On August 10, a full-size, 2010 GMC Savana van carrying school-aged children on a field trip in New Hampshire left the highway and struck a tree head on. Although the crash was serious, only one of the 13 passengers was seriously injured. “It appears seat belts saved a lot of lives today,” one state trooper told the a regional news affiliate while on-site at the crash. “These children—most or all—were wearing seat belts.”
Occasionally, caregivers arrive at checkup stations or events with a CR that was not made for our market and/or is lacking labels that say it is approved for use here. In this situation, what should a CPST do?
On January 23, NHTSA published a Notice of Proposed Rulemaking (NPRM) regarding updates it plans for FMVSS 225 and 213 in order to improve the usability of the LATCH system. This NPRM is an important step toward improving ease of use and accessibility of lower and tether anchors, a topic that hasn’t been addressed through regulation since LATCH was initially introduced 15 years ago. It outlines some basic proposals for new regulations from NHTSA and seeks comment on the necessity of further regulation.
Recent Developments Likely to Change CPS Landscape
(Scroll down for “New Rule Will Expand FMVSS 213 Coverage to 80 Pounds, Clarify LA Weights” and “NHTSA Revises Final Rule, But Concedes Little to Petition.)”
This issue of SRN covers some important developments that will have far-ranging effects in the CPS field for years to come.
First, a year after the AAP and NHTSA released updated recommendations for how children should ride, a survey from AAA confirms what we’ve sensed: there has been significant awareness and acceptance of these new guidelines by the public. The 2011 Safe Kids study of CPS use indicated that parents were already trending toward keeping kids in each stage longer, and the AAA survey shows that the efforts of the past year have further contributed to improvement.
As most readers have probably noticed, we are going through a particularly complex period with respect to determining LATCH weight limits. Most CPSTs have heard about upcoming changes in FMVSS 213 regarding lower anchor weight limits. NHTSA has ruled that, by next February or sooner, CRs must have instructions and labels limiting use of the lower attachment system to a child weight specific to each CR model. This weight limit is to be calculated based on the formula “65 pounds minus the CR weight.” Keeping things interesting, this final rule is under further review, and NHTSA may or may not announce a modification to it in coming weeks. Though this ruling pertains to CRs only, many vehicle manufacturers indicate in the 2013 LATCH Manual* that they have adopted this same formula to express lower anchor limits (and tether anchor limits, too, in some cases). So this limit now applies to about half of all vehicle brands.
The Department of Transportation’s January 2013 Significant Rulemaking Report provides an update on the status of rulemaking for side-impact CR performance requirements, as well as all other significant projects of NHTSA and other agencies.
The update cites the reason for delay of the next action, a public Notice of Proposed Rulemaking (NPRM), as “additional coordination necessary.” It now indicates a projected NPRM date of February 15, 2013 (after this issue of SRN goes to press). The NPRM will open a public comment period, which is typically 60 to 90 days from the date of posting.
In October 2008, NHTSA published the “Federal Motor Vehicle Safety Standards; Seating Systems, Occupant Crash Protection, Seat Belt Assembly Anchorages, School Bus Passenger Seating and Crash Protection” final rule, the last components of which will take effect on October 21, 2011. Important among these is the requirement for new buses of 10,000 pounds gross vehicle weight or less to be equipped with lap-shoulder belts, rather than lap-only belts, in all positions.
Having access to lockable, standardized lap-shoulder seat belts on these smaller buses may make installation of conventional CRs easy on most buses so equipped. However, caregivers and advocates are often surprised to learn that best practice is to NOT use a booster on a school bus, even when a lap-shoulder belt is available and the child would normally ride in a booster in the family vehicle.
Comments on Federal Motor Vehicle Safety Standards, Child Restraint Systems; Hybrid III 10-Year-Old Child Test Dummy Docket #NHTSA-2010-0158
We represent Safe Ride News Publications, publisher of materials that support the life-saving efforts of child passenger safety professionals, including Safe Ride News, the major child passenger safety technical periodical in the U.S. Safe Ride News Publications has been advocating for child passenger safety for over thirty years, and we consider NHTSA’s efforts over that time period to develop a range of ATDs that represent children of varying sizes and development to be critically important. The current proposal regarding the Hybrid III 6- and 10-year-old ATDs takes another step forward in that effort, and we appreciate the opportunity to comment.