3744 Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 

DEPARTMENT OF TRANSPORTATION 

National Highway Traffic Safety 

Administration 

49 CFR Part 571 

[Docket No. NHTSA–2014–0123] 

RIN 2127–AL20 

Federal Motor Vehicle Safety 

Standards; Child Restraint Systems, 

Child Restraint Anchorage Systems; 

Incorporation by Reference 

AGENCY: National Highway Traffic 

Safety Administration (NHTSA), 

Department of Transportation (DOT). 

ACTION: Notice of proposed rulemaking 

(NPRM); request for comments. 

SUMMARY: In accordance with NHTSA’s 

2011–2013 Priority Plan and the Moving 

Ahead for Progress in the 21st Century 

Act (MAP–21), this document proposes 

to amend Federal Motor Vehicle Safety 

Standard (FMVSS) No. 225, ‘‘Child 

restraint anchorage systems,’’ to 

improve the ease of use of the lower 

anchorages of child restraint anchorage 

systems and the ease of use of tether 

anchorages. This document also 

proposes changes to FMVSS No. 213, 

‘‘Child restraint systems,’’ to amend 

labeling and other requirements to 

improve the ease of use of child 

restraint systems with a vehicle 

anchorage system. This NPRM proposes 

rulemaking on these and other 

requirements to increase the correct use 

of child restraint anchorage systems and 

tether anchorages, and the correct use of 

child restraints, with the ultimate goal 

of reducing injuries to restrained 

children in motor vehicle crashes. 

DATES: Comments must be received on 

or before March 24, 2015. 

Proposed compliance date: We 

propose that the compliance date for the 

amendments in this rulemaking action 

would be three years following the date 

of publication of the final rule in the 

Federal Register. We propose to permit 

optional early compliance with the 

amended requirements. 

ADDRESSES: You may submit comments 

to the docket number identified in the 

heading of this document by any of the 

following methods: 

• Federal eRulemaking Portal: Go to 

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

online instructions for submitting 

comments. 

• Mail: Docket Management Facility, 

M–30, U.S. Department of 

Transportation, West Building, Ground 

Floor, Rm. W12–140, 1200 New Jersey 

Avenue SE., Washington, DC 20590. 

• Hand Delivery or Courier: West 

Building Ground Floor, Room W12–140, 

1200 New Jersey Avenue SE., between 

9 a.m. and 5 p.m. Eastern Time, Monday 

through Friday, except Federal holidays. 

• Fax: (202) 493–2251. 

Regardless of how you submit your 

comments, please mention the docket 

number of this document. 

You may also call the Docket at 202– 

366–9324. 

Instructions: For detailed instructions 

on submitting comments and additional 

information on the rulemaking process, 

see the Public Participation heading of 

the Supplementary Information section 

of this document. Note that all 

comments received will be posted 

without change to http://

www.regulations.gov, including any 

personal information provided. 

Privacy Act: Please see the Privacy 

Act heading under Rulemaking 

Analyses and Notices. 

FOR FURTHER INFORMATION CONTACT: For 

technical issues, you may call Cristina 

Echemendia, Office of Crashworthiness 

Standards (telephone: 202–366–6345) 

(fax: 202–493–2990). For legal issues, 

you may call Deirdre Fujita, Office of 

Chief Counsel (telephone: 202–366– 

2992) (fax: 202–366–3820). Address: 

National Highway Traffic Safety 

Administration, U.S. Department of 

Transportation, 1200 New Jersey 

Avenue SE., West Building, 

Washington, DC 20590. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Executive Summary 

II. Statutory Mandate 

III. Efforts To Improve Vehicle/Child 

Restraint Compatibility and Ease of Use 

of Child Restraint Anchorage Systems 

a. ISO Rating System 

b. SAE Guidelines 

c. NCAP Vehicle-CRS Fit Program 

d. UMTRI’s LATCH Usability Study 

1. Overview of the Study 

2. Three Seat Characteristics Were Well 

Correlated With Correct Use 

A. Clearance Angle 

B. Attachment Force 

C. Anchorage Depth 

IV. UMTRI’s Assessment of the ISO, SAE, 

and NCAP Programs 

V. NHTSA’s Preference Is the UMTRI 

Approach 

VI. Proposal To Improve Lower Anchorage 

Usability 

a. Clearance Angle 

b. Attachment Force 

c. Anchorage Depth 

d. Estimated Rate of Current Compliance 

VII. Proposal To Improve Tether Anchorage 

Usability 

a. Limit the Zone 

b. Anchorage Must Be Accessible 

c. Standardized Configuration 

d. Clearance Around the Tether Anchorage 

VIII. Conspicuity and Identification of 

Anchorages 

a. Marking Lower Anchorages 

b. Marking Tether Anchorages 

IX. Conspicuity and Identification of CRS 

Connectors 

a. Lower Anchorage Connectors 

b. Tether Hook 

X. Request for Comments 

a. Center Rear Seat 

b. Third Row 

c. Vehicles Currently Excluded From 

FMVSS No. 225 

d. Written Instructions 

1. Terminology 

2. Recommendation for Tether Anchor Use 

XI. Proposed Effective Date 

XII. Regulatory Notices and Analyses 

XIII. Public Participation 

I. Executive Summary 

Introduction 

In accordance with NHTSA’s 2011– 

2013 Priority Plan and Subtitle E of 

MAP–21, this document proposes to 

amend FMVSS No. 225 to improve the 

ease of use of child restraint anchorage 

systems. First, we propose to amend 

FMVSS No. 225 to adopt requirements 

that would make it easier for consumers 

to attach child restraints to the lower 

anchorages of child restraint anchorage 

systems. The requirements would 

ensure that vehicle manufacturers 

produce lower anchorages that: (a) Have 

sufficient clearance around each lower 

anchorage for consumers to maneuver 

the child restraint system (CRS) 

connector; (b) are located such that the 

CRS connector can be attached to the 

bar using a reasonable amount of force; 

and, (c) are within two centimeters (cm) 

of the outer surface of the ‘‘seat bight’’ 

(the seat bight is approximately the 

intersection of the seat bottom cushion 

and seat back cushion). 

Second, we propose to make tether 

anchorages easier to use by 

standardizing the configuration of the 

anchorage such that it is ‘‘a rigid bar of 

any cross section shape,’’ by prohibiting 

the anchorages from being placed under 

a vehicle seat or hidden under carpet, 

and by requiring them to be placed 

where there is enough space around the 

anchorage for consumers to tighten the 

tether strap. 

Third, this document proposes to 

amend FMVSS No. 225 and FMVSS No. 

213 to require, among other things, 

vehicles and CRSs to use a standardized 

symbol to more effectively identify the 

anchorages in the vehicle and the 

components on CRSs that attach to 

those anchorages. 

In addition, this document requests 

comments on several issues relating to 

the usability of child restraint anchorage 

systems. We request comment on 

whether child restraint anchorage 


emcdonald on DSK67QTVN1PROD with PROPOSALS2
Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 3745 

1 49 CFR 571.225. 

2Specifically, trucks and MPVs with a gross 

vehicle weight rating (GVWR) of 3,855 kilograms 

(kg) (8,500 pounds (lb)) or less, and to buses with 

a GVWR of 4,536 kg (10,000 lb) or less. 

3 49 CFR 571.213, sections S5.3.2, S5.9. Excepted 

from the requirement were booster seats, car beds, 

and harnesses. 

4Additionally, Standard No. 213 requires all 

CRSs to be capable of attachment to the vehicle seat 

by a seat belt, even if the CRS has lower anchorage 

connectors. 

5Many in the child passenger safety community 

refer to the child restraint anchorage system as the 

‘‘LATCH’’ system, an abbreviation of the phrase 

‘‘Lower Anchors and Tethers for Children.’’ The 

term was developed by a group of manufacturers 

and retailers soon after the 1999 final rule, for use 

in educating consumers on the availability and use 

of the anchorage system and for marketing 

purposes. ‘‘LATCH’’ has been used in various 

materials in the field and by NHTSA to refer to the 

vehicle 3-point child restraint anchorage system, 

but at times the term has been used to refer just to 

the lower two anchorages of the system, and at 

times it has been used to refer to the connectors of 

the child restraint system that attach to the lower 

anchorages. Also, apparently a number of 

consumers identify the tether anchorage solely with 

the ‘‘LATCH’’ system, and so mistakenly do not 

attach the CRS’s tether strap when using the vehicle 

belt system to attach a child restraint. Because some 

ambiguity has developed with the use of the term 

‘‘LATCH,’’ we generally avoid using the term 

‘‘LATCH’’ in this NPRM when possible. 

6 Decina, L., et al., ‘‘Child Restraint Use Survey: 

LATCH Use and Misuse,’’ December 2006, (‘‘Decina 

study’’), DOT HS 810 679, Docket No. NHTSA– 

2006–26735. The Decina study is summarized in 

Appendix A to this preamble. 

7 Id. 

8 Docket No. NHTSA–07–26833. A summary of 

the public meeting can be found in Appendix B to 

this preamble. 

9http://www.nhtsa.gov/staticfiles/rulemaking/

pdf/2011-2013_Vehicle_Safety-Fuel_Economy_

Rulemaking-Research_Priority_Plan.pdf 

10The agency addressed the issue of the weight 

limit of the lower anchorages by a new labeling 

requirement that informs consumers of the load 

limits of the child restraint anchorage system. See 

77 FR 11626, February 27, 2012; response to 

petition for reconsideration, 79 FR 10396, February 

25, 2014. NHTSA originally designed the child 

restraint anchorage systems to be strong enough to 

withstand crash forces generated by a 29.5 kg (65 

lb) mass (the mass would be from the child restraint 

plus the restrained child). Child restraint systems 

and the children for whom many of them are 

designed have become heavier over the years. To 

ensure the lower anchorages are strong enough to 

hold the CRS plus child in serious and severe 

crashes, NHTSA adopted a labeling requirement 

applying to child restraints which, together with the 

restrained child, would impose a combined weight 

over 29.5 kg (65 lb) on the lower anchorages. These 

CRSs must have a label informing consumers to use 

the seat belt system instead of the lower anchorages 

to attach the child restraint to the vehicle seat once 

the combined weight exceeds 29.5 kg (65 lb). 

systems and/or tether anchorages 

should be required in more rear seating 

positions than currently required, 

including in vehicles now excluded 

from FMVSS No. 225. We also request 

comment on the merits of requiring 

vehicle and CRS manufacturers to use 

standardized terminology in users’ 

manuals in describing components of 

the child restraint anchorage system and 

the connectors of child restraint 

systems, to enhance consumer 

education and increase correct use of 

child restraint anchorage systems and 

child restraints. Finally, test data 

indicate that tether anchorages are 

sufficiently robust to provide crash 

protection to virtually all children 

restrained in a harnessed child restraint. 

We request comment on the merits of 

consumer information that advises 

consumers to attach the tether when 

restraining a child in a harnessed child 

restraint, regardless of the weight of the 

child. 

Background 

In 1999, NHTSA issued FMVSS No. 

225,1 a standard that requires vehicle 

manufacturers to equip vehicles with 

child restraint anchorage systems that 

are standardized and independent of the 

vehicle seat belts. The child restraint 

anchorage system required by FMVSS 

No. 225 is a 3-point system consisting 

of two lower anchorages and a tether 

anchorage designed for attaching a child 

restraint system to a vehicle. Each lower 

anchorage consists of a six millimeter 

(mm) diameter straight rod, or ‘‘bar,’’ 

onto which a CRS connector can be 

attached. The two lower anchorage bars 

are typically located at or near the seat 

bight in a position where they will not 

be felt by seated adult occupants. The 

tether anchorage is a part to which a 

tether hook of a CRS can be attached. 

Standard No. 225 requires vehicles with 

three or more forward-facing rear 

seating positions to be equipped with 

child restraint anchorage systems at not 

fewer than two rear seating positions 

and a tether anchorage at an additional 

rear seating position. That third tether 

anchorage can be used when installing 

a CRS with the vehicle’s seat belt. The 

requirements of FMVSS No. 225 were 

phased into new vehicles from 1999 to 

2002 beginning with the tether 

anchorage in passenger cars in 1999, 

and ending with full implementation of 

FMVSS No. 225 for passenger cars, 

multipurpose passenger vehicles 

(MPVs), and trucks and buses 2 on 

September 1, 2002. 

The 1999 rule also amended FMVSS 

No. 213 to require CRSs to be equipped 

with connectors that enable the CRS to 

attach to the vehicle’s lower anchorages 

of the child restraint anchorage 

system.3 4 A new head excursion 

performance requirement was added for 

forward-facing child restraints (other 

than booster seats), and to meet it, child 

restraints typically use a tether strap 

affixed to the top of the restraints. The 

tether strap must have a hook that is 

designed to attach to the tether 

anchorage of the child restraint 

anchorage system (see S5.9(b) of FMVSS 

No. 213). 

In this NPRM we use the following 

term for the full vehicle system: ‘‘Child 

restraint anchorage system.’’ 5 We use 

the following for the lower anchorage 

points of a child restraint anchorage 

system: ‘‘Lower anchorage(s).’’ The 

tether securement point is called a 

‘‘tether anchorage.’’ For the CRS, we use 

the following terms to refer to the 

various parts of a child restraint that 

connect to the child restraint anchorage 

system, as appropriate: ‘‘Child restraint 

system connectors (or CRS connectors),’’ 

‘‘lower anchorage connector(s),’’ ‘‘tether 

anchorage connector,’’ ‘‘tether strap,’’ 

and ‘‘tether hook.’’ 

Developments Post-1999 Final Rule 

Child restraint anchorage systems 

meeting FMVSS No. 225, and child 

restraints meeting the associated 

requirements of FMVSS No. 213, have 

been successfully implemented in the 

fleet. Consumers who use the system 

generally like the system.6 However, 

many consumers do not use child 

restraint anchorage systems because 

they do not know enough about the 

systems.7 Many consumers also misuse 

the child restraint anchorage system or 

find aspects of it difficult to use. 

In 2007, NHTSA held a public 

meeting on child restraint anchorage 

systems to see how the systems could be 

improved.8 There were repeated 

comments at the meeting that the lower 

anchorages often were embedded deep 

into the seat bight, making it difficult for 

consumers to reach the lower 

anchorages and attach the lower 

anchorage connectors. There were also 

complaints that it was difficult to attach 

lower anchorage connectors to the lower 

anchorages because of surrounding stiff 

cushions or fabric/leather or the 

proximity of seat belt buckles. 

Following the 2007 meeting, the 

agency identified improving the ease of 

use of child restraint anchorage systems 

as an area of significance to NHTSA. 

NHTSA announced in the NHTSA 

Vehicle Safety and Fuel Economy 

Rulemaking and Research Priority Plan 

2011–2013 (March 2011) (‘‘2011 Priority 

Plan’’) 9 that the agency is addressing 

issues to improve the usability of child 

restraint anchorage systems and may 

initiate rulemaking on issues relating to 

the presence of anchorage systems in 

center rear seats, tether anchorage 

locations, weight limits of anchorages,10

and labeling of the anchorage locations. 


emcdonald on DSK67QTVN1PROD with PROPOSALS2
3746 Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 

11 Klinich et al., ‘‘LATCH Usability in Vehicles,’’ 

UMTRI–2012–7, April 2012. Link: http://

deepblue.lib.umich.edu/handle/2027.42/90856. The 

report was sponsored by the Insurance Institute for 

Highway Safety (IIHS) for developing IIHS’s rating 

of the usability of the child restraint anchorage 

systems in various vehicles. See IIHS Status Report: 

Vol. 47 No. 3, April 12, 2012. 

The ease of use of child restraint 

anchorage systems is inherently 

challenging because the vehicle is 

manufactured by one party and the 

child restraint is manufactured by 

another. The vehicle seat is designed 

with occupant comfort and safety in 

mind, along with aesthetics; child 

restraint compatibility can be difficult to 

plan for given the wide and constantly 

changing array of child restraints. 

Through usability requirements adopted 

in the 1999 final rule, we improved the 

interface between the vehicle anchorage 

system and the child restraint. Yet, our 

improvements for the vehicle side 

focused on standardizing the parameters 

of the 3-point anchorage system and 

specifying where the anchorage system 

should be positioned overall in a 

vehicle and relative to a ‘‘child restraint 

fixture’’ (CRF) test device to optimize 

ease of use. Although the 1999 final rule 

recognized the importance of having the 

lower anchorages visible or marked with 

an emblem signaling the presence and 

location of the anchorages, the final rule 

was the first undertaking by any country 

to establish a universal child restraint 

anchorage system independent of the 

vehicle belts. Thus, in making the first 

step toward standardizing a child 

restraint anchorage system, the agency 

only partially standardized the marking, 

and did not regulate features of the 

vehicle seat relating to cushion stiffness 

and other characteristics of the vehicle 

seat. For similar reasons, NHTSA 

refrained from standardizing CRS 

features that might affect compatibility, 

such as CRS size and mass. 

New Information Improving Anchorage 

Systems 

New information from the University 

of Michigan Transportation Research 

Institute (UMTRI) has identified 

characteristics of the vehicle seat that 

UMTRI has found to enhance the 

usability of child restraint anchorage 

systems. In April 2012, UMTRI 

published a study 11 titled, ‘‘LATCH 

Usability in Vehicles’’ (hereinafter 

‘‘LATCH Usability study’’), that 

identified vehicle seat characteristics 

shown to affect the quality of child 

restraint installations. UMTRI found 

that the correct use of lower anchorages 

was associated with the following 

features: 

• ‘‘Clearance angle’’ greater than 54 

degrees (clearance angle relates to the 

clearance around a lower anchorage 

from interfering parts that can make it 

difficult to maneuver the CRS lower 

anchorage connector); 

• ‘‘attachment force’’ of 178 Newtons 

(N) (40 pounds (lb)) or less (attachment 

force is the amount of force needed to 

attach a lower anchorage connector); 

and, 

• ‘‘anchorage depth’’ (location of the 

anchorage within the seat bight) of less 

than 2 centimeters (cm). 

Further, improved designs in 

anchorage markings have been 

developed by the International 

Standardization Organization (ISO) that 

can better communicate to the consumer 

the location and presence of the lower 

anchorages and tether anchorage, and 

further harmonize the safety standard 

with those of other countries. 

Today’s NPRM uses the information 

from UMTRI and ISO to propose 

enhancements to the usability 

requirements in FMVSS No. 225. 

Overview of Proposal 

Our ease of use improvements focus 

on reducing the physical effort needed 

to attach a child restraint to the lower 

anchorages and to the tether anchorage, 

and on improving how easily the 

anchorages can be correctly identified 

and accessed by a consumer. 

Ease of Using Lower Anchorages 

FMVSS No. 225’s current location 

requirements for the lower anchorage 

bars intend for the bars to be accessible, 

but some consumers find it difficult to 

use the bars. We propose new 

requirements for the bars to improve 

ease of use: a minimum clearance angle 

of 54 degrees, a maximum attachment 

force of 178 N (40 lb), and a location 

limit of less than 2 cm within the seat 

bight. These are the ease of use 

specifications the UMTRI LATCH 

Usability study found to correlate with 

correct child restraint installation by 

test subjects. 

Ease of Using Tether Anchorages 

Standard No. 225 currently requires 

vehicle manufacturers to equip vehicles 

with a tether anchorage at three rear 

designated seating positions (two of 

these positions are also required to be 

equipped with lower anchorages) that 

enables the attachment of a 

standardized tether hook. The standard 

currently requires tether anchorages to 

be located in a specified zone and to be 

accessible without the need for any 

tools other than a screwdriver or coin. 

To improve the usability of the tether 

anchorage, we propose the following 

requirements to make it easier for 

consumers to recognize and reach the 

anchorage. 

• We propose to amend FMVSS No. 

225 to reduce the zone in which a tether 

anchorage must be located, to prevent 

tether anchorages from being placed 

deep under a vehicle seat. 

• We propose to require tether 

anchorages to be accessible without the 

need for any tools and without folding 

the seat back or removing carpet or 

other vehicle components. (The tether 

anchorage may be covered with a cap, 

flap or cover, provided that the cap, flap 

or cover is specifically designed to be 

opened, moved aside or to otherwise 

give access to the anchorage without the 

use of any tools and is labeled with a 

specific symbol indicting the presence 

of the tether anchorage underneath.) 

• Almost all tether anchorages are 

rigid metal bars, but there are a few 

made from flexible webbing, which 

confuses some consumers who are 

looking for a bar. We propose amending 

FMVSS No. 225 to require the tether 

anchorage to be a rigid bar. 

• Some tether anchorages are too 

close to a structure, such as a head 

restraint, to allow tightening of the 

tether strap. We propose to specify a 

minimum 165 mm (6.5 in) distance from 

a reference point on the vehicle seat to 

the tether anchorage so that adequate 

clearance will be provided for 

tightening of the tether strap. We also 

propose amending FMVSS No. 213 to 

limit the length of the CRS tether 

hardware assembly (which consists of a 

tether hook and hardware to tighten and 

loosen the tether strap) to 165 mm (6.5 

in) so that the tightening mechanism 

can be easily used in the newlyspecified clearance space around a 

tether anchorage. 

Enhanced Ability To Identify 

Anchorages 

Standard No. 225 currently requires 

the lower anchorage bars either to be 

visible or the vehicle seat back marked 

showing the location of the bars. To 

improve consumers’ ability to find and 

use lower anchorages, we propose 

amending FMVSS No. 225 to require 

motor vehicles to be marked with the 

ISO-developed mark near the location of 

each lower anchorage bar, even if the 

lower anchorage is visible. Similarly, we 

propose requiring each tether anchorage 

to be marked with the ISO-developed 

mark for tether anchorages. In addition, 

we propose amending FMVSS No. 213 

to require the ISO mark on the lower 

anchorage connectors (the components 

on the child restraint system that attach 

the child restraint to the lower 

anchorages of a child restraint 


emcdonald on DSK67QTVN1PROD with PROPOSALS2
Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 3747 

12NHTSA is planning to develop new simplified 

education and consumer information programs 

building on the requirements proposed in this 

NPRM. Education efforts and consumer information 

programs would be developed to teach consumers 

to look for the ISO-developed marks in the vehicle 

to locate the lower anchorages and tether 

anchorages in their vehicles and to ‘‘match’’ them 

to the ISO marks on the CRS. 

13 ‘‘Child Restraint Use Survey: LATCH Use and 

Misuse,’’ supra. 

14Field data show that use of child restraint 

anchorage systems has noticeably increased since 

2006. National Child Restraint Use Special Study 

(NCRUSS), DOT HS 811 679, http://wwwnrd.nhtsa.dot.gov/Pubs/811679.pdf, and ‘‘A Look 

Inside American Family Vehicles 2009–2010,’’ Safe 

Kids USA (http://www.safekids.org/assets/docs/

safety-basics/safety-tips-by-risk-area/sk-car-seatreport-2011.pdf). These data are discussed in 

Appendix A of this preamble. 

15See § 31502(b)(2). That section also specifies 

that in such case that an amendment does not meet 

the requirements and considerations of § 30111(a) 

and (b) of title 49, United States Code, the Secretary 

shall submit a report to Congress describing the 

reasons for not prescribing such a standard. 

[Footnote added.] 

16Another exception is in § 31505, which 

specifies that if the Secretary determines that any 

deadline for issuing a final rule under this Act 

cannot be met, the Secretary shall provide Congress 

with an explanation for why such deadline cannot 

be met and establish a new deadline for that rule. 

[Footnote added.] 

anchorage system) and on the tether 

hook.12 We also propose to require 

vehicle manufacturers to provide 

written information (e.g., in vehicle 

owners’ manuals) explaining the 

meaning of the ISO lower anchorage bar 

and tether anchorage markings, and to 

require child restraint manufacturers to 

explain (in the CRS user’s manual) the 

meaning of the ISO mark on the lower 

anchorage connectors and tether hook. 

Rulemaking Goal 

The 2005 Decina study 13 found that 

many consumers did not know what 

child restraint anchorage systems were, 

that anchorages were available in the 

vehicle, the importance of using the 

anchorages or how to use them 

properly. We believe that as the 

requirements proposed today make the 

anchorages more conspicuous and more 

clearly marked, awareness should 

improve. With improved awareness, 

more consumers will likely attempt to 

use the anchorage system.14

The Decina study found that users 

who attempted to use child restraint 

anchorage systems generally liked the 

systems. Drivers with experience 

attaching a CRS using a child restraint 

anchorage system and using a vehicle 

seat belt strongly preferred using the 

lower anchorages over the seat belts. 

Moreover, the study also found that 

consumers were more likely to install a 

CRS correctly using a child restraint 

anchorage system than when a seat belt 

was used. NHTSA believes that as 

consumers’ awareness of child restraint 

anchorage systems increases, more 

consumers will try them and more will 

use them. If the systems can be made 

easier to use, more consumers will like 

and regularly use the system compared 

to current usage. 

UMTRI’s LATCH Usability study 

found that test subjects who correctly 

used the lower anchorage hardware 

were 3.3 times more likely to achieve a 

tight CRS installation than subjects who 

made errors using the hardware. Thus, 

we believe that if child restraint 

anchorage systems can be made easier to 

use correctly, more consumers will 

achieve a tight fit of the CRS in the 

vehicle. The tight fit of the CRS will 

lead to reduced child head and torso 

excursions in motor vehicle crashes, 

and fewer child head and torso injuries 

in crashes. 

Estimated Costs and Benefits 

The agency estimates that the 

proposed requirements for improved 

usability of child restraint anchorage 

systems would not result in any 

increase in material cost, but would 

entail some redesign of vehicle seat 

features. Approximately 79 percent of 

vehicles would need some redesign to 

meet the proposed lower anchorage 

usability requirements. Some tether 

anchorages would have to be 

repositioned further from the head 

restraint to meet the minimum strap 

wrap-around distance requirement. A 

small number of vehicles that currently 

have webbing loops for tether 

anchorages would need to be changed to 

have rigid anchorage bars. The agency 

believes that these design modification 

are minor and mainly concern the 

vehicle seat and not the vehicle 

structure. NHTSA is proposing a 3-year 

lead time for complying with a final 

rule, which, we believe, would provide 

sufficient time for vehicle 

manufacturers to accommodate any 

redesign of the vehicle seat in their 

normal course of manufacture without a 

cost increase. 

For child restraints, we estimate that 

approximately 30 percent of forwardfacing child restraints may need to have 

minor modification made to the tether 

hardware assembly to meet the 165 mm 

(6.5 in) maximum length requirement. 

We are proposing a 3-year lead time to 

meet the requirement. 

The proposal requires all the lower 

anchorages and tether anchorages to be 

marked with the ISO mark. We estimate 

the cost of ISO marks for a set of lower 

anchorages to be $0.05 and that for the 

tether anchorage to be $0.025. The total 

incremental cost of equipping all child 

restraint anchorage systems with 

appropriate ISO marks is about $0.58 

million. The proposal also requires 

similar ISO marks on child restraint 

anchorage connectors, for which the 

agency estimates an incremental cost of 

$0.74 million. The cost of changing the 

written instructions accompanying the 

vehicle or the CRS to explain the ISO 

markings is expected to be negligible 

(<<$0.01). Therefore, the total cost of 

the proposed rule is estimated to be 

$1.32 million. 

We believe that the new usability 

requirements would improve correct 

(tight) installation, and increase tether 

use. If there were a 5 percent increase 

in correct installation using the lower 

anchors and a 5 percent increase in 

tether use, the agency estimates that the 

proposed requirements would save 

approximately 3 lives and prevent 6 

moderate to higher severity injuries. 

II. Statutory Mandate 

MAP–21 (Pub. L. 112–141) 

incorporates Subtitle E, ‘‘Child Safety 

Standards.’’ Subtitle E, § 31502(a), 

requires that not later than 1 year after 

the date of enactment of the Act, the 

Secretary shall initiate a rulemaking 

proceeding to amend FMVSS No. 225 

‘‘to improve the ease of use for lower 

anchorages and tethers in all rear seat 

seating positions if such anchorages and 

tethers are feasible.’’ Section 31502(b)(1) 

of MAP–21 states that, subject to 

exceptions, the Secretary must issue a 

final rule not later than 3 years after the 

date of enactment of MAP–21. An 

exception is for an amendment to 

Standard No. 225 which ‘‘does not meet 

the requirements and considerations set 

forth in subsections (a) and (b) of 

section 30111 of title 49, United States 

Code [the National Traffic and Motor 

Vehicle Safety Act (Vehicle Safety 

Act)].’’ 15 16

The agency has interpreted § 31502(a) 

as directing DOT to initiate rulemaking 

to improve the ease of use of lower 

anchorages and tether anchorages 

currently required by FMVSS No. 225 if 

improved anchorages are feasible. This 

interpretation is based on the plain 

meaning of the phrase ‘‘improve the 

ease of use.’’ We interpret ‘‘improve’’ to 

mean to enhance or increase the ease of 

use of prevailing FMVSS No. 225 lower 

anchorages and tether anchorages, 

which, in passenger cars and small 

MPVs, are present ‘‘in all rear seat 

seating positions.’’ Our 2011 Priority 

Plan took this approach in focusing on 

improving current tether anchorage 

locations and labeling of anchorage 

locations. This NPRM satisfies the 

mandate by proposing requirements that 

would improve the ease with which 


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17 § 31502(b)(2). 

18 ISOFIX is a system, mostly used in Europe, for 

the connection of child restraint systems to 

vehicles. The system has two vehicle rigid 

anchorages, two corresponding rigid attachments on 

the child restraint system and a means to limit the 

pitch rotation of the child restraint system. While 

the ISOFIX system is not used in the U.S., the 

system is very similar to the FMVSS No. 225 child 

restraint anchorage system and therefore, the 

evaluation developed by ISO is relevant to our work 

here. 

19 ‘‘Road vehicles—Methods and criteria for 

usability evaluation of child restraint systems and 

their interface with vehicle anchor systems—Part 1: 

Vehicles and child restraint systems equipped with 

ISOFIX anchors and attachments,’’ (November 

2010). 

20The SAE J2893 recommended practice is 

designated as a ‘‘work-in-progress’’ by SAE and has 

not been finalized. 

21 Klinich et al., supra. Link: http://

deepblue.lib.umich.edu/handle/2027.42/90856. The 

report was sponsored by the Insurance Institute for 

Highway Safety (IIHS) for developing IIHS’s rating 

of the usability of the child restraint anchorage 

systems in various vehicles. See IIHS Status Report: 

Vol. 47 No. 3, April 12, 2012. http://www.iihs.org/ 

sr/default.aspx. 

22The SAE J2893 Version 1—Draft 7 was used for 

the study. SAE J2893 is still under development. 

consumers can access and use the 

anchorages, and improve the visibility 

of the anchorages so that consumers can 

more easily identify them as parts of a 

child restraint anchorage system. 

Furthermore, this document also 

requests comment on whether 

additional lower anchorages and tether 

anchorages should be required in 

vehicles. We request comment on the 

need for, and feasibility of, additional 

child restraint anchorage systems and 

tether anchorages in rear seating 

positions, particularly in the third row 

of vehicles with three rows of seating. 

We also request comments on the merits 

and feasibility of installing lower 

anchorages and tether anchorages in 

vehicles now excluded from 

requirements to provide such 

anchorages. 

Section 31502 gives us discretion in 

determining whether a final rule in this 

rulemaking is warranted. We anticipate 

issuing a final rule unless an 

amendment ‘‘does not meet the 

requirements and considerations set 

forth in subsections (a) and (b) of 

section 30111 of title 49, United States 

Code.’’ 17 The requirements and 

considerations of §§ 30111(a) and (b) 

apply to NHTSA’s FMVSS rulemaking 

under the Vehicle Safety Act. Under 

§ 30111(a), the Secretary is authorized to 

prescribe FMVSSs that are practicable, 

meet the need for motor vehicle safety, 

and are stated in objective terms. 

‘‘Motor vehicle safety’’ is defined in the 

Vehicle Safety Act as ‘‘the performance 

of a motor vehicle or motor vehicle 

equipment in a way that protects the 

public against unreasonable risk of 

accidents occurring because of the 

design, construction, or performance of 

a motor vehicle, and against 

unreasonable risk of death or injury in 

an accident, and includes 

nonoperational safety of a motor 

vehicle.’’ Under § 30111(b) of the 

Vehicle Safety Act, when prescribing 

such standards, the Secretary must 

consider relevant available motor 

vehicle safety information, consult with 

appropriate agencies, consider whether 

a standard is reasonable, practicable, 

and appropriate for the particular type 

of motor vehicle or motor vehicle 

equipment for which it is prescribed, 

and consider the extent to which the 

standard will further the statutory 

purpose of reducing traffic accidents 

and deaths and injuries resulting from 

traffic accidents. We understand MAP– 

21 as directing us to determine, after 

initiating rulemaking, whether the 

changes under consideration to FMVSS 

No. 225 meet the requirements and 

considerations set forth in subsections 

(a) and (b) of 49 U.S.C § 30111 and are 

feasible. We will make a decision about 

a final rule after that assessment. 

III. Efforts To Improve Vehicle/Child 

Restraint Compatibility and Ease of Use 

of Child Restraint Anchorage Systems 

Following issuance of FMVSS No. 

225, there have been several efforts to 

improve the compatibility of child 

restraint anchorage systems and CRSs, 

and the ease of using the systems. 

a. ISO Rating System 

ISO developed a rating system and 

criteria to provide child restraint and 

vehicle manufacturers tools for the 

assessment of the usability of ISOFIX 18

systems.19 The ISO approach evaluates 

and rates the usability of a CRS’s 

ISOFIX features, a vehicle’s ISOFIX 

system, and the interaction between the 

two. ISO also provides consumers 

(parents and caregivers) with 

information to assist them in selecting a 

CRS and vehicle with ISOFIX systems 

that are easy to use, with the aim that 

the information will result in more 

correct installations. (More information 

about the ISO draft standard is in 

Appendix C to this preamble.) 

b. SAE Guidelines 

The Society of Automotive Engineers 

(SAE) developed a draft SAE 

recommended practice entitled J2893, 

‘‘Guidelines for Implementation of the 

Child Restraint Anchorage System in 

Motor Vehicles and Child Restraint 

Systems.’’ 20 The document provides 

guidelines for vehicle manufacturers to 

consider when designing characteristics 

of vehicle lower and upper (tether) 

anchorages, and for CRS manufacturers 

for corresponding features of CRS lower 

anchorage and tether connectors, so that 

each product can be made more 

compatible with the other. SAE 

developed tools and procedures for 

evaluating the child restraint anchorage 

system hardware features in vehicles 

and on child restraints. The guidelines 

assess whether the child restraint fixture 

can attach to the lower anchorages, the 

force and clearance angles needed to 

attach to the lower anchorages, the 

collinearity of the lower anchorages, the 

marking of the anchorages with the ISO 

symbol, etc. (Appendix C to this 

preamble has more information about 

the SAE guidelines.) 

c. NCAP Vehicle-CRS Fit Program 

On February 25, 2011, NHTSA 

published a Federal Register document 

requesting comment on the agency’s 

plan to establish a new consumer 

information program, as part of the 

agency’s New Car Assessment Program 

(NCAP), to improve compatibility 

between vehicles and child restraint 

systems and the ease of using the 

systems. The contemplated program 

involves vehicle manufacturers 

voluntarily providing NHTSA 

information about which CRSs fit in 

specific vehicle models, and NHTSA, in 

turn, posting this information on the 

NCAP Web site for consumers to use 

when making purchasing decisions. 

This ‘‘Vehicle-CRS Fit program,’’ still 

under consideration by NHTSA, is 

described in more detail in Appendix C 

of this preamble. 

d. UMTRI’s LATCH Usability Study 

1. Overview of the Study 

In 2012, UMTRI published a report 

entitled, ‘‘LATCH Usability in 

Vehicles,’’ 21 describing UMTRI’s study 

to identify characteristics of child 

restraint anchorage systems that make 

the anchorage system easier to use. The 

study was conducted in three phases, 

the objectives of which were to: 

• Survey model year (MY) 2010–2011 

vehicles to document characteristics of 

child restraint anchorage systems in the 

current vehicle fleet; 

• Evaluate the proposed ISO 29061– 

1: 2010 rating system (ratings for both 

the vehicle and the vehicle-to-child 

restraint interaction), SAE draft J2893 

recommended practice,22 and NHTSA’s 

proposed NCAP Vehicle-CRS Fit 

program to see if outcomes from those 

programs are associated with quality 

installations by volunteer subjects; and, 

• Conduct volunteer tests for 

evaluating the quality of child restraint 


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23 ‘‘Road vehicles—Methods and criteria for 

usability evaluation of child restraint systems and 

their interface with vehicle anchor systems—Part 1: 

Vehicles and child restraint systems equipped with 

ISOFIX anchors and attachments,’’ (November 

2010). 

24The SAE draft recommended practice does not 

involve a rating system; therefore, UMTRI 

developed a grade based on how many of the ten 

guidelines were met. 

25The 6.8 kg (15 lb) force application is the same 

as that in the SAE J2893 protocol. 

installations using vehicle features as 

the independent measures. 

In the first phase of the study, UMTRI 

measured the child restraint anchorage 

system hardware and rear seat geometry 

of 98 top-selling MY 2010 and 2011 

vehicles. The vehicles surveyed were 

those often used for transporting 

children that also represented a wide 

range of different child restraint 

anchorage system hardware. Included in 

the survey were passenger cars, 

minivans, sports utility vehicles (SUVs), 

and pickup trucks. The vehicle 

measurements were based on 

procedures in the ISO draft standard 

and the SAE draft recommended 

practice, and some additional measures 

developed for the study, such as the 

depth of the lower anchorages into the 

seat bight. 

In the second phase, UMTRI 

calculated the usability scores for each 

vehicle in the survey using the protocols 

in ISO 29061–1: 2010,23 SAE draft 

J2893,24 and NHTSA’s February 2011 

NCAP Vehicle-CRS fit program under 

consideration. ISO ratings of vehicle 

child restraint anchorage system 

usability ranged from 41 percent to 78 

percent. UMTRI calculated the ISO 

vehicle/child restraint interaction scores 

for 20 vehicles, identifying vehicles 

with a range of vehicle features, and 7 

child restraints. ISO vehicle/child 

restraint interaction scores ranged from 

14 percent to 86 percent. Vehicles 

assessed using the SAE draft 

recommended practice met between 2 

and all 10 of the recommendations. 

UMTRI evaluated the proposed NHTSA 

Vehicle-CRS Fit program criteria at one 

rear seating position (behind the driver’s 

seat) for 12 vehicles and 7 child 

restraints. The 7 CRSs selected 

represented a variety of restraint types 

(rear facing infant seats, convertible 

seats, combination seats and beltpositioning booster seats) and child 

restraint anchorage connector features. 

Of the 24 pairings with 12 vehicles and 

two rear-facing convertibles, one 

installation met all of NHTSA’s 

proposed vehicle-CRS fit criteria. 

Twenty-three (23) installations of the 24 

vehicle/infant seat pairings and 45 

installations of the 48 vehicle/forwardfacing harness CRS pairings met all of 

the proposed vehicle-CRS fit criteria. 

In the third phase, UMTRI conducted 

volunteer testing using 36 subjects, 12 

vehicles, and 3 CRS models to see if 

outcomes from the ISO, SAE and NCAP 

programs are associated with quality 

installations (correct installations) of 

child restraints by the subjects. The 

subset of 12 vehicles was chosen to 

provide a variety of child restraint 

anchorage system hardware 

characteristics. The 3 CRSs selected in 

this phase were the Safety First Alpha 

Omega Elite, Chicco KeyFit, and Graco 

SnugRide 30. 

The study considered a ‘‘correct’’ 

installation to meet the following 

criteria: 

(1) Tight installation—Child restraint 

did not move more than 1 inch laterally 

or fore/aft when tested with a moderate 

pull/push applied at the restraint belt 

path. 

(2) Correct use of lower anchors (if 

applicable)—Child restraint connectors 

were fully engaged with the correct 

vehicle hardware in the correct 

orientation and the CRS belt webbing 

connecting to the child restraint 

anchorages was flat. 

(3) Correct use of seat belt (if 

applicable)—Seat belt was routed 

through the correct belt path, was not 

twisted, and was buckled and locked 

correctly. 

(4) Correct use of tether anchorage (if 

applicable)—Tether hook attached to 

the correct vehicle hardware in the 

correct orientation, routed around or 

under the head restraint as directed by 

the vehicle manual, and tightened so 

that there was 10 mm (0.39 in) or less 

of slack (measured by pinching the slack 

and measuring the height of the loop). 

(5) Correct installation angle— 

Installation angle was considered 

correct for rear-facing installations if the 

restraint indicator was at the correct 

level, and was considered correct for 

forward-facing installations if the 

recline foot was in the forward-facing 

position. 

2. Three Seat Characteristics Were Well 

Correlated With Correct Use 

Using a series of mixed-model logistic 

regression models with various lower 

anchorage characteristics assessed in the 

study, UMTRI identified three features 

of lower anchorages that the volunteer 

testing showed were well correlated to 

the correct installation of CRSs. These 

were: Clearance angle, attachment force, 

and anchorage depth. UMTRI stated that 

the odds of correct CRS installation 

when the child restraint anchorage 

system met the minimum criterion for 

clearance angle, attachment force, and 

lower anchorage depth are 5, 9, and 7 

times higher, respectively. UMTRI 

showed that subjects were 19 times 

more likely to correctly install the CRS 

if the vehicle met all three usability 

criteria than if none of the criteria were 

met. Using multi-variate regression 

analysis of the volunteer data, UMTRI 

found that subjects who correctly used 

the lower anchorage hardware were 3.3 

times more likely to achieve a tight CRS 

installation than subjects who made 

errors using the hardware. 

A. Clearance Angle 

Clearance angle refers to the clearance 

around a lower anchorage from parts 

that interfere with the ability to 

maneuver the CRS lower anchorage 

connector. The interfering parts can 

include part of the vehicle seat structure 

or excessively stiff seat cushion 

material. Clearance angle is measured 

by a tool (specified in the SAE draft 

J2893 recommended practice) that 

attaches to the lower anchorages. In 

UMTRI’s procedure a vertical force of 

66.7 N (15 lb) 25 is applied to the tool. 

The angle the tool achieves when that 

force is applied is the ‘‘clearance angle.’’ 

UMTRI determined the performance 

limits for clearance angle by analyzing 

the vehicle characteristics and rate of 

correct installation from the volunteer 

tests. Based on the user trial data shown 

in Figure 1 below, UMTRI determined 

that a clearance angle greater than 54 

degrees will increase the likelihood of 

correct CRS installation. 


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B. Attachment Force 

Attachment force refers to the force 

needed to attach a child restraint’s 

lower anchorage connector to a lower 

anchorage in a vehicle. UMTRI 

measured the force required to attach a 

CRS connector to a vehicle lower 

anchorage using a force gauge specified 

in SAE draft J2893. The tool is similar 

in shape and size to various CRS lower 

anchorage connectors in the market and 

to the connectors used on the Child 

Restraint Fixture and the Static Force 

Application Device 2 (SFAD2) of 

FMVSS No. 225. A force gauge in the 

tool measures the force required to fully 

engage the CRS connector to a lower 

anchorage in a vehicle. A stiff seat 

cushion and/or obstructions 

surrounding a lower anchorage may 

increase the attachment force. 

Based on the data shown in Figure 2 

below, UMTRI determined that an 

attachment force less than 178 N (40 lb) 

has a high likelihood of correct CRS 

installation. 


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26UMTRI’s tool was marked with different 

colored electrical tape at 2 cm intervals from the 

hook. When the tool was hooked onto the lower 

anchorage of the vehicle, the different colors of tape 

were exposed. For example, if the lower anchorage 

were exposed and not recessed in the seat bight at 

all, all colors in the hook were visible. 

27LATCH Usability study, 2012, supra. 

28SAE recommend practice is not a rating system; 

therefore, UMTRI developed a grade based on how 

many of the ten guidelines were met. 

C. Anchorage Depth 

Anchorage depth refers to how deeply 

the lower anchorages are embedded in 

a vehicle seat (usually in the seat bight). 

UMTRI developed a simple tool that 

easily measures lower anchorage depth. 

The tool consists of a hook-type CRS 

connector which is marked every 2 

cm.26 Lower anchorages that are set 

deeper into the seat bight are more 

difficult to locate, identify, and use. 

Based on the data shown in Figure 3 

above, UMTRI determined that a lower 

anchorage depth less than 2 cm has a 

significantly higher rate of correct lower 

anchorage use than for anchorage 

depths greater than 2 cm. 

UMTRI found that, while clearance 

angle, attachment force and anchorage 

depth are important, due to the 

correlation of the three factors it was not 

possible to truly identify their separate 

contributions to prediction of correct 

CRS installation. UMTRI believed that 

lower anchorage designs in vehicles 

should consider all three characteristics 

to improve rates of correct installation 

of child restraints. 

IV. UMTRI’s Assessment of the ISO, 

SAE, and NCAP Programs 

As part of UMTRI’s LATCH Usability 

study,27 UMTRI evaluated vehicles 

using the draft ISO standard 29061– 

1:2010 and the derived SAE grade 28 and 

found no correlation between usability 

ratings and correct installation of child 

restraints in the vehicles in user trials. 

Results indicated that the ISO vehicle 

rating, the ISO vehicle/child restraint 

interaction rating and the derived SAE 

grade showed no correlation with rates 

of the volunteers’ correct CRS 

installation using the lower anchorages 

(see Figure 4 below). 


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29 Id. 

30 Id. 31 Id. 

32We are also proposing improved marking of 

child restraint anchorages and child restraint 

anchorage connectors to improve the ease of use of 

child restraint anchorage systems. 33We note that General Motors made the 

suggestion that NHTSA explore SAE’s draft 

guidelines in its comments at the 2007 LATCH 

public meeting. 34NHTSA Technical Report, ‘‘Evaluation of 

LATCH Usability Procedure,’’ which is in the 

docket for this NPRM. 

UMTRI also evaluated 29 NHTSA’s 

proposed Vehicle-CRS Fit program 

criteria using 12 vehicles and 7 child 

restraints. The user data showed that, 

among vehicle and child restraint 

combinations that would be considered 

compatible under the proposed criteria, 

only 16 percent were correctly installed 

by the volunteers. 

V. NHTSA’s Preference Is the UMTRI 

Approach 

NHTSA has evaluated the draft ISO 

standard and the SAE draft 

recommended practice and concludes 

that neither approach would likely 

improve the usability of child restraint 

anchorage systems as effectively as the 

specifications proposed in today’s 

NPRM. The ISO draft standard primarily 

rates vehicles and does not directly 

mandate improvements to the usability 

of child restraint anchorage systems. 

Further, as discussed above, UMTRI 

evaluated vehicles using the draft ISO 

standard 29061–1:2010 and found no 

correlation between usability ratings 

and correct installation of child 

restraints in the vehicles in user trials. 

The draft SAE recommended practice 

J2893 would also be limited because it 

is only a guideline and does not 

mandate improved usability. In 

addition, as noted above, UMTRI 

evaluated the SAE derived grade from 

the 10 guidelines and found no 

correlation between the SAE derived 

grade and correct installation of child 

restraints in the vehicles in user trials.30

We believe that the amendments 

resulting from today’s NPRM would be 

more effective in improving ease of use 

and the fit of child restraints in vehicles 

than NHTSA’s proposed Vehicle-CRS fit 

program. The fit program only examines 

the fit of a small number of specific 

CRSs selected by the vehicle 

manufacturer for a specific vehicle 

model. Today’s NPRM would ensure a 

more universal compatibility between 

vehicles and child restraints. The 

Vehicle-CRS fit program would be a 

voluntary program, so vehicle 

manufacturers have the option of not 

providing NHTSA any information 

about the fit of child restraints in their 

vehicles. In contrast, the changes 

resulting from this NPRM would be 

mandated and universal for all vehicles 

and all child restraints. The changes 

made to vehicle seats resulting from this 

rulemaking would make all child 

restraints easier to use and fit tightly on 

vehicle seats. In addition, UMTRI 

evaluated the NCAP Vehicle-CRS fit 

proposal and found that volunteers in 

user trials had a low rate of correctly 

installing CRSs even when the CRSs 

were ones meeting the NCAP program’s 

‘‘fit’’ criteria.31

VI. Proposal To Improve Lower 

Anchorage Usability 

This NPRM proposes amendments to 

improve the three features of lower 

anchorages—clearance angle, 

attachment force, and anchorage 

depth—that were shown to have a 

positive impact on correct child 

restraint installations in user trials in 

UMTRI’s LATCH Usability study. 

NHTSA has reviewed the UMTRI study 

and tentatively concludes that the 

features have been reasonably shown to 

have a significant bearing on correct 

installations. Also, lower anchorages 

meeting the proposed requirements for 

clearance angle, attachment force, and 

anchorage depth appear feasible.32 The 

UMTRI procedures for measuring 

clearance angle and attachment force are 

similar to those in the draft SAE J2893 

recommended practice which were 

developed with industry input and 

participation.33 NHTSA has evaluated 

the procedures in 10 vehicles (MY 

2005–2013) and they appear objective 

and repeatable. The agency made minor 

modifications to the measurement tools 

to enhance their ease of use and to 

further improve the repeatability of 

measurements.34

Comments to NHTSA’s 2007 LATCH 

public meeting on child restraint 

anchorage system usability included 

many complaints about the difficulty of 

attaching lower anchorage connectors to 

lower anchorages because of 

interference from surrounding stiff 

cushions, fabric/leather or buckles. 

There were also observations about the 

difficulty of using the lower anchorages 

because they are often embedded in the 


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35National Child Restraint Use Special Study, 

supra. 

36UMTRI used this measurement tool in its 

LATCH Usability Study and measured the applied 

vertical force and the resulting clearance angle 

using a force gauge and an inclinometer, 

respectively. 

37 Docket No. NHTSA–2007–28793–24. 

seat bight. It appears that the proposed 

changes would sufficiently address 

these problems. 

We tentatively conclude that this 

NPRM would ultimately increase child 

safety. The NCRUSS 35 data show that a 

loose CRS installation comprises one of 

the five most significant mistakes 

consumers make in the field when 

installing child restraints. We wish to 

reduce loose CRS installations in the 

field since a loose installation could 

result in higher excursions of the child 

and CRS during a crash and a greater 

risk of injury due to the child’s possible 

contact with vehicle interior structures, 

as compared to correct (tight) 

installations. We believe that if child 

restraint anchorage systems can be made 

easier to use correctly, then correct 

(tight) installations will increase. 

a. Clearance Angle 

Clearance angle relates to the 

clearance around a lower anchorage 

from interfering parts that can make it 

difficult to maneuver and attach a CRS 

lower anchorage connector. We believe 

that a clearance angle requirement 

would facilitate easier attachment of a 

CRS lower anchorage connector by 

preventing interference from 

surrounding components. 

‘‘Clearance angle’’ is a criterion 

included in draft SAE J2893, and the 

tool we would use to measure the 

clearance angle was based on a tool 

developed by the SAE in draft J2893 

(Version 1—Draft 7).36 The tool, 

illustrated in Figure 5 below, includes a 

load cell with a handle to measure the 

applied vertical force on the tool and a 

potentiometer to measure the angle with 

respect to the horizontal achieved by the 

tool during the force application. In our 

proposed test procedure, the tool would 

be attached to a lower anchorage. A 

vertical force of 66.7 N (15 lb) is applied 

to the tool. The angle the tool achieves 

(with respect to the horizontal) when 

that force is applied is the ‘‘clearance 

angle.’’ We propose to amend FMVSS 

No. 225 to adopt a clearance angle 

requirement of not less than 54 degrees, 

as supported by the findings of the 

UMTRI LATCH Usability study. The 

requirement would apply to each lower 

anchorage in a vehicle. 

We note that draft SAE J2893 specifies 

that the clearance angle should be 

greater than 75 degrees. We have 

differed from that draft specification 

because the UMTRI LATCH Usability 

study has user trial data to show that a 

clearance angle greater than 54 degrees 

is sufficient to increase the likelihood of 

correct CRS installation. We are not 

aware of similar user data to support the 

SAE target of 75 degrees. 

Our proposed 66.7 N (15 lb) force 

application is the same as that in the 

draft SAE J2893 protocol. We believe 

that the force represents a low force that 

an adult can easily apply. A NHTSA 

study to determine the force that ablebodied adults could apply to open 

emergency exit windows found that this 

force ranged from 66.7 N (15 lb) to 533.7 

N (120 lb) with a mean of 244.6 N (55 

lb).37

b. Attachment Force 

‘‘Attachment force’’ refers to the force 

needed to attach a child restraint lower 

anchorage connector to a lower 

anchorage. After considering the UMTRI 

LATCH Usability study, we propose to 

amend FMVSS No. 225 to require child 

restraint anchorage systems to be 

manufactured such that the attachment 

force needed to attach an attachment 

force tool to the lower anchorage must 

be less than 178 N (40 lb). UMTRI’s 


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volunteer subjects study indicates that 

an attachment force less than 178 N (40 

lb) has a high likelihood of correct CRS 

installation. 

The attachment force tool, illustrated 

in Figure 6 below, is based on the tool 

specified in SAE draft J2893 (Version 1 

Draft 7) and which was used in the 

UMTRI LATCH Usability study. The 

end of the tool is similar in shape and 

size to various ‘‘push-on’’ CRS lower 

anchorage connectors in the market and 

to the connectors used on the SFAD2 of 

FMVSS No. 225. In order to improve the 

repeatability of the measurements 

obtained by the tool, the agency 

modified the tool used in the UMTRI 

LATCH Usability study as follows. A 

trigger switch was included to 

determine when the tool is fully 

engaged to a lower anchorage in a 

vehicle. A button load cell in a push 

handle was added to measure the force 

needed to fully engage the tool to the 

anchorage. Finally, a potentiometer was 

included to measure the approach angle 

of the tool with respect to the 

horizontal. 

We note that draft SAE J2893 specifies 

that the attachment force should be less 

than 75 N (16.9 lb), which is more 

stringent than that proposed in this 

NPRM. We are proposing a 178 N (40 lb) 

limit because it is supported by the 

findings of UMTRI’s LATCH Usability 

study showing the correlation of the 

limit with correct CRS installation. We 

are not aware of such data supporting 

the SAE limit under consideration. 

There is also a slight difference 

between the draft SAE J2893 procedure 

and UMTRI’s procedure regarding how 

the measurement is taken. The SAE 

draft procedure specifies that, when 

taking the measurement, the attachment 

force tool approaches the lower 

anchorage at an angle near zero degrees 

(i.e., it is parallel to the seat bottom 

cushion surface). UMTRI found that it is 

not possible to attach the tool to the 

lower anchorages in most vehicles when 

it is held parallel to the seat bottom 

cushion. UMTRI modified the SAE 

protocol for measuring the attachment 

force such that the force is measured at 

the angle (from 0 to 45 degrees) to the 

horizontal producing the lowest force 

value. In addition to making it possible 

to attach the tool to the lower 

anchorages, UMTRI believed that the 0 

to 45 degrees range of angles for 

attaching the measurement tool to the 

lower anchorages better represents how 

a parent would attach a CRS lower 

anchorage connector to the lower 

anchorages compared to the SAE 

method. NHTSA tentatively agrees with 

UMTRI’s conclusions and has proposed 

the 0 to 45 degree range in this NPRM. 

c. Anchorage Depth 

Anchorage depth refers to how deeply 

the lower anchorages are embedded in 

the vehicle seat (usually in the seat 

bight or seat back). UMTRI’s LATCH 

Usability study found that an anchorage 

depth of less than 2 cm within the seat 

bight is associated with a significantly 

higher rate of correct lower anchorage 

use than anchorage depths greater than 

or equal to 2 cm. NHTSA proposes a 

requirement that each lower anchorage 

must have an anchorage depth of less 

than 2 cm, as measured by a speciallydesigned compliance tool (the tool is 

illustrated in Figure 7, below). The tool 

incorporates a hook-type CRS 

connector. The distance 2 cm from the 

backside of a lower anchorage bar when 

the connector is attached to a lower 

anchorage is marked on the tool (as 

shown in Figure 8, below). In a 

compliance test, the tool would be 

attached to a lower anchorage. The 2 cm 

mark would have to be visible from a 

vertical longitudinal plane passing 

through the center of the bar, along a 

line making an upward 30 degree angle 

with a horizontal plane, without the 

technician’s manipulating the seat 

cushions in any way. 


emcdonald on DSK67QTVN1PROD with PROPOSALS2EP23JA15.005</GPH>
Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 3755 

38SgRP (seating reference point) is the unique 

design H-point as defined in SAE Recommended 

Practice J1100, ‘‘Motor Vehicle Dimensions,’’ 

revised June1984. 

We tentatively conclude that the 

proposed anchorage depth requirement 

would make the requirement in 

S9.2.2(a) of FMVSS No. 225 

unnecessary, so we propose deleting 

S9.2.2(a). S9.2.2(a) specifies that the 

lower anchorages must be located less 

than 70 mm (2.75 in) behind the 

rearmost point at the bottom plane of 

the CRF while the CRF is pressed 

rearward against the seat back with a 

horizontal force of 100 N (22.4 lb). The 

purpose of S9.2.2(a) is to ensure that the 

lower anchorages are not deeply 

recessed into the seat bight. We 

tentatively conclude that the proposed 

requirement for anchorage depth takes 

the place of S9.2.2(a) by ensuring the 

lower anchorages are not deeply 

recessed. The proposed 2 cm (0.8 in) 

limit on anchorage depth would not 

permit lower anchorages to be as deeply 

recessed into the vehicle seat as 

permitted by S9.2.2(a). The UMTRI 

volunteer study showed that 

accessibility of the lower anchorages— 

and correct CRS installation—is better 

determined using anchorage depth than 

the current requirement in S9.2.2(a). 

On the other hand, we have 

tentatively determined that S9.2.2(b) 

continues to be needed and should be 

retained even if a limit on anchorage 

depth is adopted. S9.2.2(b) specifies that 

the lower anchorages must be located 

more than 120 mm (4.7 in) behind the 

SgRP.38 Its intent is to ensure that the 

lower anchorages are not so far forward 

so as to cause discomfort to occupants 

not in CRSs or pose an unreasonable 

risk of injury in rear impacts. 

We believe the requirement in 

S9.2.2(b) does not conflict with the 

proposed anchorage depth requirement. 

UMTRI’s survey of 98 MY 2010–2011 

vehicles showed that the seat bight of 

the surveyed vehicles was at least 140 

mm (1.5 in) from the estimated SgRP, as 

shown in Figure 9. (UMTRI’s 

measurement referenced the H-point, 

which with regard to rear seats that do 

not move, is at the same location as the 

SgRP.) The proposed anchorage depth 

requirement specifies that the anchorage 

has to be less than 2 cm deep into the 

seat bight. Lower anchorages can be 

positioned less than 2 cm deep into the 

seat bight and still meet S9.2.2(b). 


emcdonald on DSK67QTVN1PROD with PROPOSALS2EP23JA15.006</GPH>
3756 Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 

39UMTRI LATCH Usability study, supra. 

d. Estimated Rate of Current 

Compliance 

UMTRI’s survey of 98 MY 2010–2011 

vehicles 39 showed that 9 percent met 

none of the three provisions, 31 percent 

met one provision, 37 percent met two 

provisions, and 21 percent met all three 

provisions for lower anchorages. Ninety 

percent met the attachment force 

provision (<178 N (40 lb)), 58 percent 

met the clearance angle provision (>54 

degrees) and 28 percent met the 

anchorage depth (<2 cm (0.8 in)) 

provision, as shown in Figure 10 below. 

Table 1, below, shows the percentages 

of vehicles within ranges of the 

proposed attachment force, clearance 

angle, and anchorage depth 

requirements. 


emcdonald on DSK67QTVN1PROD with PROPOSALS2EP23JA15.007</GPH> EP23JA15.008</GPH>
Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 3757 

40NHTSA Technical Report, ‘‘Evaluation of 

LATCH Usability Procedure,’’ which is in the 

docket for this NPRM. 

41Except for the element relating to set-back of 

the anchorage, UMTRI’s LATCH Usability study did 

not address ease of use of tether anchorages. 

. 

42Aram, M.L., Rockwell, T., ‘‘Vehicle Rear Seat 

Study-Technical Report,’’ NHTSA, 2012. A copy of 

the report is in the docket. 

43Supra. 

44These anchorages are accessible without 

folding the seat. 

TABLE 1—PERCENTAGE OF VEHICLES (FROM UMTRI’S SURVEY OF 98 MY 2010–11 VEHICLES) VERSUS RANGE OF

LOWER ANCHORAGE ATTACHMENT FORCE, CLEARANCE ANGLE AND DEPTH

Attachment force Clearance angle Anchorage depth 

<178N ......................................... 89.5% >54 degrees ................................ 58.0% <1.9 cm ....................................... 28.5% 

178–311N ................................... 5.2% 44–54 degrees ............................ 23.6% 2–3.9cm ...................................... 27.5% 

312–645N ................................... 5.2% 35–43 degrees ............................ 10.7% 4–5.9 cm ..................................... 40.8% 

20–34 degrees ............................ 7.5% 6–7.9 cm ..................................... 3.0% 

NHTSA’s evaluation of 10 MY 2005– 

2013 vehicles 40 resulted in attachment 

force measurements at 27 lower 

anchorage positions, and clearance 

angle and lower anchorage depth 

measurements at 31 lower anchorage 

positions. The attachment force 

measurements were all well below 178 

N (40 lb). Seventeen of 31 anchorage 

positions had clearance angles greater 

than 54 degrees, and 16 of the 31 

anchorage positions had an anchorage 

depth less than 2 cm. Five vehicles met 

the proposed clearance angle criterion 

and 5 met the proposed anchorage 

depth criterion at all lower anchorage 

positions tested. Three of the 10 

vehicles tested met all 3 proposed 

usability criteria for lower anchorages. 

VII. Proposal To Improve Tether 

Anchorage Usability 

FMVSS No. 225 specifies where tether 

anchorages may be located, but 

consumers are still having difficulty 

finding, identifying, accessing, and 

using the tether anchorages. Some tether 

anchorages have been located deep 

under the seat (the seat would have to 

be folded over to access the anchorage) 

or under a carpet. Some tether 

anchorages are located too close to the 

seat head restraint where there is not 

enough space for the CRS tether strap to 

be tightened. Some tether anchorage 

configurations are differently configured 

from those typically found in vehicles, 

e.g., they consist of a webbing loop 

rather than a rigid bar. To improve the 

ease of use of tether anchorages, we 

propose the following requirements.41

a. Limit the Zone 

FMVSS No. 225 specifies that tether 

anchorages must be located within the 

shaded zone shown in Figures 3 through 

7 of FMVSS No. 225 for the designated 

seating position (DSP) for which the 

anchorage is installed. The allowable 

zone encompasses a wide area which 

has resulted in some tether anchorages 

being located where consumers have 

had difficulty accessing them, such as 

deep under the seat where folding the 

seat is required to reach/attach the 

tether anchorage. This place is the 

forward-most edge of the area under the 

vehicle seat defined by the intersection 

of the torso line reference plane (defined 

by the SAE J826 two-dimensional 

drafting template) and the floor pan. 

We propose to amend Figures 3 

through 7 of the standard to disallow 

tether anchorages from being placed 

deep under the seat. Specifically, the 

agency is proposing that the forwardmost edge of the allowable tether 

anchorage zone represented by the 

shaded area in Figure 3 of FMVSS No. 

225 be moved rearward to a position 

defined by the intersection of the 

vehicle floor with a plane that is parallel 

to the torso line reference plane and 

which passes through the rearmost 

point of the bottom of the seat at its 

centerline. We note that vehicles with 

tether anchorages located deep under 

the seat where the seat must be folded 

to reach the anchorages are no longer 

manufactured, so this change in 

requirements would have little or no 

impact on current vehicle designs. 

However, we tentatively believe the 

amendment is needed to prevent these 

designs from coming back into the fleet. 

NHTSA evaluated vehicle fleet data to 

find where tether anchorages were 

typically located. We reviewed 

combined data from a NHTSA survey 42

of 24 MY 2010 vehicles and the UMTRI 

LATCH Usability study 43 of 98 MY 

2010–2011 vehicles. The data indicate 

that the most common tether anchorage 

locations are the seat back (41 percent) 

and the package shelf (37 percent). 

Tether anchorage locations on the seat 

back are typical of MPVs and trucks, 

while the package shelf location is 

characteristic of passenger cars. Tether 

anchorages located on the back wall of 

the occupant compartment (8 percent) 

are seen only in pickup trucks. Less 

common tether anchorage locations are 

the roof (6 percent) (often found in 

SUVs, station wagons, and some center 

seats of passenger cars), the floor (4 

percent) and under the seat 44 (3 

percent). 

In current vehicles, the tether 

anchorages located on the seat back and 

on the package shelf (the two most 

common locations) are mostly centered 

or slightly off-center from the DSP, as 

depicted in Figure 11 below. However, 

in vehicles with a cargo area or another 

seating row behind the seating position 

with the tether anchorage (such as 

station wagons and MPVs), and vehicles 

without a cargo area contiguous with 

the seating position (such as pickup 

trucks), the tether anchorage are often 

installed on the roof, floor, back wall or 

under the seat. 


emcdonald on DSK67QTVN1PROD with PROPOSALS2
3758 Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 

45Amenson, T., Sullivan, L.K., ‘‘Dynamic 

Evaluation of LATCH Lower Anchor Spacing 

Requirements and Effect of Tether Anchor Location 

on Tether and Lower Anchor Loads,’’ NHTSA, 

2013. A copy of the report is in the docket for this 

NPRM. 

We considered but decided against 

further limiting the zones in Figures 3 

through 7 of FMVSS No. 225. We are 

mindful that, when determining tether 

anchorage locations, vehicle 

manufacturers must consider the 

strength of the structure to which the 

tether anchorage is affixed. They also 

have to consider the degree to which the 

tether anchorage—or the child restraint, 

when using the anchorage—interferes 

with ingress, egress, seating, and/or the 

comfort and safety of vehicle occupants. 

Due to these considerations, vehicle 

manufacturers sometimes install tether 

anchorages slightly off-center to a 

seating position, or on the roof, floor, or 

back wall. Thus, some flexibility is 

needed in locating the anchorages. 

Moreover, as explained below, those 

atypical locations do not appear to pose 

a safety problem. 

We performed sled tests using 

different fore-aft and lateral tether 

anchorage locations and found no 

difference in CRS performance when the 

CRSs were tethered at different 

locations at extreme points within the 

allowable zone.45 In the evaluation, we 

conducted a series of nine frontal 

impact sled tests using the FMVSS No. 

213 test protocol to assess the effect of 

tether anchorage location on dummy 

kinematics and injury outcomes. One 

forward-facing child restraint was used 

with a Hybrid III 3-year-old (HIII–3C) 

dummy in each test configuration. The 

lower anchorages were spaced 280 mm 

(11 in) apart. The tether anchorage was 

positioned at various locations to 

replicate the vehicle seat back, roof, and 

package shelf above and behind the seat 

bight (see Table 2 below). At each of the 

tether anchorage configurations, the 

lateral position of the tether anchorage 

was also varied from the center to 150 

mm (5.9 in) and 300 mm (11.8 in) to the 

right of center. 

TABLE 2—TETHER ANCHORAGE

LOCATIONS FROM SEAT BIGHT

[Tether anchorage locations from FMVSS No. 

213 bench seat bight] 

Aft 

(cm) 

Above 

(cm) 

Package Shelf ...................... 650 585 

Seat back ............................. 280 210 

Roof ...................................... 550 1070 

The results showed that changing the 

tether anchorage location did not 

significantly affect the injury outcomes 

of the HIII–3C dummy in these tests. 

Overall, the head injury criterion (HIC) 

measured in a 36 millisecond timeframe 

(HIC36) ranged from 366 to 585 for the 

various tether anchorage locations and 

was significantly lower than the 

performance limit of 1000 (see Figure 

12, below). For each of the various 

lateral positions of the tether anchorage 

on the seat back, the package shelf, and 

the roof, the dummy injury measures 

(HIC36, chest acceleration, and dummy 

excursions) were similar and 

significantly lower than the injury 

assessment reference values of FMVSS 

No. 213. 

For illustration purposes, HIC36 was 

the only injury criterion used in the 

following graphs; however the full data 

(including chest accelerations and 

excursions) can be found in the 

docketed technical report. 


emcdonald on DSK67QTVN1PROD with PROPOSALS2EP23JA15.009</GPH>
Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 3759 

The load distribution on the lower 

anchorages and tether anchorages vary 

depending on whether the tether 

anchorage is located on the package 

shelf, seat back, or roof, due to the 

length of the tether. However, varying 

the lateral location of the tether 

anchorage in each of these general 

locations (package shelf, seat back or 

roof), generated similar peak loads for 

the lower anchorages and tether 

anchorage despite the center or side 

locations of each tether anchorage site 

(see Figure 13, below). 


emcdonald on DSK67QTVN1PROD with PROPOSALS2EP23JA15.010</GPH> EP23JA15.011</GPH>
3760 Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 

46This issue was brought to NHTSA’s attention 

by child passenger safety technicians who perform 

child restraint system checks across the country and 

teach/assist parents in installing CRSs properly. 47R-point as defined in SAE J787b. 

48Supra. 

49Strap wrap-around line is the nonlinear path 

traversed by a string connecting two points. 

These results suggest that there is not 

an unreasonable safety risk posed by 

locating the tether anchorage at the 

lateral extreme points of the allowable 

zone. Thus, we tentatively conclude that 

retaining the zones depicted in Figures 

3 to 7 of FMVSS No. 225, except to 

disallow the area under a vehicle seat, 

appropriately balances safety, ease of 

use, and design flexibility. 

b. Anchorage Must Be Accessible 

The agency proposes to require that a 

tether anchorage must be in a location 

where the anchorage is accessible 

without the need to remove carpet or 

other vehicle components to access the 

anchorages. However, a tether 

anchorage may be covered with a cap, 

flap or cover, provided that the cap, flap 

or cover is specifically designed to be 

opened, moved aside or otherwise 

provide access to the anchorage. It must 

also be labeled with the ISO symbol 

indicting the presence of the tether 

anchorage underneath. We also propose 

to require the anchorage to be accessible 

without the use of any tools, including 

the use of a screwdriver or coin. 

c. Standardized Configuration 

FMVSS No. 225 does not provide any 

material or dimensional requirements 

for tether anchorages, other than 

specifying that the tether anchorage 

must permit the attachment of a tether 

hook meeting the configuration and 

geometry specified in Figure 11 of 

Standard No. 213. Most vehicle 

manufacturers use a metal bar design for 

the tether anchorage. These metal bars 

vary in cross section shape; some are 

round and others are flat. However, a 

few pickup trucks and MPVs provide a 

webbing loop as the tether anchorage. 

The webbing loop is so different from 

the conventional metal bar design that 

consumers have difficulty identifying 

them as tether anchorages.46 Also, in 

some cases, the webbing anchorages 

need to be retrieved from another 

component such as a foldable carpet 

flap that runs across the back seat. In 

certain cases, the carpet flap needs to be 

folded back to find the webbing tether 

anchorage and then the webbing needs 

to be pulled out with a pencil. 

To increase the ease of use of tether 

anchorages, we propose amending 

FMVSS No. 225 to standardize the 

configuration of the tether anchorage 

such that it is a ‘‘rigid bar of any cross 

section shape.’’ One of the main 

objectives of this NPRM is to increase 

the standardization of child restraint 

anchorage system features, because we 

believe doing so increases consumers’ 

familiarity with the anchorage systems 

and will increase the ease of using the 

systems, particularly when coupled 

with education efforts that provide a 

simple and uniform message. The 

webbing loop design differs 

considerably from the appearance of a 

typical tether anchorage. Even if 

consumers become more aware of the 

importance of tether use, they may still 

fail to use a tether anchorage because 

they do not recognize the webbing loop 

as a tether anchorage. Having a 

standardized design for the tether 

anchorages such that they can be 

described as a ‘‘rigid bar’’ would help 

consumers easily recognize the 

anchorages in their vehicles and 

facilitate simplified and more effective 

messages in educational materials. 

The agency is seeking comment on 

whether further standardization of the 

tether anchorage should be pursued to 

make the tether anchorage a more 

recognizable vehicle feature. The agency 

has tentatively decided not to specify 

dimensions for the tether anchorage, to 

give manufacturers some design 

flexibility in meeting FMVSS No. 225’s 

strength requirements. We request 

comment on the issue. 

d. Clearance Around the Tether 

Anchorage 

This NPRM proposes requirements to 

make it easier for a consumer to attach 

a child restraint tether hook to a tether 

anchorage and tighten the tether strap. 

We propose to amend FMVSS No. 225 

to require a 165 mm (6.5 in) minimum 

distance from a tether anchorage to a 

reference point on the vehicle DSP for 

which the tether anchorage is installed. 

FMVSS No. 225 specifies that tether 

anchorages must be located within the 

shaded zone shown in Figures 3 to 7 of 

the standard for the DSP for which the 

anchorage is installed. The standard 

specifies a reference point ‘‘W’’ that is 

50 mm (1.9 in) below and 50 mm (1.9 

in) rearward of the shoulder reference 

point (R-point),47 and a reference point 

‘‘V’’ that is 350 mm (13.7 in) vertically 

above and 175 mm (6.8 in) horizontally 

back from the H-point. The standard 

also specifies a strap wrap-around 

length of 200 mm (7.8 in) from the Wpoint and a strap wrap-around length of 

250 mm (9.8 in) from the V-point (see 

Figure 4 of FMVSS No. 225). Tether 

anchorages may be located only within 

the zone that is generated using both 

reference points and their associated 

strap wrap-around lengths to ensure 

there is sufficient distance for a tether 

strap and hook to be attached to the 

anchorage. 

The UMTRI LATCH Usability study 48

found that under current FMVSS No. 

225, tether anchorages can be located 

too close to the head restraint, top of the 

seat back, or the tether attachment point 

on a CRS, resulting in insufficient 

clearance space to tighten the CRS 

tether strap. UMTRI reviewed the 

‘‘tether hardware assembly,’’ which 

consists of the tether hook and hardware 

to tighten and loosen the tether strap, on 

21 child restraints made by 11 different 

CRS manufacturers and found the tether 

hardware assembly to range from 102 to 

184 mm (4 to 7.2 in) in length, with 15 

CRSs having tether hardware assembly 

lengths between 140 mm (5.5 in) and 

165 mm (6.5 in). UMTRI suggests that 

having tether anchorages on a package 

shelf or behind the seat back at a 

distance of at least 165 mm (6.5 in) 

rearward or below the back of the head 

restraint or top of the seat back (if no 

head restraint is present) would provide 

better clearance for attaching the tether 

hook of a CRS and tightening the strap. 

We have reviewed the UMTRI LATCH 

Usability study and tentatively agree 

that specifying a minimum 165 mm (6.5 

in) distance from the tether anchorage to 

a reference point on the vehicle seat 

would improve the ease of use of tether 

anchorages. The clearance would allow 

tightening of tether straps in most 

vehicles without experiencing 

interference from other structures, such 

as the head restraint. The reference 

point on the vehicle seat, which we 

have designated ‘‘SB,’’ would be defined 

as the intersection of the plane parallel 

to the torso line reference plane (defined 

in Figure 3 of FMVSS No. 225) that 

passes through the rearmost point of the 

seat and the wrap-around line 49 from 

the ‘‘V-point’’ to the tether anchorage. 

The rearmost point of the seat includes 

the head restraint, if one is present. The 

V-point represents a low-mounted tether 

strap on a CRS and the W-point 

represents a high-mounted tether strap 

on a CRS. The agency believes both the 

V- and W-point could have been used 

for determining the vehicle seat 

reference point, SB, but we selected the 

V-point to define the reference point 

because it would encompass both lowmounted and high-mounted tether 

straps. 

To improve compatibility between 

vehicles and CRSs, we also propose to 

amend FMVSS No. 213 to require that 

the tether hardware assembly 

(consisting of the tether hook and 


emcdonald on DSK67QTVN1PROD with PROPOSALS2
Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 3761 

50 ‘‘Child Restraint Use Survey: LATCH Use and 

Misuse,’’ supra. 

51 ISO 13216–1:1999 ‘‘Road vehicles— 

Anchorages in vehicles and attachments to 

anchorages for child restraint systems.’’ 

52E.g., in comments to the 2007 LATCH Public 

Meeting, GM raised the merits of an industry 

agreement to label all tether anchorages with an 

anchorage symbol and all lower anchorages with an 

ISO lower anchorage symbol. 

53Aram, M.L., Rockwell, T., ‘‘Vehicle Rear Seat 

Study-Technical Report,’’ NHTSA, 2012, which is 

in the docket for this NPRM. 

hardware to tighten and loosen the 

tether strap) must be no longer than 165 

mm (6.5 in). We propose this limit so 

that all CRS tether straps will be able to 

be tightened given the minimum tether 

anchorage distance from the SB 

reference point. 

The UMTRI LATCH Usability study 

found that the length of the tether 

hardware assembly of the 21 child 

restraints it reviewed ranged from 102 to 

184 mm (4 to 7.2 in). UMTRI estimated 

that about 30 percent of CRS models 

might need tether hardware assembly 

changes to meet the 165 mm (6.5 in) 

limit. We do not believe limiting the 

length of the tether hardware assembly 

would be overly burdensome for CRS 

manufacturers, since the assembly 

appears to consist of simple parts. 

Comments are requested on this issue. 

VIII. Conspicuity and Identification of 

Anchorages 

To improve the ease with which 

consumers find lower anchorages and 

tether anchorages in the vehicle, we 

propose amending FMVSS No. 225 to 

improve conspicuity and identification 

of the anchorages. (In the next section, 

we propose complementary 

requirements amending FMVSS No. 213 

to improve conspicuity and 

identification of the CRS connectors.) 

a. Marking Lower Anchorages 

FMVSS No. 225 (S9.5) currently 

requires lower anchorage bars to be 

visible, or the vehicle seat marked, to 

alert the consumer to the presence of the 

anchorages and to assist consumers in 

locating the lower anchorages. If the 

vehicle seat is marked, the current 

marking requirement is for a circle not 

less than 13 mm (0.51 in) in diameter, 

located within a specified distance from 

the horizontal centerline of each lower 

anchorage. The circle may be either 

solid or open, and may be with or 

without words, symbols or pictograms, 

but if a word, symbol or pictogram is 

used, its meaning must be explained in 

the vehicle’s owner’s manual. 

Decina’s 2005 survey 50 indicated that 

many consumers do not recognize that 

the lower anchorage bars are for 

installing child restraints or do not 

know that the marks indicate the 

presence of the lower anchorages. The 

survey showed that 55 percent of 

consumers who did not use lower 

anchorages to install a CRS, cited their 

lack of knowledge—not knowing what 

the anchorages were, that they were 

available in the vehicle, the importance 

of using them, or how to properly use 

them—as the reason for not using them. 

Since currently not all lower 

anchorages are required to have 

markings, and since the marks, when 

provided, often differ in appearance 

from one vehicle model to another, 

current education campaigns rely on the 

vehicle’s written instructions (typically 

the owner’s manual) to inform the 

consumer of the anchorage locations. 

This is likely one reason for the 

consumers’ lack of knowledge regarding 

the location of the lower and tether 

anchorages, since consumers’ use of the 

owner’s manual is low. 

We propose to amend FMVSS No. 225 

to require all vehicles to bear a 

standardized mark, developed by ISO as 

a voluntary standard,51 at the location of 

each lower anchorage bar, regardless of 

whether the anchorage bar is visible. 

The mark shows where the bar is 

located and identifies the bar as a lower 

anchorage. The mark must be a circle 

not less than 13 mm (0.51 in) in 

diameter located as specified in 

S9.5(a)(3) of FMVSS No. 225. The mark 

is shown below in Figure 14. We also 

propose to require manufacturers to 

include an explanation of the meaning 

of the lower anchorages markings in 

written information (e.g., in the vehicle 

owner’s manual, if one is provided). 

The symbol may be shown in mirror 

image, and the color of the symbol is at 

the option of the manufacturer. The 

symbol may be embossed. 

A number of commenters to the 2007 

LATCH public meeting believed that the 

conspicuity and identification of child 

restraint anchorages should be 

improved. They suggested adopting the 

ISO symbol to mark all child restraint 

anchorage systems in order to 

standardize the markings and help the 

caregiver identify the anchorages.52

We tentatively agree that adopting a 

standardized symbol would help. 

Requiring marks for all lower 

anchorages (regardless of whether the 

anchorages are visible) would improve 

conspicuity and identification of the 

anchorages. In addition, standardized 

anchorage marks would help in the 

development of a consistent and simple 

education message to improve 

awareness of child restraint anchorage 

systems and correct identification of the 

anchorages. Having the standardized 

markings may help the ISO symbols 

become a recognizable icon to 

consumers and may help simplify 

consumer information. A simplified 

message using the consistent marks 

could increase use of child restraint 

anchorage systems and child restraints 

generally, reduce installation errors, and 

ultimately reduce risk of injuries and 

fatalities. 

The ISO mark has already been 

adopted by a majority of vehicle 

manufacturers. NHTSA surveyed 24 MY 

2010 vehicles 53 to gather data on rear 

seat characteristics, and included data 

on the vehicles’ child restraint 

anchorage systems, such as the locations 

of the systems, how they were 

configured, and manufacturers’ 


emcdonald on DSK67QTVN1PROD with PROPOSALS2EP23JA15.012</GPH>
3762 Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 

54 ‘‘LATCH Usability in Vehicles,’’ supra. 

55 ISO 13216–1:1999 ‘‘Road vehicles— 

Anchorages in vehicles and attachments to 

anchorages for child restraint systems.’’ The ISO 

standard specifies that the tether anchorage symbol 

has to appear on a cover, if a cover is used to hide 

the tether anchorage. 

56This is the same dimensions for the tether 

anchorage markings specified in CMVSS No. 210.1. 

recommendations for using the systems. 

Data on vehicles’ child restraint 

anchorage systems in 98 top-selling MY 

2010–2011 vehicles is also available 

from the UMTRI LATCH Usability 

study.54

NHTSA analyzed the data from the 

agency’s survey and from the UMTRI 

LATCH Usability study to learn how 

vehicle manufacturers design and mark 

the lower anchorages in current 

vehicles. The combined survey data of 

122 vehicles showed that 34 percent of 

the vehicles had visible lower 

anchorages, 17 percent had lower 

anchorages with some cover (slits, doors 

or flaps), and all other vehicles had 

anchorages embedded in the seat bight). 

Also, 18 percent of the surveyed 

vehicles had no marks on the lower 

anchorages because the anchorages were 

visible, 76 percent were marked with 

the ISO symbol, and 6 percent were 

marked but without the ISO symbol. 

b. Marking Tether Anchorages 

FMVSS No. 225 currently does not 

require tether anchorages to be marked 

with any symbol identifying them as 

such. We propose amending FMVSS No. 

225 to require the vehicle to bear a 

standardized mark, also developed by 

ISO,55 at the location of each tether 

anchorage. The purpose of the marking 

requirement would be to increase 

consumer awareness of the existence of 

tether anchorages and to facilitate 

consumer education efforts. The mark 

shows the location of the tether 

anchorage and identifies the anchorage. 

Either of two ISO labeling symbols may 

be used (see Figure 15, below). Canada 

Motor Vehicle Safety Standard (CMVSS) 

No. 210.1, ‘‘User-friendly tether 

anchorages for restraint systems,’’ 

already requires vehicles to be labeled 

with one of the ISO tether labeling 

symbols. We propose to require the 

tether anchorage mark to be not less 

than 20 mm (0.8) in height.56

The symbol may be shown in mirror 

image, and the coloring of the symbol is 

at the option of the manufacturer. The 

symbol may be embossed. 

We propose that each tether 

anchorage would be marked, even if it 

is plainly visible. The mark would have 

to be centered at the middle of the tether 

anchorage bar. The shortest distance 

from the nearest edge of the mark to the 

center of the tether anchorage bar must 

be not more than 25 mm (1 in). There 

are no specifications for the distance of 

the marks from the tether anchorage in 

the ISO standard or in the CMVSS, but 

we tentatively conclude that specifying 

a maximum spacing to the mark is 

necessary to reduce confusion in 

identifying and locating the anchorages 

(discussed further below). We also 

propose to require manufacturers to 

include an explanation of the meaning 

of the tether anchorage markings in 

written information (e.g., in the vehicle 

owner’s manual, if one is provided). 

We propose to permit a tether 

anchorage to be covered with a cap, flap 

or cover, but the cap, flap or cover must 

be specifically designed to give access to 

the tether anchorage. We would not 

permit an ordinary floor mat to cover a 

tether anchorage; to be permitted, the 

floor mat would need to be specifically 

designed to give access to the tether 

anchorage, such as by having a flap that 

must be moved aside to access the 

anchorage. Moreover, if a cap, flap or 

cover is covering a tether anchorage, 

and the cap, flap or cover is 

permanently attached to the vehicle, the 

cap, flap or cover must be marked with 

the centered ISO symbol to inform 

consumers of the presence of the tether 

anchorage under it. If the cap, flap or 

cover is not permanently attached to the 

vehicle, the cap, flap or cover must be 

marked and the tether anchorage must 

also be separately marked, to make sure 

the anchorage would be marked in case 

the unattached cap, flap or cover is lost. 

We believe that alignment and 

proximity requirements are needed 

because some vehicles such as SUVs 

and station wagons have tether 

anchorages located in the seat back or 

the floor of the vehicle, along with other 

cargo anchorages or similar hardware. 

One common CRS installation error 

consumers commit is attaching a CRS 

tether hook to other cargo anchorages or 

hardware not designed for a tether. 

Since tether anchorages are not always 

marked with the ISO symbol or some 

other label identifying them as CRS 

tether anchorages, it is difficult for some 

consumers to distinguish which is the 


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tether anchorage. To illustrate, the MY 

2012 Chevrolet Avalanche has a labeled 

tether anchorage, yet it is still difficult 

to see which structure is the tether 

anchorage because the symbol is on a 

plastic surface located laterally from the 

tether anchorage, and the tether 

anchorage is not distinguishable from 

other metal structures near it. To 

improve the ease of use of tether 

anchorages, we are specifying the 

alignment and proximity of the ISO 

symbol with tether anchorages so that 

the symbol can be easily associated with 

the anchorages. 

NHTSA’s analysis of the data from the 

agency and UMTRI surveys of 122 

vehicles indicates that 41 percent of the 

vehicles had tether anchorages with no 

cover and 73 percent of the tether 

anchorages were marked with an ISO 

tether symbol. 

IX. Conspicuity and Identification of 

CRS Connectors 

As suggested by some commenters in 

response to the 2007 LATCH public 

meeting, the agency is also proposing to 

require the same ISO marks on CRS 

lower anchorage connectors and on 

tether hooks as we have proposed for 

the vehicle components. The required 

marks would be in a smaller minimum 

size compared to the vehicle markings. 

We propose that the symbol may be 

shown in mirror image, and the color of 

the symbol may be at the option of the 

manufacturer. The symbol may be 

embossed. 

a. Lower Anchorage Connectors 

We propose to amend FMVSS No. 213 

to require an ISO mark on the lower 

anchorage connectors. The mark would 

be the same standardized symbol used 

on the vehicle’s lower anchorages (see 

Figure 16). We tentatively believe that 

requiring CRS lower anchorage 

connectors to be marked with the same 

standardized symbol as the vehicle’s 

lower anchorages would make 

consumers more aware of the existence 

of child restraint anchorage systems. 

Further, it would also facilitate 

consumer education efforts by 

simplifying education messages. 

Consumers could be simply told to 

match the marks on the lower anchorage 

connectors to the lower anchorage 

marks on the vehicle. 

We are proposing that the ISO mark 

for the CRS lower anchorage connectors 

shall be at least 9 mm (0.35 in) in 

diameter. We propose a smaller 

minimum size of the mark for this mark 

compared to the size of the ISO mark for 

the vehicle lower anchorages (13 mm 

(.51 in)) to accommodate the smaller 

space available on the lower anchorage 

connectors for the mark. We also 

propose to require CRS manufacturers to 

include an explanation of the meaning 

of the lower anchorage connector 

markings in the CRS user’s manual. 

b. Tether Hook 

We propose to amend FMVSS No. 213 

to require one of the two ISO tether 

anchorage marks on the tether hook or 

the tether strap of a CRS. If the mark is 

on the tether strap or a tag attached to 

the strap, the mark must be located 

within one inch of the tether hardware 

assembly (tether hook and adjustment 

hardware). The two tether anchorage 

mark options are shown below in Figure 

17. Child restraint manufacturers would 

have the option of using either mark. 

We are proposing that the ISO mark 

must be at least 8 mm (0.35 in) in 

diameter. We propose a smaller 

minimum size for this mark compared 

to the size of the ISO mark for the 

vehicle tether anchorage (20 mm) to 

accommodate the smaller space 

available on the tether hook and the 

tether strap for the mark. We also 

propose to require CRS manufacturers to 

include an explanation of the meaning 

of the markings in the CRS user’s 

manual. 


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57We did not require child restraint anchorage 

systems in all three rear seating positions because 

demographics data did not show that there were a 

significant number of families with three or more 

children in child restraint systems. NHTSA also 

sought to minimize the cost of the rule to the extent 

reasonable. 

58 64 FR 10803, March 5, 1999, FMVS No. 225 

final rule. 

59Aram, M.L., Rockwell, T. ‘‘Vehicle Rear Seat 

Study-Technical Report,’’ NHTSA, 2012, which is 

in the docket for this NPRM. 60LATCH Usability study, supra. 61A Look Inside American Family Vehicles: 

National Study of 79,000 car seats, 2009–2010. Safe 

Kids USA. September 2011. 

62National Child Restraint Use Special Study, 

DOT HS 811 679, http://www-nrd.nhtsa.dot.gov/

Pubs/811679.pdf (full report pending). 

We tentatively believe that requiring a 

CRS tether hook or tether strap be 

marked with the same standardized 

symbol as the vehicle’s tether anchorage 

would make consumer education more 

effective. It would simplify education 

messages to be able to tell consumers to 

match the mark on a CRS tether hook or 

strap to a tether anchorage mark in the 

vehicle. 

X. Request for Comments 

a. Center Rear Seat 

FMVSS No. 225 (S4.4) requires 

vehicles with three or more forwardfacing rear DSPs to have a child restraint 

anchorage system at not fewer than two 

rear DSPs.57 Vehicles with three or more 

forward-facing rear DSPs are required to 

have a tether anchorage at a third 

forward-facing DSP. At least one tether 

anchorage must be in a forward-facing 

rear DSP other than an outboard DSP 

(i.e., a center seat). NHTSA recognized 

in the March 5, 1999 final rule 58 that 

vehicle manufacturers would probably 

install the lower anchorages in the two 

outboard seating positions because two 

child restraint anchorage systems were 

unlikely to fit side-by-side in the rear 

seat. The requirement for a third tether 

anchorage at a center seat provides 

consumers the option of installing child 

restraints in a center DSP, where there 

is the vehicle’s belt system and a tether 

anchorage. 

Information from the NHTSA rear seat 

survey 59 of 24 MY 2010 vehicles and 

the UMTRI survey 60 of 98 MY 2010– 

2011 vehicles shows that vehicle 

manufacturers have mostly opted to 

install the two required child restraint 

anchorage systems in the two outboard 

positions of the second row and only 

equip the center seat, if available, with 

a tether anchorage. A review of the 

combined data from the NHTSA rear 

seat survey and the UMTRI survey 

found that of vehicles with a rear center 

DSP, none offered two dedicated lower 

anchorages in the center position. 

Since the issuance of the final rule, 

many consumers have expressed a 

desire to use the rear center seating 

location to install a CRS using the lower 

anchorages. NHTSA requests comment 

on possible ways to address this. The 

Safe Kids survey 61 indicated that about 

a third of children in CRSs with internal 

harnesses (these CRSs are designed to be 

attached to the vehicle seat by the child 

restraint anchorage system or the seat 

belt) are installed in the rear center seat. 

One approach would be to require a 

set of lower anchorages in the rear 

center seating position, instead of one or 

both of the child restraint anchorage 

systems available at the outboard 

positions in most current vehicle 

models. We request comment on the 

feasibility of installing a child restraint 

anchorage system in a rear center 

seating position and on whether we 

should require such installation. We 

believe there are potential limitations to 

the center seat, such as space, hardware 

and other features that could impede 

accommodating a set of lower 

anchorages in the center seat, especially 

if there were a set of lower anchorages 

in the outboard seating position(s). 

In addition, we believe it is more 

desirable to have two usable child 

restraint anchorage systems available to 

consumers in the rear seat (in the 

outboard positions) rather than only one 

in the center. NCRUSS 62 data showed 

that of the 4,132 vehicles with children 

9 years old or younger in the second 

row, 329 vehicles (8 percent) had two 

children in child restraints with internal 

harnesses in the second row: 293 

vehicles (7 percent) had the two 

children in the outboard seating 

positions and 36 vehicles (0.9 percent) 

had the two children in adjacent seating 

positions, (one in an outboard seating 

position and one in the center seating 

position). Twenty vehicles (0.5 percent) 

of the 4,132 vehicles had the three 

children seated in a CRS in the second 

row: 8 vehicles (0.2 percent) had three 

children in child restraints with internal 

harnesses, 1 vehicle (0.025 percent) had 

2 child restraints with internal 

harnesses and a booster seat and 11 

vehicles (0.26 percent) had 2 booster 

seats and 1 child restraint with an 

internal harness. 

A second approach would be to 

require a third set of dedicated lower 

anchorages in the rear center seat. 

Although as with the previous approach 

we generally believe insufficient space 

and potential interference with 

hardware and other features could 

impede the installation of dedicated set 

of lower anchorages for the center 

seating position in all vehicles, UMTRI 

studied the feasibility of lower 


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63 Klinich, K.D., Manary, M.A., Orton, N.R. 

‘‘Feasibility of Center LATCH.’’ This report is in the 

docket for this NPRM. 64Aram, M.L., Rockwell, T. ‘‘Vehicle Rear Seat 

Study-Technical Report,’’ NHTSA, 2012, which is 

in the docket for this NPRM. 65CPSTs are trained in a program conducted by 

Safe Kids Worldwide to conduct child safety seat 

checks across the country and provide parents and 

caregivers hands-on assistance with proper use of 

child restraint systems and seat belts. 

66Rigid lower anchorage connectors are prevalent 

in Europe. Although they are not prevalent now in 

the U.S., they are permitted by FMVSS No. 213. ISO 

13216 Road vehicles—Anchorages in vehicles and 

attachments to anchorages for child restraint 

systems. http://www.iso.org/iso/home.htm. 

67See NPRM proposing to add a side impact test 

to FMVSS No. 213, 79 FR 4570, January 28, 2014. 

68The NHTSA rear seat study showed that all the 

vehicles except the Toyota Tundra had lower 

anchorage spacing less than 520 mm (20.4 in). The 

lower anchorages on the Toyota Tundra Crew and 

Extended Cab models were spaced greater than 580 

mm (22.8 in) apart. The Tundra owner’s manual 

Continued 

anchorages in the rear center seat 63 for 

85 MY 2010–2011 vehicles. UMTRI 

determined that vehicles with 710 mm 

(27.9 in) or more distance between the 

centerlines of outboard lower 

anchorages behind the driver and front 

passenger seats would have sufficient 

space to provide three sets of usable 

dedicated lower anchorages in the right, 

center, and left seating positions in the 

rear row. Based on this finding, UMTRI 

noted that 47 of the 85 vehicles 

surveyed (56 percent) could include a 

dedicated center lower anchorage 

position in addition to the two outboard 

anchorage positions without seat belt 

interference. 

We request comment on the feasibility 

of installing a dedicated child restraint 

anchorage system in the rear center 

seating position in addition to the two 

anchorage system in the outboard 

seating positions in vehicles with 710 

mm (27.9 in) or more distance between 

the centerlines of outboard lower 

anchorages. We request comment on the 

merits of requiring such installation. 

A third approach would be based on 

‘‘simulated’’ child restraint anchorage 

systems. A ‘‘simulated’’ child restraint 

anchorage system in the rear center 

seating position consists of the inboard 

lower anchorages of the child restraint 

anchorage systems in the two outboard 

seating positions and the tether 

anchorage in the center seat. The 

agency’s rear seat study 64 further found 

that of vehicles that had a rear center 

DSP (19 out of 24), 15.8 percent had 

instructions that permitted using a 

simulated child restraint anchorage 

system in the rear center seating 

position. Child passenger safety 

technicians (CPSTs) 65 recommend 

using a ‘‘simulated’’ child restraint 

anchorage system only if both the 

manufacturer of the child restraint and 

the manufacturer of the vehicle endorse 

using a simulated system. We are 

interested in learning more about how 

widely CRS manufacturers and vehicle 

manufacturers endorse use of simulated 

child restraint anchorage systems. We 

request comment on whether we should 

encourage, or possibly require, CRS 

manufacturers and vehicle 

manufacturers to include statements in 

the owner’s instructions endorsing the 

use of simulated child restraint 

anchorage systems in rear center seating 

positions. 

An issue arising with simulated child 

restraint anchorage systems relates to 

the spacing of the lower anchorages. 

FMVSS No. 225 requires the lower 

anchorages to be spaced 280 mm (11 in) 

apart, measured as the center-to-center 

distance of the lower anchorage bars. 

The distance between the lower 

anchorages is important to maintain 

uniformity with the spacing of rigid 

lower anchorage connectors on child 

restraints,66 and to standardize the 

configuration of the lower anchorages to 

increase the likelihood that consumers 

will attach a CRS to a child restraint 

anchorage system and not to a part of a 

vehicle seat that was not intended for 

anchoring a child restraint. If a vehicle 

has the two requisite child restraint 

anchorage systems with the lower 

anchorages spaced 280 mm (11 in) apart 

in the outboard DSPs, the agency 

questions whether the simulated child 

restraint anchorage system could have 

the lower anchorages spaced more than 

280 mm (11 in) apart? 

We tentatively conclude that the 

answer is yes. This is because virtually 

all CRS designs in the U.S. use flexible 

lower anchorage connectors (as opposed 

to rigid), which are uniquely capable of 

being installed using a ‘‘simulated’’ 

child restraint anchorage system with 

varying spacing widths. A vehicle’s 

lower anchorages would also be labeled, 

which would reduce the chances of the 

consumer attaching the child restraint 

lower anchorage connectors to the 

wrong part. Moreover, as discussed 

below, test data so far indicate that 

simulated child restraint anchorage 

systems perform satisfactorily from a 

crashworthiness point of view. 

NHTSA’s rear seat survey showed that 

the spacing of the inboard anchorages of 

the outboard seating positions varied 

from 270 to 675 mm (10.6 to 26.5 in). 

These included all vehicles regardless of 

whether a simulated child restraint 

anchorage system was recommended. 

Ford Motor Company (Ford) has 

endorsed in its manuals the use of 

simulated child restraint anchorage 

systems in Ford vehicles (e.g., Focus, 

Fusion) that have lower anchorages 

spaced less than 500 mm (19.6 in) apart, 

although the consumer is instructed to 

also obtain approval from the child 

restraint manufacturer before using a 

simulated child restraint anchorage 

system. We understand that Ford makes 

this recommendation based on 

independent tests demonstrating that 

distances greater than 280 mm (11 in) 

between lower anchorages would not 

have adverse effects on child passenger 

safety. 

UMTRI data also indicate that 

simulated child restraint anchorage 

systems perform satisfactorily. UMTRI 

conducted tests to quantify the effect of 

lower anchorage spacing on CRS 

performance. UMTRI performed a total 

of 15 sled tests using lower anchorage 

spacing of 280, 500 and 550 mm (11, 

19.6 and 21.6 in) with five unspecified 

models of CRSs using the FMVSS No. 

213 standard bench seat and test 

protocol. No installation issues, 

structural failures, or unusual dummy 

kinematics were observed. Wider 

spacing between lower anchorages (550 

mm (21.6 in) compared to 280 mm (11 

in)) only caused a lower anchorage peak 

load increase of 3–14 percent. No 

consistent trends or significant changes 

were found in seat back rotation (of rearfacing seats), peak head excursion, peak 

knee excursion, HIC, or chest 

acceleration. 

NHTSA’s testing also found 

satisfactory performance when using 

lower anchorages spaced greater than 

280 mm (11 in). A series of six frontal 

impact sled tests were conducted based 

on the FMVSS No. 213 dynamic test 

procedure. Six side impact sled tests 

were also conducted by rotating the 

FMVSS No. 213 seat fixture 90 degrees 

to the direction of impact and using the 

half-sine pulse and velocity that was 

used in NHTSA’s development of a 

proposed side impact test procedure.67

In the frontal impact sled tests, an allin-one child restraint (Alpha Omega 

Elite) was tested in its forward-facing 

mode with a HIII–3C dummy, and an 

infant carrier (Evenflo Discovery 5) was 

tested in the rear-facing mode with a 12- 

month-old CRABI dummy. In the side 

impact sled tests, the same all-in-one 

restraint was tested in its forward-facing 

mode with a Q-series 3-year-old child 

(Q3s) dummy and a different infant 

carrier (Graco Infant Safe Seat Step 1) 

was tested in the rear-facing mode with 

a 12-month-old CRABI dummy. Three 

tests of each CRS model were performed 

varying the lower anchorage spacing at 

280, 400 and 520 mm (11, 15.7, 20.4 

in).68 Similar to other studies, the 


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contains no statements on use of simulated child 

restraint anchorage systems in the center position. 

NHTSA considered the spacing on the Toyota 

Tundra vehicles outliers in the study, and thus 

chose 520 mm (20.4 in) as the widest lower 

anchorage spacing in its testing. 

69Amenson, T., Sullivan, L.K., ‘‘Dynamic 

Evaluation of LATCH Lower Anchor Spacing 

Requirements and Effect of Tether Anchor Location 

on Tether and Lower Anchor Loads.’’ 

70Based on 2013 vehicle production estimates 

submitted by vehicle manufacturers to NCAP. 

71 ‘‘LATCH Usability in Vehicles,’’ supra. 

72NCRUSS, supra. 

73 Id. 

74 Docket NHTSA–2010–0062; 76 FR 10637. 

results showed that increasing the lower 

anchorage spacing did not affect the 

injury measures of the dummies used in 

the frontal and side impact sled tests. 

The HIC values and head and chest 

accelerations were all within acceptable 

limits for the 3-year-old and 12-month 

old child dummies in 20 mph (32 km/ 

h) side impacts and 30 mph (48 km/h) 

frontal impacts. 

Given that there appears to be a lower 

need for the lower anchorages to be 280 

mm (11 in) apart in a simulated child 

restraint anchorage system than in the 

required child restraint anchorage 

systems, and given that simulated 

systems appear to be performing 

satisfactorily in dynamic testing, should 

we encourage or require CRS 

manufacturers and vehicle 

manufacturers to include, in instruction 

manuals, statements that endorse the 

use of simulated child restraint 

anchorage systems in rear center seating 

positions? An advantage of CRS and 

vehicle manufacturers endorsing 

simulated child restraint anchorage 

systems is to provide consumers the 

option of installing a CRS in the center 

rear seat with the lower anchorages plus 

tether at no cost. 

In examining this question, another 

issue to consider is whether the strength 

of the lower anchorages of the simulated 

system needs to be tested as a unit to 

FMVSS No. 225’s strength requirements 

(S9.4). We tentatively conclude that the 

answer is no, such testing appears 

redundant. This is because the strength 

of the lower anchorages would be 

assessed when the requisite child 

restraint anchorage systems at the 

outboard DSPs are tested. Further, our 

sled tests showed that the loads of the 

lower anchorages do not change 

significantly with the different lower 

anchorage spacing (280, 400 and 520 

mm).69 If the agency were to test the 

strength of a simulated child restraint 

anchorage system, a new test device 

would have to be developed because the 

test device currently used in FMVSS 

No. 225 is made to test only lower 

anchorages that are spaced 280 mm (11 

in) apart. 

A separate, but related, issue to 

consider is the potential problem of 

users using the same lower anchorage 

for the attachment of two lower 

anchorage connectors from adjacent 

child restraints. We request comments 

on solutions to mitigate this possible 

misuse problem. Ford includes a 

warning in vehicle owner’s manuals to 

‘‘never attach two child safety seats to 

the same anchor.’’ We request comment 

on whether vehicle manufacturers have 

received any complaints of confusion or 

reports of failures due to consumers 

installing two CRSs to the same lower 

anchorage. We also request comment on 

whether CPSTs have encountered this 

type of misuse in the field. 

There is also the issue of whether we 

should limit the lateral spacing of the 

lower anchorages of the simulated 

system, to prohibit vehicle 

manufacturers from recommending the 

use of the inboard lower anchorages if 

the anchorages are more than a specified 

distance, such as 520 mm (20.4 in). 

NHTSA has test data indicating 

satisfactory performance by CRSs 

attached to lower anchorages spaced a 

maximum 520 mm (20.4 in) apart. We 

do not have test data assessing lower 

anchorages spaced more than 520 mm 

(20.4 in) apart. 

b. Third Row 

FMVSS No. 225 requires that at least 

one of the two required child restraint 

anchorage systems be installed at a 

second row seating position in each 

vehicle that has three or more rows. In 

the 1997 NPRM underlying the 1999 

final rule establishing the standard, the 

agency requested comment on 

demographic data on the number of 

children typically transported in child 

restraints in family vehicles, to evaluate 

the need for additional child restraint 

anchorage systems in vehicles with 

three or more rows. The data we 

received did not show there were a 

significant number of families with 

three or more children in child 

restraints. Based on that data, NHTSA 

issued FMVSS No. 225 to require only 

two full child restraint anchorage 

systems in vehicles, plus the third tether 

anchorage. 

We request comment on whether 

FMVSS No. 225 should require child 

restraint anchorage systems or tether 

anchorages in all rear seating positions. 

Would requiring child restraint 

anchorage systems or tether anchorages 

in all rear seating positions meet the 

need for motor vehicle safety? Would 

the requirement protect the public 

against unreasonable risk of death or 

injury in an accident? There were a 

number of comments to the 2007 

LATCH public meeting expressing 

dissatisfaction with the number of child 

restraint anchorage systems that are 

present in the third row of vehicles. 

Some commenters said that consumers 

sometimes purchase vehicles with three 

or more rows to accommodate large 

families, but are unable to install all of 

the child restraints with child restraint 

anchorage systems because the third 

row does not have the systems. 

NHTSA examined MY 2013 fleet data 

to determine the availability of child 

restraint anchorage systems in the third 

row. We estimate that 57.2 percent of 

vehicles with three rows have one 

additional seating position equipped 

with a child restraint anchorage system 

(additional to those required), 10 

percent have two additional seating 

positions equipped with a child 

restraint anchorage system, and 32.7 

percent do not have child restraint 

anchorage systems in the third row.70

UMTRI’s LATCH Usability study 71

found that 71 percent of vehicles with 

a third row had one or two tether 

anchorages in the third row (most were 

in addition to those required), 9 percent 

had 3 tether anchorages in the third row 

(most were in addition to those 

required), and 19 percent did not have 

a tether anchorage in the third row. In 

assessing the safety need for the 

requirement, we will consider how 

frequently child restraint anchorage 

systems are used in the third row. 

Recent surveys show that only about 

2.4 72 to 4.5 percent 73 of children in 

CRSs with internal harnesses (CRSs that 

would use the lower anchorages) are 

seated in the third row. We believe that 

the low use of the third row is due in 

part to the small number of families 

with multiple children in CRSs with 

internal harnesses. 

There is also reduced space in the 

third row, which may make it difficult 

to fit most rear-facing CRSs. Information 

obtained from our February 25, 2011, 

request for comments notice 74 on the 

proposed NCAP Vehicle-CRS Fit 

program indicated that rear-facing CRSs 

are not likely to be used in the third row 

of a vehicle due to the available space. 

Several comments from vehicle 

manufacturers (Nissan, the Alliance of 

Automobile Manufacturers (Alliance) 

and the Association of Global 

Automakers) stated that vehicle designs 

present greater fit challenges for rearfacing CRSs in the third row. The 

groups stated that as CRSs continue to 

get larger and heavier and, as vehicles 

get smaller for fuel economy purposes, 

compatibility problems may become 


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75Policy Statement—Child Passenger Safety. 

Committee on Injury, Violence and Poison 

prevention March 21.2011) Pediatrics—Official 

Journal of the American Academy of Pediatrics. 

http://pediatrics.aappublications.org/content/early/

2011/03/21/peds.2011-0213.full.pdf+html (last 

accessed June 24, 2014). 

76This corresponds to the weight of a 50th to 80th 

percentile 4-year-old child. 

77 Generally lower anchorages would be used to 

attach a rear-facing child restraint until the child is 

15.8–18.1 kg (35–40 lb), and then used for a 

forward-facing restraint only while the child weighs 

14.5–22.6 kg (32 to 50 lb), depending on CRS 

weight. 

even more prevalent for the third row 

positions. Consumers Union (CU) also 

expressed that it may be unreasonable 

for some vehicles to be expected to fit 

rear-facing CRSs in the third row. CU 

stated that its own evaluations have 

shown a need to fold second row seats 

flat in order to install a third row rearfacing CRS since many second row seats 

are not adjustable fore/aft. General 

Motors (GM) stated that because second 

row seats are often not adjustable, it is 

often ‘‘impractical’’ to install rear-facing 

CRS in the third row. GM referenced 

data collected via Safe Kids from July 

2009 through January 2011 which 

showed that only one percent of 

children arrive at CRS checkpoints in a 

rear-facing CRS in the third row of a 

vehicle. UMTRI also commented that 

NHTSA’s NCAP Vehicle-CRS fit 

program should not require rear-facing 

CRSs to fit in all available third row 

positions because most parents and 

caregivers do not choose to install rearfacing CRSs in this row. 

NHTSA requests comment on 

whether FMVSS No. 225 should require 

child restraint anchorage systems in the 

third row if it is not altogether feasible 

to use rear-facing CRSs in the third row 

due to reduced space in that row. 

Information is also requested on the 

likelihood of consumers placing rearfacing CRSs in the third row, even if 

CRSs could fit in that row. Even if rearfacing child restraints could not or 

would not be installed using child 

restraint anchorage systems in the third 

row of a vehicle, are child restraint 

anchorage systems needed in the third 

row for forward-facing CRSs? The lower 

anchorages (plus tether anchorage) have 

a weight limit of 29.5 kg (65 lb) 

combined weight (CRS + child), 

meaning that consumers are instructed 

not to use the lower anchorages to 

attach a child restraint when the 

combined weight of the CRS and child 

exceeds 29.5 kg (65 lb). Consider also 

newly revised car seat use 

recommendations developed by NHTSA 

and by the American Academy of 

Pediatrics (AAP) 75 recommending that 

children should stay in a rear-facing 

CRS for as long as possible, within the 

top height and weight limit allowed by 

the CRS manufacturer. Most convertible 

CRSs specify a maximum child weight 

of 15.8–18 kg (35–40 lb) in the rearfacing mode.76 All this indicates that, 

for child restraint anchorage systems 

installed at third row seating positions, 

use of the lower anchorages in the third 

row might only be for a relatively short 

period for forward-facing restraints.77 If 

the lower anchorages were used after a 

child is transitioned to a forward-facing 

restraint (typically when the child 

reaches 15.8–18 kg (35–40 lb)), they 

would be used only while the child 

weighs 14.5 to 22.6 kg (32 to 50 lb), 

depending on the CRS weight. 

Would an amendment requiring child 

restraint anchorage systems or tether 

anchorages at some or all third row 

seating positions meet the requirements 

and considerations of § 30111(a) and (b) 

of the Vehicle Safety Act? Currently, for 

vehicles that do not have a tether 

anchorage at the rear center seating 

position in the second row, a tether 

anchorage is already required to be in a 

third row seating position. Thus, the 

proposed requirement would be to have 

a second or third tether anchorage in the 

third row. We also request comment on 

the feasibility of installing child 

restraint anchorage systems and tether 

anchorages in some or all rear seating 

positions in vehicles with three or more 

rows. 

We estimate that including lower 

anchorages in two additional seating 

positions would cost $7.2 million in 

vehicles with a third row ($2.50 per 

additional lower anchorage set) and $5.2 

million for tether anchorages in all third 

row seating positions ($1.33 per 

additional tether anchorage). Testing 

costs would increase $1,500 per 

additional child restraint anchorage 

system in each seating position for each 

vehicle model. We request comment on 

these cost estimates. 

c. Vehicles Currently Excluded From 

FMVSS No. 225 

1. We request comments on the 

feasibility of installing anchorages in 

convertibles. FMVSS No. 225 currently 

excludes convertibles from having to 

provide tether anchorages in rear seating 

positions. In comments to the 1997 

NPRM, GM and Mitsubishi stated that 

vehicle manufacturers have technical 

problems installing tether anchorages in 

convertibles because the vehicles have 

folding roofs, a stowage area behind the 

seat back for the top and its mechanism, 

and less rear seat space. NHTSA agreed 

that many convertibles could have 

design problems, and determined that it 

could not at that time readily separate 

those convertibles from those without 

technical problems. All convertibles 

were excluded from the requirement. 

Since the time FMVSS No. 225 was 

established, tether anchorage designs 

have evolved and vehicle manufacturers 

have had over 10 years of experience 

installing them to meet the standard. 

Among 35 convertible vehicle models 

with a rear seat in the 2013 vehicle fleet, 

ten are equipped with the full child 

restraint anchorage system (lower 

anchorages and tether anchorage) in two 

rear DSPs, 14 are equipped with only 

the lower anchorages at two rear DSPs, 

and 11 are not equipped with any 

anchorages. We propose deleting the 

exclusion of convertible vehicles from 

the requirement to provide tether 

anchorages. We wish to know why the 

technical problems that existed in 1997 

could not be overcome by the 

knowledge gained since 1997. We 

request comments on the feasibility of 

installing tether anchorages in the 

second row of convertibles, and in the 

first row in convertibles that do not 

have a second row. 

2. FMVSS No. 225, at S5(e), states that 

a vehicle— 

with a rear designated seating position for 

which interference with transmission and/or 

suspension components prevents the location 

of the lower bars of a child restraint 

anchorage system anywhere within the zone 

described by S9.2 or S15.1.2.2(b) such that 

the attitude angles of S15.1.2.2(a) could be 

met, is excluded from the requirement to 

provide a child restraint anchorage system at 

that position. However, except as provided 

elsewhere in S5 of this standard, such a 

vehicle must have a tether anchorage at a 

front passenger designated seating position. 

We request comment on whether this 

exclusion in S5(e) of FMVSS No. 225 is 

still needed. Since the issuance of 

FMVSS No. 225, manufacturers have 

gained experience in designing and 

installing vehicle seats with lower 

anchorages. We believe that vehicle 

seats could be installed with the lower 

anchorages so as not to interfere with 

transmission and/or suspension 

components. We have tentatively 

determined there is no longer a need for 

S5(e) and propose deleting it. 

d. Written Instructions 

NHTSA requests comments on the 

following possible ways to enhance the 

instructions provided consumers about 

using child restraint anchorage systems. 

1. Terminology 

Standard No. 225 (S12) requires 

vehicle manufacturers to provide 


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78We tentatively believe that the term ‘‘LATCH’’ 

is not clear enough for this purpose. As explained 

in an earlier footnote, the term ‘‘LATCH,’’ is an 

acronym for ‘‘Lower Anchors and Tethers for 

Children,’’ which was developed by industry as a 

consumer-friendly term to describe the child 

restraint anchorage system. While the term has been 

beneficial, it is also associated with some ambiguity 

and confusion. For one thing, various vehicle and 

CRS manufacturers have used the term ‘‘LATCH’’ 

in users’ manuals differently. ‘‘LATCH’’ has been 

used to refer to the ‘‘lower anchors’’ of a child 

restraint anchorage system, the full 3-point child 

restraint anchorage system, or to the CRS tether. 

Also, some consumers mistakenly associate CRS 

tether use only with attachment of the CRS using 

the lower anchorages of a child restraint anchorage 

system and not with a CRS attachment using the 

seat belt, a misconception possibly reinforced by 

the LATCH term. 

79NHTSA amended FMVSS No. 213 (February 

27, 2012, 77 FR 11626) (response to petition for 

reconsideration, February 25, 2014, 79 FR 10396) to 

require, among other things, a label on some CRSs, 

specifying the maximum child weight for using the 

lower anchorages to install child restraints with 

internal harnesses. Child weight limit = 29.5 kg 

(65lb)¥CRS weight. The 2014 final rule provided 

manufacturers an option of rounding the value up 

to the next multiple of 2.2 kg (5 lb) using a lookup 

table. 

80UMTRI Research Review—Crash Protection for 

Child Passengers: Rationale for Best Practice, 

January-March 2012, Volume 43, Number 1. 

http://www.umtri.umich.edu/content/rr_43_1.pdf. 

81Analysis of 1993–2007 NASS–CDS data files 

showed that the most-common AIS 2+ injuries 

among children restrained in rear seats were to the 

head and face and the most-common contacts for 

AIS 2+ injuries to these children were the seat and 

back support. An estimated 39 percent of AIS 2+ 

injuries in frontal crashes to children restrained in 

rear seats were to the head and face with 59 percent 

of these injuries resulting from contact with the seat 

and back support in front of the seating position. 

82We believe that tether use may particularly 

benefit taller children since they may experience 

greater head excursion than children with shorter 

seated height. 

83Additionally, our analysis of 1993–2007 

NASS–CDS data files indicate that 99.4 percent of 

crashes that involve restrained children have delta 

Vs less than or equal to 30 mph. 

84 Dynamic Load Measurement of Child Restraint 

Anchors in Frontal Vehicle Crashes Conducted by 

Transport Canada, See docket for this notice of 

proposed rulemaking. Details of the Transport 

Canada tests are available in Docket No. NHTSA– 

2014–0026. 

85The Transport Canada tests included a 56 km/ 

h (35 mph) frontal impact test of a Kia Forte with 

a Hybrid III 10 year-old child dummy restrained in 

Safety 1st Apex 65 CRS. The CRS was installed in 

the right outboard rear seat with lower and tether 

anchorages. The CRS weighed about 5.9 kg (13 lb). 

The combined weight (child+CRS) in this test was 

40.8 kg (90 lb), the peak vehicle acceleration was 

46 G. The total maximum anchorage loads 

measured in this test was 20,395 N (4,584.9 lb). The 

peak tether anchorage load was 7,759 N (1,744.3 lb). 

In that test, one of the lower anchorages failed but 

the tether anchorage was intact. 

written instruction for using child 

restraint anchorage systems and tether 

anchorages. Standard No. 213 (S5.6.1) 

specifies that child restraint systems 

provide printed instructions that 

include a step-by-step procedure for 

installing and securing the child 

restraint system in a vehicle. To 

improve the ease of use of child 

restraint anchorage systems, should the 

written information provided pursuant 

to Standards No. 225 and No. 213 use 

standardized terminology referring to 

the parts of the child restraint anchorage 

system and the components of the child 

restraint that connect the CRS to the 

vehicle? We request comment on 

whether requiring the following terms 

in child restraint and vehicle user’s 

manuals would help make the 

instructions clearer and more uniform: 

‘‘lower anchor(s)’’ and ‘‘tether anchor’’ 

for components of the child restraint 

anchorage system, and ‘‘lower anchor 

attachments’’ and ‘‘tether’’ for 

components of the CRS that are used to 

connect the CRS to the vehicle. A 

‘‘lower anchor attachment’’ is 

comprised of a ‘‘lower anchor 

connector’’ and a ‘‘lower anchor strap,’’ 

(for flexible lower anchor attachments) 

and a ‘‘tether’’ is comprised of a ‘‘tether 

hook’’ and a ‘‘tether strap.’’ Would 

standardized terminology improve 

consumer education efforts and increase 

the likelihood that child restraints 

would be used correctly? 78

2. Recommendation for Tether 

Anchorage Use 

NHTSA has tentatively determined 

that consumers should be instructed to 

always attach the CRS tether when 

restraining a child in a forward-facing 

CRS with an internal harness. Further, 

we believe that the instruction is 

appropriate when the CRS is installed 

using the lower anchorages of a child 

restraint anchorage system 79 and when 

the CRS is installed using a seat belt. 

The instruction is simple and would 

increase the ease of use of tether 

anchorages. The agency requests 

comments on this issue. 

If consumers were provided the 

simple and straightforward instruction 

to always attach the tether on the 

subject CRSs, we believe that tether use 

would increase, to the benefit of child 

passengers. In tests of a restrained 

dummy in forward-facing CRSs with 

harnesses, researchers found reduced 

head excursions due to tether use in 

frontal sled tests conducted at different 

speeds.80 Field data indicate that the 

most common injury to children 

restrained in child restraints is a head 

injury, and the source of injury is often 

contact with vehicle structures in front 

of the child restraint, such as the vehicle 

front seat back.81 We tentatively 

conclude that the use of tethers would 

reduce the magnitude of head 

excursions, and that reduced head 

excursions would result in fewer and 

less severe head injuries.82

Test data indicate that tether 

anchorages are extremely robust and 

would be reasonably able to withstand 

crash forces generated by virtually all 

restrained children in the subject CRSs. 

As explained below, NHTSA (a) 

estimated the dynamic loads that are 

imparted to tether anchorages in 47–56 

km/h (30–35 mph) crashes; 83 (b) 

assessed the strength of current tether 

anchorages through quasi-static 

laboratory testing; and (c) analyzed 

those data to estimate the dynamic loads 

that current anchorages would be able to 

withstand. NHTSA has tentatively 

determined that the analysis shows that 

tether anchorages are sufficiently strong 

to warrant an instruction that they 

should be used with all children 

restrained in a forward-facing CRS with 

an internal harness. 

Dynamic Loads 

The agency estimated the loads that 

are imparted to tether anchorages in 

relatively severe crashes. We reviewed 

Transport Canada data of tether 

anchorage loads measured in 47–56 km/ 

h (30–35 mph) full frontal rigid barrier 

crash tests of 20 MY 2009 and 2010 

vehicle models.84 Transport Canada 

placed child restraints in the outboard 

rear seating positions using the child 

restraint anchorage system (including 

the top tether). The program involved 28 

crash tests with the HIII–6C dummy and 

4 crash tests with the HIII–10C dummy. 

The weight of the CRSs used in the tests 

ranged from 5.1 kg (11.4 lb) to 11.3 kg 

(25.1 lb), and the combined weight of 

the CRS plus the 6 year-old and 10 yearold child dummies ranged from 28.1 to 

42.1 kg (62 to 93 lb). The peak vehicle 

acceleration in these crash tests ranged 

from 30 g to 68 g. 

In the Transport Canada tests, the 

total anchorage loads (sum of forces on 

the lower anchors and the tether anchor) 

ranged from 7,500 N (1,686 lb) to 20,800 

N (4,676 lb) with the HIII–6C dummy, 

and from 13,300 N (2,990 lb) to 20,400 

N (4,586 lb) with the HIII–10C dummy 

(see Tables A1(a) and A1(b) in the 

Appendix to the preamble of the 

February 25, 2014 final rule, 79 FR at 

10414–10416). The peak measured 

tether loads ranged from 677 N (152 lb) 

to 6,951 N (1,562 lb). The tether loads 

were approximately 8 percent to 50 

percent of the total measured anchorage 

loads, with an average of 29 percent of 

the total. There were no tether 

anchorage failures in any of the tests.85

We believe the data from the 

Transport Canada tests (involving 47–56 

km/h (30–35 mph) full frontal rigid 

barrier crash tests) represent just about 

all crashes involving restrained children 


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86Analysis of 1993–2007 NASS–CDS data files. 

87 Valentin-Ruiz, et al. ‘‘Quasi-static load tests to 

evaluate the strength of child restraint anchorage 

systems in MY 2006–2011 vehicles,’’ NHTSA 

Report, December 2013. See docket for this notice 

of proposed rulemaking. 

88 ‘‘Quasi-static load tests to evaluate the strength 

of child restraint anchorage systems in MY 2013 

vehicles,’’ ALPHA Technology Associates, Inc., 

December 2013. See docket for this notice of 

proposed rulemaking. 

89A few tether anchorage load tests were 

conducted until failure of the anchorages. However, 

after an equipment failure, the tether loads were 

limited to 10,000 N (2,248 lb) to prevent damage to 

the equipment. Since the tether anchorage tests 

were performed after the lower anchorage tests, and 

because some of the vehicle seats experienced 

excessive seat damage and deformation during the 

lower anchorage tests, achieving target loads in the 

tether anchorage tests was not possible in some 

vehicles. 

90Twenty-five tether anchors were tested to 

increased loads. In some tests, even though there 

was no anchorage failure, there was significant 

displacement and deformation of adjoining 

structures including the seat. In some cases, the 

target loads could not be achieved because of 

significant deformation of the seat structure. 

91See 68 FR 38208, 38218; June 27, 2003. 

92 Id. 

93When the combined weight of CRS+child 

exceeds 29.5 kg (65 lb), the CRS is to be attached 

by the seat belt plus tether. 

94Thus, the combined weight of CRS+child 

should not exceed 29.5 kg (65 lb) on the lower 

anchorages. 

95The CRS manufacturers instruct consumers to 

attach the CRS by the seat belt plus tether when the 

combined weight of CRS+child exceeds the weight 

limit of the child restraint anchorage system. 

in the subject CRSs in the U.S. Our 

analysis of real world crash data 

indicate that 99.4 percent of crashes that 

involve children in CRSs have delta Vs 

less than or equal to 30 mph.86 Thus, 

the Transport Canada data are indicative 

of the loads that are typically imposed 

on tether anchorages in virtually all 

crashes involving children in forwardfacing CRSs with internal harnesses. 

Measured Strength of Tether Anchors in 

the Current Fleet 

We conducted quasi-static tests on 

child restraint anchorages in 11 MY 

2006–2011 87 vehicle models and 18 MY 

2013 vehicle models 88 to assess the 

strength of the anchorages in the current 

fleet. (These vehicles were previously 

crash-tested, but NHTSA examined the 

vehicles to assess the condition of the 

child restraint anchorage systems to 

determine the suitability of the vehicles 

for inclusion in the quasi-static test 

program.) A static pull test was 

conducted on the tether anchors alone 

in three rear seating positions using a 

cable at loading rates similar to that 

specified in FMVSS No 225, but to 

higher loads or to anchorage failure.89

Among the 11 MY 2006–2011 vehicle 

models tested, 27 tether anchors were 

subjected to quasi-static loads. All the 

tether anchorages had strengths greater 

than 10,000 N (2,248 lb). Three tether 

anchorages were loaded to failure: 

Failure of the tether anchorage occurred 

at 11,900 N (2,675 lb) in the Ford 

Taurus, and 13,200 N (2,967 lb) and 

14,400 N (3,237 lb) in the Toyota Yaris. 

Among the 18 MY 2013 vehicle 

models tested, 43 tether anchors were 

subjected to quasi-static loads. All of the 

tether anchorages had strengths greater 

than 10,000 N (2,248 lb).90

Dynamic to Static Strength 

Although there is no consistent and 

direct correlation between dynamic to 

static strength of anchorage systems, 

and although the dynamic to static 

strength ratio is vehicle specific, data 

show that child restraint anchorage 

systems are able to withstand higher 

loads dynamically than statically. In the 

Alliance’s petition for reconsideration of 

the strength requirements of the 1999 

final rule establishing FMVSS No. 225, 

the Alliance indicated that the quasistatic test load of FMVSS No. 225 

simulating a high-speed impact should 

be approximately 50 percent of the 

expected dynamic load.91 Toyota also 

expressed the view 92 that the tether 

anchorage is able to withstand greater 

loads dynamically than statically, and 

estimated the value to be 30 percent. 

NHTSA has estimated the minimum 

dynamic loads that current anchorages 

would be able to withstand, given the 

information from the Alliance and 

Toyota regarding a dynamic to quasistatic load relationship and the quasistatic load data that were available from 

our test program. NHTSA’s quasi-static 

anchorage load tests showed that all 

tether anchorages had a static strength 

greater than 10,000 N (2,248 lb). 

Applying the more conservative 

assumption for a dynamic to static 

strength ratio of 1.3, the dynamic 

strength of the tether anchorages is 

expected to be greater than 13,000 N 

(2,922 lb). 

This estimated dynamic strength of 

13,000 N (2,990 lb) is about two times 

the tether anchorage loads measured in 

Transport Canada’s 47–56 km/h (30–35 

mph) frontal vehicle crash tests. In those 

tests, the peak measured tether loads 

ranged from 677 N (152 lb) to 6,951 N 

(1,562 lb). These data suggest that tether 

anchorages are unlikely to fail in 

virtually all crashes involving children 

restrained in forward-facing CRSs with 

internal harnesses. 

We have tentatively determined that 

the benefits of tether use for all children 

in the subject CRSs (regardless of child 

weight) outweigh the risks occurring 

from tether anchorage failure due to a 

higher combined weight and/or a higher 

severity crash. Thus, we believe that 

tethers should be attached regardless of 

child weight in forward-facing CRSs 

with internal harnesses.93 The tether 

supplements the primary attachment of 

the CRS to the vehicle seat (the primary 

attachment is accomplished by the 

lower anchorages of the child restraint 

anchorage system or by the vehicle seat 

belt). The primary attachment of the 

CRS to the vehicle should never fail in 

a crash since its integrity is needed to 

avoid a catastrophic uncoupling of the 

CRS from the vehicle.94 Further, child 

restraints are required by FMVSS No. 

213 to provide basic crash protection, 

including head protection, when 

installed only by the lower anchorages 

of a child restraint anchorage system or 

a seat belt, without the tether. The tether 

contributes to the basic crash protection 

provided by CRSs by enhancing head 

protection. Given the data that indicate 

that tether anchorages are already 

reasonably robust to withstand crash 

forces, we tentatively believe that tether 

use should be recommended for all 

children in forward-facing child 

restraints with internal harnesses so that 

the enhanced head protection can be 

achieved. 

Some CRS manufacturers are 

currently recommending tether use for 

all forward-facing child restraints with 

internal harnesses, regardless of the 

child weight.95 Given the available 

information on anchorage strength and 

on the benefits of tether use, we 

tentatively believe that such an 

instruction should be encouraged. We 

request comment on the merits of an 

instruction to consumers to use the 

tether to install all forward-facing child 

restraints with internal harnesses. 

XI. Proposed Effective Date 

The agency is proposing a lead time 

of 3 years from date of publication of the 

final rule. This means that vehicles 

manufactured on or after the date 3 

years after the date of publication of the 

final rule would be required to meet the 

ease of use requirements. In addition, 

child restraints manufactured on or after 

the date 3 years after the date of 

publication of the final rule would be 

required to meet the proposed FMVSS 

No. 213 requirements. We propose to 

permit optional early compliance with 

the requirements beginning 60 days 

after the date of publication of the final 

rule. 

We believe there is good cause for 

providing a 3-year lead time. The lead 

time is long enough for vehicle 

manufacturers to redesign the lower 

anchorages in their vehicles to meet the 


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3770 Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 

proposed requirements. The UMTRI 

LATCH Usability study survey of 98 MY 

2010–2011 vehicles indicates that 79 

percent will need some redesigning to 

comply with the new lower anchorage 

usability requirements, and a small 

percentage of vehicles that currently use 

webbing loops for tether anchorages will 

need to redesign the anchorages to rigid 

anchorage bars. We believe that these 

design modifications are minor and 

mainly concern the vehicle seat and not 

the vehicle structure. Some tether 

anchorages may have to be repositioned 

to provide the 165 mm (6.5 in) strap 

wrap-around distance. This 

modification to the tether anchorage 

location in some vehicles is also minor 

and would not require any changes to 

the vehicle structure. 

The 1999 final rule promulgating 

FMVSS No. 225 provided a 3-year lead 

time (with a phase-in) for compliance 

with the lower anchorage requirements 

even though vehicles did not have lower 

anchorages. The main requirements 

proposed by this NPRM involve only 

adjustments to the positioning of lower 

anchorages and tether anchorages 

already installed pursuant to FMVSS 

No. 225 and some modifications to seat 

cushion stiffness. Therefore, the agency 

is proposing a 3-year lead time, with no 

phase-in, since we believe that the lead 

time is sufficient for vehicle 

manufacturers to reposition lower 

anchorages and tether anchorages, if 

needed, to change seat cushion 

characteristics, and to mark the lower 

anchorages and tether anchorage with 

the ISO signage. Three years would also 

be sufficient time to change the 

relatively few tether anchorages that are 

made of webbing material to rigid 

anchorage bars. The three years of lead 

time would provide sufficient time for 

manufacturers to change the written 

instructions provided with the vehicles 

as proposed. 

We also believe that 3 years of lead 

time provides sufficient time for child 

restraint manufacturers to meet the 

proposed rule. Comments are requested 

on whether this lead time should be 

shortened. This NPRM proposes minor 

changes to the requirements applying to 

CRSs. The requirements are: Limiting 

the length of the tether hardware 

assembly (consisting of a tether hook 

and hardware to tighten and loosen the 

tether strap) to 165 mm (6.5 in) (UMTRI 

estimated that about 30 percent of CRS 

models might need some changes to the 

tether hardware assembly to meet the 

165 mm (6.5 in) limit), marking the 

lower anchorage connectors and the 

tether connector (hook) with the ISO 

marking, and changing written 

instructions provided to consumers to 

include the defined terms and 

instruction on using the tether. These 

are minor changes that do not affect the 

shell or any other structure of the child 

restraint. We believe the marking and 

user’s instructions amendments could 

be implemented in a year. Would it be 

worthwhile to implement some or all of 

the proposed changes to child restraints 

before the proposed changes are 

implemented for vehicles, particularly 

the marking and user’s written 

instructions requirements? The 

combined data from NHTSA’s survey of 

24 MY 2010 vehicles and from UMTRI’s 

LATCH Usability study indicate that, of 

the 122 vehicles surveyed, 76 percent of 

lower anchorages and 73 percent of 

tether anchorages were marked with the 

ISO symbol. Since many child restraint 

anchorage systems are already being 

marked with the ISO symbol, we 

tentatively conclude that it might be 

beneficial to have a shorter lead time to 

mark the CRS lower anchorage 

connectors and tether hook with the ISO 

symbol than 3 years after publication of 

a final rule. In that way, consumers can 

begin learning sooner rather than later 

to match the ISO symbols on CRSs with 

the ISO symbols in the vehicle. 

XII. Regulatory Notices and Analyses 

Executive Order (E.O.) 12866 

(Regulatory Planning and Review), E.O. 

13563, and DOT Regulatory Policies and 

Procedures 

The agency has considered the impact 

of this rulemaking action under E.O. 

12866, E.O. 13563, and the Department 

of Transportation’s regulatory policies 

and procedures. This rulemaking was 

not reviewed by the Office of 

Management and Budget under E.O. 

12866, ‘‘Regulatory Planning and 

Review.’’ The rulemaking action has 

also been determined to be not 

significant under the Department’s 

regulatory policies and procedures. 

The total cost of the proposed rule is 

estimated to be $1.32 million. The cost 

is primarily due to the ISO labeling 

requirement. 

Vehicle Costs 

The agency tentatively concludes that 

the proposed requirements for 

attachment force, clearance angle and 

anchorage depth would not add costs to 

the vehicle. To meet the requirements, 

vehicle seat designs would change, but 

the redesigns would involve simple 

modifications to the existing vehicle 

materials (i.e., the seat cushion) and not 

an addition to the vehicle or a change 

to the vehicle structure. We estimate 

that vehicle seats in approximately 79 

percent of vehicles would be affected, 

but the changes to meet the requirement 

would only call for steps such as cutting 

larger open areas in the seat foam 

surrounding the lower anchorage bars, 

or repositioning the seat cushion 

relative to the anchorage bars. 

Redesigning the vehicle seats to meet 

the requirements would be a one-time 

event, and would be so minor that the 

costs for the redesigns would be slight. 

In addition, NHTSA proposes to provide 

three years of lead time before 

manufacturers must certify their 

vehicles as meeting the final rule 

requirements. That lead time would 

provide sufficient time for 

manufacturers to minimize costs since 

they may incorporate designs that meet 

the new requirements into their regular 

vehicle redesign and manufacturing 

cycle. 

The agency estimates that the cost of 

conducting the lower anchorage 

usability tests for evaluating attachment 

force, clearance angle, and anchorage 

depth would be an average of $300 per 

vehicle. We estimate that 560 models 

comprise the 16.32 million vehicles sold 

annually that are subject to this NPRM. 

The total testing cost for 560 models is 

$168,000. This testing cost, distributed 

among the 16.32 million vehicles sold 

annually, with an average model life of 

10 years, is approximately $0.001 per 

vehicle. 

With regard to the proposed tether 

anchorage requirements, some tether 

anchorages in existing vehicles will 

have to be moved further from the head 

restraint to meet the minimum strap 

wrap-around distance requirement. 

NHTSA has tentatively determined that 

such a change would not add cost to the 

vehicle, since new material, or 

substantial change to vehicle design, 

would not be needed. The agency 

estimates that the cost of conducting the 

tether location measurement would be 

approximately $50. We estimate that 

560 models comprise 16.32 million 

vehicles sold annually, for an annual 

testing cost of $28,000. This testing cost, 

distributed among the 16.32 million 

vehicles sold annually, with an average 

model life of 10 years, is significantly 

less than $0.001 per vehicle. Since these 

testing costs per vehicle (lower 

anchorage usability tests and tether 

anchorage location test) is so small, it is 

not included in the overall costs of the 

rule). 

A very small percentage of vehicles 

that currently have webbing loops for 

tether anchorages will need to make the 

anchorages rigid bars. It is difficult to 

estimate the redesign costs of these 

vehicles because the number of vehicles 

affected is very small. Comments are 

requested on the redesign costs and 


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Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 3771 

96Eichelberger, A.H., Decina, L.E., Jermakian, J.S., 

McCartt, A.T., ‘‘Use of top tether with forward 

facing child restraints: Observations and driver 

interviews,’’ Insurance Institute for Highway Safety, 

April 2013. 

97NCRUSS, DOT HS 811 679, http://wwwnrd.nhtsa.dot.gov/Pubs/811679.pdf. 

98Final Economic Assessment FMVSS No. 213 

and 225 Child Restraint Systems and Child 

Restraint Anchorage Systems, 1999, Docket No. 

NHTSA–1998–2290, Item No. 27. Table 6b of the 

Final Economic Assessment shows a head injury 

measure for the 3-year-old child dummy of 503 

when tether is used and 631 when tether is not 

used. 

99Final Economic Assessment FMVSS No. 213 

and 225 Child Restraint Systems and Child 

Restraint Anchorage Systems, 1999, Docket No. 

NHTSA–1998–3390, Item No. 27. Table 4 of the 

Final Economic Assessment shows a head injury 

measure for the 6-year-old child dummy of 642 for 

tight installation and 697 for loose installation. 

certification costs for these vehicles, and 

how a 3-year lead time for complying 

with the new requirements affects those 

costs. 

The proposal would require all the 

lower anchorages and tether anchorages 

to be marked with the ISO signage. We 

estimate there are 16.32 million vehicles 

produced annually, with 31.9 million 

lower anchorage-equipped seating 

positions and 42.9 million tether 

anchorage-equipped seating positions. 

Our survey of 122 MY 2010–2011 

vehicles indicates that 82 percent of 

lower anchorages and 73 percent of 

tether anchorages already are marked 

with the ISO symbol. We estimate the 

cost of ISO marks for a set of lower 

anchorages to be $0.05 and the cost of 

marking the tether anchorage would be 

$0.025. The total incremental cost to 

have ISO marks for all lower anchorages 

in the fleet is $0.29 million (= $0.05 × 

0.18 × 31.9). The total incremental cost 

to have ISO marks for all tether 

anchorages in the fleet is $0.29 million 

(= $0.025 × 0.27 × 42.9). Therefore, the 

total incremental cost of labeling all 

child restraint anchorages with 

appropriate ISO marks is about $0.58 

million. 

The cost of changing the written 

instructions accompanying the vehicle 

is expected to be negligible 

(significantly less than $0.01). 

Child Restraint System Costs 

The proposal would require the 

length of the tether hardware assembly 

(which consists of a tether hook and a 

webbing tightening mechanism) of child 

restraint systems to be not greater than 

165 mm (6.5 in). About 30 percent of 

forward-facing child restraints may need 

some minor modification to the tether 

hardware assembly to meet the length 

limit. We tentatively conclude that a 3- 

year lead time is sufficient for this 

purpose. The tether hardware assembly 

is a simple part that can be easily 

produced and attached to child restraint 

tethers. 

The NPRM also proposes to require 

the ISO marks to be placed on child 

restraint anchorage connectors. The 

agency estimates that 14.9 million CRSs 

are sold in the U.S. annually, of which 

75 percent (11.18 million infant carriers, 

convertibles, forward-facing only, 

combination, and 3-in-1 CRSs) have 

lower anchorage connectors and of 

which 48 percent (7.18 million 

convertibles, forward-facing only, 

combination, and 3-in-1 CRSs) have 

tethers. Applying an estimated cost of 

$0.05 for ISO marks on one set of lower 

anchorage connectors, the total cost for 

all applicable CRSs is $0.56 million 

(= $0.05 × 11.18 million). Applying an 

estimated cost of $0.025 for ISO marks 

on a tether anchorage connector, the 

total cost for all applicable CRSs is 

$0.18 million (= $0.025 × 7.18 million). 

Therefore, we estimate that the total cost 

of adding ISO marks to child restraint 

anchorage connectors is $0.74 million (= 

$0.56 million + $0.18 million). 

The cost of changing the written 

instructions accompanying the CRS is 

expected to be negligible (significantly 

less than $0.01). 

Benefits 

We expect the new usability 

requirements would improve correct 

(tight) installation of CRSs, and increase 

tether use. Survey data indicate that the 

tether is used in 56 percent of child 

restraint installations, but is used 

correctly in only 39 percent of the 

installations.96 The data also indicate 

that approximately 60 percent of child 

restraints are installed using the lower 

anchorages.97

Assuming a 5 percent increase in 

tether use, and using data on the 

reduction in injury measures in sled 

tests with and without tether use,98 the 

agency estimates that the proposed 

changes to the tether anchorage 

requirements of FMVSS Nos. 213 and 

225 could save 1.5 lives and prevent 4 

moderate to severe injuries. Assuming a 

5 percent increase in correct CRS 

installation due to the proposed 

improvements to the lower anchorage 

requirements, and using the reduction 

in injury measures in sled tests with 

loose and tight installations,99 the 

agency estimates that the proposed 

usability requirements for the lower 

anchorages could save 1.4 lives and 

prevent 2.4 moderate to severe injuries. 

Therefore, we estimate that the 

proposed requirements could save about 

2.9 lives and prevent 6 moderate to 

severe injuries per year. 

The proposed rule would also 

streamline FMVSS No. 225 by removing 

outdated material, such as sections of 

the standard that relate to requirements 

that were phased in when the standard 

was adopted. Streamlining FMVSS No. 

225, a result of retrospectively 

reviewing the standard, would be 

consistent with E.O. 13563, ‘‘Improving 

Regulation and Regulatory Review’’ and 

the plain language provisions of E.O. 

12866. 

Regulatory Flexibility Act 

Pursuant to the Regulatory Flexibility 

Act (5 U.S.C. 601 et seq., as amended by 

the Small Business Regulatory 

Enforcement Fairness Act (SBREFA) of 

1996) whenever an agency is required to 

publish a notice of proposed rulemaking 

or final rule, it must prepare and make 

available for public comment a 

regulatory flexibility analysis that 

describes the effect of the rule on small 

entities (i.e., small businesses, small 

organizations, and small governmental 

jurisdictions), unless the head of an 

agency certifies the rule will not have a 

significant economic impact on a 

substantial number of small entities. 

Agencies must also provide a statement 

of the factual basis for this certification. 

I certify that this proposed rule would 

not have a significant economic impact 

on a substantial number of small 

entities. NHTSA estimates there to be 29 

manufacturers of child restraints, none 

of which are small businesses. Even if 

there were a small CRS manufacturer, 

the impacts of this proposed rule would 

not be significant. This NPRM proposes 

minor changes to the requirements 

applying to CRSs. The requirements are: 

Limiting the length of the tether 

hardware assembly (tether hook and 

tightening mechanism) to 165 mm (6.5 

in) (UMTRI estimated that about 30 

percent of CRS models might need some 

changes to the tether hardware assembly 

to meet the 165 mm (6.5 in) limit), 

marking the lower anchorage connectors 

and the tether hook or tether strap with 

the ISO marking, and changing written 

instructions provided to the owners to 

include the defined terms and 

instruction on using the tether. These 

are minor changes that do not affect the 

shell or any other structure of the child 

restraint. We believe that there would be 

no incremental cost due to limiting the 

tether hardware assembly to 165 mm 

(6.5 in) since the tether hardware 

assembly costs would not increase 

because of the requirement. We estimate 

that the cost of marking the CRS child 

restraint anchorage connectors would be 

about $0.05 per set of lower anchorage 

connectors and $0.03 per tether hook. 

Changing the written instructions 


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accompanying CRSs would be negligible 

(significantly less than $0.01). 

There are six small vehicle 

manufacturers. We believe that the 

proposed rule would not have a 

significant economic impact on these 

manufacturers. The vehicles produced 

by the small manufacturers already have 

to provide child restraint anchorage 

systems and tether anchorages meeting 

FMVSS No. 225, unless the vehicle is 

excluded from the standard. We believe 

that the changes proposed in this NPRM 

only make adjustments to the physical 

features of the anchorage systems, 

adjustments that should have a positive 

impact on the ease of use of the systems, 

but that are small in terms of affecting 

the overall configuration of current 

anchorage systems. We estimate the cost 

of marking the lower anchorages and the 

tether anchorages would only be <$0.12 

approximately (depending on the 

number of anchorages in the vehicle) 

per vehicle. The cost of changing the 

written instructions accompanying the 

vehicle would be negligible (<$0.01). 

Final-stage vehicle manufacturers buy 

incomplete vehicles and complete the 

vehicle. Alterers modify new vehicles. 

In either case, NHTSA tentatively 

concludes that the impacts of a final 

rule on such entities would not be 

significant. Final-stage manufacturers or 

alterers installing rear seats in vehicles 

subject to FMVSS No. 225 already have 

to provide child restraint anchorage 

systems and tether anchorages meeting 

FMVSS No. 225. We believe that the 

changes proposed in this NPRM only 

make small adjustments to the physical 

features of the anchorage systems, 

adjustments that should have a positive 

impact on the ease of use of the systems, 

but that are minor in terms of the impact 

on the configuration of current 

anchorage systems. We estimate the cost 

of marking the lower anchorages and the 

tether anchorages would be less than 

$0.12 per vehicle (depending on the 

number of anchorages in the vehicle). 

The cost of changing the written 

instructions accompanying the vehicle 

would be negligible (significantly less 

than $0.01 per vehicle). 

National Environmental Policy Act 

NHTSA has analyzed this proposed 

rule for the purposes of the National 

Environmental Policy Act and 

determined that it would not have any 

significant impact on the quality of the 

human environment. 

Executive Order 13132 (Federalism) 

NHTSA has examined today’s 

proposed rule pursuant to Executive 

Order 13132 (64 FR 43255, August 10, 

1999) and concluded that no additional 

consultation with States, local 

governments or their representatives is 

mandated beyond the rulemaking 

process. The agency has concluded that 

the rulemaking would not have 

sufficient federalism implications to 

warrant consultation with State and 

local officials or the preparation of a 

federalism summary impact statement. 

The proposed rule would not have 

‘‘substantial direct effects on the States, 

on the relationship between the national 

government and the States, or on the 

distribution of power and 

responsibilities among the various 

levels of government.’’ 

NHTSA rules can preempt in two 

ways. First, the National Traffic and 

Motor Vehicle Safety Act contains an 

express preemption provision: When a 

motor vehicle safety standard is in effect 

under this chapter, a State or a political 

subdivision of a State may prescribe or 

continue in effect a standard applicable 

to the same aspect of performance of a 

motor vehicle or motor vehicle 

equipment only if the standard is 

identical to the standard prescribed 

under this chapter. 49 U.S.C. 

30103(b)(1). It is this statutory command 

by Congress that preempts any nonidentical State legislative and 

administrative law addressing the same 

aspect of performance. 

The express preemption provision 

described above is subject to a savings 

clause under which ‘‘[c]ompliance with 

a motor vehicle safety standard 

prescribed under this chapter does not 

exempt a person from liability at 

common law.’’ 49 U.S.C. 30103(e) 

Pursuant to this provision, State 

common law tort causes of action 

against motor vehicle manufacturers 

that might otherwise be preempted by 

the express preemption provision are 

generally preserved. However, the 

Supreme Court has recognized the 

possibility, in some instances, of 

implied preemption of such State 

common law tort causes of action by 

virtue of NHTSA’s rules, even if not 

expressly preempted. This second way 

that NHTSA rules can preempt is 

dependent upon there being an actual 

conflict between an FMVSS and the 

higher standard that would effectively 

be imposed on motor vehicle 

manufacturers if someone obtained a 

State common law tort judgment against 

the manufacturer, notwithstanding the 

manufacturer’s compliance with the 

NHTSA standard. Because most NHTSA 

standards established by an FMVSS are 

minimum standards, a State common 

law tort cause of action that seeks to 

impose a higher standard on motor 

vehicle manufacturers will generally not 

be preempted. However, if and when 

such a conflict does exist—for example, 

when the standard at issue is both a 

minimum and a maximum standard— 

the State common law tort cause of 

action is impliedly preempted. See 

Geier v. American Honda Motor Co., 

529 U.S. 861 (2000). 

Pursuant to Executive Order 13132 

and 12988, NHTSA has considered 

whether this proposed rule could or 

should preempt State common law 

causes of action. The agency’s ability to 

announce its conclusion regarding the 

preemptive effect of one of its rules 

reduces the likelihood that preemption 

will be an issue in any subsequent tort 

litigation. To this end, the agency has 

examined the nature (e.g., the language 

and structure of the regulatory text) and 

objectives of today’s proposed rule and 

finds that this proposed rule, like many 

NHTSA rules, would prescribe only a 

minimum safety standard. As such, 

NHTSA does not intend that this 

proposed rule would preempt state tort 

law that would effectively impose a 

higher standard on motor vehicle 

manufacturers than that established by 

today’s proposed rule. Establishment of 

a higher standard by means of State tort 

law would not conflict with the 

minimum standard proposed here. 

Without any conflict, there could not be 

any implied preemption of a State 

common law tort cause of action. 

Civil Justice Reform 

With respect to the review of the 

promulgation of a new regulation, 

section 3(b) of Executive Order 12988, 

‘‘Civil Justice Reform’’ (61 FR 4729, 

February 7, 1996) requires that 

Executive agencies make every 

reasonable effort to ensure that the 

regulation: (1) Clearly specifies the 

preemptive effect; (2) clearly specifies 

the effect on existing Federal law or 

regulation; (3) provides a clear legal 

standard for affected conduct, while 

promoting simplification and burden 

reduction; (4) clearly specifies the 

retroactive effect, if any; (5) adequately 

defines key terms; and (6) addresses 

other important issues affecting clarity 

and general draftsmanship under any 

guidelines issued by the Attorney 

General. This document is consistent 

with that requirement. 

Pursuant to this Order, NHTSA notes 

as follows. The preemptive effect of this 

proposed rule is discussed above. 

NHTSA notes further that there is no 

requirement that individuals submit a 

petition for reconsideration or pursue 

other administrative proceeding before 

they may file suit in court. 


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100 Draft ISO Standard 29061–1:2010, ‘‘Road 

vehicles—Methods and criteria for usability 

evaluation of child restraint systems and their 

interface with vehicle anchor systems—Part 1: 

Vehicles and child restraint systems equipped with 

ISOFIX anchors and attachments,’’ (November 

2010). 

101 Draft SAE J2893, ‘‘Guidelines for 

Implementation of the Child Restraint Anchorage 

System in Motor Vehicles and Child Restraint 

Systems.’’ 

Paperwork Reduction Act (PRA) 

Under the Paperwork Reduction Act 

of 1995, a person is not required to 

respond to a collection of information 

by a Federal agency unless the 

collection displays a valid OMB control 

number. Before seeking OMB approval, 

Federal agencies must provide a 60-day 

public comment period and otherwise 

consult with members of the public and 

affected agencies concerning each 

collection of information requirement. 

NHTSA believes the proposed 

requirement to explain the meaning of 

the proposed standardized marks on the 

lower anchorage connectors and the 

tether hook in the CRS instruction 

manual would constitute a ‘‘collection 

of information’’ requirement for child 

restraint system manufacturers. We are 

providing a 60-day comment period on 

reporting burdens and other matters 

associated with the instruction 

requirement. 

OMB has promulgated regulations 

describing what must be included in the 

request for comment document. Under 

OMB’s regulation (5 CFR 1320.8(d)), an 

agency must ask for public comment on 

the following: 

Whether the proposed collection of 

information is necessary for the proper 

performance of the functions of the 

agency, including whether the 

information will have practical utility; 

The accuracy of the agency’s estimate 

of the burden of the proposed collection 

of information, including the validity of 

the methodology and assumptions used; 

How to enhance the quality, utility, 

and clarity of the information to be 

collected; 

How to minimize the burden of the 

collection of information on those who 

are to respond, including the use of 

appropriate automated, electronic, 

mechanical, or other technological 

collection techniques or other forms of 

information technology, e.g. permitting 

electronic submission of responses. 

In compliance with these 

requirements, NHTSA asks for public 

comments on the following collection of 

information: 

Title: ‘‘Consolidated Child Restraint 

System Registration, Labeling and 

Defect Notifications.’’ 

OMB Control Number: 2127–0576. 

Requested Expiration Date of 

Approval: Three years from the 

approval date. 

Type of Request: Revision of a 

currently approved collection. 

Affected Public: Business, Individuals 

and Households. 

Summary of the Collection of 

Information: This rulemaking proposes 

to require CRS manufacturers to include 

an explanation of the meaning of the 

standardized markings on the lower 

anchorage connectors and the tether 

hook (if available on the CRS) in the 

printed instructions already provided 

with each new CRS. The standardized 

markings on the CRS lower anchor 

connector and tether hook would help 

in the development of a consistent and 

simple education message to improve 

awareness of child restraint anchorage 

systems and improve correct installation 

of child restraints. 

NHTSA anticipates a change to the 

hour burden or costs associated with 

FMVSS No. 213 due to inclusion of an 

explanation of the meaning of the 

standardized markings in the CRS 

printed instructions. Child restraint 

manufacturers produce, on average, a 

total of approximately 4,500,000 child 

restraints per year. We estimate 2 

seconds of additional burden per child 

restraint for the addition of the 

information on the existing instruction 

manual (2 sec × 4,500,000 units = 

9,000,000 seconds = 2,500 hours). 

Estimated Additional Annual Burden: 

2,500 Hours. 

Comments are invited on: Whether 

the proposed collection of information 

is necessary for the proper performance 

of the functions of the Department, 

including whether the information will 

have practical utility; the accuracy of 

the Department’s estimate of the burden 

of the proposed information collection; 

ways to enhance the quality, utility and 

clarity of the information to be 

collected; and ways to minimize the 

burden of the collection of information 

on respondents, including the use of 

automated collection techniques or 

other forms of information technology. 

You may submit comments (identified 

by the DOT Docket ID Number above) 

by any of the following methods: 

Federal eRulemaking Portal: Go to 

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

online instructions for submitting 

comments. Mail: Docket Management 

Facility: U.S. Department of 

Transportation, 1200 New Jersey 

Avenue SE., West Building Ground 

Floor, Room W12–140, Washington, DC 

20590–0001. Hand Delivery or Courier: 

West Building Ground Floor, Room 

W12–140, 1200 New Jersey Avenue SE., 

Washington, DC 20590–0001 between 9 

a.m. and 5 p.m. ET, Monday through 

Friday, except Federal holidays. Fax: 

202–493–2251. Regardless of how you 

submit your comments, please provide 

the docket number of this document. 

You may call the Docket at (202) 366– 

9324. 

Note that all comments received will 

be posted without change to http://

www.regulations.gov, including any 

personal information provided. Anyone 

is able to search the electronic form of 

all comments received into any of our 

dockets by the name of the individual 

submitting the comment (or signing the 

comment, if submitted on behalf of an 

association, business, labor union, etc.). 

You may review DOT’s complete 

Privacy Act Statement in the Federal 

Register published on April 11, 2000 

(65 FR 19477–78). 

National Technology Transfer and 

Advancement Act 

Under the National Technology 

Transfer and Advancement Act of 1995 

(NTTAA) (Pub. L. 104–113), all Federal 

agencies and departments shall use 

technical standards that are developed 

or adopted by voluntary consensus 

standards bodies, using such technical 

standards as a means to carry out policy 

objectives or activities determined by 

the agencies and departments. 

Voluntary consensus standards are 

technical standards (e.g., material 

specifications, test methods, sampling 

procedures, and business practices) that 

are developed or adopted by voluntary 

consensus standards bodies, such as the 

International Organization for 

Standardization (ISO) and the Society of 

Automotive Engineers (SAE). The 

NTTAA directs us to provide Congress, 

through OMB, explanations when we 

decide not to use available and 

applicable voluntary consensus 

standards. 

NHTSA reviewed various procedures 

and requirements developed by ISO and 

SAE to improve the ease of use of child 

restraint anchorage systems. ISO 

developed a rating system that evaluates 

and rates the usability of the CRS’s 

ISOFIX features, the vehicle’s ISOFIX 

system, and the interaction between the 

two.100 SAE developed a draft 

recommended practice providing 

guidelines to vehicle manufacturers to 

consider when designing characteristics 

of vehicle lower and upper (tether) 

anchorages, and to CRS manufacturers 

for corresponding features of CRS lower 

anchorage and tether connectors.101 In 

our review, we determined that the ISO 

and SAE draft programs overall are 

unlikely to improve the usability of 

child restraint anchorage systems as 

effectively as today’s NPRM. The ISO 


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draft standard primarily rates the 

vehicles and does not directly mandate 

improvements to the usability of child 

restraint anchorage systems. Further, 

UMTRI evaluated vehicles using the 

draft ISO standard 29061–1:2010 and 

found no correlation between usability 

ratings and correct installation of child 

restraints in the vehicles in user trials. 

The draft SAE recommended practice 

J2893 is limited because it is a guideline 

and does not mandate improved 

usability. 

However, we have tentatively 

determined that aspects of the ISO and 

SAE procedures and requirements 

would improve the ease of use of child 

restraint anchorage systems and have 

proposed their inclusion in this NPRM. 

This NPRM proposes to require the 

signage developed by ISO for marking 

lower anchorages and tether anchorages 

in vehicles, and lower anchorage 

connectors and tether hooks on CRSs. 

This NPRM also proposes to adopt the 

clearance angle and attachment force 

criteria developed by draft SAE 

Standard J2893, and proposes to use 

SAE-developed tools and procedures for 

evaluating child restraint anchorage 

system hardware in vehicles. 

Unfunded Mandates Reform Act 

Section 202 of the Unfunded 

Mandates Reform Act of 1995 (UMRA), 

Public Law 104–4, requires Federal 

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 (adjusted for inflation 

with base year of 1995). Adjusting this 

amount by the implicit gross domestic 

product price deflator for the year 2010 

results in $136 million (110.993/81.606 

= 1.36). This NPRM would not result in 

a cost of $136 million or more to either 

State, local, or tribal governments, in the 

aggregate, or the private sector. Thus, 

this NPRM is not subject to the 

requirements of sections 202 of the 

UMRA. 

Executive Order 13609 (Promoting 

International Regulatory Cooperation) 

The policy statement in section 1 of 

E.O. 13609 provides, in part: 

The regulatory approaches taken by 

foreign governments may differ from 

those taken by U.S. regulatory agencies 

to address similar issues. In some cases, 

the differences between the regulatory 

approaches of U.S. agencies and those of 

their foreign counterparts might not be 

necessary and might impair the ability 

of American businesses to export and 

compete internationally. In meeting 

shared challenges involving health, 

safety, labor, security, environmental, 

and other issues, international 

regulatory cooperation can identify 

approaches that are at least as protective 

as those that are or would be adopted in 

the absence of such cooperation. 

International regulatory cooperation can 

also reduce, eliminate, or prevent 

unnecessary differences in regulatory 

requirements. 

NHTSA requests public comment on 

the ‘‘regulatory approaches taken by 

foreign governments’’ concerning the 

subject matter of this rulemaking. In the 

discussion above on the NTTAA, we 

have noted that we have reviewed the 

procedures and regulations developed 

by ISO and SAE to increase the ease of 

use of child restraint anchorage systems 

and have used parts of those procedures 

in this NPRM. Comments are requested 

on the above policy statement and the 

implications it has for this rulemaking. 

Regulation Identifier Number 

The Department of Transportation 

assigns a regulation identifier number 

(RIN) to each regulatory action listed in 

the Unified Agenda of Federal 

Regulations. The Regulatory Information 

Service Center publishes the Unified 

Agenda in April and October of each 

year. You may use the RIN contained in 

the heading at the beginning of this 

document to find this action in the 

Unified Agenda. 

Plain Language 

Executive Order 12866 requires each 

agency to write all rules in plain 

language. Application of the principles 

of plain language includes consideration 

of the following questions: 

• Have we organized the material to 

suit the public’s needs? 

• Are the requirements in the rule 

clearly stated? 

• Does the rule contain technical 

language or jargon that isn’t clear? 

• Would a different format (grouping 

and order of sections, use of headings, 

paragraphing) make the rule easier to 

understand? 

• Would more (but shorter) sections 

be better? 

• Could we improve clarity by adding 

tables, lists, or diagrams? 

• What else could we do to make the 

rule easier to understand? 

If you have any responses to these 

questions, please write to us with your 

views. 

In our proposed regulatory text for 

FMVSS No. 225, we have removed 

outdated sections and deleted obsolete 

language in an effort to make the 

standard more concise and easier to 

understand. We also propose to 

renumber some sections when multiple 

outdated paragraphs would be deleted, 

so that the standard would be easier to 

read. Please let us know if there are 

other housekeeping measures we could 

take to improve the plain language of 

the standard. 

XIII. Public Participation 

In developing this proposal, we tried 

to address the concerns of all our 

stakeholders. Your comments will help 

us improve this proposed rule. We 

welcome your views on all aspects of 

this proposed rule, but request 

comments on specific issues throughout 

this document. Your comments will be 

most effective if you follow the 

suggestions below: 

—Explain your views and reasoning as 

clearly as possible. 

—Provide solid technical and cost data 

to support your views. 

—If you estimate potential costs, 

explain how you arrived at the 

estimate. 

—Tell us which parts of the proposal 

you support, as well as those with 

which you disagree. 

—Provide specific examples to illustrate 

your concerns. 

—Offer specific alternatives. 

—Refer your comments to specific 

sections of the proposal, such as the 

units or page numbers of the 

preamble, or the regulatory sections. 

—Be sure to include the name, date, and 

docket number with your comments. 

Your comments must be written and 

in English. To ensure that your 

comments are correctly filed in the 

docket, please include the docket 

number of this document in your 

comments. 

Your comments must not be more 

than 15 pages long (49 CFR 553.21). We 

established this limit to encourage you 

to write your primary comments in a 

concise fashion. However, you may 

attach necessary additional documents 

to your comments. There is no limit on 

the length of the attachments. 

Please submit your comments to the 

docket electronically by logging onto 

http://www.regulations.gov or by the 

means given in the ADDRESSES section at 

the beginning of this document. 

Please note that pursuant to the Data 

Quality Act, in order for substantive 

data to be relied upon and used by the 

agency, it must meet the information 

quality standards set forth in the OMB 

and DOT Data Quality Act guidelines. 

Accordingly, we encourage you to 

consult the guidelines in preparing your 

comments. OMB’s guidelines may be 

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

omb/fedreg/reproducible.html. 


emcdonald on DSK67QTVN1PROD with PROPOSALS2
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How do I submit confidential business 

information? 

If you wish to submit any information 

under a claim of confidentiality, you 

should submit three copies of your 

complete submission, including the 

information you claim to be confidential 

business information, to the Chief 

Counsel, NHTSA, at the address given 

above under FOR FURTHER INFORMATION

CONTACT. In addition, you should 

submit a copy from which you have 

deleted the claimed confidential 

business information to the docket. 

When you send a comment containing 

information claimed to be confidential 

business information, you should 

include a cover letter setting forth the 

information specified in our 

confidential business information 

regulation. (49 CFR part 512.) 

Will the agency consider late 

comments? 

We will consider all comments that 

the docket receives before the close of 

business on the comment closing date 

indicated above under DATES. To the 

extent possible, we will also consider 

comments that the docket receives after 

that date. If the docket receives a 

comment too late for us to consider it 

in developing a final rule (assuming that 

one is issued), we will consider that 

comment as an informal suggestion for 

future rulemaking action. 

How can I read the comments submitted 

by other people? 

You may read the comments received 

by the docket at the address given above 

under ADDRESSES. You may also see the 

comments on the Internet (http://

regulations.gov). 

Please note that even after the 

comment closing date, we will continue 

to file relevant information in the docket 

as it becomes available. Further, some 

people may submit late comments. 

Accordingly, we recommend that you 

periodically check the docket for new 

material. 

Anyone is able to search the 

electronic form of all comments 

received into any of our dockets by the 

name of the individual submitting the 

comment (or signing the comment, if 

submitted on behalf of an association, 

business, labor union, etc.). You may 

review DOT’s complete Privacy Act 

Statement in the Federal Register 

published on April 11, 2000 (Volume 

65, Number 70; Pages 19477–78). 

List of Subjects in 49 CFR Part 571 

Imports, Motor vehicle safety, Motor 

vehicles, and Tires; Incorporation by 

Reference. 

In consideration of the foregoing, 

NHTSA proposes to amend 49 CFR part 

571 as set forth below. 

PART 571—FEDERAL MOTOR 

VEHICLE SAFETY STANDARDS 

■ 1. The authority citation for Part 571 

continues to read as follows: 

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

30117 and 30166; delegation of authority at 

49 CFR 1.95. 

■ 2. Section 571.5 is amended by adding 

paragraphs (k)(5) through (k)(8), to read 

as follows: 

§ 571.5 Matter incorporated by reference. 

* * * * * 

(k) * * * 

(5) [Reserved] 

(6) Drawing Package, ‘‘NHTSA 

Anchorage Depth Tool,’’ dated August 

19, 2013, into § 571.225. 

(7) Drawing Package, ‘‘NHTSA 

Attachment Force Tool,’’ dated May 22, 

2013, into § 571.225. 

(8) Drawing Package, ‘‘NHTSA 

Clearance Angle Tool,’’ dated May 21, 

2013, into § 571.225. 

* * * * * 

■ 3. Section 571.213 is amended by 

adding S5.6.1.12, revising S5.9(a), 

S5.9(b) and S5.9(c), and adding Figure 

15 and Figure 16 in numerical order, to 

read as follows: 

§ 571.213 Child restraint systems. 

* * * * * 

S5.6 Printed Instructions for Proper 

Use. 

* * * * * 

S5.6.1.12 In the case of child 

restraint systems marked as specified in 

S5.9 (a) and (b), explain that the 

markings identify the lower anchorage 

connectors and the tether anchorage 

connector, respectively, and that the 

consumer should look for corresponding 

marks on the vehicle child restraint 

anchorage system to attach the 

appropriate connectors of the child 

restraint system. 

* * * * * 

S5.9 Attachment to child restraint 

anchorage system. 

(a) Each add-on child restraint, other 

than a car bed, harness and beltpositioning seat, shall have components 

permanently attached that enable the 

restraint to be securely fastened to the 

lower anchorages of the child restraint 

anchorage system specified in Standard 

No. 225 (§ 571.225) and depicted in 

Drawing Package SAS–100–1000, 

Standard Seat Belt Assembly with 

Addendum A or in Drawing Package, 

‘‘NHTSA Standard Seat Assembly; 

FMVSS No. 213, No. NHTSA–213– 

2003’’ (both incorporated by reference, 

see § 571.5). The connectors must be 

attached to the add-on child restraint by 

use of a tool, such as a screwdriver. In 

the case of rear-facing child restraints 

with detachable bases, only the base is 

required to have the connectors. The 

connectors designed to attach the addon child restraint to the lower 

anchorages of the child restraint 

anchorage system shall be permanently 

marked with the pictogram in Figure 15. 

The pictogram is not less than 9 mm in 

diameter. 

(b) In the case of each child restraint 

system that has components for 

attaching the system to a tether 

anchorage, those components shall 

include a tether hook that conforms to 

the configuration and geometry 

specified in Figure 11 of this standard. 

The tether hook or the tether strap shall 

be permanently marked with either 

pictogram shown in Figure 16. If the 

mark is on the tether strap or on a tag 

attached to the tether strap, the mark 

must be located within 25 mm of the 

tether hardware assembly (which 

consists of a tether hook and a webbing 

tightening mechanism designed to 

tighten or loosen the tether strap). 

(c) In the case of each child restraint 

system that has components, including 

belt webbing, for attaching to an 

anchorage of a child restraint anchorage 

system, the belt webbing shall be 

adjustable so that the child restraint can 

be tightly attached to the vehicle. The 

length of the tether hardware assembly, 

which consists of a tether hook and a 

mechanism designed to tighten and 

loosen the tether strap, shall not exceed 

165 mm. 

* * * * * 


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Notes 1. Drawing not to scale. 

2. Symbol may be shown in mirror image. 

3. Color of the symbol is at the option of 

the manufacturer. 

Notes 1. Drawing not to scale. 

2. Symbol may be shown in mirror image. 

3. Color of the symbol is at the option of 

the manufacturer. 

4. Either symbol may be marked at the 

option of the manufacturer. 

■ 4. Section 571.225 is amended by: 

■ a. Revising S4.2; 

■ b. Removing S4.3, S4.4 and S4.5, 

redesignating S4.6 as S4.3 and revising 

newly redesignated S4.3; 

■ c. Removing S5(e); 

■ d. Revising S6.1(a), S6.1(b), S6.2, and 

removing S6.2.1 through S6.2.2.2; 

■ e. Revising S6.3 and removing S6.3.1 

through S6.3.4.4; 

■ e. Revising the first sentence of S8, the 

introductory text of S8.1, and removing 

and reserving S8.2; 

■ f. Removing the introductory text of 

S9, revising S9.1.1(d) and S9.2.2(a), 

adding S9.2.4 and S9.2.5, and revising 

S9.5; 

■ g. Revising S11, S12(b) and S12(c), 

and adding S12(d); 

■ f. Removing S13 through S16.4; 

■ g. Revising Figures 3, 8 and 9, 

removing and reserving Figures 10, 11, 

and 19, and adding Figures 24 through 

27. 

The revised and added text and 

figures read as follows: 

§ 571.225 Child restraint anchorage 

systems. 

* * * * * 

S4.2 Vehicles shall be equipped as 

specified in paragraphs (a) through (c) of 

this paragraph, except as provided in 

S5. 

(a) Each vehicle with three or more 

forward-facing rear designated seating 

positions shall be equipped as specified 

in S4.2(a)(1) and (2). 

(1) Each vehicle shall be equipped 

with a child restraint anchorage system 

conforming to the requirements of S6 

and S9 at not fewer than two forwardfacing rear designated seating positions. 

At least one of the child restraint 

anchorage systems shall be installed at 

a forward-facing seating position in the 

second row in each vehicle that has 

three or more rows, if such a forwardfacing seating position is available in 

that row. 

(2) Each vehicle shall be equipped 

with a tether anchorage conforming to 

the requirements of S6 at a third 

forward-facing rear designated seating 

position. The tether anchorage of a child 

restraint anchorage system may count 

towards the third required tether 

anchorage. In each vehicle with a 

forward-facing rear designated seating 

position other than an outboard 

designated seating position, at least one 

tether anchorage (with or without the 

lower anchorages of a child restraint 

anchorage system) shall be at such a 

designated seating position. 

(b) Each vehicle with not more than 

two forward-facing rear designated 

seating positions shall be equipped with 

a child restraint anchorage system 

conforming to the requirements of S6 

and S9 at each forward-facing rear 

designated seating position. 

(c) Each vehicle without any forwardfacing rear designated seating position 

shall be equipped with a tether 


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anchorage conforming to the 

requirements of S6 at each front 

forward-facing passenger seating 

position. 

S4.3 Movable seats. (a) A vehicle 

that is equipped with a forward-facing 

rear designated seating position that can 

be moved such that it is capable of being 

used at either an outboard or nonoutboard forward-facing seating position 

shall be considered as having a forwardfacing non-outboard seating position. 

Such a movable seat must be equipped 

with a tether anchorage that meets the 

requirements of S6 or a child restraint 

anchorage system that meets the 

requirements of S6 and S9, if the vehicle 

does not have another forward-facing 

non-outboard seating position that is so 

equipped. 

(b) Tether and lower anchorages shall 

be available for use at all times, except 

when the seating position for which it 

is installed is not available for use 

because the vehicle seat has been 

removed or converted to an alternate 

use such as allowing for the carrying of 

cargo. 

* * * * * 

S6.1 * * * 

(a) Consist of a rigid bar of any cross 

section shape that permits the 

attachment of a tether hook (of a child 

restraint system) meeting the 

configuration and geometry specified in 

Figure 11 of Standard No. 213 

(§ 571.213); 

(b) Be accessible without the need for 

any tools and without folding the seat 

back or removing carpet or other vehicle 

components to access the anchorages. 

However, the tether anchorage may be 

covered with a cap, flap or cover, 

provided that the cap, flap or cover is 

specifically designed to be opened, 

moved aside or to otherwise give access 

to the anchorage and is labeled with the 

symbol shown in Figure 27 of this 

standard. 

* * * * * 

S6.2 Location of the tether 

anchorage. 

(a)(1) Subject to S6.2(b), the part of 

each tether anchorage to which a tether 

hook attaches must be located within 

the shaded zone shown in Figures 3 to 

7 of this standard of the designated 

seating position for which it is installed. 

The zone is defined with reference to 

the seating reference point (see § 571.3). 

(For purposes of the figures, ‘‘H Point’’ 

means seating reference point.) A tether 

anchorage may be recessed in the seat 

back, provided that it is not in the strap 

wrap-around area at the top of the 

vehicle seat back. For the area under the 

vehicle seat, the forwardmost edge of 

the shaded zone is defined by the 

intersection of the vehicle floor with a 

plane that is parallel to the torso line 

reference plane and which passes 

through the rearmost point of the 

bottom of the seat at the centerline of 

the seat, as shown in Figure 3. 

(2) The distance of the tether 

anchorage from a reference point (SB) 

obtained by the intersection of a plane 

parallel to the torso line reference plane 

that passes through the rearmost point 

of the seat and the strap wrap-around 

line from the V-point to the tether 

anchorage, shall be no less than 165 mm 

as shown in Figure 8 of this standard. 

The rearmost point of the seat includes 

the rearmost point of the head restraint, 

if a head restraint is present. For 

adjustable head restraints, the rearmost 

point of the seat is determined with the 

head restraint positioned at its highest 

position. For adjustable head restraints, 

the strap wrap-around line from the Vpoint to the tether anchorage shall be 

routed under the head restraint and 

between the adjustment bars or adjacent 

to an adjustment bar. In vehicle seating 

positions with integrated head restraints 

or with head restraints that do not 

provide space under the head restraint 

to route a tether strap, route the strap 

wrap-around line from the V-point to 

the tether anchorage over the head 

restraint. In seating positions without 

head restraints, route the strap wraparound line from the V-point to the 

tether anchorage over the seat back. 

(b) In the case of a vehicle that— 

(1) Has a user-ready tether anchorage 

for which no part of the shaded zone 

shown in Figures 3 to 7 of this standard 

of the designated seating position for 

which the anchorage is installed is 

accessible without removing a seating 

component of the vehicle; and 

(2) Has a tether strap routing device 

that is— 

(i) Not less than 65 mm behind the 

torso line for that seating position, in 

the case of a flexible routing device or 

a deployable routing device, measured 

horizontally and in a vertical 

longitudinal plane; or 

(ii) Not less than 100 mm behind the 

torso line for that seating position, in 

the case of a fixed rigid routing device, 

measured horizontally and in a vertical 

longitudinal plane, the part of that 

anchorage that attaches to a tether hook 

may, at the manufacturer’s option (with 

said option selected prior to, or at the 

time of, certification of the vehicle) be 

located outside that zone. 

(iii) The measurement of the location 

of the flexible or deployable routing 

device described in S6.2(b)(2)(i) is made 

with SFAD 2 properly attached to the 

lower anchorages. A 40 mm wide nylon 

tether strap is routed through the 

routing device and attached to the tether 

anchorage in accordance with the 

written instructions required by S12 of 

this standard. The forwardmost contact 

point between the strap and the routing 

device must be within the stated limit 

when the tether strap is flat against the 

top surface of the SFAD and tensioned 

to 55 to 65 N. In seating positions 

without lower anchorages of a child 

restraint anchorage system, the SFAD 2 

is held with its central lateral plane in 

the central vertical longitudinal plane of 

the seating position. The adjustable 

anchorage attaching bars of the SFAD 2 

are replaced by spacers that end flush 

with the back surface of the SFAD 2. 

(iv) The distance from the routing 

device (where the strap has completely 

cleared the routing device as shown in 

Figure 9) to the tether anchorage shall 

be no less than 165 mm. 

S6.3 Strength requirements for 

tether anchorages. 

(a) When tested in accordance with 

S8, the tether anchorage must not 

separate completely from the vehicle 

seat or seat anchorage or the structure of 

the vehicle. 

(b) Provisions for simultaneous and 

sequential testing. (1) In the case of 

vehicle seat assemblies equipped with 

more than one tether anchorage, the 

force referred to in S6.3 may, at the 

agency’s option, be applied 

simultaneously to each of those tether 

anchorages. However, that force may not 

be applied simultaneously to tether 

anchorages for any two adjacent seating 

positions whose midpoints are less than 

400 mm apart, as measured in 

accordance with S6.3(b)(i) and (ii) and 

Figure 20. 

(i) The midpoint of the seating 

position lies in the vertical longitudinal 

plane that is equidistant from vertical 

longitudinal planes through the 

geometric center of each of the two 

lower anchorages at the seating position. 

For those seating positions that do not 

provide lower anchorages, the midpoint 

of the seating position lies in the 

vertical longitudinal plane that passes 

through the SgRP of the seating 

position. 

(ii) Measure the distance between the 

vertical longitudinal planes passing 

through the midpoints of the adjacent 

seating positions, as measured along a 

line perpendicular to the planes. 

(2) A tether anchorage of a particular 

child restraint anchorage system will 

not be tested with the lower anchorages 

of that anchorage system if one or both 

of those lower anchorages have been 

previously tested under this standard. 

* * * * * 

S8 Test procedures. Each vehicle 

shall meet the requirements of S6.3 


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when tested according to the following 

procedures. * * * 

S8.1 Apply the force specified in 

S6.3 as follows— 

* * * * * 

S8.2 [Reserved] 

S9. Requirements for the lower 

anchorages of the child restraint 

anchorage system. 

* * * * * 

S9.1.1 * * * 

(d) The bars must not be capable of 

being stowable or foldable. 

* * * * * 

S9.2 Location of the lower 

anchorages. 

* * * * * 

S9.2.2 * * * 

(a) Located such that when the lower 

anchorage depth tool depicted in 

Drawing Package, ‘‘NHTSA Lower 

Anchorage Depth Tool,’’ dated June 

2014 (incorporated by reference; see 

§ 571.5), is attached to the anchorage 

bar, the 2 cm mark on the tool is visible 

from a vertical longitudinal plane 

passing through the center of the bar, 

along a line making an upward 30 

degree angle with a horizontal plane; 

and 

* * * * * 

S9.2.4 The lower anchorages shall 

be located such that no more than 178 

N (40 lb) of force is needed to securely 

attach the tool, depicted in Drawing 

Package, ‘‘NHTSA Attachment Force 

Tool,’’ dated June 2014 (incorporated by 

reference; see § 571.5), to an anchorage 

bar with the tool positioned in at least 

one angle from 0 degrees to 45 degrees 

from the horizontal using the procedure 

in S11(b) of this standard. 

S9.2.5 The lower anchorages shall 

be located such that the tool depicted in 

Drawing Package, ‘‘NHTSA Clearance 

Angle Tool,’’ dated June 2014 

(incorporated by reference; see § 571.5), 

measures a clearance angle of at least 54 

degrees using the procedure in S11(c) of 

this standard. 

* * * * * 

S9.5 Marking and conspicuity 

requirements. 

S9.5.1 Requirements for lower 

anchorages. 

(a) Above each bar installed pursuant 

to S4, the vehicle shall be permanently 

marked with a circle that: 

(1) Is not less than 13 mm in diameter; 

(2) Contains the pictogram shown in 

Figure 24 of this standard; and 

(3) Is located such that its center is on 

each seat back between 50 and 100 mm 

above or on the seat cushion 100 ±25 

mm forward of the intersection of the 

vertical transverse and horizontal 

longitudinal planes intersecting at the 

horizontal centerline of each lower 

anchorage, as illustrated in Figure 22. 

The center of the circle must be in the 

vertical longitudinal plane that passes 

through the center of the bar (±25 mm). 

(4) The circle may be on a tag. 

(b) The bars may be covered by a 

removable cap or cover, provided that 

the cap or cover is permanently marked 

with the pictogram shown in Figure 24. 

If the cap or cover is permanently 

attached to the vehicle, the lower 

anchorage bars are not required to be 

separately marked with the pictogram. If 

the cap or cover is not permanently 

attached to the vehicle, the lower 

anchorage bars must also be marked 

with the circle meeting S9.5.1(a)(1) 

through (a)(3) of this standard. 

S9.5.2 Requirements for tether 

anchorages. 

(a) For each tether anchorage installed 

pursuant to S4, there shall be a 

permanent mark that: 

(1) Consists of the pictogram shown in 

Figure 25 of this standard that is not less 

than 20 mm in diameter; 

(2) The center of the circle in the 

longitudinal direction must be in the 

vertical longitudinal plane that passes 

through the center of the tether 

anchorage bar (±5 mm), as shown in 

Figure 26 (Front View) of this standard. 

(3) The nearest edge of the mark shall 

be located not more than 25 mm away 

from the tether anchorage bar as shown 

in Figure 26 (Side View) of this 

standard. 

(b) The tether anchorage bar may be 

covered by a cap or cover that is 

removable without the use of any tool, 

provided that the cap or cover is 

permanently labeled with a mark 

meeting the requirements of S9.5.2(a)(1). 

The center of the mark on the cap or 

cover shall be centered at the middle of 

the tether anchorage bar, as shown in 

Figure 27 of this standard. If the cap or 

cover is permanently attached to the 

vehicle, the tether anchorage is not 

required to be separately marked. If the 

cap or cover is not permanently 

attached to the vehicle, the tether 

anchorage must also be marked with the 

circle meeting S9.5.2(a)(1) through 

S9.5.2(a)(3) of this standard. 

* * * * * 

S11. Test procedures. Each vehicle 

shall meet the requirements of this 

standard when tested according to the 

following procedures. Where a range of 

values is specified, the vehicle shall be 

able to meet the requirements at all 

points within the range. 

(a) Strength requirements. 

(1) Forward force direction. Place 

SFAD 2 in the vehicle seating position 

and attach it to the two lower 

anchorages of the child restraint 

anchorage system. Do not attach the 

tether anchorage. A rearward horizontal 

force of 135 ±15 N is applied to the 

center of the lower front crossbar of 

SFAD 2 to press the device against the 

seat back as the fore-aft position of the 

rearward extensions of the SFAD is 

adjusted to remove any slack or tension. 

Apply a preload force of 500 N 

horizontally and in the vertical 

centerline of the SFAD 2 at point X. 

Increase the pull force as linearly as 

practicable to a full force application of 

11,000 N in not less than 24 seconds 

and not more than 30 seconds, and 

maintain at an 11,000 N level for 1 

second. 

(2) Lateral force direction. Place SFAD 

2 in the vehicle seating position and 

attach it to the two lower anchorages of 

the child restraint anchorage system. Do 

not attach the tether anchorage. A 

rearward force of 135 ±15 N is applied 

to the center of the lower front crossbar 

of SFAD 2 to press the device against 

the seat back as the fore-aft position of 

the rearward extensions of the SFAD is 

adjusted to remove any slack or tension. 

Apply a preload force of 500 N 

horizontal and perpendicular to the 

longitudinal centerline of the SFAD 2 at 

point X of the test device. Increase the 

pull force as linearly as practicable to a 

full force application of 5,000 N in not 

less than 24 seconds and not more than 

30 seconds, and maintain at a 5,000 N 

level for 1 second. 

(b) Attachment force. The seat back 

angle, if adjustable, is set at the 

manufacturer’s nominal design seat 

back angle. Remove any lower 

anchorage cover if present. To measure 

attachment force, hold the force 

attachment tool perpendicularly aligned 

with the center of the lower anchorage. 

Position the tool at an angle of 0 to 45 

degrees from the horizontal, and push 

the tool towards the lower anchorage. 

Measure the force needed to engage the 

tool to the lower anchorage. 

(c) Clearance angle. The seat back 

angle, if adjustable, is set at the 

manufacturer’s nominal design seat 

back angle. Remove any lower 

anchorage cover if present. To measure 

clearance angle, attach the clearance 

angle tool to the lower anchorage and 

apply a vertical force of 67 N (15 lb) to 

the tool. Measure the angle (with respect 

to the horizontal) of the tool while the 

force is being applied. 

* * * * * 

S12. Written instructions. 

* * * * * 

(b) In the case of vehicles required to 

be marked as specified in paragraphs 

S4.1, S9.5.1 and S9.5.2, explain the 


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meaning of markings provided to locate 

the lower anchorages of child restraint 

anchorage systems and the top tether 

anchorages; 

(c) Include instructions that provide a 

step-by-step procedure, including 

diagrams, for properly attaching a child 

restraint system’s tether strap to the 

tether anchorages; and 

(d) Include instructions on how to 

locate and access the tether anchorage 

and the lower anchorages. 

Figures to § 571.225 

* * * * * 

Notes: SB point is the intersection of the 

plane parallel to the torso line reference 

plane that passes through the rearmost point 

of the vehicle seat, and the strap wraparound line from the V-point to the tether anchorage. 


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Figure 3 Side View, User ready Tether Anchorage Location 

Figure 8. Top view (left) and side view {right) 

of minimum distance between tether anchorage and point SB. 
3780 Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 

* * * * * 

Notes: 1. Drawing not to scale. 

2. Symbol may be shown in mirror image. 

3. Color of the symbol at the option of the 

manufacturer. 


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Notes: 1. Drawing not to scale. 

2. Symbol may be shown in mirror image. 

3. Color of the symbol at the option of the 

manufacturer. 

(Tolerance of ±5 mm) 

(Tolerance of ±10 mm in the 

Longitudinal and/or Lateral Plane.) 

Note: The following Appendices will not 

appear in the CFR. 

Appendix A: Field Studies 

Decina Study—2005 

Three years after FMVSS No. 225 was fully 

phased in and child restraints made to meet 

the corresponding changes in FMVSS No. 

213, NHTSA conducted a survey from April 

to October 2005 to assess the progress made 

since 2002 and identify the possible needs 

for additional steps. See Decina et al., ‘‘Child 

Restraint Use Survey: LATCH Use and 

Misuse,’’ supra.). NHTSA wanted to know 

whether drivers of vehicles equipped with 

child restraint anchorage systems were using 

the systems to secure child restraints to the 

vehicle seat, and if so, whether they were 

properly installing the restraints. In the 

survey, the make/model and the type of 

restraint installed in each seating position 

were recorded for each vehicle, and the 

demographic characteristics and the type of 

child restraint system were collected for each 

occupant. In addition, information was 

gathered about the drivers’ knowledge of 

child restraint anchorage systems, along with 

their opinions on how easy it was for them 

to use the systems. The study involved 1,121 

children from birth to age 4 in child restraint 

systems. 

Key findings of the survey were: 

(a) Of the child restraints located in a 

seating position equipped with an upper 

tether anchor, 55 percent were attached to 

the vehicle using the upper tether. 

(b) Among the 87 percent who placed the 

CRS at a position equipped with lower 

anchors, 60 percent used the lower 

attachments to secure the restraint to the 

vehicle. 

(c) In 13 percent of the vehicles equipped 

with child restraint anchorage systems in 

which there was a child restraint, the 

restraint was placed in a seat position not 

equipped with lower anchors—instead, the 

vehicle seat belt was used to secure the 

restraint to the vehicle. 

(d) Sixty-one (61) percent of upper tether 

nonusers and 55 percent of lower anchorage 

nonusers cited their lack of knowledge—not 

knowing what the anchorages were, that they 

were available in the vehicle, the importance 


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102National Child Restraint Use Special Study, 

DOT HS 811 679, http://www-nrd.nhtsa.dot.gov/

Pubs/811679.pdf (Full report pending). 

103Rear-facing seats and booster seats are not 

typically equipped or used with tether straps in the 

U.S. 

104 ‘‘A Look Inside American Family Vehicles 

2009–2010,’’ Safe Kids USA (http://

www.safekids.org/assets/docs/safety-basics/safetytips-by-risk-area/sk-car-seat-report-2011.pdf). 

105The National Child Passenger Safety 

Certification Program certifies individuals as 

CPSTs. NHTSA assists in developing the 

curriculum of the certification; the National CPS 

Board oversees the quality and integrity of the 

training and certification requirements; and Safe 

Kids Worldwide functions as the certifying body. 

106The reduced tether use in the 2012 Safe Kids 

data compared to NHTSA’s NCRUSS study could be 

attributed to the differences in the two observation 

samples. The Safe Kids observations are made at 

seat check stations where caregivers come to seek 

advice from the CPSTs on correct CRS installation. 

These caregivers may be novice CRS users or are 

unsure of the method of CRS installation. Therefore, 

this convenience sample of observations may be 

biased towards incorrect or non-ideal CRS 

installations. On the other hand, the NCRUSS 

observations are from a stratified sample 

representative of CRS use and installation in the 

United States and are designed to be bias-free. 

107 72 FR 3103, January 24, 2007, notice of public 

meeting, request for comments. 

108 Id. 

of using them, or how to use them properly— 

as the reason for not using them. 

(e) Of those drivers with experience using 

both lower anchorages and seat belts: (1) 81 

percent of upper tether anchorage users and 

74 percent of lower anchorage users said 

upper tether and/or lower anchorages were 

easy to use; and (2) 75 percent preferred the 

lower anchorages over seat belts. 

(f) Sixty-one (61) percent of child restraints 

installed with child restraint anchorage 

systems were securely installed. 

All in all, the Decina study found that 

consumers who have experience with the 

child restraint anchorage systems like them. 

Among consumers having knowledge of both 

lower anchorages and seat belt attachment, 

75 percent preferred using lower anchorages. 

Further, the report found that child restraint 

anchorage systems are helping to reduce the 

incorrect installation of child restraints (61 

percent of child restraints installed with 

child restraint anchorage systems were 

securely installed, as compared to about 40– 

46 percent of CRSs installed by seat belts 

securely installed). 

However, the report also indicated that 

proper use of child restraint anchorage 

systems is not inherently evident. Many 

drivers do not use the anchorage system 

because they do not know about it or 

understand its purpose. There is also some 

confusion about where the anchorages can be 

found. In addition, there were differing 

degrees of difficulty using the anchorages 

depending on location and configuration of 

the CRS hardware. 

National Child Restraint Use Special Study— 

2011 Data 

The National Child Restraint Use Special 

Study (NCRUSS) is a large-scale nationallyrepresentative survey that involves both an 

inspection of the child passenger’s restraint 

system by a CPST and a detailed interview 

of the driver.102 The survey collected 

information on drivers and their child 

passengers of ages 0–8 years between June 

and August 2011. NCRUSS data were 

collected at 24 primary sampling units 

(PSUs) across the country. The PSUs were 

previously established from a separate 

ongoing data collection effort, the National 

Automotive Sampling System (NASS). The 

PSUs are defined geographically, similar to 

cities or counties. The PSUs were selected to 

cover urban, rural, and suburban 

environments and are located in 17 different 

states. 

The survey collected 4,167 observations on 

children under 9 years of age, of which 268 

(weighted percentage = 8.5 percent) were of 

infant seats with a base, 142 (weighted 

percentage = 3.6 percent) were of convertible 

or all-in-one type CRSs installed in rearfacing mode and 1,983 (weighted percentage 

= 49.6 percent) were of convertible, 

combination or all-in-one type CRSs installed 

in forward-facing mode with harness. The 

remaining observations were of children in 

other types of restraints including booster 

seats, seat belts, vests, car beds, etc. The 

survey also found less than 2 percent of 

children unrestrained. 

For CRSs with internal harnesses, the 

survey results show that 49 percent of CRSs 

were installed with lower anchorages, 44 

percent were installed with seat belts, and 7 

percent with both seat belt and lower 

anchorages. When the analysis was restricted 

to only vehicles equipped with child 

restraint anchorage systems, 61 percent of the 

CRSs were installed using the lower 

anchorages and 9 percent with both seat belt 

and lower anchorages. Decina had found that 

55 percent of the harnessed CRSs observed in 

vehicles with child restraint anchorage 

systems were attached using the lower 

anchorages. The NCRUSS study shows a 15 

percent increase in the rate of all lower 

anchorage installations from 2005 to 2011. 

As for tether use, for forward-facing CRSs 

with internal harnesses,103 tether use was 71 

percent when installed with the lower 

anchorages and 31 percent when installed 

with seat belts. 

Safe Kids Worldwide (Safe Kids) Data 

In September 2011, Safe Kids published a 

study based on 79,000 observations from ‘‘car 

seat check’’ events and appointments that 

took place between October 1, 2009 and 

September 30, 2010.104 Safe Kids developed 

a standardized checklist that it uses at car 

seat check events and records how the child 

and/or child restraint arrived at the event and 

how the child and/or child restraint left the 

event. The checklists are then scanned and 

entered into a database that Safe Kids 

manages and updates. 

The study found that correct installation 

ranged between 39 to 61 percent for seat belt 

installations and between 46 to 60 percent for 

lower anchorage installation. Safe Kids 

defined correct seat belt installation as one in 

which the child restraint’s manufacturer’s 

instructions were followed and that is in 

accordance with the Child Passenger Safety 

Certification Program (CPSCP) 105 best 

practices, including seat belt routing, 

tightness (must not move more than 1 inch 

side to side or front to back when grasped by 

the belt path) and having a locked seat belt. 

Correct lower anchorage installation 

consisted of using the lower anchorages as 

instructed in both the CRS and vehicle 

manuals as well as following the CPSCP best 

practices including: Using correct hardware, 

using connectors in the right direction, 

correct identification of the designated lower 

anchors in the vehicle and installation 

tightness. 

Safe Kids found a 7 percentage point 

difference in correct use between lower 

anchorage installations and seat belt 

installations for infant seats with base, and a 

10 percentage point difference in correct use 

between lower anchorage installations and 

seat belt installations of forward-facing seats, 

with lower anchorage installations having the 

higher rates of correct use. For other rearfacing seats, seat belt installations had a 1 

percentage point advantage of correct use 

compared to installations with lower 

anchorages. 

As for tether use, the study found 59 

percent correct tether use in forward-facing 

CRSs. 

We also reviewed Safe Kids sample data 

from the first quarter of 2012 comprising 

17,000 observations. The data showed that 48 

percent of CRSs with internal harness were 

installed with the lower anchorages, 46 

percent with the seat belt and 6 percent with 

both seat belt and lower anchorages in all 

vehicles (data did not distinguish whether 

the vehicles were equipped with child 

restraint anchorage systems). Overall tether 

usage in forward-facing CRSs with internal 

harness was only 29 percent. Tether use was 

45 percent when the CRS was attached with 

lower anchorages and 15 percent when the 

CRS was attached with seat belt.106

Appendix B: Summary of 2007 Public 

Meeting 

In response to the 2006 report by Decina 

et al., supra, NHTSA held a public meeting 

on February 8, 2007 to bring together child 

restraint and vehicle manufacturers, retailers, 

technicians, researchers, and consumer 

groups to discuss ways to improve child 

passenger safety through improving CRS 

designs and increasing the proper use of 

child restraint systems.107 Questions were 

posed to the participants of the public 

meeting regarding child restraint anchorage 

system design, ease of use, and approaches 

to educating the public about proper use.108

NHTSA solicited comments on design 

considerations for tether anchorage locations, 

lower anchorage accessibility, system 

availability in the center seating position, 

and design of child restraint hooks and 

connectors. With respect to child restraint 

anchorage system ease of use, NHTSA was 

interested in the development of more userfriendly connectors, consumer information 

on vehicle child restraint anchorage system 

hardware, and CRS and vehicle 

compatibility. As for consumer education, 

NHTSA wanted to know what types of 


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109 ISOFIX is a system, mostly used in Europe, for 

the connection of child restraint systems to 

vehicles. The system has two vehicle rigid 

anchorages, two corresponding rigid attachments on 

the child restraint system and a means to limit the 

pitch rotation of the child restraint system. 

questions consumers had and how to spread 

child restraint anchorage system awareness. 

The agency received comments from 

vehicle manufacturers, child passenger 

advocacy groups, researchers, and 

individuals. While the comments and 

suggestions received on child restraint 

anchorage system were varied, the main 

themes were as follows: 

Lower Anchorages: There was support for 

improving the conspicuity, accessibility, and 

ease of use of the lower anchorages without 

compromising comfort to adult occupants, 

and standardizing the location of the lower 

anchorages. 

Markings of Anchorages: There were 

suggestions for requiring all anchorages to be 

marked by the International Standards 

Organization (ISO) symbol regardless of 

anchorage visibility, requiring similar 

markings for the CRS connectors, and 

considering color coded labels to clarify the 

anchorage locations for each DSP. 

Child restraint anchorage system for rear 

center seat: There was support for requiring 

a child restraint anchorage system in all rear 

center seats, or developing provisions to use 

the inboard anchorages of the outboard 

seating position for the center seat while 

taking into consideration the possibility of 

misuse when two CRSs are connected to the 

same anchorage. 

Child restraint anchorage system for 3rd 

row seating positions: Some suggested 

requiring additional child restraint anchorage 

system-equipped DSPs for vehicles with 

three or more rows. 

Consumer education: There were 

suggestions on using consistent terminology 

in education material and developing up-todate uniform curriculum, requiring that a 

DVD or Web site be included in the 

instruction manual for CRS installation, 

emphasizing the use of tethers and explicitly 

encouraging the use of child restraint 

anchorage systems rather than simply listing 

it as an option for installation. 

A more detailed summary of comments 

received from the 2007 public meeting 

regarding child restraint anchorage system 

ease of use is set forth below. 

Lower Anchorage Usability 

• Advocates for Highway Safety 

(Advocates), the American Academy of 

Pediatrics (AAP), and Safe Ride News (SRN) 

suggested that lower anchors be located 

farther forward in the seat bight to increase 

visibility and make installation and removal 

easier. 

• Advocates suggested that lower anchors 

need to be just as accessible as seat belts. 

Otherwise, parents will continue to install 

child restraints with seat belts over the 

LATCH system. 

• SafetyBelt Safe USA (SBS) said that it is 

more difficult to remove restraints from 

recessed anchors. 

• SRN called for further research into 

whether hidden lower anchors are a deterrent 

to using the LATCH system. 

• Honda was concerned that moving 

anchors out of the seat bight would cause 

occupant discomfort and would necessitate 

the redesign of some seats. Instead, Honda 

suggested that there might be a different way 

to clear space around anchors without 

moving them forward. 

• General Motors (GM) suggested that 

NHTSA evaluate SAE’s lower anchor access 

design guidelines. 

Conspicuity and Identification of Anchors 

(Marking of Anchors) 

• GM, Advocates, AAP, SRN, and the 

University of Virginia (UVA) recommended 

that all tethers and lower anchors, regardless 

of visibility, be conspicuously marked. GM 

suggested that the industry develop a 

voluntary agreement to label all tethers with 

an anchor symbol and all lower anchors with 

a baby dot symbol. The connectors on the 

child restraint would also be labeled with the 

same symbols for easy matching. 

• AAP, SRN, and several CPSTs 

recommended that sets of lower anchors be 

labeled or color coded to clarify which 

seating position they serve, especially in the 

case of overlapping lower anchors. 

Tether Anchorage Specifications, Location, 

and Accessibility 

• GM and SRN supported further 

restriction of the tether zone to eliminate 

problems associated with tethers located 

underneath seats and to make tether anchors 

more accessible. It was also noted that further 

limitation of this zone would also ensure that 

child restraints with shorter tether straps 

would be able to reach the tether anchor. 

• Honda recommended that NHTSA gain 

full understanding of the optimal tether 

locations for different vehicle configurations 

before further restricting the zone. It noted 

that tether anchor locations in many vehicles 

are limited due to strength requirements. 

• Honda recommended that NHTSA 

consider the comfort, ingress/egress and 

excursion space of other occupants when 

determining acceptable tether locations. 

• AAP recommended that vehicle 

manufacturers provide tether locations 

forward of seats for use with rear-facing seats. 

Anchorage System for Center Seat 

• GM and Honda recommended that 

provisions be developed for the use of 

inboard lower anchors from outboard seats to 

create a center seat full LATCH system. 

However, Honda noted that it does not 

currently encourage this type of use since 

these anchors often are not set 280 mm (11 

in) apart, as specified in FMVSS No. 225. 

Honda, SBS, GM and SRN recommended that 

NHTSA research the range of safe distances 

between lower anchors in order to determine 

the feasibility of this type of use. 

• AAP was concerned that if consumers 

are given the option of attaching a child seat 

to the inboard anchors of outboard seats, they 

will then attach two child restraints to the 

same lower anchor when installing adjacent 

restraints. One CPST recommended a 

solution of making lower anchors smaller in 

size to discourage parents from attempting to 

attach multiple restraints to a single anchor. 

• Advocates, UVA, and three CPSTs 

suggested that all center seats be equipped 

with a full LATCH system. 

• AAP, Advocates, and two CPSTs agreed 

that conflicting information is currently 

given to parents regarding the center seat 

position being the ‘‘safest’’ and the 

availability of full LATCH systems in the 

center seat. The commenters suggested that 

this discrepancy should be reconciled to 

avoid confusion when installing seats in the 

center position. Possible solutions suggested 

include a dedicated set of center seat anchors 

or built-in center seat child restraints. 

Full LATCH for 3rd Row Seat Positions 

• SRN and SBS suggested that the 

minimum number of full LATCH systems for 

a vehicle with three rows be increased. They 

thought that providing more LATCH systems 

per vehicle could reduce the number of 

incidences where multiple restraints are 

attached to a single anchor. 

Consumer Education 

• AAP advised against inconsistent 

vocabulary, recommending that NHTSA 

clarify certain terminology, such as 

‘‘LATCH’’ referring to the entire system 

rather than just the lower anchorages. 

• Cohort 22 and UVA suggested that either 

a DVD or a Web site link be included in 

instruction manuals to provide users an 

installation video that would better clarify 

what a ‘‘tight fit’’ means. 

• Honda suggested making a tether strap 

routing procedure available to consumers. 

• AAP believed that the importance of the 

tether in the LATCH system must be 

emphasized to consumers. SRN 

recommended that manuals explicitly 

encourage the use of LATCH rather than 

simply listing it as an option for installation. 

• GM, Honda, SRN, and a CPST 

emphasized the importance of consumer 

education and public awareness of LATCH. 

SRN suggested that an up-to-date and 

uniform curriculum of information be 

developed so that the information given to 

parents and caregivers is consistent from all 

sources (e.g. hospitals, police, and doctors). 

Appendix C: Other Usability Efforts 

International Organization for 

Standardization (ISO) 

ISO, a worldwide voluntary federation of 

ISO member bodies, is drafting an approach 

toward improving the usability of a child 

restraint anchorage system called 

‘‘ISOFIX.’’ 109 (ISO 29061–1:2010, Road 

vehicles—Methods and criteria for usability 

evaluation of child restraint systems and 

their interface with vehicle anchorage 

systems—Part 1: Vehicles and child restraint 

systems equipped with ISOFIX anchorages 

and attachments.) The draft ISO approach 

uses a rating system and criteria to provide 

child restraint and vehicle manufacturers 

with a tool for the assessment of the usability 

of ISOFIX systems. ISO also provides 

consumers (parents and caregivers) with 

information to assist them in selecting a CRS 

and vehicle with ISOFIX systems that are 

easy to use, with the aim that the information 

will result in more correct installations. 

The ISO approach evaluates and rates the 

usability of the CRS’s ISOFIX features, the 


emcdonald on DSK67QTVN1PROD with PROPOSALS2
3784 Federal Register / Vol. 80, No. 15 / Friday, January 23, 2015 / Proposed Rules 

110The SAE J2893 Version 1–Draft 7 was used for 

the UMTRI study. Any mention of the SAE J2893 

recommendations throughout this document will 

refer to this draft version of the guidelines which 

are still under development. 

111 76 FR 10637, February 25, 2011 request for 

comment, Docket No NHTSA–2010–0062. NHTSA 

is in the process of considering the next steps for 

the program. 

vehicle’s ISOFIX system, and the interaction 

between the two. While the ISOFIX system 

is not used in the U.S., the system is very 

similar to the FMVSS No. 225 child restraint 

anchorage system and therefore, the 

evaluation developed by ISO can mostly be 

applied to our systems. The vehicle 

assessment with this methodology include 

the instructions on how to identify the 

number and location of ISOFIX-equipped 

seating positions, the visibility and labeling 

of the ISOFIX anchorages, the proximity of 

hardware equipment to the tether anchorage 

that could be mistakenly used to attach the 

tether, and interference between lower 

anchorages and seat belt equipment. The 

interaction between the vehicle and CRS is 

evaluated using the criteria listed in Table 2. 

The ISOFIX systems of the CRS, vehicle, 

and the interaction between the two are rated 

using a weighted scoring system with the 

weights corresponding to the importance of 

each criterion for improving ease of use and 

correct installation. Each criterion is rated on 

a 3 point scale where a rating of good, 

average, and poor are given a score of 3, 1, 

and 0, respectively. The importance of each 

criterion is also rated on a 3 point scale 

ranging from 1 to 3, with 3 being the most 

important. 

TABLE 2—CRITERIA ITEMS IN FORM 3 OF ISO 29061–1:2010 WITH SCORING SYSTEM

[CRS and vehicle interaction] 

Score 

Good, average 

and poor 

(3/1/0 points 

respectively) 

Importance 

(A,B,C = 3/2/1 

points 

respectively) 

3.1.1 Using the CRS, are the prepared vehicle ISOFIX anchorages accessible during the connecting process (i.e., is it possible to use them?) 

3.1.2 ISOFIX anchorages accessible during installation process? 

3.1.3 Is there clear feedback that the CRS is correctly attached to the ISOFIX anchorages? 

3.1.4 Can the ISOFIX attachments be tightened after the initial connection to the lower anchorages? 

3.1.5 Flexible attachments only: When properly installed, no hidden slack can exist in lower attachments. 

3.1.6 Is the child harness fully operable when ISOFIX is installed properly? 

3.2.1 Actions required to attach the tether to the tether anchorage? 

3.2.2 Can tether be tightened properly? 

3.2.3 Is there clear feedback that the child restraint system is correctly attached to the tether anchorage? 

3.3.1 Actions required to adjust the primary anti-rotational device to the correct position (e.g., a support leg 

in a rearward installation)? 

3.3.2 Actions required to operate any secondary anti-rotational device(s) [e.g., a rebound bar, or rebound 

tether(s), in a rearward installation]? 

3.4.1 CRS and base preparation: CRS Base and CRS shell ready for installation? 

3.4.2 Actions required to attach the CRS shell to base? 

3.4.3 Is there a clear feedback of correct locking of the CRS to the base? 

3.4.4 Actions required to detach CRS from base? 

3.5.1 Ease of releasing tension of tether? 

3.5.2 Actions required to detach and store the tether strap after tension has been released? 

3.5.3 Ease of releasing tension of flexible CRS attachments? 

3.5.4 Actions required to remove and store the primary anti-rotational device? 

3.5.5 Actions required to remove and store any secondary anti-rotational device(s)? 

3.5.6 Actions required to detach the attachments from the ISOFIX anchorages? 

b. Society of Automotive Engineers (SAE) 

Recommended Practice (Draft) 

A draft SAE recommended practice 

entitled J2893,110 ‘‘Guidelines for 

Implementation of the Child Restraint 

Anchorage System in Motor Vehicles and 

Child Restraint Systems,’’ developed by 

SAE’s Child Restraint Systems Standards 

Committee, provides guidelines to vehicle 

manufacturers for certain characteristics of 

vehicle lower and upper (tether) anchorages, 

and to CRS manufacturers for corresponding 

features of CRS lower anchorage and tether 

connectors, so that each of their products can 

be made more compatible with the other. 

SAE developed tools and procedures for 

evaluating the child restraint anchorage 

system hardware features in vehicles and 

child restraints. The eleven guidelines 

include the following: 

Can the child restraint fixture attach to the 

lower anchors? 

Is the force to attach lower anchors less 

than 75 Newton (N) (16.9 pound (lb))? 

Is the clearance angle as measured with a 

specified angle measurement tool greater 

than 75 degrees? 

When resting unattached on the vehicle 

seat, is the lateral angle of the child restraint 

fixture less than 5 degrees? 

When installed on the lower anchors, is the 

pitch angle of the child restraint between 5 

and 20 degrees? 

Does a specified collinearity tool attach to 

the lower anchors? 

Does a specified angle measurement tool 

contact any rigid structure around the lower 

anchors? 

When installed, is the distance from the Zpoint on the child restraint fixture to the seat 

cushion less than 51 mm? 

Are tether anchors marked with the ISO 

Symbol? 

Are lower anchors marked with the ISO 

symbol? 

If a tether router is present, does it 

accommodate a specified tether hardware 

assembly clearance tool? 

c. NCAP’s Pending Vehicle-CRS Fit Program 

On February 25, 2011,111 NHTSA 

published a request for comments on the 

agency’s plan to adopt a new consumer 

information program that would be part of 

the agency’s New Car Assessment Program 

(NCAP). The intent of the program is to make 

it easier for consumers to obtain a CRS that 

fits well in their vehicle. (76 FR 10637, 

February 25, 2011, Docket No NHTSA–2010– 

0062.) 

NHTSA proposed the Vehicle-CRS Fit 

program to be a voluntary program, in which 

NHTSA would make available to consumers 

information provided by vehicle 

manufacturers as to the specific CRSs that fit 

in specific vehicle models. NHTSA 

developed a set of criteria to define what 

constitutes an acceptable ‘‘fit’’ under the 

program. The plan was for vehicle 

manufacturers to use the criteria to assess the 

fit of child restraints in their vehicles and 

determine which CRSs can be identified as 

fitting the vehicle. The vehicle manufacturers 


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would provide this information to NHTSA, 

and NHTSA in turn would post this 

information on the agency’s NCAP Web site, 

www.safercar.gov. 

The agency proposed that part of the 

assessment of an adequate fit would evaluate 

the interface of the CRS with the child 

restraint anchorage system. The agency 

proposed that the following criteria be 

included in evaluating the fit of a CRS in a 

vehicle: 

Whether the tether of the CRS can be 

attached to the tether anchorage; 

Whether the tether can be properly 

tightened once attached to the tether 

anchorage; 

Whether the lower anchorage connectors 

on the CRS can be properly attached to the 

vehicle’s lower anchorages; 

Whether the lower anchorage connectors 

on the CRS can be tightened (if necessary) 

once connected to the lower anchorages; 

Whether the seat belt buckles for adjacent 

seating positions are available for use by 

other passengers after the CRS is installed in 

the vehicle using the lower anchorages of a 

child restraint anchorage system; and 

Whether the upper weight limit of the CRS 

is less than the upper weight limit specified 

for the vehicle’s lower anchorages. 

NHTSA envisioned that consumers would 

use the information on the safecar.gov Web 

site to see the CRSs that the vehicle 

manufacturer has said will fit a particular 

vehicle. As part of the program, NHTSA 

would conduct spot-checks of the 

manufacturers’ information to verify that the 

identified CRSs do meet the fit criteria of the 

program. 

Issued on: January 5, 2015. 

R. Ryan Posten, 

Associate Administrator for Rulemaking. 

[FR Doc. 2015–00162 Filed 1–22–15; 8:45 am] 

BILLING CODE 4910–59–P 


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