December 15, 2010
Last week, the National Transportation Safety Board gathered all the government, industry and academic play-ahs in the board room of its headquarters to answer a question that’s been nagging safety advocates: Why doesn’t anyone give a damn about child safety in cars and planes?
The day-long meeting was meant to be a kick-off to the NTSB’s 2011 focus on child safety in airplanes and automobiles, with a special focus on increasing child restraint and seat belt use rates. Note to NTSB: you might want to allocate more time to this project – the lag in child safety regulation and industry practices has been the sad state of affairs for decades. Decades.
First up was the Federal Aviation Administration. The agency defended its practice of allowing children to fly without child safety restraints. Without a hint of irony, the FAA said that such a requirement would result in more people driving rather than flying, putting children at higher risk because the injury and fatality rates for children in motor vehicle crashes far surpasses that those in an airplane.
Next came the National Highway Traffic Safety Administration and auto and child safety seat manufacturers, toting the same load of excuses for not improving rear seat and child safety they’ve carried for years. Instead of talking about better rear seat and rear seat belt design, or perhaps, say, coordinating child safety seat manufacturers with automakers to design products that specifically fit a particular seat geometry, presenters turned to their favorite scapegoat: parents. Though many of the presentations noted the decrease in child fatalities and injuries because more parents are placing their children in proper restraints, they also discussed methods address the stubbornly high misuse rate of current child restraints.
The Juvenile Products Manufacturers Association, which loves parents’ money, but parents, not so much, blamed its customers for denying the dangers of motor vehicle crashes. David Campbell, a former Graco executive who now works as a safety consultant, represented the JPMA at the meeting. He argued that parents don’t take the time to install the seats correctly and don’t spend enough on the expensive seats that are easier to manage. This, of course, presumes that all parents can afford the pricier restraints. It also presumes that parents know enough to make these distinctions. Contradictory safety recommendations, no guidance from actual manufacturers on which seats best fit which cars; a dearth of regulation; confusing public policy, a lack of government leadership – an entire employment specialty, Child Restraint Specialist has sprung from this mess – but, hey let’s blame parents!
The NTSB attempted to point some of this out as it steered the conversation toward the lack of effectiveness of current rear seat belt design.
NHTSA has long maintained that occupants under 80 pounds or less than 4′ 9″ tall do not properly fit in a standard rear seat lap/shoulder belt. That rear seat compartments are not designed to protect children has been well documented. The seat pans are typically too long, causing the child to sit forward on the seat. This, in combination with poor anchorage locations, positions the lap belt across a child’s abdomen. In crashes, this results in seat belt syndrome, in which children sustain severe internal and spinal injuries caused by the belt squeezing their organs and providing a flexion fulcrum for their spines. The shoulder belts, typically designed for taller occupants, often wind up with the belt webbing positioned across the child’s neck instead of the chest, which can result in serious or fatal neck injuries.
On the issue of testing, NHTSA, Ford and Insurance Institute for Highway Safety (IIHS) conceded that none of their testing or rating systems address children in the rear seat. Children and young adults continue to be seriously injured in the rear seat compartment, because that area of the vehicle remains essentially unregulated. Neither FMVSS 213 nor NCAP include dynamic crash testing requirements for children in the rear seat compartment, masking the dangers and limitations of current rear seat restraint designs. FMVSS 213 tests child restraints on a single bench seat that is mounted on a sled buck with no vehicle structure in front of it, and therefore does not test for real-world head contact risk in the rear seat compartment. This method of testing cannot address the effects of vehicle seat design, vehicle restraint design, the effect of the potential impact areas for the child dummies, or compatibility issues.
In fact, analysis of child dummy head excursions in FMVSS 213 compliance tests and the excursion distance of rear seat compartments indicate that head contact with the back of the front seatback is likely. Head injuries from impacts with the vehicle interior to neck and torso injuries from poor belt geometry are still prevalent, though preventable. Rear seat restraint systems need to be dynamically tested in vehicles with restrained child dummies and dummies in child restraints and assessed using the injury criteria and excursion limitations from FMVSS 213 and 208. Euro NCAP and Australian NCAP have tested child restraints dynamically in vehicles before 1999 in both frontal and side impacts.
In response to the TREAD Act, the agency implemented a pilot program designed to investigate the feasibility of rating child restraints based on dynamic performance. The tests subjected child restraints to a 48 km/h (30 mph) crash test under the same test conditions as the FMVSS No. 213, in various configurations with dummies of various sizes. The pilot program was conducted under the New Car Assessment Program (NCAP). Results showed little variance between different child restraints tested in the same configuration; however, a more substantial, statistically significant, difference in HIC performance was observed between different configurations of the same child restraint. These results indicate that the agency cannot assume similar results for different configurations of the same child restraint. Most of the dummy injury values fell well under the current injury assessment reference values published in FMVSS No. 213.
The TREAD Act also required the Secretary of Transportation to develop a child restraint safety rating system that was “practicable and understandable” to help consumers to make informed decisions when purchasing child restraints. In 2002, NHTSA published a final rule announcing its intent to establish a consumer information program for add-on child restraints based on ease of use. But when the final rule was published a year later, the agency announced that the results of the pilot testing program would be made available only as research. Today, no ratings are assigned to any of the child restraint systems tested.
The IIHS’s Anne McCartt said that the Institute cannot test for the safety of children under 10 because there is so much variation child restraints and rear seat compartment design that it would be too logistically challenging. Hmm, safety experts can’t figure it out, but let’s blame the parents!
Would it be possible, NTSB Chairman Deborah Hersman asked, to optimize the vehicle rear seat restraint system to better fit children?
That would be too hard. Steve Rouhana, Ford’s senior technical leader for safety in Passive Safety Research and Advanced Engineering, argued that if you make the rear seat safe for children, then the safety of adult occupants is compromised. Rear seats are very different than front seats, he explained, because they have more than one function – access to the rear compartment, cargo retention, etc. etc. In other words, Ford needs to make sure that back seat is designed to hold the box containing the big-screen television, so it really can’t be expected to place a premium on child occupants.
(Manufacturers, of course, have been aware of the incompatibility between rear seat lap/shoulder belts and older children for decades. In 1987, when NHTSA began rulemaking to require lap/shoulder belts in the rear seat, Ford and Honda argued for revisions based on the presence of children in the rear seat. Both noted the serious fit issues with children in adult belts.)
As for integrated child seats – Ford has no intention of adding them, Rouhana said. They were a market bust. (Parents didn’t buy them.)
In sum, the child restraints manufacturers blamed the automakers for not working with them to marry aftermarket seats to vehicles, the automakers blamed the child seat manufacturers for bad designs; advocates blamed both for making the entire enterprise so complicated it is difficult to determine which rear seats and which child safety restraints are safe; the FAA blamed NHTSA. Somehow, it was still all the parents’ fault.
“Booster seats are a band aid approach,” Rouhana said. “We need a holistic approach.”
Indeed. Now, who will make that happen? The NTSB, with no enforcement powers but a decent bully pulpit, does a good job pointing out the massive gaps in safety policy. The rulemaking agencies and their partners in industry tend to ignore the stream of recommendations, until Congress gets a burr under its saddle and passes a law compelling a regulation. DOT Secretary Ray LaHood has ordered NHTSA to develop a program focused on identifying specific seats that fit well in certain vehicles. We’ll see how that goes.
This may be the first time Chairman Hersman has heard any of this, but it’s old news to us. We have read the rulemaking histories of child safety and rear seat regulations, heard industry’s arguments, plumbed the recall and testing documents on child safety seats and followed the research on child injury and death in motor vehicle crashes. If our readers perceive a cranky tone in this post, it’s because not one of the major stakeholders has shown any leadership on this issue and the job remains undone. Simply, child safety is not a priority.
Tell us, what other product can be marketed to families, but not be safe for the entire family to use without the addition of a third-party piece of equipment? Why do the experts look at a 75 percent misuse rate for child safety seats and blame the users instead of the product designers? Why have automakers abdicated their responsibilities to child occupants? Why has NHTSA allowed them to do it? Vehicle manufacturers have the data, the engineering and the research capabilities to develop a solution. What they lack is the will. Instead, they ask parents to find the appropriate third-party restraint that will best protect their children in their vehicle. What’s needed is a shake-up in the entire approach to this problem.
In the meantime, auto manufacturers will keep trying to push the public’s buy-button with images of irresistible kids snug in the rear, while the mom smiles sagely at the wheel. Just remember: the company that produced this vehicle doesn’t really care if that cute kid is safe in the rear seat. And the smiling mom? They blame her, and she has no clue.