The NHTSA Issues NPRM to Amend Child Restraint Regulations to Improve Ease of Use
On January 23, 2015, the National Highway Traffic Safety Administration (NHTSA) published in the Federal Register (Vol. 80, Number 15, FR Docket No. 2015-00162; Docket No. NHTSA-2014-0123 ) a Notice of Proposed Rulemaking (NPRM) to amend Federal Motor Vehicle Safety Standard (FMVSS) No. 225, Child Restraint Anchorage Systems, to improve the ease of use of the lower and tether anchorages of child restraint anchorage systems. The NPRM also proposed changes to FMVSS No. 213, Child Restraint Systems (CRSs), to amend labeling and other requirements to improve the ease of use of child restraint systems with a vehicle anchorage system.
This NPRM is in accordance with NHTSA's 2011-2013 Priority Plan and Subtitle E of MAP-21 direction, to amend FMVSS No. 225 to improve the ease of use of child restraint anchorage systems. These requirements are intended to ensure that vehicle manufacturers produce lower anchorages that have sufficient clearance, are located such that the CRS connector can be attached to the bar using a reasonable amount of force and are within two centimeters of the outer surface of the seat bight.
Additionally, the NPRM proposes to make tether anchorages easier to use by standardizing the configuration of the anchorage such that it is a rigid bar of any cross section shape, by prohibiting the anchorages from being placed under a vehicle seat or hidden under carpet, and by requiring them to be placed where there is enough space around the anchorage for consumers to tighten the tether strap.
The NPRM proposes to amend FMVSS 225 and FMVSS 213 to require vehicles and CRSs to use a standardized symbol to more effectively identify the anchorages in the vehicle and the components on CRSs that attach to those anchorages.
The NPRM requests comments on several issues relating to the usability of child restraint anchorage systems including these:
- Should child restraint anchorage systems, including tether anchorages, be required in more rear seating positions, including rear center seating positions, third row seats and convertibles, than is currently mandated by FMVSS 225?
- What are the merits of requiring vehicle and CRS manufacturers to use standardized terminology in users' manuals for describing components of the child restraint anchorage system and the connectors of child restraint systems, enhancing consumer education and increasing correct use of child restraint anchorage systems and child restraints?
- Test data indicates that tether anchorages are sufficiently robust to provide crash protection to virtually all children restrained in a harnessed child restraint. What are the merits of consumer information that advises consumers to attach the tether when restraining a child in a harnessed child restraint, regardless of the weight of the child?
- Should CRS and vehicle manufacturers be encouraged, or possibly required, to include statements in the owner's instructions endorsing the use of simulated child restraint anchorage systems in rear center seating positions?
Comments regarding this NPRM must be received by NHTSA by March 24, 2015. The proposed compliance date for these changes is three years following publication date of the Final Rule in the Federal Register, with early compliance permitted.