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Guest Editorial: Joseph M. Colella
Joe Colella
Joe Colella is a longtime CPS advocate, SRN contributor, and the director of Traffic Safety Projects, an organization specializing in occupant protection education.

     Misunderstanding the toll of crash forces on CRs, along with more attention to family financial burdens, has increased discussion of whether or not a CR can continue to be used after a minor crash or when the CR was unoccupied during the crash.  Frankly, I am surprised by how many CPSTs seem to rely heavily on advice from NHTSA or other outside sources, dismissing the warnings and requirements of the specific CR manufacturer.  When parents are advised in a way that overrules the CR manufacturer, everyone involved is put at risk.
    Although it is true that NHTSA offers helpful guidance on this subject at
www.nhtsa.gov, it must be remembered that this reflects an agency position and its supporting research, but it is not a policy.  It is more important to give appropriate attention to the CR manufacturer’s replacement instructions.   These ARE policy and are based on manufacturer knowledge of what happens to its specific models in crashes.
    The standardized curriculum addresses this subject on slide 8-24.  It says that CR replacement is not always required, but points to guidelines from both NHTSA and the CR manufacturer to assess crash severity and to gain advice regarding replacement. The associated Instructor Notes list two discussion points:

•What did students find in the CR manuals regarding
     crash replacement?
•Always recommend that the manfacturer’s instructions
     be followed.

    Every major manufacturer addresses CR replacement in its instructions.  The level of detail provided varies — many instructions specify the same guidance whether or not the CR was occupied during the crash, some discuss crash severity levels, and a few point to indicators built into the CR.  A call to the manufacturer may be advised.
    In addition, every major manufacturer has some sort of free CR replacement program that applies to certain crash cases. Some will provide a new CR in exchange for any CR needing replacement after a crash, while others replace seats under certain conditions or offer assistance with getting a replacement through the insurer. These programs are one way manufacturers gain special insight into the performance of their own CRs, making them uniquely qualified to give informed re-use advice.
    Certain parts of CRs are intended to deform during crashes for energy management purposes, but even those deformations may not be visible. Relying on the expertise of manufacturers regarding their own specific CR models is the ONLY way we can appropriately protect children and ourselves as educators.
    Many national and state organizations rightfully have adopted policies stating that the manufacturer’s instructions MUST be followed. Our standardized certification curriculum recognizes that the manufacturer should have the final word. What’s more, many state occupant protection laws require proper restraint use — usually either explicitly defined or defined in court as following manufacturer instructions.  Therefore, overriding instructions is not only careless, it is a violation of the law.
    I know that the financial situation of national, state, and local CPS programs has changed dramatically. Some programs used to give away CRs frequently, but now cannot afford large numbers of replacement seats. The solution is not to diminish the accuracy and quality of advice by making our own judgments regarding re-use. It is not our job to provide replacement CRs to the public. It is our duty to protect the families we serve from harm and ourselves and our employers from exposure to liability.   Therefore, it is the CPST’s responsibility to notify the caregiver of manufacturer requirements and to document this communication.

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