NHTSA's Proposal for Side Impact Improvements Will Require Automakers To Install Side Air Bags
On May 17, 2004 the US National Highway Traffic Safety issued a Notice of Proposed Rulemaking (NPRM) to revise Part 571 FMVSS 214; Side Impact Protection & FMVSS 201; Occupant Protection in Interior Impact and also Part 598; Side Impact Phase-in Reporting Requirements.
Executive Summary
This NPRM would substantially upgrade the agency's side impact protection standard, especially by requiring protection in crashes with narrow objects and protection against head injuries in side impact crashes with both narrow objects and other vehicles. These proposed changes would upgrade the performance requirements in two ways:
First, it would upgrade the standard by requiring that all passenger vehicles with a gross vehicle weight rating of 4,536 kilograms (10,000 pounds) or less protect front seat occupants against head, thoracic, abdominal and pelvic injuries in a vehicle-to-pole test simulating a vehicle's crashing sideways into narrow fixed objects like telephone poles and trees. To meet the head injury criteria in the pole test, vehicle manufacturers would likely need to install dynamically deploying side head protection systems, such as head air bags or inflatable air curtains that drop down from the roof line above the door frame. NHTSA states that air curtains can reduce head injuries in side crashes of passenger vehicles with poles and trees as well as side impacts from vehicles with high front ends. NHTSA also contends that air curtains can also help reduce partial and full ejections through side windows. Compliance with the pole test would be determined in two test configurations, one using a new, second-generation test dummy representing mid-size adult males and the other using a new test dummy representing small adult females.
Second, this NPRM would upgrade the standard's existing vehicle-to-vehicle test that requires protection of front and rear seat occupants against thoracic and pelvic injuries in a test that uses a moving deformable barrier to simulate a moving vehicle's being struck in the side by another moving vehicle. This NPRM would upgrade that test by requiring protection against head injuries. It would replace the mid-size male dummy currently used in that test with a new mid-size male dummy and require compliance with the head, thoracic and pelvic injury criteria developed for this new dummy. It would also enhance protection for small adult occupants by adding a new small female test dummy and requiring compliance with the injury criteria developed for that dummy. Thus, the number of test configurations would increase from one to two.
NHTSA believes that these differing situations facing each individual manufacturer can best be accommodated by phasing-in the upgraded proposed side impact protection requirements for head protection.
The phase-in is proposed to be implemented in accordance with the following schedule:
- 20% of each manufacturer's light vehicles manufactured during the production year beginning (four years after publication of a final rule; for illustration purposes, September 1, 2009);
- 50% of each manufacturer's light vehicles manufactured during the production year beginning September 1, 2010;
- 100% of all vehicles manufactured on or after September 1, 2011.
Also as with previous phase-ins, NHTSA is proposing reporting requirements to accompany the phase-in. The agency is proposing to include these reporting requirements in a new Part 598 in Title 49 of the CFR.
General Discussion
Based on the progress of recent research and the growing significance of vehicle compatibility issues, NHTSA is proposing to upgrade FMVSS No. 214 substantially by requiring all passenger vehicles with a gross vehicle weight rating (GVWR) of 4,536 kilograms (kg) or less (10,000 lb or less) to protect front seat occupants against head, thoracic and pelvic injuries in a vehicle-to-pole test simulating a vehicle's crashing sideways into narrow fixed objects like telephone poles and trees. This would be the first time that head injury criteria would need to be met under the standard. The vehicle-to-pole test is similar to the one currently used optionally in FMVSS No. 201, except that NHTSA proposes to change the angle of impact from 90 to 75 degrees and increase the test speed from 29 to 32 kilometers per hour (km/h) (18 to 20 miles per hour (mph).
Vehicles would need to meet the injury criteria using new dummies representing mid-size males and small females. NHTSA states that their crash data indicate that 35 percent of all serious and fatal injuries to near-side occupants in side impacts occurred to occupants 5 feet 4 inches (or 163 centimeters) or less, which are better represented by the small female dummy. Thus, NHTSA believes that use of both dummies, instead of just the mid-size male dummy, will better represent the at-risk population.
For the mid-size or 50th percentile male, NHTSA proposes to adopt a modified version of the European side impact dummy, the ES-2 dummy, for use in the test, since this dummy is technically superior to the SID-H3 50th percentile male test dummy currently used in FMVSS No. 201 and to the SID 50th percentile male test dummy currently used in FMVSS No. 214. The modified ES-2 dummy (known as the ES-2re) is superior in that it has improved biofidelity and enhanced injury assessment capability compared to the other dummies. A predecessor dummy, known as EuroSID-1, is currently specified by European governments for use in perpendicular side impact testing and work has been undertaken to replace that dummy with the ES-2re. The non-governmental European New Car Assessment Program (EuroNCAP) on side impact has used the ES-2 dummy since February 2003 in perpendicular MDB side impact tests. The small or 5th percentile female dummy has been used by Transport Canada in crash tests in the late 1990s and early 2000, and is used by the Insurance Institute for Highway Safety (IIHS), a non-profit group funded by insurers, in IIHS's side impact consumer information program which ranks vehicles based on performance when impacted perpendicularly by a moving barrier at about 30 mph. The countermeasures that are installed to meet the proposed pole test would need to enable the vehicle to meet the requirements when tested with both dummies, which would ensure protection for shorter drivers who sit closer to the steering wheel than the mid-size occupant.
NHTSA anticipates that vehicle manufacturers will install dynamically deploying side air bags to meet the proposed vehicle-to-pole test. The agency estimates that the proposals in this NPRM would prevent 686 fatalities and 880 MAIS 3 to 5 injuries a year when fully implemented throughout the light vehicle fleet. Those benefits are based on an assumption that manufacturers would use a 2-sensor (per vehicle) combination air bag system. (This system would be the least costly countermeasure that manufacturers could use to achieve compliance. Manufacturers might also install side air curtains or other measures that not only reduce head injuries, but also can help reduce ejections through side windows.) The cost for the 2-sensor combination air bag system is estimated to be $121 per vehicle. NHTSA states that this proposal is intended to provide significant lead-time to ensure that the regulatory burden is practicable and feasible.
In addition, this NPRM proposes to upgrade the moving deformable barrier test in several ways. It would enhance the MDB test's existing chest and pelvis protection requirements and require compliance with head injury criteria. It proposes replacing the current 50th percentile male dummy with the new dummy mentioned above and would require compliance with the criteria developed for that new dummy. The proposal would also enhance protection for smaller adult occupants by adding the new 5th percentile female dummy mentioned above and require compliance with the injury criteria for that dummy.
Comments should be submitted early enough to ensure that Docket Management receives them not later than October 14, 2004.