[Federal Register Volume 62, Number 34 (Thursday, February 20, 1997)]
[Proposed Rules]
[Pages 7858-7897]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 97-4084]



[[Page 7857]]

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Part IV





Department of Transportation





_______________________________________________________________________



National Highway Traffic Safety Administration



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49 CFR Part 571



Federal Motor Vehicle Safety Standards; Child Restraint Systems; Tether 
Anchorages and Anchorage Systems; Proposed Rule

  Federal Register / Vol. 62, No. 34 / Thursday, February 20, 1997 / 
Proposed Rules  

[[Page 7858]]



DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

49 CFR Part 571

[Docket No. 96-095; Notice 3]
RIN 2127-AG50


Federal Motor Vehicle Safety Standards; Child Restraint Systems; 
Tether Anchorages for Child Restraint Systems; Child Restraint 
Anchorage System

AGENCY: National Highway Traffic Safety Administration (NHTSA), 
Department of Transportation.

ACTION: Notice of proposed rulemaking (NPRM); request for comment.

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SUMMARY: This document proposes to require that motor vehicles and add-
on child restraints be equipped with a means independent of vehicle 
safety belts for securing the child restraints to vehicle seats. The 
adoption of the proposal would avoid problems of incompatibility 
between child restraints and vehicle safety belts and increase the 
correct installation of child restraints. This proposal would reduce 
allowable head excursion, which would have the effect of requiring 
child restraints to be equipped with an upper tether strap, and would 
require vehicles to have two factory-installed, user-ready anchor 
points for attaching the tether. It would also require vehicles to have 
two rear vehicle seating positions equipped with a specialized lower 
anchorage system, and require child restraints to be equipped with 
means of attaching to that system.
    The proposal for the lower anchorages is based on two of the 
systems discussed at an October 1996 NHTSA public workshop concerning 
alternative systems for providing dedicated means for attaching child 
restraints to vehicle seats. Almost all of the different systems 
evaluated and discussed at the workshop appeared comparable in terms of 
demonstrated safety and public acceptance. However, one system appeared 
to be less expensive and have the advantage of using hardware familiar 
to consumers. This system is the ``uniform child restraint anchorages 
(UCRA) system,'' referred to as such by a consortium of manufacturing 
groups in a June 28, 1996 petition for rulemaking to the agency. The 
International Standards Organization (ISO) Working Group on child 
restraint systems recognized in a November 1996 meeting the need for 
this system to permit improvements in the short term.
    The other notable dedicated system is one supported by European 
members of the ISO Working Group. This alternative, which is completing 
development, uses a two-prong nonflexible item of hardware on the child 
restraint to mate with two fixed anchorages at the bottom of the back 
of the vehicle seat without the use of any belt webbing. Under today's 
proposal, either of these systems could meet the proposed requirement 
for a dedicated lower anchorage system, but manufacturers installing 
the fixed anchorage system would also have to ensure that the system is 
compatible with the UCRA system, so that UCRA-type child restraints can 
be used in all vehicles equipped with either anchorage system.
    To the extent possible, this proposal also harmonizes with the 
actions of other regulatory agencies around the world. This proposal 
seeks to harmonize with Canadian and Australian regulations by 
requiring an upper tether anchorage and with prospective European 
regulations by allowing a non-UCRA anchorage system.
    This proposal pertains to the compatibility of child restraints 
with motor vehicle seats, and not that of child restraints with 
aircraft seats. The Federal Aviation Administration and NHTSA are 
developing possible requirements and procedures for improving the 
compatibility of child restraints in aircraft. If the agencies decide 
that rulemaking is warranted on that issue, such rulemaking will be 
commenced as a separate action.

DATES: Comments on this notice must be received by the agency no later 
than May 21, 1997.

ADDRESSES: Comments should refer to the docket number and notice number 
and be submitted in writing to NHTSA's Docket Section at the following 
address: Until March 10, 1997: Room 6130, After March 10, 1997: Room 
5109, 400 Seventh Street, S.W., Washington, D.C., 20590. Telephone: 
(202) 366-5267. Docket hours are 9:30 a.m. to 4:00 p.m. Monday through 
Friday.

FOR FURTHER INFORMATION CONTACT: At NHTSA, for nonlegal issues: Dr. 
George Mouchahoir, Office of Vehicle Safety Standards (telephone 202-
366-4919). For legal issues: Deirdre Fujita, Office of the Chief 
Counsel (202-366-2992). Both can be reached at the National Highway 
Traffic Safety Administration, 400 Seventh St., S.W., Washington, D.C., 
20590.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Statement of the Problem
II. Improved Anchorage System
    a. Standardized System
    b. Competing Concepts
III. Public Workshop
    a. Summary of Presentations
    1. ISOFIX 4-point Rigid System
    2. CANFIX 2-Point Rigid System
    3. UCRA Soft Anchor System
    4. European Industry Hybrid System
    5. Car Seat Only System
    b. Clinics
    c. Cost
    d. Tether
    e. Agreement on Differences
    f. Future Work
IV. Subsequent Developments
    a. Albuquerque, N.M.
    b. Additional Information
    c. Petition on Scheme D (Hybrid System)
V. Evaluation of Concepts
    a. Top Tether
    b. Lower Anchorage Points
    1. Improve Compatibility
    2. Safety Performance
    3. Consumer Acceptability
    4. Costs and Burdens
    5. Harmonization
    6. Leadtime and Availability
    7. Proposed System
    c. Discussion of Alternatives
    1. SAE Recommended Practice J1819
    2. Lockability
    3. Car Seat Only System
VI. Proposal for New Vehicle Standard
    a. Highlights of Proposal
    b. Applicability
    c. Seating Positions
    d. Construction
    1. Lower anchorages
    2. Upper anchorages
    e. Performance
    f. Instructions
VII. Proposal for Amendments to Child Seat Standard
    a. Applicability
    b. Required Components
    c. Dynamic Performance
    d. Instructions and Labeling
VIII. Proposed Effective Date
IX. Rulemaking Analyses and Notices
    a. Executive Order 12866 (Regulatory Planning and Review) and 
DOT Regulatory Policies and Procedures
    b. Regulatory Flexibility Act
    c. Executive Order 12612 (Federalism)
    d. Unfunded Mandates Reform Act
    e. National Environmental Policy Act
    f. Executive Order 12778 (Civil Justice Reform)
X. Comments

I. Statement of the Problem

    The effective use of child restraints is important because of the 
number of children killed and injured in vehicle accidents. Annually, 
about 600 children less than five years of age are killed and over 
70,000 are injured as occupants in motor vehicle crashes. Data from the 
National Center for Health Statistics (for 1991) indicates that motor 
vehicle

[[Page 7859]]

occupant fatalities were the third leading cause of death for this age 
group (NCHS, 1993).
    While child seats are highly effective in reducing the likelihood 
of death or serious injury in motor vehicle crashes, the degree of 
their effectiveness depends on how they are installed. NHTSA estimates 
that the potential effectiveness of child seats, when correctly used, 
is 71 percent. However, it is estimated that imperfect securing of 
children in the child seats and/or of the child seats in vehicles 
reduce that effectiveness from the potential 71 percent to an actual 59 
percent. That is, as a group, child seats (those that were used 
correctly together with those that were misused) have an actual 
effectiveness of 59 percent.
    Child restraint effectiveness is reduced by limitations imposed by 
vehicle belt design, and by belt anchorage locations. Child seats are 
generally designed to attach to a vehicle by means of the vehicle's lap 
belt system. While child seats provide high levels of safety when 
correctly attached to a standard vehicle seat assembly with only a lap 
belt, in most vehicles different types of seat belt systems exist in 
addition to or in lieu of a lap belt. Among the different types are 
belt systems with a locking latchplate, a non-locking (sliding) 
latchplate, a reversible lockable retractor, an emergency-locking 
retractor, or an automatic seat belt. Some of these belt systems, such 
as those equipped with a locking retractor, are able to hold a child 
seat without use of attachment accessories, but a parent must correctly 
manipulate the system, such as by pulling the belt completely out of 
the retractor and then feeding excess slack back into it after buckling 
in the child seat. Some belt systems can be used to secure a child seat 
only when used with an accessory item that impedes movement of the belt 
or child seat in a crash, such as a locking clip or supplemental strap. 
Some belt systems, such as an automatic seat belt, may not be 
compatible with a child seat at all.
    The agency recognizes the difficulty of designing vehicle seat 
belts to restrain both child restraint systems and a wide range of 
weights and sizes of individuals. Some vehicle seats have the seat belt 
anchorage positioned far forward of the vehicle ``seat bight'' (the 
intersection of the seat cushion and the seat back). Forward-mounted 
anchor points may better protect an adult using the vehicle seat belt 
system by drawing the vehicle belt low across the pelvis where the body 
can best tolerate the forces in a crash. However, when used with a 
child seat, the belt anchor is so far forward of the seat bight that 
the vehicle belts cannot initially provide any resistance to the 
forward, longitudinal motion of a child seat reacting to a decelerating 
crash pulse. The child restraint moves forward until it is sufficiently 
far forward of the belt anchorages that the belt finally can resist the 
forward, longitudinal motion of the child seat. This forward movement 
of the child restraint can result in excessive forward movement of the 
child's head, and a greater likelihood of head impact.
    Child restraint effectiveness is also reduced by incorrect securing 
of children and child restraints due to the complexities of adapting 
vehicle belts to those purposes and due to failure to follow 
instructions. To properly install child restraints, devices such as 
lockable retractors, locking clips, and supplemental belts must be used 
in many cases. Unfortunately, it appears that many people installing a 
child seat are either unfamiliar with the use of these devices (which 
generally are not used or needed except in conjunction with a child 
restraint), not able to understand or unwilling to read instructions 
concerning their proper use, or unable to surmise from their design how 
to use them correctly. People generally are frustrated about the 
difficulty in installing child seats correctly in vehicle seats. Recent 
user trials conducted in the U.S.1 and Canada 2 found that 
virtually all the people surveyed in the studies expressed high levels 
of dissatisfaction with conventional means of attaching child 
restraints in vehicles. NHTSA receives an average of about 50 calls a 
day to its Consumer Complaint Hotline from people asking for step-by-
step guidance in installing their child seats. When an article appears 
in the media about incompatibility problems between child restraints 
and vehicle seats, those calls typically increase to over 500 a day. 
All of these callers express frustration at the difficulty of 
installing a child seat securely, and all urge NHTSA to make the 
installation easier. NHTSA understands that child restraint 
manufacturers also receive a large number of similar calls and asks 
that commenters verify this.
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    \1\ ``An Evaluation of the Usability of Two Types of Universal 
Child Restraint Seat Attachment Systems,'' General Motors 
Corporation, 1996.
    \2\ ``The ICBC Child Restraint User Trials,'' Rona Kinetics and 
Associates Ltd. Report R96-04, prepared for the Insurance 
Corporation of British Columbia, December 1996.
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    A four-state study done for NHTSA in 1996 examined people who use 
child restraint systems and found that approximately 80 percent of the 
persons made at least one significant error in using the systems. 
(``Patterns of Misuse of Child Safety Seats,'' DOT HS 808 440, January 
1996.) Observed misuse due to a locking clip being incorrectly used or 
not used when necessary was 72 percent, and misuse due to the vehicle 
safety belt incorrectly used with a child seat (unbuckled, 
disconnected, misrouted, or untightened) or used with a child too small 
to fit the belts was 17 percent.

II. Improved Anchorage System

a. Standardized System

    The difficulty with using vehicle safety belts to attach child 
restraints arises from the fact that those belts are primarily designed 
to restrain and protect larger and older vehicle occupants. Given the 
inability to change vehicle belt design and anchorage location because 
of this purpose, the agency is seeking a means of securing a child 
restraint that is independent of the safety belt. For a number of 
years, industry groups and governmental bodies have explored improving 
the securement of a child seat on a vehicle seat. The child seat and 
motor vehicle industry is unanimous that the means of attaching child 
restraints to the vehicle interior should be easier, more efficient and 
without incompatibility problems. Further, all agree that there should 
be a universal and independent means of attaching child restraints. 
That is, there should be means that are either identical or at least 
compatible, regardless of vehicle make or model, and that are dedicated 
solely for use in securing child restraints. The importance of 
universality across vehicle make or model also compels a universal 
requirement for the anchorage system, and would mitigate against having 
the system be available on an optional basis.
    The concept of a universal and independent anchorage system was 
embraced by the ``Blue Ribbon Panel on Child Restraint and Vehicle 
Compatibility,'' which NHTSA Administrator Ricardo Martinez, M.D., 
formed in February 1995 to improve the use and attachment of child 
safety seats.3 In its May 30, 1995 report recommending ways to 
improve the compatibility between child restraints

[[Page 7860]]

and vehicle seating positions, the panel recommended that there be an 
entirely separate anchorage system for child restraint installation, 
given the complex variables affecting the proper installation of child 
restraints using existing vehicle safety belts.
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    \3\ The Blue Ribbon Panel included child safety advocates and 
representatives of the motor vehicle, child safety seat and seat 
belt industries, including representatives from Ford, Chrysler, 
General Motors, Mercedes Benz, Volkswagen, BMW, Volvo, Nissan, 
Toyota, Honda, Century, Gerry, Fisher-Price, Cosco, Evenflo, 
Kolcraft, Riley Hospital, DANA Foundation, American Academy of 
Pediatrics, University of Michigan, TRW, and Takata, and advocates 
Stephanie Tombrello and Annemarie Shelness.
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    While there is universal agreement on the need to improve the ease 
with which child seats can be properly secured to vehicle seats and 
concurrence with the merits of a separate anchorage system, there is 
disagreement on which system is best. It is assumed that a 
``universal'' anchorage system must standardize the means of 
attachment, so that it and it alone would be required for all affected 
vehicles, and it alone would be the system with which child seats would 
be required to be compatible. This is needed to ensure universal 
compatibility between child seats and vehicles.

b. Competing Concepts

    In 1990, the ISO began work on a universal child seat anchorage 
system (``ISOFIX''). The ISOFIX concept originated as a 4-point rigid 
system, where four sturdy braces are mounted on the bottom of a child 
restraint. Each brace has a latch at its end. Two of the latches 
connect, through holes at the vehicle seat bight, to a metal bar in the 
seat frame. The other two latches, at the bottom braces, connect to a 
bar below the vehicle seat cushion. The ISOFIX system is supported by 
Volvo, as well as others.
    Other concepts for universal anchorage systems have developed as 
alternatives to the 4-point ISO system, many in response to perceived 
problems with the ISOFIX system, such as ISOFIX being too rigid, too 
susceptible to false latching, too bulky, unreasonably expensive, and 
too heavy.
    Transport Canada developed the CANFIX system, which consists of two 
rigid rear anchorages at the seat bight (rather than the four points of 
ISOFIX), plus an upper tether. This system envisions all vehicles to be 
equipped with upper tether anchorage locations. CANFIX is supported by 
Australia, which refers to the system as CAUSFIX. At this time, neither 
Canada nor Australia requires the CANFIX or CAUSFIX but both are 
interested in pursuing such a requirement in the near-term. It is 
noted, however, that Transport Canada has stated that in lieu of rigid 
lower anchorage points, it could support soft anchorages such as those 
of the ``UCRA'' system described below, in addition to an upper tether.
    General Motors (GM) helped develop a ``uniform child restraint 
anchorage (UCRA)'' system consisting of two lower anchorages near the 
bight line and an upper tether anchorage. The lower anchorages have 
small latches that are compatible with easy-to-use buckles (as well as 
tether hooks) that would be installed on the child seat. The top tether 
anchorage would have a buckle or tether hook that is compatible with a 
tether and latch or hook on the child seat.
    GM joined with thirteen other vehicle and child restraint 
manufacturers in petitioning NHTSA to require the UCRA system on 
vehicles and componentry compatible with the anchor system on child 
seats. The joint petitioners are: the American Automobile Manufacturers 
Association (AAMA), which includes General Motors, Chrysler, and Ford; 
five companies of the Association of International Automobile 
Manufacturers (AIAM) (Honda, Isuzu, Nissan, Subaru, and Toyota); the 
Juvenile Products Manufacturer's Association (JPMA), which includes 
child restraint manufacturers Century, Evenflo, Fisher-Price, Gerry and 
Kolcraft; and Indiana Mills and Manufacturing, a supplier of belt 
systems and hardware.
    As another alternative to the ISOFIX 4-point rigid system, several 
European ISO manufacturer members are currently developing a hybrid 
system. The system consists of two lower anchorage points located in 
the seat bight and an upper tether anchorage point located behind the 
vehicle seat back. A child restraint system could be attached to the 
two lower anchorage points by means of either a buckle (such as the 
UCRA buckle) or the ISOFIX connector. The object of this option is to 
achieve worldwide compatibility between the UCRA and ISOFIX types of 
connectors.
    The four systems described above are the four options, known as 
``Schemes'' A through D, that the ISO has been considering for the past 
year. The four-point rigid anchor system (ISOFIX) is known as Scheme A; 
the two-point rigid anchor and rigid attachment, plus tether, is Scheme 
B; the two-point flexible anchor and flexible attachment, plus tether, 
is Scheme C; and the two-point rigid or semi-rigid anchor and flexible 
attachment is Scheme D.
    Another approach for a universal anchorage system was advanced by 
Cosco, a child restraint manufacturer. Cosco suggested in a July 1, 
1996 petition for rulemaking to NHTSA that vehicle manufacturers alone 
should be responsible for improving compatibility between child seats 
and vehicle seats and the ease of installation of child seats. Cosco 
believed that vehicles should provide a dedicated Type I lap belt for 
child seats, at or rear of the vehicle seat bight. Cosco calls its 
system the ``Car Seat Only (CSO)'' system. Cosco envisions that the CSO 
system would require no changes in the design and manufacture of child 
restraints.

III. Public Workshop

    The relative merit of each of the systems was discussed at a public 
workshop NHTSA held on October 16 and 17, 1996 in Washington, D.C. 
Attending were about 100 persons from the U.S., Canada, Europe, Japan 
and Australia, representing governments and manufacturers of motor 
vehicles and child restraints, as well child safety advocates.4
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     4 A transcript of the meeting has been placed in NHTSA Docket 
No. 96-095, Notice 01, and is available from Neal R. Gross, Court 
Reporters and Transcribers, 1323 Rhode Island Avenue, N.W., 
Washington, D.C., 20005 (telephone 202-234-4433).
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    NHTSA held this two-day meeting to discuss the various alternatives 
of universal child restraint anchorage systems that are being 
considered by the agency, safety advocates, and automotive and child 
safety organizations, such as the Society of Automotive Engineers (SAE) 
and the ISO. The five options described above were presented and 
discussed as to design characteristics, safety performance, public 
acceptance and economic considerations. The meeting focused on bringing 
to discussion the characteristics of the various alternatives and not 
necessarily on reaching a consensus on a system. Participants had the 
opportunity to experiment with the UCRA and hybrid systems in actual 
vehicles that were provided by their respective manufacturers.

a. Summary of Presentations

    The following discussion summarizes the remarks of each presenter.
1. ISOFIX 4-point Rigid Systems
    Thomas Turbell (Sweden), presenting on Scheme A (ISOFIX), reviewed 
the ISO work of the last six years on the 4-point system. He said that 
the first ideas on an anchorage system envisioned a fixation point in 
the vehicle where forward-facing child seats and rear-facing seats 
could be installed. The ISOFIX type 1 system (two rigid points), the 
ISOFIX Type 2 system (``DELTAFIX,'' two rigid points and one point in 
the front) were compared in an early user trial with the conventional 
Swedish child restraint system (installation by the seatbelt and by two 
lower tethers attached to the seat frame). Eighty percent of the users 
installed the

[[Page 7861]]

ISOFIX type 1 system correctly the first time, 60 percent the DELTAFIX, 
and only 30 percent the conventional system. Eighty-nine percent of the 
subjects indicated that they wanted the new ISOFIX type 1 system. 
Ninety percent were willing to pay a 50 percent increase over a normal 
price of a child seat at that time.
    Work on the system continued in subsequent meetings of the ISO 
group in Stockholm in 1993, and Munich, where a list of features 
considered essential for the system was developed. For example, 
``misuse should be almost impossible, the cushion of the car seat 
should have no influence on the system, and * * * the performance 
should be better than the present systems.'' A ``UNIFIX'' proposed by 
the UK was later changed to the UNIFIX-2 four-point, and in 1993 in San 
Antonio, the ISO group decided that this was the system to develop. In 
1993, the group had its first draft ISO standard on the system, and in 
1994 it had a sixth draft completed.
    In London in 1995, the ISO group split the draft standard into 
three parts because there were problems with certain aspects of it. The 
Blue Ribbon Panel indicated a positive regard for the ISOFIX system, 
and the group received a resolution from the European Parliament 
pushing them to introduce the ISOFIX as soon as possible.
    In San Diego in 1995, General Motors presented its ideas on the 
UCRA and the Blue Ribbon Panel modified its earlier support for ISOFIX. 
In subsequent meetings in Cologne and London in 1996, GM presented its 
findings on its user clinic, and the Hybrid system was presented. Since 
then, a consumer clinic has been conducted on the different ISO schemes 
and a working group meeting has been held in Albuquerque.
    After reviewing the history of the development of the ISOFIX, Mr. 
Turbell noted concerns to consider. He believed that the anchorage 
system should be unrestricted by design patents. ``[Patents] will 
probably stop [an internationally] standardized system.'' He noted a 
concern about small cars being able to fit anchorage systems in a small 
rear seat, stating ``[W]e can't let the available space in the smallest 
rear seat decide the size of the child restraints.'' He also stated his 
belief that rigid systems might have an advantage over other systems 
with regard to the ease with which an air bag switch-off device can be 
incorporated.
2. CANFIX 2-Point Rigid System
    France Legault (Transport Canada), presenting Scheme B (CANFIX) 
(the system is also known as CAUSFIX in Australia), explained that 
Canada varied from the four-point ISOFIX system because of Canada's 
high regard for tethers on child seats and tether anchorages in 
vehicles. Canada requires anchorages in passenger cars, and will soon 
introduce a regulation extending the requirement to trucks, 
multipurpose passenger vehicles, and sport utility vehicles.
    Ms. Legault stated that CANFIX has one flexible top tether anchored 
to the body of the vehicle, and two lower rigid points based on the 
ISOFIX system. CANFIX has the possibility to include improved tether 
installation with better adjustability, e.g., in a reel or ratchet 
mechanism. It also has the possibility of a tether interlock, which 
would prevent the entire system from being installed if one of the 
points is not attached, and the possibility of an air bag switch-off. 
She said that before CANFIX was presented to the ISO group in 1995, 
Canada conducted sled testing and found that performance of the system 
was slightly improved over a conventional type of child restraint 
system. In that work, Canada also was able to design and build a device 
to test anchorages in a vehicle by pulling on them.
    Canada's position on a universal child restraint anchorage system 
is that while it has sponsored the two-point rigid system, Canada is 
also open to the idea of soft anchors at the bottom ``depending on 
usability and cost. * * *'' However, Canada definitely supports a 
tether. Ms. Legault indicated that Canada will retain its head 
excursion and chest acceleration criteria, which have the effect of 
requiring a tether, because of the perceived safety benefits of a 
tether. Canada will be improving its tether regulation to require 
factory installation of the actual hardware for the anchorage. 
Currently, Canada requires only a hole or a threaded hole, and the 
consumer has to obtain and install the bolt and latchplate.
    Canada believes harmonization is an important consideration in 
developing a universal child restraint anchorage system. Cost is 
important, and well as useability. Ms. Legault said that a positive 
engagement feature (e.g., a click or other indication on an engaged 
attachment) would be important for usability. She is concerned about a 
``transition period,'' where new and old vehicles and child seats could 
be intermixed. New child restraints equipped with components for an 
anchorage system must be capable of use with older vehicles lacking a 
system. Ms. Legault said that testing with a CANFIX prototype showed 
that, in about 85 percent of its vehicles (lacking receptors for the 
rigid points), the prongs would go in between the seat cushion and seat 
back, so that the seat belt could still be used to attach the child 
seat.
    Canada is in the process of testing the CANFIX and several 
conventional restraints to make sure that the tether will provide 
additional protection, not just when it is properly used but also when 
it is used with varying amounts of slack. Canada will be testing high-
mounted tethers and low-mounted tethers. Early test results show that a 
tether improves performance in head and chest acceleration and head 
excursion, even if the tether is loose. A tether also reduces neck 
forces and moments.
    Canada conducted surveys to determine the use rate of tethers. In a 
1992 survey of owners of vehicles that provided no tether anchorage, 
about 25 percent installed the anchorage and used it. Of vehicles that 
had standard anchorages, tether use doubled. In addition, new data from 
the Province of Quebec show that its tether use increased from 47 
percent to 65 percent after vehicles became equipped with a tether 
anchor, even when motorists had to take the extra step of installing 
the tether anchorage hardware.
3. UCRA Soft Anchor System
    David Campbell (Century Products), Kazuhiko Miyadara (Toyota), and 
Jack Havelin (GM), presented Scheme C (UCRA) and the petition for 
rulemaking on the UCRA. Mr. Campbell stated that the key objectives of 
its work on a uniform child restraint anchorage system are ``to find a 
single world-wide system, to address the issue of compatibility and 
misuse, while improving dynamic performance of current restraints.'' He 
stated that the system should be independent of the adult seat belt 
system so that manufacturers can have the flexibility to optimize the 
performance of the anchorage system for child restraints and allow the 
adult seat belt system to be optimized for the other occupants in the 
vehicle. Mr. Campbell stated that child restraint manufacturers believe 
that the UCRA system is the best system because the buckle and latch 
plate system is intuitive:

    They are the type of systems that are currently available in 
vehicles * * *. Secondly, it will minimize misuse. You won't have 
the routing issues that we have through current child restraints 
today with the vehicle lap belts because they are attached and you 
know how to use it.

    The UCRA also is designed so that current child restraints can be 
easily adapted to use it. This could be done by

[[Page 7862]]

means of a special belt provided by restraint manufacturers. The belt 
would have buckles on both ends to use with the UCRA latchplates, and 
would route through the current belt path used today.
    Mr. Campbell said that the manufacturing costs of the UCRA are 
lower than those for some of the other systems. There also is less 
added weight. He agreed with most of NHTSA's estimates about the weight 
increases of the various systems, but believed the UCRA would add only 
about 1 to 1.6 pounds (lb), rather than NHTSA's estimate of 4.5 lb. He 
stated that it would take less leadtime to begin implementing a UCRA 
requirement as opposed to the alternative systems, because the UCRA 
uses ``existing technology--known systems, known belts, known buckles, 
known latch plates.'' Expanding on the cost issue, the presenter stated 
that current child restraints cost and sell at retail between $35.00 
and $90.00 in the U.S.:

    Our market price is very sensitive, and one of the objectives we 
have is to increase the usage rate and not have a negative effect on 
the current usage rate. Soft anchors are predicted to add something 
in the order of magnitude of $20.00 to the cost of a child 
restraint. The Canadian CANFIX, the estimates were about $55.00 at 
retail, and for the ISOFIX it was $95.00. * * * Car seat loaner 
programs could be affected by this.

    Mr. Campbell also stated that the UCRA systems meets Standard 213's 
performance criteria without attaching the tether. Tethered, it meets 
Canada's requirements. He stated that use of the tether does 
significantly reduce head and knee excursions, but there is some trade 
off in chest accelerations and HIC values, and the use of the tether in 
a higher position can help reduce that HIC.
    Mr. Miyadara discussed past and current work evaluating usability, 
safety and cost issues for a two-point rigid system, a two-point soft 
system and current child restraint systems.
    A past study evaluated usability in a customer preference clinic of 
current, past and future users. No significant difference was found 
between the two-point hard and the two-point soft system. Safety was 
assessed in dynamic testing. Some differences in HIC and chest G values 
were found, but the actual effect that those differences could have on 
a child occupant were unknown. The presenter expected, though, that 
safety could be somewhat improved with regard to chest Gs. The 
presenter said that one of Toyota's biggest concerns with both a two-
point rigid and a two-point soft system is with potential ``loose fit'' 
of a child restraint on a vehicle anchorage system.
    A study of vehicle and child seat cost impacts indicated that a 
two-point soft system should be much more acceptable to the customer.
    Mr. Miyadara discussed current work on addressing the ``loose fit'' 
issue. Toyota has been jointly developing a device that could be used 
with a soft system to avoid the problem of consumers installing a child 
seat so that its fit is too loose. Toyota is evaluating a strap type 
device with belt adjuster, strap type with A-lock, lever-type and 
ratchet type. Toyota believes that it can work out the loose fit issue 
for a soft system in the near future.
    Toyota's future work includes a customer preference clinic on the 
Schemes A through C systems, and dynamic testing.
    Mr. Miyadara concluded by stating that Toyota's goals in joining in 
the AAMA et al. petition is to achieve international harmonization and 
provide increased safety to children by eliminating or decreasing 
misuse and improving crash performance, at a cost acceptable to the 
consumer. Further, to address the problems of incompatibility as soon 
as possible, the system should be implemented quickly. Mr. Miyadara 
said Toyota does not believe there is any reason to select the two-
point rigid system over the two-point soft system. He also suggested 
that NHTSA consider conducting a customer preference clinic of its own.
    Mr. Havelin addressed what he believed to be confusion about GM's 
position on a universal anchorage system. He said that GM supports an 
internationally harmonized requirement. Mr. Havelin stated that GM 
believes that an anchorage system should, foremost, increase child 
restraint use rates (citing the statistic that three out of four of the 
fatally injured children in the U.S. under the age of five are not 
using a child restraint), and secondly, reduce the potential for misuse 
and improve crash protection. GM suggested that NHTSA ``establish the 
template'' for international harmonization by issuing an NPRM based on 
three principles. ``First, what does our common customer want, that is, 
the child seat manufacturer's customer as well as the vehicle 
manufacturer's customer. We think the results of customer clinics need 
to be tempered to some degree by sound benefit/cost analysis * * * And 
finally, that template should be based on valid science. * * * [S]ome 
[consumer clinics and cost analyses] are better than others and we need 
to be focused on which ones are valid and which ones are not.''
    Mr. Havelin said that GM believes consumers prefer the UCRA system 
because the dual straps on the child seats use familiar anchorage 
hardware, and provide an intuitive, secure installation. Also, the 
tether is obvious and provides a secure anchorage. All three of the 
strap anchors give a positive indication when correctly attached. He 
said that other reasons the UCRA is preferred is that the child seat 
would be light and compact, and without any threatening surfaces (e.g., 
rigid prongs) associated with it. GM believes that the UCRA is within 
the acceptable cost range for consumers.
    The presenter also highlighted other perceived benefits of the 
UCRA, such as that it need not be tethered to meet Standard 213's 
performance requirements, can be retrofitted into existing vehicles, 
incorporates what GM considers to be ``fully developed and field-proven 
hardware, and can be implemented faster than the other attachment 
systems.''
4. European Industry Hybrid System
    Klaus Werkmeister (Germany), presenting Scheme D, provided some 
historical background on the development of a universal child restraint 
anchorage system. He believed that interest in a worldwide universal 
system started in the late 1980's to address a high rate of severe 
accidents where children were killed or injured. Experts determined 
that the real problem with those accidents was not the severity of the 
crash, but the considerable misuse rate of child seats due to the wrong 
adaptation of seat belts.
    In preparing for an April 1996 meeting in Cologne of the ISO 
Working Group of Child Restraint Systems, German vehicle manufacturers 
met to identify criteria they believed were important for an anchorage 
system. They developed a list of 12 properties. First, there should be 
no top tether, due to concerns about its non-use. Second, the system 
must have two lower symmetrical anchorage points, because unacceptable 
performance may result from an unsymmetrical configuration. Third, due 
to the configuration and dimensions of interior vehicle compartments, 
especially of smaller cars, there must be a 250 mm to 280 mm lateral 
spacing between the latch points. Fourth, the latch points must have a 
degree of stability to ensure that excursion limits are not exceeded. 
Fifth, the child restraint must be able to attach through a one-hand 
operation, to ensure that the restraint can be easily installed.

[[Page 7863]]

Sixth, there must be a means to prevent attaching the child restraint 
on one side only. Seventh, the user must be able to tension the child 
restraint with one hand. Eighth, there must be no reduction of seat 
comfort for adult passengers. Ninth, the locking device that attaches 
the child seat to the vehicle system must be attached to the child 
restraint, not the vehicle, to limit overall cost impacts. Tenth, to 
avoid design restrictions, the locking device need not be required to 
be a pushpad buckle. Eleventh, to ensure that a child restraint does 
not have excessive webbing or ratcheting devices, the length of the 
adjustment system used to tension the system should not exceed 200 mm. 
Lastly, the dimensions of the latch points on the vehicle should be as 
specified in Scheme A.
    The presenter said that dynamic testing of the four-point rigid and 
the soft anchor system showed a reduction in safety performance when 
the systems are not properly tightened. Also, a non-symmetrical 
configuration resulted in very high head acceleration.
    Mr. Werkmeister said that the Scheme D system incorporates ideas 
from both rigid and soft anchor systems. The system calls for defining 
a field around the ISOFIX fixture, which might include an area behind 
the seat bight (where hard anchors could be located), or an area in 
front of the seat bight (where semi-rigid anchors could be). A 
connector would be used to attach the child seat to the anchorage on 
the vehicle. At the option of the child restraint manufacturer, the 
connector could be attached to a piece of webbing (such as in the UCRA 
system), or could be built into the child seat (as in the ISOFIX rigid 
systems). The presenter estimates that the cost of the connector system 
would be about $12 for the vehicle and $9 to $15 for the child seat.
    The presenter expressed concerns about use rates for a top tether, 
believing that use rates will be far less than Canada's 65 percent. He 
also discussed concerns about the width between anchorage points and a 
symmetrical configuration of the child restraint. He emphasized the 
need for design flexibility in an anchorage system. He believed 
manufacturers should be provided maximum design flexibility to meet 
performance requirements and market demands, and believed that Scheme D 
best provides this.
5. Car Seat Only System
    John Reynolds and Carol Dingledy (Cosco), presented the ``Car Seat 
Only (CSO)'' system. Mr. Reynolds stated that Cosco looked at three 
critical issues when evaluating universal anchorage systems. First, 
Cosco looked at performance and determined that a system must not 
reduce the safety performance of existing child restraints. Second, 
Cosco looked at ``implementation,'' or the transition phase between the 
existing and new systems, the primary problem being the mix of new car 
seats with old cars, and old car seats with new cars. Third, Cosco 
looked at how the systems could affect the cost of child restraints, 
and in turn, overall use rates. Mr. Reynolds stated that after 
evaluating the systems under these criteria, Cosco decided to develop 
its CSO system. Cosco believed that because the system is a simple lap 
belt, it would have the least negative impact in terms of 
implementation and transition. Further, the CSO system would have the 
lowest cost to the car seat user, since the cost to the restraint 
manufacturer is virtually none.
    Ms. Dingledy elaborated on Cosco's concerns with implementation 
time and cost. She said that adopting a system other than the CSO will 
require considerable research on the part of child seat manufacturers 
to determine if seats comply. She said that, given the variety of car 
seats that must be tested (e.g., infant-only, convertible, forward- and 
rear-facing) and the different types of vehicle seats, just researching 
a new system prior to rulemaking will take at least many months, if not 
a year or so. She also indicated that research is needed to determine 
whether a rigid system might place excessive forces on a child's neck, 
particularly a young child who has less developed neck muscles. She was 
also concerned that the actual implementation of competing systems 
would require long leadtimes to implement (possibly two to five years 
development time, plus 10 years production time), as well as a great 
deal of public education. The presenter stated that this is in contrast 
to the CSO, which can be implemented much more quickly and which 
requires little education. Ms. Dingledy said that international 
harmonization of an anchorage system does not appear to be realistic in 
the near term.
    The presenter discussed cost concerns at length. She said that a 
system that significantly increases the price of car seats will 
decrease the number of new seats purchased at retail, possibly 
resulting in (1) more used child seats being purchased or (2) more 
children being incorrectly restrained in seats they have outgrown or by 
adult belts when they are too small for the belts. She believes 
consumers in the U.S. will resist purchasing car seats that retail 
between $100 and $200, and that even a $20 increase would slash sales 
dramatically. She indicated that the average price of a convertible 
restraint is $63, but about one quarter of the car seats purchased cost 
$50 or less; less than 5 percent cost $100 or more. She believes that 
perhaps 10 percent of persons purchasing car seats would be unable to 
purchase a seat if prices increase dramatically. She emphasized a 
concern about the impacts of cost increases on loaner programs.
    Ms. Dingledy estimated that a 10 percent decrease in child seat use 
rates would result in approximately 40 additional child fatalities 
annually. She also said that about three million car seats are sold 
each year to retail stores and loan programs. The presenter cautioned 
that a 10 percent reduction in the number of seats sold means 300,000 
children per year riding without a new car seat, which translates into 
1.2 million additional children riding unrestrained.
    Ms. Dingledy stated that questions arising about the CSO system 
concerning the possibility that adults may mistakenly use the CSO belts 
are unwarranted. She said that an adult would prefer a lap/shoulder 
belt to a lap only belt due to the superior performance and comfort of 
a Type II belt. She also said that the CSO belt could be installed at a 
location that makes it inaccessible for use with an adult, and could be 
prominently labeled or color contrasted to distinguish it from an adult 
belt system.
    At the conclusion of her remarks, Ms. Dingledy introduced Frank 
Rumpleton (appearing on behalf of the Juvenile Products Manufacturers 
Association) (``JPMA''), who presented the views of the North American 
car seat manufacturers. He said that the number one priority of these 
manufacturers is to increase the usage and more importantly the proper 
use of child restraint systems. In addition, they wish to ensure that 
the changes made to child seats are simple, intuitive and easy for the 
caregivers to use. They also support worldwide harmonization. 
Underlying all these priorities, however, is the belief that 
initiatives must be cost effective, because of a direct correlation 
between cost and use rates. He said that every dollar of cost at least 
doubles at the retail shelf. He suggested that the cost of an anchorage 
system could be better absorbed on the vehicle side than on the child 
restraint side.
    The presenter said that JPMA categorically rejects the four-point 
ISOFIX system and the two-point CANFIX or CAUSFIX rigid system, because 
of cost. He said that JPMA supports soft anchor systems, which includes 
the UCRA, CSO and Scheme D.

[[Page 7864]]

JPMA hoped that all parties attending the workshop would focus on the 
soft systems as a starting point and focus on the similarities and the 
positive aspects of each of these proposals, to develop a solution that 
maximizes the potential use of child restraints and minimizes the cost 
to the ultimate consumer.

b. Clinics

    Separate presentations were made on the public acceptance and 
support of the development of a universal anchorage system. The 
Insurance Corporation of British Columbia (ICBC) along with Rona 
Kinetics reported on the findings of its clinic on usability of various 
alternatives. The study surveyed 76 subjects in Vancouver, Canada 
representing a cross section of age, sex, and experienced/unexperienced 
groups. General Motors presented the findings of a February 1996, 
clinic that was conducted in Troy, Michigan with a sample of about 400 
subjects. Toyota also presented a customer preference study on various 
types of soft and rigid anchor systems that was conducted in Japan on 
rigid and soft systems. Finally, a study was recently initiated in the 
UK and a progress report on its findings of an initial small number of 
subjects surveyed was presented.
    Generally, the findings of these clinics were in agreement on two 
major issues: 1) all subjects surveyed seem to prefer a universal 
anchorage system over the current child restraints and 2) no 
significant difference in consumer acceptance was detectable when 
comparing between a rigid and soft anchorage system.

c. Cost

    The participants agreed that the cost of the rigid options is much 
higher than the soft anchorage system, with added costs to the child 
restraint system of about $100 for the 4-point ISOFIX, $60 for the 
CANFIX and $20 for the UCRA soft anchorage system. Cosco, whose 
alternative does not incur additional costs to current child 
restraints, raised important concerns regarding the potential negative 
effects of high increases to the retail price of current child 
restraints. Concerns over families not being able to afford the 
increase and over loaner programs with fixed budgets for purchasing and 
providing free child seats to low income families were discussed. The 
issue of cost increases was in conflict with European countries 
expectations, according to the attendants from Sweden who indicated 
that these added costs do not have such implications as expected in the 
U.S. market.

d. Tether

    Other discussions addressed specific issues pertinent to the 
development of universal child restraint anchorage systems. One major 
issue that was discussed pertained to the upper tether. A 
representative from the Insurance Institute for Highway Safety 
presented an overview of the experiences and possible reasons for non-
use of the upper tether in the US during the 1980s. On the other hand, 
a participant from Australia reported that the use of the upper tether 
in Australia is about 98%. Transport Canada also reported substantial 
increases in use of the tether in Canada. These experiences seem to 
indicate that the high usage of upper tether stems from the fact that 
the tether anchor points are provided on the vehicle and are visible to 
and easily accessible for use by consumers. There appeared to be an 
agreement among participants that a child restraint with an upper 
tether provides better protection to the child during a crash.

e. Agreement on Differences

    In the interactive exchange among attendees during the course of 
the workshop, several important points relating to development of a 
universal child seat anchorage system emerged. The following key views 
were expressed:
     User clinics indicate that consumers are overwhelmingly 
unhappy with the manner with which current child seats are attached to 
vehicle seats and wish to see improvement.
     The various systems evaluated in consumer trials (ISOFIX, 
schemes A through C) do not differ much in terms of safety performance 
(assuming proper installation) and public acceptance.
     Schemes B, C and D (CANFIX, UCRA and the Hybrid) are 
virtually variations of the same system, except for the hardware used 
to connect the child seat to the vehicle. CANFIX has specified a rigid 
anchor and rigid connectors on the child seat. UCRA specifies a buckle 
and latchplate system; the buckle would be on a piece of webbing 
attached to the child restraint and the latchplate would be on a semi-
rigid stalk at the vehicle seat bight. The Hybrid system would specify 
a 6 mm bar (e.g., a D ring) that could connect to a child seat either 
in front of or behind the vehicle seat bight. The UCRA system differs 
from the Hybrid system only with regard to the connector piece that 
fastens the child restraint to the vehicle.
     Purchasers of child restraints in the U.S. are very 
sensitive to price. Sixty-four percent of the car seats sold in the 
U.S. sell for less than $60. Consumers in this country are unwilling to 
pay the $300 it costs on average for a child seat in Sweden.
     The European manufacturers generally still prefer a rigid 
system, while U.S. manufacturers oppose it. Canada has indicated a 
willingness to move from a rigid two-point plus tether (Scheme B) to a 
soft two-point plus tether system.
     Scheme D (the Hybrid system) has potential in 
accommodating both rigid and soft systems. It would provide the 
greatest design flexibility, in that it would specify minimum elements 
of the vehicle anchor (e.g., a 6 mm bar) and a location that could 
connect to a child seat either in front of or behind the vehicle seat 
bight. It would provide vehicle manufacturers the option of supporting 
the anchor rigidly or semi-rigidly. Child restraint manufacturers could 
choose any means to attach to the anchor. A child seat could have a 
telescopic or a rigid device, or a soft attachment (piece of webbing), 
so long as the child seat can attach to the anchor.
     Each system has strengths but also possible weaknesses. 
Questions were raised about the cost, weight and development time 
needed for a rigid system, the slack that could be introduced into the 
belts of a soft system and the suitability of a soft system with fold-
over seats, the need for anchors to be visible to consumers in a Hybrid 
system, the possibility of slack and misrouted belts with the CSO 
system, and the actual use of a top tether in tethered systems.
     The various systems under consideration are unencumbered 
by patents of any kind. Britax (a European child restraint 
manufacturer), when asked about a certain patent application, expressly 
declared that it holds no patents or applications for patent or other 
claims that would hinder third parties from making ISOFIX equipped 
vehicles or child restraints using rigid or semi-rigid anchorages.

f. Future Work

    Manufacturers of motor vehicles and child restraints extensively 
explored the differences between the UCRA and European hybrid systems 
with an agreement to further develop this option to harmonize between 
the European vehicle manufacturers and Britax and the US and Japanese 
child restraint/vehicle manufacturers. These participants expressed 
that future efforts would be made to elaborate on progress of this 
development at a November 7 and 8, 1996, ISO Working Group on child 
safety meeting in Albuquerque,

[[Page 7865]]

New Mexico and future meetings of the Group.

IV. Subsequent Developments

a. Albuquerque, New Mexico

    During the November 7 and 8, 1996 meeting of the ISO Working Group 
on Child Restraint Systems (ISO/TC 22/SC 12/WG 1), the Group voted on a 
proposition containing two resolutions on the specifications for the 
anchorage of a universal child restraint anchorage system. The first 
resolution recognized the need to allow two anchorage systems: one 
based on two-prong nonflexible hardware (a system that is under 
development), and another based on flexible UCRA-type hardware (a 
system that is available today). A second resolution opposed an upper 
tether anchor in motor vehicles.
    Following the Albuquerque meeting, the Secretariat of the ISO 
Working Group opposed the proposition--which was intended to advise 
different governments on how to treat the use of ISOFIX with and 
without a top tether--on the basis that it goes beyond the mandate of 
the Working Group. A re-voting of an amended resolution was conducted 
by correspondence with the delegations of country members, and was due 
back to the Secretariat on December 6, 1996. The voting on this 
resolution was to select between: i) specifying a top tether anchorage 
in vehicles; ii) not specifying the tether; or, iii) either of these 
options. It was also agreed that two reports--one for the rigid and one 
for the rigid/semi rigid options--will be prepared by members of the 
Working Group to describe and specify these systems.
    The result of the re-voting was a resolution to produce two draft 
standards for universal child restraint attachment interfaces. One 
draft standard would cover an attachment system comprising the UCRA-
type attachments on the lower points. The other standard would cover 
the rigid anchorage system. The standards would not include 
specifications for an upper tether anchorage. (The results of the re-
voting and copies of the rough drafts of the two reports were placed on 
December 13, 1996 in Docket No. 96-095, Notice 01 for the readers' 
review.)

b. Additional Information

    On November 21, 1996, some of the UCRA petitioners provided the 
agency with additional information supporting their petition. NHTSA 
representatives met with representatives from General Motors, Century 
Products, Indiana Mills and the Lear Corporation, at the request of the 
latter, to discuss the resolutions of the ISO Working Group meeting in 
Albuquerque. (A December 13, 1996 memorandum describing this meeting 
and attaching the handouts is entry number 16 in Docket 96-95, Notice 
1.) The petitioners emphasized that the North American child restraint 
manufacturers strongly favor the UCRA system with an upper tether and 
have doubts that a determination can be made at this time that the 
rigid system would be a long term solution. They also presented the 
findings of an evaluation that Indiana Mills performed in response to a 
NHTSA call for harmonization during the public workshop. (The agency 
had requested that hardware manufacturers explore the feasibility of an 
anchorage system that would accommodate buckles, snap hooks and ISO-
type connectors with a flat latch or round link, for consideration at 
the Albuquerque ISO meeting.) Indiana Mills described the advantages 
and disadvantages of the various types of hardware and its reasons for 
supporting the existing technology of a flat latch plate/buckle system. 
Lear Corporation presented cost data for rigid and soft attachments to 
various types of vehicle seating systems. It stated that the vehicle 
added cost data should be considered as a complement to the NHTSA study 
cost figures. Specifically, it included cost figures on items, such as 
covers and trim of rigid anchors, that were not included in the costing 
of the NHTSA study. The data showed that the costs of the soft 
anchorage system per seat on the vehicle range from about $4 to $10, as 
compared to about $13 to $30 for the rigid anchorage points system.

c. Petition on Scheme D (Hybrid System)

    On December 18, 1996, BMW, Chrysler, Ford, Land Rover, Mercedes-
Benz, Volkswagen, and the University of Michigan Child Passenger 
Protection Research Program, petitioned NHTSA to consider an approach 
based on Scheme D and modify the suggestions made in the UCRA petition. 
These petitioners supported a system incorporating two ``latch plates'' 
formed of 6 mm diameter elements for the vehicle, ``coupled with the 
alternatives for the [child restraint system], namely, tether hooks or 
buckles on belts with tilt-lock adjusters for tension release, or the 
rigid ISOFIX connectors on a sliding element.'' The petitioners believe 
that this system will offer vehicle and child restraint manufacturers 
the greatest design flexibility, and will further international 
harmonization at an early date.

V. Evaluation of Concepts

    During the course of the agency's deliberations on a universal 
child restraint anchorage system and as a result of the discussions at 
the October 1996 workshop and other information, the agency has 
tentatively determined that child seats can be better secured to a 
vehicle (thereby reducing incompatibility problems and increasing 
safety) by providing three anchorage points between the restraint and a 
vehicle seat. One point is at the top center of the restraint 
(attachment of a child restraint to a vehicle would be accomplished at 
that point through a top tether), and the other two are at the vehicle 
seat bight.

a. Top Tether

    ISO Schemes B and C (CANFIX/CAUSFIX and UCRA) include provisions 
for a top tether. Cosco indicated it would support a tether 
requirement, although the manufacturer is concerned whether tethers 
will be used in this country. The European systems do not call for 
tethers.
    As a result of the agency's deliberations on this rulemaking,5 
the agency reevaluated its view of a top tether on child restraints. 
NHTSA currently does not require a tether or a tether anchorage on 
vehicles. The agency does not prohibit a tether, but generally requires 
child restraints to meet Standard 213's 30 mph dynamic testing 
requirements without attaching a tether to reflect the historically low 
use rate of tethers in this country.
---------------------------------------------------------------------------

    \5\ On November 15, 1996, the American Academy of Pediatrics 
(AAP) petitioned NHTSA to amend Standard 213 to require child 
restraint manufacturers to supply tether straps on all child seats 
and require vehicle manufacturers to provide tether anchors at all 
rear seating positions. AAP also requested that child restraint 
manufacturers be required to make tether straps for existing car 
seats available to consumers by mail order and at retail outlets. 
NHTSA granted this petition on January 14, 1997.
---------------------------------------------------------------------------

    NHTSA tentatively concludes that a top tether should be provided to 
better secure a child restraint. By restraining the top portion of a 
child seat, a tether would supplement the vehicle belt system in 
limiting forward movement of the child restraint in a crash. With less 
forward movement, head excursion can be reduced.
    This document proposes a performance requirement that would have 
the practical effect of requiring a tether on child seats. A new head 
excursion requirement for forward-facing seats would be added to limit 
excursion to 720 mm (28.35 inches) forward of the Z-point on the test 
seat assembly when a child seat is attached

[[Page 7866]]

to the standard seat assembly in accordance with the manufacturer's 
instructions. To meet this requirement, manufacturers will likely have 
to provide a top tether, which would be attached in the test for this 
new requirement. NHTSA believes that the head excursion limit of 720 mm 
is practicable with a tether because it is the same as the Canadian 
requirement and because most, if not all, child restraint manufacturers 
currently produce child restraints for sale in Canada and thus already 
meet the requirement for those products. The 720 mm requirement would 
promote harmonization with Canadian requirements. Further, the European 
child restraint manufacturers believe that a 720 mm limit could be 
achieved with the rigid anchorage system with two lower anchorages and 
no upper tether.
    Test data strongly support the safety value of a tether. AAMA et 
al. submitted test results in support of a requirement for a tether 
anchorage, stating:

    Test results clearly demonstrate that a fastened tether can 
significantly reduce dummy head excursion measurements which most 
developers and evaluators use as the primary predicator [sic] of a 
CRS's performance in field accidents * * * .
    An Australian report cites forward-facing CRS test results, 
indicating that ``as well as reducing head excursion, a top tether, 
with the right high mounted geometry, significantly reduces head 
acceleration and neck loads in frontal impacts'' [footnote excluded] 
* * * . Recent computer simulations and tests of the recommended 
UCRA concept suggest that * * * a fastened tether significantly 
reduces dummy head excursion during high severity frontal impacts.

    Computer simulations conducted by petitioners AAMA et al. showed a 
reduction in force levels experienced by a restrained dummy's head, 
neck and chest when a tether was used as compared to no tether, and a 
reduction in head and knee excursions. Actual testing of child 
restraint systems with and without a tether showed that with the tether 
attached, there generally were reductions in head injury criterion 
(HIC) values and chest g's, and in head and knee excursions.
    These findings are consistent with NHTSA's limited testing of 
tethers. In two tests of an Evenflo Scout forward-facing convertible 
seat with the inboard anchor of the lap belt restraining the child 
restraint to the test seat assembly positioned four inches forward of 
the seat bight, the HIC and 3 ms chest acceleration clip were 631 and 
59.6 g's respectively. When the child restraint was tethered on its 
top, these HIC and chest clip measurements were reduced to 503 and 42.2 
g's, respectively.
    In her comments at the October public workshop, Ms. Legault of 
Transport Canada reported that on-going testing of tethered, untethered 
and loosely-tethered restraints indicate improved head acceleration, 
head excursion and chest acceleration with a tether strap, even when 
the strap is loose. Additionally, upper neck forces and moments were 
also improved with a tether. (Transcript of October 17, 1996, pp. 32-
34.) (However, Indiana Mills tests showed increased HIC and chest g's 
for a child seat with a dual strap anchorage with a tether, compared to 
one without a tether. Comments are requested explaining these 
increases.)
    However, nonuse of the tether has been a problem in the U.S. In an 
effort to boost use rates, NHTSA once proposed requiring all vehicles 
under 10,000 lb GVWR to have tether anchorages at all rearmost seating 
positions, to make it possible for motorists to easily attach the 
tether straps on their child restraints to the vehicle. 45 FR 81625; 
December 11, 1980. At the time of the proposal, tether use was about 50 
percent. NHTSA terminated rulemaking on this proposal after determining 
that (a) since the proposal, there was a continual shift toward 
untethered seats, so that most seats did not need a tether to meet 
Standard 213's requirements; (b) motor vehicle manufacturers had 
increasingly been voluntarily providing provisions, such as 
indentations to identify anchorage points and pre-drilled or threaded 
holes, in their vehicles to facilitate the attachment of tether straps; 
and (c) the most effective way to promote child safety would be to 
amend Standard 213 to require all child restraints to meet Standard 
213's requirements without attachment of the tether. July 5, 1985; 50 
FR 27632.
    Petitioners AAMA et al. believe that a tether will be used. GM's 
consumer focus group testing indicates a positive response toward a 
tether, particularly if the tether anchorage is equipped with all the 
components needed for use with the child restraint. The petitioners 
state, ``Australian field experience shows very high tether use rates 
are obtainable when factory installed tether anchorages are provided.'' 
(Emphasis in text.) Indeed, top tether use is reported in excess of 95 
percent in Australia, primarily due to requirements for installation of 
the anchorages and to early and continuous public education on the use 
of tethers. ``Options for a Universal Child Restraint Attachment 
System,'' M. Lumley, June 14, 1996, revised October 10, 1996. 
Petitioners are also encouraged by information from the Canadian 
Province of Quebec indicating a 65 percent tether use rate in vehicles 
required to have just a tether anchorage, and not the tether hardware. 
``This in spite of the fact, that vehicle owners must install the 
tether anchorage hardware themselves or return to their dealer to have 
it installed.''
    In an effort to increase tether use in Canada, Transport Canada is 
proposing to require vehicles to have a factory-installed, user-ready 
tether anchorage, with hardware included. Transport Canada believes 
that tether use will increase if an anchorage equipped with all needed 
parts for consumer use is provided at the factory. NHTSA tentatively 
believes that this information from petitioners AAMA et al. and from 
Transport Canada provides a basis for concluding that tethers would be 
used if child seats are equipped with a tether and vehicles are 
equipped with a factory-installed, easy- and ready-to-use tether 
anchorage. Accordingly, in view of the potential added safety value of 
a tether, the agency proposes requiring installation of a ready-to-use 
tether anchorage at the two seating positions that would be required to 
have the lower anchorages dedicated for attaching a child restraint 
system. (See infra, section VI.c.) For purposes of harmonization, the 
proposed requirements for the tether anchorages are essentially 
identical to those proposed by Transport Canada.
    However, because NHTSA does not know the extent to which tethers 
will be used in this country, the agency believes the standard should 
also retain the present head excursion requirement, which limits 
excursion to 813 mm (32 inches) without use of a tether strap. 
Retaining the requirement would ensure a minimum level of safety 
performance when the tether strap is not used. Further, NHTSA proposes 
that child restraints dynamically tested on a child restraint anchorage 
system with UCRA anchorages should be subject to the 813 mm (32 inches) 
head excursion requirement without attaching the tether. This accords 
with the AAMA et al. petition, which suggests not attaching the tether. 
Comments are requested on this issue. Comments are also requested on 
the potential of using tethers in aircraft.

b. Lower Anchorage Points

    Improving the lower anchorage points of a child seat to the vehicle 
would make it easier for parents to correctly attach a child seat to 
the vehicle.
    NHTSA stated in the Federal Register notice announcing the workshop 
that an

[[Page 7867]]

anchorage system should accomplish the following:
     Improve the compatibility between child restraint systems 
and vehicle seats and belt systems, thereby decreasing the potential 
that a child restraint was improperly installed;
     Ensure an adequate level of protection during crashes;
     Ensure correct child restraint system use by ensuring that 
the child restraint systems are convenient to install and use;
     Ensure that the child restraint systems and anchorages are 
cost effective; and
     Achieve international compatibility of child restraint 
performance requirements for uniform anchorage points.
    In remarking on the various ISO schemes and in other presentations, 
participants in NHTSA's workshop concurred with and elaborated on these 
considerations.
1. Improve Compatibility
    All of the anchorage systems appear to improve compatibility 
between child restraint systems and vehicle belt systems. Consumers 
comparing ISO Schemes A, B and C systems against conventional child 
restraints indicated that the new methods of attachment are easier than 
current methods. Cosco's CSO system was not evaluated in these studies, 
but to the extent that the CSO does not depend on a locking clip or 
other means to adapt the belt to a child restraint, an improvement over 
existing belt systems, at least concerning that aspect of design, can 
be assumed. The CSO belt would still have to be routed correctly 
through the child restraint. All anchorage systems would improve 
compatibility between child restraint systems and forward-mounted 
anchors. Views were expressed at the October 1996 workshop that Schemes 
A, B and C systems would improve compatibility between child restraints 
and contoured vehicle seats. A rigid anchor system may suspend the 
child restraint above the contoured seat, and a UCRA would provide some 
resistance to the side-to-side motion of a child seat on a humped 
contoured seat. The CSO might not be as effective on humped seats in 
limiting side-to-side motion of a child restraint.
2. Safety Performance
    ISO Schemes A, B and C systems have performed satisfactorily in 
dynamic tests. The CSO system has not been tested, but it simulates the 
standard seat assembly used in Standard 213 compliance tests.
    Consumer clinics indicate that ISO Scheme A, B and C systems are 
comparable in terms of a user's ability to correctly install them. 
Users are able to install child restraints correctly in those systems. 
Scheme D and the CSO were not evaluated.
    The degree to which an anchorage system will be correctly used 
outside the context of a clinic is unknown at this time, but design 
differences between the systems could affect such use. Attendees at the 
public workshop expressed concern with potential misuse problems that 
could arise by virtue of the design of each system. A type of misuse 
that could occur with a rigid system (ISOFIX four-point or CANFIX) is 
if the user does not fully attach all points of the system. Test data 
indicate that performance of the child restraint is severely degraded 
if one or more points are not attached. Some attendees believed that 
users must be able to see clearly where to insert the child seat 
connector to the vehicle system, and that a guide of some sort is 
needed if the attachment point is behind the seat bight. Some believed 
that an education campaign is needed to teach people how to use the 
system since a rigid bar anchorage is unfamiliar in this country.
    Proponents of the UCRA system believe that the soft anchor system 
is superior to a rigid system in that the connectors are buckles and 
latches that are consumer-familiar in design to the seat belt hardware 
on vehicles. Proponents believe that users will know ``intuitively'' 
how to use the connector and will recognize the sound and feel of the 
click that indicates a positive attachment. Several participants 
expressed concern about a possible misuse problem arising due to the 
presence of webbing on the connectors, i.e., that slack in the webbing 
will negate a tight fit of a child seat on the system. Toyota indicated 
it is developing a means of addressing this potential problem.
    Cosco believes the CSO system ``is the most intuitive system 
suggested because people have been using this type of system for 
years.'' NHTSA believes that while users might be familiar with the 
system, the CSO system poses some of the same problems as the lap belt 
currently used to attach child restraints. The belt would have to be 
correctly routed through the child restraint, which is a problem 
occurring with present seats. Slack in the belt would negate a secure 
fit of the child seat, so an adjuster of some sort would be needed, and 
it would have to be positioned on the belt where a user could maneuver 
around the child seat to tighten the belt. The seat belt would have to 
be long enough to permit it to be fastened around all types of child 
restraints, including restraints for children with special needs. A 
common complaint with current child seats is the difficulty of routing 
the belts through the system and pulling the belt tight. It appears 
that the CSO system might not alleviate those problems in all 
restraints. Further, there is the potential that the CSO belt would be 
inadvertently used by an adult occupant as a restraint, particularly in 
a seating position equipped with a lap belt, even if the CSO belt were 
labeled.
    It may be possible to attach child seats with either a rigid anchor 
(ISOFIX four-point rigid, CANFIX) or a soft anchor (UCRA) system design 
to a vehicle seat in the same way that current child seats are 
attached, using the occupant belt system (and meet minimum performance 
criteria). Thus, it may be possible to use them in a vehicle that lacks 
an anchorage system. The ability to attach a child seat in a 
conventional manner, i.e., using the vehicle belt, is an essential 
feature addressing the use of new child seats with old vehicles, and 
vice versa (old child seats with new vehicles). Ms. Legault of 
Transport Canada said that testing with a CANFIX prototype showed that, 
in about 85 percent of its vehicles (lacking receptors for the rigid 
points), the prongs could be inserted between the seat cushion and seat 
back, so the seat belt could still be used to attach the child seat. 
All child seats with UCRA-designed anchorages can be attached to a 
vehicle by use of the existing vehicle safety belt, because the UCRA 
design is based on a simple addition of buckles to current models of 
child seats. The CSO design would also result in all child seats being 
able to be attached in a conventional manner. It is unknown whether the 
four-point ISOFIX seat could be attached with an existing vehicle belt 
and perform satisfactorily.
    The various systems differ in their ability to allow child seats 
and vehicles to be retrofitted with features of the anchorage system. 
The ability to retrofit is desirable, since it would increase the 
number of seats that provide improved protection. Retrofitting seats 
and vehicles would provide all children the benefits of the improved 
technology. It does not appear that the four-point ISOFIX or the two-
point CANFIX allows for retrofitting either the child restraint or the 
vehicle. These rigid anchorage systems necessitate an elaborate 
redesign of existing child seats. The anchorage pins on the vehicle 
seat would have to be precisely aligned with the prongs on the child 
seat to ensure that the system performs properly. Alignments of this 
nature are generally

[[Page 7868]]

not believed to be feasible in the aftermarket.
    Proponents of the UCRA system state that existing seats can be 
installed using the UCRA system if the system is supplemented by a 
special belt with buckles at each end that are compatible with the UCRA 
latchplates on the vehicle. The belt would be provided to the owner of 
the old (pre-standard) child seat to route through the existing belt 
route path on the child seat. Further, proponents of the UCRA system 
believe that vehicles can be retrofitted with the UCRA system. The CSO 
system calls for no change in the design of a child seat, so old child 
seats could be used with a CSO system in a vehicle. Cosco did not 
indicate whether vehicles can readily be retrofitted with the CSO belt 
system, although it appears as feasible as retrofitting them with the 
UCRA system.
3. Consumer Acceptability
    Consumer clinics indicate that ISO Scheme A (rigid four-point), B 
(CANFIX) and C (UCRA) systems are comparable in terms of consumer 
acceptance. Participants in GM's clinic indicated a preference for 
UCRA. Scheme D and the CSO were not evaluated in the clinics. 
Participants in all the clinics indicated a desire to see an 
improvement in the way child restraints are attached to vehicles. With 
regard to bulk and added weight to a child restraint, the CSO adds no 
weight, and the UCRA appears to have an advantage over a rigid system 
and the CANFIX. The rigid prongs and supporting structure on a rigid 
system add much more weight than the buckles of a UCRA and also 
protrude from the child restraint.
4. Costs and Burdens
    Cost is an area where the systems differ greatly. The cost of the 
rigid options is much higher than the soft anchorage system, with added 
costs to the child restraint system of about $100 for the four-point 
ISOFIX, $60 for the CANFIX and $14 for the UCRA soft anchorage system. 
The agency is concerned that the $60 to $100 added costs of the rigid 
systems could engender public dissatisfaction with child restraints, 
reduce child restraint use rates and significantly reduce the number of 
seats available through car seat loaner programs. The CSO system does 
not incur additional costs to current child restraints.
    Schemes A, B and C systems are fairly design restrictive, in 
specifying the geometry and location of assorted components on the 
vehicle and child seat. Scheme D (Hybrid) and the CSO specify only the 
features of the vehicle system, and not of the child seat. Design 
flexibility allows manufacturers latitude in meeting market demands and 
developing new technology, yet would be a trade-off in standardization 
of the anchorage system.
5. Harmonization
    Harmonization was one of the major goals of the agency's October 
1996 public workshop. NHTSA stressed the importance of international 
harmonization during the workshop and urged ISO member country member 
delegates to agree on a unique child restraint anchorage system.
    The UCRA system would harmonize with Canada, Australia, New Zealand 
and Japan in specifying a top tether. With the top tether proposal, the 
proposed rule would harmonize with Transport Canada's current head 
excursion threshold and with its planned new regulation proposing to 
require manufacturers to provide anchors for tethers in motor vehicles. 
The rigid anchor system is endorsed by European members of the ISO 
Working Group.
6. Leadtime and Availability
    The different systems are at varying stages of development in 
design concept. Final design of the four-point ISOFIX system and the 
two-point rigid CANFIX have not been completed, although proponents of 
those systems believe that completion is imminent. Design of the UCRA 
system is completed.
    The view was expressed at the October 1996 workshop that the 
leadtime needed to implement a requirement for a rigid system would be 
much longer than that needed to implement the UCRA system. This is 
because the UCRA uses ``existing technology--known systems, known 
belts, known buckles, known latch plates'' (quoting David Campbell). 
Cosco argues that its CSO system would be the fastest to implement.
7. Proposed System
    The agency has decided to base a proposal for a universal child 
restraint anchorage system primarily on the UCRA system. The four-point 
and two-point rigid and the UCRA appear comparable in terms of safety 
performance and public acceptance, but the UCRA appears to have 
advantages over the others with respect to its cost impact, near-term 
availability and ability to address intermix and retrofit issues. 
Further, the UCRA system has advantages in terms of its usability. The 
agency believes the familiarity of its components (particularly the 
crucial connector pieces--buckles and latchplates--that attach a child 
seat to the vehicle system) is a definite advantage over the other 
systems. Also, the UCRA system is not as bulky or heavy as the other 
systems, which increases its usability.
    In addition, NHTSA believes that the soft anchor system has a 
potential for use in restraining child seats in aircraft. The Federal 
Aviation Administration (FAA) stated in a submission to NHTSA's docket 
for the October 1996 public workshop on a universal anchor system that 
``preliminary review and evaluation of the proposed ISOFIX systems 
under consideration by [NHTSA] suggest that the UCRA concept presents 
the best solution in the aircraft environment.'' 96-95-N01-008. FAA is 
concerned that the rigid prongs of an ISOFIX-type child seat may not be 
compatible with aircraft seat cushions or suited for narrow aircraft 
seats.
    While NHTSA has decided to propose the UCRA system due to its 
advantages in cost, usability, potential for use in aircraft, and the 
fact that it is proven technology available today, the agency is still 
interested in the possibility of achieving harmonization on a universal 
anchorage system. To that end, NHTSA is proposing to permit vehicle 
manufacturers to substitute the two lower rigid points of ISO Scheme D 
(the Hybrid system) in place of the UCRA anchors, provided that the 
vehicle is also equipped with adapters that enable the lower rigid 
points to accommodate UCRA-type child restraint systems.
    The European manufacturer members of the ISO Working Group on Child 
Restraints Systems believe that their countries will require the two 
rigid anchorage points in the future.6 Accommodating both hardware 
systems would be consistent with the agency's goal of solving the 
problem of incompatibility between child restraints and motor vehicles 
as expeditiously as possible, while promoting harmonization. The UCRA 
system, being a well developed and familiar current technology, is 
currently available. The non-flexible system would be given the 
opportunity to be developed, tested and evaluated in the market place 
to prove what its proponents believe to be its superiority as the child 
restraint anchorage technology of the future.
---------------------------------------------------------------------------

    \6\ It should be noted that the work thus far by the ISO has 
been at the Working Group level. Any ISO standard on this matter has 
still to go to higher committee before it becomes a standard.
---------------------------------------------------------------------------

    NHTSA tentatively concludes that the two proposed systems can 
coexist in the

[[Page 7869]]

short term. The UCRA system will not hinder any development of the non-
flexible hardware system. The proposed rule allows vehicle 
manufacturers to install a 6 mm pin to attach a child restraint that is 
equipped with jaw-type non-flexible hardware. The proposed rule would 
not prevent manufacturers of child restraints from developing a 
restraint with non-flexible hardware, and would facilitate a transition 
to future technology. However, in the interest of eradicating 
incompatibility problems henceforth, child restraints with non-flexible 
hardware would be required to have components (e.g., buckles), 
permanently attached to the child restraints, that are compatible with 
the UCRA anchorages. This proposal considers the UCRA system to be 
paramount, and a rigid system would be allowed as long as the UCRA 
system is universal for all vehicles and child restraint systems.

c. Discussion of Alternatives

    A number of other approaches have been suggested to minimize or 
eliminate incompatibility between child seats and vehicle seats. This 
section addresses these alternatives to the approach proposed today.
1. SAE Recommended Practice J1819
    In 1994, the Society of Automotive Engineers (SAE) published its 
Recommended Practice SAE J1819, ``Securing Child Restraint Systems in 
Motor Vehicle Rear Seats,'' to promote compatibility between child 
seats and vehicle rear seats and seat belts. J1819 provides voluntary 
design guidelines to vehicle manufacturers for certain characteristics 
of rear seats and seat belts, such as seat cushion shape and stiffness, 
and seat belt anchorage location, belt length, buckle and latchplate 
size, and lockability. In addition, J1819 provides design guidelines to 
child seat manufacturers for child seat features that correspond to the 
vehicle features.
    J1819 specifies a ``Child Restraint System Accommodation Fixture'' 
to represent a child seat, so that designers of both the vehicle and 
child seat can evaluate each product for compatibility.
    NHTSA tentatively concludes that J1819 alone does not fully solve 
incompatibility problems. It is a tool for evaluating incompatibility, 
not a requirement that vehicle seats and child restraints must be 
compatible.
    In the October 1996 workshop, Mr. Howard Willson (who chairs the 
Children's Restraint Systems Standards Committee of the SAE) stated 
that J1819 might be amended to add ``a test for seat contour.'' The 
test would enable vehicle manufacturers to ``identify seating positions 
where it's probable that child restraints will not work well because of 
seat contour.'' He also stated

I doubt that we will agree to simply design our seating positions so 
that they're all as flat as the seats in a pick-up truck used to be, 
for example. There is an appeal to a shaped seat, an appeal to the 
users. (Transcript of October 18, pp. 8-9.)

    At the same workshop, Mr. David Campbell said that a child 
restraint anchorage system--

should be independent of the adult seat belt system so that 
manufacturers can have the flexibility to optimize the performance 
of the anchorage system for child restraints and allow the adult 
seat belt system to be optimized for the other occupants in the 
vehicle. (Transcript of October 12, p. 40.)

    NHTSA tentatively agrees with this statement. Further, NHTSA 
recognizes that it is very difficult for a single system to optimize 
the safety protection for adults of all ranges and child restraints of 
different types. Nonetheless, the agency requests comments discussing 
possible design alternatives to a universal child restraint anchorage 
system.
2. Lockability
    In 1993, NHTSA amended its occupant crash protection standard 
(Standard 208) to adopt a ``lockability'' requirement effective 
September 1, 1995. The rule requires vehicle lap belts or the lap belt 
portion of lap/shoulder belts to be capable of being used to tightly 
secure child safety seats, without the need to attach a locking clip or 
any other device to the vehicle's seat belt webbing, retractor or any 
other part of the vehicle. 58 FR 52922, October 13, 1993. The 
requirement applies to seating positions other than the driver's 
position on vehicles with a gross vehicle weight rating of 10,000 
pounds or less.
    The rule requires the lap belt to be lockable and specifies test 
procedures demonstrating compliance with the lockability requirement. 
The rule does not specify how the vehicle belt is to be locked, except 
to prohibit locking by ``inverting, twisting or otherwise deforming'' 
the belt webbing. An example of a permitted means of locking a belt is 
extending the belt all the way, then feeding in the slack.
    NHTSA tentatively concludes that the lockability requirement is 
insufficient alone in addressing incompatibility problems. While the 
requirement ostensibly makes a locking clip obsolete, it still depends 
on the user knowing enough and making the effort to manipulate the belt 
system. Also, the vehicle belt must be routed correctly through the 
child restraint, which may not be an easy task in all cases. Further, 
the lockability requirement does not address incompatibility problems 
arising from forward-mounted seat belt anchors. Excessive forward 
movement of a child seat can still occur, even if the feature is 
engaged and the belt is ``locked.'' Comments are requested on this 
issue. NHTSA is considering deleting the lockability requirement as 
unnecessary if requirements for a child restraint anchorage system are 
adopted. A lockability requirement may not be needed for a seating 
system with a universal anchorage system since the vehicle's belt would 
no longer be used for attaching a child restraint. However, lockability 
might be needed to attach child seats that are not equipped for a 
universal anchorage system, even if the vehicle seat has such a system.
3. Cosco's CSO system
    Cosco's CSO system is appealing in its simplicity and low cost, but 
the CSO system is essentially no different from the current lap belt 
means of attaching child restraints to vehicle seats. NHTSA is 
concerned that the CSO system might not make attaching a child seat 
significantly easier than it is today. As noted previously, the CSO 
belt would have to be correctly routed through the child restraint, 
which manufacturers believe many consumers find difficult to do. In 
addition, from photographs of the CSO system, it might be difficult to 
tighten the belt. Consumers have expressed concern about their child 
seat not being secure on the vehicle seat because of the lateral side-
to-side motion of the child restraint that occurs no matter how tightly 
the lap belt is adjusted. On a contoured, humped, seat, there is even 
more lateral ``play.'' The CSO system might not be able to address 
these concerns. Cosco provided no data on these issues assessing the 
viability of this approach. Another concern relates to the potential 
that the CSO belt would be inadvertently used by an adult occupant as a 
restraint, even if the CSO belt were labeled. It is also unknown how 
consumers will accept the addition of more seat belt systems in the 
rear seat, in addition to the Type I and II belts already provided in 
the rear seat. The agency requests data or comment on any research that 
has been done on the CSO system evaluating its acceptability by 
consumers, its performance with child restraints, the potential for 
correct use with child restraints and for misuse by adult passengers. 
Focus group testing comparing the CSO system to the UCRA and other 
standardized systems would be especially helpful.

[[Page 7870]]

VI. Proposal for New Vehicle Standard

a. Highlights of Proposal

    The most significant requirements proposed by this document are 
highlighted below.
    (1) A new safety standard would require all passenger cars and 
light trucks and vans to be equipped with a child seat anchorage 
system, defined in the standard, at two rear seating positions. If an 
air bag cutoff switch is provided that deactivates the air bag for the 
front passenger position, one system would have to be provided in that 
position, and another in a rear seating position. If there is no rear 
seat and no air bag cutoff switch, an anchorage system would be 
disallowed in the front passenger seat. A built-in child seat may be 
substituted for one of the systems, but not both, since rear-facing 
built-in systems are currently unavailable.
    (2) The system would consist of two lower anchorages at the vehicle 
seat bight (the intersection of the seat cushion and the seat back) and 
a top tether anchorage. The lower anchorages could consist of either 
UCRA-type latchplates or rigid anchorages (ISO Scheme D), provided that 
connectors are provided with the Scheme D anchorages that enables a 
child seat with UCRA buckles to be used with the rigid anchorages. The 
child restraint system standard (Standard 213) would be amended, in 
effect, to require child seats to be equipped with a top tether, and 
with attachment components (e.g., buckles) that are compatible with the 
UCRA latchplates on the vehicle.
    (3) The proposed requirements would specify the construction of the 
child restraint anchorage system, the location of the anchorages, and 
the geometry of related components, such as the hardware that attaches 
to a child seat.
    (4) A new safety standard would specify performance and location 
requirements for the tether anchorages. The standard would apply to all 
tether anchorages installed in a vehicle, regardless of whether the 
anchorage is required by a safety standard or voluntarily installed by 
the manufacturer. The agency tentatively believes that all anchorages 
should be subject to the proposed performance and location requirements 
to ensure that any anchorage used in the vehicle performs properly.
    (5) To prevent the anchorages from failing in a crash, the vehicle 
anchorages, including structural components of the assembly, would have 
to withstand specified loads in a static pull test.
    (6) Child restraint systems would be dynamically tested under 
Standard 213 when attached to the vehicle system. The standard seat 
assembly specified in the standard to test add-on child seats would be 
revised to incorporate the upper and lower anchorages of a child 
restraint anchorage system. It would have both UCRA anchorages (Scheme 
C) and rigid anchors (Scheme D). A head excursion limit of 813 mm (32 
inches) would have to be met without attaching the top tether.
    (7) A child seat equipped with features enabling it to be attached 
to an anchorage system would also have to meet the present 813 mm head 
excursion requirement of Standard 213 when tested with just a lap belt. 
This is to ensure a minimum level of safety performance when the child 
seat is used in a vehicle that does not have an anchorage system.
    (8) In addition, each child restraint would have to meet a 720 mm 
(28 inches) head excursion requirement when tested according to the 
manufacturer's instructions. A tether provided with the child restraint 
may be attached in this test.
    (9) Instructions for using the anchorage system would have to be 
provided with each child restraint and in the vehicle owner's manual.
    As discussed above, this proposal is based on the premise that a 
child restraint anchorage system would make child seats compatible with 
motor vehicles, and thus increase the safety value of restraints. The 
approach taken by this proposal would be to rectify the vehicle-to-
child restraint incompatibility problem along two lines: vehicles would 
be required to have a child restraint anchorage system with components 
``ready'' to attach a child seat, and child restraints would be 
required to have components ``ready'' to attach to the vehicle system. 
By having a dedicated anchorage system for child restraint systems, 
manufacturers can optimize the designs of their vehicle belt and child 
restraint systems to provide higher safety protection to both adults 
and children.
    A potential but seemingly necessary limitation in the proposed 
compliance tests is that the vehicle system is statically tested by 
devices that replicate the loads imposed by a child seat, and a child 
restraint is dynamically tested on a seat assembly simulating a vehicle 
seat. That is, an actual vehicle anchorage system would not be tested 
with an actual child restraint, and vice versa. This is to avoid 
possibly complicating enforcement efforts if an apparent failure arises 
in a compliance test. If vehicles were tested with actual child seats, 
and vice versa, and if a vehicle anchorage system, for example, were 
found to fail the proposed requirements, an issue could arise as to 
whether the failure was with the vehicle system, or with the child seat 
attached to the vehicle system. To avoid this complication, the 
compliance tests must be as controlled as possible to remove unknown 
influences on the performance of regulated parts.
    While the actual vehicle-to-child seat attachment would not be 
tested, NHTSA believes that the performance obtained in the compliance 
test will reflect the real-world performance of the anchorage system 
and the child restraint. This is because the geometry of the belts and 
latchplates primarily responsible for the vehicle-to-child seat 
interface would be precisely specified by this proposal. These 
components would have to be provided on vehicles and child seats 
precisely as specified in the standards. In turn, these components, in 
the same geometry as that specified in the standards, would be used in 
the compliance tests. Thus, the vehicle-to-child seat interface should 
be adequately tested.

b. Applicability

    The requirement for a child restraint anchorage system would apply 
to passenger cars and trucks and multipurpose passenger vehicles (MPVs) 
under 10,000 pounds (lb) gross vehicle weight rating (GVWR) (hereafter 
referred to as ``LTVs''), except as noted below.
    Petitioners AAMA et al. suggested, with respect to trucks and MPVs, 
that the requirement be limited to those with a GVWR of 8,500 lb or 
less and an unloaded vehicle weight of 5,500 lb or less. AAMA stated:

    The GVWR range suggested was incorporated using the identical 
GVWR range currently required to meet the dynamic performance 
requirements of FMVSS 208 for occupant protection. The relatively 
small number of vehicles larger than those within this range, the 
physical dynamics of these size vehicles and the unexpected use of 
CRSs [child restraint systems] in them, support maintaining this 
GVWR range for this proposal.

    NHTSA agrees that vehicles with GVWRs of more than 10,000 lb are 
much less frequently used to carry young children (as compared to 
vehicles with GVWRs of less than 10,000 lb) and thus should be excluded 
from a requirement to provide a child restraint anchorage system. 
However, child restraint systems could be used in vehicles with a GVWR 
between 8,500 and 10,000 lb, such as in vehicles used for 
transportation to child care programs. In the interest of best ensuring 
that a child restraint anchorage

[[Page 7871]]

system would be available when needed and to minimize incompatibility 
problems between child restraints and vehicle seats to the extent 
possible, NHTSA proposes to apply this rule to trucks, buses and 
multipurpose passenger vehicles with a GVWR of 10,000 lb or less. 
Comments are requested on this issue.
    AAMA et al. suggested excluding walk-in van-type vehicles and 
vehicles manufactured to be sold exclusively to the U.S. Postal 
Service. The agency agrees that these vehicles are unlikely to be used 
for transporting children in child safety seats. NHTSA made the 
determination in the rulemaking adopting the lockability requirement, 
supra, that these vehicles are not likely to be used to carry children 
in child seats. Accordingly, NHTSA proposes to exclude these vehicles 
from today's proposed vehicle standard.
    The AAMA petitioners suggested that the standard should not apply 
to a vehicle that ``the manufacturer designates as not intended for CRS 
use.'' The petitioner further suggested that ``[v]ehicles not intended 
for CRS use shall include this information in the vehicle's owner's 
manual'' and on a label in the vehicle. The agency has tentatively 
decided against this approach. NHTSA does not know, and petitioners did 
not explain, why manufacturers should be permitted to exclude a vehicle 
from the proposed requirements, given that such a provision could 
substantially reduce the number of vehicles that are equipped with an 
anchorage system. Reducing the universe of vehicles equipped with the 
anchorage system would eviscerate the ``universality'' of the system, 
which could result in many consumers not having an improved means of 
attaching a child restraint in their vehicle.

c. Seating Positions

    This proposal would require the child seat anchorage system (i.e., 
a top tether anchorage and lower anchorages) in two rear seating 
positions. NHTSA proposes requiring the system to be placed in a rear 
seating position because available data indicate that the rear seating 
positions are the safest positions in which to install a child 
restraint system. Vehicles that lack a rear seating position capable of 
fitting a rear-facing child seat would be required to provide a system 
in the front seat if the vehicle has a cutoff switch that deactivates 
the air bag installed at the right front passenger position in the 
vehicle. However, a child restraint anchorage system would also have to 
be installed in the rear seat of these vehicles, because a rear seat 
that is too small to fit a rear-facing child restraint can nonetheless 
probably fit a forward-facing seat. If the vehicle lacks a rear seat 
and does not have an air bag cutoff switch, an anchorage system would 
be disallowed in the front passenger seat. A built-in child seat may be 
substituted for one of the anchorage systems, but not both, since 
built-in seats currently cannot accommodate a rear-facing restraint.
    There was no consensus among the petitioners as to the number of 
child restraint anchorage systems that should be required and where in 
the rear they should be. Many believe that the system should be 
installed at each of the outermost designated seating positions of the 
second row (and a tether anchorage in the rear lap-belt center 
position). The Japanese vehicle manufacturers believe that only one 
rear seat position should be required to have the system. Fisher-Price, 
a child restraint manufacturer, believes that the rear center seating 
position is recognized as the safest and that the system should 
therefore be required there.
    NHTSA has tentatively determined that each vehicle with a rear seat 
should have at least two rear seating positions that can properly hold 
a child restraint system. The agency is concerned whether there is a 
need for an anchorage system at more than two seating positions. NHTSA 
requests information on this issue, such as demographic data on the 
number of children in child restraints typically transported in a 
family vehicle. It is noted that nothing in the proposed standard would 
prohibit a vehicle manufacturer from voluntarily providing child 
restraint anchorage systems in rear seats at more than the required 
seating positions, if a purchaser wants additional systems.
    This proposal does not specify that both anchorage systems would 
have to be provided at an outboard position. In some vehicles with 
large interiors, it may be possible to install one of the required 
systems in a center seating position.

d. Construction

    Requirements are proposed for the construction of the child 
restraint anchorage system. The system would consist of two child 
restraint anchorages at the vehicle seat bight and a tether anchorage.
1. Lower anchorages
    The proposed rule would permit manufacturers to conform lower 
anchorages to either option A, consisting of requirements based on the 
UCRA system (ISO Scheme C), or option B, based on the Hybrid system 
(Scheme D).

Option A (UCRA System)

    For vehicles incorporating the UCRA system, the standard would 
specify that lower anchorages are located 280 mm apart, measured to the 
centerline of each latchplate when fully extended in a plane parallel 
to the vehicle's longitudinal axis. When fully extended, the tip of 
each latchplate must not extend more than 50 mm forward of the seat 
bight. The 50 mm value was suggested to ensure accessibility of the 
lower anchorages. The petitioners and the ISO ad hoc group specified 
this figure in a November 15, 1996 draft ISO/WD13216-1i report. 7 
NHTSA tentatively believes the value is reasonable to ensure that the 
lower latchplates are not so rearward that they may be buried in the 
seat bight, yet are not so forward that excessive forward movement of a 
child seat could result.
---------------------------------------------------------------------------

    \7\ This figure is consistent with the ISO/WD 13216-1i report 
that are in the December 13, 1996 submittal to Docket No. 96-095, 
Notice 1.
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    The standard would also specify the geometry of related components, 
such as webbing and latchplates (tongues) of the lower anchorage 
points. NHTSA is proposing the latchplate geometry that was suggested 
in the petition by AAMA et al. The agency is proposing to specify the 
geometry of these components as necessary to ensure the universality of 
the anchorage system. 8 It negates the likelihood that a used 
child restraint with particular attachment components would be ``handed 
down'' or sold to a person owning a vehicle with an incompatible 
anchorage system. Further, since a simple, effective way of testing 
anchorage systems with varying components has not been devised, 
specifying the geometry is the best means of ensuring that anchorage 
systems will securely attach a child restraint, and provide an adequate 
level of child protection.
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    \8\ While the geometry of the vehicle latchplates would be 
mandated, child restraint systems would not have designs specified, 
other than that to have ``components permanently attached to the 
system that securely fasten to the [vehicle's] latchplates'' 
(proposed S5.9(a)). However, the agency anticipates the use of UCRA 
buckles.
---------------------------------------------------------------------------

    The lower anchorages would be equipped with specialized latchplates 
that would attach to buckles on a child seat. The geometry of the 
components is such that the webbing, buckles and latchplates are 
similar in design to components found on current adult occupant belt 
systems. This is to ensure that the components and their operation are 
familiar to persons installing a child seat. The geometry of the 
components is such that they are smaller in size than

[[Page 7872]]

like components on the adult occupant belt systems. This is to reduce 
the likelihood that the person installing a child restraint might 
confuse the belts and buckles of the child seat anchorage system with 
the adult occupant belt systems.
    Several participants at the October 1996 workshop expressed 
concerns or suggestions about aspects of the UCRA's belt systems. Klaus 
Werkmeister expressed concern that the UCRA system's lower anchorages 
could be lost in the seat bight of a foldover seat after the seat is 
flattened to make room for cargo and then reinstalled as a seat. On the 
other hand, John Gane said that the ICBC clinic had folding rear seats 
and that these didn't interfere with either the hard or soft anchor 
systems. Transcript, October 17, 1996, page 228-230. Comments are 
requested on this issue.
    Mr. Gane also suggested that the ICBC clinic indicated that the 
side straps for the UCRA should be distinguished from the straps 
comprising the harness for the child. He said that when the straps were 
not distinguished, ``we had a huge failure rate of people to understand 
how the seat was intended to work.'' Id., p. 220. (Some clinic 
participants attached the vehicle anchor belt to the child restraint's 
internal harness.) ICBC later modified the UCRA child restraint to 
color code the belts. Comments are requested on whether the straps of 
the UCRA should be distinguished, and if so, what measures should be 
required to distinguish them (e.g., color coding and/or labeling).
    Howard Willson stated that the webbing-supported anchorages of the 
UCRA should be required to have a specific stiffness so that users can 
use one hand to attach the child seat connector to the anchorage. The 
AAMA et al. petitioners also suggested that the latchplates should not 
displace rearward more than 25 mm under a 50 N rearward load. Comments 
are requested on the need for such a requirement, the level at which a 
requirement should be set, the means of testing a requirement, and 
limiting side-to-side deflection of the latchplates which may degrade 
the ability to attach the child seat with just one hand. Comments are 
also requested on any other performance that should be required of the 
UCRA system to ensure that it will be effective.

Option B (Scheme D)

    For vehicles incorporating the ISO Scheme D system, the standard 
would specify anchorage dimensional and marking requirements developed 
in draft by the ISO in ``ISO/WD 13216-1i Road Vehicles-Child Restraint 
Systems-Standardized Universal Attachment to Vehicle (ISOFIX)--Part 1: 
Dimensions and General Requirements,'' (November 15, 1996). The rule 
would require the lower anchorages to be 6 mm diameter transverse 
horizontal round bars with a minimum effective length of 25 mm. The 
spacing between the bars would be 280 mm apart, center-to-center. This 
value is harmonized with ISO to be agreeable with manufacturers of 
European, Japanese and U.S. motor vehicles. 9 Other specifications 
for the location of the lower anchorage bars would also be set forth in 
the standard. The anchorage location zone would be determined using a 
child restraint apparatus (see Figures 1, 2 and 3 of the proposed 
standard).
---------------------------------------------------------------------------

    \9\ This figure is consistent with the ISO/WD 13216-1i report 
that are in the December 13, 1996 submittal to Docket No. 96-095, 
Notice 1.
---------------------------------------------------------------------------

    Vehicle manufacturers incorporating the Scheme D system would also 
be required to provide connectors that would enable the system to be 
used with a UCRA-type child seat. The connector would have a component 
on one end that latches onto the 6 mm bar, and a UCRA latchplate on the 
other for attaching a UCRA child seat to the anchorage system. Comments 
are requested on the degree to which the geometry of the connector 
should be specified. A connector would have to be provided for each 
Scheme D lower anchorage point. NHTSA believes that a connector should 
be provided to ensure that parents having a UCRA-type child restraint 
can use the restraint in any vehicle. This aspect of the proposal was 
not included in the petition from BMW et al. Those petitioners 
suggested that a connector from a child restraint to the vehicle 
anchorages should be provided on the child restraint, by the child 
restraint manufacturer. Comments are requested on this issue.
2. Upper Anchorage
    The tether anchorage would be harmonized with Canadian and 
Australian requirements. Canada is preparing to require vehicles to 
have a factory-installed, user-ready tether anchorage. While AAMA et 
al. originally petitioned to require a specialized buckle that would be 
compatible with a latchplate on a child seat tether, petitioners have 
indicated a desire to harmonize with Canada and Australia. Thus, a 
simple anchor (such as a ring) on the vehicle would be sufficient, 
although a more sophisticated anchor could be provided if it is 
compatible with the tether hook that today's NPRM proposes to require 
on child restraints.

e. Performance

    The main performance requirement for the anchorage system would 
specify strength criteria for the lower and upper anchorages and 
related hardware. In addition, the standard would require the system to 
meet Standard 209's belt and buckle requirements, such as those 
relating to abrasion, resistance to light, corrosion resistance and 
temperature resistance. Comments are requested on whether Standard 
213's buckle release requirements (S5.4.3.5) should also be met. Among 
other things, those requirements specify that a buckle must not release 
when subjected to a force of less than 40 N, and shall release when a 
force of not more than 62 N is applied.
    The proposed strength criteria are to prevent the anchorages from 
failing in a crash. The anchorages, including structural components of 
the assembly, would have to withstand specified loads in a static pull 
test.
    The performance criteria for the lower anchorages would require 
that, in a static test of the anchorages: (a) no portion of the 
latchplate for each anchorage shall move more than 125 mm forward of 
the seat bight when subjected to a forward force of 5,300 N and, (b) 
there shall be no complete separation of any anchorage component of the 
assembly (including webbing, straps, latchplates, adjustment and 
anchorage hardware and retractors).
    The static pull test would specify that each lower anchorage is 
tested to withstand the application of a 5,300 N forward load. In the 
test, a force of 5,300 N would be applied to each anchorage in the 
forward direction parallel to the vehicle's longitudinal vertical 
plane. The force would be applied by means of a belt strap that is of 
sufficient length to extend not less than 250 mm forward from the 
vertical plane intersecting the seat bight. The belt would be fitted at 
one end with hardware for applying the force, and at the other end with 
hardware for attachment to the anchorage latchplate. The 5,300 N force 
is attained within 30 seconds, with an onset force rate not exceeding 
135,000 N per second, and is maintained at the 5,300 N level for ten 
seconds. The test procedure and force level were selected to harmonize 
with the proposed Canadian regulations on the upper tether, as well as 
with the suggested force level of the UCRA petition. The same test is 
proposed for the rigid anchor system with the adapter attached to each 
anchor point.

[[Page 7873]]

    A static pull test would also be specified in a new standard 
10 for the upper tether anchorage, in accordance with Canada's 
proposed tether anchorage requirement. The force level and application 
rate would harmonize with the proposed Canadian regulations on the 
upper tether. The standard would specify that each structural component 
of the anchorage shall withstand a force of not less than 5,300 N, and 
that there shall be no complete separation or failure of any anchorage 
component. Comments are requested on whether more specificity is needed 
for these strength requirements, and on whether other performance 
requirements should be included in the standard.
---------------------------------------------------------------------------

    \10\ Assuming a final rule on this subject is issued, the 
requirements set forth in the proposed tether standard could be 
incorporated into the standard on the child restraint system 
anchorage system, rather than in a separate standard.
---------------------------------------------------------------------------

    Each tether anchorage would be tested separately. However, more 
than one tether anchorage installed on a row of seats would be tested 
simultaneously.

f. Instructions

    The standard would require that instructions about attaching a 
child restraint to the vehicle anchorage system be provided in the 
vehicle owner's manual. The instructions would have to indicate the 
seating positions equipped with a child restraint anchorage system, and 
include instructions that provide a step-by-step procedure, including 
diagrams, for properly attaching a child restraint system to a vehicle 
anchorage system equipped with UCRA-type anchorages. In addition, for a 
vehicle equipped with a rigid anchorage system, instructions would also 
have to be provided for properly attaching a child restraint to the 
rigid system.

VII. Proposal for Amendments to Child Seat Standard

a. Applicability

    Standard 213 would be amended to require all child seats, other 
than belt positioning seats, to be equipped with components that are 
compatible with the UCRA anchorages on the vehicle system. Belt-
positioning seats, which are a type of booster seat designed for older 
children, are designed to use a vehicle's lap and shoulder (Type II) 
belt system to restrain the child occupant. Because a vehicle's belt 
system is not necessarily directly routed around or through a belt-
positioning seat to secure it to a vehicle, and because upper torso 
protection is provided by the shoulder portion of the Type II belt, 
there does not appear to be any incompatibility between a vehicle seat 
or its seat belts and belt-positioning seats. Also, because a Type II 
belt system is placed around the child occupant who is seated on a 
belt-positioning seat, there would be a minimal amount of forward 
movement of the child and child seat before forward movement is 
restrained by the Type II belts.

b. Required Components

    Requirements would be established for the components of the child 
seat that attach to the vehicle system. A child restraint would be 
permitted to have components that attach to rigid or semi-rigid Scheme 
D anchorages (Hybrid system), but the restraint must nonetheless have 
the UCRA attachments permanently attached to it. This would ensure that 
persons owning any type of child seat can use the restraint in any 
vehicle (i.e., all vehicles would be able to attach a UCRA-type seat, 
either attached to a UCRA system, or by way of UCRA connectors to 
Hybrid anchorages). The agency requests comments on whether child 
restraints intended to be used with systems that have Hybrid anchorages 
should be required to provide an adapter, rather than the UCRA 
components.
    By way of reduced allowances on head excursion, each child seat 
would be required to have a tether that attaches to the vehicle. To 
minimize the chances of incompatibility between the seat and the 
vehicle, the standard would specify the exact geometry of the tether 
hook.
    The regulatory text for this proposal does not include a provision 
that the child seat components attaching to the lower anchorages of the 
vehicle system have retractors to take up excessive slack in the belts. 
NHTSA requests comments on whether a retractor is needed or is manual 
adjustment enough to ensure that the child seat will be snug against 
the vehicle seat back. Excessive slack in the connecting belts could 
result in excessive head and knee excursions for the child occupant, 
and a greater likelihood of head impact.
    In the October 1996 workshop, Kazuhiko Miyadara, Jocelyn Pedder of 
Transport Canada, and others indicated that a soft anchor system should 
have a means of taking up slack in the belts. Comments are requested on 
what type of retractor, if any, should be specified for the UCRA.

c. Dynamic Performance

    The dynamic test specified in Standard 213 would be used to 
evaluate the performance of the child seat when attached to the 
universal vehicle anchorage system. The standard seat assembly 
specified in the standard to test add-on child seats would be revised 
to incorporate a child restraint anchorage system meeting the proposed 
specifications. A child restraint would be attached to the system using 
the appropriate buckles and other components of the child restraint. 
Injury criteria and other performance requirements specified in 
Standard 213 would have to be met when the child seat is attached to 
the anchorage system.
    Forward-facing restraints would be required to meet a head 
excursion limit of 720 mm (28.35 inches) when tested in accordance with 
its manufacturer's instructions. To meet this requirement, most 
manufacturers would likely have to provide a top tether, which would be 
attached in the test for this new requirement. Restraints would also be 
required to meet a head excursion limit of 813 mm (32 inches) when the 
tether is not attached, to ensure that a minimum level of safety is 
provided in a misuse situation. Each child seat would also have to meet 
the 720 mm (tethered) and 813 mm (untethered) head excursion limits 
when attached by a lap belt. This test would be to ensure a minimum 
level of safety performance when the child seat is used in a vehicle 
that does not have a UCRA or rigid anchor system.
    NHTSA believes that Standard 209's belt and buckle requirements 
relating to abrasion, resistance to light, corrosion resistance and 
temperature resistance, should apply to the webbing and hardware 
installed on a child seat to connect to a vehicle system as required by 
the existing provisions of S5.4 of Standard 213. The agency tentatively 
concludes that these belt and buckle requirements of Standard 209 
should apply to ensure the safe performance of the belts and associated 
hardware.

d. Instructions and Labeling

    Standard 213 would be amended to require that instructions about 
attaching a child restraint to the vehicle anchorage system be provided 
in the printed instructions accompanying each restraint. The 
instructions would have to provide a step-by-step procedure, including 
diagrams, for properly attaching a child restraint system to a vehicle 
anchorage system equipped with UCRA-type anchorages, and if the child 
restraint is intended for a vehicle equipped with a rigid or Hybrid 
anchorage system, instructions for properly attaching to such a system. 
NHTSA also proposes amending Standard 213's labeling requirements, to 
either add a new provision or amend an existing one such as S5.5.2(g), 
to instruct owners to secure the child restraint system with either a 
vehicle

[[Page 7874]]

belt or components attaching to a vehicle's child restraint anchorage 
system.
    S5.5.2(j) of Standard 213 would already require a label instructing 
owners to secure the top tether strap of the child restraint. That 
section states that in the case of each child restraint system equipped 
with an anchorage strap, the following must be permanently labeled:

SECURE THE TOP ANCHORAGE STRAP PROVIDED WITH THIS CHILD RESTRAINT AS 
SPECIFIED IN THE MANUFACTURER'S INSTRUCTIONS.

Comments are requested on what changes, if any, should be made to this 
labeling requirement to increase the likelihood that parents will 
attach the top tether strap.

VIII. Proposed Effective Date

    In their petition, AAMA et al recommended a schedule for phasing in 
the suggested requirements, should those requirements be adopted. The 
petitioners requested different schedules for vehicle manufacturers, 
child restraint manufacturers, and final-stage vehicle manufacturers 
and alterers. The latter group of manufacturers are typically small 
businesses. (See table 2, below.) The schedules suggested by AAMA et 
al. are based on the assumptions that (a) the attaching system 
envisioned by the petitioners is adopted, and (b) a final rule is 
issued by January 1, 1997.
    The petitioners suggest that vehicle manufacturers be permitted two 
alternatives in phasing in complying vehicles, beginning September 1, 
1998. Under the first alternative, 10 percent of the vehicles 
manufactured in the first model year after September 1, 1998, would be 
required to have the child restraint anchorage system (manufactured on 
or after September 1, 1998, through August 31, 1999), 30 percent of the 
vehicles manufactured in the second model year (ending August 31, 
2000), 50 percent in the third model year (ending August 31, 2001), and 
100 percent in the fourth year (ending August 31, 2002). Under the 
second alternative, no vehicle need comply with the proposed standard 
before September 1, 2000, but 75 percent of a manufacturer's vehicles 
produced on or after September 1, 2000 through August 31, 2001 (model 
year 2001) would have to comply with the requirements, and 100 percent 
of its vehicles manufactured on or after September 1, 2001 would have 
to comply.
    The requested schedule for child seat manufacturers also includes 
two alternatives for phasing in complying child seats, beginning 
September 1, 1998. The petition refers to child restraints manufactured 
in a particular ``model year,'' which apparently assumes the September 
1 to August 31 cycle traditionally used to designate vehicle model 
years. Under the first alternative, 5 percent of the child seats 
manufactured in the first ``model year'' after September 1, 1998 would 
be required to have the components enabling the child restraint to 
attach to the universal vehicle system (model year ending August 31, 
1999), 15 percent of the child restraints manufactured in the second 
model year (ending August 31, 2000), 25 percent in the third model year 
(ending August 31, 2001), and 100 percent in the fourth year (ending 
August 31, 2002). Under the second alternative, no child restraint need 
comply with the proposed amendments to Standard 213 before September 1, 
2000, but 50 percent of a manufacturer's restraints produced on or 
after September 1, 2000 through August 31, 2001 (model year 2001) would 
have to comply with the requirements, and 100 percent of its child 
seats manufactured on or after September 1, 2001 would have to comply.
    The petitioners provided the following table showing the requested 
phase-in schedules for vehicle and child seat manufacturers:

              Petitioners Requested Phase-In Alternatives (Percent of Products Required to Comply)              
----------------------------------------------------------------------------------------------------------------
                                                  Vehicle                          Child seat                   
                                               manufacturers       Vehicle       manufacturers      Child seat  
                 Model year                    alternative #1   manufacturers    alternative #1   manufacturers 
                                                 (percent)      alternative #2     (percent)      alternative #2
----------------------------------------------------------------------------------------------------------------
1999........................................               10                0                5                0
2000........................................               30                0               15                0
2001........................................               50               75               25               50
2002........................................              100              100              100              100
----------------------------------------------------------------------------------------------------------------

    The requested schedule for final-stage manufacturers and alterers 
would provide these manufacturers the option of using the phase-in 
schedule for vehicle manufacturers, described above, or the alternative 
of having the requirements become mandatory on September 1, 2001 for 
100 percent of a manufacturer's vehicles, and not before.
    NHTSA has made the following tentative decisions about leadtime. 
The agency believes that the proposed requirement that vehicles provide 
a user-ready tether anchorage and that child seats provide a tether can 
be made effective at a much earlier date than a requirement for the 
lower anchorages of a child restraint anchorage system. Passenger cars, 
in particular, generally are already equipped with a tether anchor 
(Canada has required a tether anchorage in passenger cars since 1989), 
so it appears that a user-ready anchorage can be provided in the near 
future. Canada is proposing an effective date of September 1, 1999 for 
its tether hardware requirement for passenger cars. NHTSA proposes that 
its tether anchorage requirement for passenger cars be the same as the 
Canadian proposal.
    For LTVs, Canada has also proposed that its tether anchor (hole) 
requirement be effective September 1, 1999, and its tether hardware 
requirement effective a year later. In view of these dates and that 
anchorages (holes) are apparently not as currently available on LTVs as 
on passenger cars, NHTSA proposes a September 1, 2000 effective date 
for its tether hardware requirement for LTVs.
    With regard to child restraints, restraints manufactured in the 
U.S. and sold in Canada already are equipped with a tether to meet 
Canadian requirements. NHTSA believes that most U.S. manufacturers 
produce child restraints for sale in Canada. NHTSA is considering an 
effective date of September 1, 1999 for its proposal to effectively 
require tethers by way of reducing Standard 213's head excursion 
requirement.
    As to a requirement for the lower anchorages, the petitioners did 
not explain why a phase-in is needed, or why more than four years would 
be needed to implement the requirement. The agency is determined to 
remedy the

[[Page 7875]]

problem of incompatibility of child restraints and motor vehicles as 
promptly as possible and requests comments on the feasibility of having 
full implementation (100 percent of affected vehicles) in a shorter 
period, e.g., two years after the publication of a final rule. GM 
indicated in the UCRA petition that if allowed, it would begin 
installing the UCRA system on vehicles before completion of this 
rulemaking on UCRAs. (NHTSA replied in an August 27, 1996 letter that 
manufacturers are permitted to voluntarily install the system before 
completion of a final rule.) Given that the UCRA technology is 
developed and available, and capable of being installed in today's 
vehicles, the agency believes the system could be implemented within 
two years. The same issue arises with regard to the effective date for 
requiring child restraints to be equipped with buckles and other 
components compatible with the UCRA system. Comments are requested on 
why a phase-in is needed, and on whether a shorter compliance date is 
possible.11
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    \11\  A phase-in of an amendment to an equipment standard is 
uncommon. It should be noted that to implement a phase-in 
requirement, the agency would require manufacturers to provide 
information on the total annual sales of their seats, so that the 
agency can determine whether the requisite number of seats complied 
with the new requirements.
---------------------------------------------------------------------------

    NHTSA recognizes that the rigid attachment system may need longer 
time to implement, especially on vehicles that may need to redesign 
their vehicle seats and/or floor pans. This was acknowledged by the 
international safety community in the December 6, 1996 ISO resolution 
that the rigid system is a hardware alternative that needs some time 
for development, as compared to the flexible hardware option. (See 
section IV.a., supra.) The agency's proposal would allow the long term 
rigid anchors solution to coexist with the UCRA approach that is 
available today. Even though the proposed lead time of 24 months may 
not be sufficient for the rigid anchorage hardware technology, the 
proposed rule provides vehicle manufacturers with the option of 
implementing the rigid system (with connectors) once it is developed, 
while providing a UCRA-type system in the short term.

IX. Rulemaking Analyses and Notices

a. Executive Order 12866 (Federal Regulation) and DOT Regulatory 
Policies and Procedures

    NHTSA has examined the impact of this rulemaking action and 
determined that it is economically significant within the meaning of 
Executive Order 12866 and significant within the meaning of the 
Department of Transportation's regulatory policies and procedures. 
NHTSA has prepared a Preliminary Economic Assessment (PEA) for this 
notice which discusses issues relating to the potential costs, benefits 
and other impacts of this regulatory action.
    A copy of this analysis has been placed in the docket for this 
rulemaking action. Interested persons may obtain copies of this 
document by writing to the docket section at the address provided at 
the beginning of this notice.
    To briefly summarize the analysis, NHTSA estimates that the cost of 
a rule requiring the UCRA system would be approximately $160 million. 
The cost of the rule related to the vehicle would range, per vehicle, 
from $3.88 (one UCRA in front seat only) to $7.76 (for one UCRA in 
front seat and one in back seat or two UCRAs in rear seats). NHTSA 
estimates that 15 million vehicles would be affected: 9 million 
passenger cars and light trucks with ``adequate'' rear seats, 3 million 
vehicles with no rear seat, and 3 million vehicles that can only 
accommodate a forward-facing child seat in the rear seat (not a rear-
facing infant seat). The cost of the rule for vehicles is estimated to 
be about $105 million. The cost of the UCRA attachments on the child 
seat is estimated to be about $55 million (3.9 million child restraints 
(excluding belt-positioning boosters) at $14 per seat).
    The benefits of the rule are estimated to be 24 to 32 lives saved 
per year, and 2,187 to 3,615 injuries prevented.
    As discussed in the PEA for this proposal, in view of the cost of 
the UCRA attachments on a child restraint, estimated to be about $14 
per restraint, NHTSA requests information on the price elasticity of 
child restraints. NHTSA is concerned about the potential effects of 
this rule on the purchase behavior of consumers. As one participant in 
the October 1996 workshop pointed out, if consumer demand is 
sufficiently sensitive to new car seat prices, the resulting changes in 
car seat usage could partially or totally offset the benefits of the 
proposed rule. NHTSA has estimated that the proposed rule will raise 
the price of the average car seat by $14. For a $50 car seat, this 
represents a 28 percent increase in price. On the other hand, each of 
the States and the District of Columbia require the use of child 
restraints in motor vehicles. To what extent, if at all, would an 
increase in the price of a child restraint lead to a decrease in demand 
for the product, notwithstanding child restraint use laws mandated by 
each State? Also, NHTSA and child restraint manufacturers have been 
inundated with calls from parents asking for help in installing seats 
correctly. Would this interest in child safety motivate a sufficiently 
large number of people to pay $14 for changes to a child restraint that 
would make a restraint easier to install and more secure on a vehicle 
seat? NHTSA is especially interested in comments from consumers on 
these questions.
    Consumers have essentially four choices: buy a car seat despite the 
higher price, buy a used seat, seek a giveaway or loaner program, or 
forego the seat altogether. If a 28 percent price increase were to 
result in a 10 percent decrease in new sales and thus a corresponding 
decline in usage (assuming options two and three are not available), 
then the estimated benefits of the rule (24 to 32 fatalities prevented 
per year) could be offset by an estimated 24 fatalities from reductions 
in the number of seats in use. Consumers turning to the used car seat 
market would receive no benefit from the proposed rule. The offsetting 
effects would be reduced if there is a corresponding increase in 
giveaway and loaner programs, but by virtue of the price increase these 
programs would have to find new or additional funding.
    The agency does not know how many programs exist and requests 
information on this issue. A cost increase could result in fewer seats 
being purchased by the program for loan or giveaway. On the other hand, 
persons responsible for some State loaner/giveaway programs informed 
the agency that if the new seats cost more, they would be able to find 
the funding to keep up with demand. They also said that the time saved 
installing child seats in each vehicle and making adjustments would be 
worth the difference in price.
    Unfortunately, NHTSA has not located any data or estimates of the 
actual sensitivity of new child restraint sales to price changes. For 
the sake of comparison, a large proportion of consumer goods exhibit 
greater sensitivity to price than that described in the hypothetical 
example above, even in the short run. If new child restraint purchases 
in fact exhibit the same magnitude of price sensitivity as many other 
consumer goods, the proposed rule could increase rather than reduce the 
overall risks to the Nation's children.
    For these reasons, NHTSA strongly encourages data, analyses, and 
comment on this issue. The agency also requests comments on ways to 
mitigate these effects, such as ways to minimize effects on price. For 
example, the $14 cost increase includes the cost of two buckles that 
attach to latchplates of the

[[Page 7876]]

UCRA system on the vehicle. Would costs be reduced if the latchplates 
were part of the child restraint and the buckles part of the vehicle 
system? This assumes that the buckle hardware is of higher cost than 
the latchplates. Should NHTSA conclude that both (1) the combination of 
expected child restraint price changes and consumer sensitivity to 
those price changes is sufficiently large and (2) there are no cost-
effective ways to mitigate these effects such that the final rule will 
result in a net increase in child safety, NHTSA would need to 
reconsider the proposal.

b. Regulatory Flexibility Act

    The Regulatory Flexibility Act of 1980 (Public Law 96-354), as 
amended, requires agencies to evaluate the potential effects of their 
proposed and final rules on small businesses, small organizations and 
small governmental jurisdictions. Section 603 of the Act requires 
agencies to prepare and make available for public comment an initial 
regulatory flexibility analysis (IRFA) describing the impact of 
proposed rules on small entities. NHTSA has included an IRFA in the PEA 
for this proposal.
    NHTSA tentatively believes that the proposed rule could have a 
significant impact on a substantial number of small entities. The 
proposed rule would affect motor vehicle manufacturers, almost all of 
which would not qualify as small businesses, and portable child 
restraint manufacturers. NHTSA estimates there to be about 10 
manufacturers of portable child restraints, four or five of which could 
be small businesses.
    Business entities are generally defined as small businesses by 
Standard Industrial Classification (SIC) code, for the purposes of 
receiving Small Business Administration assistance. One of the criteria 
for determining size, as stated in 13 CFR 121.601, is the number of 
employees in the firm. There is no separate SIC code for child 
restraints, or even a category that they fit into well. However, there 
are categories that could be appropriate. To qualify as a small 
business in the Motor Vehicle Parts and Accessories category (SIC 
3714), the firm must have fewer than 750 employees. The agency has 
considered the small business impacts of this proposed rule based on 
this criterion. On the other hand, to qualify as a small business in 
the category including manufacturers of baby furniture, the firm must 
have fewer than 500 employees. Comments are requested on which Standard 
Industrial Classification code would best represent child restraint 
manufacturers.
    The IRFA discusses the possible impacts on small entities and 
requests information that would assist NHTSA in further analyzing those 
impacts. As discussed in the IRFA, the incremental cost increase of $14 
to the current price of a child restraint would significantly raise the 
price of child restraints, which could have a significant economic 
impact on a substantial number of small businesses. NHTSA does not know 
the elasticity of demand for child restraints. While child restraint 
use is mandated by each State, there is significant nonuse of 
restraints. An increase in the price of a child restraint could lead to 
a decrease in demand for the product, notwithstanding the restraint use 
laws.
    According to information from Cosco (see summary, above, of NHTSA's 
October 1996 public workshop), the average purchase price of a 
convertible car seat today is $63. About 25 percent of the car seats 
purchased cost $50 or less; less than five percent cost $100 or more. 
Cosco estimated that at least 10 percent of the people would not be 
able to purchase a car seat if prices increased significantly.
    Comments are requested on the effect that raising child restraint 
prices by $14 (UCRA attachments) to possibly $100 (hard anchor system) 
would have on small businesses that manufacture child restraints. Would 
an across-the-board increase in price reduce small business sales? What 
is the magnitude of the impact?
    As discussed above in section IX.a., a loaner program could have 
fewer seats available. Assuming that would be the case, NHTSA seeks 
information on the extent to which the number of seats a program makes 
available impacts on the organization itself. For example, do proceeds 
from loaner or giveaway programs (where a nominal fee might be charged) 
support the not-for-profit organization's activities?
    NHTSA tentatively believes that there are no alternatives to the 
proposal which would accomplish the stated objectives of 49 U.S.C. 
Sec. 30101 et seq. and which would minimize any significant economic 
impact of the proposed rule on small entities. As discussed above in 
section V.c., ``Discussion of Alternatives,'' NHTSA considered a number 
of other approaches to minimize or eliminate incompatibility between 
child seats and vehicle seats. SAE Recommended Practice J1819, 
``Securing Child Restraint Systems in Motor Vehicle Rear Seats,'' does 
not appear sufficient alone to solve incompatibility problems. It is a 
tool for evaluating incompatibility, not a requirement that vehicle 
seats and child restraints must be compatible. Further, it is very 
difficult for a single system to optimize the safety protection for 
adults of all ranges and child restraints of different types. The 
current ``lockability'' requirement does not appear sufficient alone in 
addressing incompatibility, because it still depends on the user 
knowing enough and making the effort to manipulate and correctly route 
the belt system. Also, the lockability requirement does not address 
incompatibility problems arising from forward-mounted seat belt 
anchors. The ``Car Seat Only (CSO)'' system suggested by Cosco probably 
would not make attaching a child seat significantly easier than it is 
today. The CSO belt would have to be correctly routed through the child 
restraint, which is a problem occurring with present seats, and appears 
hard to tighten. Also, Cosco provided no information showing that the 
CSO belt would improve the securement of a child restraint on contoured 
(especially humped) seats. Another concern relates to the potential for 
inadvertent use by an adult occupant.
    Comments are requested on possible alternatives to the proposal 
which mitigate any significant economic impact of the proposed rule on 
small entities, while accomplishing the objectives of 49 U.S.C. 
Sec. 30101 et seq.

c. Executive Order 12612

    This proposed rule has been analyzed in accordance with the 
principles and criteria contained in Executive Order 12612, and the 
agency has determined that this proposal does not have sufficient 
federalism implications to warrant the preparation of a Federalism 
Assessment.

d. Unfunded Mandates Reform Act

    The Unfunded Mandates Reform Act of 1995 (Pub. L. 104-4) requires 
agencies to prepare a written assessment of the costs, benefits and 
other effects of proposed or final rules that include a Federal mandate 
likely to result in the expenditure by State, local or tribal 
governments, in the aggregate, or by the private sector, of more than 
$100 million annually. NHTSA has included an evaluation in the PEA for 
this proposal. The costs and benefits of the proposal are discussed 
above and throughout the PEA. (As explained above, the cost would be 
approximately $105 million for vehicles, and $55 million for child 
restraints. The benefits would be saving approximately 24 to 32 
children's lives per year, and preventing 2,187 to 3,615 injuries. An 
independent means of attaching child restraints would also enable 
vehicle manufacturers to optimize the design of vehicle belt systems 
for adult occupants.)

[[Page 7877]]

    Participants in a NHTSA public meeting held in March 1995 at the 
Lifesavers National Conference on Highway Safety Priorities, who 
typically work in State highway traffic safety agencies, community 
traffic safety programs and State or local law enforcement agencies, 
expressed strong support for a requirement for a universal child 
restraint anchorage system, such as that proposed in this NPRM. Support 
for a universal child restraint anchorage system, such as that proposed 
in the NPRM, was also expressed at NHTSA's October 1996 public workshop 
on various types of anchorage systems. As discussed above in sections 
V.c. and IX.b., and in the PEA, the agency does not believe that there 
are feasible alternatives to the proposal, including SAE Recommended 
Practice J1819, the lockability requirement or Cosco's CSO system.

e. National Environmental Policy Act

    NHTSA has analyzed this rulemaking action for the purposes of the 
National Environmental Policy Act. The agency has determined that 
implementation of this action would not have any significant impact on 
the quality of the human environment.

f. Executive Order 12778 (Civil Justice Reform)

    This proposed rule does not have any retroactive effect. Under 
section 49 U.S.C. 30103, whenever a Federal motor vehicle safety 
standard is in effect, a state may not adopt or maintain a safety 
standard applicable to the same aspect of performance which is not 
identical to the Federal standard, except to the extent that the state 
requirement imposes a higher level of performance and applies only to 
vehicles procured for the State's use. 49 U.S.C. 30161 sets forth a 
procedure for judicial review of final rules establishing, amending or 
revoking Federal motor vehicle safety standards. That section does not 
require submission of a petition for reconsideration or other 
administrative proceedings before parties may file suit in court.

X. Comments on the Proposal

    Interested persons are invited to submit comments on the proposal. 
It is requested, but not required, that 10 copies be submitted.
    All comments must not exceed 15 pages in length. (49 CFR 553.21). 
Necessary attachments may be appended to these submissions without 
regard to the 15-page limit. This limitation is intended to encourage 
commenters to detail their primary arguments in a concise fashion.
    If a commenter wishes to submit certain information under a claim 
of confidentiality, three copies of the complete submission, including 
purportedly confidential business information, should be submitted to 
the Chief Counsel, NHTSA, at the street address given above, and seven 
copies from which the purportedly confidential information has been 
deleted should be submitted to the Docket Section. A request for 
confidentiality should be accompanied by a cover letter setting forth 
the information specified in the agency's confidential business 
information regulation. 49 CFR Part 512.
    All comments received before the close of business on the comment 
closing date indicated above for the proposal will be considered, and 
will be available for examination in the docket at the above address 
both before and after that date. To the extent possible, comments filed 
after the closing date will also be considered. Comments received too 
late for consideration in regard to the final rule will be considered 
as suggestions for further rulemaking action. Comments on the proposal 
will be available for inspection in the docket. The NHTSA will continue 
to file relevant information as it becomes available in the docket 
after the closing date, and it is recommended that interested persons 
continue to examine the docket for new material.
    Those persons desiring to be notified upon receipt of their 
comments in the rules docket should enclose a self-addressed, stamped 
postcard in the envelope with their comments. Upon receiving the 
comments, the docket supervisor will return the postcard by mail.

List of Subjects 49 CFR Part 571

    Imports, Motor vehicle safety, Motor vehicles.

PART 571--[AMENDED]

    In consideration of the foregoing, NHTSA proposes to amend 49 CFR 
Part 571 as set forth below.
    1. The authority citation for Part 571 would continue to read as 
follows:

    Authority: 49 U.S.C. 322, 30111, 30115, 30117 and 30166; 
delegation of authority at 49 CFR 1.50.

    2. Section 571.210a would be added to read as follows:


Sec. 571.210a  Standard No. 210a; Child restraint anchorage system.

    S1. Purpose and scope. This standard establishes requirements for a 
system for anchoring child restraint systems to increase the likelihood 
that child restraints are properly secured in motor vehicles.
    S2. Application. This standard applies to passenger cars, and to 
multipurpose passenger vehicles, trucks and buses with a GVWR of 10,000 
pounds or less, except walk-in van-type vehicles and vehicles 
manufactured to be sold exclusively to the U.S. Postal Service.
    S3. Definitions.
    Child restraint anchorage means any component involved in 
transferring child restraint loads to the vehicle structure, including 
but not limited to, the attachment hardware on the vehicle structure, 
webbing and straps attached to the vehicle and hardware attached 
thereto, the seat frames, seat pedestals, and the vehicle structure 
itself.
    Child restraint anchorage system means a system that is designed 
for attaching a child restraint to a vehicle at a particular designated 
seating position and for transferring child restraint loads to the 
vehicle structure and that consists of--
    (1) Two lower child restraint anchorages at the seat bight; and
    (2) A tether anchorage for attaching a top tether strap of a child 
restraint system.
    Child restraint apparatus means the fixture depicted in Figures 1, 
2 and 3 of this standard which simulates the dimensions of a child 
restraint, and which is used to determine the space required by the 
child restraint and the location and access to the lower anchorages.
    Seat bight means the intersection of the vertical plane tangent to 
the forward most point of the seat back and the horizontal plane 
tangent to the uppermost point of the seat cushion.
    Tether anchorage is defined in 49 CFR 571.210b, ``Tether anchorages 
for child restraint systems.''
    S4. Requirements. Each motor vehicle shall meet the requirements in 
this section when, as specified, tested in accordance with S5 and this 
paragraph.
    S4.1  Type.
    (a) Except as provided in S4.1(b) through (d) of this section, each 
vehicle shall be equipped with a child restraint anchorage system for 
at least two rear designated seating positions.
    (b) A vehicle may be equipped with a built-in child restraint 
system conforming to the requirements of Standard No. 213 (49 CFR 
571.213) in lieu of one of the child restraint anchorage systems 
required by S4.1(a) of this section.
    (c) A vehicle that meets the conditions concerning rear seats in 
either S4.5.4.1(a) or S4.5.4.1(b) of Standard No. 208 (49 CFR 571.208) 
and

[[Page 7878]]

that has an air bag cutoff switch meeting the requirements of S4.5.4 of 
Standard 208 shall have a child restraint anchorage system installed 
for a designated seating position in the front seat, and for a position 
in the rear seat if the vehicle has a rear seat.
    (d) A vehicle that has no forward-facing designated seating 
positions to the rear of the front seating positions and no air bag 
cutoff switch meeting the requirements of S4.5.4 of Standard 208, shall 
not have a child restraint anchorage system installed for a designated 
seating position in the front seat.
    S4.2  Lower anchorages.
    The child restraint anchorage system shall have two lower 
anchorages and shall conform to either S4.2.1, or S4.2.2 and S4.2.3, at 
the manufacturer's option.
    S4.2.1  Flexible anchorages. 
    S4.2.1.1  Configuration and Geometry.
    A child restraint anchorage system shall incorporate two lower 
anchorages with latchplates conforming to the configuration and 
geometry specified in Figure 4 of this standard.
    S4.2.1.2  Location.
    (a) When fully extended in a plane parallel to the vehicle's 
longitudinal axis, the centerlines of the two latchplates are 280 mm 
apart.
    (b) When fully extended in a plane parallel to the vehicle's 
longitudinal axis, the tip of each latchplate must not extend more than 
50 mm forward of the seat bight.
    S4.2.1.3  Strength.
    When tested in accordance with S5 of this standard, a child 
restraint anchorage system shall meet the following requirements:
    (a) No portion of the latchplate for each lower anchorage shall 
pass through a vertical, transverse plane that is 125 mm forward of the 
seat bight; and
    (b) There shall be no complete separation of any anchorage 
component component (including webbing, straps, hooks and buckles, 
latchplates, adjustment and attachment hardware and retractors).
    S4.2.2  Rigid or semi-rigid anchorages.
    S4.2.2.1  Configuration and geometry.
    A child seat anchorage system shall incorporate two lower 
anchorages that are 6 mm diameter transverse horizontal round bars with 
a minimum length of 25 mm.
    S4.2.2.2  Location.
    (a) The transverse spacing of the bars shall be 280 mm, center-to-
center.
    (b) The lower anchorage bars are located with respect to the child 
restraint apparatus rearward extensions as shown in Figures 2 and 3 of 
this standard, with the child restraint apparatus placed on the vehicle 
seat cushion and against the vehicle seat back. Anchorage bars that are 
rigidly supported are to be 50 mm rearward of the rearmost surface of 
the fixture, while semi-rigidly supported bars may be located from 50 
mm rearward to 10 mm forward of that surface. The center of rigidly 
supported lower anchorage bars shall be at least 120 mm behind the 
vehicle seating reference point.
    (c) Rigidly supported lower anchorage bars must be in a zone from 
10 to 20 mm above the bottom surface of the child restraint apparatus, 
while semi-rigidly supported bars must be in a zone from 0 to 20 mm 
above that surface.
    S4.2.2.3  Strength.
    When tested in accordance with S5 of this standard, a child 
restraint anchorage shall meet the following requirements:
    (a) No portion of any component attaching to the lower anchorage 
bars shall move forward more than 125 mm.
    (b) There shall be no complete separation of any anchorage 
component.
    S4.2.3  Connectors.
    Each vehicle equipped with lower anchorages conforming to S4.2.2 of 
this standard shall be equipped with connectors that permit the 
attachment of a child restraint that is equipped with components which 
attach to lower anchorages conforming to S4.2.1. Each connector shall 
be equipped with a latchplate conforming to the configuration and 
geometry specified in Figure 4 of this standard. When attached to a 
lower anchorage, the tip of each latchplate must not extend more than 
50 mm forward of the seat bight when the connector is fully extended.
    S4.3  Tether anchorage.
    The child restraint anchorage system shall incorporate a tether 
anchorage conforming to 49 CFR 571.210b, ``Tether anchorages for child 
restraint systems.''
    S4.4  Webbing, buckles and belt adjustment hardware.
    S4.4.1  Webbing.
    The webbing provided with a child restraint anchorage system 
shall--
    (a) After being subjected to abrasion as specified in S5.1(d) or 
S5.3(c) of FMVSS No. 209 (49 CFR 571.209), have a breaking strength of 
not less than 75 percent of the strength of the unabraded webbing when 
tested in accordance with S5.1(b) of FMVSS 209; and
    (b) Meet the requirements of S4.2(e) through (h) of FMVSS No. 209 
(49 CFR 571.209).
    S4.4.2  Buckles and belt adjustment hardware.
    Each belt buckle and item of belt adjustment hardware used in a 
child restraint anchorage system shall conform to the requirements of 
S4.3(a) and S4.3(b) of FMVSS No. 209 (49 CFR 571.209).
    S4.5  Marking and Guidance.
    For lower anchorages conforming to S4.2.2, at least one lower 
anchorage bar is to be readily visible to the person installing a child 
restraint. The vehicle seat cushion or seat back shall include markings 
or features to assist in the correct lateral positioning of the child 
restraint system as it is moved rearward to engage the lower 
anchorages.
    S4.6  Instructions.
    The vehicle owner's manual shall:
    (a) Indicate the seating positions equipped with a child restraint 
anchorage system;
    (b) Include instructions that provide a step-by-step procedure, 
including diagrams, for properly attaching a child restraint system to 
a vehicle anchorage system equipped with lower anchorages conforming to 
the requirements of S4.2.1 (with or without use of a connector); and,
    (c) Include instructions for properly installing a child restraint 
system in a vehicle anchorage system equipped with lower anchorages 
conforming to the requirements of S4.2.2, if the vehicle is equipped 
with such anchorages.
    S5  Test procedures.
    S5.1  Lower anchorages.
    Test each lower anchorage separately, with or without connectors 
provided with the vehicle. Apply a force of 5,300 N to each anchorage 
in the forward horizontal direction parallel to the vehicle's 
longitudinal axis. Apply the force by means of a belt strap that 
extends at least 250 mm forward of the seat bight. The belt is fitted 
at one end with hardware for applying the force, and at the other end 
with hardware that attaches to an anchorage or connector. Apply force 
to the belt strap so that the 5,300 N force is attained within 30 
seconds, with an onset force rate not exceeding 135,000 N per second, 
and is maintained at the 5,300 N level for at least 10 seconds.
    S5.2  Tether anchorage.
    Tether anchorages are tested according to the procedures specified 
in 49 CFR 571.210b, ``Tether anchorages for child restraint systems.'

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Figure 1--Child Restraint Apparatus-Isometric

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Figure 2a--Child Restraint Apparatus Anchorages Front View

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Figure 2b--Child Restraint Apparatus Anchorages Side and Plan View

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    3. Section 571.210b would be added to read as follows:


Sec. 571.210b  Standard No. 210b; Tether anchorages for child restraint 
systems

    S1. Purpose and scope. This standard establishes requirements for 
the strength and location of tether anchorages to ensure proper 
anchoring of child restraint systems.
    S2. Application. This standard applies to tether anchorages 
installed in passenger cars manufactured on or after September 1, 1999, 
and in multipurpose passenger vehicles, trucks and buses manufactured 
on or after September 1, 2000.
    S3. Definitions.
    Tether anchorage means any component that transfers loads from 
tether anchorage hardware to the vehicle structure.
    Tether anchorage hardware means any component that transfers tether 
strap loads to a tether anchorage and is designed to accept a tether 
strap hook.
    Tether strap means a device that is fitted with a tether strap hook 
and secured to the rigid structure of a child restraint system and that 
transfers the load from that system to the anchorage hardware.
    Tether strap hook means a device, illustrated in Figure 11 of 
Standard No. 213 (49 CFR 571.213), used to attach a tether strap to 
tether anchorage hardware.
    S4. Requirements. Each tether anchorage shall meet the requirements 
of this section.
    S4.1  Configuration.
    S4.1.1  Except as provided by S4.1.2, each tether anchorage shall--
    (a) Be equipped with tether anchorage hardware that is easily 
accessible and that permits the attachment of a tether hook meeting the 
configuration and geometry specified in Figure 11 of Standard No. 213 
(49 CFR 571.213) of this section;
    (b) Be located in accordance with S4.2 of this section; and
    (c) Be sealed to prevent the entry of exhaust fumes.
    S4.2  Anchorage positioning requirements.
    S4.2.1  Passenger cars and multipurpose passenger vehicles. The 
vertical centerline of each tether anchorage and each tether anchorage 
hardware component shall be located within the shaded zone shown in 
Figures 2, 3, 4 and 8 of this standard, with reference to the shoulder 
reference point of a template described in section 3.1 of SAE Standard 
J826 (June 1992), where
    (a) The H-point of the template is located at the unique Design H-
point of the seat, as defined in section 2.2.11.1 of SAE Recommended 
Practice J1100 (June 1993), at the full rearward and downward position 
of the seat;
    (b) The torso line of the template is at the same angle from the 
vertical plane as the seat back with the seat adjusted to its full 
rearward and full downward position and the seat back in its most 
upright position; and,
    (c) The template is positioned in the vertical longitudinal plane 
that contains the H-point of the template.
    S4.2.2  Trucks and buses. Subject to S4.3.2.1, the vertical 
centerline of each tether anchorage and each tether anchorage hardware 
in a truck or bus shall be located within the shaded zone shown in 
Figures 5, 6, 7, and 8 of this standard, with reference to the H-point 
of a template described in section 3.1 of SAE Standard J826 (June 
1992), where
    (a) The H-point of the template is located at the unique Design H-
point of the seat, as defined in section 2.2.11.1 of SAE Recommended 
Practice J1100 (June 1993), at the full rearward and downward position 
of the seat;
    (b) The torso line of the template is at the same angle from the 
vertical plane as the seat back with the seat adjusted to its full 
rearward and full downward position and the seat back in its most 
upright position; and
    (c) The template is positioned in the vertical longitudinal plane 
that contains the H-point of the template.
    S4.3.2.1  The centerline of a tether anchorage in a truck or bus 
may be located outside the shaded zone referred to in S4.3.2 if a 
routing device that is of sufficient strength to withstand the loads 
referred to in S4.4 is installed within that shaded zone.
    S4.4  Strength.
    S4.4.1  If a tether anchorage is installed for only one designated 
seating position on a seat, the tether anchorage with the tether 
anchorage hardware installed shall, when tested in accordance with S5, 
withstand a force of 5,300 N. There shall be no complete separation or 
failure of any anchorage component.
    S4.4.2  If a tether anchorage is installed for more than one 
designated seating position on a bench seat, each tether anchorage with 
the tether anchorage hardware installed shall, when tested in 
accordance with S5, withstand the simultaneous application of a force 
of 5,300 N to each assembly of tether anchorage and tether anchorage 
hardware. There shall be no complete separation or failure of any 
anchorage component.
    S5  Test procedure.
    With the seat adjusted to its full rearward and full downward 
position and the seat back in its most upright position, attach a belt 
strap that extends not less than 250 mm forward from the vertical plane 
intersecting the seat bight (the intersection of the surfaces of the 
seat cushion and the seat back). The strap is fitted at one end with 
hardware for applying the force and at the other end with a bracket for 
attachment to the tether anchorage hardware and passes over the top of 
the vehicle seat back as shown in Figure 8 of this standard. Apply a 
force of 5,300 N to each anchorage in the forward horizontal direction 
parallel to the vehicle's longitudinal axis. The 5,300 N force is 
attained within 30 seconds, with an onset force rate not exceeding 
135,000 N per second, and is maintained at the 5,300 N level for one 
second.

Figure 1--[Reserved]

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Figure 2--Side View, Tether Anchorage Location for Passenger Cars 
and Multi-Purpose Passenger Vehicles

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Figure 3--Rear View, Tether Anchorage Location for Passenger Cars 
and Multi-Purpose Passenger Vehicles

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Figure 4--Plan View, (R-Point Level), Tether Anchorage Location for 
Passenger Cars and Multi-Purpose Passenger Vehicles

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Figure 5--Side View, Tether Anchorage Location for Trucks

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Figure 6--Rear View, Tether Anchorage Location for Trucks

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Figure 7--Plan View, (V-Point Level), Tether Anchorage Location for 
Trucks

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Figure 8--Three-Dimensional Schematic View for Tether Anchorage 
Location for Passenger Cars, Multi-Purpose Passenger Vehicles and 
Trucks

[[Page 7893]]

    4. Section 571.213 would be amended by:
    a. adding to S4, in alphabetical order, a definition of ``child 
restraint anchorage system,'' ``tether anchorage hardware,'' ``tether 
strap,'' and ``tether strap hook'';
    b. revising S5.1.3, S5.1.3.1, S5.3.1, S5.3.2 and S5.6.1;
    c. adding S5.9 and S5.10;
    d. revising S6.1.1(a)(1), S6.1.1(c) and S6.1.2(a)(1)(i);
    e. adding S6.1.2(d)(1)(iii); and
    f. revising Figure 1A and adding figures 11 and 12.
    The revised and added paragraphs would read as follows:


Sec. 571.213  Standard No. 213; Child restraint systems

* * * * *
    S4. Definitions.
* * * * *
    Child restraint anchorage system is defined in S3 of FMVSS No. 210a 
(49 CFR 571.210a).
* * * * *
    Tether anchorage hardware is defined in S3 of FMVSS No. 210b (49 
CFR 571.210b).
    Tether strap means a device that is fitted with a tether strap hook 
and secured to the rigid structure of a child restraint system and that 
transfers the load from that system to the tether anchorage hardware.
    Tether strap hook means a device, illustrated in Figure 11 of this 
standard, used to attach a tether strap to tether anchorage hardware.
* * * * *
    S5.1.3  Occupant excursion. When tested in accordance with S6.1 and 
the requirements specified in this paragraph, each child restraint 
system shall meet the applicable excursion limit requirements specified 
in S5.1.3.1 through S5.1.3.3.
    S5.1.3.1  Child restraint systems other than rear-facing ones and 
car beds. Each forward-facing child restraint system shall retain the 
test dummy's torso within the system.
    (a) In the case of an add-on child restraint system, no portion of 
the test dummy's head shall pass through a vertical, transverse plane 
that is 720 mm forward of point Z on the standard seat assembly, 
measured along the center SORL (as illustrated in figure 1B of this 
standard), and neither knee pivot point shall pass through a vertical, 
transverse plane that is 915 mm forward of point Z on the standard seat 
assembly, measured along the center SORL, when attached to the seat 
assembly as described in S6.1.2(a)(1)(i)(A)(1).
    (b) In the case of an add-on child restraint system, no portion of 
the test dummy's head shall pass through a vertical, transverse plane 
that is 813 mm forward of point Z on the standard seat assembly, 
measured along the center SORL (as illustrated in figure 1B of this 
standard), and neither knee pivot point shall pass through a vertical, 
transverse plane that is 915 mm forward of point Z on the standard seat 
assembly, measured along the center SORL, when attached to the seat 
assembly as described in S6.1.2(a)(1)(i)(A)(2) or S6.1.2(a)(1)(B).
    (c) In the case of a built-in child restraint system, neither knee 
pivot point shall, at any time during the dynamic test, pass through a 
vertical, transverse plane that is 305 mm forward of the initial pre-
test position of the respective knee pivot point, measured along a 
horizontal line that passes through the knee pivot point and is 
parallel to the vertical plane that passes through the vehicle's 
longitudinal centerline.
* * * * *
    S5.3  Installation.
     S5.3.1  Except for components designed to attach to a child 
restraint anchorage system, each add-on child restraint system shall 
have no means designed for attaching the system to a vehicle seat 
cushion or vehicle seat back and no component (except belts) that is 
designed to be inserted between the vehicle seat cushion and vehicle 
seat back.
    S5.3.2  (a) When installed on a vehicle seat, each add-on child 
restraint system, other than a belt-positioning seat, shall be capable 
of being restrained against forward movement solely by means of:
    (1) A Type I seat belt assembly (defined in Sec. 571.209) that 
meets Standard No. 208 (Sec. 571.208);
    (2) A Type I seat belt assembly plus a tether anchorage; and,
    (3) A child restraint anchorage system.
    (b) Each belt-positioning seat shall be capable of being restrained 
against forward movement by means of a Type II seat belt assembly 
(defined in Sec. 571.209) that meets Standard No. 208 (Sec. 571.208).
* * * * *
    S5.6.1  Add-on child restraint systems.
    Each add-on child restraint system shall be accompanied by printed 
installation instructions in English that provide a step-by-step 
procedure, including diagrams, for installing the system in motor 
vehicles, securing the system in the vehicles, positioning a child in 
the system, and adjusting the system to fit the child. If the child 
restraint system has components for attaching to a child restraint 
anchorage system, installation instructions shall be included that 
provide a step-by-step procedure, including diagrams, for properly 
attaching a child restraint system to a vehicle anchorage system 
equipped with lower anchorages conforming to the requirements of S4.2.1 
of Standard No. 210a (49 CFR Sec. 571.210a). In addition, if the child 
restraint is equipped with components that attach to a vehicle 
anchorage system equipped with lower anchorages conforming to the 
requirements of S4.2.2 of Standard No. 210a, instructions shall be 
provided for properly installing a child restraint to such an anchorage 
system.
* * * * *
    S5.9  Attachment to child restraint anchorage system.
    (a) Each add-on child restraint system, other than a belt-
positioning seat, shall have components permanently attached to the 
system that securely fasten to the latchplates conforming to S4.2.1 of 
Standard No. 210a (49 CFR Sec. 571.210a) and depicted in Drawing 
Package ____ (consisting of drawings and a bill of materials) with 
addendum A, revision dated January 6, 1997, (incorporated by reference; 
see Sec. 571.5).
    (b) In addition to the components required by S5.9(a), each child 
restraint system intended for use with lower anchorages conforming to 
S4.2.2 of Standard No. 210a (49 CFR Sec. 571.210a) shall have 
components of a configuration depicted in Figure 12 of this standard, 
in a location that enable the child restraint to securely fasten to the 
anchorages.
    S5.10  Each tether strap on a child restraint system must be 
equipped with a tether strap hook that conforms to the configuration 
and geometry specified in Figure 11 of this standard.
* * * * *
    S6.1.1  Test conditions.
    (a) Test devices.
    (1) The test device for add-on restraint systems is a standard seat 
assembly consisting of a simulated vehicle bench seat, with three 
seating positions, which is described in Drawing Package SAS-100-1000 
with Addendum A Revised (consisting of drawings and a bill of 
materials), dated December __, 1996 (incorporated by reference; see 
Sec. 571.5). The assembly is mounted on a dynamic test platform so that 
the center SORL of the seat is parallel to the direction of the test 
platform travel and so that movement between the base of the assembly 
and the platform is prevented.
* * * * *

[[Page 7894]]

    (c)(1) Attached to the seat belt anchorage points provided on the 
standard seat assembly (illustrated in Figures 1A and 1B of this 
standard) are Type I seat belt assemblies in the case of add-on child 
restraint systems other than belt-positioning seats, or Type II seat 
belt assemblies in the case of belt-positioning seats. These seat belt 
assemblies meet the requirements of Standard No. 209 (Sec. 571.209) and 
have webbing with a width of not more than 50 mm, and are attached to 
the anchorage points without the use of retractors or reels of any 
kind.
    (2) Attached to the standard seat assembly is a child restraint 
anchorage system conforming to Standard No. 210a (Sec. 571.210a). The 
seat assembly is equipped with lower anchorages that conform to S4.2.1 
and S4.2.2 of that standard.
* * * * * *
    S6.1.2  Dynamic test procedure.
    (a) Activate the built-in child restraint or attach the add-on 
child restraint to the seat assembly as follows:
    (1)(i) Test configuration I.
    (A) Except for a belt-positioning seat, an add-on child restraint 
system is installed at the center seating position of the standard seat 
assembly using either the standard lap belt or the child seat anchorage 
system--
    (1) In accordance with the manufacturer's instructions provided 
with the system pursuant to S5.6.1; or
    (2) In accordance with the manufacturer's instructions, except that 
the add-on restraint is secured to the standard vehicle seat using only 
the standard vehicle lap belt (except a child harness, a backless child 
restraint system with a top anchorage strap, and a restraint designed 
for use by physically handicapped children are not subject to this 
paragraph.
    (B) A belt-positioning seat is attached to either outboard seating 
position of the standard seat assembly in accordance with the 
manufacturer's instructions provided with the system pursuant to S5.6.1 
using only the standard vehicle lap and shoulder belt.
* * * * *
    (d) * * *
    (1) * * *
    (iii) When attaching a child restraint system to the child 
restraint anchorage system on the standard seat assembly, all belt 
systems used to attach the restraint to the standard seat assembly are 
tightened to a tension of not less than 53.5 N and not more than 67 N, 
as measured by a load cell used on the webbing portion of the belt.
* * * * *

BILLING CODE 4910-59-P

[[Page 7895]]

[GRAPHIC] [TIFF OMITTED] TP20FE97.025



[[Page 7896]]

[GRAPHIC] [TIFF OMITTED] TP20FE97.026



Figure 11--Tether Strap Hook

[[Page 7897]]

[GRAPHIC] [TIFF OMITTED] TP20FE97.027



Figure 12--Rigid Connector-Side View

    Issued on February 13, 1997.
L. Robert Shelton,
Associate Administrator for Safety Performance Standards.
[FR Doc. 97-4084 Filed 2-18-97; 8:45 am]
BILLING CODE 4910-59-C