.

Belt usage by those who knew at the time of purchase that their car had an

automatic belt was higher than for those who did not know. For the Rabbit,

usage was 90% for those who knew and 85% for those who did not know. For

the Chevette, the figures were 74% and 62%, respectively. While automatic

belt purchasers who were not aware that their cars were so equipped are

similar to purchasers of mandated automatic restraints, the use-inducing

systems on the above cars are not expected to be widely included in future

models, particularly the interlock system. Thus, comparisons between these

usage rates and what can be expected for all cars need to be made

carefully.

6) Another question asked was whether the MY 1980 owners wore seat belts

in their other cars or their previously owned car the last time they drove.

Only 25% of the automatic Chevette owners stated that they used their

manual belts the last time they drove another car, while 33% of the

automatic Rabbit owners claimed they used their manual belts the last time

they drove another car. Thus, either the automatic nature of the belt, the
V-21

use-inducing features, and/or simply the "newness" of the vehicle greatly

increased belt usage, and our data do not permit us to separate the

contributions of the three factors.

7) Sixty-seven percent of MY 1980 Rabbit owners said that if there were no

interlock they would use the belt, 25% would probably not use it, and

7% would never use it. This can be compared to the owners' first

impressions and impressions after they had owned the car for a while:

First Impression Later Impression

Aut

Che

Favorable

Unfavorable

No opinion

Of the Rabbit owners, 61% were favorably impressed when they first tried

the system. This is close to the 67% that said they would use the

restraint even if it did not have an interlock. The Chevette owners had a

lower percentage with a favorable first impression.

Telephone survey data indicate that there is some decrement in usage of

automatic belts over time. Owners of MY 1978-79 Chevettes, who

participated in a 1979 survey, were called back in 1981.T Their reported

usage was lower than they had reported in 1979.

Automatic

Chevette

39%

54

7

Automatic

Rabbit

61%

32

7

Automatic

Chevette

49%

44

7

Automatic

Rabbit

77%

18

5

19 "Automatic Safety Belt Systems: Changes in Owner Usage over Time in GM

Chevettes and VW Rabbits," Opinion Research Corporation, August 1981,

DOT-HS-806-058.
V-22

Reported Usage

Percentage

1979 1981 Point Change

MY

MY

1978 Rabbits

1978-79 Chevettes

89.

73.

1%

9%

83

62

no'

• U/o

00'

. O/o

-6.1

-11.1

Reported Rabbit belt usage declined 6.1 percentage points over the two

years, an average of 3.0 percentage points per year. The reported

decrement in Chevette belt usage was larger, 11.1 percentage points over

the two years or an average of 5.5 percentage points a year. Note that

this reported decline in automatic belt usage over the 2-year period does

not agree with on-road observational data shown in Table V-6, which

indicates that automatic belt usage in VW Rabbits-did not change as the

vehicles aged over the first five years of use.

Surveys in 1979 and 1980 by Teknekron Research, Inc., and Automated

Services, Inc., respectively, asked licensed drivers what they thought of

the idea of automatic belts in the next cars they purchased. The responses

were as follows:
V-23

TABLE V-10

PUBLIC OPINION OF AUTOMATIC BELTS

RESPONSE 1979 %20 I2aa21

A Great Idea

Tolerate

Disconnect

Other

Don't Know

These surveys indicate a general willingness to try automatic belts,

but they also indicate a hard-core non-user group (32.3% and 21.9% said

they would disconnect the system in 1979 and 1980, respectively).

3. Non-Detachable Automatic Belt

The agency has usage data on one non-detachable automatic belt system, the

Toyota motorized system:

38.0

25.0

32.3

1.2

3.5

45.3

29.1

21.9

3.8

20 »1979 survey of Public Perceptions on Highway Safety," Teknekron Reksearch,

Inc., July 1979, DOT HS-805-165, p.44.

21 "1980 Survey of Public Perceptions on Highway Safety," Automated Services,

Inc., September 1980, DOT HS-805-702, p. 51.
V-24

Toyota Motorized System

On-Road Telephone and Mail

Observations Percent Usage Survey Responses Percent Usage

203 96 755 92

Two hundred and three on-road observations were recorded with 96 percent

usage.22 Telephone and mail surveys found 92 percent usage for 755

respondents.25 yne agency does not believe that these Toyota usage data can

be used to estimate usage of non-detachable belts for the entire fleet

because of the voluntary aspects of purchasing the automatic belt cars and

because this motorized system would probably not be used by many

manufacturers due to its expense.

While the MY 1980 Chevette automatic restraint system, which disconnected

at the lap belt portion of the 3-point belt leaving an elongated shoulder

belt, might be considered a non-detachable belt, the agency does not have

any observed usage data on this system. A telephone survey found 70

percent usage for 1,002 respondents.24

22 "Safety Belt Usage Among Drivers," Opinion Research Corp., May 1980, DOT

HS-805-398; "Restraint System Usage in the Traffic Population," Opinion

Research Corp., May 1983, DOT HS-806-424; "Progress Report on Restraint

System Usage in the Traffic Population," Goodell-Grivas, Inc., November

1983.

23 "Automatic Safety Belt Usage in 1981 Toyotas," 3WK International Corp.,

February 1982, DOT-HS-806-146.

24 "Automatic Safety Belt System Owner Usage and Attitudes in GM Chevettes and

VW Rabbits (1980 Models)" Opinion Research Corp. February 1981,

DOT-HS-805-797.
V-25

It is possible that the usage rates of automatic belts with interlocks may

be similar to those of non-detachable automatic belts. Although there are

significant differences in both the physical design and the nature of the

usage inducement in these systems, they are similar in requiring

considerable effort on the owner's part in order to defeat their automatic

protection features. However, as previously discussed, the available

surveys that examine usage of interlock systems (GM survey and VW Rabbit

usage data) are not representative because they are implicitly biased since

they represent mostly persons who are more than typically safety conscious,

or persons who do not own the sampled vehicles. Therefore, usage data on

existing automatic belt systems with an interlock should not be considered

indicative of future usage rates for non-detachable belts.

The GM rental car study does indicate that more stringent use-inducing

systems will result in higher usage rates. For example, the most stringent

system (System 1) , which included a starter interlock, had a usage

rate that was 30 percent (17 percentage points) higher than the second most

inducive system (System 2) , which had only a continuous buzzer. The buzzer

system was, in turn, nearly 150 percent (34 percentage points) higher than

the least inducive automatic belt system (System 3) , which had only a

continuous light. The interlock system (System 1) was a full 51 percentage

points higher than the least inducive automatic system (System 3) , as

mentioned earlier. As discussed above, some issues have been raised on the

methodology of this study.
V-26

B. Restraint Usage Level Estimation

In this section, restraint usage levels for the calculation of benefits are

estimated. The available data do not permit a precise estimate of future

automatic seat belt usage rates; therefore, an estimate of a lower and an

upper usage boundary to establish a range of expected usage for automatic

seat belts is developed. The actual future usage level is expected to

fall at some point within the estimated range and not at either extreme.

An air bag readiness factor is also estimated.

1. Automatic Seat Belts

A range of possible levels of usage of automatic seat belts will be

calculated based on all the data available to the agency on observed

on-road usage of manual belts, self-reported manual seat belt usage, and

attitudes on seat belt usage. In addition, approaches are employed to

estimate usage based on automatic and manual seat belt usage data from

telephone surveys, on-the-road observations, and accident reports.

The first approach for estimating a range of possible automatic seat belt

usage is to consider observed on-road usage. The 1983, 19-city, observed

driver manual belt usage rate of 14.0% (Table V-1) could be accepted as the

minimum level of usage of automatic belts to be expected. As discussed

below, however, other information supports a somewhat higher lower bound

for automatic belt usage.
V-27

A second approach is to lrok at the results of surveys on self-reported

manual seat belt usage to gauge occupants' actual practices regarding belt

usage. Table V-2 presents the results of 8 surveys on manual seat belt

use. Based on the table, manual seat belt users can be segregated into

those who say they use belts always or almost always, those who say they

never or almost never use belts, and those that fall somewhere in between.

"Always or almost always" has a range of 16-24 percent and averages 21

percent. This is fairly consistent with the 17 percent confirmed belt

users found in the 1977 Market Opinion Research study discussed above.

However, these figures are higher than actual usage rates recorded in

roadside observations in 19 cities over the period, which ranged from 11-14

percent (Table V-1). One interpretation would be that while respondents

apparently overstate their actual belt use, a fact documented by Waller and

Barry as mentioned above, in their own minds they consider themselves to be

belt users. Such an interpretation would suggest a lower boundary on

automatic belt use of approximately 20 percent, with some certainty that at

least this percentage of occupants would use automatic belts.

The percentage of occupants who never buckle up might serve to help

approximate the percentage of hard core non-users, those who likely would

not use detachable automatic belts. Table V-2 reports a percentage of

respondents in the six surveys who say they never or almost never buckle up

ranging from 30-59 percent, with an average of 48 percent. In three of

the six surveys, the 1978 Hart (565K), the 1982 Lawrence Oohnson (39%), and

the 1984 McGinley survey (30?o), this response means "never" or no use of

belts. Two additional surveys reported by Newport and Tarrance (1981) and

Tarrance and Associates (1983) showed 40 percent and 33 percent
V-28

"infrequent" users, respectively. The 1982 Lawrence Johnson survey

response was also classified into frequent, sometime, and infrequent users,

with 41 percent being classified as infrequent users. The foregoing

suggests that about 30-40 percent of vehicle occupants could be classified

as non-users of manual belts. This is reasonably consistent with the 43

percent non-users found in the 1977 Market Opinion Research study. Some

unknown proportion of these manual belt non-users could become users of

automatic belts, since they would have the convenience of not having to

buckle up. As shown in Table V-10, 27 percent of the licensed drivers

surveyed (average of the 1979 and 1980 surveys) said they would disconnect

automatic belts. This suggests that perhaps 5-15 percent (30?o-40K less

27SD) of those who never wear manual belts might wear automatic belts.

A third approach in attempting to gauge future automatic belt usage is to

look at the reasons people give for not using manual belts. Table V-3

provides results of two surveys sponsored by NHTSA on the subject.

Interviewers asked both seat belt users and non users for reasons for not

wearing belts. The number of respondents who reported no reasons for

disliking or not using belts, an average of 15.5 percent for the two

surveys, is according to one of the surveyers, Teknekron Research, Inc.,

probably the true indicator of how many people in the sample wear their

safety belts, although it cannot be proven.

An indicator of hard core non-users who would be most unlikely to use a

belt system, including an automatic, detachable system, is the percentage

stating as the reasons they do not want to use manual belts (1) they don't
V-29

want to be restrained, (2) they are afraid of bring trapped in a car during

an accident, or (3) they doubt the value of belts as a safety measure.

Following is the tabulation of these responses:

1979 1980 Average

"Don't want to be restrained" 7.7% 8.8% 8.3%

"Afraid of being trapped in 10.7% 11.058 10.9%

car during accident"

"Doubt value as safety measure" 4.5% 5.8% 5.2%

22.9% 25.6% 24.2%

Twenty four percent of the respondents gave reasons for not using manual

belt systems that would also pertain to automatic belt systems. This

indicates that an upper boundary of automatic belt usage would be

approximately 76 percent. As far as overall belt usage expectations are

concerned, the pertinent question is what proportion of the remaining

approximately 60 percent who are neither present belt users nor established

hard core non-users might be induced or compelled by features of automatic

belt systems into using them. This suggests that this portion of the

population could be positively influenced toward increased belt usage by

effective public information and education programs and improved belt

designs.

Reasons for not wearing belts that could be negated by the automatic belt

systems are " don't want to be bothered, lazy, forgetful" (17.8%) (Table

V-3). If the problem of being bothered, lazy and forgetful were the only
V-30

reason for this 17.8 percent of the people not buckling up. we could derive

an approximate lower bound for automatic belt usage of 33 percent (15.5

percent with no reason (users) plus the 17.8 percent who said they did not

want to be bothered or were lazy or forgetful). However, we do not know

how many of the 17.8 percent might also have other reasons for not buckling

up which would preclude them from using automatic systems as well.

Therefore, the most that can be said is that a lower usage rate bound would

fall within the 15-33 percent range.

While the analysis points to a lower usage boundary of 15-33 percent,

actual usage would probably be above this limit. It is likely that some of

those who found manual belts uncomfortable (14.4%) or inconvenient to use

(16.2%) will find that these problems do not exist with automatic belts. A

1976 survey of owners of 1975 Volkswagens, including 2,196 with automatic

systems and 561 with manual systems, asked respondents to relate their

experience with specific comfort and convenience problems associated with

automatic and manual belt systems. Table V—11 shows the percent of persons

by type of belt system who indicated they have experienced the various

problems. The right hand column indicates the extent to which particular

problems were more prevalent in Volkswagens with manual belts than with

automatic belts. The automatic system was superior in all areas of comfort

and convenience shown relating to the belt system itself. The obvious

inconvenience associated with the automatic belt system is that of getting

in and out of the car. The experience and opinions of owners of both types

of belt systems indicate that some, perhaps a substantial number, of those
V-31

who do not use manual belts because they are inconvenient and uncomfortable

will use automatic belts because they find that these problems no longer

exist or their severity is significantly reduced. Other data indicating

TABLE V-11

PERCENT WITH PROBLEM25

ISSUE

Jewelry Lost, or Damaged

Belt Falls off Shoulder

Belt Hard on Clothing

Belt Rubs on Face or Neck

Belt Exerts Pressure on Chest

Belt Chafing or Rubbing Chest

Belt Hinders Reach for Glove

Compartment or Controls

Padded Knee Panel (Auto)

Belt Interferes With Entering

Car (Auto)

Belt Interferes With Exiting

Car Auto

Fastening or Buckling Belt (Manual)

Belt Retractor Locks When Buckling

(Manual)

Belt Interferes With Entering Back

Seat (Manual)

Belt Attachments Inaccessible (Manual)

AUTOMATIC

10

10

16

19

19

23

25

16

37

38

__

—

MANUAL

14

19

36

42

39

38

43

—

38

42

50

44

DIFFERENCE

ADVANTAGEAUTOMATIC

OVER MANUAL

4%

9

20

23

20

15

18

-16

-37

-38

38

42

50

44

that automatic belts are more comfortable and convenient than manual belts

are presented in Chapter' XI.

These findings on the attitudes of Rabbit owners are not supported,

however, by the results of the survey of Chevette (and Rabbit) owners

reported above (p. V-19). Forty nine percent of the owners of MY's 1978-79

2 5 "Passive vs. Active Safety Belt Systems in Volkswagen Rabbits: A

Comparison of Owner Use Habits and Attitudes;" Opinion Reasearch

Corporation, August 1976,DOT-HS-801-958.
V-32

Chevettes with automatic belts and 49 percent of the owners of similar MY

1980 Chevettes said they preferred manual belts, compared to 41 percent and

44 percent, respectively, who preferred their automatic belts.

In conclusion, the attitudinal surveys discussed appear to support a lower

boundary of automatic seat belt usage of 15-33 percent and an upper

boundary in the area of 75 percent. The lower limit range is just above

the observed driver manual belt usage rate of 14 percent and is consistent

with the value of 20 percent drawn from self-reported usage data discussed

in the previous section; the upper limit is 5-15 percentage points higher.

Another approach to estimating automatic seat belt usage entails

investigation of usage rates for the relatively few automatic systems in

place. Table V-12 presents data on automatic and manual belt use in VW

Rabbits and Chevrolet Chevettes. The VW Rabbit accident data are the most

recent and best available. Data on usage of the motorized automatic belt

system in Toyota Cressidas are not included since, as stated previously,

the agency believes that this luxury system is not likely to be typical of

future systems.

In analyzing and interpreting the Rabbit and Chevette automatic restraint

usage data in Table V-12, it should be understood that for reasons

enumerated above (page V-11), the usage rates reported are higher, possibly

substantially, than could likely be expected in a future fleet of automatic

belt equipped vehicles. The high usage rate is principally attributable to
V-33

the starter interlock on the VW system and on MY 1978-79 Chevettes, and to

the greater propensity, especially for the Rabbit owners, to use seat

belts.

It is readily noticeable that VW restraint usage rates for accident data

are markedly lower than rates ascertained from surveys (discussed above,

pages V-13 and V-14). Usage estimates based on accident restraint usage

data are therefore shown separately. Estimates based on combinations of

accident and survey restraint usage rates are also shown.

One method of using these data for estimating future use of automatic

belts, which compensates for the high Rabbit and Chevette owner usage

rates, is not to use the rates per se but to assume that the relationshipr

between usage rates for automatic and manual belts for Rabbits and

Chevettes will apply in the future to vehicles that currently do not have

automatic belts. Column (c) of Table V-12 shows the percentage point

increment of automatic belt usage over manual belt usage. One possibility

is to take the increment that automatic belt usage is over manual belt and

add it to the current fleet usage rate to estimate the future fleet

automatic belt usage rate.
V-34

TABLE V-12

AUTOMATIC AND MANUAL BELT USAGE

On-Road Observations^

1977-83 VW Rabbit

1980-83 Chevette

Weighted

Average observation data

Accident Data VW Rabbit27

1975-82 New York

1975-83 North Carolina

1975-82 Maryland

1975-79 Colorado

Weighted

Average Accident Data

telephone Surveys"

MY 1978-80 Rabbit

MY 1978-79 Chevette

MY 1980 Chevette

Weighted

Average Telephone

Surveys

Range of Values

Weighted Averages

Rabbit Accidents

Rabbit, Observation &

Surveys

All Rabbit

Chevette

Rabbit and Chevette

Excl. Ace.

Overall Average

(a)

Automatic

Usage

(Percent) Number

80

70

80

52

48

63

50

53

89

72

70

80

50-89

53

85

63

71

80

64

1,343

43

1,386

3,162

2,205

1,833

457

7,657

2,023

1,002

1,002

4,027

-

7,657

3,366

11,023

2,047

5,413

13,070

(b)

Manual

Usage

(Percent) Number

32

14

22

26

17

31

27

25

47

34

31

40

14-47

25

34

25

16

23

23

3,380

4,691

8,071

8,939

4,745

4,313

1,386

19,383

425

216

208

849

-

19,383

3,805

23,188

5,115

8,920

28,303

(c)

Differences

in usage

(a)-(b)

48

56

58

26

31

32

23

28

42

38

39

40

29-56

28

51

38

55

57

41

(d)

Multiplier

(a) / (b)

2.5

5.0

3.6

2.0

2.8

2.0

1.9

2.1

1.9

2.1

2.3

2.0

1.9-5.0

2.1

2.5

2.5

4.4

3.5

2.8

2 ^ Opinion Research Corporation, "Safety Belt Usage Among Drivers," May 1980,

DOT-HS-805-398, and "Restraint System Usage in the Traffic Population,"

May 1983, DOT-HS-806-424, collected November 1980 to October 1982;

Goodell-Grivas, Inc., 1983 data.

2 7 Collected for NHTSA by Highway Safety Research Center, University of North

Carolina, not previously published.

2 ° Opinion Research Corporation, "Automatic Safety Belt System Owner Usage and

Attitudes in GM. Chevettes and VW Rabbits," May 1980 and February 1981,

DOT-HS-805-399, DOT-HS-805-797.
V-35

For example, the average automatic belt usage increment for on-road

observations, 58 percentage points, could be added to the observed 1983

driver manual belt usage rate of 14 percent to derive an estimated

automatic belt usage rate of 72 percent. This has been termed the

incremental approach.

Another possibility is to take the ratio of automatic belt use to manual

belt use and assume that this relationship would hold for the future fleet

of vehicles. This has been termed the multiplier approach to estimating

future automatic belt usage. Column (d) of Table V-12 shows the ratios of

automatic to manual belt usage rates. The multiplier (ratio) for on-road

observations is 3.6. The multiplicative technique entails multiplying this

factor by the current 19-city driver usage rate (14 percent) to derive

estimated future use (3.6 x 14%s50!«). Table V-13 presents various

estimates of future automatic belt usage based on the incremental and

multiplier approaches applied to a manual belt usage rate of 14 percent,

the observed, 19-city 1983 value for drivers of the on-road fleet.

As shown in Table V-13, the incremental approach for estimating future

automatic belt usage produces a range of 42-71 percent with a value of 55

percent for all data; the multiplier approach produces a range of 29-62

percent usage with a value of 39 percent for all data. Note that the

averages excluding accident data are higher, 71 percent usage
V-36

TABLE V-13

ESTIMATED FUTURE AUTOMATIC BELT USAGE RATES FROM

APPLYING INCREMENTAL AND MULTIPLIER FACT0RS29

(PERCENT)

Data Source Incremental Approach Multiplier Approach

Rabbit Accidents

Rabbit Observation and Surveys

All Rabbit

Chevette Observations and Surveys

Rabbit and Chevette Excl. Ace.

All Rabbit and Chevette

Range 42-71 29-62

applying the incremental approach and 49 percent applying the multiplier

approach. This is not surprising given the markedly lower restraint system

usage rates, especially automatic belt usage, in VW Rabbits involved in

accidents.20 Note that the above rates apply only to drivers; full front

usage would be about 5 percentage points lower.

42

65

52

eys 69

71

55

29

35

35

62

49

39

Based on data in Table V-12; increments and multipliers applied to 1983

driver manual belt usage rate of 14 percent, based on observations in 19

cities.

An estimate of automatic belt usage incremental and multiplier values can

be developed for vehicles involved in fatal accidents using FARS data and

employing a methodology presented in the preliminary regulatory impact

analysis. (PRIA, footnote p. IV-16) Assuming manual belt usage for VW

Rabbits of 30%, fatality effectiveness ranges of 35-50% for automatic belts

and 40-50% for manual belts, and given that for VW Rabbits the FARS

data indicate that the fatality rate for automatic belts is 19.3% less than

the fatality rate for manual belts as used (PRIA, Table IV-5, page IV-15),

incremental automatic belt usage over manual belts would be 33-53

percentage points. Thus, total usage of Rabbit automatic belts in fatal

accidents would be 63-83%. Using a manual belt usage rate of 25% as found

in accidents would result in an increment of automatic belt use over manual

belt of 34-53 percentage points, nearly identical to the previous

calculation. The calculated incremental usage is largely insensitive to

the manual belt usage rate. In this latter example, usage of Rabbit

automatic belts in fatal accidents would be 59-78%.
I

f

V-37 I

Table V-14 summarizes the estimates of automatic seat belt usage rates

developed in the preceding analysis based on (1) on-road observations of

driver manual belt use in all cars, (2) surveys in which respondents state

their manual seat belt usage rates, (3) attitudinal surveys on why the

driving public does not wear manual belts and on problems experienced with

manual and automatic systems, and (4) on observational and telephone

surveys and accident statistics on automatic and manual belt use. For the

first three data categories, estimated bounds of automatic seat belt usage

are presented, with the lower bound relating to confirmed or dedicated

users and the upper bound reflecting that there will be a group of

hard-core non-users of coercive automatic restraints. The lower and upper

usage rate bounds that are estimated are not themselves likely to be the

actual rates realized. Although probabilities have not been developed,

actual usage is expected to fall within the range established by these

lower and upper bounds. For the fourth category of data, a number of

possible usage rates (not bounds), derived by employing the multiplier and

incremental approaches, are presented.

From the data and information available, the agency has derived an

estimated range of automatic seat belt usage of 20-70%. The estimate of 20

percent for the lower restraint usage boundary is based on the observed

1983 driver manual belt usage rate (14%), telephone and home-interview

surveys on manual belt use (20%), and on reasons people give in surveys

for not buckling up (15-33%). The estimate of 70 percent for the upper

boundary is based on the estimates derived from surveys on manual belt use

(60-70%) and surveys on why people do not buckle up (75%).
V-38

TABLE V-14

ESTIMATED USAGE RATES FOR AUTOMATIC BELTS

(PERCENT)

Lower Multiplier Incremental Upper

Data Source Bound Method31 Method31 Bound

28

50

29

54

72

42

1983 Driver Manual Belt 14

Use, on-road Observations

in 19 Cities

Telephone and 20 60-70

Home-Interview

Surveys on Manual Belt Use

Stated Reasons on Why 15-33 75

People Don't Buckle up

Telephone Surveys

On-Road Observations

Accident Data

Average-Telephone and 49 71

Observation Data (Excl., Ace.)

Average-All Data 39 55

Low and High Point Estimates 28-50 42-72

Overall Estimate: Lower Bound 20%

Upper Bound 70SK

The estimates that are based on the multipier and incremental approaches

are consistent with the 20-70% range. The two approaches are distinct

methods for estimating usage, and each set of values should not be

interpreted as deliniating a lower and an upper boundary.

See Table V-12. The higher and lower figures are not to be considered

ranges; both are point estimates of the usage rate.
V-39

Of the two boundaries, the.1 lower is perhaps the most controversial. Based

on the information before it, the agency believes that usage of automatic

belts would be higher than for current manual belts and that a lower usage

bound of 20 percent, as supported by the foregoing analysis, is reasonable.

However, General Motors believes that both non-detachable and detachable

automatic belt usage rates will fall to manual belt usage rates; increased

usage will last only until the belt is disconnected the first time. In

that case, usage would be below the estimated range. In its response to

the SNPRM, GM estimated that automatic belts might increase usage by 5

percentage points - the comment did not indicate for how long. Honda feels

that long-run usage of automatic belts may not be better than current

manual usage, the key determinants being comfort and convenience. Ford

believes that while the use of automatic belts will be higher than for

manual belts for a period, reflecting increased usage by occasional manual

belt users, over the long run usage of automatic and manual belts will be

equivalent. Other manufacturers believe there will be little, albeit some,

increase in usage. Chrysler feels that automatic belt usage will be less

than 10 percent higher than manual belt usage.

On the other hand, the American Seat Belt Council believes usage of

automatic belts will be 50 percent, roughly between the current observed

rate for drivers of 14 percent for manual belts and 80 percent for in-use

automatic belts. Professor William Nordhaus applies a usage increment for

automatic belts of 33 percentage points in his calculations, based on the

VW accident experience in the Fatal Accident Reporting System and NHTSA

assumptions on restraint effectiveness that were published in the

Preliminary Regulatory Impact Analysis. Adding this increment to the
V-40

current driver manual belt usage rato of 14 percent results in an automatic

belt usage rate of 47 percent for drivers. John Graham found that expert

opinion varies on how much automatic belts would increase usage. His

survey of 7 experts found that detachable belts would increase usage by 10

percentage points with an 80 percent confidence interval of 5 to 40

percentage points.

The critical difference between automatic belts and current manual

belts—inertia—could increase usage substantially. Once an automatic belt

is connected, it continues to function automatically until disconnected.

The agency believes that inertia will increase automatic over manual belt

usage but cannot estimate the amount. General Motors states, however, that

the inertia effect of automatic belts can only be assumed until the belts

are first detached. However, disconnecting belts does not necessarily

mean that they will stay disconnected. Current occasional users may

reconnect them, and the inertia effect would again be operational. Also,

other occupants may reconnect them and leave them connected when they get

out.

Usage rates could also be affected by use-inducing or reminder mechanisms

such as a continuous buzzer, a 4-8 second buzzer, or a light. The American

Seat Belt Council believes that a continuous buzzer could double usage and

that buzzers, chimes, and lights could all increase usage; Volvo thinks

that usage can be improved through a visual warning plus an audible signal

consisting of a "ticking" sound that is no more annoying than the sound in

turn signal systems; Volkswagen feels that a continuous buzzer might be as

effective as an interlock. Ford, on the other hand, feels that while a
V-41

continuous buzzer would induce some borderline non-users to use belts,

driver irritation and counteraction to defeat the system could be

expected. (A 4-8 second buzzer is required with current manual belts and

is also required for automatic belts.) However, neither a continuous

buzzer, nor an interlock system may be required by the agency.

An issue arises — whether to establish different bounds for detachable and

non-detachable belts. The difference between the two systems refers to the,

webbing release mechanism. The detachable belt has a push button "buckle

release" which, when pressed, physically disconnects the belt. The

non-detachable belt has a "spool release" mounted on the retractor to allow

for emergency egress. When actuated, additional webbing is released from

the retractor spool, but the belt cannot be completely separated. Thus

far, the 1980 Chevette and Toyota Cressidas since MY 1981 are the only

production vehicles that have been equipped with non-detachable automatic

belts.

Numerous auto manufacturers, IIHS, two restraint system suppliers (Breed

Corporation and American Seat Belt Council), a state agency, a consumer

group and an individual provided comments on non-detachable belt usage and

acceptance. A representative sampling of comments follows:

GM — The public will not accept the coercive non-detachable belt as shown

with the 1980 Chevette. Fear of entrapment and general annoyance would

lead many hard core non-users to defeat non-detachable belts. While there

would be an initial increase in usage, long term usage of either

detachable or non-detachable belts would fall to manual belt usage rates.
V-42

Ford — There is bound to be some adverse reaction to non-de!;achable belts

due to fear of entrapment. Although initially higher, long range usage of

non-detachable belts would eventually drop down to detachable belt rates,

which would be equivalent to rates for manual belts.

Volkswagen — Hard core non-users would find non-detachable belts more

objectionable than detachable belts.

Honda — Non-detachable belts would not be accepted by the public because

of entry/exit problems, entrapment, and poor appearance. Hard core

non-users will react adversely. In the short run, non-detachable belts

would increase usage; in the long run usage is dependent upon comfort.

Nissan — There would be no difference in the long run usage rates of

detachable and non-detachable belts. Non-detachable belts would engender

adverse public reaction.

Saab Scania — 15-30 percent of the driving public may not have any belts

after non-detachable belts are made inoperable.

Breed — There will be significant levels of disconnect with non-detachable

belts. European experience indicates 20 percent will not use belts.

American Seat Belt Council — 10-20 percent are hard core non-users who

will cut out non-detachable belts. This would result in enough irate

people to provoke Congress to repeal the requirement.
V-43

Massachusetts Department of Public Health — To maximize the usage of

automatic belts, they should not be readily detachable.

Motor Voters, a consumer group — the required installation of automatic

belts, especially those designed to make disconnection difficult, would

engender public reaction not merely to defeat the belts, but to defeat the

entire rule.

Insurance Institute for Highway Safety — The IIHS survey, which the agency

believes does not yield valid results (see Chapter XI), indicates only 12

percent would damage a non-detachable belt.

John Graham — A survey of 7 experts in the field found that non-detachable

belts would cause substantial public irritation and ultimate rejection by

Congress. A survey of A behavioral experts estimated that 55 percent of

motorists would dismantle non-detachable belts. A fifth behavioral expert

believed that Congress would outlaw non-detachable belts.

In summary, the docket comments indicate a diversity of opinion on

differences in usage of detachable and non-detachable belts. Some

commenters stated that detachable and non-detachable belts would provide

the same level of usage. Others discussed the two belt systems separately,

indicating that a detachable belt may increase the usage of occasional

users, while the non-detachable belt might affect all but the hard core

non-users. However, nearly all commenters indicated that non-detachable
V-44

belts would engender adverse public reaction by at least the hard core

non-users (10-20 percent of drivers) with possible ultimate rejection by

Congress.

Another distinction made between detachable and non-detachable belts is in

long term availability. If 10-205o of drivers cut out non-detachable belts,

they will be unavailable to future owners or users of these cars. When

they are sold and resold, the proportion of cars with cut-out belts would

increase.^2

The agency believes that some increment of usage should be imputed to

non-detachable belts, since some effort would be required to deactivate the

system. However, because the information available does not permit such

precision, separate usage bounds for detachable and non-detachabls belts

are not estimated. Usage rates for future non-detachable automatic belt

systems would probably be above usage rates for future detachable

systems, with both rates falling within the estimated 20-70* usage range.

The effect of a starter interlock, which prevents a vehicle from being

started if the belt is not attached, warrants further discussion because of

its possible large impact on usage. Practically all of the information

gathered on actual usage of automatic belts and incorporated into the

foregoing analyses pertained to usage in VW Rabbits, and to a lesser

extent, GM Chevettes. As discussed above, both of these cars had

detachable belt systems with an interlock, except for the approximately

Twenty-one states currently have periodic motor vehicle inspections which

could counter this problem. Eight of these states already have safety

belts on their inspection check list.
V-45

10,000 1980 MY Chevettes which had a non-detachable lap-shoulder belt

system with no interlock. It would be difficult to argue that an interlock

system, which prevents the car from being started if the belt is detached,

does not increase usage. Volkswagen has stated to the docket that the

interlock is the real use inducing factor and has advised against using the

high usage rates of automatic systems with interlock in VW Rabbits to

predict usage rates for fleets of other vehicles. And, as presented above,

the Chevette rental car study showed a 51 percentage point higher usage

rate for automatic belts with interlock (Table V-7). While restraint usage

in rental cars may not be indicative of usage rates in private cars, and

belts may not have been reattached after each rental, it nevertheless seems

likely that .much of the difference in usage is attributable to the

interlock.

The only evidence that an interlock system is not the primary use inducing

feature is the limited telephone survey data on usage in MY 1978-79

Chevettes with interlock {12%) and MY 1980 Chevettes with an automatic belt

system without interlock (1Q%). (Table V-9) However, the MY 1980 system

disconnected only at the lap belt portion of the 3-point belt leaving an

elongated shoulder belt, which was in effect a non-detachable belt; it

seems reasonable to presume that this characteristic increased usage. The

agency believes that the interlock does increase usage and that the usage

rates for the future vehicle fleet with detachable automatic belt systems

without interlock would be lower than they would be with an Interlock.
V-46

In view of the preceding and for reasons stated above, estimates of usage

of automatic seat belt systems that are based on experience with systems

with interlocks are likely higher, possibly substantially, than could be

expected in a future fleet of vehicles equipped with automatic belt systems

without interlock. Therefore, usage estimates that are presented above,

which are based on the Rabbit and Chevette data, are probably higher than

should be expected.

The actual usage rate to be realized in the future will of course depend on

the many considerations discussed above, such as comfort and convenience

and acceptance of the system's appearance, and on education programs to

increase usage. National public informational and educational programs

could be started before any law mandating automatic belts went into effect

and continue thereafter. Such efforts could emphasize the safety benefits

of wearing safety belts and highlight the fact that automatic belts are

more comfortable and convenient to use than manual belts, a fact verified

by numerous studies. Information could also be provided to overcome the

concerns of those who report that they doubt the value of belts as safety

measures and of those who say they are afraid of being trapped in their

vehicles after an accident. The Department believes that such

informational and educational programs would play a key role in increasing

usage of automatic belts. The future usage rate will also depend on the

automatic systems' proven on-road effectiveness in reducing deaths and

injuries and the amount of publicity thereon.
V-47

2. Seat Belt Usage Under Mandatory Use Laws

This section discusses the potential usage of manual seat belts under state

mandatory seat belt usage laws. It also examines various factors that

could affect seat belt usage under mandatory usage laws and attempts to

estimate a range of probable usage that might be expected under MUL's.

As discussed above, voluntary manual belt use by drivers in 19 major cities

throughout the country in 1983, was about 14 percent, while usage by all

front seat occupants was 12.5 percent. The extent to which mandatory use

laws would increase these usage rates would depend on many factors, the

most important being the number and the specific states that pass such

laws, the provisions for enforcement and sanctioning for non-compliance in

each state, the amount of publicity on enforcement activities, and the

extent and quality of education and publicity on the potential benefits of

seat belt use. For the purposes of this analysis, the usage rate is

estimated at the national level and is based on the assumption that MUL's

were universally adopted. (However, to a large degree, the considerations

and relationships discussed here would also pertain to seat belt usage

under MUL's in individual states). To the degree that MUL's would not be in

effect in all states, national usage would, obviously, be less due to lower

usage in states without MUL's.

Changes in belt usage rates in countries which have enacted MUL's might

serve to gauge how much MUL's would increase usage in the United States.

Table V-15 lists the 29 countries with MUL's. As shown, usage laws are in

effect in six countries in Asia/Africa/Mid-East, 16 countries in Western
V-48

Europe (Iceland and Italy are the only countries of Western Europe that do

not require belt usage), five countries in Eastern Europe, seven provinces

of Canada, and the Commonwealth of Puerto Rico.

The most common program requirements and enforcement and sanction practices

among these countries are summarized below:

Vehicles Covered; Typically passenger cars or cars and vans

Occupants Covered; Typically all front seat occupants

Exemptions; Typical exemptions are based on age, body size, and medical

condition.

Enforcement; In two-thirds of the countries, when stopped for another

purpose; in one-third either none or advice to buckle up by police.

Fine; In most countries (equivalent of) $10-$20; in a few, none or

minimal; in one, up to $250.

Exceptions; Vary widely by country; in most countries, belt usage is not

required in vehicles which are moving in reverse.

Table V-16 presents driver seat belt usage rates before and after MUL's

went into effect in 17 countries for which such information is available.

Usage data for Canada are not included in this table, but are shown and

discussed separately below. The manner in which data were collected and

the types of roadways and traffic conditions which were surveyed varied

from country to country. As shown, usage rates ranged from 5 to 40 percent

before MUL's went into effect, to 14 to 95 percent after; usage typically

at least doubled and in some cases increased three times or more, depending

on the initial usage rate. Based on Table V-16 entries, the average usage,
V-49

for the 17 countries shown, was 23 percent before mandatory belt usage and

66 percent after — an increase of 43 percentage points. Admittedly this

is a rough calculation given the differences among countries in survey

methods and categories of roadway and travel conditions for which seat belt

usage data were collected. Nevetheless, this combination of data provides

an indication of what usage might be under MUL's given a large number of

unknown requirements and operating conditions for any future MUL programs.
V-50

TABLE V-15

Countries with

Asia/Africa/1id-East (6) 3.

Australia

Israel

3apan

Malaysia

New Zealand

South Africa

Europe-Western (16) 4.

Austria

Belgium

Denmark

Finland

France

Greece

Ireland

Luxemberg

The Netherlands .

Norway

Portugal

Spain

Sweden

Switzerland

United Kingdom

West Germany

ce: American Seat Belt Council,

Restraint Laws, April 1981,

Belt Usage Laws

North America (2)

Canada (Seven Provinces)

Puerto Rico

Europe-Eastern (5)

Bulgaria

Czechoslovakia

Hungary

USSR

Yugoslavia

International Seat Belt and Child

and other sources.
V-51

TABLE V-16

CHANGES IN SEAT BELT USAGE RATES

UNDIIR MANDATORY USE LAWS3?

Country

Australia

New Zealand

France

Puerto Rico

Sweden

Belgium

Netherlands

Finland

Israel3*

Effective

Date of

Law

1-72

6-72

7-73

1-74

1-75

6-75

6-75

7-75

7-75

Belt Usage

Before

(1971)

3O?o'

(1972)

40%

20-25%

(1973)

5%

(1974)

22% streets

(1974)

17%

(1974)

11% urban

24% rural

(1975)

30% highways

on weekdays

9% urban traffic

6% rural

After

(1972-76)

73-87%

(1975)

89%

(1979)

95% highways

75% country roads

50% night in cities

35% day and night in

built up areas

(1977) (usage has

14% risen to as

high as 35% in

intervening

years)

(1978)

75% streets

(1976) (Subsequent

87% slow decline

reported)

(1976)

58% urban

75% rural

(1975)

68% highways on weekdays

53% urban traffic

(1977) (law applies

70% rural to interurban travel

only)

Except as otherwise noted, the source of the information presented in the

table was "Effectiveness of Safety belt Usage Laws, "Peat, Marwick,

Mitchell & Company, May 1980, DOT-HS-805-490.

"patterns of Safety Belt Usage Following Introduction of Safety Belt

Wearing Law," Hakkart, A.; Ziedel, D.; Technion, Israel Institute of

Technology, June 1983.
V-52

Country

Norway35

Denmark

Switzerland

West Germany

Austria

South Africa

Ireland

Great Britain^6

Effective

Data of

Law

9-75

1-76

• 1-76

(repealed

10-77)

11/80

reenacted

1-76

7-76

12-77

2-79

1-83

Belt Usage

Before

(19/3)

13% urban

35% rural

25%

(1975)

19% city streets

35% highways

42% expressways

(1975)

55% autobahns

32% country roads

20% city roads

33% weighted

average

(1975)

10% urban

25% rural

(1976)

10%

(1978)

20%

40%

After

(1980)

77% urban

88% highway

(1980)

70%

(1977)

75% city streets

81% highways

88% expressways

(1978)

77% autobahns

64% country road

47% city street

58% weighted ave

(1978)

20% urban

30% rural (not

enforced

(1978)

62%

(1980)

45%

95%

Unweighted (by travel) average of rates entered on table:

Usage Before Law

23%

Usage After Law

66%

^ "Effectiveness of Safety Belts in Reducing Motor Vehicle Accident Trauma,"

Draft Report, Transportation System Center, U.S. Department of

Transportation, Dune 1984.

3 6 Department of Transport Press Notice 164 (U.K.) 5 April 1984.
V-53

The study from which most of the data included in Table V-16 were obtained

concluded that the main factors that influence the frequency with which

individuals wear their seat belts under MUL's are 1) the level of

enforcement applied by police, 2) the natural propensity of individuals to

be law abiding, and/or 3) the individuals' personal perspectives regarding

their own safety.37

A second method for estimating what seat belt usage in the United States

under MUL's might be entails reviewing the effects on usage of MUL's in the

Canadian provinces that have enacted such laws. Given their geographical

proximity to the United States, Canadians have many similar institutions,

customs, lifestyles, and attitudes as Americans, and increases in seat belt

usage resulting from MUL's in Canada might be a better basis for estimating

American usage than looking at the worldwide experience. In addition, the

Canadian government has conducted statistically sound belt use surveys in

the provinces for several years and consequently reliable data on the

effects of the MUL's are available.

Table V-17 presents driver seat belt usage data for six of the seven

provinces that have passed MUL's. Usage rates before the effective dates

of the laws in the respective provinces, as well as the 1983 rates, are

shown. An MUL in a seventh province, Manitoba, went into effect in January

1984, and survey data on the effect on seat belt usage in that province

have not been collected to date. Usage rates before MUL's went into effect

for the six provinces with laws in effect in 1983 averaged 21 percent.

"Effectiveness of Safety Belt Usage Laws," Peat, Marwick, Mitchell, and

Company, May 1980, DOT-HS-805-490.
V-54

Usage rates for the same six provinces in 1983 averaged 61 percent, an

increase of 40 percentage points under MUL's. Usage rates :.n 1983 for the

four provinces that had no mandatory use laws average 15 percent, somewhat

below the rate prevailing in the current MUL provinces before their use

laws went into effect.

Under any MUL program, enforcement activities — and to a great extent

public information and educational (PI&E) programs — are important parts

TABLE V-17

CHANGES IN DRIVER SEAT BELT USAGE IN CANADA

UNDER MANDATORY USE

Province

Ontario

Quebec

Saskatchewan

British Columbia

Newfoundland

New Brunswick

Manitoba

Effective

Date of Law

1-76

8-76

1-77

10-77

7-82

6-83

1-84

Use Before

23%39

18%39

32%39

37^9

9%

4%

12%

Use In 1983

60%

61%

54%

67%

76%

68%

12%

Averages weighted by Traffic Counts at Data Collection Sites:

Provinces with Mandatory Use Laws 61%

Provinces with No Mandatory Use Laws 15%

Unweighted Average Usage Before 21%

Laws Passed (Excl. Manitoba)

3 8 "Road Safety Leaflet," Transport Canada, December 1983.

39 "The Effectiveness of the Canadian Mandatory Seat Belt Use Laws," Jonah,

Brian A., and Lawson, John 3.; Road Safety Directorate, Transport Canada,

December 1983. The rates shown indicate usage during the year prior to the

effective date of the mandatory use laws. Usage generally increased during

the 2-year period prior to the laws' effective dates.
V-55

of the effort to increase seat belt use. Any attempt to estimate usage

under prospective MUL's in a given country based on the experience in

another country(ies) must consider respective activities in these two

areas, especially the enforcement area.

Studies on the effect of PI&E programs under MUL's were conducted by the

Canadian Federal Government as well as by provincial governments. One

study reported that PI&E programs increased the amount of public opinion

favorable to seat belt usage and increased the public knowledge regarding

the benefits of seat belt usage but had very little effect in increasing

seat belt usage.40

However, experience in other foreign countries indicates that public

information and media programs can be effective in improving belt usage

rates. Notably, Great Britain ran several seat belt usage media campaigns

in the 1970's and early 1980's. The first such program raised usage in the

affected area from 14 percent to 29 percent over a 3 week period. However,

when the advertising was withdrawn usage began to slip and was back to 22

percent after 3 months. Later campaigns were successful in raising usage

to the 29-33 percent level. Above this level additional advertising

appeared to make little or no impression. Extensive publicity was also

used preceding the implementation of Great Britain's seat belt use law in

January 1983. One thrust of publicity began at the end of September 1982,

with national newspaper advertisements incorporating a clip-and-return

coupon to obtain two informational leaflets. Posters were also printed and

Peat, Marwick, Mitchell and Company, J3p_. Cit., findings from interviews

with officials from the Provinces of Ontario and Saskatchewan.
V-56

distributed to local safety organizations along with the two informational

leaflets. The second round of publicity began in early January using

national newspaper advertisements and a national poster campaign. Upon

implementation of the law, seat belt usage increased to approximately 95

percent, from a level of 40 percent prior to enactment of the law in August

1982, and has remained at that level.

In Canada, the seat belt law is generally enforced in conjunction with

enforcement of other traffic laws and varies somewhat from province to

province. A study to measure the effect of increased enforcement

activities on belt usage was conducted in Ottawa from September 1979

through April 1980.41 j^e number of citations issued increased 975 percent

during the week of increased enforcement and dropped substantially over the

next six months. During the period of increased enforcement, mass media

publicity on the enforcement program, and educational programs explaining

the benefits of seat belt use were conducted. Seat belt use went from a

pre-demonstration rate of 58 percent to 80 percent during the period of

increased enforcement and educational activity, then to 77 percent one

month later, and down to 70 percent six months later.

Based on these studies, it appears that seat belt usage that would be

achieved under MUL's in the United States would depend on the extent of

enforcement, the severity of sanctions, and the amount and quality of mass

media publicity and educational programs. The Department is currently

undertaking numerous public informational and educational programs and

"Effects of a Selective Traffic Enforcement Program on Seat Belt Usage,"

Jonah, B.; Dawson, N.; Smith, G.; Transport Canada; in Journal of Applied

Psychology, 1982, Vol. 67, No. 1.
V-57

other promotional activities to increase voluntary seat belt usage. For

example, increases are being sought through a number of comprehensive

community-based programs currently being implemented across the country.

These programs include the basic components of the Department's national

campaign, such as face to face education through a variety of networks, the

use of mass media programs, and incentive programs. Most of these

activities to increase voluntary seat belt usage could be continued under

MUL's as well. An incentive oriented program in Chapel Hill, North

Carolina, produced an increase from a usage rate of 24 percent prior to the

program to a peak of 41 percent; the usage rate was 35 percent 5 1/2

months after the project ended. In addition, usage could be affected by

civil litigation penalties in which insurance payments associated with auto

accident injuries would be reduced if seat belts were not being worn when

the injury occurred.

Given the large number of unknowns associated with any future MUL programs

that might be adopted by the states that could affect seat belt usage,

especially the degree of enforcement and harshness of penalties for

non-compliance, it is difficult to estimate a specific belt usage rate that

would likely occur under MUL's; therefore, a range of usage is estimated.

The most reasonable basis for estimating usage would appear to be the

Canadian experience with MUL's, supported by the experience in 17 countries

as presented above, and assume the same increase in usage would apply to

the U.S. As discussed above, driver seat belt usage in the six Canadian

provinces with MUL's (in effect in 1983) increased 40 percentage points

over the pre-MUL rates. Assuming that other front seat occupants

experience a similar increase in usage, i.e., a 40 percentage point
V-58

increase over the 1983 rate of 12.5 percent for all front seat occupants,

results in an estimate of usage under MUL's of 52.5 percent. This rate

compares with an estimate of 55.5 percent derived by applying the

17-country, 43 percentage point increase under MUL's, which is felt to be

less reliable.42

The foregoing suggests a best estimate of seat belt usage under MUL's of

approximately 55 percent. It is noted, however, that the average seat belt

usage rate of 66 percent in the 17 countries with MUL's falls above the 55

percent level. It is also noted that belt usage in the Canadian provinces

with MUL's was 44 percent in 1980 and 47 percent in 1981, before increasing

substantially to 56 percent in 1982 and 61 percent in 1983.43 The foregoing

instances of seat belt usage rates somewhat above and below the 55 percent

level suggest that it would be appropriate to estimate a range of usage

rather than adopt the point estimate of 55 percent. Acknowledging a high

degree of uncertainty, the Department believes that an estimated range of

seat belt usage under MUL's of 40-70 percent is reasonable.

^2 The multiplier method of estimating seat belt usage, which was discussed

earlier in this chapter, would produce a usage estimate of 36 percent for

front seat occupants (both the Canadian and 17-country experience produce

multipliers of 2.9). However, it is felt that the incremental approach for

estimating usage is more appropriate, since the estimate derived by

employing that method produces an estimate more in agreement with the rates

experienced under MUL's in other countries. The fact that voluntary usage

in the U.S. is lower than was usage in other countries before their MUL

laws became effective does not mean that usage under MUL's in the U.S.

would be lower than in other countries. The Department believes that the

degree of enforcement of MUL's is the key determinant of usage (and to a

lesser extent public information and education) rather than the inclination

of individuals to voluntarily use seat belts.

4 3 Transport Canada, Op. Cit.
V-59

3. Air Bags

Air bags are not "used" per se; instead an air bag "readiness factor" is

substituted for usage in the calculation of benefits. There are four

subsets of the readiness factor: First, those cases in which an air bag

has been deployed in an accident and has not been repaired prior to another

accident; second, inadvertent deployments of air bags that are not

repaired; third, the actual reliability of the air bag; fourth, those

individuals who disable or dismantle the air bag for whatever reason (fear

of deployment, philosophical reasons, etc.).

An estimate of the potential number of air bag cars in the total fleet

being driven with the air bag unrepaired or otherwise inoperative can be

estimated as follows:

a. Unrepaired Accident Deployments

If all cars had air bags, O.8S0 of them would be in deployment accidents

each year (see the Insurance Section (Section VII) for the derivation of

this figure), and 36?o of these cars would be repaired, or 0.29% of the

fleet. In the long run, when all cars in the fleet have air bags, 1.2* of

total vehicle exposure would occur with unrepaired air bags, assuming none

of the air bags was repaired, calculated as follows:
V-60

Age

1

2

3

4

5

6

7

8

9

10

Total

Exposure^

.1811

.1511

.1326

.1183

.1058

.0924

.0782

.0620

.0460

.0325

1.0000

Cumulative

Probability of

Surviving'Deployment

.0029 =

.0058

.0087

.0116

.0145

.0174

.0203

.0232

.0261

.0290

Total

.0005

.0009

.0012

.0014

.0015

.0016

.0016

.0014

.0012

.0009

.0122

The Department has no data with which to estimate the proportion of

deployed bags that would be repaired. Assuming 38% of the air bags are not

repaired (See the Insurance Section for assumptions leading to the

estimate), 0.46?o (.38 x .0122) of the car fleet would be without operable

air bags.

b. Unrepaired Inadvertent Deployment

The Department knows of 16 inadvertent deployments over the lifetime of the

12,187 air bag cars. There may have been more inadvertent deployments that

were not reported. Five of these deployments were on the road and may not

happen with new cars because of safeguards built into the sensing systems

utilized in the newer air bag designs. The remaining 11 deployments

occurred mainly in vehicle servicing situations which may or may not occur

as frequently with the new systems depending on their design, particularly

44 Percent of vehicle miles travelled by age multiplied by scrappage rates.
V-61

the sensor locations. Assuming that a similar percent of inadvertent

depldyments would occur with future systems results in an estimated 0.0009

inadvertent deployments over the average car's lifetime. The agency has no

data to accurately determine what percent of inadvertently deployed air

bags would go unrepaired, although it is likely that inadvertent

deployments in a service facility would be repaired by that establishment.

If 30% of the air bags were not repaired, then an additional

.03%(.0009x.30) of all car exposure would be without air bags due to owners

not repairing the bags.

General Motors and Volkswagen stated that air bag systems should be

designed to 99.999% and 99.9985% reliability, respectively, against

inadvertent deployment. Using these design goals and assuming a 30%

non-repair rate, car exposure without air bags resulting from inadvertent

deployment would be 0.0003% or 300 cars in a 100 million car fleet.

c. Air Bag Reliability

The electronic and mechanical reliability of the air bag system is expected

to be designed to high standards. Systems should be designed to deploy

properly in crashes at least 99.99% of the time (General Motors and

Volkswagen) leaving a 0.01% failure rate at most.
V-62

d. Owner Dismantling

Some commenters indicated that they would dismantle and/or remove an air

bag from their vehicles. Without data to determine what percent of air

bags would be dismantled, the Department assumes that perhaps 1-2% of all

cars on the road would be so affected over the long run.

In summary, combining all four factors results in approximately 2% of all

car exposure being without air bags in the long run — resulting in an air

bag readiness factor of 98%.

4. Belt Usage With Air Bags

Docket commenters brought forth three theories regarding belt use with air

bags:

a) Belt use would decline because people would believe that the air bag

gives complete protection. The Department believes that education may be

able to overcome this knowledge gap, if it exists.

b) Belt use would remain the same — those who wear belts now would

continue to do so.

c) Belt use would increase — because lap belt usage in the past was near

20?o and the shoulder belt makes today's belts uncomfortable to some people,

more people would wear a lap belt.
V-63

The Department does not know whether manufacturers would supply a

lap/shoulder belt with the air bag (as Mercedes is doing) or a lap belt. It

is possible that lap belt usage would be higher than lap/shoulder belt

usage. On the other hand, people who are not in the habit of using belts

might not change their habits simply because an air bag and lap belt

replaced the lap/shoulder belt. In the absence of such data, the benefits

calculations in the FRIA are based on the assumption that current belt

usage will continue with air bags.
VI-1

VI. SAFETY BENEFITS

In this chapter the estimated effectiveness of a restraint system when used

(see Chapter IV), and the projected usage of that restraint system (see

Chapter V) are combined numerically to estimate the number of lives saved and

injuries reduced. The major results of this analysis are shown in Table VI-1.

Low

Air Bags Only

Air Bags With Lap

Belts (12.b% Usage) 4,410

Air Bag With Lap/

Shoulder Belts

(12.5% Usage)

Automatic Belts

(20% Usage to

7O?o Usage)

520

5,030

Mandatory Belt

Use Laws (in all States)

(40% Usage to

70% Usage)

2,830

5,920

TABLE VI-1

SAFETY BENEFITS

INCREMENTAL REDUCTION IN

-Fatalities —AI S 2-5 Injuries

Mid- Mid- AIS 1

Point High Low Point High Injuries

3,780 6,190 8,630 73,660 110,360 147,560 255,770

6,670 8,960 83,480 117,780 152,550 255,770

4,570 6,830 9,110 85,930 120,250 155,030 255,770

750 980 8,740 12,180

6,270 7,510 86,860 105,590

15,650 22,760

124,570 172,120

3,220 3,590 47,740 53,440 59,220 82,510

6,720 7,510 100,430 112,410 124,570 172,120

These estimates are annual benefits assuming full implementation. The low,

mid-point, and high estimates are based on the effectiveness ranges. The

mid-points are shown only for illustrative purposes. The calculated
VI-2

benefits are over and above those accruing from current levels of restraint

usage (12.5%). Belt usage with air bags in the second and third cases, on

Table VI-1 is assumed to be at current levels of restraint usage (12.5*).

Total belt usage with automatic belts is assumed to range between 20 and 70

percent. The automatic belt safety benefits shown in Table VI-1 are based

on the center seat position being exempt from the standard and the

assumption that center seat occupants will wear the manual lap belt as

often as drivers and front right seat passengers (20-7035). Incremental

safety benefits for mandatory use laws (MULs) are shown if MULs are

effective in alj States and usage is assumed to range between 40 and 70

percent.

A detailed analysis of potential impact on safety benefits of applying or

exempting the front center seat position from the automatic restraint

requirements is presented below under section F. For illustrative

purposes, the impact of different alternatives affecting this seating

position have been calculated using the mid-points of the effectiveness

ranges.

A. Passenger Car Occupant Fatalities

Based on Fatal Accident Reporting System (FARS) data, the total number of

passenger car occupant fatalities for 1982 was 23,098. Of this total, an

estimated 21,224 (92 percent) were front seat occupants. This 92 percent
VI-3

figure, comparing front seat to all occupant fatalities with known seating

position, has held constant since 1975 when FARS was initiated.

Table VI-2 shows the front seat passenger car occupant fatalities for 1975

to 1982 based on FARS data. The "unknown" seating position fatalities have

been distributed between front and rear seats according to the respective

percentages of "known" fatalities.

Table VI-3 presents the number and percentage of front seat passenger car

fatalities with known seating positions. The "other front" fatalities would

include such cases as when a child is standing on the floor or someone is

lying down across the front seat.

TABLE VI-2

FRONT SEAT PASSENGER CAR OCCUPANT FATALITIES1

1975

1976

1977

1978

1979

1980

1981

1982

1983

23,900

24,000

24,700

26,000

25,700

25,200

24,700

21,200

20,400 (Preliminary Estimate)

These are rounded to the nearest hundred fatalities; fatalities with unknown

seating position are distributed between front and rear seats according to the

distribution of known fatalities.
VI-4

TAB.E VI-3

FRONT SEAT PASSENGER CAR FATALITIES

WITH KNOWN SEATING POSITION

1975

So

1976

%

1977

%

1978

%

1979

%

1980

%

1981

5o

1982 •

%

DRIVER

16,270

72.2

16,375

72.1

16,967

72.0

18,224

72.7

18,267

73.8

17,966

73.3

17,722

73.8

15,225

73.1

FRONT

MIDDLE

644

2.9

602

2.7

577

2.5

627

2.5

513

2.1

526

2.2

460

1.9

373

1.8

FRONT

RIGHT

5,601

24.8

5,714

25.1

5,992

25.4

6,180

24.7

5,968

24.1

6,012

24.5

5,844

24.3

5,202

25.0

OTHER

FRONT

21

0.1

24

0.1

14

0.1

16

0.1

6

-

9

-

6

_

16

0.1

TOTAL

22,536

100

22,715

100

23,550

100

25,047

100

24,754

100

24,513

100

24,032

100

20,816

100
VI-5

Table VI-4 presents a projection of front seat fatalities by seating

position for the year 1990. Typically, in an analysis where full

implementation would not occur for 10 or more years, one would project

fatalities from the effective date of a rule 10 years into the future (say

1998, assuming an implementation date of 1988). However, the agency has

only projected fatalities to the year 1990 and assumes that the magnitude

of fatalities would not change significantly between 1990 and 1998.

Furthermore, the relative safety benefits of the alternatives would not be

affected by an increase in the fatality projection. Total passenger car

fatalities for 1990 are forecast to be 26,700;2 92 percent of these

(24,560) are estimated to be front seat occupant fatalities. The

distribution by seating position takes into consideration the trend of

declining front middle seating position fatalities and the possibility

that, as downsizing continues, there will be a diminishing number of 6-seat

passenger cars. Thus, the percentage of front middle seating position

fatalities is estimated to decline to 1.5 percent of all front seat

fatalities. It should be noted, however, that recent market trends

indicate a renewed interest in large cars. Driver fatalities appear to

have reached a new plateau of over 73 percent starting in 1979; thus, the

average for 1979-1982 (73.5 percent) is assumed to also be the 1990 value.

This leaves a residual of 25.0 percent for front right fatalities.

2 "Traffic Safety Trends and Forecast," NHTSA, September 1983.
VI-6

TABLE VI-4

PROJECTED FRONT SEAT PASSENGER CAR OCCUPANT FATALITIES

BY SEATING POSITION

(1990)

FRONT FRONT OTHER

DRIVER MIDDLE RIGHT FRONT TOTAL

1990 18,050 370 6,140 . - 24,560

% 73.5 1.5 25.0 - 100.0

B. Passenger Car Occupant Injuries

The annual distribution of front seat passenger car occupant injuries

(excluding fatalities) was estimated on the basis of 1982 data from the

National Accident Sampling System (NASS). Since AIS 1 injuries constitute

86 percent of all front seat injuries, this analysis will examine AIS 1

injuries and AIS 2-5 injuries separately. These 1982 distributions, as well

as the projections for 1990, are shown in Table VI-5.
VI-7

TABLE VI-5

DISTRIBUTION OF FRONT SEAT PASSENGER CAR OCCUPANT INJURIES BY AIS LEVEL

FOR 1982 AND PROJECTED FOR 1990

(EXCLUDING FATALITIES)

ACTUAL — 1982

AIS INJURY

LEVEL

0

1

2

3

4

5

% OF AIS 1

INJURIES

DRIVER

5,978,394

1,388,519

187,660

45,627

5,592

3,233

FRONT

MIDDLE

209,734

29,914

6,467

289

0

0

FRONT

RIGHT

1,882,971

515,786

47,417

16,100

2,411

728

OTHER

FRONT

4,934

2,526

1,604

0

0

0

71.7 1.5 26.6 0.2

TOTAL

8,076,033

1,936,745

243,148

62,016

8,003

3,961

100

AIS 2-5

INJURIES 242,112 6,756 66,656 1,604

76.3 2.1 21.0 0.6

317,128

100

PROJECTIONS FOR 1990

AIS 1

INJURIES

AIS 2-5

INJURIES

2,110

290

,000

71

,000

78

.5

.5

40,

5,

000

1.

000

1.

5

5

800

75

,000

27

,000

20

.0

.0

2,950,0.00

100

370,000

100

There were almost 2 million AIS 1 injuries and over 315,000 AIS 2-5 injuries

in 1982. Table VI-5 shows their distribution by seating position. Based on

the agency's belief that the number of occupants and injuries in the front

center seating position will decline, the agency assumes that in 1990 the same

percentage of injuries as fatalities will occur in the front center position

(1.5%).
VI-8

For 1990, the percentage of injuries by seating position is determined by

comparing 1982 data with the 1981 data and rounding to the nearest 0.5

percent. (In 1981 for AIS 1 injuries — 69.7 percent were drivers, 3.0

percent front middle, 27.1 percent front right and 0.2 percent others; for AIS

2-5 injuries — 78.8 percent were drivers, 2.1 percent front middle, 18.9

percent front right and 0.2 percent others.)

Total AIS 2-5 injuries for 1990 are determined by comparing projected 1990

fatalities to 1982 fatalities and applying this factor to 1982 injuries (i.e.,

24,560 = 1.16 x 317,128 = 370,000 AIS 2-5 injuries).

21,200

Total AIS 1 injuries for 1990 are determined in the same manner except that

the total is increased by a correction factor to take unreported accidents

into consideration.

There is some debate as to the magnitude of the correction factor which should

be used with NASS data. The Insurance Institute for Highway Safety (IIHS)

commented that the number of motor vehicle injuries are underreported by NASS.

IIHS submitted a study comparing Northeastern Ohio Hospital Emergency Department entries versus police reports of accidents. The findings of this report

note that to overcome biases introduced by the underreporting of injuries to

the police, the non-fatal injury numbers should be multiplied by 1.4.3

Docket No. 74-14-N32-1668, "Northeast Ohio Trauma Study," Barancik, etal.,

American Journal of Public Health, July 1983, Vol. 73, No. 7.
VI-9

NHTSA recognized the underreporting problem in NASS and sponsored a study by

Westat Inc. to estimate the magnitude of the problem.4 The Westat study is

not a definitive treatise on the subject; it has problems relating to respondents not wishing to tell about unreported accidents over the telephone,

etc. However, it is more nationally representative than a study done in one

state, especially since reporting practices vary considerably from state to

state.

The results of the Westat study are:

— 0.27 unreported injury accidents per NASS injury accident;

— 0.14 unreported accidents requiring hospital treatment for each

NASS accident requiring hospital treatment; and

— no unreported accidents requiring a hospital stay.

The findings of the Westat study and the Ohio study are significanty different; the Westat study proposes a multiplier for hospital treated injuries

of 1.14, whereas the Ohio study indicates a value of 1.4. The agency believes

it is more appropriate to apply the results of the Westat study to the NASS

accident data because the Westat study was specifically designed to address

the issue of underreporting on a national basis.

"National Accident Sampling System, Nonreported Accident Survey," Westat Inc.,

Contract DOT-HS-9-02128, November 1981.
VI-10

One limitation of using the Westat study for this analysis is that injury

severity by AIS level for unreported accidents is unknown. Since there

were no unreported accidents requiring a hospital stay, none of the

injuries would be AIS 4 or 5. Since AIS 1 injuries are 86 percent of all

injuries and since we are dealing with unreported accidents, almost all of

these injuries would probably be AIS 1 injuries. For this analysis the

agency assumes that all of these injuries are AIS 1 injuries.

The adjustments to the AIS 1 injuries for unreported accidents are included in

the 1990 projections and are calculated as follows:

1.16 x 1,936,745 1982 AIS 1 injuries = 2,247,000 1990 reported injuries

1.16x0.27x2,253,873 1982 AIS 1-5 injuries = 706,000 1990 unreported injuries

2,950,000 AIS 1 injuries

C. Range of Impacts on Fatalities and Injuries

The following formula is used to determine the number of fatalities that

would occur in 1990 if no one uses restraints. A similar formula is used

for AIS 1 and AIS 2-5 injuries:
VI-11

FNR = lc

1-(UC)(EF)

Where: Fjyjp = Fatalities in 1990 if no one uses restraints

Fc = Fatalities in 1990 with current restraint usage

Uc = Current Restraint Usage

Ep = Fatality effectiveness

When applying this formula for different effectiveness estimates (low,

mid-points, and high estimates of effectiveness), FQ and UQ remain constant

while effectiveness changes. Thus, Fj^p varies depending on the

effectiveness estimate used in the formula. For illustrative purposes, the

effectiveness estimates for the three-point manual belts for the driver and

right front, and lap belts for the front middle seating position use the

mid-paints of the ranges.

1990 Fatalities (Fc)

1990 AIS 1 Injuries

1990 AIS 2-5 Injuries

Manual Belt Usage (Uc)

Fatality Effectiveness(Ep)

AIS 1 Injury Effectiveness

AIS 2-5 Injuries

Effectiveness

Driver

18,050

2,110,000

290,000

.140

.45

.10

.50

Front Middle

370

40,000

5,000

.050

.35

.10

.30

Front Right

6,140

800,000

75,000

.0B4

.45

.10

.50
VI-12

This gives the following results:

Fatalities assuming no 19,260 377 6,380

one used restraints

AIS 1 injuries assuming 2,140,000 40,200 807,000

no one used restraints

AIS 2-5 injuries assuming 311,830 5,080 78,290

no one used restraints

The values in Tables VI-6 through VI-9 are the incremental reductions of

fatalities or injuries when compared to current belt usage levels. These

are derived from the following formula shown for fatalities. A similar

formula is used for AIS 1 and AIS 2-5 injuries.

Incremental Fatalities Reduction = Total Fatality Reduction - Fatality

Reduction at Current Usage Levels

F I = (FNR)(UP)(EF) - (FNR - Fc)

Where: Fj r Incremental fatality reduction

FJSJR = Fatalities assuming no one used restraints

Up = Projected usage level

Ep = Fatality Effectiveness

Fc = Fatalities in 1990 with current restraint usage

As mentioned previously, F^R varies with the effectiveness estimates

(low, mid-point, and high effectiveness). Thus, when calculating benefits

for automatic restraints, it is implicit (in the formula) that the low

effectiveness estimate for manual belts is used to calculate a "low"

estimate of current manual belt fatality reduction, which is subtracted
VI-13

f'om the "low" fatality reductions for air bags derived from the low

effectiveness estimate for air bags. In calculating safety benefits

throughout this analysis, low effectiveness for manual belts is compared to

low effectiveness estimates for air bags, mid-point effectiveness to

mid-point estimates and high effectiveness is compared to high estimates.

Separate estimates are provided for mandatory belt use laws, automatic belts,

and airbag systems. These values represent annual fatality or injury

reductions at full implementation (that is, when all cars are equipped with a

particular restraint device or when mandatory belt use laws are effective

in all States).

Table VI-6 presents incremental safety benefits for all front seating

positions^ for three different effectiveness estimates — low end of the

range, the mid-point for illustrative purposes, and the high end of the

range. Tables VI-7, VI-8, and VI-9 present incremental safety benefits by

seating position assuming the mid-points of the effectiveness ranges, for

illustrative purposes. Some of these values in Tables VI-7, VI-8, and VI-9

are used in the following center seat position discussion.

That is, full front seat air bags; for automatic belts it is assumed that

the center seat is exempt from the standard and manual lap belt usage in

the center seat equals belt usage of the driver and front right seat

passenger.
VI-14

TABLE VI-6

SAFETY BENEFITS

INCREMENTAL REDUCTION IN

Fatalities

MidLow Point High

—AI S 2-5 Injuries

Mid- AIS 1

Low Point High Injuries

Air Bags Only 3,780 6,190 8,630 73,660 110,360 147,560 255,770

Air Bags With Lap

Belts (12.5% Usage) 4,410 6,670 8,960 83,480 117,780 152,550 255,770

Air Bag With Lap/

Shoulder Belts

(12.5% Usage) 4,570 6,830 9,110 85,930 120,250 155,030 255,770

Automatic Belts

20% Usage

30%

40%

50%

60%

70%

Mandatory Belt

Use Laws (in all

40% Usage

50%

60%

70%

520

1,420

2,320

3,230

4,130

5,030

States)

2,830

3,860

4,890

5,920

750

1,850

2,950

4,060

5,160

6,270

3,220

4,380

5,540

6,720

980

2,280

3,590

4,900

6,200

7,510

8,740

24,370

37,990

55,610

71,240

86,860

3,590 47,740

4,900 65,300

6,200 82,860

7,510 100,430

12,180

30,860

49,540

68,230

86,900

105,590

53,440

73,100

92,760

112,410

15,650 22,760

37,440 52,640

59,220 82,510

81,000 112,380

102,790 142,250

124,570 172,120

59,220 82,510

81,000 112,380

102,790 142,250

124,570 172,120
VI-15

Table VI-7

ANNUAL FATALITY REDUCTION

MANDATORY BELT USE LAWS IN ALL STATES

(ASSUMING MID-POINTS OF EFFECTIVENESS RANGES —

MANUAL BELT EFFECTIVENESS IS 45 PERCENT FOR DRIVER

AND FRONT RIGHT PASSENGER AND 35 PERCENT FOR FRONT MIDDLE LAP BELT)

Incremental Savings Over Current Usage Levels of Manual Belts^

Usage Driver Front Middle Front Right Total

40% 2,260 50 910 3,220

50% 3,120 60 1,200 4,380

60% 3,990 70 1,480 5,540

70% 4,860 90 1,770 6,720

TABLE VI-7 Cont'd

AUTOMATIC BELTS, (ASSUMING MID-POINTS OF EFFECTIVENESS RANGES —

EFFECTIVENESS IS 42.5 PERCENT FOR DRIVER AND

FRONT RIGHT PASSENGER AND 35 PERCENT FOR FRONT MIDDLE LAP BELT)

Incremental Savings Over Current Usage Levels of Manual Belts

Usage Driver Front Middle Front Right Total

20% 430 20 300 750

30% 1,250 30 570 1,850

40% 2,060 50 840 2,950

50% 2,880 60 1,120 4,060

60% 3,700 70 1,390 5,160

70% 4,520 90 1,660 6,270

Assumes usage levels of manual belts in 1990 are the same as current usage

rates - 14.0 percent driver, 5.0 percent front middle and 8.4 percent front

right. Fatalities reduced by current usage levels in 1990 are 1,210 drivers,

7 front middle, and 240 front right.
VI-16

TABLE ''1-7 Cont'd

AIR BAGS (ASSUMING MID-POINTS OF EFFECTIVENESS RANGES —

30 PERCENT EFFECTIVE WITHOUT LAP BELT,

45 PERCENT EFFECTIVE WITH LAP BELT AT

CURRENT USAGE LEVELS, AND AIR BAGS WITH LAP/SHOULDER BELTS ARE 50 PERCENT

EFFECTIVE WITH CURRENT USAGE LEVELS; READINESS FACTOR IS 98 PERCENT)

Incremental Savings Over Current Usage Levels of Manual Belts

Restraint System

Air Bag With

Belt Usage

Air Bag With

Belt (12.58

Air Bag With

No

Lap

Usage)

Lap/

Driver

4,450

4,850

4,980

Front Middle

100

110

110

Front Right

1

1

1

,640

,710

,740

6,670

6,830

Shoulder Belt

(12.5% Usage)

TABLE VI-8

ANNUAL NUMBER OF AIS 1 INJURIES REDUCED AT FULL IMPLEMENTATION ASSUMING

A MANUAL OR AUTOMATIC RESTRAINT SYSTEM WITH 10 PERCENT EFFECTIVENESS

Incremental Savings Over Current Usage Levels of Manual Belts^

20%

30%

40%

50%

60%

70%

12,800

34,200

55,600

77,000

98,400

119,800

Front Middle

600

1,010

1,410

1,810

2,210

2,610

Front Right

9,360

17,430

25,500

33,570

41,640

49,710

22,760,

52,640

82,510

112,380

142,250

172,120

Assumes usage levels of manual belts in 1990 are the same as current usage

rates - 14 percent drivers, 5 percent front middle and 8.4 percent front

right, AIS 1 injuries reduced by current usage levels in 1990 are 30,000

drivers, 200 front middle and 6,780 front right.
VI-17

TABLE VI-8 Cont'd

ANNUAL NUMBER OF AIS 1 INJURIES REDUCED ASSUMING 10 PERCENT

EFFECTIVENESS FOR AIR BAG, AIR BAG WITH LAP BELT, OR AIR BAG WITH

LAP SHOULDER BELT; READINESS FACTOR IS 98 PERCENT

Incremental Savings over Current Usage Level of Manual Belts

Restraint System

Air Bag With No

Belt Usage

Air Bag With Lap

Belt (12.5% Usage)

Air Bag With Lap/

Shoulder Belt

(12.555 Usage)

Driver

179,720

179,720

179,720

Front Middle

3,740

3,740

3,740

TABLE VI-9

Front

72

72

72

Right

,310

,310

,310

Total

255,770

255,770

255,770

ANNUAL NUMBER OF AIS 2-5 INJURIES REDUCED WITH MANDATORY BELT USE LAWS

IN ALL STATES, ASSUMING MID-POINTS OF EFFECTIVENESS RANGES —

MANUAL BELT EFFECTIVENESS IS 50 PERCENT FOR DRIVER AND FRONT

RIGHT PASSENGER AND 30 PERCENT FOR FRONT MIDDLE LAP BELT

Incremental Savings Over Current Usage Levels of Manual Belts^

Usage Driver Front Middle Front Right Total

40%

50%

60%

70%

40,540

56,130

71,720

87,310

530

690

840

990

12,370

16,280

20,200

24,110

53,440

73,100

92,760

112,410

Assumes usage levels of manual belts in 1990 are the same as current usage -

14 percent driver, 5 percent front middle and 8.4 percent front right. AIS

2-5 injuries reduced by current usage levels in 1990 are 21,828 drivers, 76

front middle and 3,288 front right.
VI-18

TABLE VI-9 Cont'd

ANNUAL NUMBER OF AIS 2-5 INJURIES REDUCED ASSUMING

MID-POINTS OF EFFECTIVENESS RANGES —

AUTOMATIC BELT EFFECTIVENESS IS 52.5 PERCENT FOR DRIVER AND FRONT RIGHT

PASSENGER AND 35 PERCENT FOR FRONT MIDDLE LAP BELT

Incremental Savings Over Current Usage Levels of Manual Belts

Usage Driver Front Middle Front Right Total

202; 7,800 230 4,150 12,180

30% 22,610 380 7,870 30,860

40% 37,420 530 11,590 49,540

50% 52,230 690 15,310 68,230

60% 67,040 840 19,020 86,900

70% 81,860 990 22,740 105,590

TABLE VI-9 Cont'd

ANNUAL NUMBER OF AIS 2-5 INJURIES REDUCED ASSUMING MID-POINTS OF

EFFECTIVENESS RANGES -- AIR BAGS ARE 35 PERCENT

EFFECTIVE, AIR BAGS WITH LAP BELTS ARE 55 PERCENT EFFECTIVE WITH CURRENT

USAGE LEVELS AND AIR BAGS WITH LAP/SHOULDER BELTS ARE 60 PERCENT, EFFECTIVE

WITH CURRENT USAGE LEVELS; RESTRAINT READINESS FACTOR IS 98 PERCENT

Incremental Savings Over Current Usage Rates of Manual Belts

Restraint System

Air Bag With

Belt Usage

Air Bag With

Belt (12.5%

Air Bag With

No

Lap

Usage)

Lap/

Driver

85,130

91,550

93,690

Front

1,

1,

1,

Middle

670

700

700

Front

23

24

24

Right

,560

,530

,860

Total

110,360

117,780

120,250

Shoulder Belt

(12.5% Usage)

The Insurance Institute for Highway Safety (IIHS) (74-14-N35-022) argues

that this formula does not take into account that belt users are less

frequently involved in serious accidents. IIHS contends that even with

70-80 percent automatic or manual belt use, non-users will be so

overinvolved that actual reductions may fail to match use rate increases.

According to this theory, risk-prone drivers will never wear belts and

those drivers are overinvolved in accidents. Thus, IIHS would argue that

while the Department's effectiveness estimates have taken into account the
VI-19

seriousness of the accident, they have not been corrected to reflect this

over involvement; in the IIHS view, this results in overstating safety

benefits. However, no data are available to either validate this theory or

to attempt to quantify its possible effects. That is, it is not possible

to estimate the number of risk-prone drivers who do not use their belts and

the percentage of accidents in which such drivers are involved.

On the other hand, in his comments to the SNPRM (Docket No. 74-14-N35-079)

Professor Nordhaus states that the Department's manual and automatic belt

effectiveness estimates are too low; he argues that those drivers that are

more likely to buckle-up, perhaps 45 percent of all drivers, are not

risk-prone drivers and will thus be involved in less serious accidents.

Therefore, the analysis understates safety benefits in Professor

Nordhaus'opinion. As noted above, the Department has not made changes in

its analysis to account for this possibility in the absence of specific

data.

Professor Nordhaus also argues that the 19.3 percent reduction in fatality

rates for VW automatic restraint Rabbits should be used to determine

fatality reductions for automatic belts and that any combination of usage

rates and effectiveness should result in a 19.3 percent reduction in

fatalities. He contends that it is illogical to take effectiveness

estimates from one data set and combine it with usage estimates from

another. This argument ignores the reasons why the Department did not use

VW Rabbit automatic belt usage data (see Chapter V) and the fact that the

Department is analyzing fatality reductions for all cars, not just VW

Rabbits with an interlock. He also demonstrates a lack of understanding of
VI-20

NHTSA's analysis of the Rabbit accident data. As Professor Nordhaus

stated, the automatic belt Rabbit fatality rate is 19.3 percent lower than

that for manual belt Rabbits. This rate results from some increase in

usage as well as the effectiveness of the belts. Knowing the fatality

rate, and usage in accidents we can solve for effectiveness and arrive at a

54 percent figure (see p. IV-25). However, the usage figure to derive this

effectiveness number is much lower than that actually observed and since

observed usage is deemed a more reliable figure than that estimated for

accidents the agency solved again for effectiveness using the observed

usage and arrived at a 39 percent value. Nordhaus argues that this

methodology is invalid. The agency disagrees because Nordhaus fails to

recognize the uncertainty inherent in the accident usage data. The

agency's calculations take into account this uncertainty and the effect it

has on belt effectiveness.

D. Breakeven Point Analysis of Safety Benefits

This section examines the safety benefit breakeven points among systems.

That is, at what automatic or manual belt usage level would the belt system

provide the same safety benefits as air bags. Because of the ranges in air

bag, automatic belt, and manual belt effectiveness, the breakeven point

analysis is complicated.
VI-21 .

Table VI-10 shows the breakeven points under a number of effectiveness

assumptions. The breakeven points range from 44 percent to over 100

percent; these are the extremes of the effectiveness ranges. Thus,

mandatory belt use laws or automatic belts would have to increase belt

usage to at least 44 percent to achieve the same benefits as an air bag and

lap belt, at the present rate of belt usage (12.5%). Figure VI-1 shows the

relationship between automatic belts and air bags with lap belts. If the

lap belt with the air bag system was not used by any occupants, the

breakeven points would range from 39 percent to 100 percent.

TABLE VI-10

BREAKEVEN POINT ANALYSIS SAFETY BENEFITS

Effect

Air Bag10

Low (20%)

Mid-Point (30%)11

High (40%)

Low (20%)

High (40%)

Air Bag

Low (20%)

Mid-Point (30%)

High (40%)

Low (20%)

High (40%)

Fatalities

lveness

Automatic Belt

Low (35%)

Mid-Point (42.5%)

High (50%)

High (50%)

Low (35%)

Manual Belt

Low (40%)

Mid-Point (45%)

High (50%)

High (50%)

Low (40%)

Breakeven Point^

63%

74%

81%

44%

Over 100%

55%

70%

81%

44%

Over 100%

The breakeven point is the point at which usage of safety belt systems

provide equal life saving benefits to air bag systems.

1° Air bags with lap belts at 12.5% usage of lap belts.

11 Mid-points are shown for illustrative purposes.

VI-23

For AIS 2-5 injuries, the breakeven points between air bags with lap belts

at current usage rates and manual or automatic belt usage are nearly the

same, ranging from 49 percent to over 100 percent.

It must be noted that, in the above discussion, the "breakeven" points are

simply the points at which estimated safety benefits are equal. They do

not take into account the cost factor, thus they do not represent a measure

of cost-effectiveness.

E. Time Phase Analysis of Fatality Benefits

One of the advantages of a mandatory belt use law is that it impacts all

cars in the fleet rather than only new cars affected by an automatic

restraint standard. Thus, it is interesting to examine the benefits of

various alternatives over time.

The benefits of an automatic restraint standard over time can be estimated

by examining fatalities by vehicle age. Table VI—11 shows the 1982

distribution of passenger car occupant fatalities by model year (FARS

data). The model year 1982 and 1983 cars are combined to show the effect

of the first full year implementation of an automatic restraint standard.

The percent of fatalities for any particular year is highly dependent upon

sales in that model year (notice lower percentages than expected in 1981

and 1975 recession years and higher percentages than expected in the high

sales years of 1979 and 1973). Table VI-11 presents 3-year and 5-year

moving averages in an attempt to smooth out the data, given the assumption
VI-24

of constant sales per year; however, these smoothing techniques will not

work for the initial years or the final years. Finally, a smooth curve is

chosen for analytical purposes.

Table VI-11 shows that 10 years after automatic restraints are installed,

74 percent of the fatalities would have been in automatic restraint

equipped cars, without taking into account the effectiveness of automatic

restraints. This estimate assumes that the recent trend to hold on to cars

longer will continue. If this trend does not continue, this 74 percent

estimate would increase.

TABLE VI-11

PASSENGER CAR OCCUPANT FATALITIES BY AGE

(BASED ON 1982 FARS)

Model

Year

1982+8312

1981

1980

1979

1978

1977

1976

1975

1974

1973

1972

1971

1970

1969

1968

Pre 1968

Age

<1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

>15

% of

Fatals

5.9

8.5

9.0

9.3

8.4

7.0

.6.9

5.1

7.0

7.0

6.0

4.4

3.8

2.7

2.3

6.7

ibo.Os

3-Year

Moving

Average

N.C.

8.9

8.9

8.2

7.5

6.3

6.3

6.3

6.7

5.8

4.7

3.6

2.9

2.3

5-Year

Moving

Average

_

N.C.

8.4

8.1

7.3

6.9

6.6

6.4

5.9

5.6

4.8

3.8

2.9

2.1

Projected

Average

Assuming

Constant

Sales Per

Year (%)

6.0

9.0

8.9

8.8

8.3

7.4

6.9

6.6

6.4

6.0

5.7

4.8

3.7

2.8

2.2

6.5

10o.0fe

Cumulative

%

6.0

15.0

23.9

32.7

41.0

48.4

55.3

61.9

68.3

74.3

80.0

84.8

88.5

91.3

93.5

100.0

N.C. = Not calculated in order to not include the <1 year average for

1982+83.

12 1982 models had 5.7 percent of fatalities and the 1983 models had only

0.2 percent of fatalities.
VI-25

Table VI-12 presents a year-by-year (time phase) analysis of the fatality

benefits of an automatic restraint standard, air bags, or automatic belts, and

a mandatory belt use law. Mid-points of the effectiveness ranges are used

in this time phase analysis for illustrative purposes.

The time phased benefits of state implemented mandatory belt use laws as an

alternative to an automatic restraint requirement depend upon the specific

time frame established for state passage and implementation of a belt use

law.

When the benefits of the two alternatives are compared, i.e., mandatory use

laws versus automatic restraint standards, three timing questions should be

considered: 1) the number of states that implement mandatory belt use laws

before an automatic restraint requirement would become effective; 2) the

percent of all occupants covered by a mandatory restraint use law, by year;

and 3) the level of compliance that would result.

Table VI-12 presents three hypothetical scenarios with different

implementation schedules. All these scenarios assume a starting point

equivalent to the effective date of an automatic occupant protection

standard. Scenario 1 assumes all states will pass a mandatory belt use law
VI-26

very quickly and have it implemented by the effective date of the

standard. Scenario 2 assumes 67 percent of the population will be covered

under mandatory use laws before the effective date of the standard and

automatic restraints would not be required. No reduction in fatalities is

assumed for 33 percent of the population. Scenario 3 assumes 20 percent of

the population will be covered by mandatory use laws by the effective date

of an automatic restraint standard and the remaining 80 percent of the

population will be in states where automatic restraints (automatic belts

are assumed for this analysis) are required.

A comparison of the data for the hypothetical mandatory belt use law

scenarios in Table VI—12 shows that if all states quickly pass a mandatory

belt use law and usage increased to 70 percent or more, short term benefits

(over the next 10 years) would be about 2.5 times higher than benefits with

air bags or automatic belts with 70 percent usage. It also shows that the

only condition under which automatic belts would provide equal or more

benefits than mandatory use laws would be if usage of automatic belts was

near the high end of the usage range and manual belt usage under mandatory

use laws was at the low end of the range.
VI-27

TABLE VI-12

TIME PHASE ANALYSIS OF FATALITY BENEFITS

Air Bag With Automatic Belt: Mandatory RP U Use L.qw! 4n-7Q%

Year

1

2

3

4

5

6

7

8

9

10

TOTAL

(1-10)

11

12

13

14

15

TOTAL

(1-15)

12.

of

1

1

2

2

3

3

4

4

_4

28

5

5

5

6

6

57

5% Usage

Lap I

400

,000

,590

,180

,730

,230

,690

,130

,560

,960

,470

,340

,660

,900

,090

,240

,700

3elt 20-70%

50-380

110-940

180-1,500

250-2,050

310-2,570

360-3,030

410-3,470

460-3,880

510-4,280

560-4,660

3,200-26,760

600-5,010

640-5,320

660-5,550

680-5,720

700-5,860

6,480-54,220

Usage

3

3

3

3

3

3

3

3

3

3

32,

3

3

3

3

3

Scenario

,220-6,720

,220-6,720

,220-6,720

,220-6,720

,220-6,720

,220-6,720

,220-6,720

,220-6,720

,220-6,720

,220-6,720

220-67,200

,220-6,720

,220-6,720

,220-6,720

,220-6,720

,220-6,720

48,300-100,800

1 Scenario 2

2,160-4,500

2,160-4,500

2,160-4,500

2,160-4,500

2,160-4,500

2,160-4,500

2,160-4,500

2,160-4,500

2,160-4,500

2,160-4,500

21,600-45,000

2,160-4,500

2,160-4,500

2,160-4,500

2,160-4,500

2,160-4,500

32,400-67,500

1

1

1

8,

1

1

1

1

1

14,

Scenario 3

680-1,650

730-2,100

790-2,540

840-2,980

890-3,400

930-3,770

970-4,120

,010-4,450

,250-4,770

,090-5,070

980-34,850

,120-5,350

,160-5,600

,170-5,780

,190-5,920

,200-6,030

820-63,530

Definition of Hypothetical Scenarios:

Scenario 1 -- All states pass mandatory use law for all front seat

passenger car occupants by the effective date of an automatic restraint

standard.

Scenario 2 -- 67% of all front seat occupants are covered by a mandatory

use law. The remaining 33* are assumed to have no reduction in fatalities.

Scenario 3 — 20% of all front seat occupants are covered by a mandatory

use law. New cars in the remaining 80% of the states are equipped with

automatic belts with 20-70% belt usage.
VI-28

Some commenters stated that they ffvored a combination of

alternatives—automatic restraints and mandatory belt use laws. This

consideration could maximize the short run and long run benefits, unless

usage of automatic and manual belts was very low—in which case airbags

would still provide more benefits. Not only can this combination provide

benefits to the current fleet of cars but the mandatory belt use law might

also increase the benefits of the automatic restraint equipped cars by

increasing usage of automatic belts or manual belts with the air bag.

Table VI-13 presents examples of fatality benefits assuming airbags or

automatic belts are required and mandatory seat belt use laws are

implemented. The time phasing of these scenarios is taken from the child

restraint experience and is shown in Table VI-13. Increasing belt usage

with airbags by mandatory seat belt usage laws can greatly increase total

benefits (from 28,476 lives saved to possibly 49,480 over the first 10

years). Also, this combination of alternatives can have a large advantage

over mandatory belt use laws alone, in the long run.

The advantage of combining mandatory belt use laws and an automatic

restraint (in this case automatic belt) requirement compared to an

automatic belt requirement alone are a large increase in benefits over the
VI-29

10-year phase in period (3,200-26,760 lives sa'ed for automatic belts alone

compared to 16,760-41,020 when automatic belts are combined with MULs).

However, the benefits of the combined mandatory belt use law and automatic

belt requirement, compared to a mandatory belt use law alone, depend on how

well the mandatory belt use laws work. If mandatory belt use laws result

TABLE VI-13

TIME PHASE ANALYSIS OF FATALITY BENEFITS

Automatic Belt and

Mandatory Belt Use Law

40-70% Usage14

ear

••mUMMM

1

2

3

4

5

6

7

8

9

10

Assumed

Percent of

States With

MUL

2

2

6

8

30

94

94

94

94

94

Air Bag With 12.5% Usage

of Lap Belt

and Mandatory Belt

Use Law 40-70% Usage

460-580

1,060-1,120

1,750-1,930

2,380-2,600

3,430-4,190

5,270-7,490

5,590-7,660

5,890-7,820

6,190-7,970

6,470-8,120

110-560

170-1,050

360-1,810

490-2,410

1,150-3,760

2,930-6,290

2,910-6,290

2,900-6,290

2,880-6,280

2,870-6,280

TOTALS 38,480-49,480 16,760-41,020

Benefits peak in year 6 since the percent of states covered by a mandatory

belt use law does not increase after this point and after year 6 there are

more automatic belt cars on the road than manual belts. Using the midpoints

of the effectiveness range, automatic belts are 2.5 percentage points less

effective than manual belts.
VI-30

in the same usage as automatic restraints and can be passed in every state

then, since manual belts may be more effective than automatic belts, there

would be additional benefits by not requiring automatic belts. However, if

a combination of the two alternatives, automatic belts and mandatory belt

use laws, result in automatic belts having higher usage rates than manual

belts, then there would be an advantage to the combination of the two

alternatives.

F. Center Seating Position

1. Considerations Related to Center Seating Position

This section analyzes the effect that deleting the requirement of automatic

occupant protection for front center seating positions would have on

fatalities and injuries. Mid-points of the effectiveness ranges are used

in this center seating position analysis for illustrative purposes.

The Department proposed alternatives eliminating the automatic restraint

requirements for the middle front seating position for two reasons:

a) The Department is concerned that the alternative requirements of FMVS5

208 may inadvertently result in the demise of six-seat passenger cars.

Although most of the alternatives call for a performance standard and do

not specify the method of compliance, manufacturers, because of cost

considerations, may opt to provide automatic seat belts in lieu of air

bags. There is no known practical method that can provide automatic seat

belt protection for front center seat occupants. Vehicle manufacturers
VI-31

that supply automatic belts to meet the requirement would probably ure a

console or other means to eliminate the middle seating position. The net

result is that six-seat cars as we know them today may no longer be

produced. Of course, full front air bags could provide automatic

protection for all three front seating positions and allow retention of

six-seat passenger cars.

Roger Maugh of Ford stated15 "The requirement for automatic protection for

the front center seating position essentially eliminates the

three-passenger front seat type of passenger cars. There is no known

practical three-passenger front seat automatic seat belt concept. Then

such a requirement also makes it unlikely that six-passenger car types

should be continued even with air bags because of the unsolved problem of

the hazards air bags pose to out-of-position passengers. We were doing our

testing with that air bag designed to basically accept the energy and

decelerate two 90 percent mannikins...and, of course, what that means is

that you end up putting an air bag in there that has a tremendous amount of

energy. It is that tremendous amount of energy that...gives you the

problem of the out-of-position occupant." However, as indicated in Chapter

III, the agency does not believe that the out-of-position occupant is a

large problem.

Even if automatic protection is not required in the center seat position,

the center seat position may be eliminated if a manufacturer chooses to use

non-detachable automatic belts because of the difficulty presented by the

Testimony of Roger Maugh, Ford, at the Kansas City Hearing, December 2,

1983, pg. 283 and 296.
VI-32

belts in getting in and out of the center seat. If manufacturers are

allowed to use detachable automatic belts, then the center seat position

can be utilized by detaching an outboard seating position belt.

b) The second reason is related to the small and declining number of

fatalities and injuries associated with this seating position. As shown in

Table VI-3, there were 644 fatalities in 1975 in the front middle seating

position, 373 in 1982, and an estimated 340 in 1983; these comprise less

than 2 percent of all front seat passenger car fatalities. With the

continued down-sizing in cars, there would be, in the absence of the

standard, fewer and fewer (although not zero)""> six-seat cars on the

highway, resulting in fewer front middle seating position fatalities. As

shown in Table VI-4, front middle seat fatalities are expected to account

for only 1.5 percent of all front seat fatalities in the future (roughly

370 fatalities in 1990). Also, data from the Nationwide Personal

Transportation Study"!? indicate that from 1969 to 1977, the percent of

vehicles with six or more occupants on trips of all purposes has declined

from 2.7 percent to 1.9 percent. Thus, automatic restraints for the front

center seating position would not yield as many benefits as originally

thought when the standard was issued in 1977.

One of the commenters indicated that the center seat position should not be

exempt from the standard since young children were frequently injured in

this seating position. In the October 1981 FRIA, the agency examined this

16 in 1982, one-third of the cars sold were six-seat cars.

•' "Nationwide Personal Transportation Study — Automobile Occupancy," Report

No. 1, April 1972, U.S. DOT, Federal Highway Administration, p. 12, and

data from the 1977 Nationwide Personal Transportation Study.
VI-33

issue. The 1980 FARS data indicate fatalities in the age group 0-5, young

children, represented 23.4 percent for front center positions, but only 3.3

percent for front right positions. The 1981 and 1982 FARS data indicate

roughly the same percentages, with 0-5 year old children representing 23.3%

and 24.7% of all front center seat occupant fatalities. Preliminary 1983

FARS data show 18.8% of all front center seat occupant fatalities were 0-5

year old children. However, the total front center seat fatalities also

dropped in 1983. The decrease in child fatalities in this seating position

is believed to be the result of three factors relating to child restraint

usage: 1) child restraint usage increased in 1982 and 1983 due to child

restraint laws, 2) the effectiveness of child restraints, and 3) more

children are being put into the rear seats (58% in 1983 FARS data versus

52?o in 1982), perhaps as a result of child restraint laws. The Department

would expect the proportion of center seat child fatalities to decrease

as child restraint usage increases.

There are also convenience and "peer pressure" arguments associated with

eliminating the front center seating position from the standard. If the

center seating position is not required to be provided with automatic

restraints, the manufacturers may be able to design detachable automatic

belts for a bench seat; thus allowing the center seat to be utilized

without air bags. (The center seat would still be required to be equipped

with the current manual lap belt.) However, the automatic belt might have

to be disconnected in order to allow a passenger to get into the middle

seating position. The question then arises as to what percent of the
VI-34

automatic belts would be reconnected. If some people don't reconnect them,

then usage declines and some of the benefits of requiring automatic

protection — or at least for the right front passenger — could be lost.

On the other hand, the MOR study^ stated that interaction between driver and

passengers was a significant factor affecting belt usage. Since normally one

would enter the front center position from the passenger side, the driver's

automatic belt would not need to be disconnected and the driver may encourage

the reconnect ion of the right front belt and/or the use of the center seat lap

belt. Thus, center seat lap belt usage could conceivably increase compared to

expected usage in cars with only manual belts.

In addition to Ford's comments noted earlier, AMC, the American Automobile

Association and Consumers Union, indicated that they favored exempting the

center front seating position from the automatic occupant protection

requirement. Chrysler recommended the center front seat be exempted to

improve the test procedure as applied to airbag systems.

2. Benefit Calculations

As shown in Tables VI-4 and VI-5, it is estimated that 1.5 percent of front

seat fatalities and injuries would occur in the front center seating

position (370 fatalities and 5,000 AIS 2-5 injuries). These estimates

assume a ceteris paribus situation: That FMVSS 208 is not in effect and

18 "An Analysis of the Factors Affecting Seat Belt Use," Market Opinion

Research, 1977.
VI-35

that no other measures would affect occupant injuries or the number of

six-seat cars being sold. Mid-points of the effectiveness ranges are used

in these benefit calculations for illustrative purposes.

Given current lap belt usage in the center seat position (5 percent) and lap

belt effectiveness in reducing fatalities (35 percent), the number of

fatalities that would occur if no one wore restraints is 377

[370/1-(.05)(.35)]. Thus, seven lives are being saved by current levels of

manual belt usage.

Because there is currently no known practicable means to automatically

restrain center seat occupants by belts, if the center front seat position

was covered by the standard, then these occupants would likely have to be

protected by air bags. _I_f all six seat cars were equipped with air bags,

front center seat occupant, fatalities would decline by 114 (377 deaths x

roughly 0.31 effectiveness for air bags at the mid-point of the

effectiveness range with 5.0 percent lap belt usage x .98 readiness factor

for air bags). Subtracting from this the number of fatalities that would

be avoided by manual belts (seven) leaves a net savings of 107 lives.

Similar calculations for AIS 2-5 injuries result in manual belts saving 16

AIS 2-5 injuries, air bags saving 1,779 AIS 2-5 injuries, for a net savings

of air bags over manual belts of 1,703 AIS 2-5 injuries. However,

manufacturers may not equip large numbers of cars with air bags or may

still eliminate the center seating position. Thus, these savings are

unlikely to be realized, unless air bags are mandatory.
VI-36

Requiring automatic protection for the front center seat will result in shifts

in seating position, if the center seat is eliminated. Some persons who would

otherwise sit in the front center position would switch to the front outboard

or rear seats. Data from the 1982 FARS show that in those accidents where

the front center seat occupant was killed, 20 percent of the time there was no

one sitting in the right front seat. If, under a mandate for automatic

occupant protection, manufacturers comply by providing automatic seat

belts, and assuming that there is a console or other means of keeping

people from sitting in the center front seat, it is assumed that 20 percent

of current front center seat occupants would sit in the front right seat

and 80 percent would move to the rear seat. Similarly for injuries, 1982

NASS data show that 17 percent of the time when the center seat was

occupied in all accidents, there was no one in the right front seat.

The following analysis is done strictly from a statistical viewpoint. That

is, given that there will be a serious (towaway) or fatal accident,

statistically, how much better or worse off is an occupant by sitting in a

seat other than the front center seat? No attempt is made to account for

the number of accidents that may not occur because the "distraction" factor

of having a front center seat occupant is eliminated. (Some accidents may

occur because the front center seat occupant distracts the driver from

paying attention to the road.) Conversely, it is assumed that no additional

accidents occur because the driver may turn around to converse with someone

who is now a rear seat passenger or to check on a child in the rear seat.

By analyzing the probability of injury or death of shifts in seating

position, the agency is making two additional assumptions: (1) there is

available seating space elsewhere in the car, and (2) the probability of
VI-37

teing injured or killed does not change from the current distribution.

Should there not be available seating space, either of three outcomes are

possible: (1) an additional car will be used; or (2) the sixth passenger

will not take the trip, resulting in the analysis overstating potential

death and injury, but there will also be a decrease in vehicle utility; or

(3) the sixth occupant may sit in a non-designated seating position (e.g.,

on a front center console, two people in one designated seating position

such as two children in one seat, in the rear of a stationwagon, or on

someone's lap) with unknown but most likely negative safety results.

The Fatal Accident Reporting System (FARS) is the main source of data on

fatalities. FARS includes only those accidents in which there was a fatality.

Fatality rates for each seating position are developed from FARS data by

dividing fatalities in a given seating position by the number of occupants in

that seating position for all fatal accidents (see Table VI-14).

Similarly, 1982 AIS 2-5 injury rates are taken from NASS injuries and

observations.

TABLE VI-14

FATALITY AND INJURY RATES'!9

FOR OTHER THAN DRIVER POSITIONS

1982 NASS

1982 FARS AIS 2-5 Injuries

FRONT CENTER .2400 .0279

FRONT RIGHT .3774 .0274

ALL REAR SEATS .2218 .0212

The ratio of fatalities or injuries to all occupants in a given seating

position. Driver fatality rates are not included since FARS data would tend

to bias the fatality rates of drivers upwards compared to other seating

positions, since drivers are frequently the only occupant in a fatal

accident. A comparison with NCSS data gives us confidence that the

relative fatality rates for other seating positions are not affected by

the FARS reporting criteria.
VI-38

Thus, data £ low that the front right seat has a much higher fatality rate

than the front center seat, but the injury rates are virtually identical.

The rear seats are statistically the best seating positions.

Table VI-15 shows the calculations for determining how fatalities and

injuries would change if the center seating position could not be used.

TABLE VI-15

THE HYPOTHETICAL EFFECT ON FATALITIES AND INJURIES OF SHIFTING SEATING

POSITIONS

1982 FARS Data Used 1982 NASS Data Used

For 1990 Fatalities For 1990 AIS 2-5 Injuries

182,079

30,953

x .0274

848

Front Center Occupants

20% Move to Front Right

Seat for Fatalities, M%

For Injuries

Casualty Rate of Front

Right Seat20

New Front Right

Casualties

80% Move to Back Seats

For Fatalities, 83%

For Injuries

Casualty Rate of Rear

Seats

New Rear Seat Casualties

1,571

314

x .3774

119

1,257

x .2218

279

Total New Casualties

Minus Old Casualties

Assuming No Restraint Use

Change In Casualties

397

-377

+20

151,126

x .0212

3,204

4,052

These rates could be adjusted to indicate the casualty rate with automatic

belts rather than with manual belts. The fatality rate changes slightly to

.3777, but this does not change the new front right casualties from 119.

The injury rate would not change from .0274, the change is in the rounding.
VI-39

There could be 20 more fatalities per year without the center seating

position. The moving of 20 percent of the center seat occupants to the

front right seat, which has a higher fatality rate, increases fatalities,

while the moving of the remaining 80 percent to the rear seat reduces

fatalities.

For AI5 2-5 injuries, the results are very different. AIS 2-5 injuries

could be reduced by 1,028 per year, basically by forcing people into the

back seat. Both the fatality and injury calculations assume no increase in

automatic belt usage over the 12.5% current manual belt usage.

Another assumption that, can be made for hypothetical purposes is that belt

usage for the right front passenger will increase with the installation of

automatic belts to 20-70 percent total usage. Table VI-16 shows the

calculations under this assumption. At the same time, it is assumed that

manual belt usage of the rear seat occupants would not increase with the

installation of automatic belts.

Table VI-16 shows that 6 to 31 lives could be saved, and an additional 47 to

248 AIS 2-5 injuries could be reduced, because some people who would have been

sitting in the front center seat might now be buckled up in the front right

seat.

Table VI-17 shows the net impact on fatalities and injuries of continuing

the requirement for automatic protection in the front center seat and the

use of a console in the front center seating position given the assumptions
VI-40

in this analysis. There is very 1 ttle impact on fatalities (+14 to -11).

There could be a reduction in AIS 2-5 injuries of 1,074 to 1,276 per year

if no one could sit in the front center seat.

TABLE VI-16

THE HYPOTHETICAL EFFECT ON FATALITIES AND INJURIES

ASSUMING RIGHT FRONT PASSENGERS INCREASE

BELT USAGE WITH AUTOMATIC BELTS

Current Manual Automatic Automatic

Belt Usage Belt Usage Belt Usage

(8.4?i) (20%) (70%)

AIS 2-5 AIS 2-5 AIS 2-5

Fatalities Injuries Fatalities Injuries Fatalities Injuries

New right 119 848 119 848 119 848

front seat

fatalities/

injuries from

previous center

seat occupants

Increase in 0 0 11.6515 11.6% 61.6% 61.6%

belt usage

Effectiveness N/A N/A 42.5% 47.5% 42.5% 47.5%

Benefits due N/A N/A 6 47 31 248

to belt usage

TABLE VI-17

NET IMPACT ON FATALITIES AND AIS 2-5 INJURIES

OF ELIMINATING THE FRONT CENTER SEATING POSITION

AIS 2-5

FATALITIES INJURIES

Impact of moving from front

center seat +20 -1,028

Impact of front right seat

using restraints

(20-70% Total Belt Usage) -6 to -31 -47 to -248

NET +14 to -11 -1,074 to -1,276
VI-41

Another possible scenario can be analyzed. A.< sume that the front center seat

is exempt from the standard and this seating position remains in the car with

entrance available by detaching an automatic belt. Then assume these front

center seat occupants, being influenced by outboard occupants, use their belts

20-70% of the time. The benefits in this case would be 19-85 lives saved

and 230-990 AIS 2-5 injuries reduced.

Conclusions—Center Seating Position

Requiring automatic protection for the front center seating position leaves

the manufacturers of six-seat passenger cars at least two options—air bags

or elimination of the center seating position. If all cars used air bags,

an estimated 107 of the projected 370 fatalities could be saved, and 1,703

of the projected 5,000 AIS 2-5 injuries could be reduced. If the

manufacturers used a console to eliminate the front center seating

position, there would probably be very little impact on fatalities.

However, there could be a reduction in AIS 2-5 injuries'of 1,074 to 1,276.

Thus, a reduction of 21-34 percent of the AIS 2-5 injuries is possible

(1,074 to 1,703/5,000). The big disadvantage of requiring automatic

protection in the front center seat is the potential demise of the six-seat

passenger car.

If the front center seat is exempt from the standard, 19-85 fatalities and

230-980 injuries would be reduced if usage increased 20-70 percent. These

reductions are larger than those which could be obtained by eliminating the

center seat position, but smaller than those anticipated from air bags. The

injury benefits are smaller than either supplying air bags or eliminating
VI-42

the center seating position. Nonetheless, the analysis S'IOWS that not

requiring automatic protection for the front center seat, while requiring

it for the outboard positions, can lead to reductions in injuries and

fatalities, compared to the current situation of having manual belts in all

seating positions.

G. "Risk Compensation" Hypothesis

There were several commenters to the docket regarding risk compensation.

Notably, a study by John G. U. Adams (74-14-N32-1675), a study by

Adrian K. Lund and Paul Zador (74-14-N32-1671), Professor E. Scott GelJer

(74-14-N32-1008), John Graham (74-14-N35-063) and Professor Lloyd Orr

(74-14-N35-076).

The "risk compensation" theory is described by Lund and Zador^i as:

"If drivers are forced to receive more protection than they would

choose voluntarily, they respond with riskier driving that

compensates, more or less, for the forced increase in protection."

A 1982 paper by 3ohn Adams, a British professor, suggests that mandatory

use laws (MULs) are ineffective.22 f^e report argues that: (1) The

decrease in road fatalities since 1973 was greater in four countries that

did not have (MULs) than in 13 countries that did; and (2) the evidence

21 Adrian K. Lund and Paul Zador, "Mandatory Belt Use and Driver Risk Taking,"

22 IIHS, 1983.

John G. U. Adams, The Efficacy of Seat Belt Legislation, 5AE Paper

Series, 820819, June 1982.
VI-43

supports the hypothesis that "protecting car occupants from the

consequences of bad driving encourages bad driving"—more commonly referred

to as the "Risk Compensation Hypothesis."^

There are severaJ factors that cast serious doubts on the validity of

Adam's analytical approach. For example:

(1) Adams uses "total traffic" fatalities rather than "car occupant"

fatalities in his analysis. This approach could easily yield distorted

results since, as his report notes: "Occupant fatalities comprise 37

percent of all highway fatalities in Japan, 42 percent in Britain, 56

percent in France and 72 percent in the United States."24

(2) Adams also notes: "Road death statistics can fluctuate substantially

from year to year in a way that frequently mystifies the experts. In a

particular country, in a particular year, other influences might obscure or

greatly exaggerate the effect of a seat belt law."

Lund and Zador reviewed past studies about the theory and find the result

of these studies to be inconclusive. As an MUL became effective in the

province of Newfoundland of Canada in Duly 1982, the authors conducted a

research project as to driver behavior before and after the law became

effective. As a control, Lund and Zador undertook similar experiments in

Nova Scotia, which was unaffected by an MUL. The result of their study

showed no riskier driver behavior after implementation of the law—i.e., no

First advanced by S. Peltzman, "The Effect of Automobile Safety

2£ Regulation," Journal of Political Economy, 1975.

Adams, ibid., p. 2.
VI-44

evidence of risk compensation. This is the only study that the agency is

aware of that presents a before-and-after comparison of MUL-related

behavior observations under controlled conditions.

Professor Orr disagrees with the Lund and Zador Report indicating that the

changes in behavior may be more subtle and that the small changes in

behavior dismissed by Lund and Zador may, in fact, be significant.

Professor Orr offers a myriad of reasonable behaviors which could partially

offset the benefits of MUL's or automatic restraint requirements. For

example, parents may be more willing to allow teenagers to drive to late

night recreational activities, if they know they will be buckled-up or have

an air bag. John Graham, however, concludes, based on three separate

studies, that there is no substantial empirical evidence for the

risk-compensation theory nor is there any evidence that even if it were

valid it would apply to a crashworthiness measure such as is the subject of

this rulemaking.

In summary, the Department finds no data to convince it that the risk

compensation theory applies in the case of mandatory use laws, or automatic

restraints. Nor has it found any data to help quantify this effect. The

Department has already reduced its manual belt effectiveness estimates

based on data that indicates unrestrained occupants are involved in more

serious accidents than today's restrained occupants. After this

correction, the foreign experience, which should include any risk

compensation effects, appears to agree with our estimates of effectiveness

for manual belts (see Chapter IV). Since the automatic belt effectiveness

estimates are derived from the manual belt effectiveness estimates, safety
VI-45

benefits from automatic belts may also include any risk compensation

effects. However, the air bag effectiveness estimates would not include

any risk compensation effects, if they exist.

""• Benefits of a Gradual Introduction of Automatic Occupant Protection

Tables VI-18, VI-19, and VI-20 show the reductions in fatalities, AIS 2-5

and AIS 1 injuries, respectively, over the lifetime of the cars sold during

a gradual introduction of automatic occupant protection. Reductions are

shown for two possible scenarios: under the first scenario, automatic belts

would be used for 10, 25 and 40 percent of the fleet for the first, second

and third years; under the second, air bags would be provided for 6.67,

16.67 and 26.67 percent of the fleet for three consecutive years,

respectively. The benefits should be added to those that accrue under full

implementation of the standard, (see Table VI-1).

I. Benefits of Mandatory Use Laws

Table VI-21 shows the safety benefits that would occur if states containing

a total of 67 percent of the Nation's population enacted mandatory use

laws, without the implementation of the automatic restraint requirements of

FMVSS 208. Of course, benefits would be higher if additional states

passed mandatory use laws.
VI-46

TABLE VI-18

INCREMENTAL REDUCTION IN FATALITES

OVER THE LIFETIME OF THE MODEL YEAR FLEET

CENTER SEAT EXEMPT

BASED ON LOW-HIGH EFFECTIVENESS ESTIMATES

MY 1987 MY 1988 MY 1989

10% Automatic Belts, 25% Automatic Belts; 40% Automatic Belts;

6.67% Air Bags 16.67% Air Bags 26.67% Air Bags

Air Bags Only

Air Bags with Lap Belt

(12.5% Usage)

Air Bags with Lap/

Shoulder Belts

(12.5% Usage)

Automatic Belts

(20% Usage to

70% Usage)

250-570

290-590

300-600

50-100

500-750

620-1,420

720-1,470

750-1,500

130-250

1,260-1,880

990-2,260

1,160-2,350

1,200-2,390

210-390

2,010-3,000

Air Bags Only

Air Bags with Lap Belt

(12.5% Usage)

Air Bags with Lap/

Shoulder Belts

(12.5% Usage)

Automatic Belts

(20% Usage to

70% Usage)

TABLE VI-19

INCREMENTAL REDUCTION IN AIS 2-5 INJURIES

OVER THE LIFETIME OF THE MODEL YEAR FLEET

CENTER SEAT EXEMPT

BASED ON LOW-HIGH EFFECTIVENESS ESTIMATES

MY 1987 MY 1988 MY 1989

10% Automatic Belts, 25% Automatic Belts; 40% Automatic Belts;

6.67% Air Bags 16.67% Air Bags 26.67% Air Bags

4,830-9,700

5,490-10,030

5,650-10,200

870-1,570

8,690-12,460

12,080-24,240

13,710-25,070

14,120-25,480

2,190-3,910

21,720-31,140

19,330-38,780

21,940-40,100

22,590-40,770

3,500-6,260

34,740-49,830
VI-47

TABLE VI-20

INCREMENTAL REDUCTION IN AIS 1 INJURIES

OVER THE LIFETIME OF THE MODEL YEAR FLEET

CENTER SEAT EXEMPT

Air Bags Only

Air Bags with Lap Belt

(12.5% Usage)

Air Bags with Lap/

Shoulder Belts

(12.5% Usage)

Automatic Belts

(20% Usage to

70% Usage)

MY 1987

10% Automatic Belts,

6.67% Air Bags

16,810

16,810

16,810

2,280

17,210

MY 1988

25% Automatic Belts;

16.67% Air Bags

42,010

42,010

42,010

5,690

43,03b

MY 1989

40% Automatic Belts;

26.67% Air Bags

67,220

67,220

67,220

9,100

68,850
VI-48

TABLE VI-21

ANNUAL SAFETY BENEFITS OF

MANDATORY USE LAWS

AFFECTING 678! OF THE POPULATION

INCREMENTAL FATALITY REDUCTION

EFFECTIVENESS

USAGE LOW (40%) MID-POINT (45%) HIGH (50%)

40% 1,900 2,160 2,410

70% 3,970 4,500 5,030

INCREMENTAL AIS 2-5 INJURY REDUCTION

LOW (45%) MID-POINT (50%) HIGH (55%)

40% 31,990 35,800 39,680

70% 67,290 75,310 83,460

AIS 1 INJURY REDUCTION

10%

40% — 55,280

70% 115,320
VII -1

VII. INSURANCE PREMIUM REDUCTIONS

The potential reduction in fatalities and injuries that are likely to

result from mandated automatic restraints could produce a corresponding

decrease in legal, medical and rehabilitation expenses. The reduction in

these and other expenses associated with fatalities and injuries which are

traditionally covered, at least in part, by insurance policies, would

decrease insurance company payouts. On the other hand, it is possible that

the additional cost of automatic restraints may increase insurance company

payouts for certain property damage claims. Since insurance premiums are

generally based on loss experience, it is assumed that shifts in this

experience will eventually be reflected in the premiums paid by consumers.

Generally, three types of insurance provide coverage for injuries suffered

in automobile accidents', automobile insurance, health insurance, and life

insurance. Possible changes in insurance premiums for each type of

insurance are examined in detail in this chapter. A summary of these

changes is shown in the table below for the range of possible effectiveness

rates. Note that savings occur in automobile, health, and life insurance

due to fatality and injury reduction while costs associated with air bag

deployments may cause a small increase in automobile insurance policies

that cover property damage (collision and comprehensive insurance). The
VII-2

numbers in this summary table are derived from Tables VII-3, VI1-17,

VII-19, and VII-23 respectively for automobile insurance savings, automobile insurance losses, health insurance, and life insurance.

SUMMARY OF RANGE OF POTENTIAL NET EFFECTS

ON INSURANCE PREMIUMS FROM

AUTOMATIC RESTRAINT REQUIREMENTS

Per Vehicle

Annual

Savings ($ )

Air Bags

Automobile Insurance

Savings-Safety 9-17

Loss-Deployment (3 )

Health Insurance 4- 8

Life Insurance 0- 1

Total 10-23

Automatic Belts

{For 20 Percent Assumed

Usage )

Automobile Insurance 1- 2

Health Insurance 0- 1

Life Insurance 0

Total 1- 3

Automatic Belts

(For 70 Percent Assumed

Usage )

Automobile Insurance 10-14

Health Insurance 5- 7

Life Insurance 1

Per Vehicle Total Annual

Lifetime 1990 Fleet

Savings ($ ) Equivalent Savings ($M)

62-115

(18)

29- 54

3 - 7

76-158

5-

2-

0-

14

7

1

7- 22

Total 16-22

65-

3 1 -

4-

94

44

6

100-144

1108-2046

(312)

521- 962

62- 136

1379-2832

89- 243

42- 114

7- 14

138- 371

1146-1676

539- 788

71- 106

1756-2570

Note that any changes in insurance premiums are likel y to lag behind actual

changes in loss experience. Moreover, the ful l value of the changes

indicated in the above table would probably not occur unti l roughly 10 to
VII-3

15 years after any of the proposed rules would be implemented-when the

entire vehicle fleet has already been replaced with vehicles containing

automatic restraints. Both safety benefits and premium reductions in

intervening years would be considerably smaller because safety benefits

would onl> accrue to the newer vehicles in the fleet. The "Total Annual

Savings" column in the above table reflects a hypothetical situation in

which the entire 1990 passenger car fleet was equipped with automatic

restraints and had been so long enough to affect insurance experience. It

is provided here in order to remain consistent with safety benefit

calculations, which were based on 1990 fatality and injury forecasts.

A. Automobile Insurance

Automobile insurance plans include a variety of different coverages.

Basically these include personal injury liability and medical coverage,

which pays for bodily injury caused by accidents; physical damage

liability, which covers damage to property of others caused by the

policyholder; collision insurance, which covers damage to the

policyholder1s vehicle from accidents; and comprehensive coverage, which

covers damage to the policyholder's vehicle from non-motor vehicle accident

causes such as fire, flood, and theft.

Premiums paid for the first two of these coverages, personal injury

liability and medical, would be reduced by the safety benefits

that result from automatic restraints. Pienuums paid for the remaining

three coverages, physical damage liability, collision and comprehensive,
VIImay be increased to cover higher replacement and book value costs

associated with air bags (the relatively low cost of automatic belts would

have an insignificant effect on insurance premiums).

In the following sections, estimates will be made of the effect on ;

premiums for each of these coverages. The effect of safety benefits on

personal injury coverage will be examined first, followed by the added

premium costs that may result for the various physical damage coverages.

1. Personal Injury Premium Reduction from Safety Benefits

The potential safety benefits associated with automatic restraints have

prompted some insurance companies to offer premium reductions for cars

equipped with these devices. These reductions are currently based on

expected savings in both claims and expenses associated with first party''

injury coverage. Based on a recent survey of insurance companies, NHTSA

estimates that about 40 to 70 percent of all automobile insurance policies

nationwide offer discounts of up to 30 percent on vehicles that have some

form of automatic restraint.

This analysis is based on the assumption that the reduction in fatalities

and injuries associated with automatic restraints will result in cost

savings that will be passed on to consumers via premium reductions. While

it is not certain what level of fatality and injury reduction would occur,

insurance industry testimony indicates that savings from injury reduction

Under first party coverage, the policy holder collects compensation for

losses from the insurer. Third party coverage refers to compensation paid

by the policy holder's insurer to other persons involved in the cra^h.
VII-5

will in fact be passed on to consumers. In past Public Hearings,2 some

insurance industry representatives indicated that they could not provide

any assurances regarding the transfer of cost savings to consumers.

Specifically, State Farm said a decision can only be made after a careful

assessment of the impact of automatic restraints when an adequate number

of cars are on the highway. However, in recent public hearing on FMVSS 208

State Farm stated that "substantial cost reductions . . . will be reflected

in the rates which will be charged State Farm policyholders." In

subsequent comments to the SNPRM, State Farm reaffirmed that insurance

savings will be passed on to the consumer and labeled such savings as

"substantial" while suggesting that the DOT estimates are conservative.

Other companies, have also stated that savings would be reflected in lower

premiums. In recent public hearings,3 Nationwide Insurance Co. cited

existing discounts for automatic restraints, bonus coverage for seat belt

users, and recent rate decreases in 19 jurisdictions as evidence that

decreases in fatality and injury experience will, in fact, be passed on to

consumers through premium reductions. Nationwide reiterated this,view in

comments to the SNPRM. Other commenters also testified that premiums would

reflect changes in injury experience. These include the American Insurance

Association,4 the United States Automobile Association,5 Allstate Insurance

2 Public Hearing Concerning the Automatic Restraint Requirements of FMVSS

208, "Occupant Crash Protection, Volumes I and II," August 5-6, 1981, U. S.

DOT, Diversified Reporting Services.

•* Public Hearing on Issue of Automatic Restraint Systems, Overland Park,

Kansas, 12/1/83.

4 Public Hearing on Issue of Automatic Restraint Systems Overland Park,

Kansas, 12/1/83.

-* Public Hearing on Federal Motor Vehicle Safety Standard 208, Occupant Crash

Protection 11/28/83, Los Angeles, California.
VII-6

Company,6 The Automobile Club of Southern California,""7, the National

Association of Independent Insurers,8 and 3ames P. Corcoran, Superintendent

of Insurance of the State of New York.9 Recently (6/84 ), New York State

passed a law that would require insurance companies to offer discounts to

drivers who have automatic restraints in their cars. Finally, the

Automobile Club of Michigan, an affiliate of AAA, stated that the> have

committed to the Michigan Legislature to reduce premiums by 20 percent on

the day a mandatory seat belt law becomes effective in Michigan.10

Insurance industry claims of premium reductions notwithstanding, the

Department is still uncertain regarding the amount of premium reductions to

be passed on to policyholders. The Department sought additional estimates

of insurance savings through questions in the SMPRM, but insurance

companies failed to pro\ide further specifics regarding possible policyholder savings. The insurers claim they already offer 20 to 40 percent

premium discounts for automatic restraint-equipped vehicles. However, these

onl> apply to first-person injury payments, a relatively small part of

total premiums. USAA was the only insurer to translate this "30 percent

discount" into dollars, and at the Los Angeles public hearing stated it

amounted to about $3 per year.

6 Public Hearing on Federal Motor Vehicle Safety Standard 208, Occupant Crash

Protection, 11/28/83, Los Angeles, California.

^ Public Hearing on Federal Motor Vehicle Safety Standard 208, Occupant Crash

Protection 11/29/83, Los Angeles, California.

8 Public Hearing on Federal Motor Vehicle Safety Standard 208, Occupant Crash

Protection, Washington, D.C. 12/7/83.

9 Public Hearing on Federal Motor Vehicle Safety Standard 208, Occupant Crash

Protection, Washington, D.C. 12/3/83.

10 Docket 74-14-N33-129
VII-7

The above discounts often apply only to air bags, not automatic belts.

Nationwide, Aetna, Allstate, and GEICO related their current discounts to

air bags only. Only Kemper stated it offered premium reductions for both

automatic belts and air bags.

Insurers, in general, continued to refuse to estimate reductions for

personal liability premiums. As in the past, only Nationwide offered a

quantified estimate, $31 per year, for air bags, for all personal injury

premiums. Several other companies stated the Nationwide estimate appeared

reasonable while others claimed, because of industry competitiveness and

because rates are based on experience, that "substantial" reductions would

occur. However, Allstate stated that it was hard to predict reductions due

to passive belts because manufacturers might produce "poorly performing

automatic belts" which might not save any lives or prevent any injuries.

Overall, although it appears that some level of insurance premium reduction

will result from automatic restraints, the exact level of that reduction is

uncertain, and is highly dependent on the success of the restraint system

in reducing deaths and injuries.

Current premium reductions are associated with first party injury coverage

only. The following analysis of insurance cost savings is based on the

assumption that as the fleet is replaced with more vehicles equipped with

automatic restraints, insurance companies could begin to experience cost

savings that would allow them to extend premium reductions to third party

premiums as well as first party premiums. Tor competitive reasons,

insurance companies may eventually discontinue the practice of offering
VII-8

vehicle specific discounts and offer, instead, general reductions in first

and third party injury premiums.''''

Estimates of insurance premium reduction have varied considerably. For

example, data provided by Nationwide Mutual Insurance Companies to the

FMVSS 208 docket12 indicated that the installation of air bags in all

automobiles would reduce private passenger first and third party liability

premiums by 24.6?o or $31 annually per insured car. However, the Insurance

Commissioner of NY State, James Corcoran, estimates that, based on NY State

data, annual premium savings of $66 per insured vehicle could be realized

if automatic restraints were required. NHTSA has not adopted these

estimates for several reasons: 1 ) the Nationwide estimate reflects

expectations of air bag safety benefits that are inconsistent with current

aaency estimates. It was derived in 1976 and does not reflect what tne

agency believes to be the best estimate of air bag effectiveness. 2) The

Corcoran estimate reflects data from one state only and is not nationally

representative. Premiums in New York State tend to be higher than those in

the overall country.

^ This assumption is based on general discussions with representatives of the

insurance industry. For further discussion, see comments of William

Nordhaus, Docket No. 74-14-NPRM-N20-110 (pp. 11-12) and Docket No. :

74-14-NPRM-N22-032 (pp. 12-13).

12 Docket No. 74-14-N20-100, and 74-14-N35-038.
VII-9

In Chapter IV a range of effectiveness rates is estimated for the various

forms of automatic restraints. In the following pages, the mid-points of

these ranges will be used to illustrate the methodology on which final

estimates are based. Results for the entire range of estimates are listed

in Table VII-3.

The safety benefits derived from an automatic restraint device are a

function of both its effectiveness in reducing injuries and its usage rate.

Based on data developed in Chapter IV (air bag effectiveness weighted by

current belt usage) air bags are estimated to be 31.9 percent effective in

preventing fatalities, 36.9 percent effective in preventing AIS 2-5

injjries and 10 percent effective in preventing AIS 1 injuries. NHTSA

currently does not have data which indicate the part of insurance payouts

that result from death as opposed to injuries. Fatalities make up less

than 1.5 percent of all injuries and the incidence of AIS 2-5 injuries

outnumber deaths by a ratio of almost 14 to 1. However, liability payments

for deaths would typically be much higher than for most injuries (an

exception to this might occur with AIS A or 5 injuries, which can involve

expensive long term medical problems).

Allstate insurance estimated that 1 percent of their injury losses under

personal injury protection, uninsured motorist, and bodily injury liability

coverages are associated with instant or immediate fatalities."^ FARS,

NASS, and NCSS data, which are used to estimate safety benefits in this

analysis, define a fatality as any death that occurs within 30 days of the

accident. Considering the Allstate estimate of one percent of losses for

13 Docket No. 74-U-032-61 06.
VII-10

instant or immediate fatalities, it will be assumed for this analysis that

10 percent of all losses are associated with deaths that occur within 30

days of the accident.^ The remaining 90 percent of losses will be divided

between AIS 2-5 and AIS 1 injury categories. This division will be based

on the assumption that the aggregate economic cost of lost productivity and

medical expenses reflects the appropriate ratio of insurance payouts. A

recent NHTSA report, The Economic Cost to Society of Motor Vehicle

Accidents^ 5 indicates that for these costs (exclusive of fatalities) roughly

16 percent is incurred from AIS 1 injuries and 84 percent is incurred for

AIS 2-5 injuries. Overall weights would thus be 10 percent for fatalities,

75.6 percent for AIS 2-5 injuries, and 14.4 percent for AIS 1 injuries.

Weighting the above mentioned effectiveness estimates by these factors, an

average effectiveness 'in reducing costs from injuries and fatalities) of

32.5 percent is derived for full frontal air bags.1^

^ Allstate was not able to precisely define "instant or immediate," but the

semantic description seems to imply death on impact. Such cases would

require minimal medical attention and would therefore be less expensive

than other fatalities which would typically require treatment in intensive

care units. The use of a 10 percent estimate reflects both additional

fatalities that occur within 30 days and the higher treatment costs that

occur for those fatalities. While there are no data to confirm the

accuracy of this estimate, it should be noted that the analysis is not

overly sensitive to this variable. Prior to receipt of the Allstate

estimate, an analysis was performed based on societal costs as measured in

the 1/83 NHTSA report The Economic Cost to Society of Motor Vehicle

Accidents. That analysis weighted fatalities to injuries in a 73-27 ratio

rather than the 10-90 ratio used here. The overall results were roughly 8

percent lower than the savings estimated in this analysis. The 73-27 split

was also used in the 10.'83 PRIA. The large difference between this ratio

and the Allstate estimate probably indicates that insurance payouts do not

fully cover the value of lost productivity associated with fatalities.

15 The Economic Cost to Society of Motor Vehicle Accidents, January 1983,

D0T-H5-806-342.

16 Fatalities: .319 effectiveness x .10 = .032

AIS 2-5 Injuries: .369 effectiveness x .756 = .279

AIS 1 Injuries: .10 effectiveness x .144 ; .014

TOTAL TIS
VII—11

Similarly, lap and shoulder belts, when used, are estimated to be roughly

43.7 percent effective in reducing fatalities and injuries.17 The higher

overall effectiveness of seat belts is due to their ability to reduce

injuries for side, rear and rollover impacts as well as frontal impacts.

However, currently seat belts are worn by only 14 percent of the driving

population (12.5 percent of front seat passengers)^ whereas air bags would

protect virtually all front seat occupants.

A.M. Best Company fa publisher of insurance industry statistics) lists the

1982 value of private passenger liability premiums at $20.9 billion. Data

from the insurance industry^ indicates that 66 percent of this total or

$13.8 billion is for personal injury coverage. The remainder is for damage

to property. Best data show that roughly 73.5 percent of these premiums,

o: $10.1 billion will be paid out to accident victims as incurred losses

from motor vehicle accidents. These losses could be reduced if automatic

restraints were to result in fewer fatalities and injuries. Best data also

indicate that loss adjustment expenses such as claim adjustment, legal

fees, assessment costs, etc. represent 12.1 percent of premiums earned.

Some of these costs represent expenditures that are relatively fixed. For

example, some companies have their own claim adjusters and legal staff that

would be paid a salary regardless of small variations in the accident rate.

17 Fatalities: .45 effectiveness x .10 = .045

AIS 2-5 Injuries: .50 effectiveness x .756 = .378

AIS 1 Injuries: .10 effectiveness x .144 = .014

TOTAL 7477

18 Current usage rate s for front driver, center and right seating position are

.14, .050, and .084. The percent of projected 1990 front seat fatalitie s

for the driver, center and right seating positions are 73.5, 1.5, and 25.0?o

(.14 x .735) + (.050 x . 015 ) + (.084 x .250) = 12.5% average usage rate for

front seat.

1 9

 See Docket 74-14-N32-6106 and 74-14-N32-6126
VII-12

Other companies, however, hire claim adjusters as needed and even the

larger companies ma> pay commissions to their own claim adjusters or hire

additional legal staff if needed.

Although the short run effect of decreased injuries on these expenses is

unclear, over the long run, lower injury rates should result in a

proportional decrease in loss adjustment expenses. It will therefore be

estimated that a total of 86 percent of premiums (73.5 percent incurred

losses plus 12.1 percent loss adjustment) will be affected by reductions in

injuries and fatalities. It should be noted that this reflects overall

industry experience: for different companies the percentage may be higher

or lower.

The above premiums cover roughly 111,560,000 vehicles^ for an average

personal injur> liability premium of $124 per vehicle. Of this amount, 86

percent or $107 might vary with improvements in safety.

As mentioned above, safety benefits are a,function of both effectiveness

and usage rates. Tor this analysis, the product of these variables will be

referred to as the safety factor. The safety factor of the current vehicle

fleet as compared to the current fleet if it were air bag equipped is as

follows:

Data from Automobile Insurance Plans and Services Office ( AIPSO ) indicates

that in 1982 there were 111,564,554 vehicles (including light trucks and

MPV's) covered by private passenger automobile liability policies.
V1I-13

1983 Fleet

.437 effectiveness x .125 usage = .055 (safety factor for front seats) x

.486 (percent of all motor vehicle fatalities in front seat of

automobiles )21 = .027 (1983 fleet safety factor)

1983 Fleet (Air bag equipped)

.325 effectiveness x .98 usage = .319 x .486 = .155 (air bag equipped fleet

safety factor )

Full frontal air bags would therefore increase the safety of the current

fleet by 12.8 percentage points. This could reduce the average annual

premium by $14.22 These savings, which would accrue after the entire fleet

has been equipped with air bags, would be applicable to the entire insured

passenger car fleet. It is not certain when the existing fleet will be

replaced. This could occur as early as 1998, but it is more likely to be

early in the first decade of the new century before all vehicles are

replaced. Since it is difficult to project vehicle sales that far into the

future, for illustrative purposes, we will estimate total savings for 1998.

In 1998, the insured passenger car fleet is estimated to be roughly 126

million vehicles.23 Total annual savings would therefore be $1.8 billion.24

21 For this analysis it will be assumed that insurance losses are proportional

to fatalities. Passenger car occupants are 52.8?o of all fatalities. Front

seat fatalities are 92?o of all occupant fatalities. .92 x .528 = .486

22 Assuming that incurred losses are directly proportional to the incidence of

death and injury, the total variable loss per vehicle in 1982 if the safety

effectiveness factor had been 0 (i.e. no seat belt usage) would be $110

(107/1-.027r$110). .128 x $110 = $14.08. Note that this represents an

average savings. Savings for more accident prone groups, such as 18-24

year old male drivers, would probably be considerably higher while savings

for drivers in low risk groups would be lower.

2^ Based on current forecasts, NHTSA estimates a passenger car fleet of 13^

million in 1998. Data from AIPSO indicates that roughly 90?o of all

passenger cars are covered by liability insurance. Data from Nationwide

Mutual Insurance Co. indicates that passenger cars pay 10 percent of

commercial liability premiums. Based on AM Best data, commercial premiums

total $4.7 Billion in 1982. Assuming the same average premium cost for

commercial as for private policies the total number of cars with commercial

insurance is 3,790,000 ((.10 x $4.7B )/$124). This represents roughly 3.4

percent of the total number of vehicles with private passenger liability

coverage. Therefore, it is estimated that 93% of all vehicles have

liability coverage. .93 x 135M= 126M.
VI1-14

Had the entire fleet been equipped with air bags in 1990 (the base year for

fatality and injury benefit calculations), total annual savings would have

been $1.6 billion.

Over the life of each vehicle, the discounted value of insurance savings

(assuming a 10 percent discount rate and a 10 year vehicle life) would be

$95.25 Spread over the entire vehicle fleet (including uninsured vehicles),

the discounted value is $89.26

Other alternatives being considered involve the use of detachable or

nondetachable belts. There is considerable uncertainly regarding the

actual usage rates that would eventually result from these systems.

Estimates derived in Chapter V range from 20 to 70 percent. Table VII-1

shows the derivation of premium decreases for various usage levels of

automatic belts. Table VI1-2 summarizes the potential insurance premium

benefits resulting from various usage rates that might occur for automatic

belt systems, as well as those associated with the effectiveness rate

expected for air bags. Safety belt usage laws are also under consideration

in this analysis. Such laws would involve use of the current safety belt

system which may be slightly more effective than automatic systems.

Benefits from such laws would therefore be somewhat higher than those shown

in Table VII-1.

24 Note that light trucks, MPV's and other vehicles may also eventually

receive some reduction in their liability premium. Although these vehicles

would not contain automatic restraints, they may still benefit from the

reduced injury experienced by passenger car occupants through lower

liability settlements when the driver of the non-passenger cars is at

fault.

2-> The conversion factor for a 10% discount rate over 10 years is 6.758

6.758 x 14.08 = $95.

2 6 126m (insured vehicles) x $95/135m (all vehicles) = $88.81.
VII-1 5

TABLE VII- 1

ANNUAL PREMIUM SAVING FROM AUTOMATIC BELTS

Usaqe

20

30

40

50

60

70

Safet y

Factor27

.040

.061

.081

.101

.121

.141

Percentage

Point

.013

.034

.054

.074

.094

.114

Decreases

in

$1.43

3.74

5.94

8.14

10.34

12.54

TABLE VII- 2

SUMMARY OF POTENTIAL AUTOMOBILE PERSONAL INJURY

INSURANCE PREMIUM SAVINGS30

AIR BAGS AND AUTOMATIC BELTS, MID-POINT EFFECTIVENESS

(1982 $)

Per

Insured Vehicle

Usane

20

30

40

50

6 J

70

Air Bag:

.c Belts:

Rate

Effectiveness

33

2 7

 Usaae; Rate x

Annual

Sa\inas

1

A

6

8

10

13

14

Effectiveness

Per Vehicle

'Includes Uninsured )

Annual

Savings

Total

Annual

Total Savings

Annual 1990 Fleet

Life- Savings 1998 Equivalent

Time32 Fleet (M)33 'M)3'

10

25

40

55

70

85

95

1

3

6

8

7010

12

13

9

24

37

51

65

79

89

180

471

748

1026

1303

1580

1774

160

419

665

912

1,158

1,404

1,577

(.416) x % Front Seat Passenger Car Fatalities

2 8

(.027)

3 2

3 3

(.486).

Safety Factor minus 1983 Fleet Safety Factor (.027).

Percentage Point Increase x estimated current premium rate with no belt

usage ($110).

The values shown for manual or automatic belts must be considered as upper

limits since they do not account for the apparent lower usage of safety

belts by those involved in accidents as compared to the general population.

Present discounted value over 10 year lifetime at 1D?o discount rate.

Present discounted value over 10 year lifetime at 10*> discount rate..

Per insured vehicle annual savings x 126 m insured vehicles (based on 135 m

passenger car fleet in 1998),

Per insured vehicle savings x 112 m insured vehicles (based on 120 m

passenger car fleet in 1990).
VII-16

The above estimates, as well as all previous methodology in this chapter,

have been derived from the mid-points of the estimated ranges of

effectiveness discussed in Chapter IV. Given the uncertainty which is

partially responsible for the establishment of these ranges, consideration

should also be given to the upper and lower bounds of premium savings that

could result when the low and high effectiveness values were considered.

Table VII-3 compares the low, mid-point, and high effectiveness estimates

for air bags, for automatic belts at 20 percent usage, and for automatic

belts at 70 percent usage. Note that as a simplifying measure the

TABLE VII- 3

SUMMARY OF POTENTIAL AUTOMOBILE PERSONAL INJURY INSURANCE

PREMIUM SAVINGS FOR LOW, MID-POINT, AND HIGH EFFECTIVENESS RATES

(1982$ )

Insured Vehicles

Air Bags:

Low Eff.

Mid Eff.

High Eff.

Annual

Savinas

10

14

18

Lifetime

Savinas

67

95

123

Automatic Belts - 20?o Usage:

Low Eff. 1 5

Mid Eff. 1 10

High Eff. 2 15

Automatic Belts - 70% Usage:

Low Eff. 10 69

Mid Eff. 13 85

High Eff. 15 101

All Vehicles

Annual

Sa vinos

9

13

17

10

12

14

Total

Total Annual

Annual Sa\ings

Savings 1990 Fleet

Lifetime 1998 Fleet Equivalent

Savings (Millions) (Millions;

62

89

115

5

9

14

65

79

94

1,247

1,774

2,302

100

180

273

1,289

1,580

1,885

1,108

1,577

2,046

89

160

243

1,146

1,40i

1,67 6
VII-17

mid-point of lap and shoulder belt usage was used to define the 1983 base

safety factor for both the high and low effectiveness estimates. Use of

low or high estimates of base safety factors in various combinations with

automatic restraint safety factors would have a minimal effect on the

material results of this analysis.

2. Auto Physical Damage Premium Increases from Air Bag Replacement Costs

Although personal injury liability premiums might decrease because of

automatic restraints, air bag deployment would make repair bills for

vehicles involved in accidents somewhat higher. In addition, the cost of

air bags would raise the average book value of passenger cars. This may,

in turn result in higher auto physical damage premiums.

Three basic types of physical damage insurance could be affected by the

addition of air bags to the vehicle fleet: Collision insurance, which

covers repair of all damage to the driver's car caused by an accident,

property damage liability insurance, which covers repairs for third party

losses, and comprehensive insurance which covers damage or loss of

the insured car due to fire, theft, and vandalism. Since both collision

and liability insurance cover similar types of losses (i.e. damage from

motor vehicle accidents), they will be examined together.

Note that, in the course of public testimony and comment on this rule,

several commenters have stated that collision and comprehensive insurance

premiums would automatically increase as higher vehicle prices (reflecting

the addition of the air bag) pushed vehicles into higher cost categories.

This would occur because collision and comprehensive premiums are often
VII-18

based on "symbol" categories which classify vehicles in a specific price

range. As the price of the vehicle increases to reflect added air bag

costs, some vehicles would move out of one "symbol" category and into the

next, resulting in a higher premium for that vehicle. NHTSA does not have

the data needed to make a precise estimate of the number of vehicles that

would be affected. However, based on an examination of current symbol

categories, roughly 10-15 percent of all vehicles appear likely to

experience such a shift. It should be noted, however, that this shift is

essentially a temporary phenomenon. In discussion with the Insurance

Service Office (ISO), the organization that determines symbol rates for

much of the industry, NHTSA has confirmed that this effect would occur, but

that ultimately, competition in the insurance industry would result in

modified ISO symbols that would reflect actual loss experience. Thus,

long-run changes in comprehensive and collision insurance rates would

reflect only increased insurance losses due to replacement costs for air

bags and higher book values associated with totalled vehicles. Since this

analysis examines the long-term effects of automatic restraints, no

estimate is provided for the short-term increases that will result in the

initial years of an automatic restraint rule.

In comments to the SNPRM, two insurers, GEICO and Kemper, agreed that air

bags would result in higher physical damage premiums, although quantitative

estimates were not supplied.
VII-19

a. Motor Vehicle Accident Losses - Collision and Property Damage Liability

Insurance

Both collision and property damage liability insurance policies will have

to absorb additional costs for replacing deployed air bags, for the value

air bags add to vehicles that are totalled, and for the added cost that

will result when some damaged vehicles are considered "totalled" instead of

repairable because of the added cost of replacing the air bag.

Replacement of deployed air bags: This cost is a function of both the

number of air bag deployments and the cost of actually replacing a deployed

air bag. The number of expected deployments is estimated as follows:

\A5S data indicate that 2,300,000 passenger cars were involved in towaway

accidents in 1981 when there were roughly 105.8 million passenger cars in

use. Therefore 2.2 percent (2.3m/105.8m) of all passenger cars were

involved in a towaway accident.

Generally speaking, air bags are intended for deployment when the

longitudinal delta V (change in velocity) is 12 mph or greater. By

combining data from NCSS and MASS, it can be estimated that 24.7 percent of

all passenger car towaways experienced a frontal impact of this nature and

magnitude. This included accidents in which the primary impact force was

within 60 degrees of the centerline of the impacted vehicle. Table VII-A

illustrates the derivation of this number.
VII-20

TABLE VII-4

PERCENT OF TOWAWAY ACCIDENTS LIKELY TO DEPLOY AIR BAGS

Direction of Force

10 O'Clock

11

12

1

2

NCSS

Cumulative

Percent >=12 MPH

6.7

31.6

41.9

32.2

7.2

NASS

Percent of

x Towaway =

7.3

10.1

41.5

9.5

7.9

Cumulative

Percent >=

12 MPH

.49

3.19

17.39

3.06

.57

24.70

Although air bags are generally intended to deploy at impacts equivalent to

a delta V of about 12 mph, experience with the current air bag fleet

indicates that a number of deployments occur at delta V's somewhat below 12

mph. There are several reasons why this might occur, including safety

margins built into the sensors to insure air bag deployment, other

characteristics of the sensor mechanism which limit its ability to

precisely measure passenger compartment delta V, and errors in reporting

accident characteristics. It is likely that this last factor - reporting

error - is responsible for a significant part of reported below 12 mph

deployments. The actual delta V is difficult to estimate after the fact of

an accident. The agency has developed techniques for inferring delta V

from structural deformation of the vehicles and other crash site evidence,

but the ability to do so within one or two miles per hour is certainly not

assured.

Both safety margins and limitations in sensor mechanisms are factors that

will continue to affect real air bag deployment rates in any future vehicle

fleets. To the extent that errors in accident reporting understate actual

impact speeds, the previous estimates of deployment accidents could be
VII-21

understated so these errors would also effect any estimate of total

deployment. It is therefore appropriate to reflect these factors in

estimating future deployment rates.

An analysis of NHTSA's computerized file of the air bag fleet experience

indicates that 34?o of all air bag deployments occurred when reported

longitudinal delta V's were below 12 mph.

Based on current experience, the total number of air bag deployments that

would be expected after the entire vehicle fleet was equipped with air bags

(roughly 1998' is computed as follows:

135 million total passenger car fleet in 1998) x .022 (percent of p.c.

fleet involved in towawa> accidents) x .247 (percent of p.c. towaways with

frontal impact '> - 12 mph delta V) / .66 (adjustment for below threshold

oeployments) = 1,111,500 deployments.

It should be emphasized that the adjustment for below threshold deployments

reflects the experience of air bag systems designed in the mid to late

1970's and installed only on larger, more expensive vehicles. It therefore

ma\, not be representative of the type of performance that will occur on

future vehicle fleets. Specifically:

o The vehicles in future fleets will probably be much smaller than the

vehicles in the current sample fleet. F.ven today's fleet is on average,

much smaller than the typical air bag fleet car. This will require a

change in air bag system designs to reflect the need for faster bag
VII-22

inflation (due to shorter distance between the driver and the struck

object) and to reflect the likelihood of the higher delta V's typically

experienced by smaller, lighter vehicles.

o The driving experience of owners of current air bag equipped vehicles is

probably not typical of the overall driving population. Since air bags

were only installed on the larger, more expensive vehicles the accident

experience of these vehicles should reflect the more cautious driving

habits of the older more affluent population that typically purchases this

type of vehicle. Moreover, at least some owners of air bag equipped

vehicles chose to purchase the air bag and the voluntary purchase of a

vehicle with an air bag in itself implies an overall concern for safety on

the owner's part, which should be reflected in more conservative driving

habits.

The actual "below threshold" deployment of future air bag fleets is

uncertain. Generally, however, the more conservative driving habits of the

current fleet would imply that the overall number of low-speed deployments

should be less for the fleet as a whole than for the current air bag fleet.

Moreover, future sensor designs should, through experience and

technological advancement, be better able to accurately sense the more

serious accidents that require air bag deployment. The above estimate

based on current "below threshold" deployment experience might therefore be

considered an outside bound of actual deployment incidence in the late

1990's.
VII-23

A lower bound for deployment incidence can be computed by estimating that

in the future, sensors will still typically be set to go off at a level

somewhat below the 12 mph threshold in order to provide a safety margin for

deployment, but that quality control and improved design will eliminate

most unnecessary deployments. Assuming 10 mph as a reasonable safety

margin, the lower bound would be estimated as follows:

135 m (vehicles) x .022 (towaway rate) x .342 (% of p.c. towaways

with frontal impact > = 10 mph delta35 V) = 1,015,740.

These estimates are based on vehicles towed away from the scene of the

accident. Potentially, a number of non-towaway vehicles may also be

involved in collisions that are of severe enough delta V that they should

also result in air bag deployment. An examination of the 1982 NASS file

indicates that there were 17,180 vehicles involved in non-towaway

collisions with a delta V of 10 mph or greater. It is difficult to

directly relate these vehicles to the total number of non-towaway accidents

because NASS only examines a small percentage of all non-towaways.'^

Instead, we will estimate that the number of non-towaway deployments in the

late 1990's will increase in direct proportion to the size of the vehicle

fleet. The total estimate should therefore be 21650 ((1 35m/107m)x1 71 80 ).

Adding this to the previous low estimate (based on 10 mph delta V) gives a

total of 1,037,390 deployments.

Derived as in Table VII-A using 10 mph instead of 12 mph NCSS data.

NASS only examines non-towaways that are reported to the police and involve

an injury or the towaway of another vehicle. Most other types of accidents

would be very minor and would probably not involve air bag deployments.
VII-24

Similarly there were 7914 vehicles involved in non-towaway collisions with

a delta V of 12 mph or greater. In the late 1990's this could grow to 9972

(135m/107m)x7914). Applying this figure to the methodology based on 12 mph

delta V's gives a total of 15,109 (9972/.66). Adding these to the previous

high estimate (based on 12 mph delta V) gives a total of 1,126,609

deployments.

Expected deployments for a total fleet equipped with air bags in the late

1990's could therefore be between 1,037,390 and 1,126,609 each year. Based

on this analysis, it will be estimated that 1,100,000 passenger cars will

be involved in an accident that will result in an air bag being deployed.

This represents roughly .8 of one percent of the passenger car fleet. B\

comparison, comments provided by GM, Ford, and Chrysler to the public

docket estimated deployment rates equivalent to 1 percent, .7 of one

percent, and .8 of one percent respectively. Similar comments by insurance

companies indicated probable deployment rates of .9 of one percent for

Allstate and 1.8 percent for the Automobile Club of Michigan.^

Of the air bags that will be deployed, a certain number will be replaced

but others will not because the vehicle will have been totalled or because

the owner chooses not to replace the air bag. To estimate the number of

vehicles that are totalled, we must examine the relationship between book

value, crash losses, and vehicle exposure.

37 Docket 74-14 Notice 32.
VII-25

Table V11 — 5 shows the development of the average book value of vehicles for

the last 10 model years based on average depreciation rates and average

retail sales prices. In Table VII-6, average loss data by deductible

category is shown by model year. Also shown in Table VII-6 is the

estimated value at which a vehicle would be "totalled" instead of repaired.

This estimate represents 60 percent of the average book value derived in

Table VII-5. Sixty percent was chosen based on discussions with the

insurance industry and it represents a general "rule of thumb" frequently

used in the industry to account for scrap value, overhead costs, etc.

The data in Table VII-6 are not precise estimates of average repair cost

because they do not include costs that exceed the vehicle's book value. In

addition, accidents below the deductible amount are not included. These

effects are offsetting in nature but their net effect is unknown. From

these data, it will be estimated that, based on today's experience,

vehicles over 6 years old that are involved in an accident severe enough to

deploy an air bag will be scrapped instead of repaired.

This estimate is based on the fact that the average cost to repair a 7 year

old car plus the deductible amount exceeds the value at which the vehicle

is likely to be totalled in 3 of the 4 deductible categories.

The effect of excluding costs that exceed book value of some totalled

vehicles implies higher overall costs, but under those circumstances, the

assumption of year old vehicles being totalled would still hold. The effect

of excluding accidents below the deductible amount implies lower actual

costs, but very few such accidents are expected to occur below $50 or $100.
VII-26

In the $50 category, the value falls about $60 short of the scrappage

threshold, but the effect of excluding costs that exceed book value on

totalled vehicles has probably understated the actual costs of the category

without much offsetting effect from the exclusion of low damage accidents.

TABLE VII-5

AVERAGE BOOK VALUE BASED ON DEPRECIATION RATES

AND RELATIONSHIP OF POST 1976 BOOK VALUES

TO 1976 BASE

Year

1982

1981

1980

1979

1978

1977

1976

1975

1974

1973

Age

1

2

3

4

5

6

7

8

9

10

Percent of Original

Price Remaining-^

.798

.657

.546

.446

.362

.294

.235

.182

.133

.085

Avg. Retai l Avg. Book

x Sales Price^ = Values

9910

8850

7340

6950

6470

6120

5470

4750

4390

3 930

7908

5814

4007

3100

2342

1799

1285

865

584

334

Ratio

N/1976

6.154

4.525

3.118

2.412

1.823

1.4

1.0

-

-

_

Inverse

Ratio

.162

.221

.321

.415

.549

.714

1.0

-

-

_

Ypar Age

1974

1975

1976

1977

1978

1979

1980

1981

1982

9

8

7

6

5

4

3

2

1

419

726

663

703

802

793

828

873

1000

TABLE VII-6

AVERAGE LOSS DATA BY MODEL YEAR

AND DEDUCTIBLE CATEGORY^

$100

516

721

764

848

944

988

1029

1086

1261

714

821

854

987

1086

1167

1222

1315

1557

12_5J2

760

919

953

1101

1216

1322

1300

1444

1681

Avg.

618

782

817

927

1026

1089

1129

1209

1417

Scrappage

Threshold"*"1

350

519

771

1079

1405

1860

2404

3488

47a4

38 Sales Weighted Average Derived from Depreciation Rates in "Cost of Owning

and Operating Automobiles and Vans," 1982, Federal Highway Administration.

Source: K'ADA, ref: Automotive News, 1983 Market Data Book Issue.

SOURCE: Insurance Services.

Computed as 60 percent of column 5 in Table 5.
VII-27

Estimates of air bag deployed vehicles that will be scrapped are dependent

on exposure data. It will be assumed that the portion of vehicles over 6

years old that are involved in an accident that deploys the air bag is

equal to the relative exposure of such vehicles (number of vehicles x

miles driven). These figures were first developed in the 6/79 Final

Assessment of the Bumper Standard, and are listed in column 3 of Table

VII-B.

From Table VII-8, the relative exposure of a vehicle 7 years old is .0782;

therefore 86,020 (.0782 x 1.1m) vehicles 7 years old will be involved in an

accident that will both deploy the air bag and total the vehicle. The

relative likelihood of a similar occurence in later years that will be

derived below will be applied to this number in Table VII-9.

The number of vehicles 6 years old or younger that would be totalled will

be estimated by considering the relative book values, potential replacement

costs, and travel exposure of the various model years.

These functions are derived in Table VII-5, VII-7, and VII-8. In Table

VII-9, these functions are combined and related to the base estimate for 7

year old vehicles to produce estimates of air bag deployed but scrapped

vehicles for passenger cars 1-6 years old. Note that the estimate is a

direct function of potential repair cost and relative exposure, but an

inverse function of book value.
VII-28

The estimates in Table VI1-9 are based on loss experience in today's

vehicle fleet. However, for vehicles with deployed air bags, the added

replacement cost of these devices may increase the portion of vehicles that

are scrapped instead of repaired. To account for these vehicles, an

estimate of the relative average repair costs for vehicles with deployed

air bags will be made based on the data in Table VII-6. Table VII-10 shows

the data in Table VII-6 altered to reflect the addition of air bag

replacement costs. In addition the scrappage threshold has been revised

upward to reflect the added book value caused by the air bag. Based on this

table, it appears that the potential added $800 cost of repairing a vehicle

with a deployed air bag will result in a 3 year shift of the threshold for

model year vehicles that would be expected to be 100 percent scrapped in a

collision that is serious enough to deploy the air bag.

TABLE VI1-7

ESTIMATES OF RELATIVE POTENTIAL

REPLACEMENT COSTS BY MODEL YEAR

Year

19B2

1981

1980

1979

1978

1977

1976

Age

1

2

3

4

5

6

7

Avg. Retai l

Price x

9910

8850

7340

6950

6470

6120

5470

CPI Multiplier 4 2

1.0

1.066

1.182

1.354

1.508

1.617

1.722

1982

Avg

= Sal

Value of

. Retai l

es Price

9910

9434

8676

9410

9756

9896

9419

Ratio

N/1976

1.052

1.002

.921

.999

1.036

1.051

1.000

CPI all items index. The CPI New Car index was considered for use but

rejected because poor sales and competitive pressure has kept new car

prices from rising as fast as aftermarket materials and repair costs. There

is also a CPI auto parts and equipment index but it did not exist prior to

1978. The PPI motor vehicle parts index was also rejected because it is

felt that its extremely small sample (prior to 1982) is not a reliable

indicator of price changes in the diverse market for vehicle replacement

parts.
VI1-29

TABLE VII-6

RATIO OF EXPOSURE BY MODEL YEAR

Year

1982

1981

1980

1979

1978

1977

1676

1975

1974

1973

Age

1

2

3

4

5

6

7

8

9

10

Relat ive

Exposure^

.1811

.1511

.1326

.1183

.1058

.0924

.0782

.0620

.0460

.0325

Ratio

N/1976

2.316

1.932

1.696

1.513

1.353

1.182

1.000

TABLE VII-9

ESTIMATED VEHICLES IN ACCIDENTS THAT DEPLOY

AIR BAGS A\D ARE SUBSEQUENTLY SCRAPPED RATHER

THA\ REPAIRED — BASED 0\ CURRENT COST/BOOK VALUE RELATIONSHIPS

>>ar

1982

1981

1980

1979

1978

1977

1976

1975

1974

1973

Agp

1

2

3

4

5

6

7

Exposure

Rat io

2.316

1.932

1.696

1.513

1.353

1 .18?

1.000

Potential

Cost

x Rat in x

1.052

1.002

.921

.999

1.036

1.051

1.000

Inverse of

Book Value

Ratio =

.162

.221

.321

.415

.549

.714

1.000

Ratio

of Scrapped

Vehicles to

1976 Rase

.395

.428

.501

.627

.770

.887

1.000

TotaJ

Vehicles w

Deploved Air

Air Bags

SrrapDPd^

33977

36816

43096

53934

66235

76300

86020

68000

51000

36000

TOTAL 551,378

The percent of tota] lifetime VMT, as a function of surviving vehicles x

average miles driven by vehicle age. These- figures were initially derived

in "Final Assessment ot the Bumper Standard," U.S. Department of

Transportation, NHTSA, 3une 6, 1979 DOT-HS-804-718.

For 1977-1982, Ratio of Scrapped Vehicles to 1976 Base x 86020 (1976 basei.

For 1973-1976, Relative Exposure from Table VI1-8 x 1.1m.
VII-30

In Table VII-11, the estimates from Table VII-9 are re-calculated based on

this new threshold year (a 4 year old vehicle instead of 7 year old

vehicle). By comparing this estimate of vehicles scrapped to the one from

Table V'II-7, it can be estimated that 304,429 additional vehicles would be

scrapped rather than replaced.

Although higher repair costs may induce insurance companies to total these

vehicles, owners may in some instances, prefer to keep their vehicles and

not replace the air bag. Such a decision would be attractive to owners

whose vehicle sustained only superficial damage and remains in good running

order since it would allow them to avoid the expense and uncertainty of

purchasing a new car. It would also be attractive to insurance companies

because their settlement loss would not reflect the added cost of air bag

replacement. On the other hand, persons who have just been saved from

death or injury by the air bag may become convinced of its value and prefer

to purchase a new vehicle rather than drive their repaired vehicle without

an air bag. Data do not exist to indicate which part of these vehicles

will actually be repaired rather than scrapped. For purposes of this

analysis it will be assumed that half of these vehicles will be repaired

without the air bag. Therefore 152,215 vehicles will be potentials

scrapped due to the added cost to air bag repairs.

From air bag deployments then, there are four basic groups of vehicles:

244,193 vehicles repaired with air bag replaced

551,378 vehicles scrapped due to accident severity

152,215 vehicles scrapped due to added replacement costs

152,214 vehicles repaired without the air bag

1,100,000 vehicles with deployed air bags
VII-31

TABLE VII-10

RELATIVE AVERAGE COST ESTIMATE

FOR VEHICLES WITH DEPLOYED AIR BAGS

Year

1974

1975

1976

1977

1978

1979

1980

1961

1962

Age

9

8

7

6

5

4

3

2

1

Avg.

Loss

618

782

817

927

1026

1089

1129

1209

1417

Avg.

Deductible

154

154

15^

154

154

154

154

154

154

Air Bag

Repl.

Cost

800

BOO

800

BOO

800

800

800

800

800

Revised

Avg.

Cost

1572

1736

1771

1881

1980

2043

2083

2163

2371

Revised

Scrappage

Threshold

376

556

816

1135

1474

1946

2508

3614

4897

TABLE VI1-11

ESTIMATED VEHICLES IN ACCIDENTS THAT DEPLOYED

AIR BAGS AND ARE SUBSEQUENTLY SCRAPPED RATHER THAN REPAIRED - -

BASED ON POST AIR BAG COST/BOOK VALUE RELATIONSHIPS

Near

1962

19 81

1980

1979

1978

1977

1976

1975

1974

1973

Age

1

2

3

4

6

7

8

9

10

Exposure

Ratio

1.531

1.277

1.121

1.00

Potential

Cost

x Ratio x

1.053

1.033

.922

1.00

Inverse of

Book Value

Ratio =

.390

.533

.773

1.00

Ratio of Scrapped

Vehicles to 1979

Base

.629

.683

.737

1.00

Total

A different loss will be incurred for vehicles in each of these

categories. For repaired vehicles, this cost will be the full replacement

cost of the air bag system. In chapter VIII the initial cost of full front

air bags was estimated to be $320. The total replacement cost of these

bags is estimated to be roughly 2.5 times this amount or $800.

Total Vehicles

w/Deployed Air

Bags Scrapped^

81852

88879

95906

130130

116380

101640

86020

68000

51000

36000

855607

For 1980-1982, Ratio of Scrapped Vehicles to 1979 Base x 130130

for 1973-1979, Relative Exposure from Table VII-8 x 1.1m.

•1979 base
VII-32

The cost of replacing these bags will be borne partly by collision

insurance and partly by physical damage liability insurance. Estimates

from major insurance companies^ indicate that the percent of property

damage loss borne by collision is roughly 60 percent, with the remaining

40°6 borne by liability coverage.

Data from the Automobile Insurance Plan Service Office (AIPSO) indicates

that 63?o of all passenger cars are covered by collision insurance. As

noted in footnote 22, roughly 3 percent of all passenger cars are covered

under commercial liability policies. It will be estimated here that all of

these vehicles are also covered by physical damage policies. Thus, 66

percent of all passenger cars are estimated to have collision insurance.

Also, from footnote 22, 93 percent of all cars have liability coverage.

The total annual cost to insurance companies to cover the replacement of

deployed air bags is therefore estimated as follows:

Loss Ratio=60?o (Collision loss)/40?o (property damage liability loss)=1.5

Total Replacement Cost = 244,1 93 replaced air bags x $800 = $195,354,400

Insured property damage liability loss=x

x/.93 + 1.5x/.66=$1 95, 354,400

x=$58,349,5B2 (total loss incurred for property damage liability;

1.5x=$87,524,373 (total loss incurred for collision insurance)

By implication, these costs would cover 72,937 vehicles under property

damage liability and 109,405 vehicles under collision insurance (x/$800).

46 Docket Numbers 74-14-32-6106 and 6126.
VII-33

The tota l annual cost to insurance companies to cover the replacement of

deployed air bags is thus $145,873,955 for 182,342 vehicles.^ 7

Individual vehicles that are scrapped due to the added replacement costs of

air bags would have a net added insurance loss of between $1 and $800,

depending on the repair cost for the rest of the vehicle and the vehicle's

book value.

Data are not available to determine the exact average increase that will

occur from this effect. For purposes of this analysis, it will be assumed

that the chances of an> given net increase are equal (i.e. , repair costs

are equall> distributed in that range). The average net increase would

tnerefore be half of the maximum loss or $400. The total annual cost to

insurance companies to cover air bag costs in these scrapped vehicles is

therefore $45,464,458.48

Generally it might be assumed that some persons would choose not to

replace a deployed air bag after an accident; however, for the insured

population this replacement would be free and it will therefore be assumed

that all insured vehicles will have the bags replaced.

Applying the same formula used above for repaired vehicles:

152,215 scrapped vehicles x $400 = $60,886,000

x/.93 + 1.5x/.66 = $60,886,000

x = $18,185,783 (P.D.L.) for 45,464 vehicles

1.5x= 27,278,675 (collision) for 68,197 vehicles

Total $45,464,458 113,661
VII-34

The remaining 551,378 vehicles will be scrapped because they were in an

accident of enough severity to "total" the car regardless of the presence

of the air bag. The added loss in these vehicles should therefore be a

function of the remaining book value of the air bag.

The effect that an air bag will have on passenger car book values is

uncertain. It could be argued that the air bag will remain unused until an

accident and will thus retain nearly its full value, increasing used car

book values by hundreds of dollars. Conversely, it is possible that

consumers will not perceive the added value of these devices in used cars.

Since there is no evidence to predict the actual valuation of air bags in

used cars, this analysis will assume that they will depreciate at the same

rate as the rest of tne vehicle.

In Table \11-12, the average depreciation rate of a vehicle in a total loss

accident is computed based on the number of vehicles estimated to be

TABLE VI1-12

AVERAGE DEPRECIATION OF SCRAPPED VEHICLES

Cumulative

Deployed and Weight by Average

Year Age Scrapped Vehicles Model Year x Depreciation^ : Avg. Depreciation

1982

1981

1980

1979

1978

1977

1976

1975

1974

1973

TOTAL

1

2

3

4

5

6

7

8

9

10

3397 7

36816

43096

53934

66235

76300

86020

68000

51000

36000

.062

.067

.078

.098

.121

.138

.156

.123

.092

.065

17C00

20.2

34.3

45.4

55.4

63.8

70.6

76.5

81.8

86.7

91.5

1.25

2.30

3.54

5.43

7.72

9.74

11.93

10.06

7.98

5.95

65.90

49 1 - Percent of original price remaining (from Table VI1I-5).
VII-35

scrapped with deployed air bags in Table VI-9. In essence, this estimate

is a function of exposure ratios, potential cost to repair, and the average

book values of vehicles by model year.

The average value of an air bag in a "totalled" vehicle is therefore

estimated to be $110 ((1-.659) x $320). The total value of all air bags in

vehicles with deployed air bags scrapped due to accident severity is

therefore $45,289,41250.

Added cost from scrapped vehicles without air bag deployment: Each year, a

certain number of vehicles will be totalled in accidents that do not result

in air bag deployment. The higher book value of these vehicles resulting

from air bags will increase insurance losses associated with their

replacement. This cost is a function of the number of vehicles that will

be considered total losses after an accident and the average depreciated

value of an air bag in these vehicles.

The number of vehicles typically lost each year in accidents will be

estimated based on insurance company experience. Estimates of totalled

vehicles obtained from major insurance companies varied considerably.

AAA of Michigan estimated that 1.5 percent of their insured vehicles were

Applying the same formula used previously for repaired vehicles;

551,378 scrapped vehicles x $110 = 60,651,580

x/.93 + 1.5x/.66 = $60,651,580

x = $18,115,765 (P.D.L.) for 164,689 vehicles

x = $27,173,647 (coll.) for 247,033 vehicles

Total $45,289,412 411,722
VII-36

"total losses" each year.51 Allstate Insurance Company's experience was

considerably different. They estimated that roughly .4 of one percent of

their insured vehicles are scrapped annually.52 state Farm's experience fell

between these two extremes. Salvage rates from State Farm imply annual

"totals" covered by insurance of .7 of one percent.53 Estimates include all

salvaged vehicles, regardless of salvage method (scrapped, auctioned,

etc.). This analysis will be based on the State Farm estimate, both

because of its moderate nature and because of State Farm's position as the

largest underwriter of automobile insurance.

The total number of insured vehicles that should be expected to be

"totalled" in the late 1990's would therefore be 945,000 (135m x .007).

From this number, we must deduct the 411,722 scrapped vehicles with

deplosed air bags 'which have already been accounted for). Thus 533,278

additional insured vehicles will be scrapped that did not have their air

bags deployed. Note that no deduction was made for vehicles scrapped

because of the added cost of air bags because these represent additional

scrappages over and above those predicted by current experience.

As previously mentioned, the average value of an air bag in a totalled

vehicle is estimated to be $110. The total insurance loss of all air bags

in vehicles normally scrapped each year that do not have deployed air bags

51 Testimony of Clifford Brown, V.P. and Secretary, the Automobile Club of

Michigan at Public Hearings on FMVSS 208, 12/7/83, Washington D.C.

52 Docket No. 74-14-32-6106.

53 In 1982 State Farm salvaged 136,100 cars and light trucks and held 14.7

percent of the market. This implies a national total of 925,8^0 salvaged

vehicles at a time when there was 137." in such vehicles in use or .007 of

the vehicle population.
VII-37

is therefore $56,660,580 (533,278 x $110). Sixty percent of this loss or

$35,196,348 would accrue to collision insurance and 40 percent or

$23,464,232 would accrue to property damage liabilit y insurance. These

costs would cover damages to 319,967 vehicles (collision insurance) and

213,311 vehicles (P.D.L.), respectively.

The total expected loss from aar bags that wil l be borne by collision and

property damage liabilit y insurance policies i s summarized in Table VI1—13.

TABLE VII-13

SUMMARY OF COLLISION AND PROPERTY DAMAGE

LIABILITY LOSSES - AIR BAG DEPLOYMENTS IK 1998

Repaired

Scrapped-A/B

ScrappedSeveritv

Scrapped-

- — — — L.UL

$

87,524,

27,278,

27,173,

35,196,

L i. SI

373

675

647

340

UA- - —

VEH

109,

68,

247,

319,

.

405

197

033

967

58,

18,

18,

23,

rvur L

$

349,

185,

115,

464,

n i i

582

783

765

23 2

VEH.

72,937

45,464

164,689

213,311

$

145,873,955

45,464,458

45,289,412

58,660,580

VEH.

182.

113.

411,

533.

342

661

722

27&

\o Deployment

Total 177,173,043 744,602 118,115,362 496,401 295,288,405 1,241,003

b, Corprehensive Insurance

Comprehensive insurance policies wil l have to absorb additional costs for

the value air bags add to vehicles that are stolen. Data from the Federal

Bureau of Investigation indicates that roughly .7 percent of al l passenger

cars were stolen in 1982. Data were not available to indicate the number

of vehicles that were recovered, however, the value of recovered vehicles

was roughly 54 percent of the value of those vehicles that were stolen.

Data from the insurance industry however indicates that roughly two-thirds
VII-38

of all thefts are recovered.^ From these data, it is estimated that, on a

nationwide basis, roughly two-thirds of all stolen vehicles are recovered,

leaving .2 percent of all passenger cars as total thefts. Applying this

percentage to total passenger cars in 1998, the estimated number of

passengers car total thefts will be 270,000 (135m x .002).

Data from AIP50 indicates that 73 percent of all passenger cars are covered

by comprehensive policies. As noted in footnote 23, an additional 3

percent may be covered by commercial policies. Total comprehensive

coverage is therefore estimated to be 76 percent. The total number of

insured vehicles that would become total thefts would therefore be 205,200

(270,000 x .76\ 5 5

The cost to insurance companies for these stolen vehicles would be

increased by the average depreciated value of air bags in the vehicles. To

determine this value we must consider the relative likelihood of vehicles

of different ages being stolen. Table VII-14 shows the estimated numbers

of vehicles of a specific model year still surviving in 1982. In Table

VII-15, these estimates are combined with data from the National Automobile

Theft Board and the FBI to estimate the chance of theft by vehicle age. :

These data show that just over one percent of available vehicles are stolen

for each model year. The large deviation from this trend in 1982 is

Individual estimates of total thefts vary considerably. Both State Fariv

and Allstate provided data indicating that about .2 percent of their

insured vehicles were total thefts. AAA of Michigan however found 1.8

percent of their covered vehicles to be total thefts. A recovery rate of

two-thirds produces a national estimate that is consistent with the State

Farm and Allstate estimates.

Note that this estimate may be somewhat conservative since those vehicles

that are more likely to be stolen are probably more likely to be co\ered b\

comprehensive insurance.
VII-39

unexplained, but may be the result of reporting or registration lags.

Although logic might argue that newer cars are more likely to be stolen,

actual experience appears to show no such ^6

TABLE VII-14

ESTIMATE OF SURVIVING VEHICLES BY

MODEL YEAR IN 1982

Year

1974

2975

1976

1977

1978

1979

1980

1981

1982

>ear

1974

1975

1976

1977

1978

1979

1980

1981

1982

Domestic

Sales

7448920

7050120

8606573

91044 54

9307998

8315622

65782 75

6206296

5756660

O

•c

Aae

9

8

7

6

5

4

3

2

1

Imports

Sales

1,403,

1,577,

1,493,

2,071,

2,000,

2,327,

2,396,

2,326,

2,220,

RATIO

035

000

000

160

500

932

934

376

911

OF

of Total

Thefts

6.52

7.5

10.86

12.72

14.0

15.44

12.68

12.21

7.59

Total ^

8,851,956

8,627,120

10,099,573

11,175,554

11,308,498

10,643,554

8,975,209

8,532,672

7,977,571

TABLE VII-15

THEFTS TO SURVIVING

BY MODEL YEAR

// Thefts by

Model Year

51126

58810

58157

99742

109779

121463

99428

95743

59516

Survival

Pro.58

.519

.661

.784

.873

.929

.962

.982

.993

.998

FLEET

#

Surviving

Vehicles

4594165

5702526

7918065

9756259

10505595

10239099

8813655

8472943

7961616

//Vehicles

in 1982

4,594,165

5,702,526

7,918,065

9,756,259

10,505,595

10,239,099

8,813,655

8,472,943

7,961,616

Thefts/'

Surviving

Vehicles

.011

.010

.011

.010

.010

.012

.011

.011

.007

58

Note, however, that due to higher exposure, more new cars, in absolute

terms, are generally likely to be stolen. It may be that the higher

availability of newer cars is roughly proportional to the higher theft

demand for these vehicles, leaving the ratio of stolen cars/available cars

basically unchanged from model year to model year.

Source: Automotive News, 1983 Market Data Book Issues.

Source: Final Assessment of the Bumper Standard, NHTSA, 6/1/79,

DOT-HS-804-718.
VII-40

From Table VII-15 it is apparent that, although a vehicle's age does not

significantly influence the rate of theft, vehicle population does. To

determine the average depreciated value of air bags in stolen vehicles

therefore, it is appropriate to weight annual depreciation rates by model

year population size.

In Table VII-16, cumulative average depreciation rates are combined with

survival probability ratios to estimate the average depreciation in a

stolen vehicle. With a $320 initial purchase price for air bags, the

average remaining value of these devices in a stolen vehicle is $135

((1-. 578 )x$320 ). The total loss associated with air bags in these stolen

vehicles is therefore $27,702,000 (205,200 x $135).

In addition to theft losses, higher book values would also increase losses

associated with damage caused by fire, flood, etc. Allstate Insurance

Company provided data which indicate that .2 percent (in addition to the .2

percent stolen) of vehicles covered by comprehensive policies are lost to

fire and flood. Assuming the value of the air bags in these vehicles is

also a function of survival probability, an additional $27,702,000 in

losses would be incurred. The total loss paid for b\ comprehensive

insurance would therefore be $55,404,000.

An additional loss may be incurred on comprehensive policies due to

inadvertent deployments. These deployments may occur when sensors are

inadvertently set off while the vehicle is being repaired or as a result of

incorrect installation. In Chapter V, it is estimated that .00001 of all

passenger cars might experience an inadvertent deployment each year (see
VI1-41

Chapter V for a complete discussion of inadvertent deployment). Total

inadvertent deployments would therefore be 1,350 in the late 1990 's

(.00031x135,000,000). The maximum cost to repair these air bags would be

just over one million dollars (1,350x$800=$1,080,000 ). Since many and

probably most of these deployments will occur because of negligence by

garage personnel,^ it is likely that restoration of the air bag will, in

most cases, be paid for by the establishment that is responsible. This

would not impact automobile insurance companies, and would have only an

insignificant effect on liability insurers for the repair establishment.

The small number of inadvertent deployments which are not the

responsibility of a repair establishment would likewise have an

insignificant effect on comprehensive premiums.

TABLE VI1-16

AVERAGE DEPRECIATION OF

STOLEN VEHICLES

Relative Cumulative

Weight Average Average

By Aae Depreciation^ Depreciation

.123 20.2 2.49

.123 34.3 4.22

.121 45.4 5.49

.119 55.4 6.59

.116 68.3 7.40

.108 70.6 7.63

.097 76.5 7.42

.082 81.8 6.71

.064 86.7 5.55

.047 91.5 4.30

1. 00 57. 8

Aqe

1

2

3

4

5

6

7

8

9

10

Probability

of Survival ^

.998

.993

.982

.962

.929

.873

.784

.661

.519

.384

-^ Roughly 70 percent of inadvertent deployments that have occurred with

currently equipped vehicles were service related.

60 Fro* Table VII-14.

61 From Table VII-12.
VII-42

With roughly 102,600,000 vehicles carrying comprehensive coverage (135m x

.76), 89,100,000 vehicles carrying collision insurance (135m x .66) and

125,550,000 (135 m x .93) vehicles carrying property damage liability

insurance, the additional incurred losses from air bags may cause annual

comprehensive premium increases of roughly $.54 per insured vehicles

(55,404,000/102,600,000), collision premium increases of $1.99 per insured

vehicle ($177,173,043/89,100,000) and property damage liability premium

increases of $.94 per insured vehicle (118,115,362/125,550,000). On a per

vehicle basis (including uninsured vehicles) these losses average $.41 for

comprehensive insurance, $1.31 for collision insurance, and $.88 for

property damage liability insurance. These costs are summarized in Table

VII-17.

TABLE VII-17

SUMMARY OF POTENTIAL AUTOMOBILE PHYSICAL DAMAGE

PREMIUM COSTS RESULTING FROM AIR BAGS

(DOLLARS)

Collision

Property

Damage

L iabilit y

Comprehensive

Per

Insured

Vehicle

Annual

Cost

1.99

.94

.54

Per

Vehicle

Lifetime

Cost

13.45

6.35

3.65

Per

Vehicle

Annual

Cost

1.31

.88

.41

Per

Vehicle

Lifetime

Cost

8.85

5.95

2.77

Total

Annual

Cost 1998

Fleet (m)

177.2m

118.1m

55.4m

Total

Annual

Cost 1990 Fleet

Equivalent 62

(m)

157.5m

105.0m

42.2^1

TOTAL63

2.60 17.57 350.7m 311.7m

6 2 The 1990 fleet equivalent estimate is computed by scaling down the 1998

total annual cost by the ratio of the 1990 fleet size to the 1998 fleet

size (120/135).

6 3 No total is provided for per insured vehicle figures because each type of

insurance covers a different number of vehicles. The addition of these

numbers would therefore not be meaningful.
VII-43

B. Health and Other Insurance

In 1979, health insurance premiums in the U.S. totaled $66 billion, and

benefit payments were $57 billion. About 85 percent of the population was

covered by one or more forms of health insurance. About 68 percent of all

car owners had some form of major medical insurance.64

Direct statistics on the amount paid by the health insurance industry to

automobile crash victims are not available. However, a recent survey by

the All-Industry Research Advisory Committee (AIRAC) provides some

indication of the magnitude of health and other insurance benefits paid to

people who have been in motor vehicle crashes.65 AIRAC found that for the

1,107 persons whose claims had been closed with payment from some source,

automobile insurance provides 67.5?o of the payments, Group Health about

22.3cc, government 5.6%, and workers' compensation 3.5?o of the total

payments. Using these percentages, a rough estimate can be made that

insurance payments to these beneficiaries from all other sources (exclusive

of auto insurance) amount to about one half (47 percent) of the auto

insurance payments.66 Assuming that this ratio can be applied to automobile

insurance savings as well (see Table VI—1 ), the potential reduction in

64 Health Insurance Institute, 1980-81, Source Book of Health Insurance

Data, p. 6.

65 All-Industry Research Advisory Committees (AIRAC ), Automobile Injuries and

Their Compensation in the U.S., Volume 1, p. 126.

66 (22.3 + 5.6 + 3.5)/67.5 = 46.5
VII-44

health, government, and workers compensation under the various automatic

restraint alternatives would be between $85 million and $834 million

annually.67

Based on current projections, in 1998, the U.S. population should be

roughly 265 million persons. Assuming that 85 percent of them are covered

b\ some form of health insurance (as is the case today), these reductions

represent an annual savings of between $0.40 and $3.70 per insured

individual .68

Table V11—18 lists the range of total and annual savings, as well as the

discounted value of these savings, for air bags and the range of possible

belt usage rates. As with automobile insurance, these numbers were

computed based on mid-points of the range of effectiveness rates for

illustrative purposes. In Table VII-19, estimates are provided for the

range of effectiveness values in order to provide bounds for possible

health insurance savings.

67 Prom Table VII-2, the lowest savings estimate is $ 180 M x .47 = $ 85 M

the highest savings estimate is $1774 M x .47 = $834 M

6 8 265 M x .85 = 225 M insured persons

85 M/225 M = .38

834 M/225 M = 3.71
VII-45

Automat

Usaqe

Air Baa

1C

Rat

20

30

40

50

60

70

S I

Automobile

TABLE VII-18

HEALTH INSURANCE

SAVINGS69

Ins. Health Ins.

Belts: Total Annual Total Annual

es Savings

180

471

748

1026

1303

1580

Effectiveness

Savings7'-'

85

221

352

482

612

743

Health Ins.

Per \

Annus]

<

i .

2.

3.

4.

5.

/ehicle

1 Savings''

,63

,64

,61

57

,53

,50

Health Ins.

Per Vehicle

I i fpt imf

4.

11.

17.

24.

30.

37.

=> Savinn^72

,26

06

.62

13

63

20

33 1774 834 6.18 41.75

°" \ote that the estimates in Table VII-18 assume a lost adjustment expense

ratio for health insurance that is similar to that for automobile

insurance. NIHTSA has found evidence that overall administrative costs are

higher for automobile insurance than for health insurance. Assuming that

loss adjustment costs are less for health insurance, the above estimates

would overstate the savings resulting from health insurance. However,

since the loss adjustment cost savings represents only 14 percent of total

savings, any potential error that might result form this assumption would

not significantly affect the overall estimate of insurance savings.

70 Total Annual Automobile Insurance Savings x. 47.

71 Total Annual Health Insurance Savings/135 M Vehicles.

72 Discounted over a 10 Year Lifetime at 10!o discount Rate.
VII-46

Air Bags:

Low

Mid

Hign

Automa

Low

Mid

High

AutOT.a

Low

Mid

Hi en

Eff.

Eff.

•Eff

t i c

Eff.

Eff.

Eff

t i c

Eff.

Eff.

Uf

SUMMARY OF

FOR LOW,

POTENTIAL

MID-POINT

TABLE VII-19

HEALTH INSURANCE PREMIUM SAVINGS

, AND HIGH EFFECTIVENESS RATES

(1982$ )

Per Vehicle

Annual

Sav ings

4

6

8

Belts - 20?c

0

0

1

Belts - 70?o

5

6

Usage:

Usage:

Lifetime

Savings

29

42

54

2

4

7

31

37

44

Total Annual

Savings 1998

Fleet

(Millions)

586

B34

1,082

47

85

128

606

743

886

Total Annual

Savings 1990

Fleet

Equivalent

(Millions ]

521

741

962

42

76

114

539

660

788
VI1-47

The A1RAC survey found that for the cases in which more serious injuries

occurred — those with costs exceeding $25,000 — automobile insurance paid

only about. 23 percent of the total benefits while group health and

government sources paid about 77 percent. The number of cases in the

survey with payments of this magnitude was so small, however, that these

figures are only suggestive of the experience with major crash injuries.

C. Life Insurance

The reduction in fatalities associated with automatic restraints would

reduce life insurance payouts by eliminating some payments for term

insurance policies and delaying payments connected with whole life

policies. Term insurance provides coverage for a limited period of time,

usually no more than several years. Policies of this type expire at the

end of the contract period and when they are renewed, their premium cost

reflects the added age and corresponding increase in chance of death of the

polic>hclder. Term insurance premiums thus frequently become prohibitivel)

expensive for older individuals. Because term insurance benefits are not

paid unless the policyholder dies during the contract period, the full face

value of these policies would be saved by the insurance company if an

automatic restraint device prevented the premature death of a policyholder.

Roughly 65 percent of the value of all life insurance policies comes from

term policies.

Whole life policies, which involve the payment of fixed premiums over a

person's lifetime, account for most of the remaining 35 percent of life

insurance policies. Generally, the face value of these policies will be
VII-48

paid to the insured's beneficiary on the death of the policyholder

regardless of when that death occurs. Fatalities prevented by automatic

restraints will therefore not prevent the payment of the face value of

these policies by the insurance company. It will, however, delay these

payments and allow insurance companies to make money by investment and by

continuing to collect premiums until the policyholder's death at a later

date.

The following analysis is based on data from the 1983 Life Insurance Fact

Book published by the American Council of Life Insurance:

In 1982, life insurance policies in force had a face value of $4,476,659

million. The population of the U.S. in 1982 was 232.1 m. Therefore, the

average life insurance coverage per person was $19,288 (4,476,659m/232.Im/.

Of this, 65 percent or $12,537 represents the average term insurance

coverage per person, and 35 percent or $6,751 represents the average for

other types of life insurance (including whole life endowment and

retirement income).

The savings that would accrue to life insurance companies from term

insurance would therefore be computed as the product of the average term

value per person and the number of annual fatalities prevented. Table

VII-20 summarizes these savings for the range of usage rates for automatic

belts and for air bags. Mid-points of the range of possible effectiveness

estimates are used for illustrative purposes.^

Note that because of the relatively small values derived, no adjustment

has been made for deaths that occur from other causes during the term of

the policy. Such an adjustment would have a minute effect on an already

small value.
VII-49

TABLE VII-20

TERM LIFE INSURANCE SAVINGS

Automatic Belts:

Usage Rate

20

30

40

50

60

70

Air Bags:

Effectiveness

Lives

Saved

1990

750

1,850

2,950

4,060

5,160

6,270

Total

Savings'^

$ 9,402,750

23,193,450

36,984,150

50,900,220

64,690,920

78,606,990

Per Vehicle

Annual Savings'^1

.08

.19

.31

.42

.54

.66

Per Vehicle

Lifetime

Savings

.53

1.31

2.08

2.87

3.64

4.43

33 6,670 83,621,790 .69 4.71

In addition to the above savings for term insurance, insurance companies

will benefit to some extent through the delay of payments connected with

whole life policies. For these policies, the net cost to insurance

companies of a premature death is the lost premiums and interest revenue

that would have been derived had the policyholder lived a normal life span.

Over a very long period of time, it is conceivable that the additional

revenue from these sources would be passed on to consumers through lower

premiums. The average age of a motor vehicle fatality is roughly 30 years,

and most whole life policies mature at 65-69 years of age. This implies

35-40 years of lost premiums and interest. However, many policyholders

choose to terminate their policies for cash value prior to maturity. In

1982, 10 percent of all ordinary life insurance policies were voluntarily

terminated by the policyholder. If this same rate continues, over half of

7A Lives saved x $12,537.

7^ Total savings.'120 m vehicles. Fatality estimates are based on 1990

projection. The total passenqer car fleet size is estimated to be 120

million in 1990.
VII-50

the policies in force in any given year will be voluntarily terminated

within 10 years. It thus appears unlikely that an average motor vehicle

fatality will cut premium and revenue collection by more than 10-15 years.

A rough estimate of added revenue from whole life policies will be made by

computing the value of the additional investment earnings and premiums

gained by the extension of the policyholder's life.

Life insurance premiums totalled 49,464 million in 1982 or 1.1 percent of

the face value of associated policies (49,464/4,476,659). Annual premium

collections on whole life policies would therefore average $74

(.011x6,751 ). In 1982, of the total income received by life insurance

companies, 71.5 percent was from premiums and 28.5 percent was from

investment earnings and other income. The $74 additional premium revenue

collected each year would therefore eventually represent $104 in additional

income to the insurance company (74/.715). The current tax rate for life

insurance companies is 2.3 percent of revenue, leaving a net annual revenue

gain of $102 per fatality prevented. As discussed above, this income may

continue for an average of roughly 15 years. Therefore, once a steady

state is reached, the annual income gains per fatality prevented will be

$1,530 ($102x15). Table VII —21 summarizes the savings for the range of

usage rates for automatic belts and for air bags. Once again, mid-point

effectiveness values are used for illustrative purposes.
VI1-51

Automatic Belts:

Usage Rate

20

30

40

50

60

70

Air Bags:

Effectiveness

33

TABLE VII-21

WHOLE LIFE INSURANCE SAVINGS

Lives

Saved

1990

750

1,850

2,950

4,060

5,160

6,270

6,670

Total

Savings'^

1,147,500

2,830,500

4,513,500

6,211,800

7,894,800

9,593,100

10,205,100

Per Vehicle

Annual

Savings

.01

.02

.04

.05

.07

.08

.09

Per Vehicle

Lifetime

Savings

.06

.16

.25

.35

.44

.54

.57

Table VII-22 summarizes total savings for both term and whole lif e

insurance policies.

TABLE VII-22

POTENTIAL LIFE INSURANCE SAVINGS

Automatic Belts:

Usage Rate

20

30

40

50

60

70

Air Bags:

Effectiveness

Per

Vehicle

Annual

.08

.19

.31

.42

.54

.66

II_C j a v xi iy o —

Per

Vehicle

Lifetime

.53

1.31

2.08

2.87

3.64

4.43

Per

Vehicle

Annual

.01

.02

.04

.05

.07

.08

Per

Vehicle

Lifetime

.06

.16

.25

.35

.44

.54

Per

Vehicle

Annual

.09

.21

.35

.47

.61

.74

Per

\ehicle

Lifetime

.59

1.47

2.33

3.22

4.06

4.97

33 .69 4.71 .09 .57 .78 5.25

7 6 Lives saved x $1,530.
VII-52

As discussed above, mid-point effectiveness estimates were used to derive

the numbers in the preceeding tables. The full range of potential life

insurance savings is shown in Table VII-23 below.

TABLE VII-23

SUMMARY OF POTENTIAL LIFE INSURANCE SAVINGS

FOR LOW, MID-POINT, AND HIGH EFFECTIVENESS RATES

(1982$)

Total

Annual Savings

Per Vehicle 1990 Fleet

Annual Lifetime Equivalent

Savings Savings (Millions)

Air Bags:

Low Eff. 0 3 62

Mid Eff. 1 5 93

High Eff. 1 7 136

Automatic Belts - 20% Usage:

Low Eff. 0 0 7

Mid Eff. 0 1 10

. High Eff. 0 1 14

Automatic Belts - 70% Usage:

Low Eff. 1 4 71

Mid Eff. 1 4 88

High Eff. 1 6 106

Table VII-24 summarizes the potential overall effects on insurance premiums

that may result from automatic restraint requirements. ^

There are obvious differences between these numbers and the estimates used

in the 10/83 Preliminary Regulatory Impact Analysis. Reasons for these

differences include: use of different effectiveness and usage estimates;

the recognition of possible change in loss adjustment costs, rather than

just incurred losses; the reduction of the overall liability premium

applicable to changes in safety; the recognition of additional types of

physical damage losses; the use of more refined or current data; the

inclusion of commercial as well as private passenger premiums in loss

considerations.
VII-53

TABLE VII-24

SUMMARY OF POTENTIAL EFFECTS

ON INSURANCE PREMIUMS FROM

AUTOMATIC RESTRAINT REQUIREMENTS

Per Vehicle

Annual

Savings ($ )

Per Vehicle

Lifetime

Savings ($ )

Total

Annual

Savings (M )

1990 Fleet

Equivalent

Air Baas'B

Automobile Insurance

Savings-Safety

Loss-Deployment

Health Insurance

Life Insurance

9-17

(3)

4-8

0-1

62-115

(18)

29-54

3-7

1108-2046

(312)

521-962

62-136

Total 10-23

Automatic Belts79

(For 20 Percent Assumed Usage)

Automobile Insurance 1-2

Health Insurance 0-1

Life Insurance 0

Total 1-3

Automatic Belts

(For 70 Percent Assumed Usage)

Automobile Insurance 10-14

Health Insurance 5-7

Life Insurance 1

76-158

Total 16-22

5-14

2-7

0-1

7-22

65-94

31^4

4-6

100-144

1379-2832

89-243

42-114

7-14

138-371

1146-1676

539-788

71-106

1756-2570

full frontal air bags.

The values shown for manual automatic belts must be considered as upper

limits since they do not account for the apparent lower usage of safety

belts by those involved in accidents as compared to the general population.
VII1-1

VIII. COST AND LEADTIME ANALYSIS

Consumer prices and other life cycle costs were estimated for a variety of

front seat occupant restraint systems, including the present manual belt

system, different types of automatic belt systems, and air bags. NHTSA

estimates are summarized in Table VII1-1 in $1982. The costs of manual

belts are based on teardown studies and comments to the docket and are

believed to be typical of high production belt costs. The automatic belt

costs were developed from agency teardown studies and comments to the

docket. The air bag costs are based on teardown data on two systems and

docket comments.

Non-motorized automatic belts are estimated to cost consumers about $40 per

car more than manual belts. At full implementation, air bags are estimated

to cost consumers about $320 more than manual belts for full front seat

protection. Lifetime additional fuel costs for these restraint systems are

estimated to add $11 for non-motorized automatic belts, and $44 for full

front air bags.

The full implementation air bag cost estimate is based on 1,000,000 units

per year production level, which is believed to be representative of full

production system costs. At 300,000 units per year air bag costs are

estimated to be $340 more than manual belts and at the one hundred thousand

unit annual volume level, it is estimated full front air bags would cost
VIII-2

consumers approximately $600 more than manual belts. At production levels

of 10,000 units per year, full front air bags are expected to be about

$1,500 more than manual belts . All of the air bag cost estimates are

believed appropriate for compact and larger cars. Cars smaller than

compact size may require some additional features such as staged inflation,

which would tend to increase the consumer cost. The agency does not have

current estimates of the cost increases for staged inflation. The agency

has estimated the cost of an all-mechanical air bag to be approximately

$250 for three front occupants with the system in full production. At

present the all mechanical air bag is not in production.

TABLE VIII-1

PER VEHICLE COST IMPACTS

NHTSA ESTIMATES

Manual Belt

System

Automatic Belt

System (2 pt

or 3 pt nonpower high

volume)

Air Bag -

Driver Only

(High volume)

Air Bag -

Full Front

(High volume)

Incremental

Cost

Base

$40

$220

$320

Lifetime

Energy

Costs

$11

$12

$44

Total

Cost

Increase

$51

$232

$364

Required

Leadtime

24-36 Mi

36 Mi

36-48 Mi
VIII-3

^* System Descriptions

1. Air Bag System

a. Overview

The principal components of early air bag designs included:

crash sensors

- a bottled gas inflator, release valve, and distribution manifold for

each air bag

- an air bag, decorative cover; and

a system readiness monitor.

Various crash sensor designs were tested by potential air bag suppliers,

automobile manufacturers, and by NHTSA contractors. The designs tested

included predictive sensors (accoustical, optical, radar, radar impact

switch, and proximity) and crash actuated sensors (mechanically extended

probes and electro-mechanical inertial systems). The electro-mechanical

inertial system emerged predominant by the early 1970's because of its

reliability and relative low cost. Various mounting locations were tested

such as the bumper, radiator support brackets, firewall and transmission

tunnel. Because different vehicle models exhibit different crash energy

management characteristics, no one combination of sensor number and

location emerged as a dominant design.
VIII-4

Bottled gas inflators had a number of drawbacks, primarily their uncertain

shelf-life and the heavy weight of the pressure vessel. Pyrotechnic

infl. tors utilizing solid propellant to generate gas at a controlled rate

for air bag inflation were developed to overcome these drawbacks. A

pyrotechnic driver air bag inflator was successfully developed by 1973 and,

today, all air bag systems utilize pyrotechnic inflators for both driver

and passenger positions. (See Chapter III for a discussion of sodium

azide, the active gas generator in most inflators.)

Diagnostic modules and system readiness indicators warn users of

malfunctions, and aid servicing technicians in fault diagnosis. Electronic

capacitors provide a power source for bag deployment in the event that

battery power is lost early in the crash.

By 1973, air bag systems were considered reliable enough to be offered on

certain General Motors cars. The GM system represented a compromise

between old and new air bag technology. The crash sensing system combined

a bumper impulse detector (an early idea) with a passenger compartment

sensor. The passenger compartment sensor consisted of a diagnostic unit

and a backup sensor for the bumper detector. In addition, the electronics

module was designed to distinguish between high speed and low speed

crashes.

The driver air bag module consisted of a steering wheel hub mounted

pyrotechnic inflator, bag, and decorative cover. Knee restraint padding

was provided below the instrument cluster to prevent' driver "submarining."

The passenger module consisted of two air bags actuated by a two-stage
VIII-5

hybrid inflator. For low speed deployment, bottled argon gas was released

assisted by one pyrotechnic gas generator. For high speed deployment, the

argon gas was r leased at a faster rate, assisted by a second pyrotechnic

gas generator.

A readiness indicator light, to warn of system malfunction was activated

with engine ignition and remained lit while the diagnostic system performed

a readiness check, after which the light went off automatically if the

system was operable.

About 11,000 GM air bag equipped full-size cars were sold before the

program terminated in 1976.

Since the end of production of the GM systems other manufacturers continued

to develop air bag systems. However, none entered into production until

the Mercedes system was offered as a supplement to the driver's three point

manual belt beginning with the 198A model year.

b. Mercedes Air Bag System

At present, there are no manufacturers that offer air bags for all front

seating positions. However, Daimler Benz AG offers an optional front

passenger restraint system in their Mercedes automobiles, which combines

air bag technology with existing three point belts. The underlying design

philosophy of the Mercedes system views the air bag as a supplement to the

current three-point belt system.1

1 See Docket submission 74-14-N32-5886.
VIII-6

The Mercedes Benz Supplemental Restraint System (SRS) consists of a driver

air bag and knee bolster combined with the existing driver three-point belt

system and an automatic En urgency Tensioning Retractor (ETR) for the right

front passenger three-point belt system. The system is activated in

frontal crashes of 12 mph barrier equivalent velocity (BEV) or higher by an

electronic sensor. Both the driver air bag and the Emergency Tensioning

Retractor are fired pyrotechnically.

The electronic sensor module performs three basic functions: crash

sensing, system readiness, and system safing, that is, keeping the air bag

systems from operating inadvertently. The driver air bag module consists

of a sodium azide propelled gas generator, bag, and cover. To prevent

driver "submarining" and to limit femur loads, a corrugated steel tubular

knee bolster is installed.

In Model Year 1984 a minimum of 10 percent of 190 series cars (the new

"baby" Mercedes which weighs approximately 2650 pounds with a wheelbase of

104.9 inches) and 10 percent of the large S class cars are expected to be

equipped with the SRS. Total vehicles so equipped will be about 5000. In

Model Year 1985 a minimum of 10 percent of Model 380 SL (a luxury

convertible sports touring car) will be offered with SRS; adding

approximately 1000 vehicles to the annual total. Finally, in Model Year

1986 the SRS may be available on 10 percent of the entire Mercedes product

line if justified by ordering rates.
VIII-7

c. Other Developments

Recent innovations in air bag system design have achieved a reduction in

cost and complexity and the design of systems capable of being retrofitted

to existing cars. Much of the development effort has been expended for

driver only systems since passenger systems present a much more complex

problem in terms of bag deployment times and occupant kinematics.

The concept of a modularized driver only air bag for retrofit to existing

vehicles is not new. Over the last 10 years at least three such systems

have been proposed. These systems are: The Control Laser Crash Cushion,

the Romeo Kojyo System currently being developed and manufactured under

agency contract, and the Breed System which is the subject of an

agency-sponsored technology evaluation contract as noted in Chapter III.

In the early 1970's, Control Laser Corporation of Pompano Beach, Florida,

developed a system that could be mounted on the steering wheel hub of

passenger cars. The system consisted of a self-contained sensor, inflator,

bag, and cover, which could be screwed into the steering wheel hub of any

car with a concave steering wheel. No electrical connections were

necessary since the sensor was a mechanical, gravity type actuated by

impact. Bag actuation was accomplished by a bottled nitrogen gas inflator

contained within the module. The Control Laser system was tested

successfully in actual crash tests using human volunteers.
VIII-8

After Secretary Coleman's decision to proceed with an air bag demonstration

program in 1976, Control Laser's air bag development and marketing program

ended, since the company was not a party to the agreement and aftermarket

demand appeared insufficient to proceed further.

Romeo Kojyo Co. of Tempe, Arizona, is developing a kit for a retrofit air

bag consisting of the following components:

o Steering Wheel - a four-spoke air bag steering wheel, designed for

retrofit use, is produced for R-K by Takata Kojyo Co., Ltd., of Tokyo,

Japan, and is similar to designs used by GM, Ford, Volvo, BMW, and Daimler

Benz.

o Air Bag and Module - designed specifically to interface with the

steering wheel and also produced by Takata Kojyo. The air bag material and

the air bag itself planned for the NHTSA program are production materials

and designs from Volvo and BMW programs not now commercially available.

o Gas Generator - designed and presently being used on Daimler Benz

production vehicles, the GG-4 gas generator is produced and supplied by

Bayern-Chemie GmbH of Ottobrunn, West Germany.

o Crash Sensor - designed for use on BMW production vehicles, the crash

sensor is supplied by Technar, Inc., of Arcadia, California. Technar also

supplies the diagnostic system and the complete wiring harness and

connectors.

The Breed system is currently being developed by the Breed Corporation of

Lincoln Park, New Jersey. The Breed inflator retrofit air bag system has

no electronics. It consists of a complete air bag system, including

sensors, contained entirely within a module installed in the steering wheel
VIII-9

hub. For retrofit purposes, this concept allows the installation of the

driver system in any existing vehicle by exchanging the stock steering

wheel for a steering wheel/air bag module assembly. The s ;nsor-primerinitiator gas generator assembly fits entirely inside the folded air bag

cover module and this package is mounted entirely within the steering wheel

hub.

When the system senses an acceleration crash pulse in the occupant

compartment steering column sufficient to require air bag deployment, a

ball sensing mass in the crash sensor moves a mechanical latching system to

release a firing pin which in turn initiates a pyrotechnic primer. The

sensor primer then initiates the ignitor, which in turn initiates

combustion of the primary gas generator material in the identical manner as

in the electrically intiated systems.

The various technologies involved in activating an air bag inflator by

mechanical means are established and have been used for many years in

military ordnance applications. The mechanical latching and release

mechanism for the firing pin is a direct adaptation of the technology used

in military munitions. The technique to ensure safety when installing the

retrofit air bags is also adapted from munition technology. When the

integrated air bag unit is detached from the steering column, a safing pin

is withdrawn and the unit cannot be activated regardless of how hard it is

shocked. Upon installing the air bag module on the steering column, a pin

on the column shaft enters the sensor/inflator body and arms the unit. The

inflator is a minor modification of the standard driver inflators already

in production. The bag is the same as those used in current systems.
VIII-10

A further discussion of the possible implications of the Breed system can

be found in Chapter III.

2. Automatic Belts

Safety belts, whether manual or automatic, protect occupants from

collisions with interior components of the vehicle during a crash. The

important difference between automatic belts and manual belts is that the

automatic belt system does not involve driver or passenger action for

fastening. Four designs have been advanced: "two point" and "three point",

non-motorized and motorized. In addition, there are detachable and

non-detachable variations of these designs.

Automatic detachable belts are designed with an easily accessible release

mechanism so that, in an emergency, the belts can be disconnected to allow

exit from the vehicle. To again obtain the protection from an automatic

belt, the belt must be manually reattached. An example of this type of

belt is the VW automatic seat belt, which has an emergency release

mechanism on the B-pillar. The VW design is coupled with a starter

interlock to prevent engine ignition with the belt detached.

Non-detachable automatic belts do not have an emergency release mechanism

but rather have a "continuous" belt. To provide emergency egress, the

belt system allows the reel out of additional webbing so that the belt can

be easily pushed away from the body. An example of this type system is the

Toyota Cressida motorized automatic safety belt system. Some designs have
VIII-11

been developed which include pretensioning devices that would retract a

certain length of webbing during the first few milliseconds of a crash to

compensate for any slack which might be created by the retractor and the

occupant's clothing. For example, the Mercedes system incorporates such a

device in the passenger three-point belt as part of their SRS (see page

The difference between the two-point and three-point configurations is the

way they control lower body forward motion in a crash. The two-point

configurations employ a knee bolster attached to the dash. The current VW

system employs two-point system components. The three-point designs employ

a lap belt rather than a knee bolster to control lower body motion.

Automatic three-point belts are similar in configuration to the present

three-point manual lap and shoulder belts. They are different, however, in

that they may have to be attached at a different part of the door or pillar

to allow entry and exit when they are in the non-detached position.

Motorized belts utilize a small motor to move the upper portion of the

shoulder belt along a guide rail assembly in the door. This system greatly

improves the ease with which the occupant can enter/exit the vehicle. The

design used in the Toyota Cressida includes a manual lap belt and a knee

bolster in addition to the automatic shoulder belt. The manual belt is

needed for proper use of child safety seats.

2 SAE Technical Paper Series, Number 790321 - Advanced Restraint System

Concepts, W. Reidelbach and H. Scholz, 1979.
VII1-12

B. Automatic Restraint Cost Analysis

1. Air Bag Systems

a. Docket Comments

Table VII1-2 summarizes the Docket comments submitted by manufacturers,

suppliers, and other interested parties pertaining to the incremental

consumer costs resulting from the addition of air bag systems to passenger

cars. Note that prices are shown in $1983, as submitted by the

manufacturers. Since the agency's teardown studies reflect 1982 economics

in subsequent tables the figures are converted to $1982. This allows a

greater degree of accuracy in measuring differences in cost/price

estimates.

TABLE VIII-2

MANUFACTURER/SUPPLIER ESTIMATES

AIR BAG SYSTEMS

VEHICLE PRICE INCREASES

(OVER MANUAL BELT CARS)

($1983)

Air Bags

GM

Ford

Chrysler

Mercedes

Renault

Jaguar

AOPA

Breed

Romeo Kojyo

* Manufacturers' rough estimate, no back-up data supplied.

Driver-Side

5103

500^

880

 5

900

45

150?

Full-Front

838

807

800

1,000*

1,800*

1B56

141

3 At 3 Million Units.

4 At 1 Million Units.

•* Includes Pre-Tensioned Passenger Belt Plus Driver Lap/Shoulder Belt.

6 At 1 Million Units.

7 Retrofit; Does Not Include Installation.
VIII-13

General Motors, in its December 19, 1983 docket submission estimated unit

costs for driver only and full front seat air bag systems at annual

production volumes of 250,000 and 3,000,000 units respectively. These

estimates are presented in Tables VII1-3, and VII1-4.

Ford provided cost estimates for all of its automatic restraint designs to

NHTSA on a proprietary basis. Consequently, they are not published in this

analysis with the exception of the total price shown in Table VIII-2.

The Mercedes-Benz SRS discussed previously retails for $880 per car as an

option. This price is for the entire system. Agency estimates for the air

bag portions are discussed below.

Breed Corporation submitted an estimate of $141 per car incremental price

at a volume of one million units annually for their all-mechanical air bag

designs. In addition to its docket comments, Breed supplied a cost/volume

estimate to NHTSA's Office of Contracts and Procurement in conjunction with

the company's unsolicited proposal to equip police fleets with all

mechanical driver air bag systems. Based on the docket comments and the

unsolicited proposal, NHTSA compiled estimated consumer costs for the Breed

system - driver and passenger - at four different annual volumes. These

estimates are shown in Table VIII-5. However, it should be noted that

these estimates do not appear to cover vehicle modifications and fixed

overhead items incurred by vehicle manufacturers when installed as original

equipment. When such expenses are taken into account, NHTSA believes that

the estimates shown in Table VII1—6 best represent consumer costs for

mechanical air bag systems versus those for current electronic systems.
VIII-14

1. Incremental Variable Costs

Driver Module

Passenger Module

Sensor(s)

Diagnostic Module

Other Electrical

Vehicle Changes

Other

2. Decremental Variable Costs

Elimination of

Current Belt System

TABLE VIII-3

AIR BAG SYSTEM UNIT COSTS

GM - $1983

(Line 10 Shows $1982)

CNTR +

Driver Only R-F Passenger

)osts

128

296

35

112

26 2

65

20

Driver Plus

CNTR +

R-F Passenger

128

296

35

112

28

65

20

Components °

3. Total Incremental

Variable

4. Incremental Variable

Margin

5. Incremental Fixed/

Mixed Costs Allocated

Per Unit

6. Incremental Before

Tax Profit/Unit

(4.-5.) 9

7. Net to Manufacturer

8. Add: Dealer

Discount (18%) 10

9. Incremental Retail

Price Increase

10. $1982 (.958 x 9)

Volume

2

388

147

147

0

535

117

652

625

250 K

298

82

82

0

380

84

464

445

250 K

2

686

229

229

0

915

201

1,116

1,070

250 K

° At lower volumes adding air bags results in a slight increase in belt

component costs according to GM

° No profit is assumed by GM

^ Reflects higher dealer discount applied to full size/luxury type cars
VIII-15

TABLE VIII-4

AIR BAG SYSTEM UNIT COSTS, 3 MILLION UNITS PER YEAR

GM - $1983

(Line 10 Shows $1982)

Driver Plus

CNTR + CNTR +

R-F Passenger R-F Passenger

1. Incremental Variable

Driver Module

Passenger Module

Sensor(s)

Diagnostic Module

Other Electrical

Vehicle Changes

Other

Driver Only

Costs

118

22

72

26

61

14

2. Decremental Variable Costs

Elimination of

Current Belt System

218

Components

3. Total Incremental

Variable

4. Incremental Variable

Margin

5. Incremental Fixed/

Mixed Costs Allocated

Per Unit

6. Incremental Before

Tax Profit/Unit

(4.-5.) 11

7. Net to Manufacturer

8. Add: Dealer

Discount (18S)

 n

9. Incremental Retail

Price Increase

10. $1982 (.958 x 9.)

Volume

(2)

311

107

107

0

418

21

510

489

3 MIL

(3)

217

52

52

0

269

59

328

314

3 MIL

118

218

22

72

28

61

14

(5)

528

159

159

687

151

838

803

3 MIL

11 No profit is assumed by GM

12 Reflects higher dealer discount applied to full size/luxury type cars
VIII-16

TABLE VIII-5

BREED SYSTEM UNIT COSTS

(Breed Co. Estimates)

($1982)

Driver Only

Sensor

Inflator

Bag/Cover

Tot MFR

Mfr Profit (15S)

Dealer Cost

Dealer Profit

(30%)

Installation

Consumer Cost

Driver and Passenger

Sensor (3)

Inflator (3)

Bag/Cover (3)

Tot MFR

Mfr Profit

(15%)

Dealer Cost

Dealer Profit

(30%)

Installation

Consumer Cost

100K

6.00

25.00

10.00

41.00

6.15

47.15

14.15

5.00

66.30

18.00

75.00

30.00

123.00

18.45

141.45

42.45

15.00

198.90

At Volumes Of

3P0K

5.50

20.00

9.00

34.50

5.18

39.68

11.90

5.00

56.58

16.50

60.00

27.00

103.50

15.53

119.03

35.71

15.00

169.74

1000K

5.00

15.00

8.00

28.00

4.20

32.20

9.66

5.00

46.86

15.00

45.00

24.00

84.00

12.60

96.60

28.98

15.00

140.58

2500K

4.75

14.00

7.00

25.75

3.86

29.61

8.88

5.00

43.49

14.25

42.00

21.00

77.25

11.59

88.84

26.65

15.00

130.49
VIII-17

TABLE VIII-6

NHT5A ESTIMATES

MECHANICAL VS. ELECTRONIC AIR BAG SYSTEM COSTS

( AT 1

Mechanical System

Sensor(s)

Driver Module

Passenger Module

Vehicle Modifications

Fixed/Other/Profit

Dealer Markup

Consumer Cost

Electronic System (Mercedes)

Sensor(s)

Driver Module

Passenger Module

Vehicle Modifications

Fixed/Other/Profit

Dealer Markup

Consumer Cost

Electronic System (Ford)

Sensor(s)

Driver Module

Passenger Module

Vehicle Modifications

Fixed/Other/Profit

Dealer Markup

Consumer Cost

MILLION UNITS

Driver^

$ 6

41

16

21

11

$9T

$ 85

40

20

49

26

$220*

$ 63

39

20

40

22

ff84"

ANNUALLY)

Driver

i-PasssngRr^

$ 17

42

58

20

44

25

5206

$85

40

55

25

68

37

fTTTT

Plus

? _PaRRRngp r

$ 17

41

89

20

55

30

$ 63

39

85

25

70

38

I37U

'* For driver only air bags, mechanical systems will cost approximately 6O5»

less than electronic systems.

14 For driver/1-passenger air bags, mechanical systems will cost approximately

35% less than electronic systems.

1 For driver/2-passenger air bags, mechanical systems will cost

approximately 205o less than electronic systems.
VIII-18

Romeo Kojyo, under their current contract with NHT5A, has quoted driver air

bag retrofit kits at $500 apiece in batches of 100 to 1,000. This

quotation includes the ba•• module, electronics, and knee bolster but not

the installation costs. At an annual volume of 1 million, Romeo Kojyo

estimates a unit price of $150 exclusive of installation.

In April 1981, Ralph Rockow of Talley Industries testified that, in

quantity, air bags could be produced at an incremental consumer price of

$185. This estimate assumed 2 million units a year. In his November 29,

1983 statement before the Public Hearing held by NHTSA in Los Angeles, Mr.

Rockow, now President of Dynamic Science, stated that the price increase of

$185 was still achievable as a result of the simplified designs currently

evolving if high volumes are realized.

The Automotive Occupant Protection Association (AOPA) incorporated the

Rockow estimate in its docket comments which is presented below for a full

front passenger system at 2 million units annual volume:

$ 65 - Module (air bag, inflator, sheet metal)

30 - Sensors, Diagnostic System, Wiring

10 - Slip-ring Assembly, Decorative Cover, Misc.

$105 - Total Cost for Parts

37 - Installation & Special Tooling (36%)

$142 - Total Cost per Vehicle

21 - Profit to Manufacturer (15%)

TTST - Cost to Dealer

49 - Dealer Profit for Optional Accessory (30X)

J7T2 - TOTAL PRICE TO CONSUMER FOR AIR BAG (Including all markups)

$212 - TOTAL PRICE TO CONSUMER

27 - Incremental Cost Reduction for Changing from Today's Three-Point

Belts to Manual Lap Belt

$185 - PRICE INCREASE PER CAR TO CONSUMER
VIII-19

Although a number of manufacturers submitted cost estimates in response to

the Notice, only Ford commented specifically on NHTSA's analysis of

restraint system costs. These comrne ts are treated below in detail.

1. "Ford's review of the NHT5A cost estimate for Ford designed air bags

leads us to believe that the Costs presented in Table V-4 for the "modified

Ford driver only" and "modified Ford driver and 2 passengers" air bag

systems are not properly adjusted to 1982 economic levels. It appears that

the costs in Table V-4 were derived by adjusting upward the values in

NHTSA's cost study by a factor of 1.06, an adjustment (based on the

1981-1982 difference in the CPI All Items Index) used elsewhere in the

discussion of costs to adjust 1981 costs to 1982 economic levels."

The agency did not apply a single overall factor as Ford surmised. Rather,

NHTSA contracted with Corporate Tech Planning, Inc., and Pioneer

Engineering and Manufacturing Company to update their 1979 estimate of

automatic restraint component variable costs (DOT-HS-9-02110) to 1982

economics (P.O. DTNH-22-82-P-02075), and evaluated vehicle modifications

and overhead costs internally.

A summary of the variable cost estimates to the major subsystems is

presented in Table VIII-7. Only the primary components were considered.

Costs such as vehicle modifications to accommodate the air bag system and

the cost of shipping the system from the vendor to the automobile assembly

plant were not included.

The piece costs of the Ford air bag system as a whole decreased by about

11* during the period. Most items showed an inflationary increase of

about 10%; the cost reduction is driven by the decrease in a single

high-cost item, the microprocessor.
VIII-20

TABLE VIII-7

FORD AIR BAG SYSTEMS

PER UNIT VARIABLE COSTS (1979 VS 1982)

COMPONENT

300,000

1979 1981 A

DRIVER'S MODULE $39.29 $43.82 +$ 4.53|

(+11.5%)

PASSENGER MODULE 88.83 94.00 + 5.17

(+5.8%)

DIAGNOSTIC MODULE 65.36 28.15 - 37.21J

(-56.9%)

CRASH SENSORS (5) 37.67 40.68 + 3.01

(+8.0%)

TOTALS $231.15 206.65 -24.50

(-10.6%)

ANNUAL PRODUCTION VOLUMES

1,000,000

1979 1982 A

$35.36 $39.44 +$ 4.08

(+11.5%)

79.95 84.59 + 4.64

(+5.8%)

60.50 26.06 - 34.44

(-56.9%)

33.90 36.61 + 2.71

(+8.0%)

209.71 186.70 -23.01

(-11.0%)

2979

$33.

75.

58.

32,

199.

2,

40

71

53

02

66

500,000

1982

$37.25

80.50

25.21

34.58

177.54

A

+$ 3.85

(+11.5%)

+ 4.74

(+6.3%)

- 33.32

(-56.9%)

+ 2.56

(+8.0%)

-22.12

(-11.1%)
VIII-21

Driver's Module - The Driver's Module increase in cost of 11.585 was due to

an increase in the overhead rate (about one-third of the total) and to

increases of direct labor of purchased items. For instance, the air bag

itself increased about 11% (about 3.5% of the Driver's Module overall

increase) and a 12.9% increase in the cost of the gas generator contributed

about 5% to the overall increase.

Passengers' Module - The Passengers' Module increased in cost by about 6%.

Essentially, the same factors were at work here as on the Driver's Module,

although the Passengers' Module is larger and more expensive due to larger

components. Very nearly the same labor is required for both Modules.

Consequently, the cost increases are about the same, though the percentage

increase is small for the more costly Passengers' Module.

Diagnostic Module - The cost of the Diagnostic Module dropped 56.9% due

primarily to a reduction in the cost of the microprocessor. In 1979, a

$35.00 mil-spec device was included. In 1982, an automotive grade device

at $4.40 was included. The reduction reflects both semiconductor

industry-wide price reductions due to improved technology, and the

availability of commercial grade devices designed to automotive operating

requirements.

The $4.40 1982 microprocessor price includes $1.00 for burn-in test of each

unit. Such extensive testing is appropriate for devices employed in

critical automotive safety applications.
VIII-22

Advances in printed circuit board technology have led to price reductions,

also. Printed circuit board price decreases contributed about 1% of the

total cost reduction.

Increases in labor rates and in the prices of purchased material

contributed increases of 5.4% and 8* against the overall cost decrease.

Crash Sensors - The cost of the Crash Sensors increased by about 10?o

primarily due to increases in automotive industry wage rates.

Other Costs - Since the Corporate Tech/Pioneer study update was limited to

primary system component variable costs only, NHTSA developed its variable

cost estimates for "vehicle changes" internally. In addition, NHTSA used

standardized internally developed mark-up rates to arrive at "Dealer Cost"

and "Consumer Cost." These mark-up rates were derived from historical

analysis of corporate cost behavior as extracted from the annual report

(Form 10-K) submitted yearly by the companies to the Securities and

Exchange Commission. Table VII1-8 compares Ford's understanding of

NHTSA's methodology with NHTSA's actual cost estimate at an annual volume

of 300,000 units.
VIII-23

TABLE VIII-8

CORPORATE TECH/PIONEER/NHTSA

FORD MODIFIED AIR BAG SYSTEM COSTS

(300,000 Units, $1982)

F0RD16

1982$

NHTSA

1982$

Modified Ford Driver Only

Diagnostic Module^

Crash Sensors

Driver Module

Vehicle Changes

Subtotal Variable Costs

Manufacturer's Markup (33%)

Cost to Dealer

Dealer's Markup (13.6%)

Consumer Cost

$35

38

39

23

"TT26"

42

23

$T9T

$28

41

44

20

$T5T

44

TT77

24

$2&T

Modified Ford Driver +

2 Passengers

Diagnostic Module

Crash Sensors

Driver Module

Passenger Module

Vehicle Changes

Subtotal Variable Costs

Manufacturer's Markup (33%)

Cost to Dealer

Dealer's Markup (13.6%)

Consumer Cost

$ 35

50

52

118

37

96

53

114T

$ 28

41

44

94

25

•$737

77

TO?

41

16 As understood by Ford on pp. 15-16 of Appendix 1, Docket Comment

74-14N32-5634, dated December 19, 1983.

17 Substitution of Automotive grade microprocessor for Mil-Spec grade.

1

8 Rounded down from $351.02.
VIII-24

2. "In adjusting the Talley Industries air bag cost estimate, NHTSA added

to the updated Talley quote the cost difference between two lap belts and

two three-point belts, apparently based on the consumer cost of average

belts shown in Table V-2. The reason for this adjustment should be stated,

because it is not obvious. If the intent was to add the cost difference

between two outboard lap belts and two outboard three-point belts, the

methodology used to estimate such a difference is faulty because outboard

lap belts are much more costly than center front lap belts. Costs of lap

belts vary widely depending on the seating position for which they are

designed, and estimating the cost of driver or right front passenger lap

belt based on center front passenger lap belt costs would be inaccurate.

The front center lap belt is similar to the rear center lap belt, but front

belts must be longer to fit occupants with the seat in full-forward,

full-up position and to reach the center floor pan, which is typically

lower than the rear floor pan. Rear outboard belts are more expensive than

center belts because they include retractors. Front outboard lap belts are

still more expensive because they are longer and have more elaborate boots

to accommodate adjustment of the front seat and to facilitate one-hand

buckling. In addition, the driver's belt system has a belt warning system

switch and related wiring."

Ford is correct in that the reason for this adjustment was to add the cost

difference between two outboard lap belts and two outboard three-point

belts. Furthermore, Ford is correct in asserting that center front lap

belts are not strictly comparable to front outboard belts if for no other

reason than the absence of a retractor in the former.

To ascertain what, if any, estimating errors result from this difference,

NHTSA conducted a simplified analysis of cost changes realized by deleting

appropriate components from a 1980 Citation three-point belt system based

on agency teardown data (DQT-HS-806-295, April 1982, Final Report). The

result of this analysis is shown in Table VIII-9.
VIII-25

TABLE VIII-9

ESTIMATE OF FRONT OUTBOARD LAP BELT COSTS 1982$

Component

Total 3-point Belt

System (2)

Delete Emergency

Locking Retractor (2)

Delete Shoulder Belt

Webbing (2)

Add Automatic Lockina

Variable Cost

$25.99

(18.09)

(3.93)

13.51

Consumer Cost

$39.99

(27.40)

(5.95)

20.46

Retractor (23) (Same as

rear outboard retractor)

Total Absolute Costs $17.4B $27.10

Front Outboard Lap Belts

NOTE: Component costs taken from DDT-HS-806-295, April 1982.

The resultant cost for front outboard lap belt appears to be about $27 or

$12 less than the three-point systems. If a cost of $6-$8 is accepted as

reasonable for a center front lap belt, then the resulting total system

cost for three front lap belts should be somewhere in the neighborhood of

$33-$35. NHTSA's estimate in the PRIA was $34 for three front seat lap

belts with outboard ALR's.

Granting the validity of Ford's criticism and the somewhat simplified

analysis above, it does not appear that the method used by NHTSA in the

PRIA significantly mis-stated the total cost of front lap belts to the

point of distorting the total costs of an air bag system as derived from

the Tally estimates.
VIII-26

On page 19 in Appendix I of its December 19, 1983 Docket submission, Ford

provided additional comments on the subject of front outboard.lap belt

system costs.

"One major difference between Ford's and the agency's estimates of cost

savings for vehicle modification is in the seat belt system savings. The

NHTSA estimate includes a $16 savings estimated to result from substitution

of a lap belt system for the double-retractor (ELR-ALR) 1981 Lincoln/

Mark VI lap/shoulder belt system. This belt system has now been replaced

by a lower cost single-retractor continuous-loop system on the 1984 Lincoln

and Mark VII. The continuous-loop system was used on all Ford cars except

the Lincoln and Mark VI in 1981, and is now used on most domestic and

imported car lines. Ford's estimate, which used the 1981 Ford/Mercury

continuous loop belt system as the base, showed only a $4 variable cost

savings for changing from continuous loop lap/shoulder belts to front seat

lap belts, complete with retractors, twist boots (to permit seat adjustment

and one-hand buckling), and a driver's seat warning system switch."

Ford is correct in stating that a single retractor/continuous loop system

is less expensive than the double retractor ELR-ALR system. Hence, the

savings resulting from deletion of the continuous loop systems and

substitution of ALR lap belts will be less.

Ford cites a variable cost savings of $4 which, using agency formula

mark-ups, translates into a consumer savings of about $6. This is $6 less

than the $12 consumer savings shown in the simplified Citation analysis
VIII-27

i

described above. Differences of this magnitude may be accounted for fey the

differences between belt system designs that exist between different car

sizes and models.

3. The comments contained in the Preliminary Regulatory Impact Analysis

(p. V-15) regarding Ford's 1979 estimates of air bag costs are misleading

and NHTSA's resulting modifications of the Ford cost estimates are

inaccurate.

NHTSA's analysis states (p. V-15) that "Ford's 1981 estimate, indexed to

1982 economics, is $875 at 200,000 units, roughly 2 1/2 times NHTSA's

estimate for that production volume." Ford's Duly 1979 estimate of

"...approximately $825 a unit (at 1982 economic conditions)..."

(Mr. J. C. Eckhold's letter of July 5, 1979 to Ms. Joan Claybrook) was

already stated at 1982 economics and should not have been adjusted. (The

economics level of our estimate was also specified in our March 16, 1981

comments to Docket 74-14; Notice 20 [74-14-NPRM-N20-104, Attachment,

page 7]).

Ford is correct. The $825 unit cost for air bag systems was stated in 1982

economics and no further adjustment was necessary.

4. "NHTSA's remarks state "that some of (Ford's) component quotes from

vendors were at production levels much lower than 200,000 units.

Specifically, the diagnostic module cost was based on 6,000 to 13,000

units, and the passenger module costs were based on 13,000 units." We

believe that these statements are untrue because, after submitting the

reference cost estimates to NHTSA in July of 1979, Ford decided to limit

optional availability of the air bag system to the Lincoln and Mark VI car

lines, and during 1980 obtained vendor quotes for the same components at a

production level of 11,000 units per year. These later quotes indicated

much higher costs than those contained in our original July 1979 cost

estimates. For example, the quoted cost (at 11,000 units per year and 1982

economics) for the diagnostic module was about $100 (versus $50 in our

earlier, higher volume estimate) and the passenger air bag module quote was

about $500 (versus $179). Remarks in the NHTSA cost estimate such as

"Price to Ford based on 10,000 units, 1981 economics" (regarding the

diagnostic module) refer to these lower volume quotes which were developed

about the time of the NHTSA study, not to the earlier quotes on which our

July 1979 estimates were based.

NHTSA's remarks also claim "... that Ford may not have considered some

vehicle modification cost saving items. . ." and that "... the vehicle

modification estimate included in the Ford estimate did not take into

account cost savings which would result from the removal of some

components, such as the glove box. ..." We believe the Ford cost
VIII-28

estimate included all of the appropriate cost savings items. The cost of

the glove box, in particular, was removed from neither our estimates nor

the agency's original estimate because the glove box and glove box door

were simply relocated ( and made smaller), in our design, not removed,

resulting in a minor cost saving and retention of this essential customer

feature. Ford did not delete the cost and weight of items such as the

steering wheel ornament and the instrument panel nameplate because we

believe these items will be redesigned or relocated, rather than deleted."

Proprietary data submitted by Ford in its December 19, 1983 Docket comments

indicate that diagnostic module and passenger air bag module unit costs

] Ford is correct in stating that

NHTSA's remarks refer to the lower volume quotes as opposed to the July

1979 estimates.

With regard to vehicle modifications, NHTSA was incorrect in its assertion

that the Ford estimates did not include savings that would result from

removal of the glove box. Glove box removal is not a modification

contemplated by any of the manufacturers.

5. "The agency also criticized Ford's use of a 46 percent mark-up on

variable cost. Ford's cost estimating methodology does not apply an

average mark-up to variable cost because this method of cost estimating is

inaccurate, particularly at low volumes. We amortize fixed program

expenditures such as tooling and engineering over the number of units we

plan to produce. Applying an industry average markup of 33 percent may be

reasonable for some volumes, but it cannot be applied at all volumes. We

would point out that Ford's estimate of fixed cost allocation plus

manufacturer's profit was equivalent to 46 percent of variable cost at a

volume of^ 200,000 units, but it was only 29 percent of variable cost at

800,000 units. Coincidentally, Ford's allocation of fixed cost plus profit

at NHTSA's assumed volume of 300,000 units would be practically equivalent

to NHTSA's markup of 33 percent.

Ford's use of a 22 percent dealer profit margin (equivalent to an 18

percent dealer discount) reflects the markup traditionally applicable to

the large cars on which we planned to use our air bag system. It was not

intended to represent the dealer profit margin on the average car. NHT5A's
VIII-29

estimate of dealer profit margin may be more accurate if air bags are

mandated on all cars, but Ford's margin estimate is more accurate if air

bags are used primarily on full-size and luxury cars."

Ford is correct in asserting that the use of average markup rates is not

appropriate for all volumes, particularly low volumes. However, it is

incumbent on the agency to examine the cost and price impact of air bag

technology at both high and low volumes. Therefore, agency cost estimates

reflect air bag availability all across the product spectrum. Hence the

use of standard markup rates.

6. "Another component for which NHTSA's cost estimate varies from Ford's

is the diagnostic module, (p. V-17) Ford's estimate was based on its

design which includes special high-reliability specifications (similar to

military specifications) for the diagnostic module's microprocessor.

NHTSA's estimate used an automotive grade microprocessor in place of Ford's

high-reliability microprocessor. Although the automotive grade

microprocessor may perform satisfactorily, Ford's air bag designs still

specify premium microprocessors because we are reluctant to specify a

less-reliable component for this critical link in the system,"

NHTSA does not take issue with the judgment of Ford's designers that

reliable microprocessors are necessary. Although mil-spec grade

electronics may be used initially, the agency believes automotive grade

electronics are likely as designs mature. Therefore, NHTSA believes that

long term cost estimates based on use of automotive grade electronics are

appropriate.

b. NHTSA Analysis

The agency independently assessed the cost and weight impacts of adding air

bags to passenger cars through teardown analysis of actual air bag systems.

A complete Ford 1979 level driver and passenger air bag system and a 1981

Mercedes-Benz driver and passenger air bag system were disassembled into
VIII-30

their component parts. Using automotive engineering cost estimating

techniques, the variable DT "piece" cost of each component was estimated

exclusive of any fixed overhead expenses incurred in the production of air

bag systems. Both teardowns were updated to 1982 economics. (See final

report DOT-HS-9-02110 and Passive Restraint Cost Study Update dated

December 1982, P.O. DTNH22-82-P-O2O75.)

Tables VI11-10 and VI11—11 present the estimates for the Ford and Mercedes

air bag systems at the 1 million units per year level. These include

NHTSA's best estimate of the variable cost of required vehicle

modifications. The cost estimates also include certain component

modifications suggested by the contractors for high volume production.

The major cost/price estimating assumptions used to arrive at a consumer

retail price equivalent (RPE) are:

1. Unit Variable costs are marked up by a factor of 1.33 to arrive at

"wholesale" or "dealer" cost. This mark-up factor is based on historical

analysis of GM, Ford, Chrysler, and AMC annual income statements and

represents the volume weighted average historical ratio of variable costs

to wholesale price or dealer cost.
VIII-31

2. The "dealer discount" is assumed to be 12 percent, which corresponds to

a manufacturer mark-up of 13.75 percent from wholesale price.

The design modifications made to the Ford system have been discussed above.

The design modifications to the Mercedes system are shown in Table VII1-12.

The agency's estimate of vehicle modifications cost are shown in Table

VIII-13.
VIII-32

TABLE VIII-10

AIR BAG SYSTEM UNIT CCSTS

FORD

NHTSA ESTIMATES

$1982 CORP. TECH/PIONEER

Driver Only

1. Incremental Variable Costs

Driver Module 39

Passenger Module

Sensor(s) 37

Diagnostic Module 26

Other Electrical

Vehicle Changes 20

CNTR +

R-F Passenger

85

2. Decremental Variable

Elimination of

Current Belt System

Components ^

3. Total Incremental

Variable (1.-2.)

4. Incremental Variable

Margin (.33 x 3.) 20

5. Net to Manufacturer

(3. + 4.)

6. Add: Dealer

Discount (12$)

7. Incremental Retail

Price Increase

Volume

Costs

122

40

162

22

184

1 MIL

90

30

120

16

136

1 MIL

Driver Plus

CNTR +

R-F Passenger

39

85

37

26

25

212

70

282

38

320

1 MIL

*" Included in Vehicle Changes

20 Includes Fixed Costs Plus Other Costs Plus Profit
VIII-33

TABLE VIII-11

AIR BAG SYSTEM UNIT COSTS

MERCEDES

NHTSA ESTIMATES

MODIFIED BY CORP. TECH/PIONEER

$1982

1. Incremental Variable

Driver Module

Passenger Module

Sensor(s)

Diagnostic Module 21

Other Electrical

Vehicle Changes

2. Decremental Variable

Elimination of

Current Belt System

Components 22

Driver Only

Costs

40

i

61

24

20

Costs

R-F Passenger

55

5

Driver Plus

R-F Passenger

40

55

61

24

25

3. Total Incremental 145 60 205

Variable (1.-2.)

4. Incremental Variable

Margin (.33 x 3.) 2 3

5. Net to Manufacturer

(3. + 4.)

6. Add: Dealer

Discount (128)

7. Incremental Retail

Price Increase

Volume

49

194

26

220

1 MIL

19

79

21

90

1 MIL

68

273

37

310

1 MIL

2' Included in Sensor Cost

22 Included in Vehicle Changes

23 Includes Fixed Costs + Other Costs + Profit.
VIII-34

TABLE VIII-12

MERCEDES-BENZ REDESIGN ASSUMPTIONS FOR VOLUME PRODUCTION COST SAVINGS

SENSOR-DIAGNOSTIC MODULE

o Use of a single rather than two printed circuit boards, and layout

for automatic component insertion.

o Substitution of two integrated circuits for 65 separate discrete

components.

o Elimination of stand-offs for component mounting.

o Redesign of RFI filtering and shielding to eliminate difficult

assembly process.

o Substitution of mechanical crimping (solderless) connections at

both ends of the wiring harness.

o By using a slightly larger single printed circuit, the assembly

process of stacking two smaller boards and resulting hand soldered

interconnection are eliminated resulting in savings of two ribbon

cables, two hand soldered riveted terminal strips, a micarta

insulation layer with threaded steel posts and nylon separators.

o Use of automated assembly techniques and test.

PASSENGER MODULE (AIR BAGS)

o Elimination of neoprene coating of air bag. Domestic designs have found

coating not needed.

o Elimination of seam doublers (reinforcement strips). Destructive

tests by Uniroyal indicated that seam doublers are not needed.

DRIVER'S MODULE

o Elimination of neoprene coating.

o Elimination of seam doublers.
VIII-35

TABLE VIII-13

VEHICLE MODIFICATION AND INSTALLATION COST ESTIMATES

NHTSA ESTIMATE

(Current Design System)

Driver & 2 Pass.

Steering Column $8.31

Climate Control Reroutings

Passenger Module Mounting Structure 5.45

Wiring 16.69

Driver Knee Padding 1.54

Installation and Labor 4.56

Freight and Packaging 4.65

Warranty 10.35

Instrument Panel and Small Glove

Box Reductions [5.08]

Remove Shoulder Belts [21.13]

Total Variable Cost $25

In evaluating the estimates for the incremental consumer costs resulting

from the addition of air bags to passenger cars, NHTSA considered three

fundamental issues:

1. The differences in design assumptions between industry estimates and

agency teardown analyses,

2. The price to the customer for air bag systems currently available in

the marketplace, and

3. The annual volumes most likely realized.

With regard to different design assumptions, one major difference is in

the cost of the diagnostic module and associated electronics. As stated

elsewhere in this analysis, Ford believes that military specification grade
VIII-36

electronics are necessary in view of product liability considerations

whereas NHT5A has assumed that automotive grade electronics will suffice.

For the purpose of comparison, NHTSA is providing an estimate which assumes

that a military specification grade diagnostic module will be employed for

a Ford type system. Table VII1-14 provides NHTSA's estimate using a

military specification grade diagnostic module with a variable cost of $65,

based on teardown analysis and Ford's proprietary submission. NHTSA

believes that automotive grade electronics will be employed resulting in a

customer cost of about $60 less than that for military specification grade

electronics.
VIII-37

TABLE VIII-14

AIR BAG SYSTEM COSTS

DRIVER PLUS

1. Incremental Variable

Driver Module

Passenger Module

Sensor(s)

Diaanostic Module

NHTSA ESTIMATE OF

FORD

ORIGINAL DESIGN

$1982

CNTR +

Driver Only R-F Passenger

Costs

44

94

41

65

Driver Plus

CNTR + R-F Passenger

44

94

41

65

Other Electrical

Vehicle Changes 20 5 25

2. Decremental Variable

Elimination of

Current Belt System

Components

3. Total Incremental

Variable (1.-2.)

4. Incremental Variable

Margin (.33 x 3.)

5. Net to Manufacturer

(3. + 4.)

6. Add: Dealer

Discount

7. Incremental Retail

Price Increase,

Volume

Costs

a/

170

57 b/

227

31

258

300K

a/

99

33 b/

132

21

150

300K

a/

269

90 b/

359

49

408

300K

a/ Included in Vehicle Changes

"B"/ Includes Fixed Costs + Other Costs + Profit
VIII-3B

TQ summarize the agency's position on differing design assumptions, NHTSA

asserts that the component costs contained in its teardown analysis of the

Ford and Mercedes systems represent the best available estimates at annual

volumes of 300,000 or more over the long run. Furthermore, NHTSA has seen

no evidence that the vehicle modifications required for air bag

installation are as extensive as those provided for by GM and Ford.

The second issue is basically a question of what air bag systems are

currently available to the American motoring public. Only Mercedes-Benz

currently markets an air bag system as an option on certain of its car

lines. As described elsewhere, the Mercedes SRS consists of a driver air

bag to be used with the driver's 3-point belt and pyrotechnic Emergency

Tensioning Retractor for the front passenger's 3-point belt. The SRS

currently retails for $880 per car. The significance of this price is that

it is achieved at an annual volume of only about 5,000 cars per year in the

U.S. given Mercedes' assumption of a 10 percent installation rate on

certain 1984 model cars.

Since Mercedes provided no detailed data on the cost of the SRS versus its

price at projected volumes, the exact split between the price of the air

bag and the pyrotechnic tensioner cannot be determined. From the

August 15, 1982 Black Book New Car Invoice Guide, published by Hearst

Business Media Corporation, NHTSA determined that all Mercedes cars are

sold by the factory to the dealer at a 20 percent discount from the

suggested retail price which corresponds to a 25 percent markup from dealer

cost. Generally, option markup rates are significantly higher than
VIII-39

standard markup rates. However, in estimating the wholesale price of the

SRS, NHTSA used the 20 percent dealer discount derived from the Black

Book. This results in a dealer cost per SRS of $704 ($880 x .80).

NHTSA estimates the price split between driver air bag and passenger ETR to

be as shown below:

Driver Air Bag

Passenger ETR

a/ At an annual

Wholesale Price

$650

54

$704

volume of 5,000 cars.

Markup

Factor

1.25

1.25

1.25

Retail

Price a/

$813

67

$880

The ETR estimate may be on the low side and represents NHTSA's "best guess"

in the absence of concrete cost/price data. Additionally, the markup

factor may be too low given that the SRS is an option. These uncertainties

likely result in the wholesale price being overstated for the driver air

bag.

Of major significance is the order of magnitude in this estimate when

compared to GM's driver only air bag estimate.

—Drive r Only Air Bag System—

Incremental

Consumer Price Annual Volume

Mercedes (NHTSA $813 6,000

Estimate)

GM (Comment #1666) $650 250,000
VIII-40

Granting that there are differences in basic design between Mercedes and GM

vehicles, Mercedes appears to be charging its customers a price 25 percent

higher than that of GM for a driver only system that is optional equipment

and sold at an annual volume which is 42 times lower than that quoted by

GM.

Analysis of the docket responses indicates that the estimates for

electronic air bag systems included in the NHT5A Preliminary Regulatory

Impact Analysis are still adequate. Also indicated is that if mechanical

air bag systems prove feasible, the cost will be approximately 40 to 80

percent of the electronic systems.

The industry estimates are approximately $500 higher than NHTSA's. This is

because in our view the industry estimates are hot representative of recent

outside quotations, full air bag fleet volumes, and long term upgrading of

designs and manufacturing innovations. A comparison between NHTSA and

industry estimates is shown in Table VIII-15 with summary explanations of

differences.

The third and final issue considered by NHTSA in its evaluation of air bag

cost estimates is that of annual sales volume. The agency believes that a

volume of 1 million units annually for estimating purposes best represents

the number of units that would be produced for wide spread application of a

particular air bag system design. As shown in the PRIA (October 1983),

incremental consumer costs at the highest volume assumption the agency

considered, 2.5 million per year, results in a cost reduction of about $20

per unit as compared to the 1 million level, and the 1 million unit per

VIII-42

year level is about $20 lower in cost than the 300,000 unit per year level.

For annual volumes lower than 300,000 units, there is little consistent

data with which to formulate a cost/price estimate. Based on teardown

analyses and the "best guess" as to the cost of the Mercedes driver system,

the agency estimates that, at an annual volume of 100,000 units per car

manufacturer, a full front seat air bag system will retail for about $600.

For annual volumes of less than 10,000 units per car maker, this figure

rises to about $1500. These estimates are based on extrapolation of the

cost relationships between the Mercedes driver and passenger module in

NHT5A's teardown analysis as well as the cost of the Romeo Kojyo system,

which is $500 per kit in batches of 1000. With regard to the Romeo Kojyo

system, the assumption is that a retrofit passenger module would be about

twice the cost of a driver module or about $1,000. This assumption is

based on the following:

o The passenger system will be comprised of two driver inflators similar

in design to the Mercedes passenger system analyzed in NHTSA's teardown

study.

o The passenger bag will be approximately double the size of the driver

bag.

At very low volumes there are no scale economies realized since each unit

is virtually hand fabricated. Hence cost will be proportional to labor and

material content only.
VIII-43

To summarize the agency's position on air bag costs and weights:

o The full front seat air bag sys em will cost the consumer $320 per car

at an annual volume of 1 million units.

o At annual volumes of 100,000 units or less, full front air bags may

cost anywhere from $600-$1500 per car. At volumes of 10,000 units per year

or less, the latter figure is most representative.

o The development of a successful all mechanical air bag system may

reduce the unit price of a full front system to about $200 for a driver

plus 1-passenger system and $250 for a driver plus 2-passenger system based

on an annual volume of 1 million units in each case.

o Current design electronically activated air bags will add 21 pounds to

the weight of a typical vehicle according to NHTSA's teardown analyses.

Incremental weight estimates for adding air bag systems to passenger cars

are summarized in Table VIII-16. Only GM, Ford, and Jaguar submitted such

estimates to the docket. NHTSA finds no basis for changing its incremental

weight estimates based on the docket comments since supporting

documentation is insufficient.

TABLE VIII-16

AIR BAGS

INCREMENTAL WEIGHT ESTIMATES

NHTSA AND INDUSTRY ESTIMATES

NHTSA (PRIA) 21 LBS

GM 56 LBS

Ford 40 LBS

Jaguar 35 LBS
VIII-44

2. Automatic Belt Systems

Table VII1-17 summarizes the docket comments s ibmitted by automakers

concerning automatic belt incremental consumer costs per car.

Of the major automakers, only GM provided a detailed cost estimate in its

Docket submission. The GM estimate was for a high volume 4-door sedan with

two front seats and three-point detachable automatic belts with single door

mounted retractors. No provision was necessary for knee bolsters. Table

VII1-18 provides the GM estimate.

Thomas E. Lohr, an engineer claiming extensive experience in the design of

active and automatic seat belts with GM, Allied Chemical Corp., Irvin

Industries, and Allen Industries, submitted detailed cost estimates for "Y"

and "V" type three-point automatic belts.24 it is Mr. Lohr's position that

NHT5A's mark-up factor of 1.33 from variable cost to dealer cost is far too

high since the basic resources (e.g. tooling) for automatic belts are

already in place, requiring little investment. A mark up of 1.11 is far

more appropriate. Mr. Lohr estimates that the incremental cost of "Y" type

belts will be $45 and "V" type belts will be $42 (Docket Comment #

74-14-N30-030). NHTSA does not believe tooling and other basic resources

are in place for automatic belts. Note that Mr. Lohr's comments apply only

to three point automatic belts.

24 "Y" belt - lap and shoulder belt join into a single belt which joins center

console. "V" belt - lap and shoulder belts join at the center console.
VIII-45

TABLE VIII-17

AUTOMATIC BELTS

PER VEHICLE PRICE INCREASES

(OVER MANUAL BELT CARS)

INDUSTRY ESTIMATES

$1983

GM 45

Ford 165

Chrysler 115

Renault 200

Jaguar 15025

Honda 150-170

Nissan (Power) 3702 6

(Mechanical) 230

Peugeot (Power) 380-40027

Lohr 45

25 As of 1/12/84 1 British Pound = $1,402 or $1 = .7135 Pound

26 At an estimated volume of 10,000 units/mo.

27 At an annual volume of 19,000-20,000 units.
VIII-46

TABLE VIII-18

AUTOMATIC BELT SYSTEM COSTS

GM ESTIMATES

3-PT DETACHABLE - SINGLE RETRACTOR

DECEMBER 19, 198328

1.

2.

3.

4.

Incremental Retail

Price Increase

$1983

Less: Dealer Discount

Net to Manufacturer

(1.-2.)

Incremental Variable Costs

Belt Equipment

Vehicle Changes

Driver

22

_4

18

25

6

R-F Passenger

23

4

19

26

5

Driver Plus

R-F Passenger

45

J3

37

51

11

(43)

(35)

5. Decremental Variable Costs

Elimination of

Current Belt System

6.

7.

Components

Total Incremental

Variable (4.-5.)

Incremental Variable

(20)

11

7

(20)

11

8

(40)

22

15

•

(21)*

(14)*

Margin (3.-6.)

8. Incremental Fixed/

Mixed Costs Allocated

per Unit _7 _8 15 (14)<

9. Incremental Before

Tax Profit/Unit

(7.-8.)29 0 0 0 0

• $1982

28 The columns Driver and R-F Passenger are estimated.

29 No profit is assumed by GM.
VIII-47

The agency has conducted teardown analyses of existing and conceptual belt

systems for the VW Rabbit, 1980 Chevrolet Chevette, and the 1982 Toyota

Cressida to determine the costs and weights of automatic belts over or

under current three-point manual systems. The contractors were Corporate

Tech Planning/Pioneer Engineering (augmentation of Contract No.

DTNH22-82-C-07179). The results of NHTSA's teardown cost analyses are

shown in Table VII1-19 along with the estimates provided by high volume

manufacturers in their docket comments.
VIII-48

TABLE VIII-19

BELT SUMMARY I

Industry Estimates

Domestic

1. Ford

2. GM

3. Chrysler

3 pt.

3 pt.

Annual

Volume

mil.*

5.0 mil.

1.0 mil.

ESTIMATES

Automatic Manual

$240

$105

180

AMC (No estimates provided. Stated $70 for

realistic).

5ales Weighted Average

4. LOHR

NHTSA Estimates

5. VW detachable

6. VW nondetachable

7. VW nondetachable

8. Chevette

detachable

9. Chevette

detachable

3 pt.

2 pt.

2 pt.

3 pt.

3 pt.

3 pt.

Toyota Cressida Power (NHTSA

10. With manual

lap belts

11. Without lap

belts

Other Imports and

Nissan Power

Nissan

Honda

2 pt.

2 pt.

Low Volume

2 pt.

2 pt.

2 pt. &

3 pt.

8.0 mil.

300K

300K

300K

300K

300K

Est)

300K

300K

120K

120K

N.G.

JW

90

$132

126

113

91

91

211

178

$ 370

230

200-270

$75

$60

65

manual belts

Wi

46

$99

99

99

60 GM

6430

64

64

$ 80-100

80-100

50

Automatic

Over

Manual

$165

$ 45

115

is

T75"

45

$28-33

27

14

Av. 31

27

147

114

$290-270

150-130

150-220

* Proprietary.

TM GM and industry averages used for baseline because NHTSA did not develop

manual belt teardown estimates for the Chevette and there is no Cressida

manual belt design.
VIII-49

TABLE VIII-20

SYSTEM WEIGHT IN POUNDS

NHTSA ESTIMATES

VW Designs

3-Point

2-Point

2-Point

Manual

Automatic

Automatic

Driver

14 lbs.

16

16

Passenger

6 lbs.

11

10

Total

20 lbs

27

26

Automatic

(Over)/Under

Manual

(Base line) lb.

(7)

(6)

(non-detachable)

3-Point Automatic 12

(non-detachable)

Chevette Design

3-Point Automatic 7

Toyota Cressida

19

13

25 lbs.

0

(10)

Table VIII-20 summarizes the agency's teardown weight analysis for VW based

automatic belt systems, the Chevette 3-point automatic system, and the

Toyota Cressida motorized automatic belt system. System weights are

expressed both as absolute weights and incremental to current manual belt

systems. For the VW systems, the driver side absolute weights are greater

than the passenger side weights due to the inclusion of steering column

components not used in VW cars sold elsewhere than the U.S. The weight of

manual belt systems also includes these components, thus the incremental

weights for automatic restraints are comparable. Also note that the

3-point automatic belts are lighter than the 2-point automatic belts

because the latter includes the weight of the knee bolster.
VIII-50

In the PRIA, the agency estimated the cost of current front seat belt

systems to be $50 per car. The teardown analyses and Docket comments

indicate that this figure is too low (see Table VIII-19). On a sales

weighted basis, NHTSA now estimates that front seat belt systems currently

cost the customer $64 per car.

The agency's conclusions as to the cost and weight impacts of automatic

belts versus manual belts are summarized below:

o Non-motorized detachable automatic belts without interlocks that meet

the minimum requirements of the standard are estimated to have an

incremental consumer cost of about $28 per car over manual belts. These

estimates (typical for high production volumes) were developed from

teardown studies.

o Automatic belts, including amounts for industry planned safety and

convenience enhancement features that exceed the minimum requirements of

the standard, are estimated to have an initial consumer cost of about $40

per car more than manual belts. This is $12 more than NHTSA's estimate of

$28 for non-motorized minimum requirement designs. The additional $12

provides for manual lap belts which may be retained with 2-point automatic

designs and a 5 percent fleetwide installation rate for Cressida type

motorized and VW type interlock systems. Table VIII-21 provides NHTSA's

definitive estimate for automatic system cost impacts.
VIII-51

TABLE VIII-21

PER UNIT

COST OF AUTOMATIC BELTS OVER MANUAL

INCLUDING STANDARD EXCEEDING FEATURES

NHTSA ESTIMATES

Automatic Belt Design

Annual Volume

Incremental Cost

Av. for Meeting Minimum

Requirements

Item Exceeding Standard

Ford

2-pt.

mil*

$28

GM

3-pt.

5.0 mil

$28

Chrysler

3-pt.

1.0 mil

$28

Across

Fleet

NA

NA

$NA

Average

Car

NA

NA

$28.0

Manual Lap Belts with 6,7

2-pt. Designs^

55K with Power Belts 4.3 4.3

(380,000 vol)3 2

108 with VW Type Interlock33 2.5 .25

Cost Per Car (For Features Exceeding the Standard) 11.25

Total Cost per Car for Standard $39.25

* Proprietary.

o The industry sales weighted average incremental cost for non-motorized

belts is $79 or $51 higher than NHTSA's. This is principally because the

industry estimates included amounts for two additional door mounted

retractors, electrically activated pendulum blockers, driver and passenger

knee bolsters in some 3-point automatic designs, manual lap belts with

31 Based on proprietary data.

32 Power belts $114 over manual less $28 covering 5 percent of 7.6 million

annual fleet.

33 $5 per car for VW type interlock cover 5 percent of 7.6 million annual

fleet.
VIII-52

retractors and manufacturing and dealer markup rates higher than normal.

With normal markup rates the industry estimates sales weighted average

woi Id be reduced to $62 or $34 higher than NHTSA's estimate.

o The incremental weight penalty associated with the addition of automatic

belts for front outboard passengers is estimated to be five pounds for

mechanical systems.

4. Alternative Capital Investment Requirements

The automatic restraint capital investment requirements for the auto

industry are shown in Table VI11-22 for those commenters which provided

such data. Capital expenditures are defined as outlays for property, plant,

machinery, equipment, and special tools to be used in the production of

automatic restraint systems.
VIII-53

TABLE VIII-22

INDUSTRY INVESTMENT^

(Current Economics)

INDUSTRY ESTIMATES

Manufacturer

Domestic

GM

Ford

Chrysler

Foreign

Honda

Renault

Annual

Volume

250K

3,000K

High

High

High

Low

Automatic Belts

$125M

Air

Driver

$49M

42 8M

(Deleted-Proprietary)

$37M

$5M

$1.5M

$12M

Bags

, Full Front

$67M

573M

$89M

Because most manufacturers provided no docket comments on the subject of

capital investment, the data in Table VIII-21 are thus incomplete. In

addition, a major manufacturer - Ford - specifically requested confidential

treatment of all cost and investment data. Nevertheless, on the basis of

what is available, NHTSA estimates the impact of automatic restraints on

auto industry capital spending as shown below for all automatic belt and

for all air bag equipped fleets. NHTSA does not believe that the

implementation of automatic restraint requirements will alter the magnitude

of planned capital spending over the next several years. However, the

expenditures estimated below will preclude the auto makers from investing

in other projects. Hence, these expenditures represent a true cost in terms

of lost opportunities.

Defined as expenditures directly involving acquisition of property, plant,

machinery, equipment, and tools.
VIII-54

NHT5A ESTIMATES OF

3 Years

Domestic and Foreign Total Annual

For All New Cars Capital Investment^ . investmentAir Bags $1.3 Billion $.43 Billion

Automatic Belts .5 Billion .17 Billion

There are other product related expenses associated with the introduction

of automatic restraints, chief among which are Engineering, Research, and

Development Expenses (E, R 4 D) . Table VII1-23 summarizes the estimates of

E, R, 4 D spending for those manufacturers that provided such data.

In terms of unit retail price impact, depreciation and amortization of

capital expenditures; E, R, 4 D, and other overhead expenses are reflected

in the formula mark-up from unit variable cost described earlier. Unit

variable costs are first accumulated then marked up by a pre-determined

overhead rate to cover each unit's pro rata share of overhead expenses.

Developed from Docket Comments and Proprietary Data.

GM, Ford, and Chrysler alone are expected to spend a total of $10 billion

in capital investments in 1984. Automatic restraints will account for less

than 5 percent of this.
VIII-55

Manufacturer

Domestic

GM

Ford

Chrysler

Foreign

OTHER

Annual

Volume

250K

3,000K

High

High

TABLE VIII-23

PRODUCT RELATED EXPENSES37

INDUSTRY ESTIMATES

Air B

Automatic Belts Driver

$12M

35M

$40M

(Deleted-Proprietary)

$65M $26M

ags

Full Front

$20M

65M

$70M

Jaguar

Primarily Engineering, Research, and Development (E, R, & D) .

Development Cost = 1 Million Pounds Sterling which equals $1.4 Million at

the January 12 exchange rate $1 = .7135 Pounds.
VIII-56

C. Leadtime Considerations

Several manufacturers submitted comments on the leadtime required for the

implementation of automatic belts and air bags. The comments for automatic

belts ranged from immediately (from Volkswagen for some models only) to

more than 4 years (for Ford). For air bags, the range was from 2 years for

Mercedes and BMW up to 5 years for some models of Chrysler and Saab.

In order to determine the reasonableness of these comments, the agency

considered the principal constraints to implementation of each restraint

type. For each type of automatic restraint, the leadtimes for critical

components are as follows:

Detachable automatic belts: seat, door, pillar, and floor pan

reinforcements - approximately 24 months.

Non-detachable automatic belts: design and testing of non-detachable

feature in addition to above items

required for detachable automatic belts -

one year of additional leadtime is needed

- approximately 36 months.

Driver air bag: steering column modification (particularly, if

all models at one time) - at least 36 months; longer

for small cars.

Passenger air bag: instrument panel and glove box relocations -

approximately 24 months. Testing and development -

36 to 48 months; longer for small cars.
VIII-57

Developmental effort has already been expended for detachable belt systems

by some companies for some models. Hence, NHTSA believes that introduction

of such systems by those companies, for those models already designed to

accept automatic belts, only would require placing orders with suppliers

and incorporating minor vehicle modifications. A leadtime of 24 months

should be sufficient for those companies and models for detachable belts.

However, because these are models which will soon be discontinued,

manufacturers will either be unable to recoup their investment costs or

have to charge significantly higher prices than estimated earlier in this

chapter. Models which have not yet been developed for automatic restraints

(i.e., which have been designed and/or manufactured since the rescission)

would require at least 36 months leadtime. Since very few non-detachable

automatic belts have yet been developed or marketed, an additional year

would be needed to develop and test spool out features and other components

that would maximize consumer acceptability and safety considerations in

terms of entry/egress. Thus, at least 36 months leadtime would be required

for an across-the-board mandate for automatic belts.

Because some companies are already offering (or preparing to offer) driver

air bags in some models, these companies could offer some driver-only air

bags with a 24-36 month leadtime. For example, Mercedes could have

driver-only air bags available "across the entire model range" by MY 1986.

Volvo plans to introduce driver air bags in some MY 1987 models. BMW

testified that they could have one model equipped with driver only air bags

during the 1985 model year. However, available evidence suggests that a

substantial number of vehicle models will require major modifications to

the steering wheel and column. To redesign or modify the majority of
VIII-58

steering wheels and columns for air bag introduction in 24 months would be

disruptive. Since some models have never been designed to accomodate air

bags, 36-48 months leadtime appears to be more realistic to equip most cars

with driver air bag systems.

Passenger air bags will require extensive instrument panel modifications or

redesign; including relocation of the glove box as well as testing to solve

problems in occupant kinetics. Given the number of models involved and the

available industry staff resources, full implementation would require 36-48

months for passenger air bag systems on large and mid-size cars.

Air bag systems for subcompact cars are expected to require at least an

additional year to develop more sophisticated systems for these cars such

as 2-stage inflators and more elaborate front end structures. Thus small

car air bags are estimated to need 48-60 months leadtime (see Chapter III

for more detail).

One constraint on leadtime for air bags could be the availability of the

sodium azide propellant for bag inflators. Responses from the sodium azide

producers to agency inquiries indicate that, from the date a final rule is

issued, 24 months will be required to achieve sufficient production

capacity to meet expected demand, assuming fleetwide air bag installation.

This will not affect the overall leadtime for air bags.
VIII-59

In order to determine the consequences of incremental implementation on the

manufacturers, sales by car line in 1983 were examined to determine if

10 percent implementation could be met by the application of restraint

technology to one car line. For American Motors it was determined that the

Alliance comprised about 65 percent of the model years sales. For

Chrysler, the Omni/Horizon accounted for about 13 percent, and the

Reliant/Aries accounted for about 32 percent of the company's sales.

Typical model sales for Ford included about 10 percent for the LTD, 21

percent for the Escort, and 11 percent for the Tempo/Topaz. Sales of

various GM platforms in 1983 included about 12 percent for the 3 body, 15

percent for the A body, 16 percent for the B body, and 23 percent for the G

body. For the import manufacturers, similar results were found. For

example, the Honda Prelude was roughly 12 percent of Honda's sales, and the

Accord was about 49 percent. For Nissan the Pulsar represented about 12

percent and the Sentra represented about 40 percent of.their 1983 sales.

Volvo's sales of their 760 were about 10 percent and their DL sales were

about 50 percent of the total. Other manufacturers experienced similar

sales patterns. Thus, it is apparent that a requirement that 10 percent of

the manufacturers, production be equipped with a particular restraint

technology would in general allow just one model to be engineered for this

requirement, should that be desired. The agency believes that this

approach would impose no undue hardship on the industry.
VIII-60

Energy Costs

In addition to the manufacturers and consumers hardware cost of belt and

air bag systems, there is another cost element to consider. The use of

an occupant restraint system will slightly increase the weight of the

vehicle thereby using more fuel over its lifetime and adding to the

lifetime cost of operating the vehicle.

The agency requested more up-to-date information on occupant restraint

system weights in the October 1983 analysis. Few of the commenters

discussed the weight of the various occupant restraint systems however.

Jaguar Cars Inc., GM, and Ford, were the only manufacturers discussing

system weight in the docket submissions. Toyota, in the Kansas City

hearing, stated that their motorized automatic belt system added 25 pounds

to the car. Table VIII-24 shows these comments as well as those other

manufacturers responding to the docket but offering no data on system

weight.

The agency has also reviewed the latest data from teardown studies. While

designs of non-motorized automatic belt systems vary considerably, it

appears from tear down studies that a good estimate of the average

incremental weight of these systems is 5 pounds. A motorized automatic

belt system, such as the Toyota Cressida system, has an incremental weight

of about 10 pounds. A typical front seat air bag system incremental weight

is estimated at 21 pounds, according to teardown data.
VIII-61

TABLE VIII-24

SUMMARY OF MANUFACTURER DOCKET COMMENTS

ON OCCUPANT RESTRAINT SYSTEM WEIGHT

DOCKET 74-14-N32

Weight of System (Lbs.)

Non Motorized Motorized

Automatic Automatic

Commenter Belts Belts Air Bags

Jaguar Cars,

Inc.

American

Motors Corp,

Saab-Scania

Porsche

GM

Ford

Chrysler

VW

Renault

Toyota

Mercedes

Comment

Number/

Page Number

1690/4

5299/5

1689/

1089/

1664/8^9

3115/18

5300/

1673/

1665/

HearingKansas City/

120

5886/

Manual

Belts

6.5

N.C.

N.C.

N.C.

-

-

N.C.

N.C.

N.C.

—

N.C.

31

N.C.

N.C.

N.C.

25

N.C.

N.C.

N.C.

N.C.

35

N.C.

N.C.

N.C.

-

-

N.C.

N.C.

N.C.

Adds 25

Pounds to

Car

N.C.

N.C.

56

40

N.C.

N.C.

N.C.

-

N.C. N.C. N.C.

N.C. = No comment; did not estimate or cover weight of systems in docket

response.

Considering all the available information mentioned here, the agency will

use the following system weight estimates in calculating the energy costs

associated with the various occupant restraint systems:

GM states that there will be no increase in fuel consumption if automatic

seat belts are used in place of manual seat belts.
VIII-62

Weight Increment

Manual belts Base Case

Non-motorized automatic belts 5 lbs.

Air bags 21 lbs.

The agency has used in previous analyses of rulemaking actions and will use

here, a "secondary weight"' factor of one pound for each pound of added

weight.40- Thus, for each additional pound added due to occupant protection

systems, one pound of weight is added to the chassis subsystems (i.e.,

tires, brakes, suspension, etc.) to support the added body weight. The

agency also used a rule of thumb that for each pound of weight added to the

vehicle, there will be an increase in the lifetime fuel consumption of one

gallon.41

The calculation of the present discounted value of the lifetime fuel

increase is shown in Table VIII-25. The estimated gasoline price for

1987-1996 is based on the price of unleaded gasoline, which by the late

eighties is expected to be the bulk of the fuel used in this country. The

baseline 1982 fuel price was derived from data provided by Data Resources

Incorporated. The percent of total mileage per year is a distribution the

agency has used in numerous prior rulemakings, particularly the fuel

economy rulemakings. A discount factor of 10 percent is assumed. The

results in Table VIII-25 show that for each additional gallon of fuel used

over the life of the car, there will be a present discounted value of $1.05

added to the consumer cost. Applying this factor to the estimated

4 0 For example, the'TRIA, Amendment to FMVSS 208, Occupant Crash Protection,

Rescission of Automatic Occupant Protection Requirements," NHTSA, October

1981.

41 FRIA, Part 581 Bumper Standard, NHTSA, May 1982, p. VII-40 to VII-42.
VIII-63

increased fuel usage, non-motorized automatic restraints represents an

additional $11, and the air bag represents an additional $44 over the

current system over the life of the car.

TABLE VIII-25

PRESENT DISCOUNTED VALUE OF ONE GALLON INCREASED FUEL CONSUMPTION

ear

19B7

19B8

1989

1990

1991

1992

1993

1994

1995

1996

Estimated

Gasoline^2

Price ($ 1982)

$1.27

1.31

1.34

1.38

1.44

1.51

1.58

1.65

1.73'

1.77

Percent Total

Mileage/Year

18.11

15.11

13.26

11.83

10.58

9.24

7.82

6.20

4.60

3.25

Factor

1.000

.909

.826

.751

.683

.621

.546

.513

.467

.424

Discount ^

Value

$0,230

0.180

0.147

0.123

0.104

0.087

0.067

0.052

0.037

0.024

$1,051

$1.05

U.S. Department of Energy, Energy Projections to the Year 2010, October

1983.

Discount rate assumed to be 10 percent.
IX. COST IMPACTS

This chapter discusses the economic effects of potential increased

passenger car costs resulting from a requirement for the installation of

automatic restraint systems in new passenger cars. The economic

consequences of such a requirement on the automotive industry, its

suppliers and the national economy are considered.

Two analytical studies of the cost impact of automatic restraints were

submitted to the Docket. An analysis conducted by Barbara C. Richardson

and Sherry S. Borener (University of Michigan), sponsored by the Motor

Vehicle Manufacturer's Association, concludes that a government requirement

for air bags costing between $300 and $600 per car would have severe

detrimental effects on the automotive industry and the economy as a whole.''

In ±he short run, new vehicle sales are calculated to decrease from a low

of 2.7 percent to a high of 9.7 percent annually. Unemployment could be

expected to increase from 62,000 to 197,000 persons per year. GNP, wages,

disposable income, and personal consumption would decrease and the consumer

price index would rise.

Air Bag Restraint Regulation: Potential Domestic Macroeconomic Impacts -

Interim Heport, Barbara I. Kichardson and Sherry 5. borener, University of

Michigan, November 1983.
IX-1

A study by William Nordhaus of Yale University, commissioned by several

major insurance companies, found that the net effect on industry sales and

employment would be negligible and that the national economy would not be

affected adversely.2

Using the Richardson and Nordhaus studies as a base NHTSA performed a

separate analysis. The results of 13 attitude surveys (see Chapter XI)

were used in establishing a rough relationship between automatic restraint

costs and the percent of consumers who would purchase them voluntarily.

This provides a basis for estimating the potential effects of various price

changes on the demand for automobiles and the consequent economic impacts

on the automotive industry and the national economy. Assuming an

additional cost of $320 per car for an all air bag fleet, (see Chapter

VIII) the potential long term loss in annual vehicles sold could range from

about 20 to 80 thousand. Long run gains in gross industry revenue could

range from $1.7 to $2.4 billion. Both short and long term cost impact

estimates are presented in Tables 5, 6 and 7 of this chapter. Increases in

annual employment in both the automobile manufacturing and supplier

industries would vary from about 30 to 45 thousand. The above estimates

assume everything constant except the price increase.

Comments of William Nordhaus on Notice of Proposed Rulemaking on Federal

Motor Vehicle Safety Standard - Occupant. Crash Protection, Docket 74-14,

Notice 30, December 1^83, Appendix B.
IX-2

This chapter concentrates primarily on the cost impacts of air bags. The

effects on sales, employment and income from a price increase of $40 per

vehicle (see Chapter VIII) due to the installation of automatic belts would

be minor and could not be quantified with any degree of confidence.

The underlying issue - and the factor that triggers both adverse and

beneficial economic effects on both the automotive industry and the

national economy - is consumer reaction in the marketplace to government

mandated changes in the characteristics and price of the automobile. The

discussion which follows explores the nature of consumer demand for

automobiles.

A. Demand for Automobiles

Automobile manufacturing plays a major role in the health of the U.S.

economy. As a result, the numbers and types of automobiles consumers

purchase and the rationale behind their decisions have been the subject of

scientific inquiry for at least a half century. The most recent studies

are based on sophisticated computer models that dynamically evaluate the

interrelationships among many dozens of variables affecting automobile

demand. Table IX—1 lists a few of the factors which have been included or

considered in these studies. A key issue is that, given these numerous
IX-3

factors which directly or indirectly affect demand, how important is the

purchase price, or, more specifically, can the coefficient of this variable

in the demand equation be estimated with any degree of accuracy?

Table IX-1

Some Factors Which May Influence Demand for New Automobiles

* Purchase Price

* Life-Cycle Costs

* Interest Rates and Terms of Loan

* Price of Substitutes (e.g. used cars, smaller cars, light trucks,

vans, etc.)

* Insurance Costs

* Operating Costs (e.g. fuel)

* Disposable Income

* Anticipation of Future Employment, Income and National Economic

Stability

* Family Size

* Population Growth and Age Distribution

* Urbanization

* Effectiveness and Persuasiveness of Advertising

* Registration and Licensing Costs

* Personal Property Taxes

* Relative Safety and Convenience Compared to Other Modes

1. Elasticity of Demand

Quantitative estimates of the effect of price changes on demand are

generally expressed in terms of the "price elasticity of demand" which is

the percent change in quantity demandec divided by the percent change in
IX-4

price. A basic assumption is that all other factors affecting demand will

remain constant. Although automobile price elasticity estimates vary

widely, they commonly range from -1 to -1.5 in the short run (1 or 2 years)

and -.5 or less over the long run.3 The reason for the difference over time

is that when prices first increase consumers experience "sticker shock" and

may be hesitant to buy but after a period of time tend to adjust to the

new price.

If, with a 1 percent change in price, demand increases or decreases greater

than 1 percent, the demand for the product is said to be price elastic. If

the percent change in demand is less than the change in price it is

inelastic. Generally, the demand for necessities will be more price

inelastic than the demand for luxury goods. There is no consensus on

whether automobiles should be considered a luxury or a necessity. Very

small percentage increases in price will often be more inelastic than large

increases, particularly if the increase does not represent a significant

portion of the consumer's budget. For example, assuming a sales volume of

8 million domestically produced passenger cars, an average price of $10,000

and an elasticity coefficient of -1.0, a price increase of $10 would

theoretically result in a decline of 8,000 units sold. Practically,

however, such a small relative and absolute increase will probably go

unnoticed and have little or no effect on demand.

•> Sources for a number of elasticity estimates can be found in the Richardson

study.
IX-5

One of the most important uses of the price elasticity concept is in

evaluating the effects of price changes on total revenue received by the

industry.4 if the demand for a given product is elastic (an absolute value

greater than one) an increase in price will result in a smaller total

revenue. Total revenue will increase in cases where elasticity has an

absolute value less than one. As discussed later, this point is

particularly relevant with regard to some of the short and long term price

elasticity estimates used for the automobile industry.

2. Differentiated vs. Homogeneous Products

Precise arithmetic calculations based on classical elasticity theory may be

more justifiable with homogeneous products such as wheat or coal than with

a highly differentiated product such as a passenger car. In purchasing an

automobile consumers generally have a wide range of options, including

vehicle size, accessories, and trim. Vans and light trucks can also be

considered- close substitutes. Many car options are not actually desired,

but are nevertheless purchased by consumers who wish to "buy off the lot."

To the extent that consumers do have options and set an upper limit on the

amount they are willing to pay for the "package," the impact of a restraint

system could be measured by the opportunity cost of not purchasing one of

the options, e.g. power windows, power seats, air conditioning, etc. This

opportunity cost may be high (equal to or greater than the cost of the

Total revenue is defined as average price times quantity sold.
IX-6

restraint) to consumers who buy only what they need or very low for

consumers who do not place a high value on the options which they may be

forced into by purchasing "off the lot."

3. Other Factors Associated With Automobile Demand

As noted in Table IX-1, price is only one of a large array of factors which

influence demand for automobiles. Although very few would dispute the law

of a downward sloping demand curve (i.e., as price increases fewer will be

purchased and vice versa) this relationship holds in the real world only

when everything else has remained constant. However, in the real world

this is seldom the case and actual demand often increases or decreases

totally independent of the direction of price change. If other factors

have a negative impact, demand could decline considerably more than what

might have been predicted from a price increase. If changes in these other

factors are favorable to sales, a price increase could be completely

overshadowed and the effect inconsequential. A few of the more important

factors that may offset price effects are discussed below.

a. Income

Changes in consumer income may play a role even more important than price

in determining automobile demand. For example, a recent report by the

Department of Commerce estimates price elasticity of demand for domestic
IX-7

automobiles at -1.11 and income elasticity at 1.56.5 Thus a 1 percent

increase in income results in an increase in automobile demand of over 1.5

percent. DRI forecasts an increase in real disposable income from $1,095

billion in 1983 to $1258 billion in 1987 - an average annual increase of

about 4 percent.6 Given that the assumptions of both elasticity and income

growth are correct, sales (assuming everything else the same) would increase

by about 6 percent annually.

b. Interest

For some consumers, monthly payments might be more important than retail

price. Under those circumstances, the interest rate and the terms of the

loan may play an important role in the purchase decision. For example, as

shown in Table IX-2 an increase in the initial price of a vehicle from

$9000 to $9500 at 12 percent interest and financed for 3 years will result

in a change of monthly payments from $299 to $316.^ However, a reduction

in the interest rate of 4 percent (from 12 percent to 8 percent) results in

a payment of $298 for the $9500 vehicle, about the same as that for a $9000

vehicle financed at 12 percent. Similarly, a 12 percent loan for $9500,

if taken for 4 years rather than 3, reduces monthly payments by $66 (from

$316 to $250), as compared to a $17 (from $316 to $299) smaller payment if

the lower priced $9000 automobile is financed at 12 percent for 3 years.

Automobile Demand Forecasting Model Bureau of Industrial Economics, U.S.

, Department of Commerce 1983.

U.S. Long Term Review, Fall 1983 Data Resources, Inc.

7 This example assumes that the entire purchase price is financed.
IX-8

This hypothetical example is used solely to support the contention that

many factors in addition to sticker price influence the consumer's

purchasing decision. Extending payment periods because of a higher price

obviously provides no net economic benefit to the consumer, given the lack

of certainty as to the direction of future interest rates.

TABLE IX-2

Monthly Payment By Interest Rate, Payment Schedule

And Amount Financed

$9,000 $9,500 $10,000

3 yrs.

8% 282.03 297.70 313.37

10% 290.41 306.54 322.68

12% 298.98 315.54 332.15

4 yrs.

8% 219.72 231.93 244.13

10% 228.27 240.95 253.63

12% 237.01 250.18 263.34

5 yrs.

8% 182.49 192.63 202.77

10% 191.23 201.85 212.48

12% 200.21 211.33 222.45

SOURCE: Expanded Payment Table for Monthly Mortgage Loans.

Financial Publishing Company.

c. Insurance

Insurance premiums represent a significant portion of the total cost of

owning an automobile.8 j o the extent that consumers consider life cycle

costs, reduced insurance premiums could have a significant positive

influence on demand. As described previously, overall reductions in

o

About 15 percent, as described in Cost of Owning and Operating Automobiles

and Vans, Federal Highway Administration, 198^2.
IX-9

insurance premiums for cars with air bags will range from $10 to $23

annually. Over the life of the vehicle the savings would be worth between

$76 and $158 dollars.

Nordhaus feels that consumers will be more influenced by life cycle costs

than first costs. In a Oune 13, 1984, submission to Docket 74-14 (Occupant

Crash Protection) he estimates that first and third party insurance savings

for cars with automatic belts will be approximately $19 annually. The

discounted value of these savings over the car life is estimated at $130.

The Nordhaus estimates are based on a situation where automatic belts are

used in all cars. If air bags are chosen, some increase in property damage

insurance costs could occur.

A complete discussion of the effects of restraint systems on insurance

premiums can be found in Chapter VII. Of importance here is the issue of

whether consumers only react to vehicle price changes or whether they take

into account life-cycle costs in their purchase decisions.

B« Micro-economic Effects of Price Changes

The following sections describe some of the potential economic consequences

of a government mandated automatic restraint system on the automotive

industry and its suppliers. The emphasis will be on losses (or gains) in

passenger car sales, industry revenue, and employment. The discussion

relies heavily on the findings of the recently completed studies by

Richardson and Nordhaus.
IX-10

1. Sales

Using an assumed incremental price increase ranging from $300 to $600 per

car with price elasticities from -.9 to -1.6 in the short run and

-.1 to -.5 in the long run, Richardson reported near term annual sales

losses ranging from 167 to 593 thousand vehicles and long term losses from

19 to 185 thousand annually (see Table IX-3). Input data for annual sales

(6,088,400) and average annual price in 1982 dollars ($9866) were based on

Bureau of Economic Analysis estimates.

Given the assumptions made by Richardson, the above results cannot be faulted.

However, Nordhaus expresses strong disagreement with several of the

assumptions. He argues first that the automobile manufacturers are more

Vehicle

Price

Table IX-3

Average Annual Loss of Vehicle Sales

(In Thousands of Dollars and Percent)

Increase

$300

$500

$600

-.9

167

-2.7%

278

-4.5%

334

-5.4%

Short Term

Elasticity

-1.28

237

-3.9%

396

-3.5%

475

-7.8%

-1.6

297

-4.8%

494

-8.1%

593

-9.7%

Long Term

Elasticity

-.1

19

-.3%

31

-.5%

37

-.6%

-.5

93

-1.5%

155

-2.5%

185

-3.0%

Source: Richardson and Borener, op. cit..
IX-11

likely to comply with restraint requirements by installing automatic seat

belts resulting jn an initial price increase of $88. He further assumes

an average retail price of an automobile at approximately $10,000 and

annual sales at 10 million.9. Using a short run price elasticity of -1.0

sales will decrease by 90,000 vehicles during the first year JT consumers

respond only to the initial cost increase and not to life cycle costs.

However, Nordhaus contends that consumers are more likely to be concerned

with costs over the life of the vehicle and will take into account

anticipated reduced injury costs and insurance premium reductions. In this

case the net effect on sales will be zero. Under the same assumptions for

consumer response and using an elasticity of -0.5 Nordhaus estimates long

run (over 1 year) annual sales losses to range from 0 (where consumers

consider life cycle costs and benefits) to 45,000 (where consumers consider

only initial costs).

Table IX-4 below summarizes the Richardson and Nordhaus estimates of

changes in automobile sales resulting from an automatic restraint

requirement. Note that these are estimates of changes in vehicles sold.

The dollar volume of sales is discussed later in this chapter.

° Nordhaus apparently includes imports in total sales. Richardson included

only domestic output.
IX-12

Table IX-4

Reduction in Annual Automobile

(In Thousands)

Short Term

167-593

0-90

Sales

Long Term

19-185

0-45

Richardson

Nordhaus

There are three reasons for the differences in the estimates. First, the

low end of the Nordhaus estimate (no reduction in sales) assumes that

consumers see a positive value in automatic restraints and are willing to

substitute them for other goods and services. Second, Nordhaus assumes a

lower priced alternative; i.e., automatic belts, and third, the price

elasticity assumptions differ somewhat. Richardson assumes a range from -.9

to -1.6 in the short run and -.1 to -.5 in the long run. Nordhaus'

assumptions are -1.0 in the short run and -.5 for the long run where

consumers are concerned only with initial costs.

The concept of price elasticity holds true only under a given set of

assumptions, the most important being that all other factors remain

constant - including the product being considered for purchase. An

automobile with a new automatic restraint system is not the same product as

an auto without such a system. Consequently, there is no definitive method

for predicting consumer response to a price change unless a determination

can be made of consumer reaction to the new product. If consumers perceive

the automatic restraint system as an increase in the value of the vehicle
IX-13

equal to its additional cost and if the restraint system provides a utility

as high or higher than the next best consumption alternative, then demand

will shift upward to a point where quantity demanded and sold at the new

price is approximately equal to that at the old price. However, if

consumers view automatic restraints as a nuisance or as having a negative

value, demand will shift downward.10 In such a situation there would be a

multiple negative impact - a decline in quantity demanded due to the price

increase along with a decline due to a downward shift in demand.H

At the present time there is considerable uncertainty regarding consumer

response to automatic restraints. Although numerous attitude surveys have

been conducted their results are often inconclusive and contradictory.

Because of the data limitations the results of the brief analysis which

follows should be used with caution. However, it should be useful to the

extent that it provides a conceptual framework for estimating the effects

of a restraint system on automobile sales.

It must first be recognized that consumers are not homogeneous and

will react in a variety of ways to a price increase. In some instances

consumers, who previously would not purchase a vehicle because of the risk

of injury, may now be encouraged to enter the market - assuming the

restraints result in a substantial improvement in safety.12 ^ tn e other

extreme are those consumers who do not want an automatic restraint at any

An upward or downward shift in demand describes a situation where more or

less of a product is purchased at the same price in contrast to a movement

along the demand curve which shows quantities purchased at various prices.

11 In this case consumers would pay more for a car without an automatic

restraint or would pay money to have the device removed.

12 At present there is no empirical evidence to support an argument that

improved restraint systems would increase sales.
IX-14

price and would be willing to pay for having it removed or would, if given

a choice, pay more for the same car without the system. For purposes of

simplifying the analysis it is assumed that, at least in the long run, the

above two groups cancel each other in terms of the net effect on sales.

In the middle, and probably representing a large majority, are those who

would buy the system at some cost. Some will view the restraint system as

a significant increase in the value of the car and would be willing to pay

more than the asking price, others would value the system at about equal to

the price and the remainder would take the system but not at the price

asked. Within this group and at any given price some will experience a

"consumers surplus" and others will drop out of the new car market or

postpone buying because other needs are of a higher priority (i.e., the

incremental utility of a car with an automatic restraint is less than that

obtained from another good or service.)

The different ways consumers might respond to a price increase and the

effects on sales are described in Figure IX—1. The initial equilibrium

point is at the intersection of P and curve D resulting in a quantity

demanded of Q. If price is increased to P<| and to the extent that

consumers value the product at an amount at least equal to its price the

demand curve will shift upward to D<| and there will be no change in

quantity sold. To the extent that consumers do not place a value on the

product equal to its price there will be a northwest movement along demand

curve D and quantity sold will decline to Q<|. The curve D2 describes

a situation where consumers place a negative value on the product. The

IX-16

downward shift in demand suggests that at any given price consumers will

buy less of the product. Quantity demanded drops to

 n 2.^ ' A final

possibility is a situation where the product is so much improved that at

price P^ additional consumers enter the market. Demand increases from

Q to Q3. It should be noted that classical price elasticity theory

encompasses only one of the above possibilities - and that is the movement

along the original demand curve D.

Based on findings from several attitude surveys (see Chapter XI) Figure

IX-2 describes a statistical relationship between air bag prices and the

percent of consumers who say they would be willing to purchase them as an

option. The graph is not meant to relate increased vehicle prices to

consumer demand for vehicles. Although, as discussed previously, attitude

surveys historically have not been reliable indicators of preferences

revealed in the marketplace, it appears from the curve that about 50

percent of all consumers would purchase an air bag if the price were no

higher than $250.1^ Before continuing with the analysis several assumptions

are required. The first is that those consumers who would willingly

purchase an air bag as an option would not hesitate to buy an air bag

The potential for a downward shift in the demand curve is discussed at

length in, "The Costs and Benefits of Automobile Emissions Control and

Safety Regulations," Oames Langenfeld, Washington University, St. Louis,

Missouri, October 1983.

The curve in Figure IX-2 is fitted from 37 widely scattered data points

contained in 13 surveys. The original equation is y = 85.35 + ,179x +

.0001083x2 where y represents percent of consumers and x is price. The

R

2 value is .62. The probability that the linear and quadratic

coefficients are due to chance alone is .0001 and .054 respectively. The

scale has been compressed to eliminate 15 percent who would not buy at any

price and 11 percent who would buy at any price asked; that is, where the

upper portion of the curve becomes vertical and the lower portion crosses

the horizontal axis. The curve becomes vertical at a price of $826. The

rationale for eliminating the extremes is discussed in the text.

IX-18

equipped passenger car. A second assumption is that the demand curve for

new automobiles among those consumers who indicate a willingness to buy at

a price of $250 will shift upward to a point where quantity demanded

remains the same and that the 50 percent who are not willing to spend this

amount will remain on a lower curve. Thus, at a price of $250 about 50

percent are fairly certain to buy a restraint equipped car and the

percentage of the remainder who purchase new cars will depend on the

elasticity assumptions. Table IX-5 describes several scenarios showing the

effects of various assumptions concerning price and percent of voluntary

purchases on automobile sales. For example, assuming a price of $250, 50

percent "willing to purchase" from Figure 1X-2 and a short term elasticity

of -1.0, annual sales are estimated to decline by 100,000. The calculations

are based on an annual sales volume of 8 million and an average price of

$10,000.15

Table 1X-5 essentially establishes an intermediate position between

Richardson who assumes that consumers are totally indifferent to air bags

and Nordhaus who contends that consumers will value them at their full

price.

Sales and price data based on 1984 projections by Data Resources, Inc., and

Bureau of Economic Analysis transactions prices.
IX-19

TABLE IX-5

Change in Automobile Sales Based on Assumed Variations in Elasticity,

Price and Percent Voluntary Purchases

Price

$0

100

250

320

500

800

Percent

Voluntary

100

75

50

35

20

0

TIAL AUTOMOBILE PRICE

UAL SALES (Domestic)

Short

-1.0

0

-20,000

-100,000

-170,000

-320,000

-640,000

= $10,000

= 8 MILLION

Term

-30

-150

-250

-480

-960

Elasticity

-1.5

0

,000

,000

,000

,000

,000

-6

-10

-17

-32

-64

Long

-.1

0

,000

,000

,000

,000

,000

Term

-10,

-50,

-80,

-160,

-320,

-.5

0

000

000

000

000

000

*NHTSA COST ESTIMATE
IX-20

2. Total Revenue

Total industry revenue, a function of price and quantity sold, is a factor

perhaps more important than sales volume in predicting the effects of a

price increase on employment and the national economy. To the extent the

distribution among the factors of production (labor, capital, etc.) does

not change with an increase in revenue, it is possible to experience a net

increase in employment, wages, income, etc., even with a decrease in the

number of automobiles sold.

Richardson's estimates of revenue changes range from an annual loss of $2.6

billion in the short-run (air bag price at $600 and elasticity at -1.6) to

a gain of $3.3 billion in the long-run (air bag price $600 and elasticity

-.1) . Using the assumptions described in the previous section Nordhaus

states, "The effect on sales and profits of automobile companies depends on

the pricing assumption, on the consumer perception of safety changes and on

the price elasticity. Assuming a long-run price elasticity of -0.5, total

revenues are likely to increase from 0.5 to 1.0 percent. Assuming that

variable margin per car (i.e., average factory revenue less direct variable

costs) is $1,500 per vehicle, the change in annual automobile company

profits from imposing the automatic restraint standard are likely to lie in

the plus or minus $80 million range."

Table IX-6 shows clearly the sensitivity of total revenue estimates to the

wide range of possible assumptions. Based on the assumptions of price,

price elasticity and consumer attitudes from Table IX-5, changes in annual

sales revenues range from a loss of nearly $4 billion in the short-run to a
IX-21

gain of almost $6 billion in the long-run. Obviously, this range of

estimates, as with those of Richardson and Nordhaus, assume that all other

relevant factors remain constant.

TABLE IX-6

CHANGE IN TOTAL REVENUE BASED ONI SALES ESTIMATES FROM TABLE IX-5

(MILLIONS OF DOLLARS)

ice

$0

100

250

320*

500

800

Percent

Voluntary

100

75

50

35

20

0

-1.0

$0

+598

+975

+800

+640

-512

Elasticity

Short Term

-1.5

$0

+497

+463

-20

-1,040

-3,968

+1

+2

+3

+5

-.1

$0

+739

,898

,385

,664

,708

Long Term

TM • •

$0

+699

+1,488

+1,734

+2,320

+2,944

INITIAL PRICE = $10,000

BASE SALES = 8 MILLION (Domestic)

*NHTSA COST ESTIMATE

CHANGE IN TOTAL REVENUE = NEW PRICE (e.g., $10,250) TIMES NEW QUANTITY

(e.g., 8 MILL - 100 THOUSAND I E = -1) MINUS BASE SALES TIMES INITIAL PRICE

(e.g., $80 BILL) = +$975 MILLION

3. Auto Industry Employment

This section concentrates on employment in the automobile manufacturing

industry, including the suppliers of parts, components and equipment which

make up the final product.16 if there is a decline in quantity sold,

Employment effects in the national economy are discussed in the next

section.
IX-22

reduced employment could be expected in automobile assembly and

manufacturing plants, as well as in the supplier industries such as tires,

glass, lighting equipment, exhaust systems, etc. However, if the drop in

demand results from an increase in price due to the installation of an

automatic restraint system then an offsetting increase in employment could

occur.17 Perhaps the best predictor of changes in industry employment is

total revenue. If demand is elastic — i.e., a percentage increase in

price causes a larger percentage decline in demand — then total revenue

will drop and to the extent that wages and salaries are a function of

industry income, employment will decline. By the same reasoning,

employment will increase if demand is inelastic.

The econometric model used by Richardson estimates employment effects on

the national economy but does not address employment for any specific

industry.''" Regarding offsetting employment in the air bag industries,

Richardson, in a later submission to the Docket, states "... employment

in the air bag production industry is not explicitly addressed in the

study. However, the interrelationship of variables within the model allow

employment increases in that industry to be addressed implicitly due to

increased expenditures on vehicles."^ She cites several problems

associated with industry - specific employment projections. (1) It is not

clear what percentages of air bag expenditures would go to labor, capital

and profit. (2) It is not known whether there would be additional

This assumes that the percentage of the product's value attributed to labor

remains approximately the same.

The Michigan Quarterly Econometric Model of the U.S. Economy.

December 19, 1983 Submission to Docket 74-14 Notice 3, pg. 7.
IX-23

expenditures for labor and materials or merely a diversion of resources

from other areas. (3) The extent to which the production would come from

foreign as opposed to domestic sources is unknown.

Richardson's projected revenue changes vary from an annual short term loss

of $2.6 billion to a gain of $3.3 billion in the long-run. To the extent

that industry sales revenues and employment are at least roughly related,

then the long-run annual employment gain from an assumed $3.3 billion

increase in revenue should correspond somewhat to the short-run annual

employment loss of nearly 200,000 associated with the $2.6 billion decrease

in revenue.20

Nlordhaus employed the DRI econometric model for his estimates of employment

impact.21 Assuming a price increase of $500 the DRI model yields an annual

long term increase in employment in the transportation equipment industry

of about 15,000 workers. He assumes that consumers perceive a value of the

restraint systems equal to their cost and that the full amount of the added

cost is distributed to labor, materials, investment and mark-up in a normal

fashion.

The following paragraphs describe NHTSA's estimates of employment effects

in the automobile industry.

20 The employment loss projection is for the national economy - not the

automotive industry specifically.

21 Data Resources, Inc. "Trendlong 1283"
IX-24

The initial step in estimating employment effects is to determine the

number of workers directly and indirectly engaged in the production of

passenger cars. Although employment data on the motor vehicle industry in

general are available from the Bureau of the Census, it is not possible to

isolate passenger car production from the total. Also, employees involved

with the production of passenger car parts and components working in

companies where primary output is not automotive are not included. A rough

approximation of the total number of employees (or full time equivalents)

engaged in the production of automobiles is calculated as follows:

The Census of Manufacturers, Bureau of the Census, lists 1981 employment in

the Motor Vehicle and Motor Vehicle Equipment Industry (SIC 371) at 695.6

thousand. The value added by the manufacturers is estimated at $34.8

billion. Therefore, the average value added per employee is approximately

$50,000.22 Assuming that this average holds for all employees either

directly or indirectly involved with automobile production and that the

4

total value added in producing 8 million cars at $10,000 per unit is $80.

billion, then the number employed would be approximately 1.6 million.

Included are employees involved with manufacturing, transporting,

financing, selling, etc., the final product.23 2^

Value added per employee in all manufacturing establishments in 1981 was

about $44,300.

Not included are those who provide goods and services for a car which is in

use, e.g. service stations, repair shops, etc., and employees engaged in

the production of new fixed plant and equipment used in the manufacture of

automobiles.

The $10,000 price is assumed to be equal to the total value added to that

vehicle.
IX-25

Similar results are obtained using Bureau of Labor Statistics data

published by MVMA.25 These data show that approximately 33,000

manufacturing workers were directly or indirectly employed for each $1

billion of final demand in 1972 dollars. Converting to 1981 dollars

results in approximately 33,000 employees for every $1.8 billion in sales

or about $55,000 per employee. Using an assumed level of $80 billion in

sales yields an estimate of about 1.45 million employees.26

For purposes of estimating employment losses or gains in the automobile

industry it is assumed that about 1.5 million persons will be directly or

indirectly employed in the production of 8 million domestic passenger cars.

The bases for predicting changes in employment are the total revenue

assumptions presented in Table IX-6. Total revenue is thought to be a

better indicator of employment than vehicle units sold because changes in

the vehicle's configuration may result in more or less workers needed per

unit of output. Total revenue is a measure of the value of the final

product(s) and of the resources used in its production. Therefore, to the

extent that the distribution of revenue among various factors of production

remain constant, it can be assumed that changes in revenue will result in

similar relative changes in resources expended for wages and salaries.

Table IX-7, based on percentage changes in revenue from Table IX-6, shows

potential effects on employment under various assumptions for price, price

elasticity and the percent of consumers willing to purchase a restraint at

Motor Vehicle Facts and Figures. Motor Vehicle Manufacturers

Association, 1ybj.

Non-manufacturing employees are not included.
IX-26

given prices. In the long-run, the employment effects appear positive

under all assumptions, reflecting the net increase in revenues from Table

IX-6. In the short-run an automatic restraint system costing $500 or more

may result in a significant negative impact on employment.

TABLE IX -7

CHANGE IN AUTO INDUSTRY EMPLOYMENT BASED ON ASSUMED

VARIATIONS IN ELASTICITY, PRICE AND PERCENT VOLUNTARY PURCHASES

rice

$0

100

250

320*

500

800

Percent

Voluntary

100

75

50

35

20

0

Short

-1.0

0

+11,200

(.75)

+18,200

(1.2)

+15,000

(1.0)

+12,000

(.80)

-9,600

(-.64)

Elasticity

Term

-1.5

0

+9,300

(.62)

+8,500

(.56)

-400

(-.025)

-19,500

(-.9)

-74,400

(-5.0)

Long

-.1

0

+13,900

(.92)

+35,600

(2.4)

+45,000

(3.0)

+68,700

(4.6)

+107,000

(7.1)

Term

-.5

0

+13,100

(.87)

+27,800

(1.9)

+32,500

(+2.2)

+43,500

(2.9)

+55,200

(3.7)

BASE EMPLOYMENT IN PASSENGER CAR PRODUCTION = 1.5 MILLION

NUMBERS IN PARENTHESES ARE PERCENT CHANGES

*NHTSA COST ESTIMATE

C. Macro-economic Effects of Price Changes

It is assumed that the major potential impacts of an automobile price

increase on the national economy can be measured by changes in employment,

Gross National Product and inflation.
IX-27

1. National Employment

A significant decline in automobile sales could nave a far-reaching impact

on the automobile industry, its suppliers and the industries which support

highway transportation, e.g., service stations, repair shops, recreational

facilities, etc.

Richardson projects nationwide short-term employment losses to range from

about 60,000 to 200,000 annually. Long-term changes are not estimated.

Nordhaus estimates employment gains in the transportation equipment

industry only. These gains range from 3,000 to 15,000 annually depending

on the price of the restraint system.

As discussed previously, there are an estimated 1.5 million persons

directly or indirectly engaged in the production of passenger cars. Under

the assumptions presented in Table IX-7 the employment effects of a

mandated restraint system range from an increase of 107 thousand workers to

a decrease of 74.4 thousand.

It is generally acknowledged that for every person working in a basic

industry such as manufacturing, additional jobs are generated to support

both the people employed and the product which is manufactured. With

respect to automobile manufacturing such jobs would be found in areas which

provide services to the employed persons (e.g., restaurants, recreational

facilities, etc.) and in areas which provide goods and services for

repairing, maintaining, insuring and financing the vehicle.
IX-28

Thus, if there is a significant long-term decline in autorvobile sales and

employment there is likely to be unemployment in these secondary support

industries. Assuming that 2 persons are employed in support industries for

every one employed in automobile manufacturing then, based on Table IX-7,

in the short-run at a price of $320 a maximum of 1,200 persons would be

without jobs nationally and in the long-run there would be a nationwide

increase of nearly 100,000 jobs.27

The above estimates oversimplify the real world in several ways,

particularly in that they assume no rigidities in either direction. For

example, an increase in labor requirements does not necessarily result in

the creation of more jobs. It could mean more overtime or a shift from

part-time to full-time. It is also possible that a structural realignment

could occur meaning only a transfer of workers from one area to another. A

loss in new car sales, if temporary, will not necessarily mean an immediate

employment loss in those firms supplying goods and services to employed

automobile workers. If new car sales decline, there may be a rise in

employment in businesses engaged in maintaining and repairing the existing

fleet. Also, it should be recognized that Table IX-7 is designed to

describe the extremes in terms of employment losses or gains.

Based on the DRI and Wharton models, Chase Manhattan Bank estimates that

employment losses in the Transportation Equipment and Allied industries

account for one-third to one-half of total job losses. A Cost-Benefit

Analysis of the 1979-1985 Fuel Economy Standards, Chase Manhattan Bank

1978.
IX-29

With a labor force of over 115 million projected for the mid 1980 decade it

would be difficult to conclude that a restraint system costing the consumer

no more than $500 would result in any measurable impact on national

employment or unemployment.

2. Gross National Product

Domestic automobile production historically has accounted for about 3

percent of U.S. Gross National Product. Automobile industry sales are

cyclical, and highly dependent on the state-of-the-economy and often a

leading indicator of both economic downturns and recoveries.

Assuming a restraint cost of $500, Table IX-6 shows that changes in

industry revenue will vary from $+3.7 billion to $-1.0 billion. With total

sales of $80 billion, a decrease of $1.0 billion represents a decline of

1.25 percent in industry revenue and about three-hundredths of one percent

of 1982 GNP. An increase of $3.7 billion in auto sales revenues increases

GNP by about one-tenth of one percent.

Based on the relationships between employment and total revenue the

indirect effects of losses or gains in automobile sales should be

proportionately equivalent to that of employment. Therefore, it is

estimated that an additional 2 dollars of indirect output will be lost or

gained for each dollar change in auto industry output. The range of

effects on GNP vary from a short run loss of over $3 billion (.10 percent)

to a long run gain of $11 billion (.40 percent). The effect on real as

opposed to nominal GNP will depend on whether the restraint system is

perceived as an improvement in the quality of the automobile. For
IX-30

example, if the restraint is not considered a quality improvement, the

estimated increase in GNP will not be as high in real terms. Quality vs.

inflationary changes are discussed in the next section.

Richardson projects short-term losses in GNP ranging from .115 to .355

percent - assuming a range of air bag prices from $300 to $600 and

elasticity from -.9 to -1.6. Applying these percentages to 1982 GNP yields

a decline of national output ranging from $3.5 to $10.6 billion.

Nordhaus, assuming an elasticity of -1 and a price increase of $500,

projects a gain in GNP of about one-tenth of 1 percent "... over.the

years following the rule."

Probably the only meaningful inference that can be drawn from these

analyses is that because of substantial uncertainty the ranges are wide and

if there are any perceptible effects on GNP they will occur primarily in

the short-run and in all likelihood will be minor.

3. Consumer Price Index

Under the assumptions described previously, Richardson predicts an increase

in the consumer price index of between .22 and .45 percent. However, these

estimates of inflationary impact were derived within the Michigan

Econometric Model and are not comparable to the Bureau of Labor Statistics1

consumer price index.
IX-31

Using the DRI econometric model, Nordhaus found that a $500 restraint

system would leave the consumer price index virtually unchanged.

If the consumer price of the same product increases due to greater costs or

greater demand, the increase is considered inflationary. However, if the

higher price is due to an improvement in the quality of the product which

is equal to or greater than the additional price, there is no effect on

inflation. (The Bureau of Labor Statistics generally considers higher

consumer costs due to safety equipment and other quality improvements as

increased consumption having no effect on the consumer price index.)

Therefore, at least in theory, the effect of a restraint system could range

from a decline in consumer prices (if the system results in an improvement

in the quality of the car which is greater than the additional price'8) to a

hypothetical increase in the price index even greater than the additional

cost if the restraint system has a negative effect on the quality of the

automobile.

For purposes of establishing a range of possible inflationary effects two

assumptions will be used. The first is that the increased quality of the

automobile will be exactly equal to the increased price. In this case, the

restraint system will have no effect on inflation. At the other end of the

range is the assumption that the restraint system adds zero value. The

effect on the price index in this situation can be estimated by multiplying

the price increase by the weight of new car purchases in the BLS price

index. In December 1982, BLS estimated that new cars comprised 3.506

percent of the consumer "market basket." Assuming a price increase of $500

28 This is equivalent to a decrease in price.
IX-32

(5.0 percent) the net effect on the CPI would be (.0351) (.05) or an

increase of .18 percent.29

D. Synthesis

Table IX-8 summarizes the differences and similarities among the

Richardson, Nordhaus, and NHTSA analyses of the economic effects of

automatic restraint requirements.

1. Initial Auto Sales and Prices

Richardson uses Bureau of Economic Analysis quarterly domestic sales and

transactions prices. Prices are in 1982 dollars. Nordhaus and NHTSA sales

volumes are rounded estimates based on DRI projections for 1983 and several

years beyond. Nordhaus includes imported vehicles. Except for rounding,

per unit price assumptions are essentially the same.

2. Restraint Price

Except for the exclusion of automatic belts in the Richardson study, the

assumed increase in automobile prices due to the installation of an

automatic restraint system are not significantly different. The NHTSA

analysis includes restraint prices at $0 and $800.^0 However, these

Since BLS does in fact consider safety improvements as an increase in

quality this example is purely hypothetical.

The potential for higher prices would be greater at low production volumes.
IX-33

extremes are not considered realistic and were presented only for

illustrative purposes. Table IX-8 assumes a range from $100 to $500 for

air bags.

3. Elasticity

The price elasticity estimates, which are indicators of consumer response,

have the highest level of uncertainty among all the assumptions. Given

this uncertainty, the range of estimates among the three analyses are

relatively close.

4. Reduction in Units Sold

Richardson assumes that consumers are indifferent to air bags and view

their cost as a simple price increase. Therefore, based on several

elasticity assumptions, sales will decline from 167 to 593 thousand in the

short run and 19 to 93 thousand in the long run. Nordhaus, assuming a

price of $88 for automatic belts, expects annual sales reductions to vary

from zero to 90,000, depending on how consumers value the systems. NHTSA

estimates annual sales losses to range from a low of six thousand in the

long run to a high of 480 thousand in the short run.
IX-34

5. Total Revenue

Changes in industry revenue are simply the difference between the previous

price times quantity sold and the new price times quantity sold. All three

analyses anticipate long run increases in total revenue.31 This implies

that the additional price more than compensates for any decrease in number

of units sold.

6. Employment

There is considerable variation in the estimates of changes in auto

industry and national employment which is accounted for primarily by

differences in assumptions on employment generated in the automatic

restraint industry. Although Richardson acknowledges the possibility of

new employment opportunities, the model used in the analysis is not capable

of explicitly identifying employment changes in specific industries. Thus,

the short term loss of 62,000 to 197,000 employees directly and indirectly

related to automobile production represents an estimate of national rather

than industry employment effects. The Nordhaus and NHTSA analyses both

assume that the restraint system will result in additional automotive

industry expenditures, part of which will be spent on wages and salaries.

The expected increases in revenue should not be construed as benefits to

society. They are a cost in terms of resource expenditures which could

have been used elsewhere. The benefits are measured by the lives saved

and injuries prevented to determine net societal benefits or costs.
IX-35

7. Gross National Product and The Consumer Price Index

The projection of effects on GNP and the price index have one thing in

common - the relative changes are so small and the number of assumptions

needed to perform the calculations are so large that very little confidence

can be placed in the estimates. Perhaps the only conclusion that can be

drawn is that theoretically there could be some increases or decreases in

GNP or an increase in aggregate consumer prices but such changes are not

likely to be perceptible in the real world.
TABLE 1X-8

ASSUMPTIONS AND ECONOMIC EFFECTS — SUMMARY

-Short Tei

Richardson Rordhaus NHTSA

Initial Annual Auto 6 •

Sales Volume (mil)

• •

Initial Auto Price $9f866

Restraint Price $300 to $600

Price Elaatieity -.9 to -1.6

of Demand

Reduction in Units 167 to 593

Sold (000)

Change In Total +$130 to -$2,556

Revenue (Mill)

CJumge in Auto

Industry Employment

(000)

Change in Rational -62 to -197

Employment (000)

Change in Cross -.U5X to -.355X

National Product

Consumer Price .215 to .449

Index — Percent

Increaae

10.0

$10,000

$88 to $500

-1

0 to 901

+3 tb +15*

0 to +

0 to .1

8.0

$10,000

$100 to $500

-1 to .-1.5

20 to 480

$+598to-1,040

+18 to -202

+54 to -603

+.10Zto-.10X5

0 to .176

6.1

$9,866

$300 to $600

-.1 to -.5

19 to 185

+$884 to $3,265

10.0

$10,000

$88 to $500

-.5

0 to 451

$500 to $1,000

+3 to +15

0 to +

+.1X

0 to .1

8.0

* $10,000

$100 to $500

-.1 to -.5

6 to 160

$+739to $3,664

+13 to +69 -H

X

1

GO

a\

+13 to +2O73

+.07X to +.18X5

0 to .176

Long Tern

Richardson Nordhaua NRTSA

jFor automatic belta at $88.

,>aaualiig 1.5 Billion direct and Indirect employment in auto aanufacturlng.

^Aaaumlng a Multiplier of 3.

Transportation Equipment Industry.

Assuming GNP at $3 trillion and a Multiplier of 3.
X-1

X. SMALL BUSINESS CONSIDERATIONS

An automatic restraint standard could have an effect on those small

businesses that would be involved in the production, maintenance or sale of

automatic restraints. The direction of this effect might be either

positive or negative. Before we can analyze this effect, it is necessary

to determine what is actually meant by a small business. After this

determination has been made, a brief industry profile of those affected

industries will precede an analysis of the effect of a change in restraint

requirements on them.

The definition of a small business varies from industry to industry. The

definition used to determine whether an industry needs to be considered as

a small business under the Regulatory Flexibility Act (Public Law 96-354)

is the one that is used to determine whether a business is small enough to

qualify for a Small Business Administration (SBA) loan. Under the

Regulatory Flexibility Act, rules are required to minimize significant

economic impacts on small businesses, small organizations, and small

governmental jurisdictions. The Small Business Size Standards applied in

this chapter are those revised and effective as of March 12, 1984.

A thorough review of businesses possibly affected by this final rule has

led to the conclusion that the seat belt, air bag, dealership and

automobile industries need to be analyzed. According to 13 CFR 121.2 a

manufacturer of motor vehicle parts and accessories with fewer than 500
X-2

employees is considered to be a small business. Because several of the

seat belt manufacturers, or their suppliers, and the current air bag

companies would fit this definition, they are discussed below.

A motor vehicle dealer (new and used) is considered to be a small business

if its annual receipts do not exceed $11.5 million. (13 CFR 121.2).

According to the 1983 National Automobile Dealers Association (NADA)

Annual, an average dealership had sales of $5.71 million in 1982. This

would mean that, according to the new definition, well over half of all

dealerships should be classified as small businesses.

A manufacturer of motor vehicles and passenger car bodies is a small

business if it has fewer than 1,000 employees. Because there are about

a dozen motor vehicle companies that fit this description, motor vehicle

manufacturers are briefly considered in this chapter.

A. Seat Belt Manufacturers

1. Industry Profile

The domestic seat belt industry began to grow in the 1960s, when seat belts

became standard equipment. Effective January 1, 1968, FMVSS 208 required

seat belts for all seating positions in passenger cars. Since most of the

companies that became involved in seat belt production were already

involved in related manufacturing activities, seat belt production was

basically an expansion of existing companies. These domestic producers

include seven major manufacturers, four independent primary webbing
X-3

TABLE X-1

THE SEAT BELT INDUSTRY

Safety Belt Manufacturers

1. Allied Chemical Corp.

Automotive Products Div.

Mt. Clemens, Michigan

. 2. American Safety Equipment Corp.

San Fernando, Calif.

3. General Safety Corp.

St. Clair Shores, Michigan

4. Firestone Industrial Products Div.

(Hamill Mfg. Co. ) Washington, Michigan

5. Irvin Industries

Madison Heights, Michigan

6. Pontonier Div. of Gateway Ind.

Chicago, Illinois

7. Fisher Body of GM

Independent Seat Belt Webbing Suppliers

T. Murdock Webbing Co.

Central Falls, Rhode Island

2. Narricot Industries, Inc.

Philadelphia, Pa.

3. Phoenix Trimming Co.

Northbrook, Illinois

4. Woven Electronics Co. (formerly Southern

Weaving Co. )

Greenville, South Carolina

Fibers Suppliers

T^ Allied Fibers and Plastics Div.

of Allied Corp.

Akron, Ohio

2. Celanese Fibers Co. Div.

Charlotte, North Carolina

3. Threads L). S.A. Div.

Gastonia, North Carolina

Metal Supplier

Header Products, Inc.

Romulus, Michigan

Total

.Employment

58,000

3,700

475

1,135

1,875

1,000

250**

420**

200**

750

58,000 (Allied Corp.)

41,500 (Celanese Corp.)

5,900** (Ti-Caro Corp. )

110

* Not available

Source: Employment from Dun & Bradstreet, 1983, with the exception of

employment at General Safety and Hamill which comes from Standard and

Poors, 1983.

**Source: Administrative office of specific company
X-4

suppliers, three fibers suppliers, and one metal supplier. (See

Table X-1. ) Due to the large numbers of seat belts required, the companies

tend to be automated.

In addition to listing the major seat belt manufacturers, Table X-1 also

lists total employment in each company. Some of the safety belt

manufacturing companies, such as Allied, are involved in numerous

manufacturing activities including the production of fibers, plastics, and

electronics. For these companies, seat belt manufacturing is just one of

their activities. The seat belt manufacturer with the lowest employment,

General Safety Corp., manufactures only seat belts and shoulder harnesses.

The five major seat belt manufacturers — Allied, American Safety, Hamill,

General Safety and Irvin — each make buckles, retractors, inertia reels

and pendulums. Of these seat belt manufacturers, only Allied and American

Safety Equipment make webbing. All five produce original equipment (95^100

percent) and four produce service equipment (0.1-5 percent). None of these

top five manufacturers produces aftermarket equipment.

The independent seat belt webbing suppliers are also listed in Table X-1

with their employment. Murdock Webbing, Narricot Industries, and Phoenix

Trimming are small businesses. Webbing production for automotive seat

belts accounts for 10-15 percent of Murdock's total production, 75 percent

of Narricot's, and 40 percent of Phoenix's.

Source: American Seat Belt Council, Arlington, Va.
X-5

Of the seat belt assemblers listed in Table X-1, Allied, American Safety

and Hamill each represent about 25 percent of the market. These three, in

addition to General Safety and Irvin, account for 93 percent of the market,

with Pontonier and Fisher Body comprising the remaining 7 percent.

Most automobile companies have more than one seat belt supplier as a

precaution against strikes, natural disasters, and other disruptions. The

table below shows the major seat belt suppliers and the automotive

manufacturers that they supply. The major seat belt manufacturers also

supply seat belts to Honda and Volkswagen in the U.S.

TABLE X-2

Automobile Company Seat Belt Suppliers

Supplier

Allied Corp

American Safety Equipment

Co.

Hamill

Auto Companies

Ford (60% of Allied belts)

GM

AMC

Chrysler

GM (major customer)

Ford

General Safety Cadillac (sole supplier)

Irvin Chrysler

Source: American Seat Belt Council, Arlington, VA.
X-6

There were about 29.8 million seat belts sold as original equipment in

automobiles in 1982. This number is derived from the number of

automobile sales by designated seating positions as discussed below. We

assume that only domestic automobiles have domestically-made belts. The

following table shows the number of domestic automobile sales by seating

position in 1982.

TABLE X-3

1982 AUTOMOBILE SALES by DESIGNATED

SEATING POSITION

 2 (Domestics)

Automobile

Front Seat Sales

2 Positions 3,107,639

3 Positions 2,649,019

Total 5,756,658

Rear Seat

0 Position 74,605

2 Positions 1,403,066

3 Positions 4,278,987

Total 5,756,658

Thus, 5,756,658 automobiles each had two 3-point belts or a total of 11.513

million 3-point belts (2 x 5,756,658). The positions for lap belts must be

added together as follows:

Positions Lap Belts

Front Center 2,649,019 2,649,019

Rear Side 5,682,053 11,364,106 (2 x 5,682,053)

Rear Center 4,278,987 4,278,987

Total 18,292,112

2

Source: Manufacturers' Specifications, Automotive News.
X-7

Thus, in 1982 there were 11.5 million 3-point belts and 18.3 million lap

belts.

Although there were 29.8 million seat belts sold as original equipment on

cars in 1982, more than this number were actually produced. The

industry must inventory enough replacement belts to last for about 10

years. The replacement belts must fit different model cars which require

slightly different belts.

2. Potential Effect of an Automatic Restraint Rule Requiring Air Bags on

the Seat Belt Industry

As discussed in the introduction, a manufacturer of motor vehicle parts

and accessories with fewer than 500 employees is considered to be a small

business. Among safety belt manufacturers, only General Safety Corp. falls

into this category.

The American Seat Belt Council docket comments of December 19, 1983, state

that four seat belt webbing suppliers, Murdock Webbing Co., Narricot

Industries, Inc., Phoenix Trimming Co., and Woven Electronics Corp., are

not "large and diversified firms with over 1,000 employees." According to

the company administrative offices, Murdock Webbing employs 250 people and

Narricot Industries employs 420 people. Phoenix, which only manufactures

webbing, employs 200 people. Woven, however, employs 750 people. In

addition to webbing, the company also manufactures tapes and electronic

components.
X-8

If 3-point belts were replaced by air bags and lap belts, there would be a

reduction in webbing requirements. In the following analysis we assume

that lap belts will be used with the air bag even though it is possible

that 3-point belts could be used as they are in the Mercedes-Benz. In the

Weight and Consumer Price Components of the 1980 General Motors Chevrolet

Citation and the 1981 Chrysler Plymouth Reliant teardown analysis, seat

belt webbing has been identified and given a weight. From these data, an

average weight has been estimated. An average 3-point belt weighs 0.4914

pounds while a lap belt weighs about 0.2225 pounds, i.e., 55 percent of a

3-point belt includes other than lap belt webbing, [1-(0.2225/D.4914 )=.55].

Thus, were lap belts substituted for 3-point belts there would be a

55 percent reduction in weight for each 3-point belt.

The data used earlier in this section to calculate numbers of seat belts

manufactured in 1982 will be used here to determine the total reduction in

webbing requirements. In 1982 there were 11.513 million 3-point belts and

18.292 million lap belts. Taking our weight assumptions as discussed

above, the total weight for all 3-pt. belts would be 5.657 million pounds:

(11.513 mill. 3-pt. belts )(0.4914 lbs.) = 5.657 mill. lbs.

Lap belts would total 4.070 million pounds:

(18.292 mill, lap belts)(0.2225 lbs.) = 4.070 mill. lbs.

Thus, 9.727 million pounds was the total weight of webbing in 1982:

5.657 mill. + 4.070 mill. = 9.727 mill. lbs.

Assuming that the 11.513 million 3-point belts became lap belts, they

would only weigh 0.2225 pounds each.

(11.513 mill, lap belts )(0.2225 lbs.) = 2.562 mill. lbs.
X-9

Thus, the 11.513 million lap belts would weigh only 2.562 million pounds

instead of 5.657 million pounds. Total webbing required would be 6.632

million pounds (2.562 + 4.070 = 6.632 mill. lbs.). This is a reduction in

webbing requirements of 32 percent.

If 3-point manual belts were replaced by three point automatic belts there

may be some change in the total webbing requirements, possibly a slight

increase. Due to the diversity of possible designs for three point

automatic belts, the agency is not able to quantify the change. Similarly

for two point automatic belts there may be some change in total webbing

requirement, but the agency is not able to estimate the effect due to the

wide diversity of possible designs. In any case, the effect is believed to

be small.

B. Air Bag Manufacturers

1. Industry Profile

This is an industry profile which, first, identifies the air- bag

manufacturers according to what aspect of production they are involved in

and, then, discusses possible labor requirements in the air bag industry.

The air bag industry—extant for 14 years—will be divided into four

subindustries for this analysis. These are (1) manufacturers of sensors,

(2) manufacturers of gas generators, (3) manufacturers of the air bag

fabric, and (4) assemblers. The air bag industry is currently small and

undeveloped, since few air bags are being manufactured. Thus, labor

requirements and prices are high. It is believed that as production
X-10

increases, the industry will become more automated and less labor

intensive. It was shown in Chapter VIII, that as more units are produced,

prices will drop.

Sensors

The air bag sensors are made primarily by Breed Corp, Lincoln Park, NJ, and

Technar, Arcadia, California. Breed employs roughly 100 people and the

majority of their revenue is associated with defense contracts. While

Breed has been involved in development work with Mercedes-Benz, it is

currently supplying sensors to Ford on a limited basis. Breed has

developed a mechanical system where the air bag fuse is set off by a

mechanical ball contained in the steering column. Breed has been involved

in sensors and fusing work for the government and the military.

Technar is supplying a sensor system and diagnostic module to Romeo Kojyo

for 500 highway patrol cars in six states. Technar employs about 100

people. This includes an engineering staff of seven and a

clerical/technical support staff of nine. The other personnel are engaged

in corporate management and manufacturing production. In addition to

designing and producing crash sensoring systems for automobiles, Technar

makes sensors for aircraft and missiles. Its products include

predominantly acceleration, pressure and temperature sensors.
X-11.

Gas Generators (Inflators)

There are currently three producers of air bag gas generators. Thiokol, in

Brigham City, UT, makes generators for Ford. Talley Industries, Mesa, AZ,

also makes inflators for use in their completed modules. Rocket Research

of Redmond, WA, has been involved in the past, and could become involved in

the future.

In the early '70s Bayern-Chemie, Gmbh, a German company, began to research

and develop future systems for occupant protection cooperatively with

Daimler-Benz AG. They were able to draw on their experience from rocket

technology to develop a solid gas generator. Bayern-Chemie, which produces

15-20,000 gas generators per year, also supplies gas generators to

Romeo Kojyo.

Air Bag Fabric

Air bag material basically consists of commercially available fabric

manufactured under rigorous specifications and coated with neoprene.

Currently, Uniroyal (a large company with nearly 50,000 employees) is the

only domestic company that is actually supplying this material and is the

principal supplier for Talley Industries. Several other domestic companies

are developing materials for possible use in air bag systems but as yet are

not involved in actual production. These include Nylco Corporation of

Clinton, Massachusetts and Milliken and Co. of Spartanburg, South Carolina.

Takata Kojyo of Japan is currently supplying this material in completed

modules to Romeo Kojyo.
X-12

Assemblers

Normally, an assembler will either assemble the three components of an air

bag in its own facility or subcontract to another company. Currently there

are two principal assemblers in the U.S., Romeo Kojyo and Talley

Industries.

Romeo Kojyo of Tempe, Arizona, is an example of a manufacturing company

which buys components and does its own assembly. It was formed to develop

and manufacture air bag restraint components and systems. Romeo Kojyo is

affiliated with Takata Kojyo, Japan. Takata Kojyo is supplying to Romeo

Kojyo the air bag module, the steering wheel and hub adaptor, and the

device connecting the entire system to the steering column. Romeo Kojyo is

a small business with less than 10 employees.

Talley Industries of Phoenix, Arizona manufactures its own inflators but

purchases fabric and other components from suppliers. It then sews the bag

and assembles a completed air bag module. Talley is currently supplying

air bags to both Ford and Breed for demonstration and experimental

development programs, and has a production line order of 5,000 units from

Ford Motor Co. for use in the GSA fleet air bag program. Talley is a

fairly large firm with roughly 3,800 employees.
X-13

2. Potential Effects of an Automatic Restraint Rule on the Air Bag

Industry

In this section, the labor requirements in the air bag industry are

estimated from unit costs and labor costs. According to one supplier, a

rule of thumb in the air bag industry is that cost can be divided

approximately into one-third for labor, one-third for materials and

one-third for overhead. This will vary somewhat according to the number

of units produced. In the following table, consumer cost per unit comes

from Chapter VIII. The percent cost of labor is based on industry sources

for 1,000, 10,000 and 1,000,000 units.4 The other labor cost percentages

have been assumed.

No. of Air

Bag Systems

1,000

10,000

100,000

300,000

1,000,000

2,500,000

Consumer Cost

Per Unit (incl .

Driver+Passenger

Side)

$1,500

$600

$350

$320

$310

TABLE X-4

Wholesale

Cost Per Unit*

(incl . Driver+

Passenger Side)

$1,320

$528

$308

$282

$273

% Cost

of Labor

50-60

33.3

25

20

20

20

No. ofEmployees

165

495

693

2,116

5,120

* Wholesale cost is derived by multiplying consumer cost by 88 percent.

, David Romeo, Romeo Kojyo, Tempe, Arizona.

Ibid.

X-15

The table shows that cost per unit and the cost of labor decline as the

operation becomes larger. The consumer cost is reduced by 12 percent to

provide wholesale costs. The percent cost of labor must be applied to

wholesale costs. The number of employees increases as production increases.

To derive an estimate for labor requirements, for example, we begin with a

wholesale cost of $282 million for one million air bags. Assuming a 20

percent labor requirement, the cost for labor would be $56.4 million.

($282 mill, x .20=$56.4 million). Based on discussions with current air

bag manufacturers, we assume that $10 is the hourly wage rate for air bag

production. This rate, however, must be marked up to reflect non-wage

compensation such as employer contributions to health and life insurance

plans, unemployment insurance, retirement plans, etc. These forms of •

compensation are estimated to be 25 percent of total compensation. (This

NHTSA estimate is based on a 1977 report prepared by the Bureau of Labor

Statistics.) The hourly wage rate of $10 is 75 percent, (1-.25) of the

total hourly wage rate. Thus, the hourly compensation rate that includes

wage and non-wage compensation is $13.33 (.75 x total hourly wage rate =

$10; total hourly wage rate = $10/.75 = $13.33).

Thus, 4.231 million are the number of hours spent per year producing air

bags (56.4 million/13.33 = 4.231 million). Assuming the average person

works 2,000 hours/year, there would be 2,116 employees making one million

air bags (4,231,000/2,000=2,116). The change in labor requirements as the

number of air bag systems change has been derived and is shown in Table X-4

David Romeo, Romeo Kojyo, Temple, Arizona.
X-16

and in Figure 1. It should be remembered that these numbers are an

approximation. While only 165 employees would be required to produce

10,000 units, 5,120 would be required to produce 2.5 million.

C. New Car Dealers and Auto Repair Establishments

A major concern for automobile dealers is that fewer cars will be sold as

automobile prices rise with automatic restraints. According to Chapter IX,

a price increase of $320 due to air bags might reduce sales from

approximately 20 to 80 thousand. There were about 25,000 franchised new

car dealerships in the U.S. in 1983.6 The following calculation determines

the average number of sales lost at each dealership:

20,000 to 80,000 = .8 to 3.2

25,000

Thus, there could be approximately 1 to 3 car sales lost on an annual basis

per dealership. In 1982, the average new car dealer sold roughly 320

vehicles valued at $3.5 million. The additional price for automatic

restraints, therefore, does not result in a significant decline in sales

per dealership.

As discussed in the introduction to this chapter, a significant number of

dealers were found to be small businesses. This finding was based on

13 CFR 121.2 which defined dealers as a small business based on annual

receipts. In addition, auto repair shops and gasoline service stations are

involved in the servicing and supplying of new automatic restraint

equipment. According to 13 CFR 121.2, an auto repair shop is considered to

7 NADA Data for 1983, NADA Industry Analysis Department.

Source for Vehicle Sales, Automotive News 1984 Market Data Book.

Source for Value of Sales, NADA Data for 1983.
X-17

be a small business if its annual receipts do not exceed $3.5 million, and

a gasoline service station is a small business if its annual receipts do

not exceed $4.5 million. In 1982, auto repair shops (independent and

franchised) sales were $20.8 billion based on 177,000 establishments. Thus,

the average sales per shop were $117,514 ($20,800,000,000/177,000 =

$117,514) which is well below $3.5 million. In 1982, gasoline service

station sales were $7.2 billion and there were 72,000 stations. Again, for

each service station, the sales are well below $4.5 million

($7,200,000,000/72,000 = $100,000). Thus, the auto repair shops and the

gasoline service stations would include a significant number of small

entities.

Automobile dealers are also concerned about increasing service and parts

supply system costs, including the training of those personnel involved

with fixing or selling the new part. Auto repair shops and gasoline

service stations face the same concerns to the degree that they will be

servicing and supplying new passive restraint equipment. The current manual

belt occupant protection system is fairly simple and is' treated like any

other repair or replacement item. Even the automatic belt systems that

exist today are not overly complicated from a mechanic's standpoint and, as

such, offer little problem to dealers in a repair or maintenance situation.

While replacement of a manual belt system is not a common occurrence, parts

are available if needed. Any dealer costs associated with these systems

are generally considered as normal operating or overhead costs.

a NADA Data for 1983, p. 10.

NADA Data for 1983, p. 10. 72,000 includes only those outlets that perform

"significant" repair work (i.e. those establishments that perform work

beyond simple oil change or lube jobs and/or those establishments that

receive at least 2% of total dollar revenue from service labor).
X-18

Several additional operating costs related to the use of air bags could be

incurred by dealers, repair shops, and service stations. Because air bag

systems are more sophisticated than belt systems, specialized technician

training and education programs will be necessary for dealership personnel.

The dealers expressed concerns at the recent hearings in Los Angeles,

Kansas City, and Washington, D.C. about whether technicians could be

promptly and effectively retrained to service, repair, and replace the more

complicated automatic restraint systems.

Other air bag associated costs to dealers and automotive repair shops are

the need for special tools, diagnostic equipment and remote detonating

devices for scrappage of air bag units; fire-proof, lockable storage

facilities; and the cost of compliance with additional environmental and

safety requirements. These costs, in addition to those two discussed

above, are, in part, associated with the potential concerns associated with

sodium azide, the most common air bag pi

a complete discussion on sodium azide.)

sodium azide, the most common air bag propellant. (See Chapter III for

Although several dealers voiced concern at the hearings about product

liability issues, Chapter III concludes that manufacturers and dealers do

not face an increased risk of liability with automatic restraints.

Automatic restraints are actually expected to reduce the number of product

liability claims as the number of people previously injured or killed in

crashes allegedly caused by vehicle manufacturing or design problems will

be protected by automatic restraints. Chapter III also explains that

information provided by insurers indicates that product liability insurance

is available to cover the automatic restraint-related claims experienced by

NADA docket comments, 74-14-N32-1680, p. 9-10.
X-19

vehicle manufacturers. Indemnification programs are also offered by

vehicle manufacturers and may eliminate some of the dealers' product

liability problems resulting from factors beyond their control.

The May 14, 1984, SNPRM included three alternatives that could pose

additional problems for automobile dealers. The first alternative would

provide a waiver from an automatic restraint requirement for cars sold to

residents of a state passing a mandatory use law (MUL). If such an

alternative were adopted, dealers could face additional expenses due to an

uncertain marketing situation. As several docket commenters point out,

there could be an inharmonious patchwork of states thoughout the country

regarding MULs. Some states would have waivers while in adjacent states

automatic restraints might be required. Still others could have

legislation or waivers pending. It could be complicated for a dealer with

an interstate market to inventory cars and assure the sale of appropriately

configured cars.

Dealers could encounter difficult situations as consumers cross state lines

to buy vehicles. One docket comment provided an example of this type of

situation with the State of California and its emission control regulation.

Californians in major population centers, located at a considerable

distance from the border, were crossing the border to buy vehicles. A more

intense situation could occur on the East Coast where drivers are more

11 frequently entering and exiting nearby states. However, no data are

available to quantify any potential loss of business.

TT Volkswagen of American, Inc., docket comments, 74-14-N35-046, p.12,
X-20

The second alternative that would present problems for the dealer is the

mandatory demonstration program which would require automobile companies to

equip five percent of their passenger cars with automatic restraints for

four years. The dealers, in addition to the automotive companies, could

largely bear the cost of such a program. In the case of the 1974-76

air-bag-equipped GM cars and of the 1978-80 automatic-belt-equipped

Chevettes, for example, the franchised dealers were apparently adversely

affected. At the October 1983 hearings on the NPRM, General Motors dealers

testified that the vehicles with automatic restraints often had to be

discounted by at least the price of the device in order that such vehicles

12

could be removed from inventory and prevent rising floor plan costs.

However, since the demonstration program would only cover a small part of

total dealer inventory, such losses are not expected to be significant.

The probability that a similar problem could occur with another alternative

raised in the SNPRM, that would rescind automatic restraint requirements

if a certain percent of the states passed MULs, was also considered. It is

possible that if this alternative was selected and the requirements for

rescission were reached only after initial production of automatic

restraints was begun, some dealers might have inventories of vehicles

equipped with automatic restraints. In the event that consumers

considered these vehicles less desirable than vehicles with regular

restraint systems, this could result in lost revenue for the affected

dealerships. However, no losses would occur if effective marketing

programs created a demand for these vehicles.

T2

National Automobile Dealers Association (NADA) docket comments,

74_14_N35-066, p.9.
X-21

Further, any adverse impact of this changeover could be avoided by

improving public acceptance of automatic restraints. Public education

programs and media advertising aimed at educating the public on the nature

and importance of properly used safety devices could play an important role

in overcoming any negative perceptions and improving overall market demand

for vehicles equipped with automatic restraints. If portions of the

vehicle fleet are gradually equipped with automatic restraints, consumers

should become accustomed to their operation and effectiveness prior to the

point where general unfamiliarity might result in rejection of automatic

restraints to the extent that sales would be adversely affected.

D. Automobile Manufacturers

For the automobile manufacturing industry, companies that employ fewer than

1,000 persons are defined as small businesses under 13 CFR 121.2.

Currently eleven domestic companies fit this definition. The largest of

these companies are Avanti, of South Bend, Indiana, with 150 employees and

Excalibur Automobile Corporation in Milwaukee, Wisconsin, with 125

employees. Production for all eleven of these small companies in 1982

totalled 924 vehicles. Typically the vehicles manufactured by these

companies are either high performance vehicles, custom or specialty

vehicles, or reproductions.
X-22

On a per car basis, both development and production costs for small

manufacturers are typically much higher than those for larger manufacturers

that can mass produce vehicles. In addition, the development time needed

to incorporate new safety features into their vehicles may be longer since

they may not have current in-house expertise with new technologies. Both

of these factors will serve to limit the ability of small automobile

manufacturers to incorporate automatic restraints in their vehicles in an

efficient and competitive manner. In particular, air bag requirements

would result in price increases significantly larger than those that would

be needed on mass produced vehicles. It should be noted however, that

custom or specialty vehicles are frequently sold primarily to affluent

customers and may thus be relatively unaffected by price changes.

E. Conclusions

There are numerous small enterprises involved in the manufacture, sale and

maintenance of automatic restraints. While the effect of most alternatives

is expected to be minor, there are several exceptions. Potential

significant effects are summarized as follows:

Seat Belt Industry

One safety belt manufacturer and 3 independent seat belt webbing suppliers

are identified as small businesses. The safety belt manufacturer is

engaged solely in seat belt related activities. Automotive safety belt

webbing accounts for 10 to 75 percent of the webbing suppliers' production.

The estimated 32 percent reduction in seat belt webbing requirements that

could result from an all air bag requirement could have a significant
X-23

adverse impact on these firms, with possible losses averaging up to 1/3 of

current revenue derived from seat belt related activities. The exact

number of employees that are involved with seat belt production for these

firms is unknown, but with roughly 1300 jobs potentially involved, it

appears that up to several hundred jobs could be eliminated from small

businesses in this industry, if air bags were required on all cars and lap

belts replaced three point belts in front outboard seating positions.

Alternatives requiring air bag installation in fewer positions or fewer

vehicles would have proportionally smaller effects on this industry.

Further, a requirement for 3-point belts rather than lap belts with air

bags would completely eliminate any potential adverse effects on this

industry.

Air Bag Industry

At this time, domestic air bag production is limited primarily to small

fleet purchases and research efforts. Although several small firms are

involved in this area, with one exception, they do not appear to be

financially dependent on air bag production. Further, none of the

alternatives under consideration by DOT would require limits on air bag

production. Therefore, no adverse effects are anticipated for this

industry as a result of this rulemaking. Selection of an alternative that

requires air bags, however, would cause tremendous growth in this industry,

involving potential revenues of roughly three billion dollars annually. It

is likely that most of this growth would go to existing producers, but that

a significant share would be taken by other companies that are currently

producing related products.
X-24

New Car Dealers

Many new car dealers qualify as small businesses. Concerns were expressed

by dealer organizations about a number of issues including lost sales,

maintenance problems, and product liability. As previously discussed,

these are not expected to be significant problems. However, the

alternative which would require waivers of automatic restraint requirements

for residents of states with mandatory belt use laws could present

significant, though unquantifiable problems for new car dealers in terms of

inventory control, distribution, and sales imbalances near state lines.

The alternative which would rescind automatic restraint requirements if a

certain percent of all states passed MULs could result in some losses to

dealerships rf_ consumers rejected the automatic restraints already

installed on large inventories of passenger cars. Such losses, of course,

would not occur if sufficient consumer demand was generated for automatic

restraint equipped cars through effective public information and education

programs.

Automobile Manufacturers

Potentially, the eleven automobile manufacturers that qualify as small

businesses could be adversely affected by any alternative that requires air

bag installation in their vehicles. The high cost of these devices, when

installed in low volume production vehicles, could adversely affect either
X-25

sales or profit margins. However, it should be noted that many of the

vehicles sold by these companies are specialty vehicles, custom vehicles,

or reproductions and such vehicles, which are often sold to affluent

customers, are relatively unaffected by price changes. The extent of

the adverse effect on this industry is therefore uncertain.

Repair Shops and Garages

No significant effects are expected to result from this rulemaking. If air

bags are required, repair establishments will need to purchase tools,

equipment, and storage facilities for air bag removal and replacement.

However, as with all other capital investments needed to properly service

today's sophisticated passenger vehicles, these costs would ultimately be

recouped through charges for the service they are intended to provide.
XI. PUBLIC OPINION AND MARKET ACCEPTANCE

Public acceptability of automatic restraint systems is an important issue

in this rulemaking, as it has been throughout the history of the automatic

occupant protection standard. As stated in the NPRM, public acceptance is

important to the success of Federal efforts to increase automotive safety.

Temporary safety gains are possible with unpopular and restrictive safety

regulations, but if a sufficient number of people dislike a device enough

not to use it, the potential safety benefits of the rule will not be

realized.

That the agency must consider public acceptance in this rulemaking is

beyond question. According to a ruling by the D.C. Court of Appeals, NHTSA

cannot fulfill its statutory requirements unless it considers popular

reaction; without public cooperation there can be no assurance that a

safety system can "meet the need for motor vehicle safety" and "it would be

difficult to term 'practicable' a system, like the ignition interlock, that

so annoyed motorists that they deactivated it."'' However, there is

considerable controversy concerning the proper interpretation of public

acceptance. In a memorandum filed after the NPRM comment period closed,

State Farm Mutual Automobile Insurance Company argued that public opinion

data are largely irrelevant, and that public acceptability is only to be

considered to the extent that people will render any automatic restraint

system useless by disabling it. In an effort to clarify the issue, the

Pacific Legal Foundation et al. v. Department of Transportation, 593 F. 2d

1338 (D.C. Car. 1979).
XI-2

Department sougit additional comments on this issue in the SNPRM on State

Farm's intepretation of public acceptability.

Docket Comments

In response to the NPRM, the Department received an overwhelming number of

conments from the public - over 8000. The vast majority of these comments

were from individuals, expressing strong views about automatic restraints,

primarily air bags. While many of these comments were inspired by news

releases or mailings from interested groups, such as automobile

manufacturers, consumer groups, etc., there were still substantial numbers

of individual commenters registering their own opinion. Most of the

comments against automatic restraints, the bulk of which were against air

bags, were based on perceptions of system malfunction (inadvertent

deployment), fear of injury/entrapment and high cost. They indicate a

substantial lack of information and understanding among the public of the

characteristics of automatic restraint systems and, more importantly, of

the significant role of restraints in preventing fatalities and injuries.

On the issue of interpretation of public acceptance in the SNPRM, 29 of the

130 commenters submitted their views. The insurance companies concurred

with State Farm's interpretation. Of the responding manufacturers, one

(Renault) accepted the State Farm interpretation, four rejected it, and

five expressed no opinion. Two of the responding states endorsed the State

Farm position and two were opposed.
XI-3

State Farm reiterated its position that "public reaction...has regulatory

significance only if it is ranslated into behavior" and automatic

restraints are disabled. Until this occurs, any activity—or lack

thereof—should be considered as acceptance. The lack of widespread

resistance would thus be a "tacit vote of public approval". It argued

further that the legislative history of the Vehicle Safety Act made it

clear that safety was the overriding consideration in implementing the Act.

Thus, more weight should be given to the safety benefits of a contemplated

safety requirement than to the public acceptability of the devices used to .

comply with that requirement.

Allstate, the Insurance Institute for Highway Safety (IIHS), the Institute

of Transportation Engineers (ITE), the State of Washington and the American

Insurance Association (AIA) supported the State Farm interpretation of

acceptabilty as being relevant only to the extent it resulted in fewer

benefits. Allstate noted that if public acceptance is to be a deciding

factor in this rulemaking, then DOT should repeal the requirement for

manual belts since nearly 90 percent of the population "rejects" them. The

State of Washington doubts that more than a few people will take the time

to render passive restraints inoperable and the IIHS reviewed prior studies

to show the extent of the public's desire for passive restraints. The ITE

agreed that complying with public opinion polls should not be the agency's

goal while the AIA claimed the proper standard of interpretation is public

acquiesence, not public preference. AIA also argued that automatic

restraints only require toleration, not action (as do manual belts) and

that their purpose is to be effective, not popular.
XI-4

Auto manufacturers characterized State Farm's view of the subject as too

narrow an oversimplification (National Automobile Dealers Association); not

consistent with legislative history, judicial precedent or prior positions

of DOT (Motor Vehicle Manufacturers Association); an unacceptably narrow

interpretation (Chrysler, American Motors); and [should be] broader (Ford).

Volkswagen stated that public acceptability is two-faceted, with both the

State Farm position and the public popularity issue being equally

important. Ford stated that public acceptance involves far broader issues

than disabling unwelcome equipment. The Pacific Legal Foundation (PLF) and

Consumer Alert stated that the issue of public acceptance is not limited to

the sole question of deactivating mandatory automatic restraints; it

encompasses all factors which may affect DOT's performance of its statutory

duties. Several commentors (Chrysler, Toyota, VW, NADA, and PLF) believe

the interlock analogy is valid in the case of FMVSS 208. They claim that

the interlock requirement probably had a favorable benefit/cost ratio and

was only "rejected" by 33 percent of the people; yet a consumer backlash

resulted in the defeat of the rule through legislation. Chrysler argues

that in the narrow sense of the State Farm interpretation of public

acceptability the interlock was a success: belt use increased and traffic

safety improved. However, in the broader sense it failed since it was

repealed by the Congress.

This position was also argued by PLF which stated that DOT, when

prescribing rules, must consider the statutory mandate of whether the rule

"will contribute to carrying out the purposes of [the] Act." They contend

that another interlock-type rule, with subsequent rejection, does not

comply with this criterion. Honda cites consumer acceptance as a key
XI-5

factor. In urging a broader interpretation of public acceptability,

commentors cited factors such as the actual deaclivation or disabling of

devices (PLF, NADA, MVMA); a delay in purchasing or a change in purchasing

decisions (PLF, NADA, MVMA, American Motors); risk compensation (PLF);

expressions of opposition (NADA); and advocating legislative recission

(Toyota, Motor Voters). Motor Voters, a California consumer group,

expressed concern that given an option, manufacturers would elect to

install cumbersome automatic belts with the intent of defeating the

standard legislatively, and that this outcome would be particularly likely

if the belt design made disconnection difficult. MVMA submitted a

memorandum of law, and stated that public acceptability is part of the "all

relevant factors" considered under the Act. Two 1974 congressional actions

are cited as illustrating what is acceptable: the interlock ban, and the

congressional review of a mandatory automatic restraint rule (Senate debate

on 1974 Federal highway bill). MVMA further stated that the State Farm

interpretation includes an "erroneous view": future consequences "cannot be

ignored simply because they are matters of future probability that do not

admit of precise measurement."

The manufacturers stated that nondetachable belts would raise consumer

acceptance problems because they are more coercive than are current belts.

This expectation is based in part on the interlock experience. NADA stated

that the experience with VW Rabbits, Toyota Cressidas and GM Chevettes

indicates a lack of consumer acceptance of automatic belt systems and that

the GM experience with air bag cars shows a similar lack of consumer

acceptance. NADA argued further that the Breed airbag inflator, because of
XI-6

its ease of installation, will encourage deactivation while Mercedes

claimed they are unaware of any instances of deactivation o; their airbag

system (34,500 vehicles with airbags have been sold).

Various findings were provided on the attitude of the public toward

automatic restraints. Consumer Alert provided a public opinion poll

showing that fewer than 15 percent of the respondents wanted mandatory

automatic restraints. Public Citizen submitted a public opinion poll which

it viewed as showing a clear preference for automatic restraints,

especially air bags. IIH5 cited a recent public opinion poll indicating

that 56 percent of the respondents favored requiring automatic restraints

on new cars as standard equipment and 37 percent favored requiring that

that type of restraint be offered as an option. The American Automobile

Association stated that while consumers may not rush to purchase automatic

restraints as options where manual belts were original equipment, they

would accept automatic restraints as original equipment, particularly if

they could choose between the various types of automatic restraints. Other

groups argued that the increased protection against facial, spinal and head

injuries afforded by air bags would result in consumers choosing air bags

as the preferred automatic restraint, it they are allowed to make the

choice. Most of these groups indicated that air bags are less intrusive

than automatic belts, and would therefore be more readily accepted by the

public.

The SNPRM raised a second public acceptability issue: assuming that the

relevant factor is the number of people defeating the automatic restraints,

will enough people do this to preclude the achievement of the necessary
XI-7

safety benefits to outweigh the costs? While not all conmenters addressed

this issue, the responses received tended to fall again along two sides.

State Farm cited that "the standards' huge potential net social benefits

will be realized," while NADA cited the record that many "Americans have

disabled and will disable, devices...[;] such evidence clearly establishes

the lack of consumer acceptance...and the resultant lack of safety

benefits...."

The extensive public comments to the docket indicate that informed opinion

is strongly divided on the proper interpretation of what constitutes public

acceptance of automatic restraints for the purpose of this rulemaking. On

the other hand, the great majority of individuals commenting on automatic

restraints based their comments on insufficient information about the

benefits as well as the effectiveness and special features of the different

systems. Data and analyses that are germane to the various interpretations

are presented in this fihapter and Chapter V. Chapter V presents data on

usage of manual and automatic restraints and estimates a range of possible

future usage of automatic belts based on the public's demonstrated degree

of acceptance of manual belts, characteristics of manual and automatic

systems, and public attitudes toward them.
XI-8

Public Opinion Surveys

A number of surveys have been conducted over the last several years in

order to gain information concerning public attitudes on voluntary or

mandated automatic restraints. The issues or questions addressed by these

surveys which are covered in this section are pertinent to broad

considerations of public acceptance of automatic restraints, such as the

extent of public knowledge about automatic restraints; how the public feels

about the Federal government mandating automatic restraints in new cars or

state governments mandating the use of belts that are already in cars; how

much the public would be willing to pay for restraints; public attitudes

and preferences for alternative restraint systems; and restraint system

marketability.

In assessing the significance of survey responses on automatic restraint

issues, the fact that the driving public has little direct experience with

automatic restraints on which to base responses and form its views, should

be kept in mind. (Approximately 500,000 cars have been sold in the U.S.

with automatic belts, and about 12,000 cars have been sold with air bags.

The size of the current fleet is approximately 120 million passenger cars. )

Also, it should be emphasized that the current relevance of some of the

studies is uncertain. Depending on the issue and subject matter, consumer
XI-9

and public attitudes may change to greater or lesser degrees over time.

Responses to what are essentially philosophical questions such as whether

automatic restraints should be required equipment or whether use of manual

seat belts should be mandatory are likely to be influenced over time by the

level of public information and education and the publicity disseminated as

well as by general trends in public opinion. On the other hand, attitudes

on more concrete subjects or on issues with which respondents have had

direct experiences, while still subjective, might remain more relevant over

a longer period of time. For example, the attitude of people who have used

automatic restraints toward the comfort of their automatic system, would

probably remain relevant over time for that particular system. These

points concerning the relevance of past surveys on public attitudes should

be kept in mind.

Data gathering techniques used in the surveys whose results are presented,

included telephone, home, and workplace interviews; discussion groups; and

clinics. Information obtained varied from simple "yes" or "no" answers to

single questions to numerous and detailed responses to lengthy

questionnaires. While respondents who were surveyed were typically

randomly selected, nationally representative samples of licensed drivers or

heads of households, some surveys contacted owners of specific make and

model vehicles. Others contacted individuals in given geographical areas.

The reader is referred to individual survey reports for details on survey

methodologies and findings on facets of the surveys on automatic restraint

issues not covered herein.
XI-10

The main issues considered here are the following:

1) The extent of the public's awareness and knowledge of automatic

restraint systems;

2) Whether automatic restraints should be required through regulation or

whether it should be left to consumer choice;

3) How much the public is willing to pay for air bags;

4) Attitudes toward alternative systems - manual belts, automatic belts,

and air bags;

5) Attitudes toward mandatory safety belt usage laws; and

6) Marketing of air bags as optional equipment.

The methodologies and results of two recently performed surveys that were

provided to the docket are discussed at the end of this chapter. The

results of surveys on restraint usage are presented in Chapter V.

A. Awareness/Knowledge of Automatic Restraint Systems

Information on the degree to which the public is familiar with and

knowledgeable about automatic restraints is essential for gauging whether

results of public opinion surveys on automatic restraint issues are valid

indicators of public attitudes toward automatic restraints. Survey
XI-11

responses, however, must be used with caution if the respondents have

little knowledge of or experience with the systems about which they are

.being questioned.

Compared with other issues, only a limited number of past surveys included

questions on public awareness/knowledge of automatic restraints. The

results of information gathered are presented below.

1. Air Bags

Considerably higher percentages of the interviewees reported

awareness/knowledge of air bags than automatic seat belts.

o 1976 Yankelovich2—". . . 62 percent of drivers (interviewed) indicate

they know what an air bag is when the term is mentioned to them."

o 1976 Market Research Group, Survey Data Research^ — 83 percent of

owners of new GM cars without air bags knew or had heard of air bags.

o 1978 Hart^—79 percent reported they had heard about the air bag system.

Of these respondents, 70 percent could volunteer at least one substantive

statement about their knowledge of the air bag system. That is, 55 percent

had some knowledge about the air bag system.

o 197B Teknekron^—When asked if they had heard of air bags or air

cushions, 93 percent of the respondents replied affirmatively. Of those

who heard of air bags, nearly 72 percent correctly described how air bags

worked.

2 "Driver Attitudes Toward Restraints," Yankelovich, Skelly, and White, Inc.,

September 1976, p. 21.

3 "A Passive Occupant Restraint System Study," Market Research Group, Inc.,

and Survey Data Research, Inc., December 1976.

4 "Public Attitudes Toward Passive Restraint Systems," DOT-HS-803-570,

Peter D. Hart Research Associates, Inc., August 1978, p. 41. .

^ "1978 Survey of Public Perceptions on Highway Safety," Teknekron, Inc.,

November 1978, p. 67.
XI-12

As noted above, the percentage of respondents reporting that they "knew" or

I

"heard of" air bags ranges from 62 to 93 percent.

2. Automatic Seat Belts

There were five surveys that asked about awareness/knowledge or experience

with automatic seat belt systems (ASB). In two of the surveys (1978 Hart^

and 1983 Insurance Institute for Highway Safety (IIHS7)) the respondents

consist of the general public (adult Americans who are either licensed

drivers or who live in households with at least one automobile). The

format of the Hart survey was a personal interview, that of the IIHS survey

was a telephone interview. The other three surveys were telephone interviews of owners of specific vehicle models that were equipped with

automatic seat belts or manual belts.

o 1978 Hart8 — in comparison to 79 percent for air bags, "only 15

percent say that they have heard anything about automatic seat belts."

o 1980 Opinion Research^—80 percent of ASB-equipped Chevette owners and

61 percent of ASB-equipped VW Rabbit owners first "found out about the ASB

system" after the purchase of their cars or through dealers/salespersons.

o 1981 Opinion Research^—74 percent of ASB-equipped Chevette owners and

65 percent of ASB Rabbit owners "first heard of or became aware of" the ASB

system at the dealers where the car was purchased.

6 Op. Cit.

^ "Public Opinion About Automobile Occupant Restraint," Insurance Institute

for Highway Safety, December 19,1983.

8 Op. Cit., p. 48.

° "Automatic Safety Belt Systems Owner Usage and Attitudes in GM Chevettes

and VW Rabbits (1980 models)," D0T-HS-B05-797 Opinion Research Corp.,

February 1981, p. 10.

'® "Automatic Safety Belt Systems: Changes in Usage Over Time in GM Chevettes

and VW Rabbits," DOT-HS-806-058, Opinion Research Corp., August 1981, p. 13.
XI-13

o 1981 JWK International—76 percent of ASB equipped Toyota owners "first

heart of or became aware of" the ASB system at the dealers where the car

was (urchased.

o 1983 IIHS12 — 4 percent indicate that they presently or in the past have

owned a car with an ASB system. An additional 10 percent indicate they

have been in someone else's car equipped with ASB.

From the above, it is clear that only a small percentage of the driving

public is familiar with the ASB system.

B. Government's Role in Making Automatic Restraints Available

This section summarizes survey findings on the question of whether the

public favors the Federal Government's requiring manufacturers to install

automatic restraint systems in all new cars. It also summarizes the

limited information available on the public's desire to have a choice of

purchasing vehicles equipped with either automatic or manual restraints,

depending on individual preferences. Surveys did not address other

possibilities, such as a mandated demonstration program in which a

percentage of cars would be produced with automatic restraints, or a

phase-in of a limited number of automatic restraint-equipped vehicles each

year.

This review of public opinion on whether the government should mandate

automatic restraints should not be interpreted as indicating that this

issue, per se, is important to the decision on an automatic restraint

rule. Costs and benefits of the options are the critical inputs to the

11 "Automatic Safety Belt Usage in 1981 Toyotas," DOT-HS-806-146, JWK

International Corp., February 1981, p. 16.

12 Op. Cit.
XI-14

decision. However, this information is one indicator of the degree to

which the public would accept and use automatic restraint systems, and

this latter consideration is germane to the final decision.

Before discussing survey results, it should be emphasized that the

Department held public hearings on this rulemaking on occupant crash

protection in Washington, D.C., Kansas City, and Los Angeles at which

testimony was heard from individuals, representatives from the automobile

and insurance industries, consumer organizations, government officials, and

others. In addition, more than 8,000 comments were received in the docket.

While witnesses and commenters do not represent a randomly selected

cross-section of the American population, their points of view span all

sides of the issues and enable the Department to not only consider the

arguments supporting various positions but also to gain some appreciation

of the depth of feeling of those that testified and commented. It is

typically not possible to obtain such depth of information in public

opinion surveys.

Of the surveys reviewed, 12 asked respondents whether they favored or

opposed a requirement that air bags/automatic restraints be required in new

cars, with no option being provided the respondents for indicating opinions

that new car purchasers should have a choice of buying cars with or without

automatic restraints. Only 2 of 12 surveys included a cost figure for

respondents to consider in answering the question on a government requirement for automatic restraints. Most surveys did nothing to ascertain the

degree of knowledge respondents had about automatic restraints, nor did
XI-15

they provide them with much, if any, information about the systems. Table

XI—1 indicates the public'i response on surveys on whether the Federal

Government should require automatic restraints in all new cars. Of the 12

surveys included in the table, 8 found the respondents to be in favor of

the Government's requiring automatic restraints. The deficiencies in

survey methodologies not withstanding, these results indicate that while

many people do not favor a government mandate for automatic restraints on

all new cars (as many people do not favor any type of mandated piece of

equipment), there is also a substantial number who state they are willing

to purchase cars with automatic restraints. This suggests that public

reaction to the concept of automatic restraints can initially be expected

to be mixed. Since many people either are unaware of, or have not

personally experienced-such restraint systems, public information and

education efforts that describe the automatic systems — how they operate

and their advantages — and how they have successfully worked during actual

crashes, might increase the degree to which the public favors automatic

restraints and their mandated installation. Public education, enhanced by

the availability of the devices to demonstrate their performance, will be

the ultimate factors affecting the public's reaction.
XI-16

TABLE ' 1-1

RESULTS OF SURVEYS ASKING WHETHER RESPONDENTS

FAVORED REGULATIONS REQUIRING AUTOMATIC RESTRAINTS

IN ALL NEW CARS

SURVEY

CONDUCTED

BY

SPONSORED

BY

YEAR

OF

SURVEY

GOVERNMENT REGULATION

REQUIRING AUTOMATIC

RESTRAINTS

RESTRAINT

SYSTEM

QUESTIONED

ABOUT

COST

INFORMATION

PROVIDED

MeGinley

Maritz Market

Research

0. D. Power

Market Opinion

Research

Area Market

Research

Associates

VA. Hwy. Board of

Trans. Research

Council

Caddell

Hart

Teknekron

Gallup Poll

Market Research

Group, Survey

Data Research

Yankelovich

NHTSA

GM

NHTSA

New York

Times

Arkansas

Dept. of

Pub. Saf.

VA. Dept.

of Public

Safety

NHTSA

NHTSA

GM

MVMA

19B4 •

1983

1982

1980

1979

1978

1978

1978

1978

1977

1976

1976

Favor

%

41

51

35

19

23

45

72

55

47

58

73

46

39

15

29

Oppose

S

36

49

65

81

53

32

28

41

44

28

24

37

54

70

62

No Opinion

23

22

23

9

14

11

17

7

15

Air Bags

Air Bags

Air Bags

Air Bags

Air Bags

Air Bags

Air Bags

Air Bags or

Auto Belts

Air Bags

Air Bags or

Auto Belts

Air Bags or

Similar

Device

Air Bags

Air Bags

Air Bags

$300

$100

$320

$500

None

None

None

None

None

None

None

None

"Significant

increase in

car prices".

None

COMMENTS

Cost information

part of another

question.

1st line — owners of air

bag equipped cars.

2nd line — owners of cars

without air bags.

Based on 628 of respondents

who knew what an air bag

was.
XI-17

References to Table XI-1.

1. McGinley Marketing Research, Inc., "Trends in Public Knowledge and

Attitudes Toward Occupant Restraint Systems," Monthly Report, February

1984.

2. Maritz Market Research, "Passive Restraint Study," November 30, 1983.

3. J.D. Power and Associates, "1982 Automotive Consumers Profile,"

January 1982.

A. Market Opinion Research, Inc., Detroit, Poll on Automotive Issues,

April 1980.

5. Area Market Research Associates, "Arkansas Motorists: The 55 mph

Speed Limit and Safety Devices," July 1979.

6. Virginia Highway and Transportation Research Council, Poll of

Virginia Drivers, 1979.

7. Patrick Caddell, Poll of U.S. Drivers, 1978.

8. Peter D. Hart, Research Associates, Inc., "Public Attitudes Toward

Passive Restraint Systems," DOT-HS-803-570, August 1978.

9. Teknekron, Inc., "1978 Survey of Public Perceptions on Highway Safety,"

DOT-HS-803-179, November 1578.

10. Gallup Poll of U.S. Adults, July 1977.

11. Market Research Group, Inc. and Survey Data Research, Inc., "A

Passive Occupant Restraint System Study," December 20, 1976.

12. Yankelovich, Skelly, and White, Inc., "Driver Attitudes Toward

Restraints," September 1976.
XI-18

Of the materials reviewed, two sets of focus group discussions dealt

partially with the issue of consumer choice, and one survey directly

targeted the issue.13 /\ major reason for the dearth of surveys addressing

this issue would appear to be that from June 1977 to October 1981 a Federal

regulation was in place requiring that automatic restraints be installed in

new cars beginning with model year 1982 large cars (later changed to model

year 1983). That made consumer choice a moot issue over the period.

A series of focus group discussions in 1979 sponsored by NHTSA and conducted by National Analysts, Inc.,14 while oriented toward vehicle fuel

efficiency issues, arrived at the following conclusion on discussions of

the automatic restraint topic: "... most of those expressing an opinion

on passive restraints opposed the Government making them mandatory, and

many asked for a choice between passive belts and air bags" (p. 42). Focus

group discussions led by Market Facts, Inc.15 in 1980 reached the consensus

that both air bags and automatic belts should be available. Acceptance of

the requirement for automatic restraints was divided between those who felt

that the safety benefits would outweigh the increase in cost and the

possible loss of the freedom to choose, and those who questioned the

effectiveness and reliability of automatic restraints and opposed increased

costs and loss of freedom.

Implicit in the concept of consumer choice is that the option of

purchasing new cars with automatic restraints will be available, as the

result of regulation or otherwise.

"Consumer Orientation Toward Fuel Efficient Vehicles: Fourth Cycle,"

National Analysts, Inc., March 1980.

"A Study of Consumer Behavior Toward Fuel Efficient Vehicles, Interim

Report," Market Facts, Inc., July 1980.
XI-19

A survey focusing directly on the consumer choice issue was commissioned

by Consumer Alert, Inc., and conducted by Finkelstein and Associates ii

1978.16 Respondents' opinions on the consumer choice issue were as follows:

- Air bags seem to be an effective automobile safety

system and the government is right to require that

all new cars have them, even though consumers will

loose their freedom of choice. 15.2%

- Air bags have not been shown to be the most

efficient or effective safety system, and for this

reason the government is premature in requiring

that all new cars have them. 19.7%

- Regardless of the merits or the faults of the air

bag, the government has no right to require

consumers to pay for this automobile safety system,

if they don't want it. 58.5%

- Don't know. 6.5*0

In the above survey, the respondent was informed that the air bag option on

a new car would cost $200 ($304 in 1982 dollars), the replacement cost for

an air bag that deployed would be $500 ($760), and that air bags were

ineffective in certain types of crashes. The survey did not point out to

respondents that insurance would, in most instances, probably cover air bag

replacement costs. It also did not address the potential magnitude of

safety benefits—and assumed car, health, and life insurance cost

reductions—associated with air bags.

"National Attitudinal Survey — Air Bags," Arthur 0. Finkelstein and Associates,

July 1978.
XI-20

C. How Much Would the Public Pay for Air Bags?

Several surveys have inquired about the extra cost the public would be

willing to incur in purchasing a car with an air bag. Answers to this

question to some extent act as gauges of the public's interest and

commitment to air bag systems. Of course, implicit in the relevance of

this question of willingness to pay is that the new car purchaser will have

a choice of whether to purchase an air bag equipped car; otherwise, the

question would be moot since purchasers would have to pay the extra cost

for the system if they wanted a new car. In addition, the cost of mandated

safety equipment is part of the base price of a new car and is thus not

known to consumers and may be unlikely to engender any adverse reaction.

If the price of the car increases significantly over the prior year, with

no apparent improvement other than the installation of air bags, some

adverse reaction is possible.

Table XI-2 summarizes surveys that addressed the issue of how much the

public would be willing to pay for an air bag system. While surveys varied

to some extent on how this question was put to the public, the degree of

attention and depth of probing devoted to this issue, and the particular

cost categories specified in the questioning, the table attempts to

summarize survey findings in a consistent fashion while recognizing that in

some instances data are not strictly comparable. Surveys included, while

spanning the 1971-1983 period, are clustered in the 1976-1978 time frame.
XI-21

TABLE XI-2

PERCENT OF THC PUBLIC HILLING TO PAY CIVEN

MOUNTS FOR AIR BAG SYSTEMS

SURVEY CONDUCTED

BY

1IHS

J. D. Power-^

VA. Hwy and

Tranap. Res.

Council

Hart^

Flnkelstein

Allstate

Washington Traffic

Safsty Comm.

General Motors

Yankelovich, et al

Market Research

Group

General Motors

GROUP

SURVEYED

Adult Drivsrs <

U.S. Households

Virginia Drivers

U.S. Drivers

U.S. Drivers

U.S. Metro. Residents

Washington Rasidents

GM Small Car Owners

GM Large Car Owners

Ownera of Large GH

Cars with Bags

U.S. Orivers

Oldsmobils Owners

GH Car Owners

YEAR OF

SURVEY

1983

1982

1979

1978

1978

1977

1977

1976-77

1977

1976

1976

1976

1971

$0 $100 $200 $3C

10

6

81

91

1

5

X

OS

x 4:

80S

57*

56%

40%

51%

87%

49%

33%

35%

S

5-

56%

52%

4

/

-(1982 0

» tic

42%

S

X

6%

19%

26%

71%

29%

3 2 $

50%-^

lollars)-

0 $5C

2

45%

11%

14%

» $600 $700 $800 $90C

%(>$400

8%

4%

8%-

41%

7%

($1000) 1

4*

18

1/ The question of what the public would be willing to pay for air bags was asked in sevsrsl different ways in the surveys reviewed. Tor

example, sons surveys asked what respondents would be willing to pay, others whether they would be willing to buy the system at given coats;

some studies offered a choice of opting for no automatic restraint systems, while one sought public preference for sir bag versus automatic

belt systems given s set of cost differentisls between the two systems. This table attempts to summarize somewhat diapsrste surveys in s

useful fashion, while recognizing that in some instances dats srs not strictly comparable.

%J Eleven percent of the respondents could not provide s cost estimate. These 11 percent of the responses were ellocsted bsaed on the 89

percent responses.

2/ Respondents were asked to choose between air bag or automatic belt systems st various differences in cost for the two systems. For

this summery it is sasumed that sutomstic belts cost $80,

5/ Twenty percent or lsrge car, 32 percent of small car owners, and 4 percent of owners of large cars w'lth air bags ssid they would not

have air bags in their next cars even st no cost,

1/ The question on the maximum amount drivers would be willing to psy for air bags was summarized In the survey report only for the 62

percent of drivere who knew what an air bag was. And of this 62 percent, 61 percent were uncertain or did not know what they would be

willing to pay. The data presented hsrein, therefore, represent only 24 percent of the total sample. Also, to a limited degree, certain

assumptions hsd to bs employed to sub-divide the distribution of costs in the report.

§/ Percentages shown sre for responses to the question of whether the respondent felt the public would be "greatly interested" in the air

bag option at given prices.

"1/ Percent ages shown are Tor reaponses to the question of Aether the respondent felt the public would be "somewhat interested" in the sir

bag option at qiven prices.

fi/ Air bag selected over alternative systems with specified prices! No restraint • $0 — 5S, menusl belt system • $25-30 •- 20*,

automatic belt • $20-$25 — 25* (1971$).
XI-22

References to Table XI-2

1. Insurance Institute for Highway Safety, "Public Opinion About Automobile Occupant Restraint," December 19, 1982.

2. J.D. Power and Associates, "1982 Automotive Consumer Profile,"

3anuary 1982.

3. Virginia Highway and Transportation Research Council, Poll of

Virginia Drivers, 1979.

4. Peter D. Hart Research Associates, Inc., "Public Attitudes Toward

Passive Restraint Systems," DOT-HS-803-570, August 1978.

5. Arthur 3. Finkelstein and Associates, "National Attitudinal Survey —

Air Bags," July 1978.

6. Allstate Insurance Co., "1977 National Images Survey," November 1977.

7. Washington Traffic Safety Commission, "Air Bag Demonstration Survey,"

October 1977.

8. General Motors Corporation, Market Research Group, Inc., Survey Data

Research, Inc., "Passive Occupant Restraint System Study," 1976-1977.

9. Yankelovich, Skelly, and White, Inc., "Driver Attitudes Toward

Restraints," September 1976.

10. Market Research Group, Inc., "Air Cushion Restraint System, National

Consumer Research Study," May 1975.

11. General Motors Corporation, "Consumer Opinions Relative to Automotive

Safety Restraint Systems — Pilot Study," May 1971.
XI-23

Survey dollar values reported in the table are updated to 1982 dollars for

consistency and purposes of comparison. It should be recognized, however,

that this conversion of responses to 1982 dollars does not create strictly

comparable values, given the disproportionate increases in the prices of

various goods and services and fluctuations in real disposable and, particularly, discretionary income over the period.

The disparate results of the GM surveys indicate that greater differences

in responses will be attained when surveying groups of owners of different

sized cars than when surveying the general population of drivers. Owners

of small GM cars indicate they would be willing to pay less than owners of

larger GM cars for air bags. This may reflect the fact that the cost of

air bags would constitute a larger portion of the small car purchase price

than for large cars. This is not an unexpected response as purchasers of

small, less expensive cars would be expected to react in this manner to

relatively high priced options, be they air bags or air conditioners.

Their reaction also may reflect the somewhat greater usage of existing

manual belt systems by small car owners. Toward the upper end of the

scale, owners of large GM cars with air bags expressed strong support

for the system with 58 percent willing to pay over $500. Also, the Hart

Study found that 41 percent of those surveyed would be willing to pay over

$600 (1982$) for an air bag system, but in this survey respondents were

given the option of selecting either air bags or automatic belts at several

cost differentials; therefore, results place a value on respondents'
XI-24

preference for air bags compared to automatic belts but do not place a

value on the air bag system, per se. The IIH5 survey found that less than

half (47?o) would be willing to pay $200 for air bags; however, 18 percent

indicated they would pay as much as $1,000.

While the table shows these and some other disparities in survey findings

on the percentage of respondents who indicate they would pay given

amounts, due in part to how the questions were phrased and the options

presented the respondents, some general conclusions can be drawn. Only a

small percentage appears willing to pay more than $400 or would expect to

pay less than $100 for an air bag system. The majority of responses in

most surveys are clustered around the $200 and $300 cost categories,

covering a range of approximately $150-$350. Toward the upper end

of this cost range the driving public is roughly evenly divided in its

willingness to buy an air bag system, as an option. This suggests that a

substantial, potential market for air bags exists and that a significant

portion of the public would opt for them if they were priced within the

$150-$350 range and available in sufficient quantities. Again, it must be

pointed out that these results are only relevant to the above-mentioned

surveys, all but two of which are at least six years old, and to the

information on benefits (generally sparse) and costs provided by the survey

instrument. As experience with child restraint laws demonstrates—48

states passing such laws within six years—"public acceptance" can change

rather quickly.
XI-25

D. Attitudes Toward Alternative Restraint Systems — Manual Belts,

rutomatic Belts, and Air Bags

This section summarizes survey findings on individuals' preferences among

restraint systems, the reasons they give for favoring or opposing the three

types of systems, and the feelings and evaluations of those who have

actually tried the various systems. Findings on what are felt to be key

issues are presented. The reader is referred to the individual survey

reports for discussions of survey methodologies and results on facets of

the surveys not presented below.

1. Inter-system Comparisons

Several surveys questioned respondents directly on their choice of

restraint system. An early survey was conducted by General Motors Corporation in 1971, in which new car owners were invited to a clinic in Chicago,

provided an increasing amount of information on various restraint systems,

and requested to state their preference among systems.17

Clinic participants were provided the following sequence of information on

the various systems: descriptive information, vehicle system inspection,

film demonstration, and costs. Cost information provided was manual belts

— $25-$30 ($61-$74 in $1982), automatic belts — $20-$25 ($A9-$61), and

air cushion — $130-$160 ($319-$392). Respondents' preference of restraint

system after receiving this information broke down as follows:

'' "Consumer Opinion Relative to Automatic Safety Restraint

Systems — Pilot Study," General Motors Corporation, May 1971
XI-26 •

Manual Belts

Automatic Belts

Air Cushion

No Restraint System

20%

25%

50%

5%

100%

Respondents were also shown news stories that were favorable, unfavorable,

and balanced about the performance of air bags. Following are respondents'

preferences for automatic belts versus air bags:

Automatic Belts 44%

Air Cushion 56%

100%

This survey is most interesting as it demonstrates how "acceptance" changes

as additional information is supplied.

More recent telephone surveys asking respondents to choose between air bags

and automatic belts at specified cost differentials were conducted by

Teknekron^ and Automated Services.^

18 "1979 Survey of Public Perceptions on Highway Safety," Teknekron,

Inc., July 1979, DOT-HS-805-165.

19 "1980 Survey of Public Perceptions on Highway Safety," Automated

Services, Inc., September 1980, DOT-HS-805-702.
XI-27

Air

Bags

Automatic

Belts

Doesn't

Matter/No

Opinion

Teknekron (1979)

(air bag cost: $100-$200

more than automatic belt)

50.7% 10.858

Automated Services (1980)

(air bag cost: $200-$300

more than automatic belt)

39.0 49.2% 11.88

In 1979, respondents were told air bags would cost $100-$200 more than

automatic belts; in 1980, they were told they would cost $200-$300 more.

Results indicate'that consumer preference is sensitive to price. It

appears that at an air bag cost of around $200 ($288 in $1982) higher than

for automatic belts respondents would have been approximately evenly split

in their preference for air bags or automatic belts.

A 1978 telephone survey by Finkelstein and Associates20 queried respondents'

preference for air bags versus the standard manual belt system. As

additional information on the cost and performance of air bags was

provided respondents, preference for air bags decreased from an initial 47

percent to a final 14 percent:

"National Attitudinal Survey — Air Bags," Arthur 3. Finkelstein and

Associates, July 1978.
XI-2B

Information Provided Favor Air Bags

Initial Question

Air Bag Cost -- $200 ($304 in $1982)

Replacement Cost if

Deployed -- $500 ($760)

Safety, Fuel Economy,

Emission Control

Already Cost $666 ($1,013)

Information on Air Bag and

Seat Belt Effectiveness

47?° (+15K unsure)

4158 (+7% unsure)

255S (incl. unsure)

23* (incl. unsure)

143

The Hart 1978 home interview survey2i asked respondents, after they were

shown pictures of automatic restraint systems, to rate on a scale of 1 to 7

(1= poor, 7= excellent) the quality of air bags, automatic belts, and

manual belts with respect to four criteria. The results are presented in

Table X-3.

TABLE XI-3

ATTITUDES TOWARD ALTERNATIVE

RESTRAINT SYSTEMS — MEDIAN SCORES

CRITERIA

SAFETY

APPEARANCE

EASE OF USE

COMFORT

TOTAL

5

4

5

5

.4

.5

.5

.3

AIR

BELT

FREQ

5.5

4.7

5.7

5.6

BAG

USE22

• INFREQ.

5

4

5

5

4

.2

3

.3

TOTAL

4

3

5

3

.8

.6

.0

.2

AUTO E

BELT

FREQ.

5.5

4.3

5.4

4.3

3ELT

USE

INFREQ.

4

3

4

1

.1

.1

.5

.8

TOTAL

4

4

3

2

.9

.0

.7

.6

MANUAL E

BELT

FREQ.

5.8

4.6

5.2

4.7

JELT

USE

INFREQ.

3.8

3.2

3.1

1.3

"Public Attitudes Toward Passive Restraint Systems," Peter D. Hart

Research Associates, Inc., August 1978, DOT-HS-803-570.

Frequent and infrequent manual belt usage.
XI-29

As indicated, air bags ranked highest in all categories. Note cost was not

considered in these ratings. In another questio.i, respondents were asked

to choose between air bags and automatic belts at several price

differentials. At an airbag cost of $200 more than for automatic belts, 38

percent preferred air bags, 46 percent preferred automatic belts, and 16

percent were not sure. At a cost differential of $350, the preference was

35 percent for air bags, 50 percent for automatic belts, and 15 percent not

sure.

2. Reasons for Preference Among Systems

a. Manual Belts

Table XI-4A summarizes the reasons people give for not wearing seat belts,

as ascertained in surveys conducted by Teknekron and Automated Services.

As shown, not wanting to be bothered and being lazy and forgetful are on

average the single most popular reasons given. While automatic belts could

obviate these reasons, this does not mean that other reasons would not

preclude these people from using their belts. Seat belts being

uncomfortable and inconvenient to use are other frequently stated reasons

for not using them. Note that the reasons provided of fear of entrapment,

doubting value, and not wanting to be restrained, are also pertinent to

automatic belts. By far the most frequent response given in these studies

for wearing manual belts is the obvious one, it enhances occupant safety.
XI-30

TABLE XI-4A

Reasons for Disliking or Not Using Manual Belts

(Percent)

Reason

Don't want to be

bothered, lazy, forgetful

Uncomfortable

Inconvenient

Fear of being trapped

in vehicle

Doubt value

Don't want to be restrained

No reason (users)

Other

Teknekron23

(1979)

13.9

13.2

15.1

10.7

4.5

7.7

17.1

17.9

Automated24

Services (1980)

21.7

15.5

17.2

11.0

5.8

8.8

13.8

6.1

Table XI-4B summarizes findings reported by Newport and Tarrance on

responses to the question: "Why is it that so many people don't wear

their seat belts?"

TABLE XI-4B

Why People Don't Wear Seat Belts (1981)25

PERCENT

Too much time/hassle 25?o

Not in habit/don't think about it/

lazy 22K

Uncomfortable/too confining 2Q%

Scared of being trapped 7%

Think won't be in accident 6%

Other 15%

Don't know/not sure 5%

23 Op. Cit.

24 OP . Cit.

co "National Safety Belt Study," Frank M. Newport and V. Lance Tarrance, Jr.,

September 4, 1981.
XI-31

Note that the inconvenience factor is incorporated primarily in category

number one. A review of selected individual responses indicates that iome

of the responses counted in category two could possibly be better

categorized as questioning the safety benefits of safety belts, e.g., "they

think it has no bearing on their safety," "lack of care for their lives,"

"their laziness thinking seat belts wouldn't do much good, except in a real

bad accident."

Reasons for not wearing a seat belt ascertained in the 1983 IIHS survey are

reported in Table XI-4C.26 The percentages shown are based on the main

reasons provided by 195 respondents.

Table XI-4C

Main Reason For Not Wearing A Seat Belt

Percent

Uncomfortable/inconvenient 26

Forget/not in the habit 22

Only take short trips/unnecessary for

short distances 13

Lazy/dislike taking the time 22

Fear of entrapment 8

Other 5

Don't know/refused to answer 4

100

26 Insurance Institute for Highway Safety, November 1983, Op. Cit.
XI-32

Note that the combined response for categories two and four account for 44

percent. This contrasts to the average 17.8 percent response for category

one, "don't want to be bothered/lazy/forgetful," of the Teknekron and

Automated Services surveys. A portion of the difference is likely

attributable to inclusion of "not in the habit responses" in the IIHS

tabulations.

b. Automatic Belts

Respondents to the 1978 Hart Study27 volunteered perceived advantages and

disadvantages of automatic belts. Following are listed the more frequent

responses. The percentages shown indicate the proportion that each listed

advantage is of all stated advantages, and that each listed disadvantage is of

all stated disadvantages. Since respondents likely had little or no knowledge

(they were shown a diagram and given a verbal description of the system) or

experience with automatic belts, a public or industry information campaign that

focuses on these perceived disadvantages could undoubtedly increase

acceptance.

Peter D. Hart Research Associates, Inc., Op. Cit
XI-33

TABLE XI-5

VOLUNTEERED ADVANTAGES AND

DISADVANTAGES OF AUTOMATIC BELTS

Advantages Percent28

Have to Use Them,

Greater Use Thereof

Easy to Use, Convenient,

Don't Have to Remember

35

Prevent Injury

isadvantages

Might Get Trapped

Too Confining, Restraining

Uncomfortable

A Nuisance, in the Way

No Freedom of Choice

Getting In and Out

Is Inconvenient

Might Not Work Properly

22

Percent

23

13

11

11

10

10

9

Some respondents volunteered more than one response. Twenty two

percent of the respondents could think of no advantage to automatic

belts; 14 percent could think of no disadvantage.
XI-34

The Hart study also provided a list of advantages and disadvantages of

automatic belts from which respondents were to select their top choice.

Following are the top four selections in each category.

TABLE XI-6

SELECTED LIST OF ADVANTAGES

AND DISADVANTAGES OF AUTOMATIC BELTS

Advantages Percent

Don't Have to Remember 48

to Buckle Up

Driving Safer -- Will 29

Always Have Belt On

Because They are Simple, 14

They Will Work

Not Very Expensive 12

Disadvantages

Might Trap You In Car 39

After Accident

Too Constraining and 25

Uncomfortable

Inconvenient, Irritating 17

To Be Strapped In Even

For Short Ride

Uncomfortable, Especially 17

For Overweight People

or Pregnant Women
XI-35

Opinion Research Corporation surveyed owners of 1975 Volkswagens, some with

automatic belts and some with manual. Of those surveyed, those owners of

automatic belts and manual belts who had a choice of systems when they purchased

their vehicles were asked to provide their reasons for choosing or not choosing

the automatic system. As indicated in Table XI-7, the major factor for choosing

automatic belts was ease and convenience of use. The main reason for not

selecting the automatic system was the added expense. While the added expense

disadvantage is not germane to the issue of automatic belts if individuals would

not be given a choice of systems under an automatic restraint rule, it would be

if consumers were given an option and indicates that some would forego the

advantages of the automatic belt system because of the extra cost. Most of the

other disadvantages, of much smaller magnitude than the price issue, would also

apply to usage. The advantages related to choice of system would also be

expected to be advantages related to increased usage.

TABLE XI-7

REASONS FOR CHOICE OF BELT SYSTEM29

Reasons for Choosing Automatic System Percent

Easy/convenient to use 73

Forces one to use belt 14

Safer than conventional system 10

Wanted to try it/read about it 9

More comfortable 6

Offers greater freedom of movement 4

Like the knee pad 3

(Principal answers. Percentages add to more than 100 percent due to

multiple answers)

"Passive vs. Active Safety Belt Systems in Volkswagen Rabbits: A

Comparison of Owner use Habits and Attitudes;" Opinion Research

Corporation, August 1976. DOT-HS-801-958.
XI-36

Reasons for not Choosing Automatic System

Too expensive/extra cost 47

Dislike the knee pad 13

Inconvenient to use 7

Less safe than conventional 5

Too long a delivery time 5

Prefer conventional safety belt 3

Don't use safety belts 3

Decision made by another family member 3

Less comfortable 2

(Principal answers)

Opinion Research surveyed owners of 1978-79 MY Chevettes and 1978 MY

Rabbits, equipped with automatic belt systems^. Forty-one percent of.the

Chevette and 80 percent of the Rabbit owners said they would choose an

automatic belt system if purchasing a new car. The principal reasons

stated are shown below. Safety and convenience were the primary factors.

Comfort did not figure prominently as a factor.

1978-79 Automatic 1978 Automatic

Chevette Owners Rabbit Owners

Safety-related factors 51% 40%

Convenience Factors 39% 56%

More Comfortable 555 m

TM Automatic Safety Belt Systems Owner Usage and Attitudes in GM

Chevettes and VW Rabbits," Opinion Research Corporation, May 1980,

DOT-HS-805-399.
XI-37

Following are the principal reasons given in the same survey by the 49

perci nt of Chevette owners and 12 percent of Volkswagen owners for why they

would not purchase an automatic belt system in their next new car. (Some

Chevette and Volkswagen owners were uncertain whether they would purchase

automatic systems in their next new car.)

1978-79 Automatic 1978 Automatic

Chevette Owners Rabbit Owners

Convenience Factors

Comfort Factors

No Interlock

Freedom to Wear/Not Wear

33%

18%

16%

16%

25%

17%

17%

17%

Opinion Research Corporation also conducted a 1980 survey of owners of 1980

MY Rabbits and Chevettes equipped with automatic belts. Opinion Research

queried respondents on their reactions to the automatic belt system both

initially and after a period of time. Following are results from the 1979

and 1980 surveys.31

Opinion Research Corporation, May 1980, Ibid. "Automatic Safety Belt

Systems Owner Usage and Attitudes in GM Chevettes and VW Rabbits (1980

Model Year)," Opinion Research Corporation, February 1981,

DOT-HS-805-797.
XI-38

TABLE XI-8

REACTIONS OF AUTOMATIC BELT OWNERS

Favorable

Unfavorable

No Opinion

Favorable

Unfavorable

No Opinion

1979 Survey

Chevette Rabbit

i\5%

41

14

1979

Chevette

5135

43

6

61%

22

11

REACTIONS

Survey

Rabbit

Bh%

13

3

1980 Survey

Chevette Rabbit

39%

54

7

"AFTER OWNING CAR

1980

Chevette

49%

44

7

61%

32

7

AWHILE"

Survey

Rabbit

11%

18

5

The above response indicates a significant increase over time in the

percentage of owners having a favorable impression about automatic belts.

This favorable opinion on the automatic belt systems suggests the

possibility that they could be successfully marketed on a wider scale and that

actual familiarity, rather than breeding contempt, results in greater acceptance

than the concept itself.

Respondents were also questioned about what they liked most and least about

their automatic belt systems. Note the change in response for features

liked least between 1979 MY and 1980 MY Chevettes. The 1979 Chevette has a

detachable automatic belt with an interlock, while the 1980 model has what

is in effect a non-detachable system with no starter interlock. Entering

and exiting problems are much more prevalent in 1980 Chevettes.
XI-39

AUTOMATIC BELT

1979

Chevette

Convenience 39%

Safety 24

Comfort 6

Nothing 30

Entering/Exiting

Poor Belt Fit

Retractor Problems

Interlock or Warning

System

Mounting on Door

TABLE XI-9

FEATURES LIKED MOST AND LEAST

Survey

Rabbit

82%

17

14

8

1979

Chevette

18%

16

9

26

8

pQfl f 1 1 T* DC

Survey

Rabbit

20%

11

5

12

1

Mnof __ _-.

1980 Survey

Chevette Rabbit

45% 62%

31 36

9 15

29 12

1980 Survey

Chevette Rabbit

41%

16

7

3

5

21%

21

11

14

2

Information was gathered comparing automatic and manual belt systems. In

its 1976 survey,32 Opinion Research asked owners of VW Rabbits with

automatic or manual belt systems their respective impressions of the two

systems. Table XI-10 summarizes general impressions about the two systems

and about the more specific issue of comfort.

TABLE XI-10

AUTOMATIC AND MANUAL BELT SYSTEM OWNERS' IMPRESSIONS

Impressions of Owners of

Respective Systems

General Impressions

Favorable

Unfavorable

No Impression

C om f o rt

Comfortable

Fairly Comfortable

Not Comfortable

Other

tic Belts

83%

13

4

73%

19

7

1

Manual Belts

67%

20

13

45%

35

16

4

Opinion Research Corporation, August 1976, Op. Cit.
XI-40

As shown, automatic belts were though; of more favorably in general and

were felt to be comfortable by a much larger percentage of owners. The fact

that the automatic system consists of a shoulder belt (plus knee bolster), while

the manual system consists of a lap and shoulder belt, likely accounts for some

of the difference in the perceived level of comfort in the two systems.

Opinion Research asked respondents to evaluate their experience with

specific comfort and convenience problems associated with use of their

respective automatic and manual belt systems.

TABLE XI-11

COMFORT AND CONVENIENCE OF AUTOMATIC AND

MANUAL BELT SYSTEMS

-PERCENT WITH

ISSUE

Owners of Cars

With

Automatic Belts

Owners of Cars

With

Manual Belts

Jewelry Lost, or Damaged

Belt Falls off Shoulder

Belt Hard on Clothing

Belt Rubs on Face or Neck

Belt Exerts Pressure on Chest

Belt Chafing or Rubbing Chest

Belt Hinders Reach for Glove

Compartment or Controls

Padded Knee Panel (Auto)

Belt Interferes with Entering

Car (Auto)

Belt Interferes With Exiting

Car (Auto)

Fastening or Buckling Belt

(Manual)

Belt Retractor Locks When

Buckling (Manual)

Belt Interferes With Entering

Back Seat (Manual)

Belt Attachments Inaccessible

(Manual)

10

16

19

19

23

25

16

37

38

14%

19

36

42

39

38

43

38

42

50

56
XI-41

Except for problems associated with entering and exiting and the knee bolster,

the automatic belt system was rated higher in comfort by its users than was the

manual system by its users. There was no indication whether the presence of a

lap belt in the 3-point manual belt system made their comparison to the

automatic belt system less favorable.

Clinical evaluations of the comfort and convenience of safety belt systems

in 1980 and 1981 model vehicles revealed that automatic safety belt systems

were more comfortable than manual systems in identical vehicles. The

study, conducted by Verve Research Corporation, produced the results shown

in Table XI-12. Systems were rated for comfort based on belt fit and belt

pressure on the occupant. The rankings shown indicate where each vehicle's

system ranked among the 55 that were tested. As indicated, automatic

systems ranked well ahead of manual systems in terms of comfort, with the

exception of the VW Rabbit, for which the rankings were close. Three of the

vehicles (BMW 320i, Chevy Chevette, Ford LTD) had lap belt portions to their

automatic systems; these systems thus corresponded to the 3-point manual belt

systems to which they were compared.
XI-42

Table XI-1233

Comfort Rankings for Automatic

and Manual Belt Systems

Vehicle and Safety Average Comfort Ranking

Belt System Among 55 Vehicles Tested

BMW 320i (Auto) continuous loop

BMW 320i (Manual)

Chevy Chevette (Auto) continuous

loop

Chevy Chevette (Manual)

Ford LTD (Auto) continuous loop

Ford LTD (Manual)

VW 3etta (Auto) 2-point

VW Jetta (Manual)

VW Rabbit (Auto) 2-point

VW Rabbit (Manual, Veh.#1)

VW Rabbit (Manual, Veh.//2)

3. Air Bags

The 1978 Hart survey queried respondents on their impression of air bags

(respondents were provided verbal and visual descriptions). Following are

the top four volunteered perceived advantages and disadvantages of air

bags:

Belt Fit

16

37

17

53

2

30

26

40

39

41

25

Belt Pressure

17

47

8

54

1

34

28

52

46

45

33

"Evaluation of the Comfort and Convenience of Safety Belt Systems in

1980 and 1981 Model Vehicles, "Verve Research Corporation, March 1981,

DOT-HS-805-860.
XI-43

TABLE IX-13

VOLUNTEERED ADVANTAGES AND DISADVANTAGES OF AIR BAGS

Advantages Percent

Protect from injuries, death,

offer protection 44

Protect driver from windshield,

steering wheel, dashboard 36

Automatic, work without driver

involvement 8

Cushion impact in collision,

front end crashes 7

Disadvantages

Might not inflate, accidentally

inflate 19

Expensive to install, maintain,

restore 14

Might not inflate when they

should 12

Might obstruct vision 11

Following are the top four reasons for favoring and opposing installation

of air bags in new cars as selected by respondents from lists.
XI-44

TABLE XI-14

Selected Reasons for Favoring and Opposing Air Bags34

Reasons for Favoring Installation Percent

Provide most safety in a

front end collision

Work automatically in a crash

Provide most safety for little

children

Don't have to think about

them, hidden

34

33

30

22

Reasons for Opposing Installation Percent

Might inflate by mistake

Can't be sure they will work

Cost more than other safety

systems

Air bag system uses toxic

chemicals

Air bags might surround you or

hit you too hard

Only effective in front end

crashes, still have to

wear lap belt

Can't trust auto companies to

do a good enough job

in making such complicated

.equipment

47

25

13

12

12

12

12

Reasons given for opposing or favoring air bags, by those opposing and

favoring their required installation, respectively, in a 1979 telephone

survey of Arkansas drivers, are summarized below:

The percentages shown indicate the percentage of respondents selecting

given reasons. Some respondents selected two best reasons.
XI-45

TABLE X-1535

REASONS FOR FAVORING AND OPPOSING AIR BAGS

Reasons for Favoring

Air Bags Percent

Safety

Convenience

Other

87.4

9.1

3.5

Reasons for Opposing

Air Bags Percent

Fear Early Inflation 18.2

Fear Loss of Control 4.6

Still Unproven 31.7

Fear Entrapment 7.2

High Cost 16.4

Other 21.9

Respondents who favor mandatory air bags logically perceive safety benefits

therefrom, while those opposed expressed concern about air bags not

working when needed, inflating unnecessarily, and being too costly. The

perceived reliability of air bags was most often mentioned and dominates the

list of stated disadvantages.

"Arkansas Motorists: The 55 mph Speed Limit and Safety Devices," Area

Market Research Associates, July 1979.
XI-46

Respondents who preferred air cushions in the 1971 GM clinic were asked to

provide reasons for their choice.36 Although the safety effectiveness of

air cushions was by far the primary concern, as indicated in Table XI-16,

it is also obvious that comfort, convenience and appearance played an

important role.

TABLE XI-16

REASONS FOR AIR BAG PREFERENCE

Safest and most practical injury-free system 93%

More freedom of movement — less confining than

belt 26

"Automatic" nature of the system is good — protects

people who usually don't buckle up 8

Looks nicer than falling straps — neater 6

Makes easier entry and exit possible 4

I don't like belts 3

Prevents injuries arising from hitting steering

wheel 2

Miscellaneous comments 8

(Percentage over 100% due to multiple comments)

In 1977 GM sponsored a survey of owners of GM cars equipped with an Air

Cushion Restraint System (ACRS).^7 Opinions and attitudes were not

specifically requested; however, 475 owners offered comments, which are

summarized below:

General Motors Corporation, 1971, Op. Cit.

Air Cushion Restraint System: A survey of Owners' Opinions,"

University of North Carolina, May 1978.
0.

30

64

57

35

85

29

Percent

6

14

12

7

18

6

XI-47

TABLE XI-17

POSITIVE AND NEGATIVE COMMENTS ON AIR BAGS

Positive Comments

No problems with ACRS

Good feeling toward ACRS

Feeling of safety and confidence

Prefer ACRS over belts

Would purchase another ACRS

ACRS should be in all cars

300 63

Negative Comments

Problems with horn

Problems with checklight

Problems with servicing

Discouraged by dealers to buy ACRS

Other negative comments

All other ACRS comments

Comments irrelevant to ACRS

Total comments

Findings of the Hart and GM surveys indicate that the safety value of air

bags is clearly perceived, although questions exist about their

reliability. The majority of owners of GM air bag equipped cars had

favorable reactions to the system.

In 1976, General Motors sponsored a survey of owners of 1976 GM cars with

and without air bags.38 jhe following responses were provided when the air

bag owners were asked their reasons for purchasing a car with air bags:

21

19

28

5

41

114

36

25

475

4

4

6

1

9

24

8

5

100

"A Passive Occupant Restraint System Study," Market Research Group,

Inc., and Survey Data Research, Inc., December 1976.
XI-48

Car came equipped with air bags;

car I wanted just had them already U5%

Wanted safest car — just safer than belts 22%

Don't like seat belts and wanted protection 16%

Only 4 percent of air bag owners said they would not purchase air bags

(again), even at no added cost, compared to 30 percent of the non-owners.

To summarize, surveys generally indicate that automatic belt systems are

superior to manual systems in comfort and convenience, depending of course

on the design of a particular system, and that these characteristics would

appear to over-ride some of the reasons respondents give for not using

manual belts and therefore increase usage. Of course, a degree of comfort

and convenience is lost whenever a manual or automatic belt is utilized.

Differences in convenience of use between automatic and manual belts

are important to deciding which system to purchase, while differences in

system comfort have little bearing thereon. Respondents perceive some

degradation in vehicle appearance from automatic belts.

Air bags are rated highest on comfort, convenience, and appearance and are

perceived to be safer by infrequent belt users. Primary concerns expressed

about air bags relate to reliability, whether they will work when needed or

deploy accidentally, and cost. Again, it must be emphasized that in
XI-49

evaluating results of public surveys, it should be understood that

respondents generally have at best very little knowledge about or

experience with air bags, and not much more with automatic belts.

^* Public Attitudes Toward A Mandatory Safety Belt Usage Law

This section summarizes past and recent state and nationwide surveys on

public opinion concerning mandatory safety belt usage laws. Eighteen of

these surveys have employed reasonable methodologies to gain representative

opinions. Nine of the state surveys, either conducted or commissioned by

state agencies, were conducted from 1977-79 and a single state survey was

conducted in Michigan in 1983.

Results of the above 18 state and nationwide surveys are reported on

separate tables. The table summarizing the nationwide surveys is divided

into two parts; those surveys that in their articulation of the question on

mandatory safety belt usage were silent on whether a penalty would be

imposed, and those that stipulated a fine for non-usage. One state, New

Jersey, incorporated the consideration of a penalty in its survey, and

results are included in the table summarizing the state surveys.
XI-50

As shown on Table XI-18, 6 of the 10 state surveys found public opinion

against a mandt tory usage law, with the strongest vote against being in

North Carolina with a ratio of over 4:1. Two states had a majority

favoring a mandatory usage law, with the strongest vote in favor being in

Michigan with a ratio of 62:38 in favor. Two state surveys showed a

virtual deadlock on the issue. A survey in the Grand Rapids area of

Michigan in 1977, demonstrated the effect of a safety belt usage campaign

by reversing a 52 percent to 34 percent vote against mandatory usage before

the campaign to a 44 percent to 38 percent vote in favor after the

campaign. In New Jersey, when the stipulation of a $10 fine for

non-compliance was introduced, opinion against mandatory usage increased

from 52 percent to 63 percent.

Table XI-19 summarizes the results of the nationwide surveys on the issue

of mandatory usage. Of the five surveys that did not stipulate a penalty

for non-compliance, three indicate public preference in favor of mandatory

usage and two indicate preference against it. The three surveys in favor

of mandatory use laws were more recent.
XI-51

TABLE XI-18

STATE SURVEYS ON A MANDATORY

SAFETY BELT USE LAW

YEAR

1977

1977

1977

1977

1978

1978

1978

1979

1979

1983

STATE

New Jersey

Michigan; Grand

Rapids and surrounding

area

VIRGINIA

KENTUCKY

CALIFORNIA

NEBRASKA

NORTH CAROLINA

ARIZONA

ARKANSAS

MICHIGAN

FAVOR

39

30

34

42

44

38

32

—

42.2

14

30

54

62

PERCENT

AGAINST

52

63

52

42

38

58

33

65

42.5

62

61

46

38

UNDECIDED

9

7

14

16

18

4

35

—

15.3

23

29

—

COMMENT

with $10 fine

Pre media campaign

During media

campaign

Post media campaign
XI-52

TABLE XI-19

NATIONWIDE .URVEYS ON A MANDATORY

SAFETY BELT USE LAW

YEAR

1977

1977

1978

1979

1983

1976

1977

1978

CONDUCTED BY

Insurance Institute

for Highway Safety

American Automobile

Association

Teknekron

Teknekron

Yankelovich, Skelly,

and White39

FAVOR

47

41

54

52

65

—PERCENT

AGAINST

50

48

45

47

35

UNDECIDED

3

11

1

1

(SURVEYS STIPULATING SANCTION)

Yankelovich. Skelly,

and White^O

Gallup Poll

Hart

29

17

21

66

76

57

5

7

22

SANCTION

"Summons ;

"$25 fine1

"fines"

*° Conducted for the All-Industry Research Advisory Council, an organization formed by

the property-casualty insurance industry; docket entry 74-14-N35-067.

40 Conducted for the Motor Vehicle Manufacturers Association.
XI-53

The three nationwide surveys addressing the mandatory usage issue and

stipulating a sanction against non-compliance show a stronger opinion

against such laws than do the surveys that did not stipulate sanctions.

This suggests that a portion of the public does not associate the concept

of enforcement and sanctions with mandatory use laws - or at least they did

not 6-8 years ago. However, a number of recent state surveys suggest that

public opinion is shifting on the issue of state mandatory safety belt use

laws. Although these surveys, due to some methodological deficiencies, are

not representative of the public-at-large, their results do provide an

indication of recent public attitudes toward mandatory use laws.

Two attitude surveys conducted in the State of New York last year provide a

case in point. The first, conducted in Nassau County in the Spring of

1983, asked licensed drivers, "Are you in favor of mandatory seat belt

legislation (requiring everyone to wear seat belts)?" This questions was

posed as a potential countermeasure to mitigate the consequences of drunk

driving. The responses were 56 percent yes; 39 percent no; and 5 percent

don't know. Later in 1983, the New York State Medical Society surveyed

visitors at the 1983 State Fair. Sixty seven percent indicated they would

be in favor of a law requiring the use of safety belts by adults. In

June 1984 the state legislature of New York passed a mandatory use law.
XI-54

The Ohio State Highway Patrol conducted a survey of publi • attitudes during

3une and 3uly 1983. Patrol officers asked a set of questions of drivers

and passengers stopped for various reasons. Ninety five percent said they

favored a child restraint law; 56 percent favored a mandatory safety

belt law for adults, and 88 percent said they would obey a mandatory law if

it were passed. Similar results were obtained in a representative survey

conducted in Michigan in 1983 (see Table XI-18). Eighty five percent of

the respondents in the Michigan survey said they would comply with a state

law requiring the wearing of safety belts for all front seat occupants.

Sixty two percent said that they favored a mandatory law.
XI-55

F. Marketing of Air Bags as Optional Equipment

The U.S. automotive industry provides only one example of an attempt to

market air bags. General Motors (GM) offered the Air Cushion Restraint

System (ACRS) option from 1974 through 1976 on Cadillac DeVille and

Eldorado models; Buick Electra, LeSabre, and Riviera models; and Oldsmobile

98, 88, and Toronado models. GM built and sold only 10,243 ACRS equipped

cars over the three-year period compared to an ACRS production capacity of

300,000 units over that period and a total sales volume of 2,208,354

vehicles in which the ACRS was available. This computes to a three-year

installation rate of 0.46 percent and a total utilization of less than 3.5

percent of GM's ACRS production capacity.

In 1982,- NHTSA sponsored a study41 to examine the GM marketing effort of air

bags in the mid-1970's to try to determine whether any or all of the

factors that limited GM's sales could be corrected or overcome in future

marketing efforts. The study also identified the types of information that

would be needed in order to effectively plan and implement a marketing

program for air bags.

The results show that much can be learned from a retrospective analysis of

GM's marketing of air bags. The study identified three problems in the

market which affected the demand for ACRS.

"A Retrospective Analysis of the General Motors Air Cushion Restraint

System Marketing Effort, 1974 to 1976," National Analysts, July 1983.
XI-56

1. Lack of dealer commitment — The initial attitude of the dealer

towards ACRS is strongly linked to the dealership's ACRS performance.

Those dealers who had positive selling experiences saw ACRS as a

positive marketing advantage. Those dealers that had neutral or

negative selling experiences often shared the same doubts and fears

about ACRS as consumers. The correlation is not absolute. Some

dealers started out enthusiastically but wound up regretting the

decision to stock ACRS cars. However, no dealers started out

skeptical and later became enthusiastic about ACRS.

2. Unanticipated consumer concerns — In marketing ACRS, GM

positioned the option as a "comfort and convenience" item (ACRS would

eliminate the need for cumbersome and troublesome shoulder belts).

However, consumers had serious concerns over the technical operation

of air bags — inadvertent deployment, blocked vision, cost and

inconvenience of replacing an ACRS unit, etc. These concerns

apparently were not ameliorated by the various marketing materials

developed by GM.

Another unanticipated concern, which appears to have been of

significant importance, was the unavailability of the tilt steering

wheel option if ACRS was ordered. This was especially important

because tilt wheel was (and is) a high installation-rate option on the

relatively expensive cars on which GM offered ACRS.
XI-57

Failure to satisfy these consumer concerns, particularly the safety

fears over ACRS' operation, resulted in the ACRS being viewed as both

expensive (ACRS price ranged from $225 in MY '74 to $315 in MY '76

--$453 to $549 in $1982) and of doubtful efficacy -- a fatal

combination.

3. Installation of ACRS on full-size vehicles — While GM's logic in

offering ACRS first on full-size, upmarket vehicles appeared sound at

the time, there is evidence which suggests that ACRS1 demand grows as

vehicle size drops. This demand in smaller cars is linked directly to

safety concerns. Thus, if air bags had been offered on smaller cars,

they would have had to be positioned more as a safety item and less as

a comfort and convenience item. While ACRS would have undoubtedly met

with strong price resistance among small car buyers, the air bag

concept probably would have made more immediate sense to small car

owners. On the other hand, the ACRS was not developed for small cars

in the mid-70's — and still is not. Also, the price increase for an

ACRS is more negatively perceived by small car buyers than by large

car buyers (see Section C) .

The retrospective air bag marketing study also contains a number of

recommendations for developing a marketing strategy. Three specific areas

of concentration are mentioned:

1. Consumers — The overriding need in marketing air bags to

consumers is to create a totally positive view of the system before

price enters into the equation. This means that an intensive probing
XI-58

of consumer attitudes, particularly negative attitudes, towards the

air bag system should be undertaken before any new marketing effort.

Additionally, a marketing strategy should identify the most likely

prospective buyers of air bags and the promotional themes to which

they will best respond. In addition to these research efforts, the GM

air bag experience argues strongly for the pretesting of merchandising

materials and even sales techniques.

2. Technical Research — A major drawback of the ACRS, from both a

customer and dealer standpoint, was that there was little indication

of its presence and thus it did not become a selling point. It is

imperative to find some way to dramatize the presence of the air bag

to the point where it is an attention grabber, a visible source of

pride, and perhaps of some "bragging" value.

Also, there is a need for some sort of credible, and most likely

tangible, assurance that the air bag is ready to go into action when

it is needed. GM used a dashboard indicator light; however, that in

itself did not appear to be sufficient.

3. Dealers — While a positive attitude and commitment by

manufacturers to market air bags is essential, it is the dealers and

sales personnel who provide the direct link to the consumers. The

critical role played by dealers' and sales personnels' attitudes in

shaping the ACRS' selling experience demands that future air bag

marketing strategies take their concerns into account. A better

understanding is needed of: (1) the extent of dealer fear or
XI-59

skepticism about air bags; (2) the types of consumers to whom dealers

would and would not attempt to sell air bags; and (3) the conditions

required to motivate dealers to market air bags.

As a result of the retrospective GM air bag marketing study, it appears

reasonable to assume that air bags could be successfully merchandised as an

option, if an effective marketing strategy were developed and pursued by

the manufacturer(s). To be effective, the consumer and dealer concerns

must be addressed and resolved.

G. Public Opinion Surveys — Docket Submissions

In addition to the above surveys, the results of two new public opinion

surveys on vehicle occupant restraint issues were submitted to the docket.

One was commissioned by General Motors Corporation, the other by the

Insurance Institute for Highway Safety (IIHS). Both surveys include some

questions which the Department believes influenced the answers;

consequently, the agency believes that some responses do not accurately

reflect current consumer/public attitudes with respect to automatic

restraint systems.

The General Motors survey (Docket No. 74-14-N32-1666), conducted by Maritz

Market Research of Detroit, consisted of telephone interviews over the

November 14-22, 1983 period with 1,101 new car buyers. It is essentially

designed to measure attitudes on government regulation of safety technology

and vehicle operation.
XI-60

The IIHS survey (Docket No. 74-14-N32-1667), also a telephone survey, was

conducted by the National Center for Telephone Research during the period

November 14-17, 1983. In this survey, 1,254 heads of households at least

21 years of age with valid drivers licenses were interviewed. The IIHS

survey attempts to measure attitudes on different safety technologies,

divorced for the most part from the issue of government regulation.

However, as discussed below, the notion of government regulation becomes

intertwined with the issue of automatic restraint availability.

The representativeness and validity of the overall survey results are

discussed below. This is followed by presentation, evaluation, and

discussion of survey results on a few key issues.

1. Representativeness and Validity of the Surveys

Before discussing the individual surveys, an initial comment is warranted:

It is questionable whether either survey could obtain useful or accurate

information on automatic belts over the phone. It is too difficult to

conceptually understand the system without first-hand experience.

Therefore, responses to questions containing such terms as "automatic

restraints" or "automatic belts" are of dubious value.

a) General Motors surveyed owners of recent model cars who stated they

would be buying a new car in the future, i.e., new car buyers. No

information is provided on the universe from which the sample was drawn nor

on sample selection procedures. Because only new car buyers are surveyed,

results cannot be considered nationally representative of all those that
XI-61

would be affected by a FMVSS 208 decision — all automobile owners and

opeiators. However, while survey questions relating to whether automotive

restraints should be mandated should be directed to the motoring public at

large, questions on what the public would be willing to pay for them are

appropriately addressed to new car buyers.

The response options in the questionnaire do not provide for the "unsure"

and "does not matter" type of response. It is unreasonable to assume that

all respondents had a firm opinion on each of the issues addressed in the

questionnaire; the size of the unsure response is important in assessing

public attitudes.

Some deficiencies in question wording are discussed below in the section

summarizing results on specific questions.

b) The IIHS survey begins by giving each respondent a brief introduction to

the Nation's highway safety problem — "40-50 thousand people are killed,"

"tens of thousands are severely injured," "federal government has acted to

reduce deaths and injuries by requiring . . . protective features," "one of

these protective features is the seat belt," "about one out of 10 Americans

wear seat belts." The respondents were then asked, "how often do you wear a

seat belt when you drive your car?"

The response to this first question produced the results of "twenty-eight

percent of respondents reported always wearing their seat belts, while an

additional 12 percent reported wearing them almost always." Obviously,

these respondents either overrepresent safety-conscious people, or their
XI-62

responses are biased by the so called "acquiescence effect," a phenomenon

encountered in survey research which manifests itself as a tendency to show

support for whatever it is that appears to be of importance to the

interviewer, and the "social desirability effect," which manifests itself

by a tendency to support positions which one feels that one should support

as a good citizen. The latter two phenomena are most likely the case,

since the survey's introduction talks of death and injury, protective

features, federal government, and poor belt usage rates; and then the

respondent is immediately asked if he/she wears his/her seat belt. Many

respondents can be expected to answer positively to such a question, since

they would not wish to appear to be against safety.

If the sample is overrepresented by seat belt users, it biases the

applicability to all consumers. Also, if the "acquiescence" and "social

desirability" biases exist in this response, then their existence in

other responses is highly probable.

Some explanatory information and questions are phrased in such a manner as

to almost certainly bias results; for example, the question on whether

automatic restraints should be required in new cars. The responses to this

and selected other questions are presented and discussed below:
XI-63

2- Results and Analysis of Specific Survey Questions

a. Should air bags/automatic restraints be available in new cars?

(1) The General Motors survey addressed this issue with the following

explanatory statement and question. The results follow:

"In the event of an accident at 12 miles per hour or more, air cushions in

your steering wheel and dashboard would rapidly inflate, forming a

restraining bag for driver and passenger. Air bags would add $320 to the

cost of a car."

"Would you favor a government regulation requiring the installation of air

bags on our next new car at an additional cost of $320?" This question

was also asked for costs of $100 and $500.

Yes • No

Cost

Cost

Cost

of

of

of

$100

$320

$500

51%

35%

19%

49%

65%

81%

As stated above, addressing the question of a regulatory requirement to new

car buyers does not produce results representative of the driving public.

In addition, phrasing the question in terms of government regulations

introduces a bias against the acceptability of air bags, since it is well

known that a certain segment of the population is against practically any
XI-64

and all types of government regulation. It is impossible to determine the

degree to which the air bag issue or tie regulatory issue influenced

responses.

The air bag being described as a "restraining bag" might convey the image

of a bag which holds and suffocates the occupants; this description may

tend to reinforce rather than dispel any existing consumer concerns over

the performance and reliability of air bags.

The survey contained a similar statement and question on automatic belts:

"Now, a few questions about automatic seat belts. Cars would be equipped

with lap and shoulder belts which automatically "belt-in" seat passengers

as they sit down. Automatic seat belts would add $100 to the cost of a

car."

"Would you favor a government regulation requiring the installation of

automatic seat belts on your next new car at an additional cost of $100?"

Yes No

O' 62

While General Motors directly addresses the issue and appropriately

includes cost figures for respondents' consideration, belts being described

in terms of their ability to "belt-in" the occupants might reinforce any

exisiting fear of entrapment among respondents.
XI-65

The question of acceptable cost is appropriately addressed to new car

owners. However, since the survey merges this i sue with the issue of

restraint/regulation, which is not appropriately addressed only to new car

buyers, opinions on each cannot be assessed, and results addressing the two

jointly cannot be considered appropriately nationally representative.

Also, the GM survey did not discuss any potential benefits of belts/bags.

If respondents were told the expected safety benefits associated with the

additional cost, the answers might have been different.

(2) The IIHS survey addressed the issue in two parts — a statement and

then a question. These are shown below:

"Currently automatic seat beltv are available only to buyers of some

Volkswagen cars and more expensive Toyota cars, while air bags are

available only to buyers of some Mercedes cars. If these new features were

standard on all new cars, the cost of these features to each buyer would be

substantially lower than if purchased as an option and more people would be

protected automatically in crashes."

Question: "Do you think that air bags and automatic belts should be

standard equipment for everyone or do you think that they should be

optional for those people who want and can afford them?"
XI-66

Should be standard

Should be optional

No preference

Don't know/not sure

56%

M%

1%

2%

The IIHS survey is biased toward automatic restraints being standard

equipment in new cars for the following reasons:

o The phrasing of the question on whether automatic restraints should be

standard equipment or "optional for those people who want and can afford

them" likely does not make clear to the respondent that automatic

restraints could be required as an option in less expensive cars. While a

close reading of the explanatory statement preceding the question by

respondents might preclude this ambiguity for most, it appears likely that

many respondents hearing the statement read over the phone followed by the

question would construe "those people who want and can afford" optional

equipment to mean purchasers of the Mercedes and other expensive cars.

o Respondents were told that "substantially lower" costs would result

from automatic restraints being produced in large quantities and installed

in all new cars. "Substantially lower" likely means different and

imprecise amounts to various respondents. The absence of restraint system

cost estimates for respondent consideration denigrates response validity.

o Survey results on this question are contradicted by results on a

question about preference for an air bag or a current manual belt at

various costs for an air bag. At a cost of $350 for an air bag, 55 percent
XI-67

of the respondents preferred a manual belt compared to 42 percent

preferring the air bag. Were an air bag standard equipment, their

preference would not be satisfied.

The IIHS survey then asks the 44 percent of respondents who did not

indicate that automatic restraints should be standard equipment whether

they felt "car manufacturers should be required to at least make air bags

or automatic belts available as options so that those that want them can

buy them."

The notion of a requirement is thus introduced in considering the merits of

availability of automatic restraints as options. The issue of regulation

was not introduced for respondent consideration in voting on whether

automatic restraints should be standard equipment, e. situation which is

more likely to be achieved only through regulation.

The distribution of responses must be questioned because of this

inconsistency in incorporating the notion of regulation.

Of the 44 percent of total respondents asked, 84 percent stated that

automatic restraints should be made available, 9 percent said they should

not, and 6 percent had no preference or did not know. Combining the results

of this question with the preceding one, the IIHS survey produces the

following summary results.
XI-68

Automatic restraints should be 56?o

standard equipment

Manufacturers should be required to 37?Q

make automatic restraints at least

available as options

Automatic restraints should be 4?o

neither standard equipment nor required

to at least be available as options

No preference/don't know 3"

Shortcomings concerning the validity of the 56 percent preference indicated

for automatic restraints as standard equipment are discussed above.

Regarding indicated preference for automatic restraints being made

available as options, the question as read to respondents, "car

manufacturers should at least make air bags or automatic belts available as

options . . .," could imply that this is the least manufacturers should

do, when in fact it would entail considerable cost to manufacturers. The

agency believes the response may well have been lower had the question been

put in a more straight forward manner.

b. How much are people willing to pay for automatic restraints?

(1) The General Motors survey combines or incorporates the willingness to

pay issue with the issue of a government regulation requiring installation

of automatic restraints and therefore does not address the willingness to

pay issue, per se. Results are presented in Section (a) above.

Respondents willing to pay specified amounts for restraints may be against

government mandating their installation and respond in the negative to a

question incorporating both issues; therefore, their responses cannot be

used to strictly gauge their willingness to pay.
XI-69

(2) The IIHS survey ascertained the amounts respondents were willing to

pay for both automatic belts and air bags. The following two tables

indicate respondents' preference for automatic restraint systems or the

manual lap and shoulder belt system that is currently standard equipment in

cars, at various costs for the automatic system.

PREFERENCE FOR AUTOMATIC AND MANUAL BELTS AT DIFFERENT PRICES

Prefer Prefer No Neither/

Automatic Manual Pref. Unsure

Ignoring Price 33% 33% Z95 4"%

$100 for automatic belts 30% 53% 11% 6%

$150 for automatic belts 25% 57% 14% 4%

PREFERENCE FOR AIR BAGS AND MANUAL BELTS AT DIFFERENT PRICES

Prefer Prefer Man. No Neither/

Air Bags Belts Pref. Unsure

28% 4%

3%

The results on how much respondents are willing to pay for air bags are

reasonably consistent with results of other studies on this issue that are

summarized above.

c. Preference among alternative regulations

(1) The General Motors survey asked respondents which of five government

regulations they would "like most" and "like least" to see enforced:

Ignoring Price

$100 for air bags

$200 for air bags

$350 for air bags

$1,000 for air bags

41%

55%

47%

42%

18%

27%

42%

50%

55%

79%
XI-70

Mandatory seat belt law,

65 mph on Interstate System

Air bags in all new cars

Automatic seat belts in all

new cars

Mandatory seat belt law

Starter Interlock

Air bags in all new cars

Starter Interlock

Mandatory seat belt law

Automatic seat belts in all new

cars

Mandatory seat belt law, 65 mph on

Interstate Systems

Government Regulation

"Like Most"

To See Enforced

24%

1658

11%

100%

Government Regulation

"Like Least"

To See Enforced

4 4%

18%

14%

11%

100%

As shown, respondents most liked a mandatory seat belt law in conjunction

with increasing the speed limit on the Interstate System to 65 mph.

However, since the extent to which those selecting the seat belt law and 65

mph were simply voting for a higher speed limit is unknown, none of the

responses is useful in gauging opinion on relevant alternatives. The table

showing the distribution of responses on least liked alternatives indicates

that a requirement that air bags be installed in all new cars is by far the
XI-71

least liked alternative. Both tables show comparative choices among the

alternatives listed and do not indicate the degree to which respondents

favor each of the individual alternatives.

(2) In the IIHS survey, respondents were told that "some states are

considering seat belt use laws that would impose fines on motorists who

don't wear their seat belts." They were then asked the following question:

"If you had to choose between a seat belt law or automatic protection such

as air bags or automatic belts, which would you prefer?"

Prefer law 218S

Prefer automatic 48°•a

protection

No preference

Neither/don't know/

not sure

As shown, respondents voted a more than 2 to 1 preference for automatic

restraints. The agency believes, however, that the response for automatic

restraints was likely inflated due to the information presented to

respondents and how the question was worded. The explanation of seat belt

use laws seems to convey a certainty that fines, of some unknown magnitude,

would be levied if the seat belt is not worn. The acceptability of a seat

belt use law alternative is then weighed against the acceptability of

automatic protection to which no cost is assigned. The results, therefore,

are based on these assumptions.
XI-72

d. Mandatory Seat Belt Use Law

Of the two surveys, only the GM survey directly addressed the issue of a

mandatory seat belt use law. Respondents were asked if they would be in

favor of a mandatory seat belt use law making them subject to a traffic

violation ticket if they don't buckle up. Results:

In favor of 35?o

Not in favor of 65%

These results can be considered representative of new car buyers.

Both the GM and IIHS surveys contained several other questions. The reader

is directed to the respective surveys for the participants' responses.

In summary, the data derived from public opinion surveys, information and

material submitted to the docket, and public opinions expressed at the

public hearings and in response to the NPRM and SNPRM, all clearly point to

the need for public education on the subject of occupant protection. The

public generally seems to lack sufficient information on the importance of

occupant restraints in preventing deaths and injuries and has very little

or no information on automatic restraint systems. There are also

indications that educational efforts have positive effects in influencing

public attitudes toward programs designed to enhance occupant crash

protection.
XII-1

XII. ALTERNATIVES

The October 1983 Notice of Proposed Rulemaking proposed a broad range of

possible alternative approaches for the resolution of the automatic

restraint issue. The Notice solicited public comments on each of these

proposals, as an important aid in considering the comparative merits of

each proposal. Docket commenters were also encouraged .to and subsequently

provided additional alternatives including the possibiJity of combining

some of the alternatives, e.g., a mandatory belt use law with an automatic

restraint requirement.

After reviewing the extensive comments (over 7,800) received at the public

hearings and in the docket, the Department identified four additional

alternatives in the Supplemental Notice of Proposed Rulemaking (SNPRM) of

May 1984 and requested further comments. Thus, the Department has a large

list of possible alternatives to consider. These are shown in Table XII-1.

TABLE XII-1

ALTERNATIVES

Alternative

#1 Require air bags

#2 Require automatic restraints, disallowing detachable

belts

#3 Require automatic restraints, allowing detachable

belts

#4 Rescind the standard

#5 Center seating position and driver only sub-alternatives
XII-2

#6 Require air bags for drivers in small cars

#7a Mandatory use laws, in general

#7b If any state passed a mandatory use law, a waiver from

the automatic restraint requirements would be granted

for cars sold to residents of that state

#7c Automatic occupant restraints would be required in all

cars manufactured after a set date unless 75 percent

of the states passed mandatory use laws

#8 A mandatory consumer option

#9a Government subsidized demonstration program

#9b The government would seek an agreement with automobile

manufacturers to provide a fleet of vehicles equipped

with automatic restraints

#9c Mandatory demonstration program

#10 Retrofit Program

This chapter presents a comprehensive summary of the major issues surfaced

in comments at the 12/83 public hearings, in docket responses to both the

10/83 NPRM and the 5/84 SNPRM, as well as in the Department's examination

of these proposals. For each alternative, a brief description of arguments

both in favor of and against its selection is presented, followed by a

summary of the positions taken by interested parties in their public

comments.

Alternative #1: Require Air Bags for All Front Seat Occupants

Pros:

o Would ensure a usage rate of near 100 percent for drivers and passengers.

Even those hard core non-users of belts, who may be overinvolved in serious

accidents, would be protected in frontal crashes. (Note that this "usage"
XII-3

rate is for air bags, not lap belts or lap/shoulder belts which would

accompany an air bag system and which we have assumed would be used at a

level near the current level of belt usage.)

o Significant safety benefits. Would save 4,410-8,960 fatalities and

83,480-152,550 moderate to critical injuries per year, assuming 12.5

percent usage of lap belts with the air bag systems.

o Insurance premium reductions are estimated to be $76-158 over the car's

lifetime (present discounted value).

o In frontal crashes, provides protection at higher speeds than safety

belts and protects against some injuries that are particularly costly and

debilitating (e.g., brain and facial injuries) which belts may not be as

effective in preventing.

o Encourages continued development of air bag technology, which could

result in more effective and less costly air bags.

o Avoids objections about obtrusiveness of alternatives under which

continuous automatic belts would be installed and avoids objections to the

government mandating the use of safety belts.
XII-4

Cons:

o Increase in retail price, $320, might adversely affect auto sales,

profits and employment in the short run. Net lifetime consumer cost is

estimated to be $206-288.

o Surveys indicate a significant degree of fear or misunderstanding among

those parts of the public that oppose air bags.

— People have fears about alleged hazards associated with air bags, e.g.,

inadvertent activation. Repair personnel also fear inadvertent deployment

while they are working on car interior.

— People are concerned about reliability of air bags.

— The cost could create a negative attitude towards air bags and

government regulation.

— Equity argument for current belt users — very little additional

protection is achieved at much greater cost.

o Questionable authority to mandate air bags given statutory requirement

for performance standards.

o Necessary Leadtime longer for this alternative than for other automatic

restraint alternatives.
XII-5

o Possible technological problems with air bags in small cars and with

out-of-position occupants.

o Some manufacturers believe that air bag tests are not sufficiently

repeatable to enable manufacturers to assure themselves of compliance.

o Must use lap or lap/shoulder belts for the most effective occupant

protection. When belts are not used in conjunction with air bags, air bags

provide less protection than manual three-point belts ('when used),

o Repair shops are concerned about potential liability for failure of a

car's air bags after repair work on car.

o Possible dangers posed by persons tampering with unfired sodium azide

canisters and by scrapping cars with unfired canisters.

Generally, this alternative is supported by the insurance industry, medical

and health organizations, and many consumer groups. Support from these

groups stems primarily from the feeling that it offers the highest

potential safety benefits. Both health and insurance organizations point

out that air bags are the most effective safety device in the more serious

accidents, and that they would be the most effective way of combatting the

most debilitating forms of injury, such as head and spinal column injuries.

Especially strong support was indicated by Allstate Insurance, The Center

for Auto Safety, Joan Claybrook—of Public Citizen, The Insurance Institute

for Highway Safety, Ralph Nader—of Center for the Study of Responsive Law,

National Head injury Foundation, and Nationwide Insurance. Many supporters
XII-6

of air bags also support requirements for automatic restraints in other

forms such as automatic belts. Commenters that supported air bags but

focused their support primarily on automatic restraints in general include

Consumers Union, James P. Corcoran (Superintendent of Insurance, NY),

National Safety Council, Dr. William Nordhaus—Professor of Economics at

Yale University—commissioned by a group of insurance companies, and State

Farm Insurance. Some individual consumers also commented in favor of

air bags.

Opposition to an air bag requirement was expressed by the automobile

industry, automobile dealers, and one consumer group. The basis for this

opposition is primarily the contention that higher costs associated with

these devices will have adverse impacts on sales and employment, that the

devices are untested and may create hazards of their own, and that much

cheaper ways are available for achieving the same safety benefits. Numerous

comments from individual consumers also express fear and insecurity

about air bag performance. Commenters including GM, Ford, Chrysler,

Nissan, Honda, VW, the National Automobile Dealers Association, the

Automobile Importers of America, the Motor Vehicle Manufacturers

Association, and the Pacific Legal Foundation submitted arguments against

requiring air bags. Most groups opposing air bags favored mandatory belt

use laws as an alternative method of achieving improvements in highway

safety. Notably, Ford Motor Company supports the idea of equipping a test

fleet with automatic restraints, including air bags, in order to determine

both consumer acceptance and performance of these devices.
XII-7

Alternative #2. Require Automatic Protection for All Front Seat Occupants

However, Detachable Belts are Not Allowed

Pros and Cons assume non-detachable belts will be used in most cars.

Pros:

o Eliminates detachable automatic belts, whose usage rate is the most

uncertain.

o Compared to the air bag only alternative, would be less expensive to

manufacturers and consumers. Also would avoid possible problems associated

with developing air bags for small cars.

o Insurance premium reductions of $7-22 over the car's lifetime, assuming

belt usage of 20 percent, and $100-144 assuming usage of 70 percent.

o Could result in significant safety benefits, depending upon belt usage.

At 20 percent usage, 520 to 980 fatalities and 8,740 to 15,650 AIS 2-5

injuries could be reduced. At 70 percent usage, 5,030 to 7,510 fatalities

and 86,860 to 124,570 AIS 2-5 injuries could be reduced.

Cons:

o Air bags would probably be installed in a low percentage of cars, with

the result that economies of scale could not be achieved and high prices

would be charged for air bags.
XII-8

o Public acceptance:

— Some people may find non-detachable automatic belts uncomfortable,

inconvenient, and obtrusive.

— Obtrusiveness of non-detachable automatic belts might hamper car sales.

— Some people may fear entrapment by non-detachable automatic belts.

— Defeat by hard core non-users (e.g., cutting the belt) could result in

original and subsequent owners and passengers being deprived of the

opportunity to use belts.

o Public clamor about non-detachable automatic belts, the most coercive

type of automatic restraint, could damage other safety initiatives.

o Public unfamiliarity with egress mechanisms may result in some cases of

entrapment.

o Current manual belt users might argue that automatic belts offer no

additional protection, but could cost more over the car's lifetime and

might be inconvenient and obtrusive.

o Opponents might argue that it is improper for the government to coerce

citizens into saving their own lives. Similar arguments have been used to

overturn motorcycle helmet laws.
XII-9

o Might lead manufacturers to eliminate center front seat because there

is no commercially developed technology to provide an automatic belt

for that seat. Even if front center seat is exempt from the standard,

manufacturers may eliminate this seating position since there is no easy

way of entering this seating position with a non-detachable belt.

o No way to be certain how much usage would increase.

Requirements for automatic belts are generally favored by the insurance

industry, medical and health organizations, and most consumer groups. Some

of these organizations expressed a preference for air bags over automatic

belts, but most favored automatic belts over the status quo or State use

laws. Generally, supporters of automatic belts view these devices as an

effective and inexpensive method of reducing fatalities and injuries. The

issue of belt detachability was only addressed by a few supporting

commenters. Overall it appears that supporters view automatic belts as

effective safety measures in either detachable or non-detachable versions.

Requirements for automatic belts are opposed by the automobile industry,

automobile dealers, and one consumer group. As with air bags, these groups

contend that automatic belts will raise costs unnecessarily, and that there

is a more effective method of improving highway safety; i.e., seat belt

usage laws. A further contention of opponents is that automatic belts will

be rejected by consumers for either convenience considerations, fear of

entrapment, or philosophical objections and therefore, will not result in

significant safety improvements. On the question of belt detachability,
XII-10

opponents of automatic belt systems generally felt that non-detachable

belts might offer some short term usage improvement over detachable belts,

but that there could be more adverse public reaction to the nature of

non-detachable belts and the increased difficulty of emergency egress with

such systems. Over the long-run they believe usage rates would be roughly

the same for either system. For these reasons many manufacturers indicated

that they would not equip their cars with non-detachable automatic belts if

they were free to choose between detachable and non-detachable automatic

belts.

Alternative #3: Require Automatic Protection for All Front Seat Occupants

Detachable Belts Are Allowed

(This is a reinstatement of the existing standard.)

Pros and Cons assume detachable belts will be used in most cars.

Pros:

o Could result in significant safety benefits, depending upon belt usage.

At 20 percent usage, 520 to 980 fatalities and 8,740 to 15,650 AIS 2-5

injuries would be reduced. At 70 percent usage, 5,030 to 7,510 fatalities

and 86,860 to 124,570 AIS 2-5 injuries would be reduced.

o Should be the least objectionable automatic restraint requirement to

those who oppose automatic restraints. Over the long run, would provide

greatest flexibility for manufacturers and consumers in selecting type of

automatic restraint systems.
XII-11

o Detachability should alleviate some consumer concern about automatic

belts and governmental involvement in the consumer's decision about belt

usage.

o Would result in real-world data to evaluate usage and effectiveness of

detachable automatic belts.

o Would be less expensive to manufacturers and to consumers than would an

all air bag rule.

o Insurance premium reductions of $7-22 over the car's lifetime, assuming

belt usage of 20 percent, and $100-144 assuming usage of 70 percent.

Cons:

o Could result in consumers only being offered detachable automatic belts,

the type of automatic restraint with the most uncertain usage. (It is

estimated that nearly all manufacturers would meet the standard with belts

if required in the near future.) Additional lifetime expenditures ($51 per

car) would be made for what may be relatively small safety benefits.

o Current manual belt users could argue that automatic belts would

offer no additional protection, but would cost more.

A discussion of the positions taken by interested parties is included under

Alternative #2.
XII-12

Alternative #4: Rescind the Requirements for Automatic Restraints

Pros:

o Avoids requiring an increase in cost to manufacturers and price to

consumers.

o Public acceptance:

- Avoids government forcing public to buy automatic restraints.

— Avoids forcing current manual belt user to pay more for little, if any

additional protection.

o Allows manufacturers choice of whether and when to introduce automatic

restraints on any of their models.

o When used, manual belts are as effective (or even more effective) than

air bags or automatic belts.

Cons:

o Would not decrease deaths and injuries.

o In view of the State Farm, Supreme Court decision, requires better

justification than was used in 1981 for rescission; the Department did not

obtain data to support such justification during the public comment period.
XII-13

o Public acceptance!

— Consumers wishing to purchase automatic restraints likely to have more

limited range of models to choose from, especially in the case of air bags.

o Would lessen incentives to pursue the development and marketing of

automatic restraint technology.

Rescission of the automatic restraint standard was generally favored by the

automobile manufacturers, automobile dealers, and one consumer group. In

most cases, support for rescission was based on the contention that the

effectiveness of regulatory solutions has not been adequately proven, that

such requirements would be costly and ineffective and that they would be

rejected by consumers and that satisfactory procedures for determining

compliance did not exist. Criticism of regulatory solutions was, in many

instances, coupled with support for other non-vehicular actions, especially

for State laws mandating the use of existing belts. Many opponents of

regulatory solutions view this as the most efficient and effective way of

achieving improvements in highway safety. Numerous consumer comments were

also received favoring rescission of the standard.

Generally, the same commenters that opposed automatic restraints supported

the rescission option (although support for rescission was frequently

implicit rather than the focus of comments). However, Ford Motor Co.

argued for a suspension of several years, rather than a rescission of the

standard. Under Ford's proposal, during the suspension a test fleet would
XII-14

be equipped with automatic restraints to determine consumer acceptance and

performance of these devices. The ultimate decision to rescind or regulate

would then be made in light of the experience of the test fleet.

Opposition to rescission was implicit in arguments favoring various forms

of automatic restraints. Overall, opposition was expressed by the

insurance industry, medical and health organizations, most consumer groups

and numerous individuals. These groups cite the potential injury and loss

of life that could be prevented by automatic restraints as arguments

against rescinding FMVSS 2D8. They tend to view mandatory State usage laws

as inadequate due to the uncertainty over their passage and enforcement.

Alternative #5: Center Seating Position and Driver Only Sub-Alternatives

Pros of Requiring Automatic Protection for Center Seating Position

o Provides all front seat occupants with automatic protection.

o Avoids objections about not providing all front seat passengers with the

same type of protection.

Cons of Requiring Automatic Protection for Center Seating Position

o Only 1.5 percent of front seat fatalities and injuries are projected for

the center seating position.
XI1-15

o Could result in the elimination of the center seating position if

manufacturers did not install air bags. Loss of that position could cause

consumer backlash. Air bags would raise costs.

o Ford indicated the center seat may be eliminated even in air bag cars

due to problems with out-of-position occupants.

As discussed previously, comments to the Docket on the center seating

position by Ford, AMC, Consumer's Union, and the American Automobile

Association, favored exempting the center seat position from the standard

in order to retain six-seat cars. One commenter argued that the center

seat position should not be exempt from the standard since young children

were frequently injured in this seating position. While this is true,

Child Restraint Laws are now in place in 46 states and have already started

to reduce the high percentage of young child fatalities in the center seat

position.

Pros of Requiring Driver Only Automatic Restraints

o Is the most cost beneficial approach since 73 percent of the fatalities

occur to drivers while only 50 percent of automatic belt costs and 64

percent of air bag costs are attributable to the driver.

Cons of Requiring Driver Only Automatic Restraints

o All front seat occupants might not be protected by similar restraint

systems.
XII-16

There were very few comments to the docket regarding driver only

alternatives. Professor Nordhaus (74-14-N35-079) concluded in his analysis

that any automatic restraint in any seating position would be cost

beneficial. Thus, all seating positions should be covered. John Graham,

of Carnegie Mellon University, (74-14-N35-063) favored the driver only

alternatives because they were the most cost beneficial. Others suggested

the driver only alternatives might be a good way to introduce air bags

initially without the full cost.

Alternative # 6 — Driver-side Only Air Bags for Small Cars: One of the

alternatives proposed by the SNPRM would require that air bags be installed

on the driver side of small cars only. It assumes that air bags would be

the basis for compliance in these positions and vehicles, rather than a

supplemental system to the safety belt. Under this alternative, the final

rule could prescribe either manual belts or. any type of automatic restraint

for the other seating position in small cars and all seating positions in

all other cars. The basis for proposing this alternative is the perception

that small cars are less safe than larger vehicles and the fact that

drivers account for three-fourths of all front seat fatalities in

automobile accidents. By requiring air bags only in those vehicles and

positions where potential safety benefits are maximized, significant cost

savings can be accomplished. The SNPRM did not define "small cars,"

however, and asked for comment as to which criteria would be appropriate

for this purpose.
XII-17

Pros:

o Would provide a high level of potential protection for those vehicles

and seating locations that are most likely to involve injury to

occupants.

o Relative to full frontal air bag requirement for all cars would allow

significant cost savings to consumers.

o Would assure that new vehicle fleets have a variety"of driver restraint

systems, thus allowing consumers to choose the restraint system they

prefer.

o Would accelerate air bag development by improving public awareness of

air bags and providing additional information on effectiveness.

Cons:

o Would not assure automatic protection for other front seat occupants,

accounting for a quarter of all small car front seat fatalities.

o Would not provide automatic protection for larger cars.

o May result in higher per unit costs for air bags due to lower production

volumes.

o Would require longer leadtime than automatic restraints, which would

delay safety benefits.
XII-18

o Added cost of air bag may hurt small car sales and decrease fuel

efficiency of the fleet.

This alternative was generally opposed by both the automobile and the

insurance industry but for different reasons. The automobile industry was

unanimous in its disapproval, citing damage to small car sales and CAFE

requirements, limitations in air bag technology, and lack of justification

for requiring air bags on any specific kind of vehicle. Opposition from

the insurance industry generally focused on the failure of this alternative

to provide automatic protection for occupants of large vehicles and for

other front seat occupants. Other commenters, including state and local

governments, dealer associations, independent researchers, and the general

public were overall but not unanimously opposed to this alternative,

usually for the reasons cited above by the automobile and insurance

industries. Only one commenter, John Graham, a Harvard economist,

unequivocally favored this alternative. His reason was that it provided

the most favorable benefit/cost ratio.

Alternative # 7a — Mandatory Seat Belt Usage Laws; This alternative would

require action by state legislatures to pass laws requiring that seat belts

be used. To be effective, these laws would probably have to be coupled

with an effective enforcement program. The Department's role in this

alternative would be limited to providing incentives for state action.

Because of uncertainty regarding the number of states that would pass such

laws and the levels of compliance, the precise level of benefits associated

with this alternative cannot be determined.
XII-19

The Supplemental Notice of Proposed Rulemaking proposed two alternatives

relative to mandatory seat belt use laws. These are:

Alternative # 7b — If any state passed a mandatory use law, a waiver from

the automatic restraint requirements would be granted for cars sold to

residents of that state.

Alternative # 7c — Automatic occupant restraints would be required in all

cars manufactured after a set date unless 75 percent of the states pass

mandatory use laws.

The Department would issue minimum criteria for each state's mandatory use

law as follows:

1) A requirement that all front seat occupants in passenger cars be

restrained.

2) A prohibition of waivers from the mandatory use law, except for

medical reasons.

3) A program that includes such things as:

a) A penalty of $25 or more.

b) Civil litigation penalties; a reduction in damages a person may

recover from injuries in litigation.

c) Education programs.
XII-20

d) The posting of roadside signs notifying motorists of the seat

belt use law.

e) An evaluation program.

In addition, the Department indicated that it would be necessary for the

manufacturers to submit reports to the Department certifying that they

were making steady progress towards the installation of automatic

restraints.

Alternative # 7a — Mandatory Use Laws (MULs), In General.

Pros:

o MULs affect the whole fleet of cars initially rather than just new cars.

Thus, MULs would provide more immediate and short term benefits than

automatic belts.

o MULs would not raise the price of new cars.

o MULs maximize the use of 3-point manual belts which provide the highest

overall level of effectiveness in reducing deaths and injuries.

o MUL's have increased usage considerably in other countries; they should

logically increase usage by a large margin in the U.S. as well.
XII-21

Cons:

o The number of states that would pass a MUL is not certain.

In general, the automobile manufacturers favor MULs as the alternative that

is the most effective, in terms of safety, the most cost-effective, and

provides the highest benefits in the short run.

MULs are viewed by the automobile manufacturers as a replacement for an

automatic restraint requirement. They believe the federal government

should provide incentives for state passage of MULs. Ford favored MULs and

a demonstration program, saying they are not mutually exclusive. GM

favored MULs and proposed a passive interior alternative, discussed earlier

in Chapter III—Issues.

The insurance companies, in general, the Institute of Transportation

Engineers, Public Citizen, and a number of commenters from state

governments believe that automatic restraints and MULs complement each

other very well. They favor reinstating FMVSS 208 and then providing

incentives for States to enact MULs. Automatic belts could be seen as a

method of assisting and ensuring compliance with MULs. Allstate, IIHS,

State Farm, and Public Citizen expressed their view that reliance on an MUL

alone is contrary to the Department's mandate and statutory authority.

Other commenters stated that there were so few states that would pass a MUL

that it was not a usable alternative, or that a national MUL would be

preferable to state by state MULs.
XII-22

Alternative # 7b — States passing MULs would get a waiver from the

automatic restraint requirement.

Pros:

o MULs provide immediate benefits for all cars in states that pass these

laws rather than just for new cars.

o New car purchasers in states with MULs would save money compared to an

automatic restraint requirement.

Cons:

o Manufacturers would have to make the initial investment necessary for

automatic restraints, regardless of specific requirements in individual

states.

o Would result in a two-car system, increasing costs and administrative

burdens for the manufacturers.

o There is no high level cut-off point as in alternative 7c. If 48 states

passed MULs, the manufacturers would still have to have two different

restraint systems.
XII-23

o Dealers with interstate market areas would encounter difficulties in

ordering and stocking cars, model availablity, and assuring the sale of

properly configured vehicles. Field inventory flexibility may be

constrained if cars cannot be moved between states.

o Changes in buying habits may develop along state lines.

— An "almost new" used car market may develop between states. This can

be somewhat controlled at the dealer leve] by defining "new" car as one

with up to 3,000 miles on it.

— Consumers from a state with a mandatory use law, who want to purchase

an automatic restraint car, might have to buy it in another state.

— Used manual belt cars might be shipped to automatic restraint states

for sales as was prevalent with the California emission standards.

o It would be difficult to police interstate sales.

While nearly all commenters favor MULs, this particular approach was

opposed by almost all commentors.

The automobile manufacturers were generally opposed to this alternative for

a number of reasons:
XII-24

o Leadtime—Peugeot stated: Because there is no state decision deadline

and a two-year leadtime, automatic restraints will be put on all cars

initially whatever the states decide.

o Production, inventory, and sales problems.

o MVMA stated the effect of incentive or disincentive to MUL state passage

is hard to predict. It may resuJt in legislators debating the merits of

both systems, resulting in delays in obtaining MULs;

o Manufacturers' reports are an unnecessary burden--if they don't supply

automatic restraints, they can't sell the cars; thus progress is ensured

without the need for such reports.

o GM stated the two car strategy would be extremely costly and disruptive

to normal commerce.

The insurance companies also opposed this alternative, some stating that it

would violate Congress' mandate to prescribe uniform national standards and

that it was unlawful.

The Institute of Transportation Engineers said that state by state MULs

would undermine public acceptability of automatic restraints. John Graham

indicated that a waiver should be contingent on manual belt usage (however

achieved), not passage of a law.
XII-25

Commenting state representatives generally did not like the way this

alternative positioned federal automatic crash protection against state

mandatory use laws. This would advance the belief that automatic

restraints and seat belt use are mutually exclusive, which is especially

damaging for air bags. They also believed that setting federal criteria for

state MULs was inappropriate—that the proposed criteria should be

guidelines. Generally, they opposed the alternatives on the grounds that

the re-imposition of FMVS5 208 and state MULs were not mutually exclusive,

that Federal involvement in state MULs is inappropriate, and that

specifying criteria would only inhibit passage of such laws.

Alternative # 7c — Rescission of automatic restraint requirement if 75% of

the states enact MULs.

Pros:

o MULs affect the whole fleet of cars initially rather than just new cars.

Thus, MULs would provide more short term benefits and, if all states

passed MULs, the same or more long term benefits as automatic belts.

o If the required number of states passed MULs, manual belts which add no

new cost to a car could continue to be installed.

o This alternative would not result in the two-car system, with the

identified problems as discussed in alternative # 7b.
XII-26

Cons:

o A short leadtime for FMVSS implementation could force the manufacturers

to make the investment necessary for automatic restraints. If 75% of the

states then passed MULs, this investment would be wasted.

o Could result in some states having neither MULs nor automatic

restraints.

o Because states could repeal MULs, a reinstatement of an automatic

restraint requirement would involve a long leadtime and would delay

potential benefits.

Several manufacturers suggested changes to the leadtime proposed for this

alternative. BMW and Ford suggested a separate state decision deadline

before tooling commences so that investments would not be wasted. Some

manufacturers suggested progress milestones (e.g., if 10* of the states

pass an MUL by 1986, the compliance date for manufacturers would be

delayed). This progress milestone leadtime alternative was advanced based

upon the child restraint experience, which started slowly with Tennessee

passing the law in 1977, Rhode Island in 1980, seven more states in 1981

and 46 states as of June 1984. Some of the manufacturers supported a

policy of cancelling the automatic restraint requirement if belt use

reached a specified level. As with the previous alternative, the

manufacturers oppose reporting requirements, oppose federal MUL criteria,

and favor federal incentives as proposed in Congressman Dingell's bill.
XII-27

Several of the insurance companies stated this alternative was contrary to

DOT's mandate and authority. Professor Nordhaus argued that the

manufacturers would take the least costly approach, hoping that 75% of the

states would pass MULs, resulting in poorly designed and under tested

systems.

John Graham argued that the 1974-76 experience suggests the states won't

be enticed to pass MULs even with incentives. He claims there is no reason

to believe that an automatic restraint waiver is more enticing than

incentive funds. Also, he claims under the 75* rule that no single state

would have an incentive to pass an MUL unless many other states acted

first, or enough other states would go along.

Alternative # 8 — Mandatory Consumer Option: Under this alternative, the

Department would seek legislation requiring automobile manufacturers to

provide consumers with the option of selecting automatic restraints in some

of their models.

Pros:

o Would allow for the development of real world data on both restraint

effectiveness and consumer acceptance.

o Would allow consumers the choice of selecting either automatic or manual

belts.
XII-28

Cons:

o Data on restraint effectiveness obtained from this approach would be of

limited value because sample of owners would consist of voluntary buyers

and would thus be self-selecting towards those members of the public who

are more safety conscious.

o Data on public acceptance might similarly be flawed. Because of low

volume production, restraint prices would be high and this may

discourage many persons who would participate at lower prices.

o Implementation of this approach would be uncertain because Congressional

action would be required.

No significant support was expressed for this alternative in the public

docket.

Alternative # 9 — Demonstration Programs; There were three separate

demonstration programs considered in the NPRM or SNPRM — a) the government

would subsidize a special fleet of vehicles equipped with automatic

restraint systems; b) the government could seek an agreement with

automobile manufacturers to provide a fleet of vehicles equipped with

automatic restraints; or c) a mandatory demonstration program — as

proposed in the SNPRM based on Ford's proposal.
XII-29

Alternative # 9a — Government Subsidized Fleet; Likely participation in a

subsidized fleet program would include state and Federal Government

agencies, insurance companies, or other corporate fleet operators.

Pros:

o Would allow the public to become more familiar with automatic

restraints.

o Would increase field experience and data relevant to public protection.

Cons:

o Information obtained from these groups would not exactly replicate the

experience that could be considered typical of the average driver. Even

fleet operators would not typically have the high risk night time

driving. Thus, this would only provide limited nationally

representative data.

Alternative # 9b — The government would seek an agreement with automobile

manufacturers to provide a fleet of vehicles equipped with automatic

restraints.

Pros:

o Would allow the public to become more familiar with automatic

restraints.
XII-30

o Would increase field experience and data relevant to automatic

protection.

Cons:

o Since participation in this program is voluntary, the implementation and

adequacy of the program is questionable.

o If used alone might not satisfy the requirements of the State Farm

Supreme Court decision.

Alternative # 9c — Staged Mandatory Demonstration Program: Manufacturers

would be required to equip a fixed percent of their cars sold in the United

States with automatic restraints. The requirement would apply for four

consecutive model years. Accident and operating experience would be

closely monitored over a 5-year period, the principal objectives being to

gauge the casualty-reducing effectiveness of air bags, the usage of

automatic belts over time, and the operational problems and public reaction

to both systems.
XII-31

Pros:

o Would resolve many of the uncertainties we now have about air bag

effectiveness, automatic belt usage and public acceptance of automatic

restraints.

o Avoids the possibility of another ignition interlock or Standard 121 -

the mandate of an insufficiently tested safety device which may turn out

to be marginally effective or unacceptable.

Cons:

o Possible difficulties in selling the cars equipped with automatic

restraints, when comparable cars can be bought without them.

o Unit costs of equipping less than all cars with automatic restraints

might be higher than full implementation, especially for manufacturers

with low sales volume in the United States.

o Without assurances that a portion of the cars in the program will have

air bags the demonstration will not achieve clear-cut results on air bag

effectiveness.

o Without assurances that a large percent of a particular model would be

equipped with automatic belts, the self selection bias may result in the

demonstration program not achieving clear-cut results on automatic belt

usage (see "guidelines" below).
XII-32

The proposed demonstration was favored in principle (at 5 percent of each

manufacturer's fleet) by many auto manufacturers as providing necessary

data on effectiveness and public acceptance and it was opposed by insurance

companies as resulting in unnecessary delays.

Although most manufacturers (Ford, AMC, Chrysler, Mazda, Volvo, VW,

Peugeot, Mercedes, BMW) favor a demonstration program, at least compared to

reinstatement of FMVSS 208, there was widespread opposition to the

specifics of the proposal discussed in the SNPRM. Many of the smaller

manufacturers did not object to a demonstration program as long as it only

applied to larger companies, AMC, Lotus, and Renault took this position.

Conversely, Toyota said any demonstration must include all companies.

Many companies (including Ford, BMW, AMC, Chrysler, Volvo, Toyota) favored

a demonstration program but only if the choice of automatic restraints was

left to the manufacturer and could be limited to the driver side only or

if the test procedures were changed as Ford desired or waived altogether.

Nissan, GM and Chrysler questioned whether they could voluntarily sell even

5 percent of their cars with automatic restraints. GM also doubted whether

a demonstration would answer the questions of public acceptability and

cost. Saab called the program unrealistic, claiming it would only prolong

uncertainty while Mazda, Volvo, and Ford favored the program as proposed.

However, Ford stated that they envisioned a program that would result in an

average of 5 percent of their fleet being equipped with automatic

restraints over a 4-year period, not necessarily 5 percent per year. T»-'
XII-33

type of program may lengthen the evaluation time frame. Nissan could

participate if it had 30 months leadtime while Chrysler said it could

participate beginning in September 1986 but only for a 2-year (not 4-year)

period.

Insurance companies (Allstate, State Farm, NAII) characterized this option

as an unnecessary delay and claimed there have already been sufficient

"demonstrations" of air bags (GM and Mercedes) and automatic belts (GM, VW,

and Toyota). Allstate questioned DOT's authority to deny safety benefits

to the car owners not involved in the program. The Insurance Institute for

Highway Safety felt the program could be a useful supplement to an

automatic restraint rule.

The Institute of Transportation Engineers also called the program

unwarranted as did NADA, Professor Nordhaus, and several individual

economists. Nordhaus also wondered what, if anything, would be

demonstrated by a program with a selection bias (i.e., only those who

desire automatic restraints will purchase them).

The State of Washington and the American Seat Belt Council agreed with

having a demonstration program but they also supported the implementation

of FMVSS 208,
•XII-34

Alternative # 10 — Require Air Bag Retrofit Ability: This alternative

would require that all passenger cars have steering columns and passenger

side instrument panels that can be easily modified to accept the

aftermarket installation of an air bag system.

Pros:

o Would enable consumers to voluntarily purchase air bag systems and have

them installed after vehicle purchase.

o Would make air bags available to those who want them without imposing

the full cost of these systems on other buyers.

Cons:

o Would minimize the safety benefits that could result from automatic

restraints.

o Since purchase would be voluntary, only the most safety conscious members

of society would participate. Drivers who are less concerned with

safety, and thus more likely to have a serious accident, would not

benefit from this option.

o Installation would be conducted by numerous outlets using personnel with

various levels of expertise. This could increase the possibility of

improper installation and could result in deployment failures.
XII-35

o Prices would increase on all passenger cars, regardless of air bag

installation.

o Aftermarket sales of air bags may be low, resulting in high costs for

each driver.

Comment on the retrofit option was limited. Breed Corporation indicated

that retrofit would be practical and would allow installation at either the

manufacturer, the dealer, or at a service center. Automobile manufacturers

pointed out cost problems, especially with low installation rates, and the

unproven performance of this type of air bag system.

Selected Alternative

The selected alternative is a reinstatement of the automatic restraint

requirements. If mandatory use laws are passed that will cover 67 percent

of the population effective September 1, 1989, the rule will be rescinded.

In addition, center front seats are exempt from the requirements of the

standard.

Following is the implementation schedule:

September 1, 1986 10%

September 1, 1987 25%

September 1, 1988 40%

September 1, 1989 & thereafter 100%
XII-36

During the MY 1987-89 implementation, manufacturers would be given a credit

equal to one and a half car for each car equipped with air bags and

other non-belt automatic occupant protection systems.

The selected alternative maximizes the benefits of several major

alternatives.

Specifically:

The potential benefits of mandatory use laws (MULs)-are substantial. As

discussed in Chapter VI of the FRIA, MULs can provide large immediate

benefits because they cover the in-use fleet as well as new production

vehicles. This alternative encourages passage of MULs and provides the

impetus for prompt action by states interested in this approach.

In addition, the benefits of automatic crash protection are realized

beginning in MY 1987.

Voluntary use of the manual belts that are already in passenger cars is

also expected to rise as a result of growing public understanding of the

value of belt use in general and automatic restraints in particular.

These same factors, together with additional publicity about automatic

restraints and the gradual phase-in of these devices, will allow the public

to become more familiar with both the use and importance of automatic

restraints. Thus, all three approaches - MULs, voluntary usage and

automatic restraints will be influenced by this alternative.
XII-37

Finally, the standard is written to provide manufacturers with incentives

to develop a variety of restraint systems. This will allow consumers to

choose from different restraint technologies and will encourage development

of unobtrusive occupant protection systems and new occupant safety

technologies.
XII1-1

XIII. NET IMPACTS OF AUTOMATIC RESTRAINT DEVICES

This chapter compares the benefits and costs of air bags and detachable and

non-detachable automatic belts. It also compares safety benefits and costs by

seating position. Insurance premium reductions and dollar costs (retail price

and fuel cost increases) are combined to provide a lifetime direct net dollar

cost per car to the vehicle owner. As explained previously, total potential

"societal" cost savings are not shown in this analysis, but are discussed in

Appendix 1.

Table XII1-1 presents the benefits (safety benefits and insurance premium

reductions) and costs (retail price increases and fuel costs) of air bags and

automatic belts by seating position. Costs and insurance premium reductions are

analyzed on a per car basis.

Table XII1-2 presents a breakeven analysis that shows the automatic belt usage

levels at which insurance premium reductions offset retail price and fuel costs.

The results of these analyses indicate the following:

Air Bags

Air bags for all front seating positions, with lap belts used at current usage

rates, are estimated to save 4,410 to 8,960 lives and 83,480 to 152,550 AIS 2-5

injuries per year. Lifetime costs are $364 per car for full front air bags.

Lifetime insurance premium reductions (assuming lap belts are used by 12.5% of
XII1-2

the occupants) are $76-158. The lifetime net dollar costs after insurance

premium reductions are subtracted from air bag costs are $206-288. If

installation of air bags caused passengers to ignore their lap belts, safety

benefits would be reduced, insurance premium discounts would not be as large,

and the net lifetime cost would increase slightly to $210-298.

If air bags were only installed in outboard positions, the slight reduction in

both costs and benefits would reduce net lifetime costs slightly to $199-280 at

current seat belt usage rates.

Supplying an air bag for the driver position only would cut both costs and

benefits dramatically with benefits dropping roughly 27 percent and costs

dropping 36 percent (from full front requirements). The net effect would be a

drop in lifetime costs to $128-188 at current belt usage rates.

Overall, examining cost and benefits by seating position shows that for air

bags, the driver will get 73 percent of the benefits while incurring 64 percent

of the net costs. Thus, supplying the driver with an air bag is more cost

effective than for the other two positions.

Automatic Belts

Data in Table XIII — 1 reflect a range of possible results depending on usage

rates for an all-automatic belt equipped fleet (with the center seat exempted).

See Chapter V for a discussion of the methodology used to set the bounds of the

automatic belt usage range—20?o to 70". At 20 percent usage, an estimated 520
XIII-3

to 980 fatalities and 8,740 to 15,650 AIS 2-5 injuries could be reduced, while

at 70 percent usage, an estimated 5,030 to 7,510 fatalities and 86,860 to

124,570 AIS 2-5 injuries could be reduced.

For driver and right front automatic belts (center seat exempted) lifetime costs

are $51 per vehicle. At 20 percent usage, lifetime insurance premium reductions

are $7-22 per car resulting in a net dollar cost of $29-44 per car. At 70

percent usage there would be a net dollar savings of $49-93 per car.

Supplying an automatic belt for the driver only would have a significant effect

on both costs and benefits. Net lifetime costs are $18-26 per car at 20 percent

usage, and net lifetime savings are $39-73 at 70 percent usage.

Table XII1—2 shows that for automatic belts (driver and front right passenger —

center seat exempt), the lifetime insurance premium reductions pay for the

lifetime costs at 32-44 percent belt usage (32 percent if automatic belts are 50

percent effective, 44 percent if they are 35 percent effective). That is, if

automatic belt usage increased to 32-44 percent, or above, there would be a net

dollar savings over the lifetime of the car by requiring automatic belts. Air

bag systems do not attain similar breakeven points. The estimated lifetime cost

of a full front air bag system is $364, while lifetime insurance premium

reductions range from $76-158. As discussed in the Summary, these are not

"societal" breakeven points as they do not include lost productivity, etc.
XI11-4

TABLE XIII-1

SUMMARY OF SAFETY BENEFITS AND NET DOLLAR

COSTS OR BENEFITS FOR AIR BAGS AND AUTOMATIC BELTS

(COSTS ON A PER CAR BASIS)

SAFETY BENEFITS

FATALS

AIS 2-5

INJURIES

INCREMENTAL

LIFETIME

COSTS

LIFETIME LIFETIME

INSURANCE NET DOLLAR

PREMIUM COST OR

REDUCTIONS (BENEFITS)

Full Front Air Bag With Lap Belt

No Usage of Lap Belt 3,780-8,630

12.5% Usage of Lap Belt 4,410-8,960

Driver and Front Right

Air Bag with Lap Belt

(Center Seat Exempt)

No Usage of Lap Belt 3,710-8,490

12.558 Usage of Lap Belt 4,340-8,810

Driver Air Bag

with Lap Belt

73,660-147,560

83,480-152,550

72,480-145,408

82,260-150,370

No Usage of lap Belt 2,680-6,250 56,330-114,370

14.0% Usage of Lap Belt 3,200-6,520 64,820-118,680

$364

364

354

354

232

232

$66-154

76-158

64-151

74-155

36-100

44-104

$210-298

206-288

203-290

199-280

132-196

128-188

Driver and Right Front

Automatic Belt

(Center Seat Exempt)

2058 Usage

10% Usage

Driver Automatic Belt

20?o Usage

70% Usage

520-980

5,030-7,510

270-580

3,610-5,440

8,740-15,

86,860-124

5,260-10,

67,160-96,

650

,570

370

770

51

51

26

26

7-22

100-144

0-8

65-99

29-44

(49)-(93)

18-26

(39)-(73)

Note: ( ) means dollar benefits (insurance premium reductions) exceed dollar costs.
xi r i-5

TABLE XIII-2

BREAKEVEN POINTS ANALYSIS OF

NET DOLLAR COSTS

—SAFET Y BENEFITS

Air Bag with Lap

Belt at 12.5% Usage

Driver and Right Front

Automatic Belt

(Center Seat Exempt)

20$ USAGE

30%

40%

50%

60%

70%

FATALS

4,410-8,960

520-980

1,420-2,280

2,320-3,590

3,230-4,900

4,130-6,200

5,030-7,510

AIS 2-5

INJURIES

83,480-152,550

8,740-15,650

24,370-37,440

39,990-59,220

55,610-81,000

71,240-102,790

86,860-124,570

INCREMENTAL

LIFETIME

COSTS

$364

51

51

51

51

51

51

INSURANCE

PREMIUM

REDUCTIONS

$76-158

7-22

25-46

43-71

62-95

80-120

100-144

NET DOLLAR

COST OR

(BENEFITS)*

$206-288

29-44

5-26

(20)-8

(1i)-(44)

(29)-(69)

(49)-(93)

Note: ( ) means dollar benefits (insurance premium reductions) exceed dollar costs.

* The breakeven point range for automatic belt usage is 32-44%. At this point, insurance

premium reductions equal lifetime costs.
X I V CONCLUSION S

Afte r a thoroug h revie w o f th e issu e o f automobil e occupan t

protection , includin g th e lon g regulator y histor y o f th e matter ;

t h e comment s o n th e Notic e o f Propose d Rulemakin g (NPRM ) an d th e

supplementa l Notic e o f Propose d Rulemakin g (SNPRM) ; th e extensiv e

studies , analyses , an d dat a o n th e subject ; an d th e cour t

decision s tha t hav e resulte d fro m la w suit s ove r th e differen t

rulemakin g actions , th e Departmen t o f Transportatio n ha s reache d

thes e conclusions :

Afte r assessin g th e dat a no w availabl e t o it , th e Departmen t

h a s revise d it s 198 1 analysi s concernin g th e likelihoo d o f

increase d usag e if automati c detachabl e belt s ar e installe d

t o mee t FMVS S 208 ; it canno t projec t eithe r widesprea d

usage , o r a widesprea d refusa l t o us e suc h system s b y

automobil e occupants .

° Whil e it is clea r tha t airbag s wil l perfor m a s expecte d in

virtuall y al l cases , it i s als o clea r tha t th e effectivenes s

o f th e airba g syste m is substantiall y diminishe d i f th e

occupan t doe s no t us e a belt . Consume r acceptabilit y is

difficul t t o predict , wit h th e majo r variabl e bein g cost ,

fear , an d th e unobtrusivenes s o f airbags .

Nondetachab1 e automati c belt s ma y resul t in sharpl y

increase d usage , bu t ther e ma y als o b e substantia l consume r

resistanc e t o them ;

T h e installatio n o f automati c occupan t protectio n in

passenge r car s ma y significantl y reduc e bot h fatalitie s an d

injuries .

T h e cost s o f th e existin g automati c restrain t system s ar e

reasonable , an d th e potentia l benefit s in live s saved ,

injurie s reduce d in severit y an d cost s avoide d ar e

substantial .

Technologically , th e system s are feasibl e an d practicable .

Effectivel y enforce d stat e mandator y seatbel t us e law s

(MULS ) hav e th e potentia l fo r providin g th e greates t safet y

benefit s o f an y o f th e alternative s at littl e o r n o

additiona l cos t ove r th e curren t cos t o f installin g

occupan t restraint s (primaril y manua l belts ) in ne w cars .

Automati c occupan t restraint s provid e suc h clea r safet y

benefit s that , unles s a sufficien t rumbe r o f MUL s ar e

enacted , the y mus t b e require d in al l passenge r automobiles .
° Certai n automati c occupan t protectio n systems , suc h a s

airbag s o r passiv e interiors , offe r suc h significan t

potentia l fo r preventin g fatalitie s an d injurie s tha t thei r

u s e shoul d b e encourage d throug h appropriat e incentives .

A s a resul t o f thes e conclusions , th e Departmen t ha s decide d

t o requir e automati c occupan t protectio n in al l passenge r

automobile s base d o n a phased-i n schedul e beginnin g o n Septembe r

1 , 1986 , wit h ful l implementatio n bein g require d b y Septembe r 1 ,

1989 , unles s befor e Apri l 1 , 1989 , two-third s o f th e populatio n

o f th e Unite d State s ar e covere d b y a Mandator y Safet y Bel t Us e

L a w meetin g specifie d conditions . Mor e specifically , th e rul e

woul d requir e th e following :

° Passenge r car s manufacture d fo r sal e in th e Unite d State s

afte r Septembe r 1 , 1986 , wil l hav e t o hav e automati c

occupan t restraint s base d o n th e followin g phase-i n

schedule :

0 Te n percen t o f al l automobile s manufacture d afte r

Septembe r 1 , 1986 .

Twenty-fiv e percen t o f al l automobile s manufacture d

afte r Septembe r 1 , 1987 .

0 Fort y percen t o f al l suc h automobile s manufacture d

afte r Septembe r 1 , 1988 .

0 One-hundre d percen t o f al l automobile s manufacture d

afte r Septembe r 1 , 1989 .

T h e requiremen t fo r automati c occupan t restraint s wil l b e

replace d b y allowin g th e installatio n o f manua l o r

automati c restraint s if MUL s meetin g specifie d condition s

a r e passe d b y a sufficien t numbe r o f State s t o cove r

two-third s o f th e populatio n o f th e Unite d State s befor e

Apri l 1 , 1989 .

Durin g th e phase-i n period , eac h passenge r automobil e tha t

i s manufacture d wit h a syste m othe r tha n seatbelt s bein g

use d t o provid e th e automati c protectio n t o th e drive r wil l

b e give n a n extr a credi t equa l t o one-hal f o f a n automobil e

towar d meetin g th e percentag e requirement .

T h e fron t cente r sea t o f passenge r car s wil l b e exemp t fro m

t h e requiremen t fo r automati c occupan t protection .