7858 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety

Administration

49 CFR Part 571

[Docket No. 96–095; Notice 3]

RIN 2127–AG50

Federal Motor Vehicle Safety

Standards; Child Restraint Systems;

Tether Anchorages for Child Restraint

Systems; Child Restraint Anchorage

System

AGENCY: National Highway Traffic

Safety Administration (NHTSA),

Department of Transportation.

ACTION: Notice of proposed rulemaking

(NPRM); request for comment.

SUMMARY: This document proposes to

require that motor vehicles and add-on

child restraints be equipped with a

means independent of vehicle safety

belts for securing the child restraints to

vehicle seats. The adoption of the

proposal would avoid problems of

incompatibility between child restraints

and vehicle safety belts and increase the

correct installation of child restraints.

This proposal would reduce allowable

head excursion, which would have the

effect of requiring child restraints to be

equipped with an upper tether strap,

and would require vehicles to have two

factory-installed, user-ready anchor

points for attaching the tether. It would

also require vehicles to have two rear

vehicle seating positions equipped with

a specialized lower anchorage system,

and require child restraints to be

equipped with means of attaching to

that system.

The proposal for the lower anchorages

is based on two of the systems discussed

at an October 1996 NHTSA public

workshop concerning alternative

systems for providing dedicated means

for attaching child restraints to vehicle

seats. Almost all of the different systems

evaluated and discussed at the

workshop appeared comparable in

terms of demonstrated safety and public

acceptance. However, one system

appeared to be less expensive and have

the advantage of using hardware

familiar to consumers. This system is

the ‘‘uniform child restraint anchorages

(UCRA) system,’’ referred to as such by

a consortium of manufacturing groups

in a June 28, 1996 petition for

rulemaking to the agency. The

International Standards Organization

(ISO) Working Group on child restraint

systems recognized in a November 1996

meeting the need for this system to

permit improvements in the short term.

The other notable dedicated system is

one supported by European members of

the ISO Working Group. This

alternative, which is completing

development, uses a two-prong

nonflexible item of hardware on the

child restraint to mate with two fixed

anchorages at the bottom of the back of

the vehicle seat without the use of any

belt webbing. Under today’s proposal,

either of these systems could meet the

proposed requirement for a dedicated

lower anchorage system, but

manufacturers installing the fixed

anchorage system would also have to

ensure that the system is compatible

with the UCRA system, so that UCRAtype child restraints can be used in all

vehicles equipped with either anchorage

system.

To the extent possible, this proposal

also harmonizes with the actions of

other regulatory agencies around the

world. This proposal seeks to harmonize

with Canadian and Australian

regulations by requiring an upper tether

anchorage and with prospective

European regulations by allowing a nonUCRA anchorage system.

This proposal pertains to the

compatibility of child restraints with

motor vehicle seats, and not that of

child restraints with aircraft seats. The

Federal Aviation Administration and

NHTSA are developing possible

requirements and procedures for

improving the compatibility of child

restraints in aircraft. If the agencies

decide that rulemaking is warranted on

that issue, such rulemaking will be

commenced as a separate action.

DATES: Comments on this notice must be

received by the agency no later than

May 21, 1997.

ADDRESSES: Comments should refer to

the docket number and notice number

and be submitted in writing to NHTSA’s

Docket Section at the following address:

Until March 10, 1997: Room 6130, After

March 10, 1997: Room 5109, 400

Seventh Street, S.W., Washington, D.C.,

20590. Telephone: (202) 366–5267.

Docket hours are 9:30 a.m. to 4:00 p.m.

Monday through Friday.

FOR FURTHER INFORMATION CONTACT: At

NHTSA, for nonlegal issues: Dr. George

Mouchahoir, Office of Vehicle Safety

Standards (telephone 202–366–4919).

For legal issues: Deirdre Fujita, Office of

the Chief Counsel (202–366–2992). Both

can be reached at the National Highway

Traffic Safety Administration, 400

Seventh St., S.W., Washington, D.C.,

20590.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Statement of the Problem

II. Improved Anchorage System

a. Standardized System

b. Competing Concepts

III. Public Workshop

a. Summary of Presentations

1. ISOFIX 4-point Rigid System

2. CANFIX 2-Point Rigid System

3. UCRA Soft Anchor System

4. European Industry Hybrid System

5. Car Seat Only System

b. Clinics

c. Cost

d. Tether

e. Agreement on Differences

f. Future Work

IV. Subsequent Developments

a. Albuquerque, N.M.

b. Additional Information

c. Petition on Scheme D (Hybrid System)

V. Evaluation of Concepts

a. Top Tether

b. Lower Anchorage Points

1. Improve Compatibility

2. Safety Performance

3. Consumer Acceptability

4. Costs and Burdens

5. Harmonization

6. Leadtime and Availability

7. Proposed System

c. Discussion of Alternatives

1. SAE Recommended Practice J1819

2. Lockability

3. Car Seat Only System

VI. Proposal for New Vehicle Standard

a. Highlights of Proposal

b. Applicability

c. Seating Positions

d. Construction

1. Lower anchorages

2. Upper anchorages

e. Performance

f. Instructions

VII. Proposal for Amendments to Child Seat

Standard

a. Applicability

b. Required Components

c. Dynamic Performance

d. Instructions and Labeling

VIII. Proposed Effective Date

IX. Rulemaking Analyses and Notices

a. Executive Order 12866 (Regulatory

Planning and Review) and DOT

Regulatory Policies and Procedures

b. Regulatory Flexibility Act

c. Executive Order 12612 (Federalism)

d. Unfunded Mandates Reform Act

e. National Environmental Policy Act

f. Executive Order 12778 (Civil Justice

Reform)

X. Comments

I. Statement of the Problem

The effective use of child restraints is

important because of the number of

children killed and injured in vehicle

accidents. Annually, about 600 children

less than five years of age are killed and

over 70,000 are injured as occupants in

motor vehicle crashes. Data from the

National Center for Health Statistics (for

1991) indicates that motor vehicle
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7859

1 ‘‘An Evaluation of the Usability of Two Types

of Universal Child Restraint Seat Attachment

Systems,’’ General Motors Corporation, 1996.

2 ‘‘The ICBC Child Restraint User Trials,’’ Rona

Kinetics and Associates Ltd. Report R96–04,

prepared for the Insurance Corporation of British

Columbia, December 1996.

3The Blue Ribbon Panel included child safety

advocates and representatives of the motor vehicle,

child safety seat and seat belt industries, including

representatives from Ford, Chrysler, General

Motors, Mercedes Benz, Volkswagen, BMW, Volvo,

Nissan, Toyota, Honda, Century, Gerry, FisherPrice, Cosco, Evenflo, Kolcraft, Riley Hospital,

DANA Foundation, American Academy of

Pediatrics, University of Michigan, TRW, and

Takata, and advocates Stephanie Tombrello and

Annemarie Shelness.

occupant fatalities were the third

leading cause of death for this age group

(NCHS, 1993).

While child seats are highly effective

in reducing the likelihood of death or

serious injury in motor vehicle crashes,

the degree of their effectiveness depends

on how they are installed. NHTSA

estimates that the potential effectiveness

of child seats, when correctly used, is 71

percent. However, it is estimated that

imperfect securing of children in the

child seats and/or of the child seats in

vehicles reduce that effectiveness from

the potential 71 percent to an actual 59

percent. That is, as a group, child seats

(those that were used correctly together

with those that were misused) have an

actual effectiveness of 59 percent.

Child restraint effectiveness is

reduced by limitations imposed by

vehicle belt design, and by belt

anchorage locations. Child seats are

generally designed to attach to a vehicle

by means of the vehicle’s lap belt

system. While child seats provide high

levels of safety when correctly attached

to a standard vehicle seat assembly with

only a lap belt, in most vehicles

different types of seat belt systems exist

in addition to or in lieu of a lap belt.

Among the different types are belt

systems with a locking latchplate, a

non-locking (sliding) latchplate, a

reversible lockable retractor, an

emergency-locking retractor, or an

automatic seat belt. Some of these belt

systems, such as those equipped with a

locking retractor, are able to hold a child

seat without use of attachment

accessories, but a parent must correctly

manipulate the system, such as by

pulling the belt completely out of the

retractor and then feeding excess slack

back into it after buckling in the child

seat. Some belt systems can be used to

secure a child seat only when used with

an accessory item that impedes

movement of the belt or child seat in a

crash, such as a locking clip or

supplemental strap. Some belt systems,

such as an automatic seat belt, may not

be compatible with a child seat at all.

The agency recognizes the difficulty

of designing vehicle seat belts to restrain

both child restraint systems and a wide

range of weights and sizes of

individuals. Some vehicle seats have the

seat belt anchorage positioned far

forward of the vehicle ‘‘seat bight’’ (the

intersection of the seat cushion and the

seat back). Forward-mounted anchor

points may better protect an adult using

the vehicle seat belt system by drawing

the vehicle belt low across the pelvis

where the body can best tolerate the

forces in a crash. However, when used

with a child seat, the belt anchor is so

far forward of the seat bight that the

vehicle belts cannot initially provide

any resistance to the forward,

longitudinal motion of a child seat

reacting to a decelerating crash pulse.

The child restraint moves forward until

it is sufficiently far forward of the belt

anchorages that the belt finally can

resist the forward, longitudinal motion

of the child seat. This forward

movement of the child restraint can

result in excessive forward movement of

the child’s head, and a greater

likelihood of head impact.

Child restraint effectiveness is also

reduced by incorrect securing of

children and child restraints due to the

complexities of adapting vehicle belts to

those purposes and due to failure to

follow instructions. To properly install

child restraints, devices such as

lockable retractors, locking clips, and

supplemental belts must be used in

many cases. Unfortunately, it appears

that many people installing a child seat

are either unfamiliar with the use of

these devices (which generally are not

used or needed except in conjunction

with a child restraint), not able to

understand or unwilling to read

instructions concerning their proper

use, or unable to surmise from their

design how to use them correctly.

People generally are frustrated about the

difficulty in installing child seats

correctly in vehicle seats. Recent user

trials conducted in the U.S.1 and

Canada 2 found that virtually all the

people surveyed in the studies

expressed high levels of dissatisfaction

with conventional means of attaching

child restraints in vehicles. NHTSA

receives an average of about 50 calls a

day to its Consumer Complaint Hotline

from people asking for step-by-step

guidance in installing their child seats.

When an article appears in the media

about incompatibility problems between

child restraints and vehicle seats, those

calls typically increase to over 500 a

day. All of these callers express

frustration at the difficulty of installing

a child seat securely, and all urge

NHTSA to make the installation easier.

NHTSA understands that child restraint

manufacturers also receive a large

number of similar calls and asks that

commenters verify this.

A four-state study done for NHTSA in

1996 examined people who use child

restraint systems and found that

approximately 80 percent of the persons

made at least one significant error in

using the systems. (‘‘Patterns of Misuse

of Child Safety Seats,’’ DOT HS 808 440,

January 1996.) Observed misuse due to

a locking clip being incorrectly used or

not used when necessary was 72

percent, and misuse due to the vehicle

safety belt incorrectly used with a child

seat (unbuckled, disconnected,

misrouted, or untightened) or used with

a child too small to fit the belts was 17

percent.

II. Improved Anchorage System

a. Standardized System

The difficulty with using vehicle

safety belts to attach child restraints

arises from the fact that those belts are

primarily designed to restrain and

protect larger and older vehicle

occupants. Given the inability to change

vehicle belt design and anchorage

location because of this purpose, the

agency is seeking a means of securing a

child restraint that is independent of the

safety belt. For a number of years,

industry groups and governmental

bodies have explored improving the

securement of a child seat on a vehicle

seat. The child seat and motor vehicle

industry is unanimous that the means of

attaching child restraints to the vehicle

interior should be easier, more efficient

and without incompatibility problems.

Further, all agree that there should be a

universal and independent means of

attaching child restraints. That is, there

should be means that are either

identical or at least compatible,

regardless of vehicle make or model,

and that are dedicated solely for use in

securing child restraints. The

importance of universality across

vehicle make or model also compels a

universal requirement for the anchorage

system, and would mitigate against

having the system be available on an

optional basis.

The concept of a universal and

independent anchorage system was

embraced by the ‘‘Blue Ribbon Panel on

Child Restraint and Vehicle

Compatibility,’’ which NHTSA

Administrator Ricardo Martinez, M.D.,

formed in February 1995 to improve the

use and attachment of child safety

seats.3 In its May 30, 1995 report

recommending ways to improve the

compatibility between child restraints
7860 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

4A transcript of the meeting has been placed in

NHTSA Docket No. 96–095, Notice 01, and is

available from Neal R. Gross, Court Reporters and

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

Washington, D.C., 20005 (telephone 202–234–

4433).

and vehicle seating positions, the panel

recommended that there be an entirely

separate anchorage system for child

restraint installation, given the complex

variables affecting the proper

installation of child restraints using

existing vehicle safety belts.

While there is universal agreement on

the need to improve the ease with

which child seats can be properly

secured to vehicle seats and

concurrence with the merits of a

separate anchorage system, there is

disagreement on which system is best.

It is assumed that a ‘‘universal’’

anchorage system must standardize the

means of attachment, so that it and it

alone would be required for all affected

vehicles, and it alone would be the

system with which child seats would be

required to be compatible. This is

needed to ensure universal

compatibility between child seats and

vehicles.

b. Competing Concepts

In 1990, the ISO began work on a

universal child seat anchorage system

(‘‘ISOFIX’’). The ISOFIX concept

originated as a 4-point rigid system,

where four sturdy braces are mounted

on the bottom of a child restraint. Each

brace has a latch at its end. Two of the

latches connect, through holes at the

vehicle seat bight, to a metal bar in the

seat frame. The other two latches, at the

bottom braces, connect to a bar below

the vehicle seat cushion. The ISOFIX

system is supported by Volvo, as well as

others.

Other concepts for universal

anchorage systems have developed as

alternatives to the 4-point ISO system,

many in response to perceived problems

with the ISOFIX system, such as ISOFIX

being too rigid, too susceptible to false

latching, too bulky, unreasonably

expensive, and too heavy.

Transport Canada developed the

CANFIX system, which consists of two

rigid rear anchorages at the seat bight

(rather than the four points of ISOFIX),

plus an upper tether. This system

envisions all vehicles to be equipped

with upper tether anchorage locations.

CANFIX is supported by Australia,

which refers to the system as CAUSFIX.

At this time, neither Canada nor

Australia requires the CANFIX or

CAUSFIX but both are interested in

pursuing such a requirement in the

near-term. It is noted, however, that

Transport Canada has stated that in lieu

of rigid lower anchorage points, it could

support soft anchorages such as those of

the ‘‘UCRA’’ system described below, in

addition to an upper tether.

General Motors (GM) helped develop

a ‘‘uniform child restraint anchorage

(UCRA)’’ system consisting of two lower

anchorages near the bight line and an

upper tether anchorage. The lower

anchorages have small latches that are

compatible with easy-to-use buckles (as

well as tether hooks) that would be

installed on the child seat. The top

tether anchorage would have a buckle or

tether hook that is compatible with a

tether and latch or hook on the child

seat.

GM joined with thirteen other vehicle

and child restraint manufacturers in

petitioning NHTSA to require the UCRA

system on vehicles and componentry

compatible with the anchor system on

child seats. The joint petitioners are: the

American Automobile Manufacturers

Association (AAMA), which includes

General Motors, Chrysler, and Ford; five

companies of the Association of

International Automobile Manufacturers

(AIAM) (Honda, Isuzu, Nissan, Subaru,

and Toyota); the Juvenile Products

Manufacturer’s Association (JPMA),

which includes child restraint

manufacturers Century, Evenflo, FisherPrice, Gerry and Kolcraft; and Indiana

Mills and Manufacturing, a supplier of

belt systems and hardware.

As another alternative to the ISOFIX

4-point rigid system, several European

ISO manufacturer members are

currently developing a hybrid system.

The system consists of two lower

anchorage points located in the seat

bight and an upper tether anchorage

point located behind the vehicle seat

back. A child restraint system could be

attached to the two lower anchorage

points by means of either a buckle (such

as the UCRA buckle) or the ISOFIX

connector. The object of this option is

to achieve worldwide compatibility

between the UCRA and ISOFIX types of

connectors.

The four systems described above are

the four options, known as ‘‘Schemes’’

A through D, that the ISO has been

considering for the past year. The fourpoint rigid anchor system (ISOFIX) is

known as Scheme A; the two-point rigid

anchor and rigid attachment, plus

tether, is Scheme B; the two-point

flexible anchor and flexible attachment,

plus tether, is Scheme C; and the twopoint rigid or semi-rigid anchor and

flexible attachment is Scheme D.

Another approach for a universal

anchorage system was advanced by

Cosco, a child restraint manufacturer.

Cosco suggested in a July 1, 1996

petition for rulemaking to NHTSA that

vehicle manufacturers alone should be

responsible for improving compatibility

between child seats and vehicle seats

and the ease of installation of child

seats. Cosco believed that vehicles

should provide a dedicated Type I lap

belt for child seats, at or rear of the

vehicle seat bight. Cosco calls its system

the ‘‘Car Seat Only (CSO)’’ system.

Cosco envisions that the CSO system

would require no changes in the design

and manufacture of child restraints.

III. Public Workshop

The relative merit of each of the

systems was discussed at a public

workshop NHTSA held on October 16

and 17, 1996 in Washington, D.C.

Attending were about 100 persons from

the U.S., Canada, Europe, Japan and

Australia, representing governments and

manufacturers of motor vehicles and

child restraints, as well child safety

advocates.4

NHTSA held this two-day meeting to

discuss the various alternatives of

universal child restraint anchorage

systems that are being considered by the

agency, safety advocates, and

automotive and child safety

organizations, such as the Society of

Automotive Engineers (SAE) and the

ISO. The five options described above

were presented and discussed as to

design characteristics, safety

performance, public acceptance and

economic considerations. The meeting

focused on bringing to discussion the

characteristics of the various

alternatives and not necessarily on

reaching a consensus on a system.

Participants had the opportunity to

experiment with the UCRA and hybrid

systems in actual vehicles that were

provided by their respective

manufacturers.

a. Summary of Presentations

The following discussion summarizes

the remarks of each presenter.

1. ISOFIX 4-point Rigid Systems

Thomas Turbell (Sweden), presenting

on Scheme A (ISOFIX), reviewed the

ISO work of the last six years on the 4-

point system. He said that the first ideas

on an anchorage system envisioned a

fixation point in the vehicle where

forward-facing child seats and rearfacing seats could be installed. The

ISOFIX type 1 system (two rigid points),

the ISOFIX Type 2 system

(‘‘DELTAFIX,’’ two rigid points and one

point in the front) were compared in an

early user trial with the conventional

Swedish child restraint system

(installation by the seatbelt and by two

lower tethers attached to the seat frame).

Eighty percent of the users installed the
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7861

ISOFIX type 1 system correctly the first

time, 60 percent the DELTAFIX, and

only 30 percent the conventional

system. Eighty-nine percent of the

subjects indicated that they wanted the

new ISOFIX type 1 system. Ninety

percent were willing to pay a 50 percent

increase over a normal price of a child

seat at that time.

Work on the system continued in

subsequent meetings of the ISO group in

Stockholm in 1993, and Munich, where

a list of features considered essential for

the system was developed. For example,

‘‘misuse should be almost impossible,

the cushion of the car seat should have

no influence on the system, and * * *

the performance should be better than

the present systems.’’ A ‘‘UNIFIX’’

proposed by the UK was later changed

to the UNIFIX–2 four-point, and in 1993

in San Antonio, the ISO group decided

that this was the system to develop. In

1993, the group had its first draft ISO

standard on the system, and in 1994 it

had a sixth draft completed.

In London in 1995, the ISO group

split the draft standard into three parts

because there were problems with

certain aspects of it. The Blue Ribbon

Panel indicated a positive regard for the

ISOFIX system, and the group received

a resolution from the European

Parliament pushing them to introduce

the ISOFIX as soon as possible.

In San Diego in 1995, General Motors

presented its ideas on the UCRA and the

Blue Ribbon Panel modified its earlier

support for ISOFIX. In subsequent

meetings in Cologne and London in

1996, GM presented its findings on its

user clinic, and the Hybrid system was

presented. Since then, a consumer clinic

has been conducted on the different ISO

schemes and a working group meeting

has been held in Albuquerque.

After reviewing the history of the

development of the ISOFIX, Mr. Turbell

noted concerns to consider. He believed

that the anchorage system should be

unrestricted by design patents.

‘‘[Patents] will probably stop [an

internationally] standardized system.’’

He noted a concern about small cars

being able to fit anchorage systems in a

small rear seat, stating ‘‘[W]e can’t let

the available space in the smallest rear

seat decide the size of the child

restraints.’’ He also stated his belief that

rigid systems might have an advantage

over other systems with regard to the

ease with which an air bag switch-off

device can be incorporated.

2. CANFIX 2-Point Rigid System

France Legault (Transport Canada),

presenting Scheme B (CANFIX) (the

system is also known as CAUSFIX in

Australia), explained that Canada varied

from the four-point ISOFIX system

because of Canada’s high regard for

tethers on child seats and tether

anchorages in vehicles. Canada requires

anchorages in passenger cars, and will

soon introduce a regulation extending

the requirement to trucks, multipurpose

passenger vehicles, and sport utility

vehicles.

Ms. Legault stated that CANFIX has

one flexible top tether anchored to the

body of the vehicle, and two lower rigid

points based on the ISOFIX system.

CANFIX has the possibility to include

improved tether installation with better

adjustability, e.g., in a reel or ratchet

mechanism. It also has the possibility of

a tether interlock, which would prevent

the entire system from being installed if

one of the points is not attached, and

the possibility of an air bag switch-off.

She said that before CANFIX was

presented to the ISO group in 1995,

Canada conducted sled testing and

found that performance of the system

was slightly improved over a

conventional type of child restraint

system. In that work, Canada also was

able to design and build a device to test

anchorages in a vehicle by pulling on

them.

Canada’s position on a universal child

restraint anchorage system is that while

it has sponsored the two-point rigid

system, Canada is also open to the idea

of soft anchors at the bottom

‘‘depending on usability and cost.

* * *’’ However, Canada definitely

supports a tether. Ms. Legault indicated

that Canada will retain its head

excursion and chest acceleration

criteria, which have the effect of

requiring a tether, because of the

perceived safety benefits of a tether.

Canada will be improving its tether

regulation to require factory installation

of the actual hardware for the

anchorage. Currently, Canada requires

only a hole or a threaded hole, and the

consumer has to obtain and install the

bolt and latchplate.

Canada believes harmonization is an

important consideration in developing a

universal child restraint anchorage

system. Cost is important, and well as

useability. Ms. Legault said that a

positive engagement feature (e.g., a click

or other indication on an engaged

attachment) would be important for

usability. She is concerned about a

‘‘transition period,’’ where new and old

vehicles and child seats could be

intermixed. New child restraints

equipped with components for an

anchorage system must be capable of

use with older vehicles lacking a

system. Ms. Legault said that testing

with a CANFIX prototype showed that,

in about 85 percent of its vehicles

(lacking receptors for the rigid points),

the prongs would go in between the seat

cushion and seat back, so that the seat

belt could still be used to attach the

child seat.

Canada is in the process of testing the

CANFIX and several conventional

restraints to make sure that the tether

will provide additional protection, not

just when it is properly used but also

when it is used with varying amounts of

slack. Canada will be testing highmounted tethers and low-mounted

tethers. Early test results show that a

tether improves performance in head

and chest acceleration and head

excursion, even if the tether is loose. A

tether also reduces neck forces and

moments.

Canada conducted surveys to

determine the use rate of tethers. In a

1992 survey of owners of vehicles that

provided no tether anchorage, about 25

percent installed the anchorage and

used it. Of vehicles that had standard

anchorages, tether use doubled. In

addition, new data from the Province of

Quebec show that its tether use

increased from 47 percent to 65 percent

after vehicles became equipped with a

tether anchor, even when motorists had

to take the extra step of installing the

tether anchorage hardware.

3. UCRA Soft Anchor System

David Campbell (Century Products),

Kazuhiko Miyadara (Toyota), and Jack

Havelin (GM), presented Scheme C

(UCRA) and the petition for rulemaking

on the UCRA. Mr. Campbell stated that

the key objectives of its work on a

uniform child restraint anchorage

system are ‘‘to find a single world-wide

system, to address the issue of

compatibility and misuse, while

improving dynamic performance of

current restraints.’’ He stated that the

system should be independent of the

adult seat belt system so that

manufacturers can have the flexibility to

optimize the performance of the

anchorage system for child restraints

and allow the adult seat belt system to

be optimized for the other occupants in

the vehicle. Mr. Campbell stated that

child restraint manufacturers believe

that the UCRA system is the best system

because the buckle and latch plate

system is intuitive:

They are the type of systems that are

currently available in vehicles * * *.

Secondly, it will minimize misuse. You

won’t have the routing issues that we have

through current child restraints today with

the vehicle lap belts because they are

attached and you know how to use it.

The UCRA also is designed so that

current child restraints can be easily

adapted to use it. This could be done by
7862 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

means of a special belt provided by

restraint manufacturers. The belt would

have buckles on both ends to use with

the UCRA latchplates, and would route

through the current belt path used

today.

Mr. Campbell said that the

manufacturing costs of the UCRA are

lower than those for some of the other

systems. There also is less added

weight. He agreed with most of

NHTSA’s estimates about the weight

increases of the various systems, but

believed the UCRA would add only

about 1 to 1.6 pounds (lb), rather than

NHTSA’s estimate of 4.5 lb. He stated

that it would take less leadtime to begin

implementing a UCRA requirement as

opposed to the alternative systems,

because the UCRA uses ‘‘existing

technology—known systems, known

belts, known buckles, known latch

plates.’’ Expanding on the cost issue, the

presenter stated that current child

restraints cost and sell at retail between

$35.00 and $90.00 in the U.S.:

Our market price is very sensitive, and one

of the objectives we have is to increase the

usage rate and not have a negative effect on

the current usage rate. Soft anchors are

predicted to add something in the order of

magnitude of $20.00 to the cost of a child

restraint. The Canadian CANFIX, the

estimates were about $55.00 at retail, and for

the ISOFIX it was $95.00. * * * Car seat

loaner programs could be affected by this.

Mr. Campbell also stated that the

UCRA systems meets Standard 213’s

performance criteria without attaching

the tether. Tethered, it meets Canada’s

requirements. He stated that use of the

tether does significantly reduce head

and knee excursions, but there is some

trade off in chest accelerations and HIC

values, and the use of the tether in a

higher position can help reduce that

HIC.

Mr. Miyadara discussed past and

current work evaluating usability, safety

and cost issues for a two-point rigid

system, a two-point soft system and

current child restraint systems.

A past study evaluated usability in a

customer preference clinic of current,

past and future users. No significant

difference was found between the twopoint hard and the two-point soft

system. Safety was assessed in dynamic

testing. Some differences in HIC and

chest G values were found, but the

actual effect that those differences could

have on a child occupant were

unknown. The presenter expected,

though, that safety could be somewhat

improved with regard to chest Gs. The

presenter said that one of Toyota’s

biggest concerns with both a two-point

rigid and a two-point soft system is with

potential ‘‘loose fit’’ of a child restraint

on a vehicle anchorage system.

A study of vehicle and child seat cost

impacts indicated that a two-point soft

system should be much more acceptable

to the customer.

Mr. Miyadara discussed current work

on addressing the ‘‘loose fit’’ issue.

Toyota has been jointly developing a

device that could be used with a soft

system to avoid the problem of

consumers installing a child seat so that

its fit is too loose. Toyota is evaluating

a strap type device with belt adjuster,

strap type with A-lock, lever-type and

ratchet type. Toyota believes that it can

work out the loose fit issue for a soft

system in the near future.

Toyota’s future work includes a

customer preference clinic on the

Schemes A through C systems, and

dynamic testing.

Mr. Miyadara concluded by stating

that Toyota’s goals in joining in the

AAMA et al. petition is to achieve

international harmonization and

provide increased safety to children by

eliminating or decreasing misuse and

improving crash performance, at a cost

acceptable to the consumer. Further, to

address the problems of incompatibility

as soon as possible, the system should

be implemented quickly. Mr. Miyadara

said Toyota does not believe there is any

reason to select the two-point rigid

system over the two-point soft system.

He also suggested that NHTSA consider

conducting a customer preference clinic

of its own.

Mr. Havelin addressed what he

believed to be confusion about GM’s

position on a universal anchorage

system. He said that GM supports an

internationally harmonized

requirement. Mr. Havelin stated that GM

believes that an anchorage system

should, foremost, increase child

restraint use rates (citing the statistic

that three out of four of the fatally

injured children in the U.S. under the

age of five are not using a child

restraint), and secondly, reduce the

potential for misuse and improve crash

protection. GM suggested that NHTSA

‘‘establish the template’’ for

international harmonization by issuing

an NPRM based on three principles.

‘‘First, what does our common customer

want, that is, the child seat

manufacturer’s customer as well as the

vehicle manufacturer’s customer. We

think the results of customer clinics

need to be tempered to some degree by

sound benefit/cost analysis * * * And

finally, that template should be based

on valid science. * * * [S]ome

[consumer clinics and cost analyses] are

better than others and we need to be

focused on which ones are valid and

which ones are not.’’

Mr. Havelin said that GM believes

consumers prefer the UCRA system

because the dual straps on the child

seats use familiar anchorage hardware,

and provide an intuitive, secure

installation. Also, the tether is obvious

and provides a secure anchorage. All

three of the strap anchors give a positive

indication when correctly attached. He

said that other reasons the UCRA is

preferred is that the child seat would be

light and compact, and without any

threatening surfaces (e.g., rigid prongs)

associated with it. GM believes that the

UCRA is within the acceptable cost

range for consumers.

The presenter also highlighted other

perceived benefits of the UCRA, such as

that it need not be tethered to meet

Standard 213’s performance

requirements, can be retrofitted into

existing vehicles, incorporates what GM

considers to be ‘‘fully developed and

field-proven hardware, and can be

implemented faster than the other

attachment systems.’’

4. European Industry Hybrid System

Klaus Werkmeister (Germany),

presenting Scheme D, provided some

historical background on the

development of a universal child

restraint anchorage system. He believed

that interest in a worldwide universal

system started in the late 1980’s to

address a high rate of severe accidents

where children were killed or injured.

Experts determined that the real

problem with those accidents was not

the severity of the crash, but the

considerable misuse rate of child seats

due to the wrong adaptation of seat

belts.

In preparing for an April 1996

meeting in Cologne of the ISO Working

Group of Child Restraint Systems,

German vehicle manufacturers met to

identify criteria they believed were

important for an anchorage system.

They developed a list of 12 properties.

First, there should be no top tether, due

to concerns about its non-use. Second,

the system must have two lower

symmetrical anchorage points, because

unacceptable performance may result

from an unsymmetrical configuration.

Third, due to the configuration and

dimensions of interior vehicle

compartments, especially of smaller

cars, there must be a 250 mm to 280 mm

lateral spacing between the latch points.

Fourth, the latch points must have a

degree of stability to ensure that

excursion limits are not exceeded. Fifth,

the child restraint must be able to attach

through a one-hand operation, to ensure

that the restraint can be easily installed.
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7863

Sixth, there must be a means to prevent

attaching the child restraint on one side

only. Seventh, the user must be able to

tension the child restraint with one

hand. Eighth, there must be no

reduction of seat comfort for adult

passengers. Ninth, the locking device

that attaches the child seat to the

vehicle system must be attached to the

child restraint, not the vehicle, to limit

overall cost impacts. Tenth, to avoid

design restrictions, the locking device

need not be required to be a pushpad

buckle. Eleventh, to ensure that a child

restraint does not have excessive

webbing or ratcheting devices, the

length of the adjustment system used to

tension the system should not exceed

200 mm. Lastly, the dimensions of the

latch points on the vehicle should be as

specified in Scheme A.

The presenter said that dynamic

testing of the four-point rigid and the

soft anchor system showed a reduction

in safety performance when the systems

are not properly tightened. Also, a nonsymmetrical configuration resulted in

very high head acceleration.

Mr. Werkmeister said that the Scheme

D system incorporates ideas from both

rigid and soft anchor systems. The

system calls for defining a field around

the ISOFIX fixture, which might include

an area behind the seat bight (where

hard anchors could be located), or an

area in front of the seat bight (where

semi-rigid anchors could be). A

connector would be used to attach the

child seat to the anchorage on the

vehicle. At the option of the child

restraint manufacturer, the connector

could be attached to a piece of webbing

(such as in the UCRA system), or could

be built into the child seat (as in the

ISOFIX rigid systems). The presenter

estimates that the cost of the connector

system would be about $12 for the

vehicle and $9 to $15 for the child seat.

The presenter expressed concerns

about use rates for a top tether, believing

that use rates will be far less than

Canada’s 65 percent. He also discussed

concerns about the width between

anchorage points and a symmetrical

configuration of the child restraint. He

emphasized the need for design

flexibility in an anchorage system. He

believed manufacturers should be

provided maximum design flexibility to

meet performance requirements and

market demands, and believed that

Scheme D best provides this.

5. Car Seat Only System

John Reynolds and Carol Dingledy

(Cosco), presented the ‘‘Car Seat Only

(CSO)’’ system. Mr. Reynolds stated that

Cosco looked at three critical issues

when evaluating universal anchorage

systems. First, Cosco looked at

performance and determined that a

system must not reduce the safety

performance of existing child restraints.

Second, Cosco looked at

‘‘implementation,’’ or the transition

phase between the existing and new

systems, the primary problem being the

mix of new car seats with old cars, and

old car seats with new cars. Third,

Cosco looked at how the systems could

affect the cost of child restraints, and in

turn, overall use rates. Mr. Reynolds

stated that after evaluating the systems

under these criteria, Cosco decided to

develop its CSO system. Cosco believed

that because the system is a simple lap

belt, it would have the least negative

impact in terms of implementation and

transition. Further, the CSO system

would have the lowest cost to the car

seat user, since the cost to the restraint

manufacturer is virtually none.

Ms. Dingledy elaborated on Cosco’s

concerns with implementation time and

cost. She said that adopting a system

other than the CSO will require

considerable research on the part of

child seat manufacturers to determine if

seats comply. She said that, given the

variety of car seats that must be tested

(e.g., infant-only, convertible, forwardand rear-facing) and the different types

of vehicle seats, just researching a new

system prior to rulemaking will take at

least many months, if not a year or so.

She also indicated that research is

needed to determine whether a rigid

system might place excessive forces on

a child’s neck, particularly a young

child who has less developed neck

muscles. She was also concerned that

the actual implementation of competing

systems would require long leadtimes to

implement (possibly two to five years

development time, plus 10 years

production time), as well as a great deal

of public education. The presenter

stated that this is in contrast to the CSO,

which can be implemented much more

quickly and which requires little

education. Ms. Dingledy said that

international harmonization of an

anchorage system does not appear to be

realistic in the near term.

The presenter discussed cost concerns

at length. She said that a system that

significantly increases the price of car

seats will decrease the number of new

seats purchased at retail, possibly

resulting in (1) more used child seats

being purchased or (2) more children

being incorrectly restrained in seats they

have outgrown or by adult belts when

they are too small for the belts. She

believes consumers in the U.S. will

resist purchasing car seats that retail

between $100 and $200, and that even

a $20 increase would slash sales

dramatically. She indicated that the

average price of a convertible restraint is

$63, but about one quarter of the car

seats purchased cost $50 or less; less

than 5 percent cost $100 or more. She

believes that perhaps 10 percent of

persons purchasing car seats would be

unable to purchase a seat if prices

increase dramatically. She emphasized a

concern about the impacts of cost

increases on loaner programs.

Ms. Dingledy estimated that a 10

percent decrease in child seat use rates

would result in approximately 40

additional child fatalities annually. She

also said that about three million car

seats are sold each year to retail stores

and loan programs. The presenter

cautioned that a 10 percent reduction in

the number of seats sold means 300,000

children per year riding without a new

car seat, which translates into 1.2

million additional children riding

unrestrained.

Ms. Dingledy stated that questions

arising about the CSO system

concerning the possibility that adults

may mistakenly use the CSO belts are

unwarranted. She said that an adult

would prefer a lap/shoulder belt to a lap

only belt due to the superior

performance and comfort of a Type II

belt. She also said that the CSO belt

could be installed at a location that

makes it inaccessible for use with an

adult, and could be prominently labeled

or color contrasted to distinguish it from

an adult belt system.

At the conclusion of her remarks, Ms.

Dingledy introduced Frank Rumpleton

(appearing on behalf of the Juvenile

Products Manufacturers Association)

(‘‘JPMA’’), who presented the views of

the North American car seat

manufacturers. He said that the number

one priority of these manufacturers is to

increase the usage and more importantly

the proper use of child restraint

systems. In addition, they wish to

ensure that the changes made to child

seats are simple, intuitive and easy for

the caregivers to use. They also support

worldwide harmonization. Underlying

all these priorities, however, is the

belief that initiatives must be cost

effective, because of a direct correlation

between cost and use rates. He said that

every dollar of cost at least doubles at

the retail shelf. He suggested that the

cost of an anchorage system could be

better absorbed on the vehicle side than

on the child restraint side.

The presenter said that JPMA

categorically rejects the four-point

ISOFIX system and the two-point

CANFIX or CAUSFIX rigid system,

because of cost. He said that JPMA

supports soft anchor systems, which

includes the UCRA, CSO and Scheme D.
7864 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

JPMA hoped that all parties attending

the workshop would focus on the soft

systems as a starting point and focus on

the similarities and the positive aspects

of each of these proposals, to develop a

solution that maximizes the potential

use of child restraints and minimizes

the cost to the ultimate consumer.

b. Clinics

Separate presentations were made on

the public acceptance and support of

the development of a universal

anchorage system. The Insurance

Corporation of British Columbia (ICBC)

along with Rona Kinetics reported on

the findings of its clinic on usability of

various alternatives. The study surveyed

76 subjects in Vancouver, Canada

representing a cross section of age, sex,

and experienced/unexperienced groups.

General Motors presented the findings

of a February 1996, clinic that was

conducted in Troy, Michigan with a

sample of about 400 subjects. Toyota

also presented a customer preference

study on various types of soft and rigid

anchor systems that was conducted in

Japan on rigid and soft systems. Finally,

a study was recently initiated in the UK

and a progress report on its findings of

an initial small number of subjects

surveyed was presented.

Generally, the findings of these clinics

were in agreement on two major issues:

1) all subjects surveyed seem to prefer

a universal anchorage system over the

current child restraints and 2) no

significant difference in consumer

acceptance was detectable when

comparing between a rigid and soft

anchorage system.

c. Cost

The participants agreed that the cost

of the rigid options is much higher than

the soft anchorage system, with added

costs to the child restraint system of

about $100 for the 4-point ISOFIX, $60

for the CANFIX and $20 for the UCRA

soft anchorage system. Cosco, whose

alternative does not incur additional

costs to current child restraints, raised

important concerns regarding the

potential negative effects of high

increases to the retail price of current

child restraints. Concerns over families

not being able to afford the increase and

over loaner programs with fixed budgets

for purchasing and providing free child

seats to low income families were

discussed. The issue of cost increases

was in conflict with European countries

expectations, according to the

attendants from Sweden who indicated

that these added costs do not have such

implications as expected in the U.S.

market.

d. Tether

Other discussions addressed specific

issues pertinent to the development of

universal child restraint anchorage

systems. One major issue that was

discussed pertained to the upper tether.

A representative from the Insurance

Institute for Highway Safety presented

an overview of the experiences and

possible reasons for non-use of the

upper tether in the US during the 1980s.

On the other hand, a participant from

Australia reported that the use of the

upper tether in Australia is about 98%.

Transport Canada also reported

substantial increases in use of the tether

in Canada. These experiences seem to

indicate that the high usage of upper

tether stems from the fact that the tether

anchor points are provided on the

vehicle and are visible to and easily

accessible for use by consumers. There

appeared to be an agreement among

participants that a child restraint with

an upper tether provides better

protection to the child during a crash.

e. Agreement on Differences

In the interactive exchange among

attendees during the course of the

workshop, several important points

relating to development of a universal

child seat anchorage system emerged.

The following key views were

expressed:

• User clinics indicate that

consumers are overwhelmingly

unhappy with the manner with which

current child seats are attached to

vehicle seats and wish to see

improvement.

• The various systems evaluated in

consumer trials (ISOFIX, schemes A

through C) do not differ much in terms

of safety performance (assuming proper

installation) and public acceptance.

• Schemes B, C and D (CANFIX,

UCRA and the Hybrid) are virtually

variations of the same system, except for

the hardware used to connect the child

seat to the vehicle. CANFIX has

specified a rigid anchor and rigid

connectors on the child seat. UCRA

specifies a buckle and latchplate system;

the buckle would be on a piece of

webbing attached to the child restraint

and the latchplate would be on a semirigid stalk at the vehicle seat bight. The

Hybrid system would specify a 6 mm

bar (e.g., a D ring) that could connect to

a child seat either in front of or behind

the vehicle seat bight. The UCRA system

differs from the Hybrid system only

with regard to the connector piece that

fastens the child restraint to the vehicle.

• Purchasers of child restraints in the

U.S. are very sensitive to price. Sixtyfour percent of the car seats sold in the

U.S. sell for less than $60. Consumers in

this country are unwilling to pay the

$300 it costs on average for a child seat

in Sweden.

• The European manufacturers

generally still prefer a rigid system,

while U.S. manufacturers oppose it.

Canada has indicated a willingness to

move from a rigid two-point plus tether

(Scheme B) to a soft two-point plus

tether system.

• Scheme D (the Hybrid system) has

potential in accommodating both rigid

and soft systems. It would provide the

greatest design flexibility, in that it

would specify minimum elements of the

vehicle anchor (e.g., a 6 mm bar) and a

location that could connect to a child

seat either in front of or behind the

vehicle seat bight. It would provide

vehicle manufacturers the option of

supporting the anchor rigidly or semirigidly. Child restraint manufacturers

could choose any means to attach to the

anchor. A child seat could have a

telescopic or a rigid device, or a soft

attachment (piece of webbing), so long

as the child seat can attach to the

anchor.

• Each system has strengths but also

possible weaknesses. Questions were

raised about the cost, weight and

development time needed for a rigid

system, the slack that could be

introduced into the belts of a soft system

and the suitability of a soft system with

fold-over seats, the need for anchors to

be visible to consumers in a Hybrid

system, the possibility of slack and

misrouted belts with the CSO system,

and the actual use of a top tether in

tethered systems.

• The various systems under

consideration are unencumbered by

patents of any kind. Britax (a European

child restraint manufacturer), when

asked about a certain patent application,

expressly declared that it holds no

patents or applications for patent or

other claims that would hinder third

parties from making ISOFIX equipped

vehicles or child restraints using rigid or

semi-rigid anchorages.

f. Future Work

Manufacturers of motor vehicles and

child restraints extensively explored the

differences between the UCRA and

European hybrid systems with an

agreement to further develop this option

to harmonize between the European

vehicle manufacturers and Britax and

the US and Japanese child restraint/

vehicle manufacturers. These

participants expressed that future efforts

would be made to elaborate on progress

of this development at a November 7

and 8, 1996, ISO Working Group on

child safety meeting in Albuquerque,
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7865

5On November 15, 1996, the American Academy

of Pediatrics (AAP) petitioned NHTSA to amend

Standard 213 to require child restraint

manufacturers to supply tether straps on all child

seats and require vehicle manufacturers to provide

tether anchors at all rear seating positions. AAP also

requested that child restraint manufacturers be

required to make tether straps for existing car seats

available to consumers by mail order and at retail

outlets. NHTSA granted this petition on January 14,

1997.

New Mexico and future meetings of the

Group.

IV. Subsequent Developments

a. Albuquerque, New Mexico

During the November 7 and 8, 1996

meeting of the ISO Working Group on

Child Restraint Systems (ISO/TC 22/SC

12/WG 1), the Group voted on a

proposition containing two resolutions

on the specifications for the anchorage

of a universal child restraint anchorage

system. The first resolution recognized

the need to allow two anchorage

systems: one based on two-prong

nonflexible hardware (a system that is

under development), and another based

on flexible UCRA-type hardware (a

system that is available today). A second

resolution opposed an upper tether

anchor in motor vehicles.

Following the Albuquerque meeting,

the Secretariat of the ISO Working

Group opposed the proposition—which

was intended to advise different

governments on how to treat the use of

ISOFIX with and without a top tether—

on the basis that it goes beyond the

mandate of the Working Group. A revoting of an amended resolution was

conducted by correspondence with the

delegations of country members, and

was due back to the Secretariat on

December 6, 1996. The voting on this

resolution was to select between: i)

specifying a top tether anchorage in

vehicles; ii) not specifying the tether; or,

iii) either of these options. It was also

agreed that two reports—one for the

rigid and one for the rigid/semi rigid

options—will be prepared by members

of the Working Group to describe and

specify these systems.

The result of the re-voting was a

resolution to produce two draft

standards for universal child restraint

attachment interfaces. One draft

standard would cover an attachment

system comprising the UCRA-type

attachments on the lower points. The

other standard would cover the rigid

anchorage system. The standards would

not include specifications for an upper

tether anchorage. (The results of the revoting and copies of the rough drafts of

the two reports were placed on

December 13, 1996 in Docket No. 96–

095, Notice 01 for the readers’ review.)

b. Additional Information

On November 21, 1996, some of the

UCRA petitioners provided the agency

with additional information supporting

their petition. NHTSA representatives

met with representatives from General

Motors, Century Products, Indiana Mills

and the Lear Corporation, at the request

of the latter, to discuss the resolutions

of the ISO Working Group meeting in

Albuquerque. (A December 13, 1996

memorandum describing this meeting

and attaching the handouts is entry

number 16 in Docket 96–95, Notice 1.)

The petitioners emphasized that the

North American child restraint

manufacturers strongly favor the UCRA

system with an upper tether and have

doubts that a determination can be

made at this time that the rigid system

would be a long term solution. They

also presented the findings of an

evaluation that Indiana Mills performed

in response to a NHTSA call for

harmonization during the public

workshop. (The agency had requested

that hardware manufacturers explore

the feasibility of an anchorage system

that would accommodate buckles, snap

hooks and ISO-type connectors with a

flat latch or round link, for

consideration at the Albuquerque ISO

meeting.) Indiana Mills described the

advantages and disadvantages of the

various types of hardware and its

reasons for supporting the existing

technology of a flat latch plate/buckle

system. Lear Corporation presented cost

data for rigid and soft attachments to

various types of vehicle seating systems.

It stated that the vehicle added cost data

should be considered as a complement

to the NHTSA study cost figures.

Specifically, it included cost figures on

items, such as covers and trim of rigid

anchors, that were not included in the

costing of the NHTSA study. The data

showed that the costs of the soft

anchorage system per seat on the

vehicle range from about $4 to $10, as

compared to about $13 to $30 for the

rigid anchorage points system.

c. Petition on Scheme D (Hybrid System)

On December 18, 1996, BMW,

Chrysler, Ford, Land Rover, MercedesBenz, Volkswagen, and the University of

Michigan Child Passenger Protection

Research Program, petitioned NHTSA to

consider an approach based on Scheme

D and modify the suggestions made in

the UCRA petition. These petitioners

supported a system incorporating two

‘‘latch plates’’ formed of 6 mm diameter

elements for the vehicle, ‘‘coupled with

the alternatives for the [child restraint

system], namely, tether hooks or buckles

on belts with tilt-lock adjusters for

tension release, or the rigid ISOFIX

connectors on a sliding element.’’ The

petitioners believe that this system will

offer vehicle and child restraint

manufacturers the greatest design

flexibility, and will further international

harmonization at an early date.

V. Evaluation of Concepts

During the course of the agency’s

deliberations on a universal child

restraint anchorage system and as a

result of the discussions at the October

1996 workshop and other information,

the agency has tentatively determined

that child seats can be better secured to

a vehicle (thereby reducing

incompatibility problems and increasing

safety) by providing three anchorage

points between the restraint and a

vehicle seat. One point is at the top

center of the restraint (attachment of a

child restraint to a vehicle would be

accomplished at that point through a

top tether), and the other two are at the

vehicle seat bight.

a. Top Tether

ISO Schemes B and C (CANFIX/

CAUSFIX and UCRA) include

provisions for a top tether. Cosco

indicated it would support a tether

requirement, although the manufacturer

is concerned whether tethers will be

used in this country. The European

systems do not call for tethers.

As a result of the agency’s

deliberations on this rulemaking,5 the

agency reevaluated its view of a top

tether on child restraints. NHTSA

currently does not require a tether or a

tether anchorage on vehicles. The

agency does not prohibit a tether, but

generally requires child restraints to

meet Standard 213’s 30 mph dynamic

testing requirements without attaching a

tether to reflect the historically low use

rate of tethers in this country.

NHTSA tentatively concludes that a

top tether should be provided to better

secure a child restraint. By restraining

the top portion of a child seat, a tether

would supplement the vehicle belt

system in limiting forward movement of

the child restraint in a crash. With less

forward movement, head excursion can

be reduced.

This document proposes a

performance requirement that would

have the practical effect of requiring a

tether on child seats. A new head

excursion requirement for forwardfacing seats would be added to limit

excursion to 720 mm (28.35 inches)

forward of the Z-point on the test seat

assembly when a child seat is attached
7866 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

to the standard seat assembly in

accordance with the manufacturer’s

instructions. To meet this requirement,

manufacturers will likely have to

provide a top tether, which would be

attached in the test for this new

requirement. NHTSA believes that the

head excursion limit of 720 mm is

practicable with a tether because it is

the same as the Canadian requirement

and because most, if not all, child

restraint manufacturers currently

produce child restraints for sale in

Canada and thus already meet the

requirement for those products. The 720

mm requirement would promote

harmonization with Canadian

requirements. Further, the European

child restraint manufacturers believe

that a 720 mm limit could be achieved

with the rigid anchorage system with

two lower anchorages and no upper

tether.

Test data strongly support the safety

value of a tether. AAMA et al. submitted

test results in support of a requirement

for a tether anchorage, stating:

Test results clearly demonstrate that a

fastened tether can significantly reduce

dummy head excursion measurements which

most developers and evaluators use as the

primary predicator [sic] of a CRS’s

performance in field accidents * * * .

An Australian report cites forward-facing

CRS test results, indicating that ‘‘as well as

reducing head excursion, a top tether, with

the right high mounted geometry,

significantly reduces head acceleration and

neck loads in frontal impacts’’ [footnote

excluded] * * * . Recent computer

simulations and tests of the recommended

UCRA concept suggest that * * * a fastened

tether significantly reduces dummy head

excursion during high severity frontal

impacts.

Computer simulations conducted by

petitioners AAMA et al. showed a

reduction in force levels experienced by

a restrained dummy’s head, neck and

chest when a tether was used as

compared to no tether, and a reduction

in head and knee excursions. Actual

testing of child restraint systems with

and without a tether showed that with

the tether attached, there generally were

reductions in head injury criterion (HIC)

values and chest g’s, and in head and

knee excursions.

These findings are consistent with

NHTSA’s limited testing of tethers. In

two tests of an Evenflo Scout forwardfacing convertible seat with the inboard

anchor of the lap belt restraining the

child restraint to the test seat assembly

positioned four inches forward of the

seat bight, the HIC and 3 ms chest

acceleration clip were 631 and 59.6 g’s

respectively. When the child restraint

was tethered on its top, these HIC and

chest clip measurements were reduced

to 503 and 42.2 g’s, respectively.

In her comments at the October public

workshop, Ms. Legault of Transport

Canada reported that on-going testing of

tethered, untethered and looselytethered restraints indicate improved

head acceleration, head excursion and

chest acceleration with a tether strap,

even when the strap is loose.

Additionally, upper neck forces and

moments were also improved with a

tether. (Transcript of October 17, 1996,

pp. 32–34.) (However, Indiana Mills

tests showed increased HIC and chest

g’s for a child seat with a dual strap

anchorage with a tether, compared to

one without a tether. Comments are

requested explaining these increases.)

However, nonuse of the tether has

been a problem in the U.S. In an effort

to boost use rates, NHTSA once

proposed requiring all vehicles under

10,000 lb GVWR to have tether

anchorages at all rearmost seating

positions, to make it possible for

motorists to easily attach the tether

straps on their child restraints to the

vehicle. 45 FR 81625; December 11,

1980. At the time of the proposal, tether

use was about 50 percent. NHTSA

terminated rulemaking on this proposal

after determining that (a) since the

proposal, there was a continual shift

toward untethered seats, so that most

seats did not need a tether to meet

Standard 213’s requirements; (b) motor

vehicle manufacturers had increasingly

been voluntarily providing provisions,

such as indentations to identify

anchorage points and pre-drilled or

threaded holes, in their vehicles to

facilitate the attachment of tether straps;

and (c) the most effective way to

promote child safety would be to amend

Standard 213 to require all child

restraints to meet Standard 213’s

requirements without attachment of the

tether. July 5, 1985; 50 FR 27632.

Petitioners AAMA et al. believe that

a tether will be used. GM’s consumer

focus group testing indicates a positive

response toward a tether, particularly if

the tether anchorage is equipped with

all the components needed for use with

the child restraint. The petitioners state,

‘‘Australian field experience shows very

high tether use rates are obtainable

when factory installed tether anchorages

are provided.’’ (Emphasis in text.)

Indeed, top tether use is reported in

excess of 95 percent in Australia,

primarily due to requirements for

installation of the anchorages and to

early and continuous public education

on the use of tethers. ‘‘Options for a

Universal Child Restraint Attachment

System,’’ M. Lumley, June 14, 1996,

revised October 10, 1996. Petitioners are

also encouraged by information from the

Canadian Province of Quebec indicating

a 65 percent tether use rate in vehicles

required to have just a tether anchorage,

and not the tether hardware. ‘‘This in

spite of the fact, that vehicle owners

must install the tether anchorage

hardware themselves or return to their

dealer to have it installed.’’

In an effort to increase tether use in

Canada, Transport Canada is proposing

to require vehicles to have a factoryinstalled, user-ready tether anchorage,

with hardware included. Transport

Canada believes that tether use will

increase if an anchorage equipped with

all needed parts for consumer use is

provided at the factory. NHTSA

tentatively believes that this information

from petitioners AAMA et al. and from

Transport Canada provides a basis for

concluding that tethers would be used

if child seats are equipped with a tether

and vehicles are equipped with a

factory-installed, easy- and ready-to-use

tether anchorage. Accordingly, in view

of the potential added safety value of a

tether, the agency proposes requiring

installation of a ready-to-use tether

anchorage at the two seating positions

that would be required to have the

lower anchorages dedicated for

attaching a child restraint system. (See

infra, section VI.c.) For purposes of

harmonization, the proposed

requirements for the tether anchorages

are essentially identical to those

proposed by Transport Canada.

However, because NHTSA does not

know the extent to which tethers will be

used in this country, the agency believes

the standard should also retain the

present head excursion requirement,

which limits excursion to 813 mm (32

inches) without use of a tether strap.

Retaining the requirement would ensure

a minimum level of safety performance

when the tether strap is not used.

Further, NHTSA proposes that child

restraints dynamically tested on a child

restraint anchorage system with UCRA

anchorages should be subject to the 813

mm (32 inches) head excursion

requirement without attaching the

tether. This accords with the AAMA et

al. petition, which suggests not

attaching the tether. Comments are

requested on this issue. Comments are

also requested on the potential of using

tethers in aircraft.

b. Lower Anchorage Points

Improving the lower anchorage points

of a child seat to the vehicle would

make it easier for parents to correctly

attach a child seat to the vehicle.

NHTSA stated in the Federal Register

notice announcing the workshop that an
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7867

anchorage system should accomplish

the following:

• Improve the compatibility between

child restraint systems and vehicle seats

and belt systems, thereby decreasing the

potential that a child restraint was

improperly installed;

• Ensure an adequate level of

protection during crashes;

• Ensure correct child restraint

system use by ensuring that the child

restraint systems are convenient to

install and use;

• Ensure that the child restraint

systems and anchorages are cost

effective; and

• Achieve international compatibility

of child restraint performance

requirements for uniform anchorage

points.

In remarking on the various ISO

schemes and in other presentations,

participants in NHTSA’s workshop

concurred with and elaborated on these

considerations.

1. Improve Compatibility

All of the anchorage systems appear

to improve compatibility between child

restraint systems and vehicle belt

systems. Consumers comparing ISO

Schemes A, B and C systems against

conventional child restraints indicated

that the new methods of attachment are

easier than current methods. Cosco’s

CSO system was not evaluated in these

studies, but to the extent that the CSO

does not depend on a locking clip or

other means to adapt the belt to a child

restraint, an improvement over existing

belt systems, at least concerning that

aspect of design, can be assumed. The

CSO belt would still have to be routed

correctly through the child restraint. All

anchorage systems would improve

compatibility between child restraint

systems and forward-mounted anchors.

Views were expressed at the October

1996 workshop that Schemes A, B and

C systems would improve compatibility

between child restraints and contoured

vehicle seats. A rigid anchor system

may suspend the child restraint above

the contoured seat, and a UCRA would

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

contoured seat. The CSO might not be

as effective on humped seats in limiting

side-to-side motion of a child restraint.

2. Safety Performance

ISO Schemes A, B and C systems have

performed satisfactorily in dynamic

tests. The CSO system has not been

tested, but it simulates the standard seat

assembly used in Standard 213

compliance tests.

Consumer clinics indicate that ISO

Scheme A, B and C systems are

comparable in terms of a user’s ability

to correctly install them. Users are able

to install child restraints correctly in

those systems. Scheme D and the CSO

were not evaluated.

The degree to which an anchorage

system will be correctly used outside

the context of a clinic is unknown at

this time, but design differences

between the systems could affect such

use. Attendees at the public workshop

expressed concern with potential

misuse problems that could arise by

virtue of the design of each system. A

type of misuse that could occur with a

rigid system (ISOFIX four-point or

CANFIX) is if the user does not fully

attach all points of the system. Test data

indicate that performance of the child

restraint is severely degraded if one or

more points are not attached. Some

attendees believed that users must be

able to see clearly where to insert the

child seat connector to the vehicle

system, and that a guide of some sort is

needed if the attachment point is behind

the seat bight. Some believed that an

education campaign is needed to teach

people how to use the system since a

rigid bar anchorage is unfamiliar in this

country.

Proponents of the UCRA system

believe that the soft anchor system is

superior to a rigid system in that the

connectors are buckles and latches that

are consumer-familiar in design to the

seat belt hardware on vehicles.

Proponents believe that users will know

‘‘intuitively’’ how to use the connector

and will recognize the sound and feel of

the click that indicates a positive

attachment. Several participants

expressed concern about a possible

misuse problem arising due to the

presence of webbing on the connectors,

i.e., that slack in the webbing will

negate a tight fit of a child seat on the

system. Toyota indicated it is

developing a means of addressing this

potential problem.

Cosco believes the CSO system ‘‘is the

most intuitive system suggested because

people have been using this type of

system for years.’’ NHTSA believes that

while users might be familiar with the

system, the CSO system poses some of

the same problems as the lap belt

currently used to attach child restraints.

The belt would have to be correctly

routed through the child restraint,

which is a problem occurring with

present seats. Slack in the belt would

negate a secure fit of the child seat, so

an adjuster of some sort would be

needed, and it would have to be

positioned on the belt where a user

could maneuver around the child seat to

tighten the belt. The seat belt would

have to be long enough to permit it to

be fastened around all types of child

restraints, including restraints for

children with special needs. A common

complaint with current child seats is the

difficulty of routing the belts through

the system and pulling the belt tight. It

appears that the CSO system might not

alleviate those problems in all restraints.

Further, there is the potential that the

CSO belt would be inadvertently used

by an adult occupant as a restraint,

particularly in a seating position

equipped with a lap belt, even if the

CSO belt were labeled.

It may be possible to attach child seats

with either a rigid anchor (ISOFIX fourpoint rigid, CANFIX) or a soft anchor

(UCRA) system design to a vehicle seat

in the same way that current child seats

are attached, using the occupant belt

system (and meet minimum

performance criteria). Thus, it may be

possible to use them in a vehicle that

lacks an anchorage system. The ability

to attach a child seat in a conventional

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

essential feature addressing the use of

new child seats with old vehicles, and

vice versa (old child seats with new

vehicles). Ms. Legault of Transport

Canada said that testing with a CANFIX

prototype showed that, in about 85

percent of its vehicles (lacking receptors

for the rigid points), the prongs could be

inserted between the seat cushion and

seat back, so the seat belt could still be

used to attach the child seat. All child

seats with UCRA-designed anchorages

can be attached to a vehicle by use of

the existing vehicle safety belt, because

the UCRA design is based on a simple

addition of buckles to current models of

child seats. The CSO design would also

result in all child seats being able to be

attached in a conventional manner. It is

unknown whether the four-point

ISOFIX seat could be attached with an

existing vehicle belt and perform

satisfactorily.

The various systems differ in their

ability to allow child seats and vehicles

to be retrofitted with features of the

anchorage system. The ability to retrofit

is desirable, since it would increase the

number of seats that provide improved

protection. Retrofitting seats and

vehicles would provide all children the

benefits of the improved technology. It

does not appear that the four-point

ISOFIX or the two-point CANFIX allows

for retrofitting either the child restraint

or the vehicle. These rigid anchorage

systems necessitate an elaborate

redesign of existing child seats. The

anchorage pins on the vehicle seat

would have to be precisely aligned with

the prongs on the child seat to ensure

that the system performs properly.

Alignments of this nature are generally
7868 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

6 It should be noted that the work thus far by the

ISO has been at the Working Group level. Any ISO

standard on this matter has still to go to higher

committee before it becomes a standard.

not believed to be feasible in the

aftermarket.

Proponents of the UCRA system state

that existing seats can be installed using

the UCRA system if the system is

supplemented by a special belt with

buckles at each end that are compatible

with the UCRA latchplates on the

vehicle. The belt would be provided to

the owner of the old (pre-standard)

child seat to route through the existing

belt route path on the child seat.

Further, proponents of the UCRA

system believe that vehicles can be

retrofitted with the UCRA system. The

CSO system calls for no change in the

design of a child seat, so old child seats

could be used with a CSO system in a

vehicle. Cosco did not indicate whether

vehicles can readily be retrofitted with

the CSO belt system, although it appears

as feasible as retrofitting them with the

UCRA system.

3. Consumer Acceptability

Consumer clinics indicate that ISO

Scheme A (rigid four-point), B

(CANFIX) and C (UCRA) systems are

comparable in terms of consumer

acceptance. Participants in GM’s clinic

indicated a preference for UCRA.

Scheme D and the CSO were not

evaluated in the clinics. Participants in

all the clinics indicated a desire to see

an improvement in the way child

restraints are attached to vehicles. With

regard to bulk and added weight to a

child restraint, the CSO adds no weight,

and the UCRA appears to have an

advantage over a rigid system and the

CANFIX. The rigid prongs and

supporting structure on a rigid system

add much more weight than the buckles

of a UCRA and also protrude from the

child restraint.

4. Costs and Burdens

Cost is an area where the systems

differ greatly. The cost of the rigid

options is much higher than the soft

anchorage system, with added costs to

the child restraint system of about $100

for the four-point ISOFIX, $60 for the

CANFIX and $14 for the UCRA soft

anchorage system. The agency is

concerned that the $60 to $100 added

costs of the rigid systems could

engender public dissatisfaction with

child restraints, reduce child restraint

use rates and significantly reduce the

number of seats available through car

seat loaner programs. The CSO system

does not incur additional costs to

current child restraints.

Schemes A, B and C systems are fairly

design restrictive, in specifying the

geometry and location of assorted

components on the vehicle and child

seat. Scheme D (Hybrid) and the CSO

specify only the features of the vehicle

system, and not of the child seat. Design

flexibility allows manufacturers latitude

in meeting market demands and

developing new technology, yet would

be a trade-off in standardization of the

anchorage system.

5. Harmonization

Harmonization was one of the major

goals of the agency’s October 1996

public workshop. NHTSA stressed the

importance of international

harmonization during the workshop and

urged ISO member country member

delegates to agree on a unique child

restraint anchorage system.

The UCRA system would harmonize

with Canada, Australia, New Zealand

and Japan in specifying a top tether.

With the top tether proposal, the

proposed rule would harmonize with

Transport Canada’s current head

excursion threshold and with its

planned new regulation proposing to

require manufacturers to provide

anchors for tethers in motor vehicles.

The rigid anchor system is endorsed by

European members of the ISO Working

Group.

6. Leadtime and Availability

The different systems are at varying

stages of development in design

concept. Final design of the four-point

ISOFIX system and the two-point rigid

CANFIX have not been completed,

although proponents of those systems

believe that completion is imminent.

Design of the UCRA system is

completed.

The view was expressed at the

October 1996 workshop that the

leadtime needed to implement a

requirement for a rigid system would be

much longer than that needed to

implement the UCRA system. This is

because the UCRA uses ‘‘existing

technology—known systems, known

belts, known buckles, known latch

plates’’ (quoting David Campbell). Cosco

argues that its CSO system would be the

fastest to implement.

7. Proposed System

The agency has decided to base a

proposal for a universal child restraint

anchorage system primarily on the

UCRA system. The four-point and twopoint rigid and the UCRA appear

comparable in terms of safety

performance and public acceptance, but

the UCRA appears to have advantages

over the others with respect to its cost

impact, near-term availability and

ability to address intermix and retrofit

issues. Further, the UCRA system has

advantages in terms of its usability. The

agency believes the familiarity of its

components (particularly the crucial

connector pieces—buckles and

latchplates—that attach a child seat to

the vehicle system) is a definite

advantage over the other systems. Also,

the UCRA system is not as bulky or

heavy as the other systems, which

increases its usability.

In addition, NHTSA believes that the

soft anchor system has a potential for

use in restraining child seats in aircraft.

The Federal Aviation Administration

(FAA) stated in a submission to

NHTSA’s docket for the October 1996

public workshop on a universal anchor

system that ‘‘preliminary review and

evaluation of the proposed ISOFIX

systems under consideration by

[NHTSA] suggest that the UCRA

concept presents the best solution in the

aircraft environment.’’ 96–95–N01–008.

FAA is concerned that the rigid prongs

of an ISOFIX-type child seat may not be

compatible with aircraft seat cushions

or suited for narrow aircraft seats.

While NHTSA has decided to propose

the UCRA system due to its advantages

in cost, usability, potential for use in

aircraft, and the fact that it is proven

technology available today, the agency

is still interested in the possibility of

achieving harmonization on a universal

anchorage system. To that end, NHTSA

is proposing to permit vehicle

manufacturers to substitute the two

lower rigid points of ISO Scheme D (the

Hybrid system) in place of the UCRA

anchors, provided that the vehicle is

also equipped with adapters that enable

the lower rigid points to accommodate

UCRA-type child restraint systems.

The European manufacturer members

of the ISO Working Group on Child

Restraints Systems believe that their

countries will require the two rigid

anchorage points in the future.6

Accommodating both hardware systems

would be consistent with the agency’s

goal of solving the problem of

incompatibility between child restraints

and motor vehicles as expeditiously as

possible, while promoting

harmonization. The UCRA system,

being a well developed and familiar

current technology, is currently

available. The non-flexible system

would be given the opportunity to be

developed, tested and evaluated in the

market place to prove what its

proponents believe to be its superiority

as the child restraint anchorage

technology of the future.

NHTSA tentatively concludes that the

two proposed systems can coexist in the
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7869

short term. The UCRA system will not

hinder any development of the nonflexible hardware system. The proposed

rule allows vehicle manufacturers to

install a 6 mm pin to attach a child

restraint that is equipped with jaw-type

non-flexible hardware. The proposed

rule would not prevent manufacturers of

child restraints from developing a

restraint with non-flexible hardware,

and would facilitate a transition to

future technology. However, in the

interest of eradicating incompatibility

problems henceforth, child restraints

with non-flexible hardware would be

required to have components (e.g.,

buckles), permanently attached to the

child restraints, that are compatible

with the UCRA anchorages. This

proposal considers the UCRA system to

be paramount, and a rigid system would

be allowed as long as the UCRA system

is universal for all vehicles and child

restraint systems.

c. Discussion of Alternatives

A number of other approaches have

been suggested to minimize or eliminate

incompatibility between child seats and

vehicle seats. This section addresses

these alternatives to the approach

proposed today.

1. SAE Recommended Practice J1819

In 1994, the Society of Automotive

Engineers (SAE) published its

Recommended Practice SAE J1819,

‘‘Securing Child Restraint Systems in

Motor Vehicle Rear Seats,’’ to promote

compatibility between child seats and

vehicle rear seats and seat belts. J1819

provides voluntary design guidelines to

vehicle manufacturers for certain

characteristics of rear seats and seat

belts, such as seat cushion shape and

stiffness, and seat belt anchorage

location, belt length, buckle and

latchplate size, and lockability. In

addition, J1819 provides design

guidelines to child seat manufacturers

for child seat features that correspond to

the vehicle features.

J1819 specifies a ‘‘Child Restraint

System Accommodation Fixture’’ to

represent a child seat, so that designers

of both the vehicle and child seat can

evaluate each product for compatibility.

NHTSA tentatively concludes that

J1819 alone does not fully solve

incompatibility problems. It is a tool for

evaluating incompatibility, not a

requirement that vehicle seats and child

restraints must be compatible.

In the October 1996 workshop, Mr.

Howard Willson (who chairs the

Children’s Restraint Systems Standards

Committee of the SAE) stated that J1819

might be amended to add ‘‘a test for seat

contour.’’ The test would enable vehicle

manufacturers to ‘‘identify seating

positions where it’s probable that child

restraints will not work well because of

seat contour.’’ He also stated

I doubt that we will agree to simply design

our seating positions so that they’re all as flat

as the seats in a pick-up truck used to be, for

example. There is an appeal to a shaped seat,

an appeal to the users. (Transcript of October

18, pp. 8–9.)

At the same workshop, Mr. David

Campbell said that a child restraint

anchorage system—

should be independent of the adult seat belt

system so that manufacturers can have the

flexibility to optimize the performance of the

anchorage system for child restraints and

allow the adult seat belt system to be

optimized for the other occupants in the

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

NHTSA tentatively agrees with this

statement. Further, NHTSA recognizes

that it is very difficult for a single

system to optimize the safety protection

for adults of all ranges and child

restraints of different types.

Nonetheless, the agency requests

comments discussing possible design

alternatives to a universal child restraint

anchorage system.

2. Lockability

In 1993, NHTSA amended its

occupant crash protection standard

(Standard 208) to adopt a ‘‘lockability’’

requirement effective September 1,

1995. The rule requires vehicle lap belts

or the lap belt portion of lap/shoulder

belts to be capable of being used to

tightly secure child safety seats, without

the need to attach a locking clip or any

other device to the vehicle’s seat belt

webbing, retractor or any other part of

the vehicle. 58 FR 52922, October 13,

1993. The requirement applies to

seating positions other than the driver’s

position on vehicles with a gross vehicle

weight rating of 10,000 pounds or less.

The rule requires the lap belt to be

lockable and specifies test procedures

demonstrating compliance with the

lockability requirement. The rule does

not specify how the vehicle belt is to be

locked, except to prohibit locking by

‘‘inverting, twisting or otherwise

deforming’’ the belt webbing. An

example of a permitted means of locking

a belt is extending the belt all the way,

then feeding in the slack.

NHTSA tentatively concludes that the

lockability requirement is insufficient

alone in addressing incompatibility

problems. While the requirement

ostensibly makes a locking clip obsolete,

it still depends on the user knowing

enough and making the effort to

manipulate the belt system. Also, the

vehicle belt must be routed correctly

through the child restraint, which may

not be an easy task in all cases. Further,

the lockability requirement does not

address incompatibility problems

arising from forward-mounted seat belt

anchors. Excessive forward movement

of a child seat can still occur, even if the

feature is engaged and the belt is

‘‘locked.’’ Comments are requested on

this issue. NHTSA is considering

deleting the lockability requirement as

unnecessary if requirements for a child

restraint anchorage system are adopted.

A lockability requirement may not be

needed for a seating system with a

universal anchorage system since the

vehicle’s belt would no longer be used

for attaching a child restraint. However,

lockability might be needed to attach

child seats that are not equipped for a

universal anchorage system, even if the

vehicle seat has such a system.

3. Cosco’s CSO system

Cosco’s CSO system is appealing in its

simplicity and low cost, but the CSO

system is essentially no different from

the current lap belt means of attaching

child restraints to vehicle seats. NHTSA

is concerned that the CSO system might

not make attaching a child seat

significantly easier than it is today. As

noted previously, the CSO belt would

have to be correctly routed through the

child restraint, which manufacturers

believe many consumers find difficult to

do. In addition, from photographs of the

CSO system, it might be difficult to

tighten the belt. Consumers have

expressed concern about their child seat

not being secure on the vehicle seat

because of the lateral side-to-side

motion of the child restraint that occurs

no matter how tightly the lap belt is

adjusted. On a contoured, humped, seat,

there is even more lateral ‘‘play.’’ The

CSO system might not be able to address

these concerns. Cosco provided no data

on these issues assessing the viability of

this approach. Another concern relates

to the potential that the CSO belt would

be inadvertently used by an adult

occupant as a restraint, even if the CSO

belt were labeled. It is also unknown

how consumers will accept the addition

of more seat belt systems in the rear

seat, in addition to the Type I and II

belts already provided in the rear seat.

The agency requests data or comment

on any research that has been done on

the CSO system evaluating its

acceptability by consumers, its

performance with child restraints, the

potential for correct use with child

restraints and for misuse by adult

passengers. Focus group testing

comparing the CSO system to the UCRA

and other standardized systems would

be especially helpful.
7870 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

VI. Proposal for New Vehicle Standard

a. Highlights of Proposal

The most significant requirements

proposed by this document are

highlighted below.

(1) A new safety standard would

require all passenger cars and light

trucks and vans to be equipped with a

child seat anchorage system, defined in

the standard, at two rear seating

positions. If an air bag cutoff switch is

provided that deactivates the air bag for

the front passenger position, one system

would have to be provided in that

position, and another in a rear seating

position. If there is no rear seat and no

air bag cutoff switch, an anchorage

system would be disallowed in the front

passenger seat. A built-in child seat may

be substituted for one of the systems,

but not both, since rear-facing built-in

systems are currently unavailable.

(2) The system would consist of two

lower anchorages at the vehicle seat

bight (the intersection of the seat

cushion and the seat back) and a top

tether anchorage. The lower anchorages

could consist of either UCRA-type

latchplates or rigid anchorages (ISO

Scheme D), provided that connectors are

provided with the Scheme D anchorages

that enables a child seat with UCRA

buckles to be used with the rigid

anchorages. The child restraint system

standard (Standard 213) would be

amended, in effect, to require child seats

to be equipped with a top tether, and

with attachment components (e.g.,

buckles) that are compatible with the

UCRA latchplates on the vehicle.

(3) The proposed requirements would

specify the construction of the child

restraint anchorage system, the location

of the anchorages, and the geometry of

related components, such as the

hardware that attaches to a child seat.

(4) A new safety standard would

specify performance and location

requirements for the tether anchorages.

The standard would apply to all tether

anchorages installed in a vehicle,

regardless of whether the anchorage is

required by a safety standard or

voluntarily installed by the

manufacturer. The agency tentatively

believes that all anchorages should be

subject to the proposed performance

and location requirements to ensure that

any anchorage used in the vehicle

performs properly.

(5) To prevent the anchorages from

failing in a crash, the vehicle

anchorages, including structural

components of the assembly, would

have to withstand specified loads in a

static pull test.

(6) Child restraint systems would be

dynamically tested under Standard 213

when attached to the vehicle system.

The standard seat assembly specified in

the standard to test add-on child seats

would be revised to incorporate the

upper and lower anchorages of a child

restraint anchorage system. It would

have both UCRA anchorages (Scheme C)

and rigid anchors (Scheme D). A head

excursion limit of 813 mm (32 inches)

would have to be met without attaching

the top tether.

(7) A child seat equipped with

features enabling it to be attached to an

anchorage system would also have to

meet the present 813 mm head

excursion requirement of Standard 213

when tested with just a lap belt. This is

to ensure a minimum level of safety

performance when the child seat is used

in a vehicle that does not have an

anchorage system.

(8) In addition, each child restraint

would have to meet a 720 mm (28

inches) head excursion requirement

when tested according to the

manufacturer’s instructions. A tether

provided with the child restraint may be

attached in this test.

(9) Instructions for using the

anchorage system would have to be

provided with each child restraint and

in the vehicle owner’s manual.

As discussed above, this proposal is

based on the premise that a child

restraint anchorage system would make

child seats compatible with motor

vehicles, and thus increase the safety

value of restraints. The approach taken

by this proposal would be to rectify the

vehicle-to-child restraint

incompatibility problem along two

lines: vehicles would be required to

have a child restraint anchorage system

with components ‘‘ready’’ to attach a

child seat, and child restraints would be

required to have components ‘‘ready’’ to

attach to the vehicle system. By having

a dedicated anchorage system for child

restraint systems, manufacturers can

optimize the designs of their vehicle

belt and child restraint systems to

provide higher safety protection to both

adults and children.

A potential but seemingly necessary

limitation in the proposed compliance

tests is that the vehicle system is

statically tested by devices that replicate

the loads imposed by a child seat, and

a child restraint is dynamically tested

on a seat assembly simulating a vehicle

seat. That is, an actual vehicle

anchorage system would not be tested

with an actual child restraint, and vice

versa. This is to avoid possibly

complicating enforcement efforts if an

apparent failure arises in a compliance

test. If vehicles were tested with actual

child seats, and vice versa, and if a

vehicle anchorage system, for example,

were found to fail the proposed

requirements, an issue could arise as to

whether the failure was with the vehicle

system, or with the child seat attached

to the vehicle system. To avoid this

complication, the compliance tests must

be as controlled as possible to remove

unknown influences on the performance

of regulated parts.

While the actual vehicle-to-child seat

attachment would not be tested, NHTSA

believes that the performance obtained

in the compliance test will reflect the

real-world performance of the anchorage

system and the child restraint. This is

because the geometry of the belts and

latchplates primarily responsible for the

vehicle-to-child seat interface would be

precisely specified by this proposal.

These components would have to be

provided on vehicles and child seats

precisely as specified in the standards.

In turn, these components, in the same

geometry as that specified in the

standards, would be used in the

compliance tests. Thus, the vehicle-tochild seat interface should be

adequately tested.

b. Applicability

The requirement for a child restraint

anchorage system would apply to

passenger cars and trucks and

multipurpose passenger vehicles

(MPVs) under 10,000 pounds (lb) gross

vehicle weight rating (GVWR) (hereafter

referred to as ‘‘LTVs’’), except as noted

below.

Petitioners AAMA et al. suggested,

with respect to trucks and MPVs, that

the requirement be limited to those with

a GVWR of 8,500 lb or less and an

unloaded vehicle weight of 5,500 lb or

less. AAMA stated:

The GVWR range suggested was

incorporated using the identical GVWR range

currently required to meet the dynamic

performance requirements of FMVSS 208 for

occupant protection. The relatively small

number of vehicles larger than those within

this range, the physical dynamics of these

size vehicles and the unexpected use of CRSs

[child restraint systems] in them, support

maintaining this GVWR range for this

proposal.

NHTSA agrees that vehicles with

GVWRs of more than 10,000 lb are

much less frequently used to carry

young children (as compared to vehicles

with GVWRs of less than 10,000 lb) and

thus should be excluded from a

requirement to provide a child restraint

anchorage system. However, child

restraint systems could be used in

vehicles with a GVWR between 8,500

and 10,000 lb, such as in vehicles used

for transportation to child care

programs. In the interest of best

ensuring that a child restraint anchorage
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7871

7This figure is consistent with the ISO/WD

13216–1i report that are in the December 13, 1996

submittal to Docket No. 96–095, Notice 1.

8While the geometry of the vehicle latchplates

would be mandated, child restraint systems would

not have designs specified, other than that to have

‘‘components permanently attached to the system

that securely fasten to the [vehicle’s] latchplates’’

(proposed S5.9(a)). However, the agency anticipates

the use of UCRA buckles.

system would be available when needed

and to minimize incompatibility

problems between child restraints and

vehicle seats to the extent possible,

NHTSA proposes to apply this rule to

trucks, buses and multipurpose

passenger vehicles with a GVWR of

10,000 lb or less. Comments are

requested on this issue.

AAMA et al. suggested excluding

walk-in van-type vehicles and vehicles

manufactured to be sold exclusively to

the U.S. Postal Service. The agency

agrees that these vehicles are unlikely to

be used for transporting children in

child safety seats. NHTSA made the

determination in the rulemaking

adopting the lockability requirement,

supra, that these vehicles are not likely

to be used to carry children in child

seats. Accordingly, NHTSA proposes to

exclude these vehicles from today’s

proposed vehicle standard.

The AAMA petitioners suggested that

the standard should not apply to a

vehicle that ‘‘the manufacturer

designates as not intended for CRS use.’’

The petitioner further suggested that

‘‘[v]ehicles not intended for CRS use

shall include this information in the

vehicle’s owner’s manual’’ and on a

label in the vehicle. The agency has

tentatively decided against this

approach. NHTSA does not know, and

petitioners did not explain, why

manufacturers should be permitted to

exclude a vehicle from the proposed

requirements, given that such a

provision could substantially reduce the

number of vehicles that are equipped

with an anchorage system. Reducing the

universe of vehicles equipped with the

anchorage system would eviscerate the

‘‘universality’’ of the system, which

could result in many consumers not

having an improved means of attaching

a child restraint in their vehicle.

c. Seating Positions

This proposal would require the child

seat anchorage system (i.e., a top tether

anchorage and lower anchorages) in two

rear seating positions. NHTSA proposes

requiring the system to be placed in a

rear seating position because available

data indicate that the rear seating

positions are the safest positions in

which to install a child restraint system.

Vehicles that lack a rear seating position

capable of fitting a rear-facing child seat

would be required to provide a system

in the front seat if the vehicle has a

cutoff switch that deactivates the air bag

installed at the right front passenger

position in the vehicle. However, a

child restraint anchorage system would

also have to be installed in the rear seat

of these vehicles, because a rear seat

that is too small to fit a rear-facing child

restraint can nonetheless probably fit a

forward-facing seat. If the vehicle lacks

a rear seat and does not have an air bag

cutoff switch, an anchorage system

would be disallowed in the front

passenger seat. A built-in child seat may

be substituted for one of the anchorage

systems, but not both, since built-in

seats currently cannot accommodate a

rear-facing restraint.

There was no consensus among the

petitioners as to the number of child

restraint anchorage systems that should

be required and where in the rear they

should be. Many believe that the system

should be installed at each of the

outermost designated seating positions

of the second row (and a tether

anchorage in the rear lap-belt center

position). The Japanese vehicle

manufacturers believe that only one rear

seat position should be required to have

the system. Fisher-Price, a child

restraint manufacturer, believes that the

rear center seating position is

recognized as the safest and that the

system should therefore be required

there.

NHTSA has tentatively determined

that each vehicle with a rear seat should

have at least two rear seating positions

that can properly hold a child restraint

system. The agency is concerned

whether there is a need for an anchorage

system at more than two seating

positions. NHTSA requests information

on this issue, such as demographic data

on the number of children in child

restraints typically transported in a

family vehicle. It is noted that nothing

in the proposed standard would

prohibit a vehicle manufacturer from

voluntarily providing child restraint

anchorage systems in rear seats at more

than the required seating positions, if a

purchaser wants additional systems.

This proposal does not specify that

both anchorage systems would have to

be provided at an outboard position. In

some vehicles with large interiors, it

may be possible to install one of the

required systems in a center seating

position.

d. Construction

Requirements are proposed for the

construction of the child restraint

anchorage system. The system would

consist of two child restraint anchorages

at the vehicle seat bight and a tether

anchorage.

1. Lower anchorages

The proposed rule would permit

manufacturers to conform lower

anchorages to either option A,

consisting of requirements based on the

UCRA system (ISO Scheme C), or option

B, based on the Hybrid system (Scheme

D).

Option A (UCRA System)

For vehicles incorporating the UCRA

system, the standard would specify that

lower anchorages are located 280 mm

apart, measured to the centerline of each

latchplate when fully extended in a

plane parallel to the vehicle’s

longitudinal axis. When fully extended,

the tip of each latchplate must not

extend more than 50 mm forward of the

seat bight. The 50 mm value was

suggested to ensure accessibility of the

lower anchorages. The petitioners and

the ISO ad hoc group specified this

figure in a November 15, 1996 draft ISO/

WD13216–1i report. 7 NHTSA

tentatively believes the value is

reasonable to ensure that the lower

latchplates are not so rearward that they

may be buried in the seat bight, yet are

not so forward that excessive forward

movement of a child seat could result.

The standard would also specify the

geometry of related components, such as

webbing and latchplates (tongues) of the

lower anchorage points. NHTSA is

proposing the latchplate geometry that

was suggested in the petition by AAMA

et al. The agency is proposing to specify

the geometry of these components as

necessary to ensure the universality of

the anchorage system. 8 It negates the

likelihood that a used child restraint

with particular attachment components

would be ‘‘handed down’’ or sold to a

person owning a vehicle with an

incompatible anchorage system.

Further, since a simple, effective way of

testing anchorage systems with varying

components has not been devised,

specifying the geometry is the best

means of ensuring that anchorage

systems will securely attach a child

restraint, and provide an adequate level

of child protection.

The lower anchorages would be

equipped with specialized latchplates

that would attach to buckles on a child

seat. The geometry of the components is

such that the webbing, buckles and

latchplates are similar in design to

components found on current adult

occupant belt systems. This is to ensure

that the components and their operation

are familiar to persons installing a child

seat. The geometry of the components is

such that they are smaller in size than
7872 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

9This figure is consistent with the ISO/WD

13216–1i report that are in the December 13, 1996

submittal to Docket No. 96–095, Notice 1.

like components on the adult occupant

belt systems. This is to reduce the

likelihood that the person installing a

child restraint might confuse the belts

and buckles of the child seat anchorage

system with the adult occupant belt

systems.

Several participants at the October

1996 workshop expressed concerns or

suggestions about aspects of the UCRA’s

belt systems. Klaus Werkmeister

expressed concern that the UCRA

system’s lower anchorages could be lost

in the seat bight of a foldover seat after

the seat is flattened to make room for

cargo and then reinstalled as a seat. On

the other hand, John Gane said that the

ICBC clinic had folding rear seats and

that these didn’t interfere with either

the hard or soft anchor systems.

Transcript, October 17, 1996, page 228–

230. Comments are requested on this

issue.

Mr. Gane also suggested that the ICBC

clinic indicated that the side straps for

the UCRA should be distinguished from

the straps comprising the harness for the

child. He said that when the straps were

not distinguished, ‘‘we had a huge

failure rate of people to understand how

the seat was intended to work.’’ Id., p.

220. (Some clinic participants attached

the vehicle anchor belt to the child

restraint’s internal harness.) ICBC later

modified the UCRA child restraint to

color code the belts. Comments are

requested on whether the straps of the

UCRA should be distinguished, and if

so, what measures should be required to

distinguish them (e.g., color coding and/

or labeling).

Howard Willson stated that the

webbing-supported anchorages of the

UCRA should be required to have a

specific stiffness so that users can use

one hand to attach the child seat

connector to the anchorage. The AAMA

et al. petitioners also suggested that the

latchplates should not displace

rearward more than 25 mm under a 50

N rearward load. Comments are

requested on the need for such a

requirement, the level at which a

requirement should be set, the means of

testing a requirement, and limiting sideto-side deflection of the latchplates

which may degrade the ability to attach

the child seat with just one hand.

Comments are also requested on any

other performance that should be

required of the UCRA system to ensure

that it will be effective.

Option B (Scheme D)

For vehicles incorporating the ISO

Scheme D system, the standard would

specify anchorage dimensional and

marking requirements developed in

draft by the ISO in ‘‘ISO/WD 13216–1i

Road Vehicles-Child Restraint SystemsStandardized Universal Attachment to

Vehicle (ISOFIX)—Part 1: Dimensions

and General Requirements,’’ (November

15, 1996). The rule would require the

lower anchorages to be 6 mm diameter

transverse horizontal round bars with a

minimum effective length of 25 mm.

The spacing between the bars would be

280 mm apart, center-to-center. This

value is harmonized with ISO to be

agreeable with manufacturers of

European, Japanese and U.S. motor

vehicles. 9 Other specifications for the

location of the lower anchorage bars

would also be set forth in the standard.

The anchorage location zone would be

determined using a child restraint

apparatus (see Figures 1, 2 and 3 of the

proposed standard).

Vehicle manufacturers incorporating

the Scheme D system would also be

required to provide connectors that

would enable the system to be used

with a UCRA-type child seat. The

connector would have a component on

one end that latches onto the 6 mm bar,

and a UCRA latchplate on the other for

attaching a UCRA child seat to the

anchorage system. Comments are

requested on the degree to which the

geometry of the connector should be

specified. A connector would have to be

provided for each Scheme D lower

anchorage point. NHTSA believes that a

connector should be provided to ensure

that parents having a UCRA-type child

restraint can use the restraint in any

vehicle. This aspect of the proposal was

not included in the petition from BMW

et al. Those petitioners suggested that a

connector from a child restraint to the

vehicle anchorages should be provided

on the child restraint, by the child

restraint manufacturer. Comments are

requested on this issue.

2. Upper Anchorage

The tether anchorage would be

harmonized with Canadian and

Australian requirements. Canada is

preparing to require vehicles to have a

factory-installed, user-ready tether

anchorage. While AAMA et al.

originally petitioned to require a

specialized buckle that would be

compatible with a latchplate on a child

seat tether, petitioners have indicated a

desire to harmonize with Canada and

Australia. Thus, a simple anchor (such

as a ring) on the vehicle would be

sufficient, although a more

sophisticated anchor could be provided

if it is compatible with the tether hook

that today’s NPRM proposes to require

on child restraints.

e. Performance

The main performance requirement

for the anchorage system would specify

strength criteria for the lower and upper

anchorages and related hardware. In

addition, the standard would require the

system to meet Standard 209’s belt and

buckle requirements, such as those

relating to abrasion, resistance to light,

corrosion resistance and temperature

resistance. Comments are requested on

whether Standard 213’s buckle release

requirements (S5.4.3.5) should also be

met. Among other things, those

requirements specify that a buckle must

not release when subjected to a force of

less than 40 N, and shall release when

a force of not more than 62 N is applied.

The proposed strength criteria are to

prevent the anchorages from failing in a

crash. The anchorages, including

structural components of the assembly,

would have to withstand specified loads

in a static pull test.

The performance criteria for the lower

anchorages would require that, in a

static test of the anchorages: (a) no

portion of the latchplate for each

anchorage shall move more than 125

mm forward of the seat bight when

subjected to a forward force of 5,300 N

and, (b) there shall be no complete

separation of any anchorage component

of the assembly (including webbing,

straps, latchplates, adjustment and

anchorage hardware and retractors).

The static pull test would specify that

each lower anchorage is tested to

withstand the application of a 5,300 N

forward load. In the test, a force of 5,300

N would be applied to each anchorage

in the forward direction parallel to the

vehicle’s longitudinal vertical plane.

The force would be applied by means of

a belt strap that is of sufficient length to

extend not less than 250 mm forward

from the vertical plane intersecting the

seat bight. The belt would be fitted at

one end with hardware for applying the

force, and at the other end with

hardware for attachment to the

anchorage latchplate. The 5,300 N force

is attained within 30 seconds, with an

onset force rate not exceeding 135,000 N

per second, and is maintained at the

5,300 N level for ten seconds. The test

procedure and force level were selected

to harmonize with the proposed

Canadian regulations on the upper

tether, as well as with the suggested

force level of the UCRA petition. The

same test is proposed for the rigid

anchor system with the adapter attached

to each anchor point.
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7873

10Assuming a final rule on this subject is issued,

the requirements set forth in the proposed tether

standard could be incorporated into the standard on

the child restraint system anchorage system, rather

than in a separate standard.

A static pull test would also be

specified in a new standard 10 for the

upper tether anchorage, in accordance

with Canada’s proposed tether

anchorage requirement. The force level

and application rate would harmonize

with the proposed Canadian regulations

on the upper tether. The standard would

specify that each structural component

of the anchorage shall withstand a force

of not less than 5,300 N, and that there

shall be no complete separation or

failure of any anchorage component.

Comments are requested on whether

more specificity is needed for these

strength requirements, and on whether

other performance requirements should

be included in the standard.

Each tether anchorage would be tested

separately. However, more than one

tether anchorage installed on a row of

seats would be tested simultaneously.

f. Instructions

The standard would require that

instructions about attaching a child

restraint to the vehicle anchorage

system be provided in the vehicle

owner’s manual. The instructions would

have to indicate the seating positions

equipped with a child restraint

anchorage system, and include

instructions that provide a step-by-step

procedure, including diagrams, for

properly attaching a child restraint

system to a vehicle anchorage system

equipped with UCRA-type anchorages.

In addition, for a vehicle equipped with

a rigid anchorage system, instructions

would also have to be provided for

properly attaching a child restraint to

the rigid system.

VII. Proposal for Amendments to Child

Seat Standard

a. Applicability

Standard 213 would be amended to

require all child seats, other than belt

positioning seats, to be equipped with

components that are compatible with

the UCRA anchorages on the vehicle

system. Belt-positioning seats, which

are a type of booster seat designed for

older children, are designed to use a

vehicle’s lap and shoulder (Type II) belt

system to restrain the child occupant.

Because a vehicle’s belt system is not

necessarily directly routed around or

through a belt-positioning seat to secure

it to a vehicle, and because upper torso

protection is provided by the shoulder

portion of the Type II belt, there does

not appear to be any incompatibility

between a vehicle seat or its seat belts

and belt-positioning seats. Also, because

a Type II belt system is placed around

the child occupant who is seated on a

belt-positioning seat, there would be a

minimal amount of forward movement

of the child and child seat before

forward movement is restrained by the

Type II belts.

b. Required Components

Requirements would be established

for the components of the child seat that

attach to the vehicle system. A child

restraint would be permitted to have

components that attach to rigid or semirigid Scheme D anchorages (Hybrid

system), but the restraint must

nonetheless have the UCRA attachments

permanently attached to it. This would

ensure that persons owning any type of

child seat can use the restraint in any

vehicle (i.e., all vehicles would be able

to attach a UCRA-type seat, either

attached to a UCRA system, or by way

of UCRA connectors to Hybrid

anchorages). The agency requests

comments on whether child restraints

intended to be used with systems that

have Hybrid anchorages should be

required to provide an adapter, rather

than the UCRA components.

By way of reduced allowances on

head excursion, each child seat would

be required to have a tether that attaches

to the vehicle. To minimize the chances

of incompatibility between the seat and

the vehicle, the standard would specify

the exact geometry of the tether hook.

The regulatory text for this proposal

does not include a provision that the

child seat components attaching to the

lower anchorages of the vehicle system

have retractors to take up excessive

slack in the belts. NHTSA requests

comments on whether a retractor is

needed or is manual adjustment enough

to ensure that the child seat will be snug

against the vehicle seat back. Excessive

slack in the connecting belts could

result in excessive head and knee

excursions for the child occupant, and

a greater likelihood of head impact.

In the October 1996 workshop,

Kazuhiko Miyadara, Jocelyn Pedder of

Transport Canada, and others indicated

that a soft anchor system should have a

means of taking up slack in the belts.

Comments are requested on what type

of retractor, if any, should be specified

for the UCRA.

c. Dynamic Performance

The dynamic test specified in

Standard 213 would be used to evaluate

the performance of the child seat when

attached to the universal vehicle

anchorage system. The standard seat

assembly specified in the standard to

test add-on child seats would be revised

to incorporate a child restraint

anchorage system meeting the proposed

specifications. A child restraint would

be attached to the system using the

appropriate buckles and other

components of the child restraint. Injury

criteria and other performance

requirements specified in Standard 213

would have to be met when the child

seat is attached to the anchorage system.

Forward-facing restraints would be

required to meet a head excursion limit

of 720 mm (28.35 inches) when tested

in accordance with its manufacturer’s

instructions. To meet this requirement,

most manufacturers would likely have

to provide a top tether, which would be

attached in the test for this new

requirement. Restraints would also be

required to meet a head excursion limit

of 813 mm (32 inches) when the tether

is not attached, to ensure that a

minimum level of safety is provided in

a misuse situation. Each child seat

would also have to meet the 720 mm

(tethered) and 813 mm (untethered)

head excursion limits when attached by

a lap belt. This test would be to ensure

a minimum level of safety performance

when the child seat is used in a vehicle

that does not have a UCRA or rigid

anchor system.

NHTSA believes that Standard 209’s

belt and buckle requirements relating to

abrasion, resistance to light, corrosion

resistance and temperature resistance,

should apply to the webbing and

hardware installed on a child seat to

connect to a vehicle system as required

by the existing provisions of S5.4 of

Standard 213. The agency tentatively

concludes that these belt and buckle

requirements of Standard 209 should

apply to ensure the safe performance of

the belts and associated hardware.

d. Instructions and Labeling

Standard 213 would be amended to

require that instructions about attaching

a child restraint to the vehicle

anchorage system be provided in the

printed instructions accompanying each

restraint. The instructions would have

to provide a step-by-step procedure,

including diagrams, for properly

attaching a child restraint system to a

vehicle anchorage system equipped

with UCRA-type anchorages, and if the

child restraint is intended for a vehicle

equipped with a rigid or Hybrid

anchorage system, instructions for

properly attaching to such a system.

NHTSA also proposes amending

Standard 213’s labeling requirements, to

either add a new provision or amend an

existing one such as S5.5.2(g), to

instruct owners to secure the child

restraint system with either a vehicle
7874 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

belt or components attaching to a

vehicle’s child restraint anchorage

system.

S5.5.2(j) of Standard 213 would

already require a label instructing

owners to secure the top tether strap of

the child restraint. That section states

that in the case of each child restraint

system equipped with an anchorage

strap, the following must be

permanently labeled:

SECURE THE TOP ANCHORAGE

STRAP PROVIDED WITH THIS CHILD

RESTRAINT AS SPECIFIED IN THE

MANUFACTURER’S INSTRUCTIONS.

Comments are requested on what

changes, if any, should be made to this

labeling requirement to increase the

likelihood that parents will attach the

top tether strap.

VIII. Proposed Effective Date

In their petition, AAMA et al

recommended a schedule for phasing in

the suggested requirements, should

those requirements be adopted. The

petitioners requested different

schedules for vehicle manufacturers,

child restraint manufacturers, and finalstage vehicle manufacturers and

alterers. The latter group of

manufacturers are typically small

businesses. (See table 2, below.) The

schedules suggested by AAMA et al. are

based on the assumptions that (a) the

attaching system envisioned by the

petitioners is adopted, and (b) a final

rule is issued by January 1, 1997.

The petitioners suggest that vehicle

manufacturers be permitted two

alternatives in phasing in complying

vehicles, beginning September 1, 1998.

Under the first alternative, 10 percent of

the vehicles manufactured in the first

model year after September 1, 1998,

would be required to have the child

restraint anchorage system

(manufactured on or after September 1,

1998, through August 31, 1999), 30

percent of the vehicles manufactured in

the second model year (ending August

31, 2000), 50 percent in the third model

year (ending August 31, 2001), and 100

percent in the fourth year (ending

August 31, 2002). Under the second

alternative, no vehicle need comply

with the proposed standard before

September 1, 2000, but 75 percent of a

manufacturer’s vehicles produced on or

after September 1, 2000 through August

31, 2001 (model year 2001) would have

to comply with the requirements, and

100 percent of its vehicles manufactured

on or after September 1, 2001 would

have to comply.

The requested schedule for child seat

manufacturers also includes two

alternatives for phasing in complying

child seats, beginning September 1,

1998. The petition refers to child

restraints manufactured in a particular

‘‘model year,’’ which apparently

assumes the September 1 to August 31

cycle traditionally used to designate

vehicle model years. Under the first

alternative, 5 percent of the child seats

manufactured in the first ‘‘model year’’

after September 1, 1998 would be

required to have the components

enabling the child restraint to attach to

the universal vehicle system (model

year ending August 31, 1999), 15

percent of the child restraints

manufactured in the second model year

(ending August 31, 2000), 25 percent in

the third model year (ending August 31,

2001), and 100 percent in the fourth

year (ending August 31, 2002). Under

the second alternative, no child restraint

need comply with the proposed

amendments to Standard 213 before

September 1, 2000, but 50 percent of a

manufacturer’s restraints produced on

or after September 1, 2000 through

August 31, 2001 (model year 2001)

would have to comply with the

requirements, and 100 percent of its

child seats manufactured on or after

September 1, 2001 would have to

comply.

The petitioners provided the

following table showing the requested

phase-in schedules for vehicle and child

seat manufacturers:

PETITIONERS REQUESTED PHASE-IN ALTERNATIVES (PERCENT OF PRODUCTS REQUIRED TO COMPLY)

Model year

Vehicle manufacturers alternative #1 (percent)

Vehicle manufacturers alternative #2

Child seat manufacturers alternative #1 (percent)

Child seat manufacturers alternative #2

1999 .......................................................................................................... 10 0 5 0

2000 .......................................................................................................... 30 0 15 0

2001 .......................................................................................................... 50 75 25 50

2002 .......................................................................................................... 100 100 100 100

The requested schedule for final-stage

manufacturers and alterers would

provide these manufacturers the option

of using the phase-in schedule for

vehicle manufacturers, described above,

or the alternative of having the

requirements become mandatory on

September 1, 2001 for 100 percent of a

manufacturer’s vehicles, and not before.

NHTSA has made the following

tentative decisions about leadtime. The

agency believes that the proposed

requirement that vehicles provide a

user-ready tether anchorage and that

child seats provide a tether can be made

effective at a much earlier date than a

requirement for the lower anchorages of

a child restraint anchorage system.

Passenger cars, in particular, generally

are already equipped with a tether

anchor (Canada has required a tether

anchorage in passenger cars since 1989),

so it appears that a user-ready anchorage

can be provided in the near future.

Canada is proposing an effective date of

September 1, 1999 for its tether

hardware requirement for passenger

cars. NHTSA proposes that its tether

anchorage requirement for passenger

cars be the same as the Canadian

proposal.

For LTVs, Canada has also proposed

that its tether anchor (hole) requirement

be effective September 1, 1999, and its

tether hardware requirement effective a

year later. In view of these dates and

that anchorages (holes) are apparently

not as currently available on LTVs as on

passenger cars, NHTSA proposes a

September 1, 2000 effective date for its

tether hardware requirement for LTVs.

With regard to child restraints,

restraints manufactured in the U.S. and

sold in Canada already are equipped

with a tether to meet Canadian

requirements. NHTSA believes that

most U.S. manufacturers produce child

restraints for sale in Canada. NHTSA is

considering an effective date of

September 1, 1999 for its proposal to

effectively require tethers by way of

reducing Standard 213’s head excursion

requirement.

As to a requirement for the lower

anchorages, the petitioners did not

explain why a phase-in is needed, or

why more than four years would be

needed to implement the requirement.

The agency is determined to remedy the
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7875

11 A phase-in of an amendment to an equipment

standard is uncommon. It should be noted that to

implement a phase-in requirement, the agency

would require manufacturers to provide

information on the total annual sales of their seats,

so that the agency can determine whether the

requisite number of seats complied with the new

requirements.

problem of incompatibility of child

restraints and motor vehicles as

promptly as possible and requests

comments on the feasibility of having

full implementation (100 percent of

affected vehicles) in a shorter period,

e.g., two years after the publication of a

final rule. GM indicated in the UCRA

petition that if allowed, it would begin

installing the UCRA system on vehicles

before completion of this rulemaking on

UCRAs. (NHTSA replied in an August

27, 1996 letter that manufacturers are

permitted to voluntarily install the

system before completion of a final

rule.) Given that the UCRA technology

is developed and available, and capable

of being installed in today’s vehicles,

the agency believes the system could be

implemented within two years. The

same issue arises with regard to the

effective date for requiring child

restraints to be equipped with buckles

and other components compatible with

the UCRA system. Comments are

requested on why a phase-in is needed,

and on whether a shorter compliance

date is possible.11

NHTSA recognizes that the rigid

attachment system may need longer

time to implement, especially on

vehicles that may need to redesign their

vehicle seats and/or floor pans. This

was acknowledged by the international

safety community in the December 6,

1996 ISO resolution that the rigid

system is a hardware alternative that

needs some time for development, as

compared to the flexible hardware

option. (See section IV.a., supra.) The

agency’s proposal would allow the long

term rigid anchors solution to coexist

with the UCRA approach that is

available today. Even though the

proposed lead time of 24 months may

not be sufficient for the rigid anchorage

hardware technology, the proposed rule

provides vehicle manufacturers with the

option of implementing the rigid system

(with connectors) once it is developed,

while providing a UCRA-type system in

the short term.

IX. Rulemaking Analyses and Notices

a. Executive Order 12866 (Federal

Regulation) and DOT Regulatory

Policies and Procedures

NHTSA has examined the impact of

this rulemaking action and determined

that it is economically significant within

the meaning of Executive Order 12866

and significant within the meaning of

the Department of Transportation’s

regulatory policies and procedures.

NHTSA has prepared a Preliminary

Economic Assessment (PEA) for this

notice which discusses issues relating to

the potential costs, benefits and other

impacts of this regulatory action.

A copy of this analysis has been

placed in the docket for this rulemaking

action. Interested persons may obtain

copies of this document by writing to

the docket section at the address

provided at the beginning of this notice.

To briefly summarize the analysis,

NHTSA estimates that the cost of a rule

requiring the UCRA system would be

approximately $160 million. The cost of

the rule related to the vehicle would

range, per vehicle, from $3.88 (one

UCRA in front seat only) to $7.76 (for

one UCRA in front seat and one in back

seat or two UCRAs in rear seats).

NHTSA estimates that 15 million

vehicles would be affected: 9 million

passenger cars and light trucks with

‘‘adequate’’ rear seats, 3 million vehicles

with no rear seat, and 3 million vehicles

that can only accommodate a forwardfacing child seat in the rear seat (not a

rear-facing infant seat). The cost of the

rule for vehicles is estimated to be about

$105 million. The cost of the UCRA

attachments on the child seat is

estimated to be about $55 million (3.9

million child restraints (excluding beltpositioning boosters) at $14 per seat).

The benefits of the rule are estimated

to be 24 to 32 lives saved per year, and

2,187 to 3,615 injuries prevented.

As discussed in the PEA for this

proposal, in view of the cost of the

UCRA attachments on a child restraint,

estimated to be about $14 per restraint,

NHTSA requests information on the

price elasticity of child restraints.

NHTSA is concerned about the potential

effects of this rule on the purchase

behavior of consumers. As one

participant in the October 1996

workshop pointed out, if consumer

demand is sufficiently sensitive to new

car seat prices, the resulting changes in

car seat usage could partially or totally

offset the benefits of the proposed rule.

NHTSA has estimated that the proposed

rule will raise the price of the average

car seat by $14. For a $50 car seat, this

represents a 28 percent increase in

price. On the other hand, each of the

States and the District of Columbia

require the use of child restraints in

motor vehicles. To what extent, if at all,

would an increase in the price of a child

restraint lead to a decrease in demand

for the product, notwithstanding child

restraint use laws mandated by each

State? Also, NHTSA and child restraint

manufacturers have been inundated

with calls from parents asking for help

in installing seats correctly. Would this

interest in child safety motivate a

sufficiently large number of people to

pay $14 for changes to a child restraint

that would make a restraint easier to

install and more secure on a vehicle

seat? NHTSA is especially interested in

comments from consumers on these

questions.

Consumers have essentially four

choices: buy a car seat despite the

higher price, buy a used seat, seek a

giveaway or loaner program, or forego

the seat altogether. If a 28 percent price

increase were to result in a 10 percent

decrease in new sales and thus a

corresponding decline in usage

(assuming options two and three are not

available), then the estimated benefits of

the rule (24 to 32 fatalities prevented

per year) could be offset by an estimated

24 fatalities from reductions in the

number of seats in use. Consumers

turning to the used car seat market

would receive no benefit from the

proposed rule. The offsetting effects

would be reduced if there is a

corresponding increase in giveaway and

loaner programs, but by virtue of the

price increase these programs would

have to find new or additional funding.

The agency does not know how many

programs exist and requests information

on this issue. A cost increase could

result in fewer seats being purchased by

the program for loan or giveaway. On

the other hand, persons responsible for

some State loaner/giveaway programs

informed the agency that if the new

seats cost more, they would be able to

find the funding to keep up with

demand. They also said that the time

saved installing child seats in each

vehicle and making adjustments would

be worth the difference in price.

Unfortunately, NHTSA has not

located any data or estimates of the

actual sensitivity of new child restraint

sales to price changes. For the sake of

comparison, a large proportion of

consumer goods exhibit greater

sensitivity to price than that described

in the hypothetical example above, even

in the short run. If new child restraint

purchases in fact exhibit the same

magnitude of price sensitivity as many

other consumer goods, the proposed

rule could increase rather than reduce

the overall risks to the Nation’s

children.

For these reasons, NHTSA strongly

encourages data, analyses, and comment

on this issue. The agency also requests

comments on ways to mitigate these

effects, such as ways to minimize effects

on price. For example, the $14 cost

increase includes the cost of two

buckles that attach to latchplates of the
7876 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

UCRA system on the vehicle. Would

costs be reduced if the latchplates were

part of the child restraint and the

buckles part of the vehicle system? This

assumes that the buckle hardware is of

higher cost than the latchplates. Should

NHTSA conclude that both (1) the

combination of expected child restraint

price changes and consumer sensitivity

to those price changes is sufficiently

large and (2) there are no cost-effective

ways to mitigate these effects such that

the final rule will result in a net

increase in child safety, NHTSA would

need to reconsider the proposal.

b. Regulatory Flexibility Act

The Regulatory Flexibility Act of 1980

(Public Law 96–354), as amended,

requires agencies to evaluate the

potential effects of their proposed and

final rules on small businesses, small

organizations and small governmental

jurisdictions. Section 603 of the Act

requires agencies to prepare and make

available for public comment an initial

regulatory flexibility analysis (IRFA)

describing the impact of proposed rules

on small entities. NHTSA has included

an IRFA in the PEA for this proposal.

NHTSA tentatively believes that the

proposed rule could have a significant

impact on a substantial number of small

entities. The proposed rule would affect

motor vehicle manufacturers, almost all

of which would not qualify as small

businesses, and portable child restraint

manufacturers. NHTSA estimates there

to be about 10 manufacturers of portable

child restraints, four or five of which

could be small businesses.

Business entities are generally defined

as small businesses by Standard

Industrial Classification (SIC) code, for

the purposes of receiving Small

Business Administration assistance.

One of the criteria for determining size,

as stated in 13 CFR 121.601, is the

number of employees in the firm. There

is no separate SIC code for child

restraints, or even a category that they

fit into well. However, there are

categories that could be appropriate. To

qualify as a small business in the Motor

Vehicle Parts and Accessories category

(SIC 3714), the firm must have fewer

than 750 employees. The agency has

considered the small business impacts

of this proposed rule based on this

criterion. On the other hand, to qualify

as a small business in the category

including manufacturers of baby

furniture, the firm must have fewer than

500 employees. Comments are requested

on which Standard Industrial

Classification code would best represent

child restraint manufacturers.

The IRFA discusses the possible

impacts on small entities and requests

information that would assist NHTSA in

further analyzing those impacts. As

discussed in the IRFA, the incremental

cost increase of $14 to the current price

of a child restraint would significantly

raise the price of child restraints, which

could have a significant economic

impact on a substantial number of small

businesses. NHTSA does not know the

elasticity of demand for child restraints.

While child restraint use is mandated by

each State, there is significant nonuse of

restraints. An increase in the price of a

child restraint could lead to a decrease

in demand for the product,

notwithstanding the restraint use laws.

According to information from Cosco

(see summary, above, of NHTSA’s

October 1996 public workshop), the

average purchase price of a convertible

car seat today is $63. About 25 percent

of the car seats purchased cost $50 or

less; less than five percent cost $100 or

more. Cosco estimated that at least 10

percent of the people would not be able

to purchase a car seat if prices increased

significantly.

Comments are requested on the effect

that raising child restraint prices by $14

(UCRA attachments) to possibly $100

(hard anchor system) would have on

small businesses that manufacture child

restraints. Would an across-the-board

increase in price reduce small business

sales? What is the magnitude of the

impact?

As discussed above in section IX.a., a

loaner program could have fewer seats

available. Assuming that would be the

case, NHTSA seeks information on the

extent to which the number of seats a

program makes available impacts on the

organization itself. For example, do

proceeds from loaner or giveaway

programs (where a nominal fee might be

charged) support the not-for-profit

organization’s activities?

NHTSA tentatively believes that there

are no alternatives to the proposal

which would accomplish the stated

objectives of 49 U.S.C. § 30101 et seq.

and which would minimize any

significant economic impact of the

proposed rule on small entities. As

discussed above in section V.c.,

‘‘Discussion of Alternatives,’’ NHTSA

considered a number of other

approaches to minimize or eliminate

incompatibility between child seats and

vehicle seats. SAE Recommended

Practice J1819, ‘‘Securing Child

Restraint Systems in Motor Vehicle Rear

Seats,’’ does not appear sufficient alone

to solve incompatibility problems. It is

a tool for evaluating incompatibility, not

a requirement that vehicle seats and

child restraints must be compatible.

Further, it is very difficult for a single

system to optimize the safety protection

for adults of all ranges and child

restraints of different types. The current

‘‘lockability’’ requirement does not

appear sufficient alone in addressing

incompatibility, because it still depends

on the user knowing enough and

making the effort to manipulate and

correctly route the belt system. Also, the

lockability requirement does not

address incompatibility problems

arising from forward-mounted seat belt

anchors. The ‘‘Car Seat Only (CSO)’’

system suggested by Cosco probably

would not make attaching a child seat

significantly easier than it is today. The

CSO belt would have to be correctly

routed through the child restraint,

which is a problem occurring with

present seats, and appears hard to

tighten. Also, Cosco provided no

information showing that the CSO belt

would improve the securement of a

child restraint on contoured (especially

humped) seats. Another concern relates

to the potential for inadvertent use by

an adult occupant.

Comments are requested on possible

alternatives to the proposal which

mitigate any significant economic

impact of the proposed rule on small

entities, while accomplishing the

objectives of 49 U.S.C. § 30101 et seq.

c. Executive Order 12612

This proposed rule has been analyzed

in accordance with the principles and

criteria contained in Executive Order

12612, and the agency has determined

that this proposal does not have

sufficient federalism implications to

warrant the preparation of a Federalism

Assessment.

d. Unfunded Mandates Reform Act

The Unfunded Mandates Reform Act

of 1995 (Pub. L. 104–4) requires

agencies to prepare a written assessment

of the costs, benefits and other effects of

proposed or final rules that include a

Federal mandate likely to result in the

expenditure by State, local or tribal

governments, in the aggregate, or by the

private sector, of more than $100

million annually. NHTSA has included

an evaluation in the PEA for this

proposal. The costs and benefits of the

proposal are discussed above and

throughout the PEA. (As explained

above, the cost would be approximately

$105 million for vehicles, and $55

million for child restraints. The benefits

would be saving approximately 24 to 32

children’s lives per year, and preventing

2,187 to 3,615 injuries. An independent

means of attaching child restraints

would also enable vehicle

manufacturers to optimize the design of

vehicle belt systems for adult

occupants.)
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7877

Participants in a NHTSA public

meeting held in March 1995 at the

Lifesavers National Conference on

Highway Safety Priorities, who typically

work in State highway traffic safety

agencies, community traffic safety

programs and State or local law

enforcement agencies, expressed strong

support for a requirement for a universal

child restraint anchorage system, such

as that proposed in this NPRM. Support

for a universal child restraint anchorage

system, such as that proposed in the

NPRM, was also expressed at NHTSA’s

October 1996 public workshop on

various types of anchorage systems. As

discussed above in sections V.c. and

IX.b., and in the PEA, the agency does

not believe that there are feasible

alternatives to the proposal, including

SAE Recommended Practice J1819, the

lockability requirement or Cosco’s CSO

system.

e. National Environmental Policy Act

NHTSA has analyzed this rulemaking

action for the purposes of the National

Environmental Policy Act. The agency

has determined that implementation of

this action would not have any

significant impact on the quality of the

human environment.

f. Executive Order 12778 (Civil Justice

Reform)

This proposed rule does not have any

retroactive effect. Under section 49

U.S.C. 30103, whenever a Federal motor

vehicle safety standard is in effect, a

state may not adopt or maintain a safety

standard applicable to the same aspect

of performance which is not identical to

the Federal standard, except to the

extent that the state requirement

imposes a higher level of performance

and applies only to vehicles procured

for the State’s use. 49 U.S.C. 30161 sets

forth a procedure for judicial review of

final rules establishing, amending or

revoking Federal motor vehicle safety

standards. That section does not require

submission of a petition for

reconsideration or other administrative

proceedings before parties may file suit

in court.

X. Comments on the Proposal

Interested persons are invited to

submit comments on the proposal. It is

requested, but not required, that 10

copies be submitted.

All comments must not exceed 15

pages in length. (49 CFR 553.21).

Necessary attachments may be

appended to these submissions without

regard to the 15-page limit. This

limitation is intended to encourage

commenters to detail their primary

arguments in a concise fashion.

If a commenter wishes to submit

certain information under a claim of

confidentiality, three copies of the

complete submission, including

purportedly confidential business

information, should be submitted to the

Chief Counsel, NHTSA, at the street

address given above, and seven copies

from which the purportedly confidential

information has been deleted should be

submitted to the Docket Section. A

request for confidentiality should be

accompanied by a cover letter setting

forth the information specified in the

agency’s confidential business

information regulation. 49 CFR Part 512.

All comments received before the

close of business on the comment

closing date indicated above for the

proposal will be considered, and will be

available for examination in the docket

at the above address both before and

after that date. To the extent possible,

comments filed after the closing date

will also be considered. Comments

received too late for consideration in

regard to the final rule will be

considered as suggestions for further

rulemaking action. Comments on the

proposal will be available for inspection

in the docket. The NHTSA will continue

to file relevant information as it

becomes available in the docket after the

closing date, and it is recommended that

interested persons continue to examine

the docket for new material.

Those persons desiring to be notified

upon receipt of their comments in the

rules docket should enclose a selfaddressed, stamped postcard in the

envelope with their comments. Upon

receiving the comments, the docket

supervisor will return the postcard by

mail.

List of Subjects 49 CFR Part 571

Imports, Motor vehicle safety, Motor

vehicles.

PART 571—[AMENDED]

In consideration of the foregoing,

NHTSA proposes to amend 49 CFR Part

571 as set forth below.

1. The authority citation for Part 571

would continue to read as follows:

Authority: 49 U.S.C. 322, 30111, 30115,

30117 and 30166; delegation of authority at

49 CFR 1.50.

2. Section 571.210a would be added

to read as follows:

§ 571.210a Standard No. 210a; Child

restraint anchorage system.

S1. Purpose and scope. This standard

establishes requirements for a system for

anchoring child restraint systems to

increase the likelihood that child

restraints are properly secured in motor

vehicles.

S2. Application. This standard

applies to passenger cars, and to

multipurpose passenger vehicles, trucks

and buses with a GVWR of 10,000

pounds or less, except walk-in van-type

vehicles and vehicles manufactured to

be sold exclusively to the U.S. Postal

Service.

S3. Definitions.

Child restraint anchorage means any

component involved in transferring

child restraint loads to the vehicle

structure, including but not limited to,

the attachment hardware on the vehicle

structure, webbing and straps attached

to the vehicle and hardware attached

thereto, the seat frames, seat pedestals,

and the vehicle structure itself.

Child restraint anchorage system

means a system that is designed for

attaching a child restraint to a vehicle at

a particular designated seating position

and for transferring child restraint loads

to the vehicle structure and that consists

of—

(1) Two lower child restraint

anchorages at the seat bight; and

(2) A tether anchorage for attaching a

top tether strap of a child restraint

system.

Child restraint apparatus means the

fixture depicted in Figures 1, 2 and 3 of

this standard which simulates the

dimensions of a child restraint, and

which is used to determine the space

required by the child restraint and the

location and access to the lower

anchorages.

Seat bight means the intersection of

the vertical plane tangent to the forward

most point of the seat back and the

horizontal plane tangent to the

uppermost point of the seat cushion.

Tether anchorage is defined in 49

CFR 571.210b, ‘‘Tether anchorages for

child restraint systems.’’

S4. Requirements. Each motor vehicle

shall meet the requirements in this

section when, as specified, tested in

accordance with S5 and this paragraph.

S4.1 Type.

(a) Except as provided in S4.1(b)

through (d) of this section, each vehicle

shall be equipped with a child restraint

anchorage system for at least two rear

designated seating positions.

(b) A vehicle may be equipped with

a built-in child restraint system

conforming to the requirements of

Standard No. 213 (49 CFR 571.213) in

lieu of one of the child restraint

anchorage systems required by S4.1(a)

of this section.

(c) A vehicle that meets the

conditions concerning rear seats in

either S4.5.4.1(a) or S4.5.4.1(b) of

Standard No. 208 (49 CFR 571.208) and
7878 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

that has an air bag cutoff switch meeting

the requirements of S4.5.4 of Standard

208 shall have a child restraint

anchorage system installed for a

designated seating position in the front

seat, and for a position in the rear seat

if the vehicle has a rear seat.

(d) A vehicle that has no forwardfacing designated seating positions to

the rear of the front seating positions

and no air bag cutoff switch meeting the

requirements of S4.5.4 of Standard 208,

shall not have a child restraint

anchorage system installed for a

designated seating position in the front

seat.

S4.2 Lower anchorages.

The child restraint anchorage system

shall have two lower anchorages and

shall conform to either S4.2.1, or S4.2.2

and S4.2.3, at the manufacturer’s option.

S4.2.1 Flexible anchorages.

S4.2.1.1 Configuration and

Geometry.

A child restraint anchorage system

shall incorporate two lower anchorages

with latchplates conforming to the

configuration and geometry specified in

Figure 4 of this standard.

S4.2.1.2 Location.

(a) When fully extended in a plane

parallel to the vehicle’s longitudinal

axis, the centerlines of the two

latchplates are 280 mm apart.

(b) When fully extended in a plane

parallel to the vehicle’s longitudinal

axis, the tip of each latchplate must not

extend more than 50 mm forward of the

seat bight.

S4.2.1.3 Strength.

When tested in accordance with S5 of

this standard, a child restraint

anchorage system shall meet the

following requirements:

(a) No portion of the latchplate for

each lower anchorage shall pass through

a vertical, transverse plane that is 125

mm forward of the seat bight; and

(b) There shall be no complete

separation of any anchorage component

component (including webbing, straps,

hooks and buckles, latchplates,

adjustment and attachment hardware

and retractors).

S4.2.2 Rigid or semi-rigid

anchorages.

S4.2.2.1 Configuration and

geometry.

A child seat anchorage system shall

incorporate two lower anchorages that

are 6 mm diameter transverse horizontal

round bars with a minimum length of 25

mm.

S4.2.2.2 Location.

(a) The transverse spacing of the bars

shall be 280 mm, center-to-center.

(b) The lower anchorage bars are

located with respect to the child

restraint apparatus rearward extensions

as shown in Figures 2 and 3 of this

standard, with the child restraint

apparatus placed on the vehicle seat

cushion and against the vehicle seat

back. Anchorage bars that are rigidly

supported are to be 50 mm rearward of

the rearmost surface of the fixture, while

semi-rigidly supported bars may be

located from 50 mm rearward to 10 mm

forward of that surface. The center of

rigidly supported lower anchorage bars

shall be at least 120 mm behind the

vehicle seating reference point.

(c) Rigidly supported lower anchorage

bars must be in a zone from 10 to 20 mm

above the bottom surface of the child

restraint apparatus, while semi-rigidly

supported bars must be in a zone from

0 to 20 mm above that surface.

S4.2.2.3 Strength.

When tested in accordance with S5 of

this standard, a child restraint

anchorage shall meet the following

requirements:

(a) No portion of any component

attaching to the lower anchorage bars

shall move forward more than 125 mm.

(b) There shall be no complete

separation of any anchorage component.

S4.2.3 Connectors.

Each vehicle equipped with lower

anchorages conforming to S4.2.2 of this

standard shall be equipped with

connectors that permit the attachment of

a child restraint that is equipped with

components which attach to lower

anchorages conforming to S4.2.1. Each

connector shall be equipped with a

latchplate conforming to the

configuration and geometry specified in

Figure 4 of this standard. When attached

to a lower anchorage, the tip of each

latchplate must not extend more than 50

mm forward of the seat bight when the

connector is fully extended.

S4.3 Tether anchorage.

The child restraint anchorage system

shall incorporate a tether anchorage

conforming to 49 CFR 571.210b, ‘‘Tether

anchorages for child restraint systems.’’

S4.4 Webbing, buckles and belt

adjustment hardware.

S4.4.1 Webbing.

The webbing provided with a child

restraint anchorage system shall—

(a) After being subjected to abrasion

as specified in S5.1(d) or S5.3(c) of

FMVSS No. 209 (49 CFR 571.209), have

a breaking strength of not less than 75

percent of the strength of the unabraded

webbing when tested in accordance

with S5.1(b) of FMVSS 209; and

(b) Meet the requirements of S4.2(e)

through (h) of FMVSS No. 209 (49 CFR

571.209).

S4.4.2 Buckles and belt adjustment

hardware.

Each belt buckle and item of belt

adjustment hardware used in a child

restraint anchorage system shall

conform to the requirements of S4.3(a)

and S4.3(b) of FMVSS No. 209 (49 CFR

571.209).

S4.5 Marking and Guidance.

For lower anchorages conforming to

S4.2.2, at least one lower anchorage bar

is to be readily visible to the person

installing a child restraint. The vehicle

seat cushion or seat back shall include

markings or features to assist in the

correct lateral positioning of the child

restraint system as it is moved rearward

to engage the lower anchorages.

S4.6 Instructions.

The vehicle owner’s manual shall:

(a) Indicate the seating positions

equipped with a child restraint

anchorage system;

(b) Include instructions that provide a

step-by-step procedure, including

diagrams, for properly attaching a child

restraint system to a vehicle anchorage

system equipped with lower anchorages

conforming to the requirements of

S4.2.1 (with or without use of a

connector); and,

(c) Include instructions for properly

installing a child restraint system in a

vehicle anchorage system equipped

with lower anchorages conforming to

the requirements of S4.2.2, if the vehicle

is equipped with such anchorages.

S5 Test procedures.

S5.1 Lower anchorages.

Test each lower anchorage separately,

with or without connectors provided

with the vehicle. Apply a force of 5,300

N to each anchorage in the forward

horizontal direction parallel to the

vehicle’s longitudinal axis. Apply the

force by means of a belt strap that

extends at least 250 mm forward of the

seat bight. The belt is fitted at one end

with hardware for applying the force,

and at the other end with hardware that

attaches to an anchorage or connector.

Apply force to the belt strap so that the

5,300 N force is attained within 30

seconds, with an onset force rate not

exceeding 135,000 N per second, and is

maintained at the 5,300 N level for at

least 10 seconds.

S5.2 Tether anchorage.

Tether anchorages are tested

according to the procedures specified in

49 CFR 571.210b, ‘‘Tether anchorages

for child restraint systems.’

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Figure 1—Child Restraint Apparatus-Isometric
7880 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

Figure 2a—Child Restraint Apparatus Anchorages Front View
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Figure 2b—Child Restraint Apparatus Anchorages Side and Plan View
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7884 Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules

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3. Section 571.210b would be added

to read as follows:

§ 571.210b Standard No. 210b; Tether

anchorages for child restraint systems

S1. Purpose and scope. This standard

establishes requirements for the strength

and location of tether anchorages to

ensure proper anchoring of child

restraint systems.

S2. Application. This standard

applies to tether anchorages installed in

passenger cars manufactured on or after

September 1, 1999, and in multipurpose

passenger vehicles, trucks and buses

manufactured on or after September 1,

2000.

S3. Definitions.

Tether anchorage means any

component that transfers loads from

tether anchorage hardware to the

vehicle structure.

Tether anchorage hardware means

any component that transfers tether

strap loads to a tether anchorage and is

designed to accept a tether strap hook.

Tether strap means a device that is

fitted with a tether strap hook and

secured to the rigid structure of a child

restraint system and that transfers the

load from that system to the anchorage

hardware.

Tether strap hook means a device,

illustrated in Figure 11 of Standard No.

213 (49 CFR 571.213), used to attach a

tether strap to tether anchorage

hardware.

S4. Requirements. Each tether

anchorage shall meet the requirements

of this section.

S4.1 Configuration.

S4.1.1 Except as provided by S4.1.2,

each tether anchorage shall—

(a) Be equipped with tether anchorage

hardware that is easily accessible and

that permits the attachment of a tether

hook meeting the configuration and

geometry specified in Figure 11 of

Standard No. 213 (49 CFR 571.213) of

this section;

(b) Be located in accordance with S4.2

of this section; and

(c) Be sealed to prevent the entry of

exhaust fumes.

S4.2 Anchorage positioning

requirements.

S4.2.1 Passenger cars and

multipurpose passenger vehicles. The

vertical centerline of each tether

anchorage and each tether anchorage

hardware component shall be located

within the shaded zone shown in

Figures 2, 3, 4 and 8 of this standard,

with reference to the shoulder reference

point of a template described in section

3.1 of SAE Standard J826 (June 1992),

where

(a) The H-point of the template is

located at the unique Design H-point of

the seat, as defined in section 2.2.11.1

of SAE Recommended Practice J1100

(June 1993), at the full rearward and

downward position of the seat;

(b) The torso line of the template is at

the same angle from the vertical plane

as the seat back with the seat adjusted

to its full rearward and full downward

position and the seat back in its most

upright position; and,

(c) The template is positioned in the

vertical longitudinal plane that contains

the H-point of the template.

S4.2.2 Trucks and buses. Subject to

S4.3.2.1, the vertical centerline of each

tether anchorage and each tether

anchorage hardware in a truck or bus

shall be located within the shaded zone

shown in Figures 5, 6, 7, and 8 of this

standard, with reference to the H-point

of a template described in section 3.1 of

SAE Standard J826 (June 1992), where

(a) The H-point of the template is

located at the unique Design H-point of

the seat, as defined in section 2.2.11.1

of SAE Recommended Practice J1100

(June 1993), at the full rearward and

downward position of the seat;

(b) The torso line of the template is at

the same angle from the vertical plane

as the seat back with the seat adjusted

to its full rearward and full downward

position and the seat back in its most

upright position; and

(c) The template is positioned in the

vertical longitudinal plane that contains

the H-point of the template.

S4.3.2.1 The centerline of a tether

anchorage in a truck or bus may be

located outside the shaded zone referred

to in S4.3.2 if a routing device that is of

sufficient strength to withstand the

loads referred to in S4.4 is installed

within that shaded zone.

S4.4 Strength.

S4.4.1 If a tether anchorage is

installed for only one designated seating

position on a seat, the tether anchorage

with the tether anchorage hardware

installed shall, when tested in

accordance with S5, withstand a force of

5,300 N. There shall be no complete

separation or failure of any anchorage

component.

S4.4.2 If a tether anchorage is

installed for more than one designated

seating position on a bench seat, each

tether anchorage with the tether

anchorage hardware installed shall,

when tested in accordance with S5,

withstand the simultaneous application

of a force of 5,300 N to each assembly

of tether anchorage and tether anchorage

hardware. There shall be no complete

separation or failure of any anchorage

component.

S5 Test procedure.

With the seat adjusted to its full

rearward and full downward position

and the seat back in its most upright

position, attach a belt strap that extends

not less than 250 mm forward from the

vertical plane intersecting the seat bight

(the intersection of the surfaces of the

seat cushion and the seat back). The

strap is fitted at one end with hardware

for applying the force and at the other

end with a bracket for attachment to the

tether anchorage hardware and passes

over the top of the vehicle seat back as

shown in Figure 8 of this standard.

Apply a force of 5,300 N to each

anchorage in the forward horizontal

direction parallel to the vehicle’s

longitudinal axis. The 5,300 N force is

attained within 30 seconds, with an

onset force rate not exceeding 135,000 N

per second, and is maintained at the

5,300 N level for one second.

Figure 1—[Reserved]

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Figure 2—Side View, Tether Anchorage Location for Passenger Cars and Multi-Purpose Passenger Vehicles
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Figure 3—Rear View, Tether Anchorage Location for Passenger Cars and Multi-Purpose Passenger Vehicles
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Figure 4—Plan View, (R-Point Level), Tether Anchorage Location for Passenger Cars and Multi-Purpose Passenger

Vehicles
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Figure 5—Side View, Tether Anchorage Location for Trucks
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Figure 6—Rear View, Tether Anchorage Location for Trucks
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Figure 7—Plan View, (V-Point Level), Tether Anchorage Location for Trucks
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Figure 8—Three-Dimensional Schematic View for Tether Anchorage Location for Passenger Cars, Multi-Purpose Passenger

Vehicles and Trucks
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4. Section 571.213 would be amended

by:

a. adding to S4, in alphabetical order,

a definition of ‘‘child restraint

anchorage system,’’ ‘‘tether anchorage

hardware,’’ ‘‘tether strap,’’ and ‘‘tether

strap hook’’;

b. revising S5.1.3, S5.1.3.1, S5.3.1,

S5.3.2 and S5.6.1;

c. adding S5.9 and S5.10;

d. revising S6.1.1(a)(1), S6.1.1(c) and

S6.1.2(a)(1)(i);

e. adding S6.1.2(d)(1)(iii); and

f. revising Figure 1A and adding

figures 11 and 12.

The revised and added paragraphs

would read as follows:

§ 571.213 Standard No. 213; Child restraint

systems

* * * * *

S4. Definitions.

* * * * *

Child restraint anchorage system is

defined in S3 of FMVSS No. 210a (49

CFR 571.210a).

* * * * *

Tether anchorage hardware is defined

in S3 of FMVSS No. 210b (49 CFR

571.210b).

Tether strap means a device that is

fitted with a tether strap hook and

secured to the rigid structure of a child

restraint system and that transfers the

load from that system to the tether

anchorage hardware.

Tether strap hook means a device,

illustrated in Figure 11 of this standard,

used to attach a tether strap to tether

anchorage hardware.

* * * * *

S5.1.3 Occupant excursion. When

tested in accordance with S6.1 and the

requirements specified in this

paragraph, each child restraint system

shall meet the applicable excursion

limit requirements specified in S5.1.3.1

through S5.1.3.3.

S5.1.3.1 Child restraint systems

other than rear-facing ones and car

beds. Each forward-facing child restraint

system shall retain the test dummy’s

torso within the system.

(a) In the case of an add-on child

restraint system, no portion of the test

dummy’s head shall pass through a

vertical, transverse plane that is 720 mm

forward of point Z on the standard seat

assembly, measured along the center

SORL (as illustrated in figure 1B of this

standard), and neither knee pivot point

shall pass through a vertical, transverse

plane that is 915 mm forward of point

Z on the standard seat assembly,

measured along the center SORL, when

attached to the seat assembly as

described in S6.1.2(a)(1)(i)(A)(1).

(b) In the case of an add-on child

restraint system, no portion of the test

dummy’s head shall pass through a

vertical, transverse plane that is 813 mm

forward of point Z on the standard seat

assembly, measured along the center

SORL (as illustrated in figure 1B of this

standard), and neither knee pivot point

shall pass through a vertical, transverse

plane that is 915 mm forward of point

Z on the standard seat assembly,

measured along the center SORL, when

attached to the seat assembly as

described in S6.1.2(a)(1)(i)(A)(2) or

S6.1.2(a)(1)(B).

(c) In the case of a built-in child

restraint system, neither knee pivot

point shall, at any time during the

dynamic test, pass through a vertical,

transverse plane that is 305 mm forward

of the initial pre-test position of the

respective knee pivot point, measured

along a horizontal line that passes

through the knee pivot point and is

parallel to the vertical plane that passes

through the vehicle’s longitudinal

centerline.

* * * * *

S5.3 Installation.

S5.3.1 Except for components

designed to attach to a child restraint

anchorage system, each add-on child

restraint system shall have no means

designed for attaching the system to a

vehicle seat cushion or vehicle seat back

and no component (except belts) that is

designed to be inserted between the

vehicle seat cushion and vehicle seat

back.

S5.3.2 (a) When installed on a

vehicle seat, each add-on child restraint

system, other than a belt-positioning

seat, shall be capable of being restrained

against forward movement solely by

means of:

(1) A Type I seat belt assembly

(defined in § 571.209) that meets

Standard No. 208 (§ 571.208);

(2) A Type I seat belt assembly plus

a tether anchorage; and,

(3) A child restraint anchorage

system.

(b) Each belt-positioning seat shall be

capable of being restrained against

forward movement by means of a Type

II seat belt assembly (defined in

§ 571.209) that meets Standard No. 208

(§ 571.208).

* * * * *

S5.6.1 Add-on child restraint

systems.

Each add-on child restraint system

shall be accompanied by printed

installation instructions in English that

provide a step-by-step procedure,

including diagrams, for installing the

system in motor vehicles, securing the

system in the vehicles, positioning a

child in the system, and adjusting the

system to fit the child. If the child

restraint system has components for

attaching to a child restraint anchorage

system, installation instructions shall be

included that provide a step-by-step

procedure, including diagrams, for

properly attaching a child restraint

system to a vehicle anchorage system

equipped with lower anchorages

conforming to the requirements of

S4.2.1 of Standard No. 210a (49 CFR

§ 571.210a). In addition, if the child

restraint is equipped with components

that attach to a vehicle anchorage

system equipped with lower anchorages

conforming to the requirements of

S4.2.2 of Standard No. 210a,

instructions shall be provided for

properly installing a child restraint to

such an anchorage system.

* * * * *

S5.9 Attachment to child restraint

anchorage system.

(a) Each add-on child restraint system,

other than a belt-positioning seat, shall

have components permanently attached

to the system that securely fasten to the

latchplates conforming to S4.2.1 of

Standard No. 210a (49 CFR § 571.210a)

and depicted in Drawing Package ll

(consisting of drawings and a bill of

materials) with addendum A, revision

dated January 6, 1997, (incorporated by

reference; see § 571.5).

(b) In addition to the components

required by S5.9(a), each child restraint

system intended for use with lower

anchorages conforming to S4.2.2 of

Standard No. 210a (49 CFR § 571.210a)

shall have components of a

configuration depicted in Figure 12 of

this standard, in a location that enable

the child restraint to securely fasten to

the anchorages.

S5.10 Each tether strap on a child

restraint system must be equipped with

a tether strap hook that conforms to the

configuration and geometry specified in

Figure 11 of this standard.

* * * * *

S6.1.1 Test conditions.

(a) Test devices.

(1) The test device for add-on restraint

systems is a standard seat assembly

consisting of a simulated vehicle bench

seat, with three seating positions, which

is described in Drawing Package SAS–

100–1000 with Addendum A Revised

(consisting of drawings and a bill of

materials), dated December l, 1996

(incorporated by reference; see § 571.5).

The assembly is mounted on a dynamic

test platform so that the center SORL of

the seat is parallel to the direction of the

test platform travel and so that

movement between the base of the

assembly and the platform is prevented.

* * * * *
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(c)(1) Attached to the seat belt

anchorage points provided on the

standard seat assembly (illustrated in

Figures 1A and 1B of this standard) are

Type I seat belt assemblies in the case

of add-on child restraint systems other

than belt-positioning seats, or Type II

seat belt assemblies in the case of beltpositioning seats. These seat belt

assemblies meet the requirements of

Standard No. 209 (§ 571.209) and have

webbing with a width of not more than

50 mm, and are attached to the

anchorage points without the use of

retractors or reels of any kind.

(2) Attached to the standard seat

assembly is a child restraint anchorage

system conforming to Standard No. 210a

(§ 571.210a). The seat assembly is

equipped with lower anchorages that

conform to S4.2.1 and S4.2.2 of that

standard.

* * * * * *

S6.1.2 Dynamic test procedure.

(a) Activate the built-in child restraint

or attach the add-on child restraint to

the seat assembly as follows:

(1)(i) Test configuration I.

(A) Except for a belt-positioning seat,

an add-on child restraint system is

installed at the center seating position of

the standard seat assembly using either

the standard lap belt or the child seat

anchorage system—

(1) In accordance with the

manufacturer’s instructions provided

with the system pursuant to S5.6.1; or

(2) In accordance with the

manufacturer’s instructions, except that

the add-on restraint is secured to the

standard vehicle seat using only the

standard vehicle lap belt (except a child

harness, a backless child restraint

system with a top anchorage strap, and

a restraint designed for use by

physically handicapped children are not

subject to this paragraph.

(B) A belt-positioning seat is attached

to either outboard seating position of the

standard seat assembly in accordance

with the manufacturer’s instructions

provided with the system pursuant to

S5.6.1 using only the standard vehicle

lap and shoulder belt.

* * * * *

(d) * * *

(1) * * *

(iii) When attaching a child restraint

system to the child restraint anchorage

system on the standard seat assembly,

all belt systems used to attach the

restraint to the standard seat assembly

are tightened to a tension of not less

than 53.5 N and not more than 67 N, as

measured by a load cell used on the

webbing portion of the belt.

* * * * *

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Figure 11—Tether Strap Hook
Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / Proposed Rules 7897

Figure 12—Rigid Connector-Side View

Issued on February 13, 1997.

L. Robert Shelton,

Associate Administrator for Safety

Performance Standards.

[FR Doc. 97–4084 Filed 2–18–97; 8:45 am]

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