Consumer Information; Program for Child Restraint Systems, 10637-10664 [2011-4212]

Agencies

• National Highway Traffic Safety Administration
• DEPARTMENT OF TRANSPORTATION

[Federal Register Volume 76, Number 38 (Friday, February 25, 2011)]
[Notices]
[Pages 10637-10664]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-4212]



[[Page 10637]]

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DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

[Docket NHTSA-2010-00062]


Consumer Information; Program for Child Restraint Systems

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

ACTION: Request for comments.

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SUMMARY: On April 24, 2009, DOT announced that NHTSA would establish a 
new consumer information program, as part of the New Car Assessment 
Program, to help caregivers find a child restraint system (``child 
safety seat'') that fits their vehicle. Under the program, NHTSA will 
make available information from vehicle manufacturers as to the 
specific child safety seats the manufacturers recommend for individual 
vehicles. This document primarily details observations from an agency 
pilot study conducted to determine reasonable conditions for 
participation in such a program. It also proposes a set of forms 
comprised of objective criteria which vehicle manufacturers can use to 
identify child safety seats that fit their vehicles. The agency 
anticipates that this program will make it easier for caregivers to 
select a child safety seat that fits in their vehicle.

DATES: Comments should be submitted early enough to ensure that they 
are received no later than March 28, 2011.

ADDRESSES: Comments should refer to the docket number above and be 
submitted by one of the following methods:
     Federal Rulemaking Portal: https://www.regulations.gov. 
Follow the online instructions for submitting comments. Fax: 1-202-493-
2251.
     Mail: Docket Management Facility, U.S. Department of 
Transportation, 1200 New Jersey Avenue, SE., West Building Ground 
Floor, Room W12-140, Washington, DC 20590-0001.
     Hand Delivery: West Building Ground Floor, Room W12-140, 
1200 New Jersey Avenue, SE., Washington, DC between 9 a.m. and 5 p.m. 
ET, Monday through Friday, except Federal Holidays.
     Instructions: For detailed instructions on submitting 
comments and additional information on the rulemaking process, see the 
Public Participation heading of the Supplementary Information section 
of this document. Note that all comments received will be posted 
without change to https://www.regulations.gov, including any personal 
information provided.
     Privacy Act: Anyone is able to search the electronic form 
of all comments received into any of our dockets by the name of the 
individual submitting the comment (or signing the comment, if submitted 
on behalf of an association, business, labor union, etc.). You may 
review DOT's complete Privacy Act Statement in the Federal Register 
published on April 11, 2000 (Volume 65, Number 70; Pages 19477-78).

FOR FURTHER INFORMATION CONTACT: For non-legal issues related to the 
Vehicle-Child Restraint System (CRS) Fit program, you may contact Ms. 
Jennifer N. Dang, Office of Crashworthiness Standards (Telephone: 202-
493-0598). For legal issues, you may contact Ms. Deirdre Fujita, Office 
of Chief Counsel (Telephone: 202-366-2992). You may send mail to these 
officials at the National Highway Traffic Safety Administration, 1200 
New Jersey Avenue, SE., West Building, Washington, DC 20590-0001.

SUPPLEMENTARY INFORMATION:

Table of Contents

I. Executive Summary
II. Introduction
III. The Current Child Safety Problem
IV. NHTSA's CRS Activities
V. Addressing Vehicle-CRS Compatibility
    A. Consumer Information
    B. LATCH
VI. Considerations for Development of a New Consumer Information 
Program To Address Vehicle-CRS Compatibility
VII. Review of Worldwide Child Restraint Consumer Information 
Programs
VIII. Conditions for Participation, Program Administration, and 
Distribution
    A. Conditions for Participation in the Vehicle-CRS Fit Program
    B. Program Administration
    C. Program Distribution
IX. Pilot Study To Assess Effectiveness of Preliminary Vehicle-CRS 
Fit Program Evaluation Criteria
    A. Development of Vehicle-CRS Fit Evaluation Forms
    B. Pilot Study Approach
    1. Vehicle Selection
    2. CRS Selection
    C. General Pilot Study Observations
X. Pilot Study Observations and Resulting Proposed Fit Criteria
    A. Vehicle Seat Belts
    B. Top Tether Anchorages
    C. Lower Anchorages
    D. Head Restraints
    E. CRS Installation, Use, and Tightness
    F. Vehicle Owner's Manual
    G. Weight Limits
    H. Rear-Facing CRS
XI. Conclusions and Effective Date
XII. Paperwork Reduction Act
XIII. Public Participation
Appendices
    APPENDIX A: Worldwide Child Restraint Consumer Information 
Programs
    A. Child Restraints Evaluation Program (CREP)
    B. Consumers Union
    C. EuroNCAP
    D. Japan NCAP (JNCAP)
    E. New Program for the Assessment of Child Restraint Systems 
(NPACS) and the Child Seat Rating Scheme
    APPENDIX B: Pilot Study Evaluation Form
    APPENDIX C: Observations From Vehicle-CRS Pilot Study
    APPENDIX D: Proposed Vehicle-CRS Fit Assessment Forms
    APPENDIX E: Installation Methods for Assessing Vehicle-CRS Fit

I. Executive Summary

    Child restraint systems (CRS) are very effective at protecting 
children sitting in vehicles that are involved in motor vehicle 
crashes. Nonetheless, past studies have shown that installation 
mistakes that reduce or negate the effectiveness of CRS still occur 
frequently. Instances of misuse for child restraints can be attributed 
to user error or to incompatibilities between the child restraint and 
the vehicle. To address misuse due to user error, NHTSA conducts a CRS 
Ease of Use (EOU) program. To address the need for increased 
compatibility, DOT announced, on April 24, 2009, that NHTSA would 
establish a new consumer information program, as part of the New Car 
Assessment Program, to help caregivers find a child restraint system 
that fits their vehicle.
    The agency believes that this program will (1) provide consumer 
service by offering guidance on vehicle-CRS matchups, (2) complement 
NHTSA's Ease of Use program, 4 Steps for Kids consumer information 
campaign, as well as other child passenger safety initiatives, and (3) 
encourage child restraint and vehicle manufacturers to work together to 
address the need for increased compatibility.
    This document outlines factors that the agency deemed significant 
to the development of a Vehicle-CRS Fit program and details 
observations from an agency pilot study conducted to determine 
reasonable conditions for participation in such a program. It also 
proposes a set of forms comprised of objective criteria that vehicle 
manufacturers can use to identify child safety seats that fit their 
vehicles. In developing the proposed evaluation forms, the agency 
considered general installation techniques that are required for all 
CRS installations, specific installation techniques and other factors 
that apply to certain types of CRS or particular modes of use, and 
vehicle features that may influence proper CRS

[[Page 10638]]

fit. Under the program, NHTSA will disseminate a list of child 
restraints that manufacturers suggest will fit in their individual 
vehicles on Safercar.gov.
    To participate in the program, vehicle manufacturers shall 
recommend at least three current model year child restraints within 
each of three different CRS categories (rear-facing, forward-facing, 
and booster). For the forward-facing category, at least one high-weight 
harness CRS shall be recommended, and for the booster category, no more 
than one of the three recommended booster seats may be a dedicated 
backless booster. Additionally, the three recommended CRS for each of 
the three CRS categories shall be from three different CRS 
manufacturers and shall also meet three established price points 
(inexpensive, moderately-priced, and expensive) based on the child 
restraint's Manufacturer's Suggested Retail Price. To ensure 
recommended CRS satisfy the proposed fit evaluation criteria, the 
agency is also proposing to conduct its own assessments to spot-check 
fit for recommended vehicle-CRS combinations.
    The agency is proposing this program for voluntary participation by 
vehicle manufacturers and is seeking comment on all of its aspects.

II. Introduction

    NHTSA is primarily responsible for reducing deaths, injuries, and 
economic losses as a result of motor vehicle crashes. Child safety 
seats, technically referred to as child restraint systems (CRS) by 
Federal Motor Vehicle Safety Standard (FMVSS) No. 213, ``Child 
restraint systems,'' are widely agreed to be the most effective motor 
vehicle safety equipment available for restraining children. Although 
parents and caregivers strive to protect their children in motor 
vehicles, unfortunately, statistics on CRS misuse reveal that 
installation mistakes still happen with considerable frequency. A 2004 
study conducted with the support of NHTSA estimated that errors in 
installation, identified as critical errors by the study, occur at a 
high rate of 72.6 percent.\1\ While this study found the most common 
reasons for misuse to be loose harness straps securing the child to the 
CRS and loose vehicle seat belt attachment to the CRS, other types of 
misuse were also observed. Though instances of misuse such as loose 
vehicle seat belts can be attributed to user error, in some cases it 
may also be attributed to incompatibilities between the CRS and the 
vehicle. Due to the variety of vehicle and child restraint features in 
the U.S. market, some combinations of child restraints and vehicles 
make proper installation more difficult to achieve.
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    \1\ Decina L.E. and Lococo K. H. (2004). Misuse of Child 
Restraints. NHTSA Publication No. DOT HS 809 671, Page 2.
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    In the spring of 2009, the Secretary of Transportation tasked the 
agency with conducting a top-to-bottom review of child restraint 
regulations and consumer information. As a result of this internal 
review, the agency determined that while CRS are effective at 
protecting children, more can be done to improve their performance. 
Several agency initiatives were developed toward that end. Several 
programs pursue upgrading FMVSS No. 213 by adding side impact 
requirements to the standard, and by evaluating future improvements to 
its frontal impact requirements.
    In addition, a new consumer information initiative was begun to 
enhance the ease with which parents and caregivers can choose a CRS for 
their vehicle, knowing that the CRS will fit their vehicle when 
installed. Under the program, NHTSA will make available recommendations 
from vehicle manufacturers as to the specific child safety seats, in 
various price ranges, that fit in individual vehicles. NHTSA believes 
that providing parents with information about which child restraints 
fit in their vehicle(s) will improve consumers' confidence in and 
comfort with using CRSs, and will reduce installation mistakes.
    This document describes the agency's efforts to develop, pilot 
test, and propose a Vehicle-CRS Fit program for consumer information 
purposes. The agency is proposing this program, which will be part of 
NHTSA's New Car Assessment Program (NCAP), for voluntary participation 
by vehicle manufacturers and is seeking comment on all of its aspects. 
Vehicle manufacturers who wish to participate could use finalized 
versions of the evaluation forms provided in this document as a means 
of determining whether a particular CRS meets the agency's criteria for 
fit in their vehicles. Once a vehicle manufacturer has determined that 
a child restraint satisfies the agency's criteria for fit, it may 
submit this information to NHTSA for publication on the agency's 
consumer information Web site, https://www.safercar.gov.\2\
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    \2\ As part of the program, NHTSA will spot-check the fit of 
CRSs in vehicles to make sure that the information is accurate.
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III. The Current Child Safety Problem

    Child restraints reduce fatal injury by 71 percent for children 
less than 1 year old and by 54 percent for toddlers (1-4 years old) in 
passenger cars.\3\ Similarly, in light trucks, the corresponding 
reductions are 58 and 59 percent for infants and toddlers.
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    \3\ Traffic Safety Facts 2007: Occupant Protection, DOT HS 810 
991, National Center for Statistics and Analysis, 1200 New Jersey 
Ave, SE., Washington, DC 20590, Page 4.
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    The agency, along with manufacturers, local governments, and 
consumer groups, have consistently urged the public to put all children 
in age-appropriate restraints in the rear seats of vehicles. In recent 
years, many States have also passed child restraint and booster seat 
laws, which require children to travel in approved restraints for their 
age.\4\ These education and regulatory efforts are working; over the 
past decade, the percentage of unrestrained child fatalities has 
decreased significantly: 23 percent in 2008 \5\ compared to 43 percent 
in 1998.\6\ In June of 2009, NHTSA published a Research Note that 
provided more detailed demographic information about child restraint 
use. In a national probability sample of gas stations, day care 
centers, recreation centers, and restaurants in five fast food chains, 
it determined that 99 percent of children under age 1, 92 percent of 
children from ages 1 to 3, 89 percent of children ages 4 to 7, and 85 
percent of children ages 8 to 12 were restrained.\7\
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    \4\ https://www.iihs.org/laws/ChildRestraint.aspx.
    \5\ Traffic Safety Facts 2008: Children, DOT HS 811 157, 
National Center for Statistics and Analysis, 1200 New Jersey Ave, 
SE., Washington, DC 20590, Page 4.
    \6\ Traffic Safety Facts 1998: Children, DOT HS 808 951, 
National Center for Statistics and Analysis, 400 7th Street, SW., 
Washington, DC 20590, Page 4.
    \7\ Traffic Safety Facts: Child Restraint Use in 2008--
Demographic Results, NHTSA Publication No. DOT HS 811 148, National 
Center for Statistics and Analysis, 1200 New Jersey Ave, SE., 
Washington, DC 20590, Pages 2-5.
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    Tragically, in 2008, there were still 297 passenger vehicle 
occupant fatalities among children under 4 years of age. Restraint use 
was not known for all of these fatalities, but of the 282 children 
whose restraint use was known, 94 (32 percent) of those children were 
unrestrained. In the same year, however, an estimated 244 lives of 
children under age 5 were saved by proper restraint use. Of these lives 
saved, 219 were attributed to the use of child restraints and 25 to the 
use of adult safety belts. If 100 percent restraint use for children 
under age 5 had been attained in 2008, the agency estimates that 79 
additional lives, for a total of 323 children, could have been saved 
that year.\8\
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    \8\ Traffic Safety Facts 2008: Occupant Protection, DOT HS 811 
157, National Center for Statistics and Analysis, 1200 New Jersey 
Ave, SE., Washington, DC 20590, Page 4.

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[[Page 10639]]

IV. NHTSA's CRS Activities

    When a parent or caregiver is seeking information regarding a new 
CRS purchase, the agency's guidance is that a caregiver should select a 
restraint that is certified as meeting FMVSS No. 213, fits the child, 
can be used correctly every time, and can achieve a proper installation 
in the vehicle in which it will be used. The agency addresses these 
recommendations in the following ways:
     All child restraints sold in the United States must comply 
with the requirements in FMVSS No. 213. This standard contains dynamic 
frontal impact sled tests as well as strict labeling and component 
durability and strength requirements. All child restraints are 
evaluated on a pass-fail basis. Test dummies representing newborn, 
twelve-month-old, three-year-old, and six-year-old children are secured 
in age-, height- and weight-appropriate CRS to evaluate their dynamic 
performance. The latter three dummies are instrumented and must meet 
HIC (Head Injury Criterion), head excursion, and chest acceleration 
requirements when subjected to the 213 test. FMVSS No. 213 also 
specifies knee excursion requirements for CRS tested with the three-
year-old and six-year-old dummies, and additional structural durability 
and requirements with which all CRS must comply.
     To ensure that consumers choose a child restraint that 
fits their child, the agency created its 4 Steps for Kids consumer 
information campaign. This initiative arranges the agency's child 
passenger safety message into four phases, or ``steps,'' of a child's 
development. The first three ``steps'' are CRS-related guidelines that 
explain to consumers how to properly transition children from rear-
facing restraints to forward-facing restraints and finally to belt-
positioning boosters. The fourth ``step'' provides information on when 
it is appropriate for children to transition into rear seat adult lap/
shoulder belts. Choosing age-, height-, and weight-appropriate 
restraints for children throughout their development reduces their risk 
of injury in a crash.
     As mentioned earlier in the introduction, high rates of 
misuse for child restraints have been observed. To address this 
concern, along with child restraint usability, the agency conducts a 
CRS Ease of Use (EOU) program. The agency published a Final Notice 
announcing the EOU program in November of 2002.\9\ This program created 
child restraint usability ratings based on five categories: Ease of 
Assembly, Clarity of Labeling, Clarity of Instructions, Ease of 
Securing the Child, and Ease of Securing the CRS in the Vehicle. 
Substantial improvement in CRS usability features was observed: Only 57 
percent of child restraints received the top rating when the program 
began, and by 2007, 81 percent of child restraints received the top 
rating. In 2008, the program was updated to reflect changes in the CRS 
fleet by: Amending certain criteria, re-distributing the Ease of 
Assembly criteria category among the remaining four, and converting to 
a five-star rating system instead of the previous three-letter rating 
system.\10\ The agency continues to add child restraint usability 
ratings to the list each year. As of December 2009, ratings for 128 
child restraints were available.\11\ Child restraints are evaluated 
separately from vehicles through this program, but certain facets of 
the program relate to vehicle installation. The ``Ease of Securing the 
CRS in Vehicle'' category addresses features on the child restraint 
that aid in vehicle installation. For example, built-in seat belt lock-
offs \12\ eliminate the need for a locking clip in many instances. 
Wider belt paths allow the caregiver to more easily route the seat belt 
or lower attachment belt through the belt path, and push-button lower 
anchor connectors may be pushed on and removed with the touch of a 
button. Features such as these lessen the effort required to install a 
child restraint and are, in many cases, accommodated by the vehicle.
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    \9\ 67 FR 67448, Docket NHTSA-2001-10053.
    \10\ 73 FR 6261, Docket NHTSA-2006-25344.
    \11\ Ease of Use Ratings can be found either in Docket NHTSA-
2006-25344 or at https://www.nhtsa.gov/portal/nhtsa_eou/.
    \12\ Some child restraints have built-in devices for locking the 
vehicle seat belt in place so that the retractor or separate locking 
clips do not have to be used.
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     The agency also conducts several other child passenger 
safety initiatives. NHTSA maintains the content of the National Child 
Passenger Safety Certification curriculum through partnerships with 
respected child passenger safety experts.\13\ This certification 
program is estimated to have trained tens of thousands of interested 
individuals to become Child Passenger Safety Technicians (CPSTs). 
During this certification, individuals learn how to properly install a 
large variety of child restraints and how to assist parents and 
caregivers in doing so themselves. CPSTs are an especially valuable 
resource to the agency because they can provide information to the 
caregivers at the community level. The curriculum is monitored and 
updated as necessary based on changes to the CRS fleet and best 
practice methodology.\14\ The agency also manages National Child 
Passenger Safety Week, an annual campaign during which community 
organizations across the country host safety seat checkups and other 
child passenger safety awareness events.
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    \13\ These experts include members of The National Child 
Passenger Safety Board, AAA, Safe Kids Worldwide, The Children's 
Hospital of Philadelphia, vehicle and CRS manufacturers, and others.
    \14\ CPST best practice methodology is considered the most 
acceptable way to transport a child safely on the basis of the 
child's age, weight, height, and body development.
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    NHTSA's major child passenger safety initiatives (FMVSS No. 213, 4 
Steps for Kids, Ease of Use, and the CPST Curriculum) help parents and 
caregivers select an age-, height-, and weight-appropriate CRS that is 
simple to use and that is safe. However, the agency has recognized for 
some time that because of incompatibility issues between the vehicle 
and the CRS, parents and caregivers may still have difficulty not only 
selecting a CRS that fits their vehicle(s), but also properly 
installing selected child restraints in their vehicle(s). The CPST 
Curriculum may also not reach the general public. Accordingly, the 
agency has taken several steps to address vehicle-CRS compatibility 
issues.

V. Addressing Vehicle-CRS Compatibility

A. Consumer Information

    To date, the agency's attempts at developing a consumer information 
program that addresses vehicle-CRS compatibility issues have 
encountered a number of challenges. One of the most difficult issues 
the agency has had to resolve is how to manage the enormous amount of 
information that can be generated on the dozens of CRSs and vehicles on 
the market and the possible interface between each CRS and each vehicle 
model.
    In the fall of 1995, NHTSA tried to develop a vehicle and child 
restraint database. At the time, the agency surmised that a vehicle-CRS 
matrix could be distributed via CD-ROM to caregivers, child passenger 
safety advocates, and any other parties that educate the public about 
proper child restraint use. The resulting matrix was intended to be 
all-inclusive; information on specific child restraints would be 
coupled with details about vehicle makes, models, and available seating 
positions in which they could be successfully installed. However, 
during the database development, the agency

[[Page 10640]]

determined that its initial work toward providing information on the 
compatibility of 35 CRS with 100 vehicles from model years 1993-1996 
was overly ambitious. The sheer number of vehicle/CRS combinations made 
the data collection efforts overwhelming, especially considering that 
the agency was only working with a subset of the entire vehicle and CRS 
fleets. The initial matrix was also limited in its usefulness; the data 
applied only to the specific combinations of vehicles and child 
restraints listed. Because the development of the database proved 
unworkable, and because adoption of a standardized CRS attachment 
system was under consideration, the agency decided to discontinue its 
efforts to develop a vehicle-CRS matrix.

B. LATCH

    On March 5, 1999, the agency issued a final rule establishing FMVSS 
No. 225, ``Child restraint anchorage systems.'' This standard, which 
became fully effective on September 1, 2002, required the Lower Anchors 
and Tethers for CHildren (LATCH) system in most passenger vehicles and 
compatible hardware components on child restraints. A ``LATCH'' system 
is comprised of a set of small bars (known as lower anchors) located 
near the seat bight, and a third attachment point (known as a top 
tether anchor) located above or behind the vehicle seat. FMVSS No. 225 
requires a LATCH system to be installed at two rear seating positions 
on vehicles, and a top tether anchor at a third position. The final 
rule also amended FMVSS No. 213 to require child restraints to be 
equipped with attachments that mate with vehicles' lower anchors.
    The intention of the rulemaking was to provide an easy-to-use CRS 
attachment system that is independent of the vehicle seat belts. 
Through LATCH, incompatibility problems were reduced, and CRS 
installation made more intuitive and more effective.
    LATCH successfully resolved some of the compatibility problems that 
users experienced with seat belts. In most vehicles, child restraints 
can be installed using LATCH successfully. In a 2006 NHTSA survey, 
loose installation rates of child restraints had decreased from 
previous studies: Sixty-one percent of child restraints were securely 
installed using LATCH in the 2006 study, whereas a 2004 study examining 
incorrect installations with seat belts found only up to forty-six 
percent of child restraints were securely installed.\15\ The report 
concluded that there are two main reasons for this development: The 
absence of locking clips and the simplified process of fastening the 
LATCH attachments to the vehicle anchors. Many caregivers prefer using 
LATCH over seat belts when possible. Of those surveyed with experience 
using both LATCH and a seat belt, seventy-five percent preferred LATCH. 
Fifty-five percent of those who did not use LATCH were either unaware 
that lower anchors were available in their vehicle or were unsure how 
to use them.\16\
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    \15\ Decina, L.E., Lococo, K.H., Doyle, C.T., Child Restraint 
Use Survey: LATCH Use and Misuse, NHTSA Publication No. DOT HS 810 
679, National Highway Traffic Safety Administration, December 2006, 
Page 2.
    \16\ Additionally, it was found that caregiver preference played 
a large role in LATCH use. For example, even though the CRS may 
technically fit in the vehicle seat, the caregiver may find that 
locating the LATCH anchors is difficult due to stiff vehicle 
cushions or the deep placement of anchors within some vehicles' seat 
bights. Others may simply be more comfortable using the seat belt to 
install the child restraint because of prior experience with that 
method of installation; others may simply assume that the seat belt 
is safer.
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    In short, the LATCH system has successfully provided caregivers 
with an alternative to seat belts installations. Caregivers using LATCH 
to install their child restraint no longer have to remember a host of 
additional seat belt installation steps such as locking the vehicle 
seat belt when installing the child restraint. They also do not have to 
wrestle with seat belt geometry incompatibilities such as buckle stalk 
lengths and anchor points.

VI. Considerations for Development of a New Consumer Information 
Program To Address Vehicle-CRS Compatibility

    NHTSA is committed to improving vehicle-CRS compatibility and 
providing better consumer information. LATCH has improved the ease with 
which a CRS can be installed in a vehicle; however, it does not 
standardize the contours of the vehicle seat or the footprint of the 
CRS. Consequently, some child restraints might fit a particular vehicle 
better than other child restraints. Getting parents to select a 
restraint that is known to fit their vehicle ensures that they begin 
the installation process with a higher potential for success and level 
of efficiency in attaining a correct installation. It can also reduce 
their frustration and confusion. For these reasons, the agency has 
decided to develop and propose a consumer information program to 
address CRS fit in vehicles.
    The agency hopes that a program that focuses on vehicle-CRS 
compatibility will drive not only improved vehicle designs, but perhaps 
improved CRS designs, too, as child restraint and vehicle manufacturers 
will likely have to work together to address the need for increased 
compatibility. Changes to CRS footprints, redesigned belt paths, and 
more LATCH-friendly hardware are a few of the design changes that could 
be introduced as a result of compatibility-focused efforts. Although 
the agency realizes that implementation of such changes may take time, 
we believe that voluntary design improvements will nonetheless occur 
due to the increased cooperative efforts between vehicle and CRS 
manufacturers to improve vehicle-CRS compatibility.
    To best serve consumers, the agency believes that any program 
designed to assess vehicle-CRS compatibility should complement and 
supplement other child restraint and vehicle information it 
promulgates. Such a program should also result in a robust, repeatable 
assessment so that it is effective at not only helping parents and 
caregivers choose a child restraint that fits their vehicle(s), but 
also, in turn, helps deter misuse and frustration stemming from 
incompatibilities. We believe this can best be achieved by developing a 
program that is based solely on objective criteria. A program based on 
objective criteria should be simpler for manufacturers and evaluators 
to understand and use compared to one based on subjective assessments. 
Establishing objective assessment criteria should also help to minimize 
manufacturer concerns that consumers selecting a recommended CRS may 
still have difficulty fitting the CRS in their vehicle(s). This may 
promote increased voluntary participation as a result and ultimately 
provide consumers with the CRS information that they need.

VII. Review of Worldwide Child Restraint Consumer Information Programs

    In developing a program that would assist consumers in finding a 
child restraint that fits in their vehicle(s), NHTSA examined other 
child restraint-related consumer information and rating programs 
internationally and did not find a system that met all of the agency's 
needs.\17\ However, a portion of a draft ISOFIX usability standard 
developed by the International Standards Organization (ISO) was found 
to be most relevant.\18\
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    \17\ The agency's review of child restraint consumer information 
programs is included as Appendix A.
    \18\ ISO is a collection of organizations from 162 countries 
responsible for establishing world-wide voluntary industry 
standards. Representatives from these countries have helped publish 
over 17,500 international standards on various technical subjects, 
products, and processes.

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[[Page 10641]]

    In 1999, ISO published a draft standard outlining specifications 
for a rigid anchor system, known as ``ISOFIX,'' for attaching child 
restraints to vehicles. In 2004, it also developed a draft standard on 
tether anchorages and their acceptable locations in vehicles. Together, 
these two draft standards outlined the requirements for a dedicated in-
vehicle CRS installation system that is very similar to the U.S. LATCH 
system. In addition, ISO has since drafted rating forms for evaluating 
the usability of vehicle ISOFIX designs with different child 
restraints.\19\ The intent of these ratings forms is to assess the 
usability of a particular vehicle's ISOFIX system as well as a 
particular child restraint's installation features (which is similar 
to, but not as comprehensive as, the agency's current Ease of Use 
program). In addition, the forms also assess the interface between that 
vehicle and CRS when the user actually performs an installation.
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    \19\ ISO/DIS 29061-1. Road vehicles--Methods and criteria for 
usability evaluation of child restraint systems and their interface 
with vehicle anchorage systems.
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    Of all the consumer information and ratings programs the agency 
examined, the ISO draft standard most closely fit the agency's needs 
because of its unique assessment of the installation interface between 
a CRS and a vehicle. However, the agency was not able to draw 
extensively from the draft ISO usability standard for the proposed 
Vehicle-CRS Fit program for a number of reasons. For instance, in light 
of its comprehensive Ease of Use program, the agency did not see a need 
for including a CRS usability evaluation as a part of this Vehicle-CRS 
Fit program, nor did the agency feel that inclusion of criteria 
pertaining to the usability of CRS attachment hardware was warranted. 
Adopting a program that evaluates the actual vehicle-CRS interface 
would effectively address certain ISO criteria related to the usability 
of CRS attachment hardware in vehicles because the attachment hardware 
may generate installation issues, such as instability, that can 
prohibit a child restraint from fitting properly in a vehicle. Some of 
the ISO criteria also incorporate the ease of performing tasks related 
to the installation, and many of these are then designated ``good,'' 
``average,'' or ``poor.'' For the proposed program, the agency wanted 
to include only objective installation criteria that pertain to proper 
fit, i.e., whether a proper fit was achieved, not the ease of attaining 
that fit. In addition, the ISO draft rating forms only evaluate ISOFIX 
installations. The agency wanted a program that assessed both LATCH and 
seat belt installations. Finally, the ISO draft standard does not cover 
booster seats either, and the agency wanted to include these in its 
Vehicle-CRS Fit program since they are an important part of its child 
passenger safety initiatives.

VIII. Conditions for Participation, Program Administration, and 
Distribution

    Observations from an agency pilot study confirmed that installation 
issues can arise from either the child restraint or the vehicle, and 
can also be vehicle-CRS interface specific. For some vehicles, the same 
fit problem was observed when installing several different CRS types 
(infant, convertible, combination, booster, etc.) and models of child 
restraints. Considering that these same child restraints could be 
properly installed in several other vehicle models, it appears that for 
the vehicle models in which the subject child restraints would not fit, 
design changes to accommodate a greater number of CRS models would be 
appropriate. In some instances, inadequate fit was observed for every 
seat belt or LATCH installation for every child restraint installed in 
a vehicle. Therefore, it is likely that manufacturers of such vehicles 
would need to make changes to improve fit for both LATCH and seat belt 
installations to have information included in the consumer information 
program described today. Additionally, it was found that certain 
vehicle features may prohibit the installation of certain types of CRS 
in certain seating positions. Consequently, it may not be reasonable 
for vehicle manufacturers to claim that a child restraint fits in all 
applicable seating locations within a vehicle. Furthermore, space 
constraints, particularly for smaller vehicle models, may dictate the 
position of a vehicle's front seats or rear seating positions that are 
acceptable for installation of certain CRS.

A. Conditions for Participation in the Vehicle-CRS Fit Program

    In the interest of time and the need for improved consumer 
information, the agency is proposing that this program begin as a 
voluntary effort in MY 2012 for vehicle manufacturers only; however we 
are seeking comment on whether more time is needed. We believe that 
consumers will shop for a CRS having their vehicle already in mind, so 
it would be most reasonable for the fit program to be vehicle-based. 
The agency also believes gaining access to vehicles is more difficult 
and burdensome for child restraint manufacturers than it is for vehicle 
manufacturers to gain access to child restraints. However, the agency 
does not think that child restraint manufacturers should be excluded 
from the vehicle-CRS fit efforts; in fact, the contrary is true. NHTSA 
highly encourages vehicle and child restraint manufacturers to work 
together to complete these fit assessments. However, at this time, the 
agency will only collect vehicle-child restraint fit suggestions from 
vehicle manufacturers.\20\
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    \20\ Vehicle-CRS fit recommendations will be accepted only for 
those vehicles having Gross Vehicle Weight Ratings (GVWRs) of 10,000 
lbs. or less, as this program is intended to supplement NCAP, which 
limits testing to vehicles having GVWRs of 10,000 lbs. or less.
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    The agency is proposing that vehicle manufacturers should install 
child restraints in their vehicles, and while doing so, should bear in 
mind the considerations outlined throughout this document, and use the 
evaluation forms included in Appendix D (once they are finalized) to 
assess CRS fit in their vehicles. For a manufacturer to indicate that a 
specific child restraint fits in a particular vehicle, the child 
restraint must be assessed in all applicable modes of use and in all 
appropriate seating positions in the vehicle. Depending on the 
restraint, modes of use can include, but are not limited to: Rear-
facing, forward-facing, booster (high-back and backless), with and 
without a base, and with both ``short'' and ``long'' belt paths, where 
applicable. Child restraints that manufacturers determine fit a vehicle 
must fit in every appropriate seating location in the vehicle. For most 
passenger cars, appropriate seating positions will include those in the 
rear or second row; however, additional rows of seating must also be 
assessed, if applicable.
    Because of the agency's continuing efforts to ensure that children 
ride in the rear seat, the agency does not expect manufacturers of 
vehicles with rear seats that can accommodate child restraints to 
provide fit suggestions for the front right passenger seat.\21\ For 
two-

[[Page 10642]]

seaters and pickup trucks without a rear seat that have an air bag on-
off switch, however, we believe that it would be appropriate to 
indicate child restraints that fit the front right passenger seat.
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    \21\ The agency understands that in some cases, such as in 
transporting four children in a vehicle with only five seating 
positions, forward-facing restraints or booster seats may be 
correctly installed in the front right passenger seat. However, as 
the agency wants to encourage that children be properly restrained 
in the rear of the vehicle unless the vehicle in which they are 
traveling does not have a rear seating location, the agency does not 
want to suggest to parents and caregivers that the front seat is an 
acceptable travel position for younger occupants by providing 
vehicle-CRS fit recommendations for this seat. Therefore, the agency 
does not expect vehicle manufacturers to assess front right 
passenger seat fit if a usable rear seat exists.
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    The agency is proposing to not permit manufacturer recommendations 
of child restraints or boosters that fit in only certain seating 
positions or rows in the vehicle. The agency feels that parents and 
caregivers who purchase a child restraint for their vehicle based on 
this program should have the option to use it in all appropriate 
seating locations. This is especially important when the family grows 
and child restraints are often moved from the center to the two 
outboard seating positions or from the second to the third row. 
However, the pilot study showed that it may be difficult for vehicle 
manufacturers to meet this condition for participation. In a number of 
cases, an excellent fit was possible in outboard seating positions, but 
not in the center position, or vice-versa. Accordingly, although the 
agency tentatively believes that this stipulation is necessary, we are 
requesting comment on whether we should permit a CRS to be identified 
by the vehicle manufacturer as fitting its vehicle even if the CRS does 
not fit in all seating positions. Although we would like eventually to 
list only those child restraints that fit unconditionally in vehicles, 
should we accept, at this point in the program, a listing of CRSs that 
fit in only certain seating positions? Limitations on CRS use in the 
vehicle could be noted on Safercar.gov. We question whether requiring 
that a CRS fit all seating positions in all rows (except the driver's 
seat row) may result in reduced vehicle manufacturer participation in 
the short term and no CRS being listed for a number of vehicles on 
Safercar.gov.
    Although vehicle manufacturers must ensure that recommended child 
restraints fit for all applicable modes of their use, the agency has 
tentatively decided to allow the manufacturer to specify that a child 
restraint fits when installed with either LATCH or the vehicle seat 
belts (plus top tether, if applicable). Of course, it is most ideal for 
a child restraint to fit correctly using either method of installation. 
However, the agency's pilot study revealed that requiring both methods 
for this program would make it difficult for many manufacturers to 
participate. Depending on the vehicle design, either a LATCH or seat 
belt installation was found to be problematic for many of the CRS 
selected for the pilot study, but not necessarily both.
    The agency feels that giving the vehicle manufacturers the option 
to assess fit for either LATCH or seat belt installations will likely 
result in better participation and useful information for consumers. 
This approach can alert consumers to incompatibilities related to LATCH 
anchor spacing, seat belt length, buckle stalk length, etc., that they 
may not have been otherwise aware of, hopefully decreasing the number 
of incorrect installations in the field. The agency also suspects that 
some vehicle manufacturers will be interested in making design changes 
to increase the number of child restraints that can achieve a proper 
installation in their vehicle(s) with either LATCH or seat belts. The 
agency recognizes, however, that making vehicle improvements to either 
system can require some lead time. Consequently, in the interim, 
manufacturers can provide consumers with fit suggestions based on 
either child restraint installation method.
    The agency is also proposing that to participate in the Vehicle-CRS 
Fit program (i.e., to have the CRS information included on 
Safercar.gov), vehicle manufacturers need to identify at least three 
current model year child restraints within each of three different 
categories: rear-facing, forward-facing, and booster. We are proposing 
to condition participation on listing restraints in all type/age 
categories as a way to encourage manufacturers to address 
systematically and comprehensively the issue of CRS fit for all ages 
and sizes of children. These categories were also chosen because they 
follow NHTSA's 4 Steps for Kids program.
    Child restraints within each of the three type/age categories 
should also be from three different child restraint manufacturers. This 
condition for participation is being proposed to encourage vehicle 
manufacturers to work with a variety of child restraint manufacturers 
and products. It will also discourage a vehicle manufacturer from 
forming partnerships with only one child restraint manufacturer and 
thus minimize consumer confusion or belief that only one brand of child 
restraint is acceptable for use in their vehicle. Also, NHTSA believes 
that this condition may give manufacturers with low volume child 
restraint models the opportunity to gain additional exposure. To 
satisfy the booster category, we are proposing that no more than one of 
the three booster seats can be a dedicated backless booster. This 
condition is being proposed for a few reasons. For one, most backless 
boosters have higher minimum height and weight requirements than their 
high-back counterparts. Therefore, requiring more high-back boosters in 
order to participate serves to cover a greater range of child sizes. In 
addition, some high-back boosters are designed such that the back can 
eventually be removed and used as a backless booster when the child 
reaches a certain height. In this, there are a number of products on 
the market that are both styles in one and would have to be evaluated 
for fit in both high-back and backless modes anyway. Further, the 
agency suspects that due to their increased complexity, high-back 
boosters will likely exhibit more fit complications.
    The agency is tentatively proposing to not permit vehicle 
manufacturers to recommend fewer than three child restraints for any 
one of the three categories (rear-facing, forward-facing, and booster); 
recommendations of only one or two child restraints for any one 
category will not be posted on Safercar.gov. The agency questions 
whether this approach is appropriate or whether providing one or two 
recommendations for any one category may better serve consumers than 
providing no CRS recommendations for a particular category. Comments 
are requested on this issue.
    Since it is generally advisable for parents to keep children in a 
harness for as long as possible to ensure the highest level of crash 
protection, the agency is proposing to further stipulate that at least 
one high-weight harness CRS be identified in the forward-facing 
category. These high-weight harness CRS are child safety seats that 
allow use of internal harness systems on children weighing more than 40 
pounds. If a vehicle manufacturer has fulfilled the basic program 
participation conditions, they then have the option of also 
recommending ``All-in-one,'' ``three-in-one,'' and built-in child 
restraints. Recommendations made for these CRS types, however, are 
optional. They would have to be in addition to those made for child 
restraints outlined previously as conditions for participation. Figure 
1 depicts the acceptable types of CRS that can be recommended within 
each of the three main categories.

[[Page 10643]]

[GRAPHIC] [TIFF OMITTED] TN25FE11.029

    The agency's last proposed condition for participation in this 
program regards price points. Within each of the three categories 
(rear-facing, forward-facing, and booster), vehicle manufacturers must 
identify products that meet established price categories based on the 
child restraint's Manufacturer's Suggested Retail Price (MSRP). The 
proposed price points for each category, which were established based 
on a survey of model year 2009 CRS, are shown in Table 1. These price 
points were established so that CRS selection is not limited to the 
most expensive child restraints available, and again to ensure a 
variety of CRS makes and models. A child restraint does not need to be 
expensive to provide adequate crash protection. Likewise, the agency 
wants to encourage through this program that a child restraint does not 
need to be expensive in order to fit properly in one's vehicle. If a 
vehicle manufacturer would like to fulfill only the minimum conditions 
for participation for three child restraint recommendations in a 
particular category, they must include at least one restraint that 
falls in the ``inexpensive'' range and at most one restraint in the 
``expensive'' range. If more than three child restraints are 
recommended for any one category, the additional child restraints may 
fall within any price point the vehicle manufacturer chooses. The 
agency is proposing to provide vehicle manufacturers with this price-
point information with the Buying a Safer Car information request and 
plans to re-evaluate the price points as needed. Comments are requested 
on this approach.

                                    Table 1--Price Points for CRS Categories
----------------------------------------------------------------------------------------------------------------
                                                          Rear-facing       Forward-facing          Booster
----------------------------------------------------------------------------------------------------------------
Inexpensive.........................................              < $100              < $130               < $80
Moderately Expensive................................           $100-$200           $130-$230            $80-$100
Expensive...........................................              > $200              > $230              > $100
----------------------------------------------------------------------------------------------------------------

B. Program Administration

    The agency proposes that the easiest way to collect child restraint 
and vehicle fit suggestions is through NCAP's annual Buying a Safer Car 
information request since vehicle manufacturers are already familiar 
with its submission process. Though participation in this program would 
be voluntary, the agency would also need to ensure that any fit 
information it receives from manufacturers is correct. As in the pilot 
study, the agency could rent or lease vehicles to spot-check child 
restraints identified by vehicle manufacturers as fitting specified 
vehicles. Using the final versions of the evaluation forms proposed in 
this document, the agency would spot-check the vehicle-CRS fits 
identified by the vehicle manufacturers.\22\
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    \22\ Similar to how NHTSA conducts its EOU program, the agency 
is proposing that two two-person agency teams would spot-check fit 
recommendations in the same vehicle. If both teams did not reach 
similar conclusions about whether a CRS meets the fit requirements 
for a particular vehicle, another NHTSA representative would make 
the final determination.
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C. Program Distribution

    The agency is proposing that the vehicle-CRS fit combinations 
identified by vehicle manufacturers be published via the Safercar.gov 
Web site, the agency's main consumer information portal. Adding this 
information to Safercar.gov can provide consumers with the best 
available vehicle-CRS fit information and provide market incentives 
among manufacturers. In the past, this has helped to ensure the success 
of voluntary programs such as the agency's side air bag out-of-position 
testing initiative through NCAP.\23\ Nearly every vehicle manufacturer

[[Page 10644]]

voluntarily participated in this program within two years. The agency 
has also taken a similar approach in MY 2011 for promoting vehicles 
with advanced crash avoidance technologies.\24\ Though this program 
does not assess the occupant protection afforded by a particular 
vehicle-CRS combination in a crash, the agency believes that giving 
consumers information on whether a child restraint may be installed 
properly in a vehicle does provide indirect safety benefits. By 
providing consumers with information about child restraints that have 
been successfully installed in particular vehicles, the agency seeks to 
improve consumers' confidence in and comfort with selecting and using 
CRSs, and to reduce installation mistakes in the field.
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    \23\ Each year, vehicle manufacturers provide evidence to the 
agency that they have conducted (and passed) a series of tests 
designed to assess the aggressivity of side air bags with respect to 
out-of-position occupants. Participating vehicle manufacturers are 
given credit on Safercar.gov in exchange for providing this data.
    \24\ Federal Register Volume 72, No 175, 51908-51973. September 
11, 2009.
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    For the Vehicle-CRS Fit program, the agency is proposing to display 
all suggested child restraints along with information pertaining to 
vehicle star ratings and safety features. As is the case in the Ease of 
Use program, NHTSA plans to minimize consumer confusion by emphasizing 
to consumers that the child restraint suggestions are not 
recommendations based on the CRS or vehicle's safety performance. 
Furthermore, to reduce manufacturer concerns that displaying particular 
child restraint suggestions on Safercar.gov will imply that assessments 
are an indicator of occupant safety in the event of a vehicle crash, 
the agency proposes to add a disclaimer to the Vehicle-CRS Fit 
assessment section of the Web site which will state, ``NOTE: The 
restraints above have been determined to fit successfully in this 
vehicle via the method(s) listed. This is an assessment of installation 
ONLY and should NOT be considered a safety claim for the vehicle or the 
child restraint. ALL child restraints and vehicles sold in the United 
States must pass rigorous Federal standards. Child restraints provide 
high levels of safety when selected to be age- and size-appropriate for 
the child and properly installed.''
    In addition, it will be further explained that the child restraints 
listed may not be the only products that can achieve a successful 
installation in that vehicle. To address concerns that parents and 
caregivers may believe that child restraints listed on Safercar.gov are 
the only CRS that are acceptable for their child and that will fit in 
their vehicle, the agency proposes to also include the following note: 
``This list of child restraints is not all-inclusive. Vehicle 
manufacturers voluntarily provide this information for parents and 
caregivers as a starting point to help them select a child restraint 
that fits their child and fits their vehicle. You may find other child 
restraints that fit equally as well as those presented above. Also, you 
may contact a Child Passenger Safety Technician (CPST) in your area to 
check that your child seat both fits and is installed properly in your 
vehicle by clicking here: https://www.nhtsa.gov/cps/cpsfitting/
index.cfm.''
    If, during spot-checking activities, a child restraint is found to 
not meet the fit assessment criteria, NHTSA is proposing to remove that 
information from Safercar.gov Web site. This is consistent with 
removing the ``M'' from vehicles determined not to meet the side air 
bag out-of-position testing requirements. The same strategy was 
employed when spot-checking the performance of certain crash avoidance 
technologies for MY 2011 vehicles and beyond. If the deletion of that 
child restraint means the vehicle no longer meets the participation 
conditions for that category, the agency proposes to give the vehicle 
manufacturer the opportunity to indicate another child restraint, which 
will be checked for fit by the agency. If no alternatives can be found, 
and the vehicle no longer meets the program's participation conditions, 
it is proposed that all child restraint suggestions for that vehicle 
will be deleted from Safercar.gov. Alternatively, the agency proposes 
to allow the vehicle manufacturer to contest the result from the spot-
check test by demonstrating that the restraint in question fulfills the 
fit assessment criteria. Such a challenge will be reviewed by agency 
staff and a decision will be made as to whether the restraint meets the 
assessment criteria for ``fit'' and hence, the listing of the child 
restraint.
    For each vehicle model, the agency envisions a detailed page on 
Safercar.gov that shows consumers the child restraints that have been 
indicated as appropriate for all vehicle seating position in the three 
categories--rear-facing, forward-facing, and booster. We also propose 
to indicate LATCH availability in the vehicle and whether the 
manufacturer has indicated each child restraint fits properly using 
vehicle seat belts, LATCH, or both. Having a dedicated Web page will 
also give the agency the opportunity to reinforce important principles 
and programs such as 4 Steps for Kids and the CRS Ease of Use program. 
Consumers will be shown the height and weight ranges for the child 
restraints of interest. The agency also intends to link consumers to 
other areas of child passenger safety on NHTSA's Web site as well as 
offer installation tips and best practice guidance.
    The agency intends to use this Web site to disseminate any 
installation notes that the vehicle manufacturer may need to 
communicate. Such additional information can include, but would not be 
limited to: Front seat positioning along the seat track, sharing of 
outboard lower anchorages to ``create'' a center LATCH position, 
instances in which using lower anchors or seat belts in certain seating 
locations eliminates the use of other positions, etc.

IX. Pilot Study To Assess Effectiveness of Preliminary Vehicle-CRS Fit 
Program Evaluation Criteria

A. Development of Vehicle-CRS Fit Evaluation Forms

    In deciding to model its Vehicle-CRS Fit program after the draft 
ISO CRS-Vehicle usability program, the agency wanted, most importantly, 
to draw on the concept of developing a set of standard criteria to 
achieve the most repeatable assessments possible. The agency believed 
that developing standard evaluation forms would be the most beneficial 
approach for both vehicle manufacturers and consumers. The consumer 
information program would be enhanced if vehicle manufacturers, CRS 
manufacturers, consumers, and NHTSA have a common understanding of what 
the program considers a ``proper fit.'' Vehicle manufacturers would be 
able to directly use these forms in their internal assessments and 
would have more certainty in knowing that NHTSA will agree with their 
assessments of fit. Without a set of evaluation criteria, it could be 
possible for some vehicle manufacturers to submit data to the agency 
that does not meet NHTSA's expectations for a proper installation. In 
addition, if varying criteria were used, the agency might not be able 
to assist consumers in understanding what a manufacturer's fit 
recommendations constitute.
    As mentioned previously, to ensure a robust assessment, the agency 
reasoned that only objective criteria should be considered for the 
Vehicle-CRS Fit program. Accordingly, the agency's program will not 
assess how easily a child restraint can be installed in a vehicle, but 
will simply assess whether it can be installed successfully (i.e., 
whether the child restraint can fit in the vehicle). Although this is 
somewhat contrary to the draft ISO CRS-vehicle usability program, NHTSA 
believes there is subjectivity in the draft ISO criteria concerning the 
assessment of the ease of fit (such as those that require the

[[Page 10645]]

evaluator to assess the ease of performing a task).
    The agency has tentatively determined that the best way to 
objectively evaluate CRS fit in vehicles is to develop criteria based 
on factors known to influence installation, as outlined in the National 
Child Passenger Safety Certification Training Program student 
manual.\25\ The agency considered both general installation techniques 
(i.e., those that are required for all child restraint installations), 
as well as specific techniques that may be necessary for installation 
of certain types of child restraints or particular modes of use, such 
as ensuring that infant and rear-facing convertible restraints can be 
installed to the proper recline angle, ensuring that seat belts are of 
adequate length to install CRS with multiple belt paths (both long and 
short), and that the carry handle on infant restraints can be 
positioned according to manufacturer instructions. The agency was 
careful to incorporate vehicle features that influence proper CRS fit, 
such as top tether anchorages, lower anchorages, vehicle seat belts, 
and vehicle head restraints. In addition, we added criteria surrounding 
CRS installation tightness, and maximum weight limits of LATCH 
anchorages, as each of these factors can also dictate vehicle-CRS 
compatibility. It should be noted that many of the factors that were 
determined to be influential to achieving proper CRS installation based 
on the CPST student manual, including attachment to lower anchors, 
ability to tighten lower attachments once they are connected to lower 
anchors, maximum side-to-side and front-to-back movement of the CRS 
once it is installed, operation of the CRS harness once the CRS is 
installed, and tightening of the top tether once it is attached to the 
tether anchor, also mimicked criteria included in the draft ISOFIX 
usability standard.
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    \25\ The National Child Passenger Safety Certification Training 
Program is a curriculum designed to teach participants about the 
importance of child safety and how to properly install child 
restraints. Certified technicians, CPSTs, are equipped with the 
knowledge to explain installation procedures to parents and 
caregivers so that they may safely transport their families, and to 
empower them with the knowledge to confidently install and reinstall 
child restraints as needed. The training program, which is based on 
the concept of learning (the facts, skills, and information), 
practicing (the new skills and information), and explaining/teaching 
(what was learned to parents and caregivers), was developed by NHTSA 
in the mid-1990s and has been updated by the agency as needed. The 
National Child Passenger Safety Board oversees the quality and 
integrity of the training and certification requirements, while Safe 
Kids Worldwide administers certification. CPSTs receive hands-on 
experience through a variety of activities, including child safety 
seat checks, and their exposure to common installation problems, 
incompatibility issues, general knowledge of child restraints and 
features, make them a valuable resource for parents and caregivers 
seeking child restraint installation assistance.
---------------------------------------------------------------------------

    Comments are requested on our use of the National Child Passenger 
Safety Certification Training Program student manual and the manual's 
determinations as to whether a CRS fits a vehicle. The benefits of 
using the manual are that the criteria contained therein have been used 
in the child passenger safety community for years as determinants of 
CRS fit. Accordingly, the manual serves as the primary guide to proper 
CRS installation and is a prominent child passenger safety resource. 
The installation criteria included in the manual are based on common 
sense, simplicity, and a ``best practices'' perspective. Furthermore, 
the agency's pilot study confirmed that applying the criteria outlined 
in the CPST manual resulted in secure CRS installation. However, 
because the agency is unaware of any test or accident data supporting 
some of the criteria specified for proper installation, the agency does 
not know if certain criteria