Identification of Issues Relevant to

Regulation, Design, and Effectiveness

National Highway Traffic Safety Administration

Office of Crashworthiness Standards

Light Duty Vehicle Division

November 4, 1996

Download the Word Perfect version of this report


Executive Summary

1.0 Review of FMVSS No. 202

1.1 Requirements/Background
1.2 Rulemaking Chronology
1.2.1 Establishment of FMVSS No. 202, Head Restraints for Passenger Cars (PCs)
1.2.2 Notice of Proposed Rulemaking (NPRM) to Incorporate FMVSS No. 202 into FMVSS No. 207
1.2.3 Expansion of FMVSS No. 202 to Trucks, MPVs & Buses
1.2.4 Clarification of Test Procedure for Head Restraint Strength

2.0 Previous Regulatory Evaluation

2.1 Passenger Car Evaluation
2.2 Light Truck Evaluation

3.0 Biomechanical Aspects of Neck Injuries and Head Restraint Design

3.1 Neck Anatomy and Range of Motion
3.2 Pathology of Whiplash
3.3 Head Restraint and Seat Design as Related to Neck Injury Mechanisms
3.3.1 Historical Perspective on Head Restraint Height Requirement
3.3.2 Current Perspectives on Head Restraint Positioning and Neck Injury
3.3.3 Seat Back Stiffness and Neck Injury
3.3.4 Neck Injury Criteria and Dummy Necks

4.0 Evaluation of Real-World Crashes

4.1 Estimated Cost of Whiplash
4.2 Injury Rate and Duration and Contributing Factors
4.3 NASS Data for Front Outboard Occupants in Rear Impacts
4.3.1 Whiplash Rate by Head Restraint Type, Vehicle Type, and Occupant Gender
4.3.2 Passenger Car Whiplash Rate by Occupant Height and Gender
4.3.3 Passenger Car Whiplash Rate by Occupant Age

5.0 Review of ODI's Consumer Complaint File

6.0 Survey of Restraint Positioning and Fleet Composition

6.1 Occupant/Head Restraint Position Survey Results
6.2 Occupant/Head Restraint Position Survey Analysis
6.3 Head Restraint Height Survey
6.4 Estimate of 1995 Fleet Composition

7.0 IIHS's Evaluation of Head Restraints

8.0 European Standard

9.0 Ongoing NHTSA Research on FMVSS No. 207, Seating Systems

10.0 Future Head Restraint Designs

11.0 Identification of Safety Issues


Appendix A

Appendix B

Appendix C

Appendix D

Appendix E

Appendix F

Executive Summary

  1. Current Head Restraint Regulation

    Since January 1, 1969 passenger cars have been required by FMVSS No. 202 to have head restraints in the front outboard seating positions. Head restraints must be at least 27.5 inches above the seating reference point in their highest position and not deflect more than 4 inches under a 120 pound load. Optionally, they must not allow the relative angle of the head and torso of a 95th percentile dummy to exceed 45 degrees when exposed to an 8 g acceleration. FMVSS 202 was extended to light trucks and vans under 10,000 pounds on September 1, 1991.

    In 1982 NHTSA reported the effectiveness of integral and adjustable restraints at reducing neck injuries in rear impacts was 17 and 10 percent, respectively. The difference was due to integral restraints being higher with respect to the occupants head than adjustable restraints, which are normally left down. It was concluded that head restraints were a cost effective safety device.

  2. Whiplash Pathology

    The term whiplash refers to the motion of the head and neck relative to the torso and the associated neck injuries occurring when a vehicle is struck from the rear. Symptoms of pain in the head, neck, shoulders, and arms may be associated with damage to muscles, ligaments and vertebrae, but in many cases no lesions are evident using non-invasive means. Onset of symptoms may be delayed and may only last a few hours, however in some cases effects of the injury may last for years.

  3. Whiplash Biomechanics and Seat Design

    1. Historical Perspective

      A historical examination of head restraint height requirements indicates that the focus has been the prevention of neck hyperextension. The predecessor to FMVSS 202 was GSA Standard 515/22 which applied to vehicle purchase by the U.S. Government and went into effect on October 1, 1967 [8]. It required that the top of the head restraint achieve a height 27.5 inches above the H-point. Also in 1967, research by Severy et al.,[31] using staged 30 mph crashes concluded that a restraint 28 inches above the H-point was adequate to prevent neck hyperextension of a 95th percentile male. Kahane [19] theorized that a 50th percentile male was adequately protected by a 27.5 inch high head restraint because it was likely to reach the base of the skull. However, Kahane also speculated that a 31 inch high restraint was more than twice as effective than a 28 inch high restraint at reducing injury.

    2. Current Perspective

      Current research supports the contention that hyperextension may not be necessary for whiplash to occur. Low speed staged impacts performed by McConnell et al.,[21] indicate that mild whiplash symptoms can occur without exceeding the normal range of motion. Animal research at Chalmers University in Sweden suggests that the rapid head/neck motion, within the normal range, cause spinal canal pressures to damage nerve ganglia [37]. In contrast Mertz and Patrick [22] showed that 44 mph impacts can be sustained without injury if no relative motion occurs between the head and torso. A Volvo study reported that when vehicle occupants involved in rear crashes had their heads against the head restraint during impact no injury occurred [18]. The same study related a rear impact simulation computer model to actual accident data and identified the rate of volume change in the cervical spinal canal as a possible predictor of whiplash injury. Other predictors identified were neck shear force, neck tensile force and head angular acceleration. Another study of Volvos involved in rear impacts showed that a significant increase in injury duration occurred when the occupant's head was more than 4 inches away from the head restraint [26].

      Several computer modeling studies have shown that seat design features other then head restraint geometry affect the likelihood of neck injury. Simulating impacts consistent with FMVSS 301 (V = 32 km/h), Nelson et al.,[24] showed that increasing recliner stiffness is likely to reduce whiplash injury and occupant rebound velocity can be controlled by the extent of plastic deformation in the seat recliner. Simulating similar rear impact velocities, researchers at the University of Virginia found occupant-to-seat friction a highly determinate factor in ramping of the occupant. They also concluded that increasing seat back stiffness would reduce ramping. Simulating much lower speed impacts (V = 12.5 km/h = 7.8 mph), Svensson et al.,[35] found that a stiffer seat, in combination with modification to upholstery, reduced head/torso displacement.

  4. NASS Data Analysis (1988 - 1994)

    1. Whiplash Cost

      It is estimated from the National Accident Sampling System (NASS) data that between 1988 and 1994, 742,340 whiplash injuries (non-contact AIS 1 neck) occurred annually in passenger cars (PCs), light trucks, and vans (LTVs). The average cost (excluding property damage) of such an injury is $6,045 [5], resulting in a total annual cost of $4.5 billion. Thus, a small improvement in the effectiveness of head restraints could yield large monetary savings.

    2. Front Outboard Adult Occupants in Tow-away Rear Impacts

      NASS data from 1988 - 1994 show that in tow-away rear impacts the injury rate for LTVs and PCs is 16.4 and 29.8 percent, respectively (see Table 4.2). However, the sample size for LTVs is much smaller and possibly less accurate. For PCs the difference in injury rate by restraint type is 3.3% (32.5 - 29.2), with integral restraints having a higher rate.

      For PCs the injury rate for females is slightly higher than for males with a difference of 1.4 percent (30.4 - 29.0). When PC occupants are segmented by gender and height the injury rate for males increases for increasing height (Fig. 4.2). For females the trend is for injury rate to decrease with increasing height, but at half the rate of the male increase. The combined male-female data show an increase in injury rate with age of PC occupant.

  5. Head Restraint Position Survey and Fleet Composition

    1. Relative Position of Head and Head Restraint

      The Insurance Institute for Highway Safety (IIHS) evaluated the head restraints of 164 vehicles based on their position relative to the H-point [6]. Scores were reduced for adjustable restraint under the assumption that they typically are not adjusted properly. Eight percent of restraints were given an acceptable or better rating. Twenty-one percent were rated marginal and 71 percent as poor.

      NHTSA performed a survey of the relative position of occupant's heads and head restraints on 282 vehicles. The tops of 59 percent of adjustable restraints were at or above the occupant's ear (Table 6.2). For integral restraints the value was 77 percent. Sixty-nine percent of adjustable restraints had a backset of less than 4 inches (Table 6.3). This value was 77 percent for integral restraints. In general, a larger percentage of integral restraints were positioned to decrease whiplash potential. Half of adjustable restraint were left down. Three quarters of these could have been raised to decrease whiplash potential (Fig. 6.1).

    2. Fleet Composition

      Using 1995 sales data for the top 20 PCs and LTVs, the percentage of integral and adjustable head restraints was estimated (Table 6.6). Nearly 90 percent of PCs have adjustable restraints. By contrast nearly 80 percent of LTVs have integral restraints.

  6. European Standard

    The European analogue to FMVSS 202 is Economic Commission for Europe (ECE) Regulation No. 25. By the year 2000 this regulation will require front outboard seating positions to have a head restraint that can achieve a height of 31.5 inches above the H-point (4 inches above FMVSS 202). The minimum height at all seating positions will be 29.5 inches above the H-point.

1.0 Review of FMVSS No. 202

1.1 Requirements/Background

Since January 1, 1969, passenger cars have been required by Federal Motor Vehicle Safety Standard (FMVSS) No. 202 to provide head restraints that meet specified requirements for each designated front-outboard seating position. On September 1, 1991, FMVSS No. 202 requirements were extended to trucks (LTs), multipurpose passenger vehicles (MPVs), and buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less. The standard requires that either of two conditions be met:

1.) During a forward acceleration of at least 8g on the seat supporting structure, the rearward angular displacement of the head reference line shall be limited to 45 from the torso reference line; or

2.) The head restraint must measure at least 27.5 inches above the seating reference point, with the head restraint in its fully extended position. The width of the head restraint, at a point 2.5 inches from the top of the head restraint or at 25 inches above the seating reference point, must not be less than 10 inches for use with bench seats and 6.75 inches for use with individual seats. The head restraint must withstand an increasing rearward load until there is a failure of the seat or seat back, or until a load of 200 pounds is applied. When the load reaches 120 pounds, the portion of the head form in contact with the restraint must not exceed a rearward displacement (perpendicular to the extended torso reference line) of 4 inches.

Two types of head restraints have been utilized to meet the requirements of FMVSS No. 202:

Integral head restraints -- This system consists of a seat back high enough to meet the 27.5 inch height requirement. There is a variety of integral head restraint designs (Appendix A).

Adjustable head restraints -- This system consists of a separate head restraint pad that is attached to the seat back by sliding metal shaft(s). The occupant may adjust the restraint to the top, bottom, or intermediate positions. Some restraints allow angular rotation (Appendix A). The angular adjustment feature allows the occupant to adjust the restraint closer to the rearmost portion of the head.

1.2 Rulemaking Chronology

1.2.1 Establishment of FMVSS No. 202, Head Restraints for Passenger Cars (PCs)

Effective January 1, 1969, each passenger car manufactured on or after that date had to comply with the requirements of FMVSS No. 202 [9]. The standard required a head restraint for the driver position and right front seating position to reduce the frequency and severity of neck injury in rear-end and other collisions. The restraint was intended to limit rearward motion of an occupant's head in a rear impact crash, thereby preventing whiplash or neck sprain injury due to hyperextension of the neck.

1.2.2 Notice of Proposed Rulemaking (NPRM) to Incorporate FMVSS No. 202 into FMVSS No. 207

On March 19, 1974, a NPRM (Docket No. 74-13; Notice 1) was published in the Federal Register [10]. The NPRM proposed to: (1) extend applicability of FMVSS No. 202 to multipurpose passenger vehicles (MPVs), light trucks, and bus driver seats manufactured after September 1, 1976; (2) establish barrier crash testing for cars, MPVs, and light trucks; and (3) consolidate FMVSS No. 202 with 207 because of the relationship between head restraints and seats.

On March 16, 1978, a Notice of Request for Public Comment (Docket No. 78-07; Notice 1) invited public comments on a draft plan for the motor vehicle safety and fuel economy rulemaking of the National Highway Traffic Safety Administration (NHTSA) over the five year period 1980-1984 [11]. A review of the active dockets revealed that a number of actions were not completed either because limited resources were directed toward higher priority actions, the magnitude of the problem was not large, or NHTSA was unable to adequately document the nature and extent of the problem. A listing and brief discussion of each of the 13 actions which the Agency contemplated terminating were presented. The NPRM (Docket No. 74-13, Notice 1) was included on the list.

On April 26, 1979, NHTSA published the "Five Year Plan for Motor Vehicle and Fuel Economy Rulemaking, Calendar Years 1980-1984" which confirmed the termination of the 1974 FMVSS No. 207 upgrade and FMVSS No. 202 consolidation [12].

1.2.3 Expansion of FMVSS No. 202 to Trucks, MPVs & Buses

On September 25, 1989, a notice of Final Rule (Docket No. 88-24; Notice 2) was published in the Federal Register extending the applicability of FMVSS No. 202, "Head Restraints," to trucks, multipurpose passenger vehicles, and buses with gross vehicle weight rating of 10,000 pounds or less [14]. The expanded applicability of FMVSS No. 202 became effective September 1, 1991.

1.2.4 Clarification of Test Procedure for Head Restraint Strength

Pursuant to the President's March 4, 1995 "Regulatory Reinvention Initiative," a Final Rule was published in the Federal Register to clarify a test procedure in FMVSS 202 [15]. The test procedure for head restraint strength made reference to the "rearmost portion of the head form." This phrase was replace with "any portion of the head form in contact with the head restraint."

2.0 Previous Regulatory Evaluation

2.1 Passenger Car Evaluation

"An Evaluation of Head Restraints, Federal Motor Vehicle Safety Standard 202", by Charles Kahane, NHTSA, February 1982, estimated the effectiveness of head restraints in reducing the overall risk of injury in rear impacts at 17 percent for integral head restraints and 10 percent for adjustable head restraints. These estimates were based on Texas State accident files from 1972, 1974 and 1977. The data did not record the type of injury so it was not possible to determine head restraint effectiveness in reducing whiplash.

Kahane estimated that 75 percent of adjustable restraints were left in the down position based on observation and evaluation of studies done from 1971 to 1973 [19, pg.108]. An analysis of data from the National Crash Severity Study (NCSS) showed that the in-use median height of adjustable head restraints was less than 26 inches. By contrast, the median height of integral head restraints was over 28 inches [19, pg.259]. Since the median height of pre-standard seat backs was about 22 inches, adjustable head restraints, in effect, provided only two-thirds as much additional height as integral head restraints. This difference in height was believed to be the dominate factor causing integral restraints to be more effective in reducing injury than adjustable restraints.

The lifetime cost of integral and adjustable head restraints was calculated to be $12.33 and $40.44, respectively, in 1981 dollars [19, pg.39]. Because of their superior ability to reduce injuries and lower cost, integral restraints eliminated 5.6 times more injuries per dollar than adjustable restraints. It was further determined that the total range of cost effectiveness for head restraints was 1020 injuries eliminated per million dollars spent for drivers with integral restraints, down to 60 injuries eliminated per million dollars for passengers with adjustable restraints (Table 2.1). In comparison, it was estimated that for a million dollars it is reasonable for society to expect the elimination of 460 - 1500 whiplash injuries. The upper bound of this estimate was calculated by considering medical costs, lost wages, and legal and insurance administrative costs. The lower bound was calculated by considering liability payments including compensation for pain and suffering and economic losses. Clearly, there was considerable overlap between the expected costs and benefits for drivers with integral head restraints. For passengers with integral restraints the confidence bounds shown in Table 2.1 overlap the range of expected benefits.

Table 2.1 Cost Effectiveness of Head Restraints [19].

Position/Restraint Type Injuries Eliminated per $Million Confidence Bounds
Driver/Integral 1020 490 - 1580
Passenger/Integral 360 160 -540
Driver/Adjustable 190 60 - 320
Passenger/Adjustable 60 20 - 110

2.2 Light Truck Evaluation

The NHTSA Final Regulatory Evaluation (FRE), Extension of Head Restraint Requirements to Light Trucks, Buses, and Multipurpose Passenger Vehicles with Gross Vehicle Weight Rating of 10,000 Pounds or Less, Federal Motor Vehicle Safety Standard 202 [32], indicated that when FMVSS 202 was issued in 1968, light truck sales were not as large a fraction of the under 10,000 pounds GVWR vehicle market as they were in 1989. In 1970, light trucks comprised 15.7 percent of the combined passenger car and light truck market, compared to 28.7 percent in 1985. The changing trends in light truck use and sales resulted in the agency deeming it appropriate to determine whether some of the safety standards originally applied only to passenger cars should be extended to other vehicles.

The FRE discussed comments received in response to the NPRM extending FMVSS No. 202 to trucks, buses, and MPVs with GVWR of 10,000 pounds or less [13]. Several commenters recommended that integral head restraints be required because they had been shown to have a higher overall effectiveness. The NHTSA Office of Plans and Policy is schedule to perform an effectiveness analysis for head restraints in light trucks in the 1997 Fiscal Year .

3.0 Biomechanical Aspects of Neck Injuries and Head Restraint Design

3.1 Neck Anatomy and Range of Motion

The skeletal structure of the neck is comprised of seven cervical vertebrae defining the top of the spine between the thorax and skull. The vertebrae are numbered from C1 to C7 as they descend the neck. The C1 vertebra is named the atlas and provides the bearing surface upon which the skull rests. The superior surface of the atlas and the occipital condyles of the skull form a synovial joint. This joint allows up/down movement of the head which is exemplified by the 'yes' gesture. Another synovial joint is formed by the atlas and the axis (C2 vertebra). This allows rotation of the head from left to right about the axis of the neck exemplified by the "no" gesture. The remainder of the vertebrae are separated by fibrocartilaginous discs. The vertebrae are tied together by many anterior (front) and posterior (rear) ligaments which run the length of the spinal column. The skull, torso and vertebrae are connected by multiple muscle which are symmetric about the midsagittal plane. Movement of the head with respect to the torso is provided by these muscles.

The following terms are used to describe neck kinematics. The term flexion refers to the combined translation and rotation of the head/neck complex forward and down in the midsagittal plane. Extension is the movement rearward and down in the same plane. Lateral flexion is the translation and rotation of the head/neck complex in the medial lateral or transverse plane. Rotation is as described above. If the prefix "hyper" is used with these terms it means motion beyond the normal or voluntary range.

A study using 100 subjects between the ages of 18 and 23 years reported the average voluntary range of motion as shown in columns two and three of Table 3.1 [4]. Columns four and five show the average voluntary range of motion from another study which used 61 subjects between the ages of 18 and 24 [30]. The combined flexion plus extension range is lower for the second study. However, direct comparison of such data must be made with caution because of variations in measurement techniques.

Table 3.2 shows the average voluntary range of motion in the midsagittal plane (flex. + ext.) reported in two studies for males and females in three age groups [30, 16]. The study represented by columns two and three show a greater range of motion across all ages and sexes. The trend for both studies is for decreasing range of motion with increased age and for females to have a greater range of motion than males for all except the 18-24 year age group.

Table 3.1 Average Voluntary Range of Neck Motion, Deg.

Subjects 18-23 yrs. [4] Subjects 18-24 yrs. [30]
Male Female Male Female
Flexion 66 69 ------------ ------------
Extension 73 81 ------------ ------------
Flex. + Ext. 139 150 129 124
Total Lateral ------------ ------------ 86 86
Total Rotation ------------ ------------ 149 150

Table 3.2 Average Voluntary Total Midsagittal Head Motion, Deg.

Study [16] Study [30]
Subject Age Male Female Male Female
18-24 138 138 129 124
35-44 109 122 103 105
62-74 94 99 77 84

3.2 Pathology of Whiplash

The term "whiplash" was first used in 1928 to describe neck injuries caused by traffic accidents [33]. Whiplash or neck sprain is not thought to be a contact injury in that it is not caused by a blow to the neck, but rather by the motion of the head and neck relative to the torso. Damage to the muscle, ligaments, and vertebrae of the neck are consistent with whiplash. In general, the injuries do not lend themselves to radiological assessment [22]. However, magnetic resonance imaging (MRI) may be more effective identifying lesions [3]. Some symptoms are neck and head pain, vertigo, and dysphagia (difficulty in swallowing). Involvement of the cervical nerves and spine often lead to symptoms in the head, shoulder, arms or upper back. Onset of symptoms may take hours or days and may last hours or years.

3.3 Head Restraint and Seat Design as Related to Neck Injury Mechanisms

3.3.1 Historical Perspective on Head Restraint Height Requirement

In a 1957 study, a head restraint design was proposed to minimize neck injury. The study proposed that a padded 6-inch fixed head restraint be attached to the top of automobile seat backs for neck protection [29]. The General Services Administration (GSA) Standard 515/22 Head Restraints for Automotive Vehicles , went into effect in October of 1967 for vehicles purchased by the federal government [8]. It required that the head restraint be adjustable to 27.5 inches above the H-point and be between 1 and 4 inches behind the torso line. The preamble of the final rule contains no details as to the selection of these parameter, but states that this standard, along with the other GSA automotive standards were "developed through consultation with Government agencies, the medical profession, trade associations, technical societies, and the automotive industry".

In 1967 Severy et al.,[31] performed 12 full scale dynamic rear impact crash tests using pairs of identical Ford sedans at impact speeds of 10, 20, 30, 40 and 55 mph. Seat back heights of 22 and 25 inches were used along with seat backs and seat back/head restraint combinations of 28 inches. Seat heights were measured from the undeformed seat surface along the seat back. This was believed to be equivalent to measuring from the H-point. In part, the research was aimed at determining the "lowest seatback consistent with effective protection from whiplash...". It was concluded that a 28 inch seat back provided "adequate protection against the injury producing forces of most rear-end collisions...", even for 95th percentile males. Results showed that in a 30 mph impact, with a 28 inch seat and the test dummy positioned with a 3 and 6 inch backset, the test dummy's rearward head rotation was 16 and 24 degrees, respectively.

Kahane presented anthropometric information to support the idea that a 27.5 inch head restraint provides adequate support for the head and neck of a 50th percentile male (70 inch tall) [19]. Adequacy of height was measured against the restraint's presumed ability to reduce whiplash caused by neck hyperextension. Kahane made the following assumptions.

"A head restraint or seat back should come close to achieving its full benefit if it is high enough to reach beyond the top of the occupants neck - i.e., up to the skull. Additional seatback height would provide little additional restraint. The seatback would provide little or no protection if it fails to reach even the bottom of the occupant's neck. If the seat back reaches somewhere between the top and bottom of the neck, it would presumably give an intermediate amount of protection". [19, pg 251]

Kahane theorized through a statistical model for a 70 inch occupant; since a) the erect seating height to the base of the skull of a 50th percentile male is about 27.5 inches above the chair base; b) people slouch between 0 and 2.5 inches; and c) the length of the neck is about 4 inches, head restraint with heights below 22 inches have almost no benefit and above 27.5 inches have almost full benefit.

3.3.2 Current Perspectives on Head Restraint Positioning and Neck Injury

During the mid-to-late 1960's, as the GSA head restraint standard was being developed and implemented, the aim of the standard and research of the era seemed focused on the reduction of whiplash due to hyperextension. Current research supports the contention that hyperextension or hyperflection may not be necessary for whiplash to occur.

McConnell et al., [21] performed a series of low speed (V 3.6 - 6.8 mph) staged rear end crash tests using volunteer test subjects (males 32 to 59 yrs.). The tops of the subjects' heads were 6.3 to 7.9 inches above the tops of the head restraints and backset was 2.0 to 4.6 inches. No cervical motion beyond voluntary range of motion was observed. However, all subjects exhibited whiplash symptoms such as mild neck awareness, head aches, and muscle soreness that lasted a few minutes to a few days. Matsushita et al., [20] had similar results in sled tests, with V 1.6 - 3.0 mph, using male and female subjects. Matsushita also offered an analysis of the kinematics of volunteers with stooped-shoulder posture which suggests that upward motion of the head relative to head restraints is not entirely reliant on the torso sliding along the plane of the seat back (ramping), but rather on straightening of the spine's curvature. This was also thought to cause compression in the cervical spine.

In contrast to the findings in [21] and [20], Mertz and Patrick [22] showed that a sled acceleration simulating a 44 mph rear collision can be withstood with little discomfort if the subject's head is initially placed against a flat head rest and the seat is rigid. This result indicates that neck injuries may be significantly reduced during rear impacts if the head is prevented from moving rearward relative to the torso in the midsagittal plane.

Svensson et al.,[36] performed sled impacts at V = 12.5 km/h (7.8 mph) on modified production seats using a Hybrid III dummy with a Rear Impact Dummy (RID) neck (see section 3.3.4 for discussion on RID neck). The surface of the head restraint was flat and vertical with its top above the head C.G. (50 mm below top of head). They found that reducing the backset from 100 mm (3.9 in.) to 40 mm (1.6 in.) caused a reduction in maximum head/torso angle from 33 to 12 degrees and head acceleration from 30.9 to 18.6 g.

In a recent study by Ono and Kanno [27], neck loads were calculated for human volunteers during rear impact (V 1.2 - 2.5 mph) sled tests with varying head restraint heights and seat angles. Tests were run with a "standard" head restraint (center of restraint at head C.G. height), a "low" head restraint (center of restraint at C1 vertebra), and with no head restraint. For all test cases the bending moment sharply increased when rotation angles were still small. This may have been due to resistance from cervical muscles, which could damage soft tissue. Head rotation, bending moment, and axial load were smallest with the standard head restraint. The highest shear force, axial force, and bending moment were found with the low head restraint. In the case of no head restraint, the shear force on the neck was the lowest, but the head rotational angle was the largest, resulting in cervical hyperextension.

In a study by Volvo, a computer model (MADYMO 2D) was developed of a seated occupant with a mechanically equivalent spine [18]. The effect of head restraint position, body lean and seat inclination were investigated for a rear impact (V = 11.2 km/h = 7 mph). Ramping and straightening of the spine occurred. Results were used to determine which measured parameters best predicted injury by correlation with real world injuries. Shear and tensile force in the neck along with head angular acceleration were identified as good predictors of injury. Also, the time derivative of the volume in the cervical spinal canal or "flow" was thought to be a good predictor of injury potential.

3.3.3 Seat Back Stiffness and Neck Injury

A French study [17] using an accident data base containing 8000 involved vehicles concluded that as seat backs have become stiffer, head restraints have become more effective at reducing neck injuries. When seat backs are weak and break upon rear impact the head restraint may not become involved in altering occupant kinematics.

Nilson et al.,[24] assessed the effect of seat recliner stiffness and energy absorption on occupant kinematics and neck loading using a MADYMO model. A Hybrid III dummy was modeled with a RID neck. Rear impacts up to a V of 32 km/h (20 mph) were modeled, approximating the impact required by FMVSS 301. The seat back was modeled with recliner stiffnesses linearly increasing with angular deflection. The "medium" stiffness was 87 Nm/degree (770 in-lbs/deg.). The "weak" and "stiff" seats had half and twice the stiffness of the "medium" seat, respectively. The three linear unloading stiffnesses used in the model, ranged from completely elastic to completely plastic. The model seat was described as having a "high" head restraint, but no dimensions were given. The results showed that increases in recliner stiffness resulted in a probable increase in occupant protection as measured by head/torso angle, C1 neck moment and head acceleration. The results improved more between the "weak" and "medium" seats than between the "medium" and "stiff" seats. The "medium" stiffness seat, with a minimum yield strength of 1.5 KN-m (13,300 in-lbs), was believed sufficient to prevent the occupant from ramping out of the seat as measured against a 60 degree limit proposed by Viano [38]. The chest rebound velocity of the dummy increased with the elasticity of the unloading phase regardless of the loading phase stiffness.

Under contract to NHTSA the University of Virginia (UVA) has developed and applied a production seat MADYMO computer model in support of an ongoing FMVSS No. 207 rulemaking. The final report will be placed in the Docket. The agency will consider the results of this when deciding whether to continue or terminate the rulemaking action of two ongoing petitions on FMVSS No. 207. The study assessed the influence of parameters such as dummy size, dummy/seat friction and seat stiffness on dummy kinematics. The study concluded that increasing the amount of rearward torque a seat back can withstand to 30,000 in-lbs at 30 degrees of deflection should reduce occupant ramping. The model also found the amount of ramping to be dependent on the seat friction value used. Ramping may reduce the effectiveness of head restraints by causing the occupants head to be farther above the restraint.

Svensson et al. [35] performed sled tests at low speeds (V = 12.5 km/h = 7.8 mph) with a Hybrid III and RID neck on production seats. The head restraint tops were adjusted to eyebrow level. The elastic rebound of the seat was found to increase the relative velocity of the head and torso if the torso rebounded forward while the head was still moving rearward. Svensson also made modifications to production seats to improve whiplash protection [36]. The surface of the head restraint was made flat and vertical with its top above the head C.G. Increases in seat back stiffness increased head/torso displacement slightly. However, a stiffer seat combined with a stiffer lower-back cushion and a deeper upper-back cushion reduced head/torso displacement. This combination of changes eliminated the horizontal gap between the head and head restraint in the initial phases of the impact.

3.3.4 Neck Injury Criteria and Dummy Necks

The accurate assessment of the ability of a head restraint to reduce whiplash injuries requires both valid neck injury criteria and a dummy with properly instrumented, biofidelic neck. The extent to which human volunteers can be used to develop neck injury criteria is obviously limited, so the precise mechanisms of whiplash injury remain unknown. Based on cadaver and very limited volunteer tests, Mertz and Patrick [23] recommended occipital condyles tolerance levels for neck extension in a 50th percentile male (Table 3.3).

Table 3.3 Proposed Tolerances for Male Neck Extension by Mertz and Patrick

Study [23]
Torque 48 Nm
Shear 845 N
Axial Tension 1000 N
Axial Compression 1110

An animal study performed at Chalmers University in Sweden indicated that pressure changes in the cervical spinal canal may cause whiplash symptoms even if the voluntary range of motion is not exceeded [37]. Live pigs were exposed to rapid extension-flexion motion of the cervical spine while the spinal canal pressure at various location were measured. Histopathological examination of the animals revealed injury to the nerve-root region of the cervical and upper thoracic spine. The researchers theorized that due to the rapid pressure change the incompressible cerebra-spinal fluid had no where to go and stressed the surrounding tissue. The same injury mechanism is possible in humans, so an effective head restraint must stop head motion before the spinal canal pressures reach an injury threshold. A quantitative assessment of the human injury threshold could not be extrapolated from these data.

A NHTSA study evaluating non-contact inertial loads on the head-neck of cadavers is currently underway. The Medical College of Wisconsin (MCW) has completed construction of a cart and pendulum mechanism to evaluate frontal, rear, and side neck injuries (Appendix B). Testing has begun and is expected to continue through the 1998 fiscal year as specimens become available. There are plans to perform a series of rear impact tests with head restraints in a variety of positions. Since the specimens lack neck musculature, development of full whiplash injury criteria is not expected. Rather, the study will add to the body of knowledge in the head/neck kinematics of rear impact.

Test dummies have been used in the dynamic evaluation of head restraints since the 1960's and the biofidelity of the results has been in question for just as long [31]. Some of the data obtained in the MCW study along with volunteer data from the Naval Biodynamics Laboratory [7] have been used in the development of an improved biofidelic neck for a new crash test dummy being funded by NHTSA. A prototype neck is being tested at the MCW facility. The entire dummy will be undergoing field testing from June 1996 to June 1997. Some researchers have surmised that the current Hybrid III dummy neck lacks biofidelity in rear impact tests. Foret-Bruno [17] found that it registered excessive shear loads when little or no relative motion between the head and torso occurred. Svensson and Lovsund believed the Hybrid III neck to be too stiff in the midsagittal plane and developed the Rear Impact Dummy (RID) neck for use with the Hybrid III [34]. The neck has a mechanical representation of C1 - T2 vertebrae and has been validated against volunteer data.

4.0 Evaluation of Real-World Crashes

4.1 Estimated Cost of Whiplash

Whiplash injuries are classified as minor injuries (AIS 1) on the Abbreviated Injury Scale (AIS) since they pose a relatively low threat to life. However, due to their high incidence rates and often long-term consequences, whiplash injuries can be associated with high societal costs.

To estimate the total cost of whiplash per year in the U.S. requires an accurate value for the cost per injury and the total number of injuries. The National Accident Sampling System - Crashworthiness Data System (NASS CDS) collected data on both towaway and non-towaway crashes until 1986. Columns two and three of Table 4.1 give the average annual number of whiplashes during the period from 1982 - 1986 in towaway and non-towaway crashes. For both PCs and LTVs the ratio of towaway to non-towaway whiplashes is 75%. Columns four and five of Table 4.1 provide the average annual number of whiplash injuries in towaways occurring from 1988 - 1994. Assuming 75% ratio between whiplashes occurring in towaway and non-towaway crashes for 1988 - 1994, it is estimated that 742,340 whiplashes occurred annually for PCs and LTVs combined. This estimate may be conservative because many cervical injuries, including whiplash, occur in unreported accidents [3]. In addition, even when the accident is reported, whiplash may not be, due to its delayed onset.

Table 4.1 Annualized Whiplash Injuries (AIS 1) from NASS

1982 - 1986 1988 - 1994

Towaway 217,599 27,962 265,173 53,183
Non-Tow 290,068 37,066 ---------- ----------

According to 1994 NHTSA estimates, when the most severe injury to an occupant is an AIS 1 injury to the face, head or neck the cost is $5,893 per person [5]. This estimate excludes property damage and travel costs, but includes medical, legal, insurance, productivity and work costs. Converting this to 1995 dollars, the cost is $6,045. Projecting this figure nationally for the estimated number of whiplash injuries, the total monetary cost is $4.5 billion [$6,045 x 742,340] annually.

4.2 Injury Rate and Duration and Contributing Factors

A review of Japanese insurance data showed that in 1991 more than 50% of the injuries in car-to-car accidents were to the neck [27]. This was up from a level of 44% in 1985. Ninety-five percent of injuries in rear impacts were AIS 1 in 1991. Seventy-eight percent of the rear impact injuries were to the neck and 95% of these were whiplash. A review of rear impacts in Sweden showed 10% of occupants with neck pain after an accident have symptoms which persist for five years [25]. The risk of medical disability was 10% for AIS 1 neck injuries and only 0.1% non-neck AIS 1 injuries. In a 1987 study of rear impact accidents in Volvos, 29 of 33 occupants suffered whiplash symptoms [26].

Olsen et al.,[26] determined that a statistically significant increase in duration of injury occurred when the occupant's head was more than 10 cm (4 in.) away from the head restraint. Forty percent had symptoms for longer than three months. In another study of Volvos, when the occupant pushed against the seat back and head restraint prior to impact, thus reducing the backset distance to zero, no injury occurred [18]. However, Nygren et al.[25] did not find backset of the head restraint to increase the rate of neck injury. Rather, he determined that the farther the top of the head restraint is below the top of the occupants head the greater the risk of injury. This is consistent with the 1981 analysis of Kahane who, based on Texas accident data, speculated that a head restraint 31 inches above the H-point is more than twice as effective at reducing overall injury than a head restraint 28 inches above the H-point [19, pg. 280].

Olsen et al. and Jakobsson et al.[18] both reported that when the stiffer vehicle side structures were involved in the rear impact the rate of neck injury increased. In Jakobsson et al., it was also reported that having a turned head at the time of impact increased the chance of neck injury lasting more than three months. A reclined seat increased the neck injury potential, but an extra cushion on the head restraint did the opposite.

4.3 NASS Data for Front Outboard Occupants in Rear Impacts

The following analyses are based on NASS weighted data of towaway crashes. Non-contact AIS 1 neck injuries (whiplash) to front outboard occupants have been identified from impacts where the primary damage was to the rear of the vehicle. As shown above in section 4.1, the majority of whiplash injuries occur in non-towaway crashes. Therefore, the trends found and observations made based on the towaway data may not hold for the entire population of crashes.

4.3.1 Whiplash Rate by Head Restraint Type, Vehicle Type, and Occupant Gender

Table 4.2 shows the annual number of whiplash injuries in rear impacts to front outboard occupants over the age of fifteen from NASS weighted data (1988 - 1994). The data are broken down by gender, vehicle type and head restraint type. The parenthetical values in each cell are the rate of injury. The injury rate for LTVs and PCs is 16.4 % and 29.8%, respectively. This is consistent with the results reported by the agency in 1989 using 1982 to 1984 NASS data [32]. The 1989 analysis included LTVs without head restraints which were estimated to be 75% of the total. The agency was not able to determine conclusively the reason for the difference in whiplash injury rate.

For the 1988 to 1994 NASS data, only LTVs coded as having head restraints were included. However, the LTV injury rate estimates may not be as accurate as those for PCs because the LTV estimates are made from a much smaller sample size. This is, in part, because LTVs were not required to have head restraints until September 1, 1991. In the NASS data file (1988 - 1994), more LTV seats were coded as not having a head restraint than as having integral or adjustable, combined. Before the 1992 model year (MY), the way in which the NASS data collectors coded a seat as having an integral or no head restraint was by subjective assessment of seat appearance. No height measurement was made. Therefore, seats which may have met the height requirement of FMVSS 202 were possibly coded as not having a head restraint.

Analyzing the PC results, the overall whiplash injury rate for both sexes and restraint types is 29.8%. This is significantly less than the rates of greater than 70% reported in Japanese insurance data [27] and 80% reported in a smaller Swedish study [26]. Part of this variation may be due to whiplash not being mentioned in the accident reports because of delayed onset. Also Kahane [19, pg. 86] showed from 1979 NASS data that the rate of whiplash or possible whiplash is higher for non-towaway rear impacts than for towaway rear impacts. For the NASS PC data the injury rate for females is slightly higher than for males, with a difference of 1.4% (30.4 - 29.0) for the combined head restraint types.

The difference in injury rate for restraint types is 3.3% (32.5 - 29.2), with integral restraints having a higher rate for both sexes combined. This is not consistent with the results from Kahane which indicated that integral head restraints were more effective in reducing neck injury [19]. It is not clear why these results differ. It may be that in newer vehicles integral restraints are being placed in relatively smaller vehicle than adjustable restraints in comparison to the vehicles of the Kahane report (See Appendix E). Also, the designs of the restraints may have changed over the years or occupants may be adjusting them properly more often than in years past. Another reason for the difference could be that Kahane used Texas data only and that data was not limited to towaway crashes.

Table 4.2 NASS (1988-94) Avg. Annual Rear Impact Whiplash for Adult Occupants (15+ yr.)

Male Female M + F
PC Integral 5315 (31.3) 6362 (33.5) 11,677 (32.5)
Adjustable 16,711 (28.4) 26,990 (29.7) 43,701 (29.2)
Int. + Adj. 22,026 (29.0) 33,352 (30.4) 55,378 (29.8)

LTV Integral 775 (22.3) 359 (9.2) 1134 (15.4)
Adjustable 245 (15.0) 339 (22.8) 584 (18.7)
Int. + Adj. 1020 (20.0) 698 (13.0) 1718 (16.4)


57,096 (29.3)

Parenthetical values indicate injury rate.

4.3.2 Passenger Car Whiplash Rate by Occupant Height and Gender

The NASS data for PC rear impacts were sorted to determine the whiplash injury rate by occupant height. The occupants were segmented into categories having a three inch height range. Occupants of unknown height were rejected, as were height ranges where the total number of unweighted observations was less than 20. Figure 4.1 shows the annualized total number of occupants involved in rear impacts and the annualized number of occupants with whiplash. The median height range for both the total number of involved occupants and occupants with whiplash is 66 through 68 inches.

Kahane found that, for rear impacts, female occupants were more vulnerable to neck injury (25% higher for towaway rear crashes) than males, prior to FMVSS 202 being in place [19, pg. 95]. He theorized that this was because females, on the average, have considerably narrower necks and less muscle mass than males. Yet, the female neck must support a head of roughly the same volume as the male neck. The NASS data in Table 4.2 showed only a slightly higher female whiplash rate ({30.4 - 29.0}/29.0 = 4.8%) for PCs when occupants of all heights were lumped together.

Figure 4.2 shows the whiplash rate for each sex broken down by height. Again, if the total number of unweighted observations was less than 20, the data were not used. Each data point represents occupants with a height range 1.5 inches about this point. A line is plotted through each data point using the "least squared" method. From these lines it can be seen that the trend for the male data is increasing injury rate with increasing height (slope = 0.01). The trend for the female data is the opposite, but the line is flatter (slope = -0.005). A possible explanation for these trends may be that since, on average, females are shorter than males the current head restraint heights are more effective in reducing injury for females. The taller males are not protected as well, causing the steeper upward trend in injury rate. Looking at the individual data points at the height ranges where the genders overlap, females have a higher injury rate at two of three height ranges. This may support the theory that female musculature is not as effective in supporting the head.

4.3.3 Passenger Car Whiplash Rate by Occupant Age

An evaluation of rear impact whiplash rate by occupant age shows an increase with age (Fig. 4.3). For occupants between 15 and 34 the rate is 27.5 percent. For occupants between 35 and 54 the rate is 32.6 percent and for those 55 and over, 34.4 percent. This may be related to the reduction in voluntary range of motion with increasing age (Table 3.2).

5.0 Review of ODI's Consumer Complaint File

The total number of consumer complaints related to head restraints for model years 1988 - 1995 was 202 (Table 5.1). Twenty-two percent of the complaints were related to the head restraint being too low/short for the occupant. Twenty percent of the complaints were related to visibility impairment.

Table 5.1 FMVSS No. 202 Complaints on Head Restraints, MY 1988-1995, all models

Nature of Complaint Number of Complaints
Too low/short 45 (22.3%)
Visibility impaired 41 (20.3%)
Does not stay up/locked 30 (14.9%)
No head restraints 26 (12.9%)
Poor design/location, no support/protection 17 ( 8.4%)
Uncomfortable, rattles, loose, other minor problems 17 ( 8.4%)
Too far back 13 ( 6.4%)
Broke, failed 13 ( 6.4%)

202 (100%)

Note: Results of data run performed on September 13, 1995

A subgroup of complaints (Table 5.2) was compiled to evaluate accident related complaints with respect to head restraints. Five complaints stated that the head restraint detached, bent or no longer locked due to the accident. Four consumers believed they were injured because their head restraint was too low. One consumer believed his accident was due to impaired vision caused by the head restraint.

Table 5.2 Complaints Related to an Accident, MY 1988-1988, all Models

Nature of Complaint Number of Complaints
Failed after accident (e.g., detached,

does not lock, bent, etc.)

Injured due to low head restraint 4
Injured due to no head restraint 4
Head restraint not up/locked

during accident

Impaired visibility caused accident 1


In the past, there were two investigations related to head restraints: (1) Electrically Operated Headrest Failure or Malfunction--BMW 5- & 7-series, MY unknown; and (2) Failure of Front Seat Head Restraint--Ford Taurus, MY 1986-1988. The first investigation was initiated because the electrically operated front seat head restraints could fail to move even though the drive motor was operating. The second investigation was prompted because a consumer alleged that the adjustable front seat head restraint could not be maintained in a raised position. Neither of the investigations led to a recall.

6.0 Survey of Restraint Positioning and Fleet Composition

6.1 Occupant/Head Restraint Position Survey Results

In the Fall of 1995 a survey was performed at the Department of Transportation Headquarters and a Washington area Metro (subway) parking lot exit to evaluate head restraint usage. The survey included an evaluation of the head restraint location relative to the drivers of PCs and LTVs . The survey was aimed towards newer vehicles. The survey data form is shown in Appendix C. The numerical results are given in Tables 6.1 - 6.4 and Figure 6.1. Two-hundred and eighty-two driver head restraints were evaluated. There were two occurrences of restraint removal. Seventy-seven percent of the surveyed restraints were adjustable and 23 percent were integral (Table 6.1).

Table 6.1 Distribution of Integral and Adjustable Head Restraint

Sample Size % Integral % Adjustable
282 23 77

It was determined visually if the top of the head restraint was at or above the level of the top of the driver's ear (Table 6.2). This is the approximate location of the head's C.G. Fifty-nine percent of the adjustable restraints surveyed were at or above the top of the driver's ear. Seventy-seven percent of the integral restraints surveyed were at or above the top of the driver's ear.

Table 6.2 Vertical Position of Top of Head Restraint With Respect to Top of Occupants Ear

At or Above Ear Below Ear
Adjustable 59% 41%
Integral 77% 23%

A visual determination was also made of whether the driver's head was within 4 inches horizontally of the head restraint (Table 6.3). For adjustable head restraints 69 percent were touching or within 4 inches of the driver's head. Twenty-nine percent of these restraints were greater than 4 inches from the occupant's head. An assessment could not be made for 2 percent of cases. Seventy-seven percent of the integral head restraints surveyed were touching or within 4 inches of the driver's head. Twenty percent of these restraints were greater than 4 inches from the occupant's head. Three percent could not be assessed.

Table 6.3 Backset of Head Restraint With Respect to Rear of Occupants Head

0" - 4" > 4" Unknown
Adjustable 69% 29% 2%
Integral 77% 20% 3%

As mention in section 2.1, Kahane [19] estimated that 75 percent of adjustable restraints were left in the down position. In the current survey it was determined that 47 percent of adjustable restraints were left in their lowest position (Fig. 6.1). Twenty-six percent of these were sufficiently high to have the top of the restraint above or at the top of the ear. Fifty-one percent of adjustable restraints were not in their lowest position. Thirty percent of these were below the top of the ear. Two percent of all adjustable restraint cases could not be assessed.

6.2 Occupant/Head Restraint Position Survey Analysis

To get a sense of the combined vertical and horizontal position of the surveyed head restraints, each was placed in Class A, B or C (Table 6.4). The classes correspond to the restraint's position or potential position referenced to the driver's head. A head restraint was placed in Class A when: (1) the top of the head restraint was at or above the top of the occupant's ear, and (2) the head restraint was less than four inches away from the rearmost portion of the occupant's head. A head restraint located too far away from the occupant's head and/or too low could potentially allow rearward and/or angular displacement between the head and neck before the head contacts the restraint. Thus, restraints in Class A, potentially, offer better whiplash prevention. A head restraint was placed in Class B if, when observed, it was not positioned to meet criteria (1) and/or (2), but appeared capable of being adjusted to meet them by raising the head restraint or reducing the seat recline angle. Class C restraints appeared not capable of being positioned to meet criteria (1) and/or (2).

Fifty-three percent of the surveyed adjustable head restraints were in Class A. An additional 19 percent were in Class B with the remaining 28 percent in Class C. For integral restraints, 70 percent were in Class A, 30 percent in Class C and none in Class B.

Table 6.4 Overall Classification of Head Restraint Position

Class A Class B Class C
Adjustable 53% 19% 28%
Integral 70% 0% 30%

Based on the overall survey results the following observations can be made.

  1. Three quarters of head restraints were adjustable.

  2. Half of the adjustable restraints were left in the "down" position. Three quarters of these could have been raised to increase the potential whiplash protection.

  3. Of the restraints that were vertically adjusted, thirty percent required further adjustment to increase the potential of whiplash protection.

  4. A greater percentage of integral head restraints than adjustable head restraints were positioned to provide increased potential for whiplash protection. With proper positioning a similar percentage of adjustable restraints could achieve the same level of potential effectiveness.

Other qualitative observations were apparent from the survey. For example, many newer vehicles (MY 1990+) had a rotating feature that allowed the restraint to be in closer proximity to the occupant's head. Many occupants adjusted the restraint to fit behind the neck. Consumers may not perceive the head restraint as a protective device, but simply as a head rest or pillow. In addition, the newer vehicle head restraints appeared to be more upright and closer to the occupant than in previous models. In older model vehicles (MY 1980's & older), the head restraints tended to follow the seat back angle.

6.3 Head Restraint Height Survey

To obtain a rough estimate of head restraint heights at the driver's position for late model vehicle, a small number of vehicles were sent to the Vehicle Research and Test Center (VRTC) in Ohio. VRTC measured the maximum and minimum heights using the procedure defined in FMVSS 202. The sample consisted of 20 vehicles: 14 PCs and 6 LTVs. The results for each vehicle are shown in Appendix D. The averages are contained in Table 6.5. Of the 14 PCs measured, 11 had adjustable restraints. Of the six LTVs measured, three had adjustable restraints. On average, the LTV integral restraints were 0.9 inches over the 27.5 inch requirement of FMVSS 202. The PC integral restraints were 2.3 inches above the required height. The adjustable restraints for the LTVs and PCs achieved similar average maximum heights at about 1.3 inches over the requirement. The average adjustment ranges were 1.7 and 2.1 inches for LTVs and PCs, respectively.

Table 6.5 Average Head Restraint Heights From 20 Vehicles (inches).


Min. Max. Min. Max.
Adjustable 27.1 28.8 (n = 3) 26.8 28.9 (n = 11)
Integral ---------- 28.4 (n = 3) ---------- 29.8 (n = 3)

Note: n = sample size.

6.4 Estimate of 1995 Fleet Composition

Kahane [19, pg. 114] reported that for PCs in model years 1969 - 1981 the percentage of integral restraints varied between 9% and 39%, with the value in 1981 being 33%. To obtain a rough estimate of the distribution of integral versus adjustable head restraints in the front outboard positions of recently manufactured vehicles the sales figures for the 1995 top 20 selling PCs and LTVs were acquired [2]. The restraint type for each model was determined by observation at vehicle dealerships. Although some models had both types of head restraint available, depending on the trim-line, only the type most commonly observed was used. Appendix E contains the sales data and restraint type for each model. The top 20 sales leaders accounted for 50 and 76 percent of total 1995 sales for PCs and LTVs, respectively. Table 6.6 shows the restraint type distribution. The data clearly indicate that, in newer vehicles, PCs typically have adjustable restraints and LTVs typically have integral restraints. However, when lumped together there is about an even split between the two restraint types.

Table 6.6 Estimated Head Restraint Type Distribution for

Top 20 Selling 1995 MY PCs and LTVs

Adjustable Integral
PC 88% 12%
LTV 21% 78%
Total 53% 47%

7.0 IIHS's Evaluation of Head Restraints

In November 1995, the Insurance Institute for Highway Safety (IIHS) published the report, Measurement and Evaluation of Head Restraints in 1995 Vehicles, [6]. The head restraints in 164 vehicles were measured: five were rated as good, eight acceptable, 34 marginal and the remaining 117 as poor.

The head restraint evaluations were based on two criteria: the height of the restraint and its horizontal distance from the back of the head (backset). Both of these variables were measured relative to the head of a seated average-size male, as represented by a specially designed head form mounted on a standard H-point machine. The H-point machine was seated in accordance with FMVSS No. 208 S11.4.3.1 and the seat was adjusted to achieve a torso angle of 25 degrees from vertical.

The vertical reference value used in the evaluation of each head restraint was the distance from the top of the head to the head's center of gravity. The vertical reference measurement of 9 cm was taken from the 50th percentile adult male dummy drawing [1]. The height of a head restraint was rated as "marginal" if the restraints top was 9 1 cm below the top of the head form. The vertical rating was "good" if the distance from the top of the head form to the top of the restraint was less than 6 cm (i.e. the top of the head restraint was at least 3 cm above the head's center of gravity). Table 8.1 shows the dimensions for each rating.

The reference value used to evaluate backset was 10 cm. This is from a study by Olsson [26], mentioned in section 4.2, that showed a statistical relationship between the backset and the duration of neck symptoms. The backset of a restraint was rated as "marginal" if the horizontal distance between the head form and restraint was 10 1 cm. The backset was rating as "good" if the distance was less than 7 cm. A restraint's overall rating was the lower of the height and backset scores.

Table 8.1 IIHS Head Restraint Rating Dimensions

Height Rating Backset Rating

Top of Head Form to Top of Head Restraint Back of Head Form to Head Restraint
Good < 6 cm < 7 cm
Acceptable 7 1 cm 8 1 cm
Marginal 9 1 cm 10 1 cm
Poor > 10 cm > 11 cm

IIHS first evaluated adjustable restraints in their lowest position. If the restraint manually locked in its "up" position it was also evaluated in that position. If IIHS determined that a restraint would possibly lock under dynamic loading, the restraint was evaluated in its "up" position. The overall rating of adjustable restraints were lowered one category to reflect the likelihood that many occupants would not adjust the head restraint. Restraints that did not lock manually or dynamically in the up position received a score based on the measurements for the "down" position.

It should be pointed out that the IIHS head restraint ratings were based on geometric values only and were not correlated with either injury claims or injury rates for those specific make-models. Such an analysis may verify the geometric value rating of the vehicles.

8.0 European Standard

The European analogue to FMVSS 202 is Economic Commission for Europe (ECE) Regulation No. 25. In its current form the regulation requires all forward facing outboard seats to have head restraints. FMVSS 202 only requires restraints in the front outboard seats. Regulation No. 25 requires integral head restraints to have a 29.5 inch height above the H-point. Adjustable restraints must be able to achieve this height, but cannot be any lower than 27.5 inches in any position of adjustment. The achievable height specified by ECE No. 25 is 2 inches higher than required by FMVSS 202. Further, FMVSS 202 has no minimum limit for the range of adjustment.

In May of 1996, a proposal was accepted to phase-in raised head restraint height requirements for front outboard seats and raised minimum head restraint height requirements for all outboard seats. The phase-in period is 48 months, after which front head restraints must be able to achieve a height of 31.5 inches. Adjustable head restraint in front and rear seats cannot be any lower than 29.5 inches. These new provisions result in a required achievable head restraint height four inches above that required by FMVSS 202. The minimum acceptable height will be 2 inches higher than the required achievable height in FMVSS 202.

9.0 Ongoing NHTSA Research on FMVSS No. 207, Seating Systems

In addition to the research project sponsored at UVA (see section 3.3.3), NHTSA is funding the development of a generic integrated safety seat by EASi Engineering (EASi) and Johnson Controls (JCL), Inc. EASi is subcontracted to JCL to build and test the prototype for safety requirements. The designed integrated seat will be for a production vehicle and the safety requirements will exceed the current FMVSS requirements including FMVSS 202. A report on the final design will be placed in the Docket during the Fall of 1996. Prototypes may be designed and tested in consultation with the agency.

10.0 Future Head Restraint Designs

A variety of new head restraint designs have been proposed in an effort to reduce whiplash by improving the relative position of the head and head restraint. The "Cervigard" is a form fitting passive head restraint which attempts to be in close proximity to and support the entire head/neck complex [39].

Another proposed head restraint uses proximity sensors to track the occupant head during normal driving [28]. Electrical motors then automatically position the head restraint vertically and horizontally. During a rear impact the restraint is passive. A patent is pending on the device.

Delphi Interior and Lighting Systems has developed the Pro-tech active head restraint (Appendix F). During normal driving the head restraint can be adjusted as desired by the occupant. During a rear impact the force of the occupants torso on a pressure plate in the seat structure forces the restraint forward and upward. The developers believe this deployment process will occur rapidly enough to limit the relative motion of the head and torso resulting in a reduction in whiplash injuries. The first commercial application of the patented device will be in the 1997 Saab 9000. The Pro-tech head restraint is part of a total seat system called the "Catcher's Mitt". The "Catcher's Mitt" promises high retention of the occupant during a rear impact by providing energy absorption in transverse deforming seat back cross members. The deforming lower seat back cross member produces a pocketing of the occupant's pelvis and lower back in the deforming seat back padding which resists ramping as well as attenuates occupant loading.

11.0 Identification of Safety Issues

The purpose of a head restraint is to prevent whiplash injury of the neck in rear-impact crashes. There are several open questions related to the protection provided by head restraints.

(1) Are existing restraints sufficient in preventing neck injuries in rear impacts? How can head restraints and seating systems be improved to reduce neck injuries? What means should be used to measure improvements?

(2) Is the height requirement sufficient? Should there be a requirement for the horizontal distance between the head and head restraint? Should adjustable head restraints have to lock in position?

(3) If the FMVSS 202 height requirement is changed, should the alternate dynamic procedure be changed to maintain equivalence between the compliance options? Is a dynamic test procedure a necessity for active head restraints? Is the current knowledge base in neck injury criteria sufficient to extend the performance requirements of the dynamic procedure? Would changes to the Hybrid III neck have to be made?

(4) In response to the 1982 Evaluation [19], one commenter opposed higher restraint height requirements due to the potential decrease of occupant visibility. Can a solution be reached which considers visibility and injury prevention?

(5) The current European Community head restraint height requirements exceed FMVSS 202 and they are proceeding with increased height requirements. Should this provide the bases for a change in the U.S.?

(6) In what way could an upgrade of FMVSS No. 207, Seating Systems, affect requirements for head restraints? Should any change in FMVSS No. 202 be synchronized/ integrated with changes in FMVSS 207?

  1. Anthropometric Specifications for Mid-Sized Male Dummy (side-view with skeleton), Transportation Research Institute. The University of Michigan, Drawing No. mm-104.

  2. Automotive News: Vol. 1, April 24, 1996, pp. 145.

  3. Barancik, J. I.; Anand, A. K.; Thode, Jr. H. C.; Kramer, C. F.; Rogue, C. T.; Morton, S. L.; Kelaher, J. E.; Smallwood, S. A. (1991): Pilot Investigation of Relationship Between Neck/Cervical Spine Trauma, Associated Imaging and Crash Descriptors. Department of Applied Science, Brookhaven National Laboratory, Upton, New York. January 1991.

  4. Buck, C.A.; Dameron, F.B.; Dow, M.J.; and Skowlund, H.B. (1959): Study of Normal Range of Motion in the Neck Utilizing a Bubble Goniometer. Archives of Physical Medicine and Rehabilitation, Vol. 40, pp. 390-392.

  5. Blincoe, L.H. (1994): The Economic Cost of Motor Vehicle Crashes, 1994. US DOT, NHTSA, HS 808 425, Washington, D.C.

  6. Estep, C. R. and Lund, A. K. (1995): Procedure for Head Restraint Evaluations. Insurance Institute for Highway Safety, Arlington, Virginia, June 1995.

  7. Ewing, C.L.; Thomas, D.J. (1972): Human Head and Neck Response to Impact Acceleration. NAMRL Monograph 21, Naval Aerospace and Regional Medical Center, Pensacola, FL.

  8. Federal Register, Vol. 31, July 15, 1966, p. 9637.

  9. Federal Register, Vol. 33, February 14, 1968, p. 2945.

  10. Federal Register, Vol. 39, March 19, 1974, p. 10268.

  11. Federal Register, Vol. 43, March 16, 1978, p. 11100.

  12. Federal Register, Vol. 44, April 26, 1979, p. 24591.

  13. Federal Register, Vol. 53, December 13, 1988, p. 50047.

  14. Federal Register, Vol. 54, September 25, 1989, p. 39183.

  15. Federal Register, Vol. , 1996

  16. Foust, D.R.; Chaffin, D.B.; Snyder, R.G.; Baum, J.K. (1973): Cervical Range of Motion and Dynamic Response and Strength of Cervical Muscles. SAE Paper 73095, Proc. Of 17th STAPP Car Crash Conf.

  17. Foret-Bruno, J.Y.; Dauvilliers, F.; Tarriere, C. (1991): Influence of The Seat and Head Rest Stiffness on the Risk of Cervical Injuries in Rear Impact. Proc. 13th ESV Conf. in Paris , France, paper 91-S8-W-19, US DOT, NHTSA, HS 807 991.

  18. Jakobsson, L.; Norin, H.; Jernstrom, C.; Svensson, S.E.; Johnsen, P.; Hellman, I.I.; Svensson, M.Y. (1994): Analysis of Head and Neck Responses in rear end impacts - a new human-like model. Volvo Car Corporation Safety Report.

  19. Kahane, D.J. (1982): An Evaluation of Head Restraint - Federal Motor Vehicle Safety Standard 202. NHTSA Technical Report, DOT HS-806 108, National Technical Information Service, Springfield, Virginia 22161.

  20. Matsushita, T. et al. X-Ray Study of the Human Neck Motion Due to Head Inertia Loading. Proc. of 38th STAPP Car Crash Conference, 1994.

  21. McConnell, W.E.; Howard, R.P.; Guzman, H.M.; Bomar, J.B.; Raddin, J.H.; Benedict, J.V.; Smith, H.L.; Hatsell, C.P. (1995): Human Head and Neck Kinematics After Low Velocity Rear-End Impacts - Understanding "Whiplash." SAE Paper 952724, Proc. Of 39th STAPP Car Crash Conf.

  22. Mertz, H. J.; Patrick, L. M. (1967): Investigation of the Kinematics and Kinetics of Whiplash. Proc. 11th STAPP Car Crash Conf., Anaheim, California, USA, pp. 267-317, LC-67-22372

  23. Mertz, H. J.; Patrick, L. M. (1971): Strength and Response of the Human Neck. SAE Paper 710855, Proc. 15th STAPP Car Crash Conf.

  24. Nilson, G.; Svensson, M.Y.; Lovsund, P.; Viano, D.C. (1994): Rear-End Collisions - The Effect of Recliner Stiffness and Energy Absorption on Occupant Motion. Dept. of Injury Prev., Chalmers Univ., Gotegorg, Sweden, ISBN 91-7197-031-2.

  25. Nygren, A.; Gustafsson, H.; Tingvall, C. (1985): Effects of Different Types of Headrests in Rear-End Collisions. Proc. 10th ESV Conf., pp. 85 - 90, NHTSA, HS 806 916.

  26. Olsson, I.; Bunketorp, O.; Carlsson, G.; Gustafsson, C.; Planath, I.; Norin, H.; Ysander, L. (1990): An In-depth Study of Neck Injuries in Rear-end Collisions. 1990 International IRCOBI Conference on Biomechanics of Impacts, pp. 269-280, Bron-Lyon, France

  27. Ono, K and Kanno, M. (1993): Influences of the Physical Parameters on the Risk to Neck Injuries in Low Impact Speed Rear-End Collisions. 1993 International IRCOBI Conference on Biomechanics of Impacts, pp. 201-212, Eindhoven (The Netherlands).

  28. Rachmilevitch, A. (1996): Anti-Whiplash Protection. Proc. 29th Int. Symposium on Automotive Technology and Automation, Florence, Italy, pp. 535-541.

  29. Ruedemann, A.D. (1957): Automobile Safety Device - Head Rest to Prevent Whiplash Injury. Journal of the American Medical Association, Vol. 164, pp. 1189.

  30. Schneider, L.W.; Foust, D.R.; Bowman, B.M.; Snyder, R.G.; Chaffin, D.B.; Abdelnour, T.A.; Baum, J.K. (1975) Biomechanical Properties of the Human Neck in Lateral Flexion. SAE Paper 751156, Proc. of 19th STAPP Car Crash Conf.

  31. Severy, D.M.; Brink, M.H.; Baird, J.D. (1968): Backrest and Head Restraint Design for Rear-End Collision Protection. SAE Paper 680079.

  32. Simons, J. (1989): Final Regulatory Evaluation: Extension of Head Restraint Requirements to Light Trucks, Buses, and Multipurpose Passenger Vehicles with Gross Vehicle Weight Rating of 10,000 Pounds or Less, Federal Motor Vehicle Safety Standard 202. NHTSA Technical Report, DOT HS

  33. States, J. D.; Balcerak, J. C.; Williams, J. S.; Morris, A. T.; Babcock, W.; Polvino, R.; Riger, P. And Dawley, R. (1972 ): Injury Frequency and Head Restraint Effectiveness in Rear-End Impact Accidents. Paper 720967. Proc. of 16th STAPP Car Crash Conf., 1972.

  34. Svensson, M. Y. and Lovsund, P. (1992): A Dummy for Rear-End Collisions - Development and Validation of a New Dummy Neck. Proc. 1992 International. IRCOBI Conf. On the Biomechanics of Impacts, pp. 299-310, Verona, Italy

  35. Svensson, M.Y.; Aldman, B.; Lovsund, P.; Haland, Y.; Larsson, S. (1993): Rear-End Collisions - A Study of the Influence of Backrest Properties on Head-Neck Motion Using a New Dummy Neck. SAE paper no. 930343.

  36. Svensson, M.Y.; Aldman, B.; Lovsund, P.; Haland, Y.; Larsson, S. (1993): The Influence of Seat-Back and Head-Restraint Properties on the Head-Neck Motion During Rear-Impact. Proc. 1993 Int. IRCOBI Conf. On the Biomechanics of Impacts, Eindhoven, The Netherlands, pp. 395-406.

  37. Svensson, M.Y.; Aldman, B.; Lovsund, P.; Hansson, H. A.; Seeman, T.; Sunesson, A.; Ortengren, T. (1993): Pressure Effects in the Spinal Canal during Whiplash Extension Motion - Possible Cause of Injury to the Cervical Spinal Canal Ganglia. Proc. 1993 International IRCOBI Conference On the Biomechanics of Impacts, Eindhoven (The Netherlands)

  38. Viano, D.C. (1992): Restraint of a Belted or Unbelted Occupant by the Seat in Rear-End Impacts. SAE paper no. 922522, Proc. 36th STAPP Car Crash Conf., pp. 165-178.

  39. Automotive Industries: Vol. 175, April, 1995, pp. 76.

Appendix A

Samples of Head Restraint Designs

Appendix B

Medical College of Wisconsin Test Setup

Appendix C

Occupant/Head Restraint Position Survey Form



















< 4" AWAY > 4" AWAY



< 4" AWAY > 4" AWAY
















Appendix D

Head Restraint Height Survey Results
Make Model Model Year VIN Restraint Type Front Restraint Heights Head Restraint Width 2.5" Below Top
Integral Adjustable Integral Adjustable
Linear Angular Max. Min.
Pontiac Sunfire (2 Dr.); Bucket 1995 1G2JB1246S7525177

30.00" 28.38" 9.0"
Jeep Cherokee 4x4 (2 Dr.); Bucket 1994 1J4FJ27S5RL204793

28.5" 26.75" 10.75"
Ford Windstar Minivan; Bucket 1995 2FMDA5142SBB41033


Plymouth Acclaim (4 Dr.); Split bench 1992 1P3XA46K1NF229044

28.25" 25.5" 11.5"
Saturn SC Coupe

(2 Dr.); Bucket

1992 1G8ZG1475NZ113598

28.63" 27.0" 10.75"
Eagle Vision (4 Dr.); Bucket 1993 2E3ED56T9PH534039

27.5" 24.0" 10.25"
Nissan 240SX (2 Dr.); Bucket 1994 JN1AS44D4SW007796

29.13" 28.25" 9.25"
Ford Explorer (2 Dr.); Bucket 1993 1FMDU32XXPA55250


Chevrolet Lumina (4 Dr.); Split bench 1995 2G1WL52MXS1172244

29.5" 27.0" 11.0"
Honda Civic (2 Dr.); Bucket 1993 2HGEH2367DH518401


Volvo 850 (4 Dr.); Bucket 1996 YV1LS556T2268222


Toyota Camry LE (4 Dr.); Bucket 1996 4T1BG12KXTU674917

29.5" 27.0" 11.25"
Ford Taurus LX (4 Dr.);Bucket 1996 1FALP53S8TA118031

29.25" 27.75" 10.5"
Honda Passport (4 Dr.); Bucket 1995 4S6CY58V8S4416752

29.0" 27.5" 10.25"
Pontiac Bonneville SE (4 Dr.); Split Bench 1996 1G2HX52K5TH200537

28.5" 26.25" 12.5"

Probe SE (2 Dr.); Bucket 1995 1ZVLT20A0S5143817


Ford Thunderbird (2 Dr.); Bucket 1995 1FALP6247SH130959

28.0" 26.25" 11.0"
Ford F-150 XLT P/U; Bench 1995 1FTEF15N6SLB25102

29.0" 27.0" 10.5"
Chrysler Cirrus Lxi (4 Dr.); Bucket 1996 1C3EJ56H7TN124484

30.0" 27.25" 10.5"
Dodge Grand Caravan SE; Bucket 1996 1B4GP44R1TB185367



Appendix E

1995 Vehicle Sales Data and Restraint Type

Passenger Cars Light Trucks and Vans
Vehicle 95 Sales HR Type Vehicle 95 Sales HR Type
Ford Taurus 366266 A - 96' Ford F pickup 691452 I
Honda Accord 341384 A Chevrolet C/K pickup 536901 A
Toyota Camry 328602 A Ford Explorer 395227 I - 96'
Honda Civic 289435 I Ford Ranger 309085 I
Saturn 285674 A Dodge Ram pickup 271501 I
Ford Escort 285570 A Dodge Caravan 264937 I
Dodge Neon 240189 I Jeep Grand Cherokee 252186 I
Pontiac Grand Am 234226 A Ford Windstar 222147 A
Chevrolet Lumina 214595 A Chevrolet Blazer 214661 A
Toyota Corolla 213640 A Chevrolet S10 pickup 207193 I
Chevrolet Cavalier 199001 A Plymouth Voyager 178327 I
Chev. Corsica 192361 A GMC Sierra pickup 176957 A
Ford Contour 174214 A Ford Econoline van 157803 I
Nissan Altima 148171 A Toyota compact pickup 143472 A
Dodge Intrepid 147576 A Nissan compact pickup 126662 A
Buick LeSabre 141410 A Chevrolet Astro 119510 I
Ford Mustang 136962 A Dodge Dakota 111677 I
Nissan Sentra 134691 A Jeep Cherokee 110552 I - 96'
Pontiac Grand Prix 131747 A Ford Aerostar 87547 I
Olds. Cutlass Ciera 128860 A Chevrolet G van 86838 I

Note: A = Adjustable, I = Integral. All sales data is for 1995. Head restraint types are for MY 95 except as indicated.

Appendix F

Advanced Head Restraint Design