U.S. DOT Responds on April 24 to CR Testing Flap with Changes
    The prompt review of child restraint testing ordered by U.S. Secretary of Transportation Ray LaHood after the Chicago Tribune article appeared on March 1 has been completed.  As a result, LaHood has ordered NHTSA to develop a new side-impact test standard for child restraints.  In addition, he says the agency will develop a new consumer information initiative to make it easier for parents to know which products will fit best in specific vehicles. 
   The NHTSA team that reviewed child safety regulations included 30 experts. The team found that while current standards offer a high degree of protection, the agency should consider adding a side-impact standard.  It also recommended research on future improvements to the current frontal impact standard.
    The consumer education program is projected begin with 2011 model year vehicles.  Vehicle manufacturers will be asked to recommend specific seats in various price ranges that will fit in their models.  This type of evaluation is already done by Nissan and by various manufacturers in Europe.
    The internal review team confirmed that the current standard tests were more severe than 99.5 percent of real-world crashes but LaHood “urged NHTSA to do better.”  The team also noted that half of the children aged birth to 7 years who are killed in motor vehicle crashes were not using CRs at the time.

Putting the Latest Car Seat Testing Revelations in Perspective
(Also see the editorial below and links to responses, as well as the third article below (Editorial) on side-impact testing)
   On March 1, the Chicago Tribune published a major article on what it called ‘flaws” in CRs revealed in high-speed crash tests.  It examined reports of a series of what were apparently research tests of rear-facing CRs in actual vehicles in New Car Assessment Program (NCAP) testing.
    The Tribune found that, in nearly half of the tests, the infant seats came off their bases or exceeded injury limits in the 35-mph tests. It assailed NHTSA for not releasing the information, yet two companies have recently recalled products for such problems (Evenflo Discovery and Combi Center and Shuttle) as a result of the test findings.

Facts to remember:
1.    Today’s CRs provide extremely good protection in the vast majority of crashes. There has not been an epidemic of babies killed or seriously injured from infant seats flying off their bases, as confirmed by the response from CHOP to the Tribune article:  “‘Our investigations of real-world crashes over the past ten years found infants in rear-facing car seats had an extremely low risk of injury in a crash. Of the crashes studied, very few infants in rear-facing seats were injured,’ said Kristy Arbogast, Ph.D., director of engineering at the Center for Injury Research and Prevention. ‘Of the few injuries we did see, most were minor and without long term consequences.’”
2.    CRs made today pass tests that are stringent, although limited to frontal crashes. The 30-mph speed of the FMVSS 213 sled test is more severe than at least 95% of actual crashes. 
3.    Very, very few crashes are of the severity of the 35-mph tests of vehicles run by the New Car Assessment Program (NCAP) and reported in the Tribune article. At 35 mph, the forces are about one-third higher than in the 30-mph sled test. (To learn more about this, see “Physics 201” on page 3.)
4.    Testing every CR in every vehicle model every year would be an extraordinarily complicated, time-consuming, and expensive process that would greatly increase the cost of CRs.  The benefit of having a single test standard is that it offers a reproducible test process that uses a representative crash pulse that is reasonably severe. No one should expect a CR to protect its occupant in all possible crash conditions.
—Safe Ride News, March/April 2009

Link to full text of article: Chicago Tribune

SRN Editorial:  Putting the Latest CR Testing Revelations Into Perspective
    Things were too calm.  The time was ripe for another sensational article and the Chicago Tribune report (3/1/09) supplied it. We’ve all been through this before and know that media reports, no matter how hard the reporters try, may not have all the facts and details right, but it is easy to get alarmed.
    As details become available and the promised investigation within NHTSA is done, we will be able to put the Tribune article in context.  I’m sure we all welcome new information that will improve products but it does not help much when a report primarily serves to make parents and caregivers anxious.

Things to Remember:
1)    There has not been an epidemic of babies being killed or seriously injured from infant seats flying off their bases.
2)    CRs made today pass tests that are quite stringent, although limited to only frontal crashes.  The 30-mph speed of the sled test is more severe than at least 95% of actual crashes.  And no one should expect a CR to protect its occupant in all possible crash conditions.
3)    Very, very few crashes are of the severity of the 35-mph tests of vehicles run by the New Car Assessment Program (NCAP) and reported in the Tribune article.  
4)    Research must be done that goes beyond the standards that CRs have to meet and to push products to their limits.  We should welcome that research, but not misuse it to alarm the public.
    We join SBS USA in urging NHTSA to conduct its promised review quickly so parents know how to judge the information.  We will report more details as they surface.

Remedies for Families:
• Choose the correct size/type of CR for your child’s height/weight/age.
• Use your child’s CR correctly.
• Make sure it fits in your vehicle and can be secured tightly with LATCH or seat belt.  • Attend a car seat checkup if you need help.
• If worried, use the CR without its base --- MOST, but not all, can be used that way.

    We hope resources will be more available to NHTSA for continued research into improved testing and regulation of child restraints.
—Deborah Stewart, Editor
©Safe Ride News, March/April 2009

Editorial: Pressure to Move Toward a Side-Impact Standard for Car Seats
    In the January/February issue of SRN, I reported that the recall of the Evenflo Discovery was due to problems discovered in actual vehicles crashed as part of Side-impact New Car Assessment Program (SNCAP) testing of actual vehicles.  The inclusion of CRs in NCAP testing has been done more frequently since the failure of the  Consumers’ Union effort last year to correctly simulate such testing on a sled (SRN, January/February 2007).  I learned recently from the newsletter of Safety Research and Strategies, March  2008, that the Discovery failed in four different vehicles during NHTSA tests.  Now two other RF CRs, the Combi Centre and Shuttle, have been recalled for a base-separation problem in frontal-impact NCAP tests. 
    It seems that good performance in NCAP tests is becoming a de facto requirement for child restraints.  While such catastrophic failures are important to know about,  manufacturers are in a difficult position.  This is because no specific sled testing procedure has been established that enables them to run reproducible, practicable, comparable side-impact tests.  Frontal-impact NCAP tests are easier to simulate, but add a layer of time and cost to the design process.
    Many manufacturers say they are running their own higher-speed frontal and side-impact sled tests.  Consumers are in a difficult situation, as they have no way to evaluate competing claims by manufacturers regarding side-impact protection and higher-speed frontal tests.
    NHTSA needs to move much faster now that recalls are being conducted based on the NCAP results.  More work needs to be done to develop a supportable side-impact standard (see Letter to the Editor).  Unfortunately, this is not a simple or speedy task.  Meanwhile, we can’t ignore the failures of specific products in occasional SNCAP tests, but there’s no level playing field for CR testing.

—Deborah Stewart, Editor
Safe Ride News, March/April 2008

Car Seats Caught in Toxic Toy Legislation
    In response to the revelations of unsafe levels of lead and other toxic chemicals in some children’s toys, jewelry, and similar products, there has been considerable recent legislative activity at the state and national levels to ban products that contain toxins.  In some states, CRs have been included in the legislation, potentially limiting their availability.
    In Washington state, a bill signed into law this spring specifically includes CRs while excluding a long list of other items.  (The WA State Department of Ecology will make final decisions as to how to implement the law within the next eight months, so there will be an opportunity to try to correct this.)  In Maryland, similar legislation has specifically exempted CRs.
    The Juvenile Products Manufacturers Association, while supporting laws to limit exposure of children to toxic chemicals, would like to partner with CPS advocates to make sure that these laws would not inadvertently preclude the sale of CRs in any state.  There are two parts of CRs that could potentially incorporate lead: the steel of the frame and nonstructural components that children could handle and mouth.
    According to several CR manufacturers, lead is used in some CRs to strengthen the steel frames and buckle parts, but this lead is encapsulated in the structural steel and could not be ingested by children.  The use of this type of steel is more common in newer, innovative designs that could potentially improve the safety function of CRs.  These types of seats will not be available through retail outlets in certain states unless legislation is crafted to exclude this type of benign lead component.
    HealthyCar.org, which tested car seats for toxins in 2006 by analyzing each of the component parts (such as harness clips, padding, sunshades, etc.), found very few CR components that contained lead. On the rare occasion that lead was found, it was often just in a component such as padding or trim. Since such parts on most CRs do not contain lead, it should be relatively easy for manufacturers to substitute lead-free parts that are not part of the safety structure and function of the seat.  Carefully written legislation could help guide these types of material choices by manufacturers.
Safe Ride News, May/June 2008