Consumer Information; Rating Program for Child Restraint Systems, 65804-65833 [E7-22912]

Agencies

• National Highway Traffic Safety Administration
• DEPARTMENT OF TRANSPORTATION

[Federal Register Volume 72, Number 225 (Friday, November 23, 2007)]
[Notices]
[Pages 65804-65833]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E7-22912]


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DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

[Docket NHTSA-2006-25344]


Consumer Information; Rating Program for Child Restraint Systems

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

ACTION: Notice, request for comments.

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SUMMARY: In response to Section 14(g) of the Transportation Recall 
Enhancement, Accountability, and Documentation (TREAD) Act, the 
National Highway Traffic Safety Administration established a child 
restraint consumer information rating program. This program conducts a 
yearly assessment on the ease of using add-on child restraints and 
provides these ratings to the public. The program has been successful 
in encouraging child restraint manufacturers to improve their harness 
designs, labels, and manuals such that most now receive the top rating. 
However, some recent research, as well as a February 2007 public 
meeting held by the agency on the Lower Anchors and Tethers for 
Children (LATCH) system has indicated that some features that make 
child restraints easier to use are not being captured by the current 
program. Additionally, the agency wants to make sure that the program 
continues to provide useful information to the public. In an effort to 
further enhance the program and provide consumers with updated 
information we are proposing some new features and new rating criteria, 
and to adjust the scoring system. The agency anticipates that these 
program changes will result in more child restraints being used 
correctly by continuing to encourage manufacturers to install more 
features that help make the restraints easier to use.

DATES: You should submit your comments early enough to ensure that the 
Docket receives them not later than December 24, 2007.

ADDRESSES: Comments should refer to the docket number and be submitted 
by any of the following methods:
     Federal Rulemaking Portal: https://www.regulations.gov. 
Follow the instructions for submitting comments.
     Web Site: https://www.regulations.gov. Follow the 
instructions for submitting comments on the electronic docket site. 
Please note, if you are submitting petitions electronically as a PDF 
(Adobe) file, we ask that the documents submitted be scanned using an 
Optical Character Recognition (OCR) process, thus allowing the agency 
to search and copy certain portions of your submissions.
     Fax: 1-202-493-0402
     Mail: Docket Management; U.S. Department of 
Transportation, 1200 New Jersey Ave., SE., Room W12-140, Washington, DC 
20590.
     Hand Delivery: U.S. Department of Transportation, 1200 New 
Jersey Ave., SE., Room W12-140, Washington, DC, between 9 a.m. and 5 
p.m., Monday through Friday, except Federal holidays.

FOR FURTHER INFORMATION CONTACT: For technical issues related to the 
Ease of Use rating program, you may call Nathaniel Beuse of the Office 
of Crash Avoidance Standards, at (202) 366-4931. For legal issues, call 
Deirdre Fujita of the Office of Chief Counsel, at

[[Page 65805]]

(202) 366-2992. You may send mail to these officials at the National 
Highway Traffic Safety Administration, 1200 New Jersey Ave., SE., 
Washington, DC 20590.

SUPPLEMENTARY INFORMATION:
I. Introduction
II. The Unrestrained Child
III. Child Restraint EOU Programs Worldwide
    A. Australia
    B. Consumers Union
    C. EuroNCAP
    D. Japan NCAP
IV. Overview of the Current Ease of Use Rating Program
V. Enhancing the Ease of Use Program
    A. LATCH Misuse Survey
    B. LATCH Public Meeting
    1. Labeling and Instructions
    2. Lower Attachment Design
    3. Other Comments
    C. Comprehensive Study of the Ease of Use Program
    D. Feedback from Current Ease of Use Raters
VI. Analysis and Agency Decision on Suggested Program Changes
    A. Rating Categories and Their Associated Features
    1. Assembly
    2. Evaluation of Labels
    3. Evaluation of Instructions
    4. Securing the Child
    5. Vehicle Installation Features
    B. Rating System
    C. Other Issues
VII. Rating Vehicles Based on Child Restraint Installation Features
VIII. Conclusion, Star-System, and Effective Date
IX. Public Comment
Appendices
Appendix A: Ease of Use Rating Forms
Appendix B: Ease of Use Score Forms
Appendix C: Ease of Use Star Rating System

I. Introduction

    Through the Transportation Recall Enhancement, Accountability, and 
Documentation (TREAD) Act, Congress directed the National Highway 
Traffic Safety Administration (NHTSA) to establish a child restraint 
safety rating system that was practicable and understandable (Section 
14 (g) of the TREAD Act, November 1, 2000, Pub. L. 106-414, 114 Stat. 
1800) and that would help consumers to make informed decisions when 
purchasing child restraints. In response to the TREAD Act, the agency 
issued a final rule \1\ on November 5, 2002 establishing a program to 
rate child restraint ease of use features.
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    \1\ 67 FR 67448, Docket 2001-10053.
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    NHTSA's Ease of Use (EOU) program is modeled after a program which, 
at that time, was being used by the Insurance Corporation of British 
Columbia (ICBC) to evaluate child restraints sold in Canada. NHTSA's 
program uses similar rating categories, features, and criteria as 
ICBC's did. Shortly after NHTSA established its EOU program, ICBC chose 
to abandon their in-house program and instead began directing their 
consumers to the NHTSA ratings Web site. They continue to provide 
information specific to Canadian consumers by publishing the equivalent 
Canadian model numbers of U.S. child restraints that NHTSA rates.
    To date, NHTSA's EOU program has been very successful in 
encouraging child restraint manufacturers to improve child restraint 
harness designs, labels, and manuals such that most now receive the top 
rating. However, some recent research, as well as the public hearing 
conducted by the agency on LATCH, has indicated that some features 
intended to make child restraints easier to use are not captured by the 
current program.
    NHTSA held a public meeting on February 8, 2007 \2\ that brought 
together child restraint and vehicle manufacturers, retailers, 
technicians, researchers, and consumer groups to explore possible ways 
to improve the design and increase the use of the Lower Anchors and 
Tethers for Children (LATCH) system. At the meeting, four panels were 
held, which focused specifically on: Improving in-vehicle LATCH design, 
improving child restraint LATCH design, child side-impact safety, and 
educating the public about seat belts and LATCH. At the child restraint 
LATCH design panel session, NHTSA presented some approaches that the 
agency was considering in making improvements to its EOU program. NHTSA 
requested that all attendees and participants submit formal comments to 
the Docket \3\ highlighting concerns they may or may not have expressed 
during the session. The agency wanted to use this input to make sure 
that the program continues to provide valuable information to the 
public as well as continuing to encourage manufacturers to further 
improve their designs.
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    \2\ 72 FR 3103, January 24, 2007. Full transcript can be found 
in Docket Number NHTSA-2007-26833-23.
    \3\ See Docket Number: NHTSA-2007-26833.
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II. The Unrestrained Child

    Child restraints are the most effective vehicle safety measure 
available for children. Research on the effectiveness of child 
restraints has found them to reduce fatal injury by 71 percent for 
infants (less than 1 year old) and by 54 percent for toddlers (1-4 
years old) in passenger cars.\4\ For infants and toddlers in light 
trucks, the corresponding reductions are 58 and 59 percent, 
respectively.
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    \4\ Traffic Safety Facts 2005: Occupant Protection, DOT HS 810 
621, National Center for Statistics and Analysis, 1200 New Jersey 
Ave., SE., Washington, DC 20590.
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    The agency, along with manufacturers, local governments, and 
consumer groups, has established a consistent message for the public to 
put children in age-appropriate restraints in the rear seat of 
vehicles. This educational effort is working: Over the past decade the 
percentage of unrestrained child fatalities has decreased 
significantly. Among child fatalities for the 14 and under age group, 
46 percent were unrestrained in 2005; in 1995 this percentage was 65 
percent.\5\ In February of 2005, NHTSA conducted a National Occupant 
Protection Use Survey (NOPUS) to provide more detailed information 
about child restraint use. As a part of NOPUS, the Controlled 
Intersection Study found that 82 percent of children were properly 
restrained. Other findings were that 98 percent of children under 1 and 
93 percent of children from 1 to 3 were restrained.\6\
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    \5\ Traffic Safety Facts 1995: Children, DOT 95F2, National 
Center for Statistics and Analysis, 1200 New Jersey Ave., SE., 
Washington, DC 20590.
    \6\ Traffic Safety Facts 2005: Children, DOT HS 810 618, 
National Center for Statistics and Analysis, 1200 New Jersey Ave., 
SE., Washington, DC 20590.
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    Tragically, in 2005, there were 361 passenger vehicle occupant 
fatalities among children under 4 years of age.\7\ Restraint use was 
known for 344 of these 361 fatalities, and 110 (~30 percent) of those 
children were unrestrained. In contrast, in 2005, 420 lives are 
estimated to have been saved by child restraint use. Of these 420 lives 
saved, 382 were associated with the use of child restraints and 38 with 
the use of adult seat belts. At 100 percent child restraint use for 
children under 5, an estimated 98 additional lives, for a total of 518 
children, could have been saved in 2005.
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    \7\ Traffic Safety Facts 2005: Occupant Protection, DOT HS 810 
621, National Center for Statistics and Analysis, 1200 New Jersey 
Ave., SE., Washington, DC 20590.
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    The agency and all its safety partners must continue their efforts 
to get more children in age-appropriate restraints and to educate the 
public about their proper use and installation. Our belief is that the 
EOU rating program helps provide much needed guidance to consumers 
about certain child restraint features. We believe this guidance helps 
caregivers choose appropriate restraints for their child. The agency 
believes that an easy-to-use child restraint can result in more 
children being properly restrained.

[[Page 65806]]

III. Child Restraint EOU Programs Worldwide

A. Australia

    The New South Wales Roads and Traffic Authority joined with the 
National Roads and Motorists Association and the Royal Automobile Club 
of Victoria to establish a joint program to assess both the relative 
performance and the ease of using child restraints available in 
Australia. The resulting program is known as CREP, or the Child 
Restraints Evaluation Program. In addition to frontal and side impact 
sled testing, the program covers installation and compatibility with 
vehicles and features specific to the child restraint itself.
    The Australian program uses child restraint evaluation criteria 
very similar to the program conducted by NHTSA under its EOU program. 
The CREP criteria assess how easily the child restraints can be 
installed as well as how easily a child can be secured. The criteria 
also include an evaluation of the information included in the 
instructions, the clarity and quality of labeling and packaging, and 
compatibility by securing the restraint in a vehicle.
    The child restraints are classified into three groups: infant 
restraints, child seats, and booster seats. They are rated on a letter 
scale that ranges from the best, or ``A,'' to the worst, which is a 
``D,'' for both the dynamic rating and the EOU ratings. The scores are 
presented to consumers separately; that is, the dynamic and EOU ratings 
are not combined. The highest scoring child restraint in each of the 
three classes is highlighted on the Web site and in CREP's annual 
brochure as the ``best performer in class.''

B. Consumers Union

    Consumers Union (CU), publisher of Consumer Reports magazine, is a 
nonprofit membership organization that evaluates child restraints in 
dynamic tests, assesses their ease of use, and evaluates compatibility 
with vehicles. CU rates child restraints for EOU by evaluating 
installation features, harness features, placing the child in the 
restraint, and removing the child from the restraint. All of the items 
are evaluated on a five part scale using the following rankings: 
``Excellent,'' ``Very good,'' ``Good,'' ``Fair,'' and ``Poor.'' The 
crash protection, EOU, and installation ratings are all combined into 
an overall rating.

C. EuroNCAP

    The European New Car Assessment Program, or EuroNCAP, provides 
consumers with safety ratings for vehicles sold in Europe. The program 
is funded by European governments and private motoring clubs. Under 
EuroNCAP, vehicle manufacturers recommend child restraints suitable for 
installation in their vehicles for subsequent dynamic testing. Each 
vehicle's rear seat is fitted with two restraints: one suitable for a 
3-year-old child and another suitable for an 18-month-old infant. 
Technicians provide an evaluation of the ease of installation in the 
vehicle when setting up the full-scale crash test. They also rate the 
quality of labeling information on the child restraint. This evaluation 
is included as a small part of an overall child protection rating that 
is determined by using points and then converted to a 5-star scale. 
This overall child protection rating is related more to the vehicle 
rather than the restraints themselves. For example, each restraint's 
ease of use and fitment assessment in the vehicle can contribute only 6 
points out of 49 possible points to the child protection rating. The 
remaining points are calculated from each child restraint's dynamic 
results and specific vehicle features such as air bag warning labels.

D. Japan NCAP

    The Japanese Ministry of Land, Infrastructure and Transport, in 
cooperation with the National Organization for Automotive Safety & 
Victims' Aid, tests and evaluates the safety of automobiles as part of 
its New Car Assessment Program (JNCAP). In 2002, the JNCAP began rating 
child restraints in both dynamic testing and child restraint usability. 
The results of these tests are released in print media and on the 
Internet.
    JNCAP rates child restraints on their usability in five categories. 
These categories are very similar to NHTSA's: The instruction manual, 
product markings (labels), the ease of using the restraint's features, 
the ease of installation in the vehicle, \8\ and the ease of securing 
the child in the restraint are evaluated. Each category contains a 
number of features for evaluation; these are very similar to the 
structure used in NHTSA's EOU program.
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    \8\ It should be noted that vehicles and child restraints in 
Japan are not required to come LATCH-equipped, so their installation 
features are based on the ease of routing and using vehicle belts.
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    The specialists in this program rate each feature on a scale of 1 
to 5, with ``3'' representing an ``average'' feature. The ratings given 
by all five specialists are averaged, and then all the features within 
each category are averaged as well. No overall rating is provided.

IV. Overview of the Current Ease of Use Rating Program

    NHTSA rates each child restraint under every mode of its correct 
use. This requires the agency to use three separate forms: rear-facing 
(RF), forward-facing (FF), and booster. Each of these forms is tailored 
to the mode of use and organized according to five categories:\9\ 
Assembly, Evaluation of Labels, Evaluation of Instructions, Securing 
the Child, and Installing in Vehicle. In addition to an overall letter 
grade for the child restraint, a letter grade is also assigned to each 
of these five categories and displayed on NHTSA's Web site. The Federal 
Register notice of November 5, 2002 included, as its Appendix C,\10\ 
the EOU rating forms used by the agency to evaluate each child 
restraint in every applicable mode of use. For example, a convertible 
restraint that can accommodate a child in both the rear-facing (RF) and 
forward-facing (FF) modes would be evaluated using both the rear- and 
forward-facing forms; it would also be awarded two separate EOU 
ratings.
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    \9\ ICBC's ratings system was based on seven categories; NHTSA 
chose to adopt the same criteria for its ratings program but 
organized them into five categories.
    \10\ 67 FR 214, page 67472. See Docket NHTSA-2001-10053-66.
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    Each form contains features for rating the child restraint that are 
organized into five categories. Each feature is assessed on up to three 
criteria using an ``A'' (``good,'' worth 3 points), ``B'' 
(``acceptable,'' worth 2 points), or ``C'' (``poor,'' worth 1 point). 
In some cases, a feature may only be assessed on two criteria, ``A'' 
(``good,'' worth 3 points), or ``C'' (``poor,'' worth 1 point). If a 
feature does not pertain to the restraint in question, it is assigned a 
``not applicable,'' or ``n/a,'' which essentially eliminates it from 
the overall calculation so that it does not affect the restraint 
negatively or positively. An example of a situation where this is used 
would be for the overhead shield criteria. These devices are not very 
common, but if a child restraint manufacturer chooses to employ one the 
agency feels it is important to rate how easy it is to adjust. On the 
other hand, restraints that do not have this feature should not subject 
to a penalty for their absence.
    Each feature also has an associated weighting value that 
corresponds to its potential risk of injury if misused. A feature with 
the highest weighting factor has a numerical value of ``3'', which

[[Page 65807]]

means that its gross misuse could lead to severe injury. Items whose 
gross misuse was determined less likely to lead to severe injury are 
assigned a numerical value of ``2.'' Similarly, the features whose 
misuse was least likely to cause severe injury are assigned a weighting 
factor of 1. It should be noted that in the current rating system NHTSA 
does not have any features weighted ``1.''
    NHTSA displays both the overall letter rating and letter ratings 
for each of the five categories. NHTSA calculates the category letter 
ratings by taking the numerical value of the feature and multiplying it 
by the fixed weighting value for that feature. Then, the sum of these 
weighted feature ratings is divided by the sum of the applicable fixed 
weighting factors. The numerical category weighted average that results 
is assigned a letter grade according to the following scale:
     ``A'' = Category Weighted Average >= 2.40.
     ``B'' = 1.70 <= Category Weighted Average < 2.40.
     ``C'' = Category Weighted Average < 1.70.
    Point ranges for assigning both the category and overall ``A,'' 
``B,'' and ``C'' ratings were determined by dividing the range of 
possible overall scores into three sections. The minimum category or 
overall numerical score for any child restraint is 1.00; this is if all 
features were rated ``C''. The maximum category or overall numerical 
score for any child restraint is a 3.00; this is if all features are 
rated an ``A''.
    To calculate the overall rating for the child restraint, the sum of 
the weighted feature ratings from all five categories is divided by the 
sum of all the possible weighted scores for that category The score 
ranges for assigning a letter score to the overall rating are similar 
to those for the individual categories:
     ``A'' = Overall Weighted Average >= 2.40.
     ``B'' = 1.70 <= Overall Weighted Average < 2.40.
     ``C'' = Overall Weighted Average < 1.70.
    Consumers are presented EOU information on the NHTSA Web site in 
letter format only. However, the agency's practice has been to display 
the letter scores for each of the categories alongside the overall 
letter score.

V. Enhancing the Ease of Use Program

    As previously stated, manufacturers have responded positively to 
the EOU program; currently, an overwhelming majority of child 
restraints are rated an ``A''. For model year (MY) 2007, approximately 
81% of the child restraints received an overall ``A'' rating.\11\ This 
can be compared to approximately 57% when the program first began. This 
tremendous improvement in a short time has indeed led to improved child 
restraint designs. However, the homogeneity in scores makes it 
difficult for parents and caregivers to discern between products for 
purchase and more difficult for manufacturers to distinguish themselves 
thereby reducing the incentive to bring to market more innovative, easy 
to use child restraints and features.
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    \11\ https://www.nhtsa.dot.gov/CPS/CSSRating/Index.cfm.
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    The current forms, their features, and their criteria were designed 
prior to NHTSA's requirement of the LATCH hardware. As a result, the 
program does not fully discern between the different types of hardware 
that are now required equipment on child restraints and many of the 
rating criteria assume that LATCH is an optional piece of equipment on 
the child restraint. In addition, the criteria that are present were 
based only on the technology that was available at the time. Finally, 
the agency feels that some of the criteria need to be improved to 
reflect the ease of preparing and using different types of LATCH 
equipment that rear- and forward-facing child restraints must have.
    In deciding what changes to propose for the EOU program, NHTSA 
evaluated a recent survey it conducted on LATCH, reviewed comments 
submitted in response to the public meeting held on LATCH, and 
conducted an additional study designed to specifically evaluate the EOU 
program. NHTSA also considered feedback provided by actual EOU raters.

A. LATCH Misuse Survey

    The agency published a survey \12\ on December 22, 2006 that served 
as its first major review of the LATCH system since it was required on 
vehicles and child restraints in 2002. The results were encouraging but 
it also proved that the system was not recognized by as many caregivers 
as we had anticipated. It is consequently not being used as often as we 
had hoped. In addition, it has not solved as many installation problems 
as we originally suspected.
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    \12\ Decina, Lawrence E., Lococo, Kathy H., and Doyle, Charlene 
T. Child Restraint Use Survey: LATCH Use and Misuse. DOT HS 810 679. 
December 22, 2006.
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    The survey highlighted some misuses that could be addressed by the 
EOU program. For example, it showed that nearly 10% of the child 
restraints in the study were installed with the lower attachments 
upside down. Other statistics highlighted misuses such as twisted upper 
tether and lower attachment straps, misrouted lower anchor straps, and 
loose installation. The survey also showed that a number of rear-facing 
child restraints (over 20%) were installed at an incorrect angle. 
Additionally, one of the findings found that approximately 45% of 
parents were not using their top tethers either because they were 
unaware it was available or unsure of how it was supposed to be used.
    The survey also highlighted that a number of people were not using 
the LATCH system at all. Participants indicated a variety of reasons 
for this, including the fact that they were simply not aware that the 
system existed or that it was present in their vehicle. Though this is 
primarily an education issue, the agency believes there are ways the 
EOU program can be used to help increase LATCH awareness.

B. LATCH Public Meeting

    NHTSA held a public meeting on February 8, 2007 \13\ that brought 
child restraint and vehicle manufacturers, retailers, technicians, 
researchers and consumer groups together to explore ways to improve and 
increase the use of the LATCH system. At the meeting, four panels were 
held specifically focusing on: vehicle LATCH design, child restraint 
LATCH ease of use, child side-impact safety, and educating the public 
about seat belts and LATCH. Participants were asked to submit written 
comments to the Docket highlighting issues they may or may not have 
expressed during the meeting.
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    \13\ For a transcript of the meeting and all comments submitted 
please see Docket NHTSA-2007-26833.
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    Comments from the LATCH public meeting specific to NHTSA's EOU 
program were received from: General Motors (GM), Honda Motor Company 
(Honda), American Academy of Pediatrics (AAP), Advocates for Highway 
and Auto Safety (Advocates), Columbia Medical, Car-Safety.Org, Safe 
Ride News Publications (SRN Publications), SafetyBeltSafe USA, Cohort 
22 of the Florida International University BBA+ Weekend Program (Cohort 
22), UVA RN-BSN students (UVA), and several child passenger safety 
technicians (CPSTs). The comments can be grouped by labeling and 
instructions, lower anchor design, and other general observations.
1. Labeling and Instructions
    Though many commenters agreed with NHTSA that child restraint 
labels and instructions have been much improved since the beginning of 
the

[[Page 65808]]

EOU rating program, some commenters provided additional suggestions. 
Cohort 22 and the UVA suggested that either a DVD or a Web site link be 
included in instruction manuals for an installation video. UVA believes 
that poor instructional illustrations cause confusion during 
installation and should be replaced with actual photographs. SRN 
Publications believes that manuals should explicitly encourage the use 
of LATCH, rather than simply listing it as an option for installation. 
A CPST believed that clearer instructions are needed.
    GM, UVA, Advocates, AAP, and SRN Publication, suggested that tether 
and lower anchors in the vehicle could be better labeled,\14\ perhaps 
by using ISO-style symbols. While NHTSA's EOU program does not 
currently evaluate in-vehicle features, GM made the additional 
suggestion that symbols could also be included on the lower attachments 
and tether hooks on the child restraint. GM felt that by seeing the 
symbols in both places the consumer would be encouraged to use them 
more often.
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    \14\ Federal Standard No. 225, ``Child restraint anchorage 
systems,'' only requires symbols when the lower vehicle anchors are 
hidden.
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2. Lower Attachment Design
    Some commenters suggested that the agency evaluate and subsequently 
encourage a single technology for lower attachment. Honda and AAP 
commented that the agency conduct research on the ease of using various 
lower attachment hardware and possibly require the design that emerges 
as the most user-friendly. Some of the CPSTs suggested that all LATCH 
systems be identical in appearance so that the system is intuitive and 
installation is easy. They also suggested an audible confirmation of 
attachment. With regards to design, one CPST stated that the ``mini 
connector'' style lower attachments were the most user-friendly. SRN 
Publications encouraged restraint manufacturers and NHTSA to weigh the 
economic benefits of implementing only the most user-friendly design in 
lower anchor designs. They suggested that the agency encourage rigid 
attachments over flexible straps, and that all flexible systems, when 
used, should have adjustment mechanisms on each side of the restraint. 
SafetyBeltSafe USA recommended that a system be developed to prevent 
parents from using the wrong configuration for the lower attachments on 
convertible child restraints (i.e., routing the lower attachments 
through the RF path while trying to use the child restraint in the FF 
mode). Cohort 22 recommended an investigation into a more universal 
LATCH system for both the vehicle and the child restraint, stating that 
parents who purchase child restraints with LATCH attachments that are 
not easily compatible with their vehicles will likely just use seat 
belts instead.
3. Other Comments
    Comments to the docket from a few of the CPSTs indicated that the 
program should include criteria for lower attachment and tether storage 
systems. Many of the participants, including Honda, GM, SRN 
Publications, AAP, SafetyBeltSafe USA, Car-Safety.Org, and some of the 
CPSTs supported a variety of changes that could be made to vehicle 
designs rather than the child restraints themselves.

C. Comprehensive Study of the Ease of Use Program

    The agency commissioned a study \15\ by RONA Kinetics and 
Associates, a research firm that reviewed the current program and 
identified areas where improvements could be made. This study combined 
the expertise of RONA Kinetics with input from CPS technicians from the 
U.S. and Canada.
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    \15\ See Docket NHTSA-2006-25344].
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    One of the suggested program enhancements made in the RONA report 
was the incorporation of additional criteria that would pertain to the 
lower anchor and tether storage. The report also suggested that the 
ratings include a further evaluation of the child restraint 
instructions and that their storage system be accessible in all modes 
of the restraint's use. Further, it was suggested that the agency 
include more LATCH features, especially pertaining to flexible lower 
anchors. In addition, the report suggested that the agency consider 
changes to its method of calculating a restraint's score.

D. Feedback From Current Ease of Use Raters

    The agency also used input from its own child restraint raters as 
another source of information. One suggestion was to incorporate a 
feature that evaluated the recline capabilities of RF child restraints. 
Raters believed that such a feature could help aid the ability of 
parents to secure these child restraints without a ``pool noodle'' or 
other positioning device. It was also suggested that a number of the 
existing criteria could be changed to better reflect current and 
emerging designs. In some cases this could be achieved by combining 
related criteria into one. In other cases, deletions were suggested. 
For example, features that were anticipated but never realized in the 
actual market, like lower anchors that could be used in multiple 
orientations and harness buckles that could not be used in reverse, 
were suggested deletions. It was also felt that a reduction in the 
weighting factors assigned to many criteria could be adjusted to better 
convey which features were more critical to correct installation.

VI. Analysis and Agency Decision on Suggested Program Changes

    After a review of the comments received to the Docket from the 
public hearing, NHTSA's own review of the EOU program, and a review of 
consumers experience with LATCH, the agency has decided to propose 
several fundamental changes to the EOU program. The proposed changes 
outlined here serve to better reflect the current spectrum of features 
seen in the child restraint market. It is the agency's belief that 
through this upgrade, manufacturers will be encouraged to implement 
more widespread incorporation of features that will make it easier and 
more intuitive to install child restraints.
    The agency does not plan to change the scope of the EOU rating 
program. That is, we will continue to apply this program only to add-on 
child restraints and not built-in child restraints. \16\ Similarly, as 
before, the agency will continue to use three sets of forms to evaluate 
child restraints. One set will still be used to rate infant-only 
restraints, convertible restraints, and 3-in-1 restraints in their 
rear-facing configuration. Another set will rate convertible 
restraints, forward facing only restraints, combination forward facing/
booster restraints, and 3-in-1 restraints in their forward-facing 
configuration. The third set will be used to rate high- and low-back 
booster seats, combination forward facing/booster seats, and 3-in-1 
restraints in their belt-positioning booster configurations. Each child 
restraint selected for rating will be evaluated in each configuration 
that pertains to its proper use. For example, a convertible restraint 
would be evaluated and assigned a rating using both the rear-facing and 
forward-facing forms since it may be used in both configurations. A 
combination forward facing/booster restraint would be evaluated and 
assigned a rating for both the forward-facing and booster modes.

[[Page 65809]]

Additionally, 3-in-1 restraints that may be used rear-facing, forward-
facing, and booster seat mode would be evaluated and rated for all 
three modes.
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    \16\ For MY 2007, only 7 of the estimated 381 makes and model 
had the option of purchasing a built-in child restraint.
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    To ensure the most comprehensive revisions to the rating system, 
the agency examined all aspects of the current program. This required a 
thorough examination of the rating categories, features, criteria, 
weighting factors, the numerical ranges used to assign ratings, and the 
way the ratings themselves are conveyed.

A. Rating Categories and Their Associated Features

    The specific changes to the EOU categories are organized by rating 
category and feature. With regards to changes made to the features, we 
first wanted to incorporate concepts that were not included in the 
original program. Secondly, we wanted to strengthen some existing 
features by reducing their criteria from three levels to two. For 
example, a feature that had ``A'', ``B'', and ``C'' criteria could now 
only have ``A'' and ``C'' criteria. Thirdly, we evaluated some related 
features that could be combined in order to make the highest rating of 
the new feature more difficult to achieve. The agency also found a need 
to delete some features altogether. If a feature or its associated 
criteria is removed from a rating system, there is always concern that 
``backsliding'' could occur. That is, since manufacturers are no longer 
rated for a feature, they may revert to a previous (and likely less 
user-friendly) version of that feature due to cost or other 
considerations. The agency does not believe that is the case with the 
criteria we have chosen to eliminate. In some cases, a feature was 
removed because nearly every child restraint since the program was 
created has always been awarded an ``A'' for the feature. In other 
cases, a feature was removed because it has been incorporated into 
nearly all child restraint systems.
    The agency's proposed changes and the corresponding rationale are 
explained below. It should be noted that features are incorporated into 
the rating forms only as needed; for example, there are no LATCH 
features assessed on the booster rating forms since they are not 
required to have LATCH.
1. Assembly
    The agency is proposing to eliminate the ``Assembly'' rating 
category and distribute the features from this category among the 
``Evaluation of Instructions'' and ``Securing the Child'' categories. 
The ``Assembly'' category assessed three features on the RF and Booster 
forms and four on the FF forms (the additional feature encouraged that 
the tether arrive attached to the child restraint). A review of the 
current program revealed that most of the features in the current 
``Assembly'' category should only be assessed under one mode of a 
multi-mode child restraint to avoid grade inflation. Assessing these 
features under only one mode of use would then, in effect, require that 
feature to be marked ``n/a'' for its remaining modes. Therefore, for 
some child restraint modes, the entire ``Assembly'' category could be 
assigned a rating based on one feature. For these reasons, the agency 
is proposing to distribute the former ``Assembly'' category features 
among the four remaining categories. Additionally, many of the past 
``out-of-the-box'' issues covered by the ``Assembly'' category, such as 
child restraints that require tools to assemble, have disappeared from 
the market, further encouraging this proposal.
2. Evaluation of Labels
    Under this category, the labels from the child restraint itself are 
assessed for accuracy and completeness. The proposed upgraded rating 
forms, located in Appendix A, include the following features in the 
``Evaluation of Labels'' category. The forms that each are applied to 
are included in the parenthesis:
    a. Clear indication of child's size range. (RF, FF, Booster)
    b. Are all methods of installation for this mode of use clearly 
indicated? (RF, FF, Booster)
    c. Are the correct harness slots for this mode indicated? (RF, FF)
    d. Label warning against using a lap belt only. (Booster)
    e. Seat belt use and routing path clarity. (RF, FF, Booster)
    f. Shows how to prepare and use lower attachments. (RF, FF)
    g. Shows how to prepare and use tether. (FF)
    h. Durability of labels. (RF, FF, Booster)
a. Clear indication of child's size range. (RF, FF, Booster)
    The agency would like to expand this feature to assess whether or 
not the child restraint labels contain additional sizing information 
beyond the required height and weight limits of Federal Standard No. 
213,\17\ ``Child Restraint Systems''. Parents and caregivers could 
benefit from visual indicators that help describe how an appropriately 
sized child should fit in the restraint. For example, the label could 
use a picture to show that the child's head must be more than 1 inch 
from the top of the restraint, or that the top of his or her ears must 
be below the top of the restraint. A limited number of child restraints 
provide this information now and we believe that this information is 
useful for parents and caregivers in achieving an appropriate fit for a 
child. Additionally, such information could reduce the number of 
children who are placed in child restraints not appropriate for their 
age.
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    \17\ See 49 CFR 571.213.
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b. Are all methods of installation for this mode of use clearly 
indicated? (RF, FF, Booster)
    The agency feels that the current feature for assessing the proper 
methods of installation is sufficient. However, we would like to 
clarify the criteria to include that for the FF mode, the tether must 
be labeled with every configuration. Currently, the criteria only 
evaluates whether or not the tether is pictured but does not 
necessarily require it be labeled. The agency feels that having the top 
tether labeled could help to reinforce the use of the tether with FF 
child restraints.
c. Are the correct harness slots for this mode indicated? (RF, FF)
    The agency proposes to strengthen this feature to include criteria 
that evaluate harness slot labels under both the RF and FF modes of 
use. Previously, if there was nothing on the restraint indicating which 
harness slots were appropriate for each mode of use, the raters would 
search the manual for additional information. If it was determined from 
the manual that all the harness slots were able to be used in the 
forward-facing mode, the restraint was assigned an ``n/a.'' Now, child 
restraints can be encouraged to have harness slots that are labeled for 
both the rear-facing and forward-facing mode. The agency believes that 
consultation with the manual should not be necessary to properly use 
this feature. It is critical to the child's safety that the harness 
slots are used appropriately, as most often these are reinforced for 
strength; especially in the FF mode. Using RF harness slots for a FF 
child can lead to a very dangerous misuse, and in light of this, the 
agency wants to encourage harness slots that are labeled with a graphic 
or contrasting text to receive the highest rating for this feature.
    Additionally, the agency feels that all child restraints should 
contain some indication to help achieve the correct harness slot height 
for the child. This includes single mode child restraints and child 
restraints with no-thread harness adjustments. For example, a RF

[[Page 65810]]

child restraint may state or illustrate that the proper harness slots 
to use would be at or below the child's shoulder height. A FF child 
restraint could state or illustrate that the proper harness slot height 
to use would be at or above the child's shoulder height. In addition, 
restraints should illustrate this visual to better allow parents and 
caregivers the ability to assess the child's fit with respect to the 
harness.
d. Label warning against using a lap belt only. (Booster)
    The agency created a new feature for the booster rating forms. We 
are proposing that child restraints should be evaluated on the presence 
of an illustrative warning against the use of a lap belt only. The 
agency is not aware of any booster seats on the market that may be used 
without a three-point belt. As of model year 2008,\18\ all rear seating 
positions in passenger vehicles must come equipped with three point lap 
and shoulder belts. The agency feels that the presence of an 
illustration can reinforce that these devices must be used with a 
three-point belt. Boosters are arguably the simplest type of child 
restraints to use correctly and encouraging an extremely clear 
illustration to avoid a potentially dangerous situation is in the best 
interest of child safety.
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    \18\ 69 FR 70904. See Docket NHTSA-2004-18726.
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e. Seat belt use and routing path clarity. (RF, FF, Booster)
    The agency would like to maintain this feature, which examines how 
obvious the seat belt and flexible lower attachment routing path is. 
However, we feel that its robustness could be improved. We propose that 
the criteria evaluate the restraints on whether or not the belt path is 
labeled on both sides of the restraint. This ensures that despite the 
user's point of installation, the belt and lower anchor path can easily 
be seen.
f. Shows how to prepare and use lower attachments. (RF, FF)
    There are currently two features that assess the content of lower 
attachment-related labels. One examines the labels pertaining to the 
preparation of the lower attachments and the other examines the 
instructions for their use. It has been the agency's experience that 
having these two separate features is unnecessary; it is sometimes 
difficult for raters to ascertain which operations should specifically 
constitute ``preparation'' and which should specifically constitute 
``use.'' In order to reduce this confusion, the agency is proposing 
that these two features now be combined. In effect, there will now be 
one complete feature to evaluate whether the labels clearly depict all 
steps of preparation and use.
g. Shows how to prepare and use tether. (FF)
    In an effort to encourage more widespread tether use, the agency 
proposes to evaluate child restraints on whether their proper use and 
preparation is sufficiently explained by illustrations and concise text 
on the child restraint labels.
h. Durability of labels. (RF, FF, Booster)
    The agency is proposing to modify this feature so that it better 
assesses the durability of the labels on the child restraint. The 
current forms require that the label durability be assessed in every 
mode of use. For child restraints with more than one mode of use, this 
tended to inflate the overall score since the same labels are evaluated 
each time. The agency is revising its forms so that restraints with 
more than one mode of use will now be assessed only once, under its 
youngest mode of use (configured to accommodate youngest child 
recommended for the restraint). The agency believes this will improve 
the robustness of the label category score and overall rating.
3. Evaluation of Instructions
    The most significant changes proposed in this category, which 
evaluates the restraint's instruction manual, is a reduction in weight 
for the majority of the criteria. Under the current program, most of 
the features rated under the ``Evaluation of Labels'' category are also 
carried through to the ``Evaluation of Instructions'' category. 
Essentially, the same information is encouraged in both places. Though 
the agency feels it is important to have pertinent information 
duplicated on the instructions and the labels, we also know that is it 
much easier for manufacturers to include complete information in an 
instruction manual than it is to convey the same information on the 
restraint labels. The agency certainly believes that a restraint's 
instruction manual must be carefully considered prior to using the 
restraint. However, NHTSA believes that the pertinent information 
required for correct daily use can be communicated on the child 
restraint labels themselves. The labels should reduce the need to 
consult the instructions.
    The upgraded rating forms, located in Appendix A, include the 
following ``Evaluation of Instructions'' features. The forms that each 
are applied to are included in the parenthesis:
    a. Owner's manual easy to find? (RF, FF, Booster)
    b. Evaluate the manual storage system access in this mode. (RF, FF, 
Booster)
    c. Clear indication of child's size range. (RF, FF, Booster)
    d. Are all methods of installation for this mode of use clearly 
indicated? (RF, FF, Booster)
    e. Airbag/rear seat warning? (RF, FF, Booster)
    f. Instructions for routing seat belt. (RF, FF, Booster)
    g. Shows how to prepare & use lower attachments. (RF, FF)
    h. Information in written instructions and on labels match? (RF, 
FF, Booster)
a. Owner's manual easy to find? (RF, FF, Booster)
    The agency feels that if an instruction manual is attached to the 
child restraint in an obvious location, it has a greater likelihood of 
being seen and read. As a result, we are proposing to modify the 
criteria that examine whether the manual is easy to find when the child 
restraint is taken out of the box. Three levels of evaluation criteria 
for this feature will be reduced to two. It should be noted that this 
feature was previously assessed under the ``Assembly'' category; it was 
felt that moving the feature to the ``Evaluation of Instructions'' 
category was a better location. Also, this feature will now be assessed 
only once, when the child restraint is being evaluated in its youngest 
mode of use, to reduce grade inflation.
b. Evaluate the manual storage system access in this mode. (RF, FF, 
Booster)
    In addition to easily finding the child restraint instructions, the 
agency also feels that an obvious, accessible storage system can help 
caregivers continue to consult the instructions when needed. 
Previously, this feature was also assessed under the ``Assembly'' 
section.
    In the Final Rule establishing the EOU program, NHTSA shared its 
concerns about the accessibility and visibility of the manual when the 
child restraint was installed. NHTSA decided at that time that the 
storage system criteria would be sufficient to encourage easy access to 
the manual when the child restraint was installed. Instead, the 
criteria and our ratings focused on whether the storage mechanism is 
literally difficult to use, rather than difficult to access. There are 
some products on the market that receive the top rating for the storage 
system even though the manual cannot be easily accessed when the 
restraint is installed or when the child is seated.

[[Page 65811]]

Therefore, the agency is proposing that the feature be updated so that 
manufacturers are encouraged to design storage systems that are 
accessible regardless of mode of use, and whether or not the child is 
sitting in the child restraint. NHTSA believes a manual should be 
easily stored, and the user should be able to retrieve it while the 
child restraint is installed and the child is in the restraint.
c. Clear indication of child's size range. (RF, FF, Booster)
    Similar to the updated label feature, the agency is proposing to 
expand these criteria to include whether the child restraint 
instructions contain additional sizing information beyond the height 
and weight limits. As previously discussed, such information should 
decrease the number of children in child restraints not appropriate for 
their age. Along with the evaluations for clear height and weight 
limits, the instructions should contain a picture and text indicating 
additional child sizing information as discussed previously in the 
``Evaluation of Labels'' section.
    d. Are all methods of installation for this mode of use clearly 
indicated? (RF, FF, Booster)
    The agency feels that the current evaluation for illustrating the 
proper methods of installation is sufficient. As a result, the feature 
has been clarified only to include that for the FF mode; the tether 
must be labeled and pictured in every configuration. The agency feels 
that this will help to reinforce the use of the tether with FF child 
restraints.
e. Airbag/rear seat warning? (RF, FF, Booster)
    The agency is proposing to change the airbag warning criteria. 
Currently, all three forms contain a feature that encourages an airbag/
rear-facing restraint interaction warning. Instead of encouraging the 
same warning for each type of child restraint, the agency proposes 
encouraging FF and booster seat instructions to contain warnings about 
the rear seat being the safest place for children, since this is more 
consistent with child passenger safety recommendations. Child 
restraints evaluated under the RF forms will also have to convey this 
information in addition to the current airbag warning requirements for 
a separate, obvious, illustrated warning.
f. Instructions for routing seat belt. (RF, FF, Booster)
    The agency is proposing to enhance its requirements for seat belt 
routing instructions. In addition to looking for a diagram showing a 
clear, contrasting belt path, manufacturers should be encouraged to 
include information on different seat belt styles, retractor types, and 
latch plate types and how each should be used with the child restraint 
in question. In this, the agency hopes to continue reducing loose and 
incorrect installations due to seat belt misuse.
g. Shows how to prepare and use lower attachments and tether. (RF, FF)
    As in the ``Evaluation of Labels'' section, the features for 
``preparing'' and ``using'' the lower attachments should be combined. 
The agency also proposes to remove the separate feature that looks for 
a diagram depicting the correct orientation of the lower attachments. 
Instead, the correct orientation criteria should be included within 
this feature. The criteria for this feature is similar to those for the 
labels: Lower attachment instructions must clearly depict all steps of 
preparation and use, including routing flexible lower attachments 
properly for that mode and making certain the user is prompted to 
tighten the straps. FF child restraints must also have complete tether 
directions included to satisfy this feature.
h. Information in written instructions and on labels match? (RF, FF, 
Booster)
    The current rating forms assess whether the height and weight 
information on the labels matches. Prior to the EOU program, it was 
common to see confusing and even incorrect sizing information between 
the instructions and labels. Though it is much less common now, the 
agency proposes to maintain and strengthen this feature since we still 
see instances where there is conflicting information between the manual 
and the labels. In some cases, for example, the child restraint labels 
do not show the same style base or lower attachments as is found in the 
instructions. In addition to satisfying the current criteria, all 
pictures on the labels must convey the same information as in the 
manual. In addition to this, the child restraint model name should be 
found directly on the product as well as in the manual. The agency 
feels it is confusing to receive a manual where the purchased product's 
model name cannot be found.
4. Securing the Child
    This category, which examines the child restraint features that 
help secure the child in the restraint, has the most proposed changes. 
The rating forms, located in Appendix A, include the following 
``Securing the Child'' features. The forms that each are applied to are 
included in the parentheses:
a. Is the restraint assembled and ready to use? (RF, FF, Booster)
    b. Does harness clip require threading? Is it labeled? (RF, FF)
    c. Evaluate the harness buckle style. (RF, FF)
    d. Access to and use of harness adjustment system. (RF, FF)
    e. Number and adjustability of harness slots in shell and pad. (RF, 
FF)
    f. Visibility & alignment of harness slots. (RF, FF)
    g. Ease of conversion to this mode from all other possible modes of 
use. (RF, FF, Booster)
    h. Ease of conversion from high back to no back. (Booster)
    i. Ease of adjusting the harness for child's growth.
    j. Ease of reassembly after cleaning. (RF, FF, Booster)
    k. Ease of adjusting/removing shield. (RF, FF)
a. Is the restraint assembled & ready to use? (RF, FF, Booster)
    One feature that has been very successful in influencing the child 
restraint market has been our encouragement that child restraints 
arrive completely ready to use when taken out of the box. As a result 
of the current rating program, virtually every child restraint on the 
market today does, in fact, arrive fully assembled. The agency 
considered but ultimately determined not to propose removing the 
feature from the rating system. Hopefully this will maintain the 
incentive for child restraints to continue arriving fully assembled 
when purchased by consumers. This feature was originally located in the 
``Assembly'' category. Since that category is being dissolved it was 
decided that ``Securing the Child'' was the next logical location. The 
agency also proposes to reduce these three levels of criteria to two. 
Now, to receive the highest rating for this feature, a child restraint 
cannot require any assembly, regardless of whether it needs tools. 
Also, this feature would only be evaluated once, when the child 
restraint is rated under its youngest mode of use, in order to reduce 
grade inflation.
b. Does harness clip require threading? Is it labeled? (RF, FF)
    Previously, there was no EOU feature to evaluate the harness clip 
on a restraint. The agency has decided to propose one so as to 
encourage harness clips that do not require threading. In addition, 
NHTSA would like to encourage them to be labeled with simple text or a 
graphic that can provide some indication of where they should

[[Page 65812]]

be positioned on the properly restrained child. The agency feels that 
this will increase the correct usage of these devices.
c. Evaluate the harness buckle style. (RF, FF)
    In the current rating system, a child restraint is assessed on 
whether the harness buckle may be secured (and released easily) if it 
is buckled in reverse. The agency anticipated that parents may find 
reversing the buckle a sufficient deterrent for children who attempt to 
release the harness system on their own. The agency has no evidence, 
anecdotal or otherwise, that this technique is widely used. As a 
result, we are proposing to remove this feature from the rating 
program, as nearly all child restraint buckles already receive the top 
rating.
    However, there is no current feature that evaluates the ease of 
using one type of harness buckle over another. Some buckles allow the 
user to insert each side of the buckle independently. Other styles 
require the user to hold the two shoulder portions of the buckle 
together and insert them at the same time, commonly referred to as a 
``puzzle buckle'' style. Some manufacturers use these ``puzzle 
buckles'' to prevent either side from being incorrectly latched, which 
could lead to a dangerous misuse. However, according to many CPSTs, 
they are also more difficult for the user. Restraints with shoulder 
strap buckles that may be inserted independently of one another are 
ideal from an ease of use perspective, while buckles requiring both 
shoulder strap pieces to be inserted at together are not. Some ``puzzle 
buckles'' are more forgiving than others and have an intermediate 
method of keeping the two pieces together prior to their insertion into 
the buckle. For example, some use a small magnet or hook to hold the 
two separate pieces together, which can ease the process. As such, we 
are proposing to modify the criteria based on the presence of such 
features.
d. Access to and use of harness adjustment system. (RF, FF)
    The agency proposes to combine the features that evaluate both 
access to and use of the harness tightening system. It is critical that 
there is access to the mechanism used to tighten the harness system 
regardless of the installation mode. A restraint cannot be used 
correctly if the harness system cannot be tightened onto the child. The 
condition for access will be assessed using the FMVSS 213 bench by 
installing the child restraint with both the lower attachments and seat 
belt (as necessary). We will also continue encouraging harness systems 
that may be adjusted with a single action. However, the agency proposes 
reducing the number of levels this new feature is evaluated on from 
three to two. For example, in order to receive the highest rating for 
this feature, there must be access to the harness adjustment system in 
that mode of installation and the mechanism for adjusting the system 
must be simple to use.
e. Number and adjustability of harness slots in shell and pad. (RF, FF)
    The agency is proposing to combine some related harness slot 
criteria from this section. The current rating program separately 
evaluates the number of harness slots and whether the number of harness 
slots in the shell and padding matches. The agency feels that differing 
numbers of slots in the shell and pad can easily lead to misrouting the 
harness straps when they are adjusted. However, these are examples of 
features that almost always receive the top rating. As a result, the 
agency would like to combine these features so that no backsliding can 
occur. This feature will apply to both re-threadable and fully 
adjustable harness systems. Rather than encouraging a certain number of 
harness slots for adjustable systems, the agency will encourage that 
they be adjustable to a minimum of three heights.
f. Visibility & alignment of harness slots. (RF, FF)
    The agency maintains its position that having obvious, clear 
harness slots in the shell and pad helps to reinforce their proper use 
and avoids misrouting issues. We will continue assessing the alignment 
of the harness slots in the seat pad with the child restraint shell. 
The criteria have been re-written for clarity but their requirements 
are unchanged. Under the new rating system, however, we propose that 
child restraints with ``no-thread'' harness systems receive an ``n/a'' 
for this feature since its purpose is to help facilitate rethreading.
g. Ease of conversion to this mode from all other possible modes of 
use. (RF, FF, Booster)
    The agency is proposing to restructure the features that assess the 
ease of converting a child restraint. Previously, the criteria were 
written in a way that did not fully evaluate the relative complexity of 
converting a child restraint between its different modes, especially 
for those equipped with flexible lower anchor systems that need to be 
re-routed to change to another mode. In addition to this, a number of 
needs specific to 3-in-1 child restraint systems were not being 
reflected. For example, the complexity of removing and replacing the 
harness when a child restraint is converted from and to its booster 
mode was not reflected.
    Child restraints would now be evaluated on the difficulty a user 
would experience converting the restraint back to the mode in question 
from any other mode it could be used in. The agency recognizes that 
multi-mode child restraints, especially 3-in-1 child restraints, will 
have difficulty achieving the top rating for this feature. 
Additionally, the agency recognizes that the process of converting a 
child restraint is normally an infrequent occurrence. However, given 
the relative difficulty of converting child restraints between modes, 
as well as the potential to introduce gross misuse and misplace 
critical pieces, NHTSA feels it is important to include such a feature 
in the new ratings.
h. Ease of conversion from high back to no back. (Booster)
    The agency is proposing to add a separate feature to assess the 
difficulty of converting high back boosters to backless boosters. It 
was felt that the relative ease of converting a high back to a low back 
booster versus, for example, converting a 3-in-1 child restraint 
between its modes, warranted its own feature. In the upgraded ratings, 
a schematic should be found on the child restraint showing the 
conversion process; in addition, the process must be simple to perform.
i. Ease of adjusting the harness for child's growth.
    Though the harness system usually needs to be adjusted when 
converting the child restraint to another mode, it must also be 
adjusted as the child grows. The agency is proposing to upgrade its 
evaluation of harness adjustment systems. The agency is now encouraging 
child restraints to have fully adjustable or ``no-thread'' systems that 
are both easy to understand and simple to use. Any restraint that must 
be rethreaded to adjust or that still has the possibility of misrouting 
(some no-thread systems can still be misrouted) will not receive the 
top rating for this feature.
j. Ease of reassembly after cleaning. (RF, FF, Booster)
    Removing the child restraint cover in order to launder it can 
introduce potential misuse. Similar to the conversion process, 
harnesses may have to be removed and loose pieces that are generated 
during the disassembly can be misplaced. Some restraints still require

[[Page 65813]]

tools to remove the padding. The current RF and FF forms evaluate this 
feature by assessing whether loose parts will result from removing the 
cover and whether the harness system could be routed incorrectly. The 
agency is proposing to maintain this feature but is clarifying the 
three rating criteria. Child restraints will continue to be evaluated 
on whether the harness requires rethreading, if loose critical parts 
are generated during disassembly, and whether the cover can be easily 
removed and replaced.
    The agency is proposing to add a similar feature to the booster 
forms, as they did not contain any criteria for this bef