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1. New NHTSA policy on replacement of CR (Jan/ Feb 2004)
NHTSA has adopted the position quoted in the box (below) regarding re-use of CRs after minor crashes. The change was made public in a press release in February and included in the new CPS curriculum just before it went to press.
The agency is “committed to maintaining policies that are science based and data driven.” The new policy is based on tests done by the Insurance Corporation of British Columbia (ICBC) and the Insurance Institute for Highway Safety (IIHS). ICBC tested a various CRs in multiple low-speed and high-speed (30- and 40- mph) impacts, finding that, despite minor changes, the seats continued to perform reasonably well. IIHS performed multiple 30- mph tests on four CRs and concluded that there was no degradation of performance. In a letter to SRN, a NHTSA official said: “NHTSA now believes that child safety seats are sufficiently durable that they do not have to be automatically replaced following a minor crash. Common sense should be used in deciding whether to replace such a seat.”
NHTSA requsted anyone with additional data to share it with the agency.
The final language in the curriculum was tempered somewhat by acknowledging the position of most manufacturers on replacement. The text was clearly weighted toward support for non-replacement after a minor crash.
See the NHTSA web site for details on the research on which this decision was based: www.nhtsa.dot.gov/people/injury/childps/ChildRestraints/ReUse/RestraintReUse.htm
NHTSA Policy on Re-Use of Child Restraints
“NHTSA recommends that child safety seats be replaced following a moderate or severe crash in order to ensure a continued high level of crash protection for child passengers.
“NHTSA recommends that child safety seats do not automatically need to be replaced following a minor crash.
“Minor crashes are those that meet ALL of the following criteria:
• The vehicle was able to be driven away from the crash site;
• The vehicle door nearest the safety seat was undamaged;
• There were no injuries to any of the vehicle occupants;
• The air bags (if present) did not deploy; AND
• There is no visible damage to the safety seat
“Clarifying the need for child seat replacement will reduce the number of children unnecessarily riding without a child safety seat while a replacement seat is being acquired, and the number of children who will have to ride without a child seat if a seat were discarded and not replaced. The clarification will also reduce the financial burden of unnecessary replacement.
“The agency is committed to maintaining policies that are science-based and data-driven. Stakeholders with data that address post-crash re-use of child safety seats are encouraged to provide this information to the agency.”
See Safe Ride News editoral: 4. Controversial policy changes
2. Replacement of CR after crash—CA law (Jan/ Feb 2003)
The latest upgrades of a continually developing child restraint law, which came into effect on January 1, 2003, focuses on insurance-related issues.
State law already required auto liability, property damage, collision, or uninsured motorist policies to cover replacement of child restraints used in crashes. AB 1902 includes revisions to the insurance code obligating insurers to ask whether a CR was in use during the crash and to replace it or reimburse for the cost of a replacement.. It also designates all California Highway Patrol offices as collection sites for replaced CRs that had been used in crashes.
The motor vehicle code prohibits individuals from offering for sale or selling a CR that was in use during a crash. A violation means a fine of $100.
3. Child Restraint Upgraded (FMVSS 213) (July/ Aug 2003)
FMVSS 213 Upgraded, Coverage Extended to 66 Pounds
In June, NHTSA issued significant amendments to FMVSS 213 that will, when implemented, provide a better basis for evaluating the crashworthiness of child restraints. The most immediate change, which will become effective December 22, 2003, will raise the weight limit of child restraints to 66 pounds (30 kg). Products between 50 and 66 pounds will be tested with a weighted 6-year dummy for structural integrity only.
Other major changes are optional before August 1, 2005, and mandatory at that time. In addition to the 66-pound upper weight limit, changes include:
1) Using a bench seat on the test sled that will be more representative of current vehicle back seats, having a steeper slope to the seat cushion (15 degrees instead of only 8 from horizontal), more reclined seat back (20 degrees instead of only 15 from vertical), and wider spacing for seat belt anchors for side and center positions.
2) Using the new, state-of-the-art dummies also used in air bag testing:
• 12-month CRABI (Child Restraint Air Bag Interaction) dummy with instrumentation for head and chest accelerations and neck forces (previous infant dummies had no instrumentation for measuring stresses); the newborn dummy would be unchanged.
• 3- and 6-year Hybrid III dummies (weighing 34 pounds and 51.6 pounds respectively) with head/chest/neck instrumentation as well as chest compression.
• As before, only head and chest measures will be used for compliance with the standard. Other measurements will be used only for research.
• A weighted version of the Hybrid III 6-year dummy (62 pounds—approximating the weight of an average 8-year-old but shorter) with no instrumentation will be used for testing only the structural integrity of CRs for children from 50 to 65 pounds. Weighting is common practice today. This will be an interim dummy to use until the Hybrid III 10-year-old dummy becomes available.
3) Putting more liberal upper and lower limits on the crash pulse, so that tests can be conducted at speeds closer to 30 mph while keeping the acceleration inside the legal "corridor." Current compliance tests have been criticized (by Consumers Union, for instance) for being too slow.
NHTSA says that it believes that use of the new dummies will not necessitate redesign of current restraints. However, there will be costs for purchasing the new dummies and for certifying the existing restraints to the new requirements.
The changes in the test bench seat will help harmonize the U.S. test environment with the European regulation (ECE 44). However, now it will differ from the seat used for Canadian compliance tests. NHTSA says that it is working with Transport Canada to harmonize their requirements as much as possible. Greater harmonization would help manufacturers who sell their products in both countries.
These test requirement changes were made in response to the TREAD Act passed by Congress in November 2000. Another aspect of the Act was side-impact protection. NHTSA issued an advance notice of proposed rulemaking regarding such a standard but has decided that it is not feasible to complete it at this time. The agency said it will continue research into this aspect of child passenger protection.
Reference
Federal Register, June 23, 2003, pp. 37620– 37658, http://gpoaccess.gov/fr/index.html
4. Booster effectiveness (May 2003, suppliment)
New Crash Data Shows Effectiveness of Boosters
The latest compilation of crash data by Partners in Child Passenger Safety shows that belt-positioning boosters are much more effective than lap-shoulder belts alone for children from ages 4 to 7. PCPS data come from State Farm policyholders in 15 states and comprise the largest collection of crashes of all severities involving children to be studied.
Almost 2 percent of children (1.95%) in this age group who were in seat belts (lap-only or lap-shoulder belts) were injured while only 0.77 percent of those in belt-positioning boosters were injured. Therefore, children in BPBs were 59 percent less likely to be injured than those in seat belts; this factor was the same when only those in lap-shoulder belts were compared to BPB users. There were no significant difference in effectiveness of boosters for children of different ages. In addition, none of the children in BPBs had injuries to the abdomen, neck/spine/back, or legs, and no child died. Those using belts alone had injuries to all body regions, and five of these children died.
Of the 4,243 children (ages 4 to 7) whose experience was analyzed, 81 percent were using either a seat belt or BPB. (This is not representative nationally, only for the large but somewhat select population of families with State Farm insurance.) BPB use declined sharply with age, but was higher than in previous years’ data.
Age |
Booster Use |
Seat belt use |
4 |
16% |
42% |
5 |
13% |
72% |
6-7 |
4% |
89% |
Children using BPBs were driven by older drivers and were more likely to ride in the back seat than those using only seat belts.
PCPS has prepared fact sheets for 13 states and a general one about children ages 4 to 8. Primarily intended to assist policy makers and legislative efforts, these are available as PDFs at www.traumalink.chop.edu (click on the Child Passenger Safety logo).
Reference:
Belt-Positioning Booster Seats and Reduction in Risk of Injury Among Children in Vehicle Crashes, Durbin DR, Elliott MR, Winston FK, JAMA, June 4, 2003, Vol 289, No. 21, p. 2835
5. Confusing strap height advice for rear-facing child
Confusing Strap Height Recommendation for Rear-Facing Newborns (May/June 2004)
The recommendation given in the standardized CPS curriculum and in child restraint instructions calls for strap-height for rear-facing restraints to be positioned at or below the baby’s shoulders. This is an over-simplification that can lead to confusion. In many sets of instructions, there is an absolute statement that the straps “must be at or below the shoulders.”
The acceptance of this concept over the years has led to the design of many products with lower slots than in the past. Many rear-facing CRs now fall well within the acceptable criterion of 10 inches or less set by the AAP in its policy statement of 1996. That 10-inch height was low for products at that time, but is higher than the shoulders of most newborns, especially premature infants.
It can be very confusing for parents to be given a seemingly absolute rule which may not be possible to follow. CPSTs and other educators could simplify the message by encouraging parents to use the lowest available slots until the baby’s shoulders reach the higher slots. They should understand that the closer the slots are to the baby’s shoulders the better. However, even if the lowest slots are above the newborn baby’s shoulders, the seat can be used. If there is a wide discrepancy, a different seat could be found (see list, right).
Editors’ Note
Better, simpler wording, in my opinion, would be “use the lowest slots until the baby’s shoulders reach the level of the upper slots.”
Dorel Instructions to Change Regarding Strap Height
It was discovered recently that recent versions of the Dorel TLC infant restraint instruction booklet have a misstatement indicating that the straps must be “AT or JUST ABOVE” the shoulders. In addition, there is confusing wording in the TLC, Arriva, and Designer 22 infant seat instructions, indicating that those restraints should NOT be used if the lowest harness slots are above baby’s shoulder level.
Dorel currently is correcting the instructions on the TLC and eliminating the prohibition on use of the seat. A spokesperson said that the company does not intend for parents to avoid using its infant seats for newborns whose shoulders are below the slots. The same language found in instructions for some convertible models will not be changed, as the company would prefer owners to use an infant restraint instead for the smallest babies.
According to SRN’s measurements, the Eddie Bauer Infant Seat and Safety 1st Designer 22 have strap slots much lower than the TLC and Arriva. (See list below.)
Other manufacturers’ products
Other manufacturers’ instructions for rear-facing restraints that SRN reviewed generally indicate that the straps MUST be at or below the shoulder level. They do not, however, specifically prohibit use of the seat if the baby’s shoulders are below the lowest slot.
Products with low strap slots
from 2004 SRN Fact Sheet on premature infants
This list includes only infant and convertible restraints with their lowest slots 8 inches or less from the seat. Compiled as of January 2004, it may not include all seats in stores today. Measurements are the height of the lowest slots.
I = Infant-only seat; C = Convertible seat
Infant car seats with no minimum weight limit:
Graco/Century: [I] Assura (7.5”), Smart Fit (6”); [C] Ovation/Encore (8”), Accel (8”)
Graco: [I] Snug Ride (7.5”); [C] ComfortSport (7”)
Peg Perego: [I] Primo Viagio (6.5”)
For infants weighing 5+ pounds:
Baby Trend: [I] LATCH-Loc (5.5”)
Britax: [I] Handle with Care (6”)
Dorel/Cosco: [I] Arriva/Turnabout (8”); [C] Eddie Bauer (7”)
Evenflo: [I] Port About (4.5), First Choice (6.5”), Discovery (7”); [C] Titan (7.5”),
Triumph (7.5”), Victory (6.5”)
Car Seat Specialty: [I] Baby One (7.5”)
XSCi: [I] Pioneered Infant Seat
7. The Forgotten Child (July/August 2004)
A comprehensive report on booster seat research and policy, The Forgotten Child: Children Who Move to Seat Belts Too Soon, has just been published by Partners for Child Passenger Safety (PCPS) and the American Academy of Pediatrics (AAP). It is the first of an occasional series of reports on child passenger safety issues aimed at making research and policy findings widely available. It was inserted into the July issue of AAP News, which goes to pediatric and other subscribers.
Children from 4 to 8 years of age are most likely to be “sub-optimally restrained” in seat belts instead of much more protective booster or harness restraints. The report lays out the research basis for upgrading laws and promoting booster use for children and outlines interventions and policies that must be used to improve proper restraint use. Also included is a one-page basic reproducible fact sheet for parents about boosters.
The report is available in its entirety at the PCPS web site below. Together with the legislative fact sheets prepared by PCPS, the report will provide substantive evidence to use in upgrading restraint laws in almost half the states that still have no specific requirements for proper restraint use for this group of children.
To download the PCPS report:
www.chop.edu/traumalink/download/2004/pcps_cpsreport.pdf