Lori Miller presentation: SAE Govt/Industry Mtg 2002

SLIDE 1:
USDOT - NHTSA
DOCKET No: NHTSA-2001-10053-NOTICE 1

SAFETY RATING PROGRAMS FOR CHILD RESTRAINT SYSTEMS


SLIDE 2:
TRANSPORTATION RECALL ENHANCEMENT, ACCOUNTABILITY, AND DOCUMENTATION (TREAD) ACT

requires that, by November 2001, a notice be issued to establish a child restraint rating consumer information program (section 14g)


SLIDE 3:
PROPOSED RATING PROGRAM FOR EASE OF USE
Rating Ease of Use in Four Categories
 - assembly
 - evaluation of labels/instructions
 - securing the child
 - installation in vehicle

SLIDE 4:
PROPOSED RATING PROGRAM FOR EASE OF USE
Assembly:
 - all functional parts including seat pad or cover, attached & ready to use
 - tether attached to child restraint
 - owner's manual easy to find
 - obvious storage packet for manual


SLIDE 5:
PROPOSED RATING PROGRAM FOR EASE OF USE
evaluation of labels/instructions
 - clear indication of child's seat range
 - all modes of use clearly indicated (eg:: rear-facing only, or forward & rear-facing if convertible)
 - air bag warning in written instructions
 - shows harness slots OK to use for occupant size
 - instructions for routing for both lap belt and lap/shoulder belt in all modes
 - visibility of seat belt routing
 - visibility of tether use
 - information in written instructions and on labels match
 - durability of labels

SLIDE 6:
PROPOSED RATING PROGRAM FOR EASE OF USE
securing the child
 - bucke can be secured in reverse (harness strap buckle)
 - harness adjustment easy to tighten and loosen when child restraint installed
 - number of harness slots/ usable slots
 - ease of attaching/removing base
 - ease of conversion rear-facing to forward-facing to booster & back again
 - visibility of harness slots
 - ease of changing harness slot position
 - ease of reassumbly if pad/cover removed for cleaning
 - ease of adjusting/removing shield


SLIDE 7:
PROPOSED RATING PROGRAM FOR EASE OF USE
installation in vehicle
 - separation of vehicle belt path
 - ease of vehicle belt routing (hand clearance)
 - ease of seat belt routing (boosters)
 - ease of use of any belt-positioning hardware on CRS including lock-off
 - tether easy to tighten and release
 - belt-positioning device allowing slack to occur


SLIDE 8:
PROPOSED RATING PROGRAM FOR EASE OF USE
Proposed Weighting of Features
 - Each ease of use feature is rated as A, B, or C, with A being the highest rating and C the lowest (A=3 points, B=2 points, C=1 point)

ALSO
- each ease of use feature is assigned a numerical scale of 1-3 points, with features having the highest relationship to safety receiving 3 points

- RATING FOR THE CATEGORY + 
	numerical value of the rating for each feature
	<times>
	numerical value of the feature's ranking


SLIDE 9:
PROPOSED RATING PROGRAM FOR EASE OF USE
sample from appendix C of notice
(table)


SLIDE 10:
PROPOSED RATING PROGRAM FOR EASE OF USE
Overall Ease of Use Rating
- NHTSA is planning to combine the planned child restraint ease of use rating into a summary ease of use rating

- proposal for combining rating is majority rule for the four categories, with 2 qualifiers:
  * a seat cannot receive a "B" rating if more than one out of the 4 categories is a "C"
  * a seat cannot receive an "A" rating if more than one out of the four categories is other than an "A".


SLIDE 11:
PROPOSED RATING PROGRAM FOR EASE OF USE
Ease of Use Rating Protocol

 - two person teams will evaluate each child restraint
 - prior to evaluation, teams will have a day of training
 - child restraints will be installed using current FMVSS 2143 bench (if and when 214 is updated, the updated test bench will be used)
 - no dummy will be used


SLIDE 12:
PROPOSED RATING PROGRAM FOR EASE OF USE
Notice Comment Period

 - Comment period closed January 7, 2002
 - Nineteen commenters replied
 - commenters included
  * child restraint & vehicle manufacturers
  * independent researchers
  * insurance association
  * advocacy organizations
  * consumer safety group
 

SLIDES 13-:
PROPOSED RATING PROGRAM FOR EASE OF USE
Summay of Comments
 - over half of the comments received were in favor of rating child restraints based on ease of use

 - several commenters suggested that lower-cost seats would be foreced from the market

 - many commenters suggested separate rating forms for each type of child restraint

 - several commenters stated that the propsed rating program was lacking a rating on LATCH

 - several commenters made specific recommendations for modifications to the feature categories and ease of use features within the categories

 - those commenters that did not support the ease of use rating program suggested that ease of use is not objective


SLIDE 15:
PROPOSED RATING PROGRAM FOR EASE OF USE
NHTSA's Next Steps
 - refine criteria as appropriate
 - test new criteria for repeatability to see if there is a correlation between cost and ratings
 - conduct focus group testing
 - publish final notice by November 2002