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 Recent Developments Likely to Change CPS Landscape
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  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. (See article, page 1.) 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.

  Also influential will be NHTSA’s recently announced final rule that updates FMVSS 213 to include a 10-year-old dummy and extend the standard’s applicability to CRs made for children up to 80 pounds.  An article on page 1 describes the key components of the new rule, which goes into effect February 2014 (though manufacturers may comply sooner).  This ruling will influence the CPS industry in more ways than might be recognized initially, and I encourage interested readers to check out the final rule document with its supporting explanations. (See search information at the end of this article.)  It is very thought provoking, while dense, reading.

  So, these are certainly major steps in the right direction. With the AAP and NHTSA guidelines, expertly released in synch last spring and continuing to make a major impact on parental behavior, we are on the right track to keeping kids riding longer in each stage. And, just in time, the long-awaited 10-year-old dummy has been added to FMVSS 213 so we can be better assured that CRs made for these older children are indeed as safe as they should be.

  One outcome of adding the heavier dummy is that NHTSA concurred with the auto industry that lower LATCH anchors (LAs) were not designed to be strong enough to install CRs with what we commonly call high-weight harnesses—those that are today, in fact, the norm.  As part of the new rule, CR makers will be required to label models with the highest child weight at which the CR can be installed using LATCH.  NHTSA further specifies that the child weight must be derived using this formula:  65 pounds minus the weight of the CR. Above that weight, the user must switch to seat belt installation.

  This is a major change in understanding and communicating LA weight limits.  Not only does it mean that consumers will have a clear place to find this guidance, it also represents an important clarification from NHTSA that it considers the LA weight limit to be a combined weight of 65 pounds. Labeling may eliminate uncertainty, however limiting anchor weight so drastically is unfortunate.

  The conclusion that LA strength under current FMVSS 225 requirements is capped at a child-plus-CR weight of 65 pounds is surprising.  It contradicts NHTSA’s explanation in a 2003 response to petitions for reconsideration of FMVSS 225 in the Federal Register* that said the strength requirements for LATCH anchors were intended to hold a child’s weight of up to 65 pounds, assuming additional CR weight of 15 pounds (implying an 80-pound system limit).  For NHTSA to suddenly make this new statement without a thorough explanation and full rulemaking process is disappointing.   

  Given today’s heavier CRs, if one does the math, it seems that LA weight limits by 2014 will shift generally downward, in most cases limiting them to a child’s weight of between 40 and 50 pounds.  In the case of some heavier CRs, in fact, use may be limited so much that parents may start to wonder, “Why bother with LATCH?”  Is this the outcome we want for our “installation method of the future”? 

  One solution might be to direct our attention back to FMVSS 225 and ask if anchors should be made stronger—“modernized” to match today’s CRs.  If it is true that today’s anchors can only support a child-plus-CR weight of 65 pounds, shouldn’t the strength requirement be raised to at least 80 pounds?

  On the plus side, the new rule keeps tether anchors (TAs) separate from LAs, and NHTSA makes a strong point not to impose any required weight limit on tether use at this time.  We see this as especially important as more older (and taller) children ride in harnesses, since these kids are at even greater risk with respect to head excursion—a danger that tethers are proven to mitigate substantially.  However, will manufacturers respond by stating a higher limit for TAs than for LAs?

  SRN was joined by other CPS advocacy groups in submitting a letter to NHTSA in which we outline some strong concerns about this final rule as written.  You can view this letter along with the final rule and other comments at
www.regulations.gov. (Search for docket #NHTSA-2011-0176.)

—Denise Donaldson

*To view this, go to www.gpo.gov/fdsys, search for 68 FR 38208, then search for page 38220.

©Safe Ride News March/April 2012

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