Rear Seat Safety: Test Procedures + Design Recommendations - October 2021
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ABOUT THIS REPORT Objectives In September 2021, Consumer Reports published its first-ever Rear-Seat Safety Score. The ratings are based on the results of child safety tests as well as the presence of key safety technology. As more data is collected, ratings will expand to include more vehicles. In line with CR’s mission to create a fair, safe, and consumer-driven marketplace, this report has been written for the industry to provide more explanation and guidance on the state of rear-seat safety. It includes the following safety issues and best practice recommendations: 1) Child Seat Fit 2) Non-Belted Rear Seat Occupants 3) Lack of Advanced Rear Seat Belt Systems 4) Lack of Rear-Seat Airbag Systems 5) Lack of Effective Rear-Seat Head Restraints 6) Vehicular Heatstroke for Child Occupants Is this testing part of CR’s Overall Score? At this time, the Rear-Seat Safety Score is not included in the vehicle's Overall Score, but CR is considering adding or removing points for these systems in the future. Any changes to CR’s methodology and ratings will be communicated to the industry in advance. ABOUT CONSUMER REPORTS Consumer Reports is an independent, nonprofit member organization that works side by side with consumers for truth, transparency, and fairness in the marketplace. CR empowers and informs consumers, incentivizes corporations to act responsibly, and helps policymakers prioritize the rights and interests of consumers in order to shape a truly consumer-driven marketplace. For more information, please visit consumerreports.org. To download additional auto safety reports, join our mailing list, and learn about CR Data Intelligence—a marketplace change program that fosters the development of products, standards, and policies that prioritize safety, security, performance, and quality for consumers—visit data.consumerreports.org or email dataintelligence@cr.consumer.org. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 2
INTRODUCTION AND BACKGROUND ● Front-seat occupants have benefited greatly from advancements in vehicle structure and advanced restraint systems. ● Crash evaluations like those conducted through the U.S. New Car Assessment Program (NCAP), the European New Car Assessment Programme (Euro NCAP) and the Insurance Institute for Highway Safety (IIHS), which have focused on front-seat performance, are largely responsible for these improvements. ● But those same tests typically have not included dummies in the rear seats. The U.S. federal safety regulations for occupant restraints also do not focus on the rear seat. ● There are no dynamic test standards for rear seat belts. ● Overall, rear-seat safety advancements have lagged, resulting in inequitable improvement. ● The demographics of rear-seat occupants have also changed. Rear seats are not just for children in the backseat anymore. With the increasing prevalence of rideshare and a greater focus on environmentally-friendly options, such as carpooling, more adults are riding in the rear seat. ● Recent research points to the fact that the comparative safety benefits once seen for rear-seat passengers may no longer be as clear, as there have been marked improvements to front-seat safety. ➢ Consumer Reports believes now is the time for manufacturers and regulatory authorities to start paying more attention to the rear seats. Applying proven safety technologies to the rear seats, incorporating rear seats into current NCAP testing, and innovation are all required to reach Vision Zero (the goal of zero road fatalities). REGULATORY AND CONSUMER INFORMATION GAPS ● U.S. Federal Motor Vehicle Safety Standards (FMVSS) and consumer information programs, such as the U.S. NCAP and crash-safety ratings from the Insurance Institute for Highway Safety (IIHS), currently evaluate injury risk for only front-seat passengers in frontal impacts. ● Side-impact simulations using side barrier tests for both U.S. NCAP and the IIHS do include a rear seat passenger on the struck side of the vehicle. ● Automakers lack adequate impetus to make similar improvements for the rear seats. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 3
Crash Tests that include rear dummies: __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 4
Technologies for improvement: For rear passengers of all ages to be effectively protected, here are the safety features that are often implemented for front seats and that hold the greatest technology advantages for improving outcomes for rear-seat passengers as well. ✅ = standard equipment for most vehicles. *Based on NHTSA Safer Car Database for 2021 model year vehicles **Based on CR’s Test-Vehicle Fleet & NHTSA Safer Car for 2020 and 2021 model year vehicles. [next page] __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 5
I. Safety Issue: Child Seat Fit ● While child-seat use rates are relatively high, National Highway Traffic Safety Administration (NHTSA) data regarding misuse indicates that as many as 46% of child seat installations include some critical misuse that could have an adverse effect on a child’s safety in a crash. ● CR has been evaluating child-seat fit in the rear seats of tested vehicles for more than 25 years. ● CR’s ratings are based on the ability to obtain a secure installation with the seat belts in each unique seating position, lower LATCH anchor and top-tether accessibility, and the ability to fit three child seats across the second-row seat. ● The IIHS LATCH ratings for vehicles have driven the industry to improve lower anchor and top-tether accessibility and labeling. However, lower LATCH anchors have a 65-pound combined weight limit of a child and a child seat. As a result, many child seats will still need to be secured with the vehicle seat belt. ● Lower anchors are also not typically available for the center seating position and many parents want to be able to secure their child in the middle seat. Therefore, the influence of rear-seat geometry and seat-belt geometry is often overlooked by vehicle manufacturers. ● In addition to vehicle ratings, CR also conducts comprehensive ratings of child seats. CR’s child-seat ease-of-use and fit-to-vehicle ratings are intended to indicate a parent’s or caregiver’s potential to achieve a secure installation and correct use of child seats in their own vehicle. Best Practice Recommendations: Child Seat Fit Because child seat fit is subject to a wide array of variables and differences in compatibility between the vehicle and the child restraint, rather than define best practice criteria, we propose the following guidelines for potential areas of improvement for child-seat fit: ● Potential areas for improvement for secure seat-belt installations across child-seat types across rear-seating positions include: ○ Belt anchor points that are not so far forward of the vehicle seat bight that they preclude tightening in toward the vehicle seatback ○ Belt buckle stalks that are short enough to prevent them from entering the child restraint belt path and/or presenting at angles that preclude tightening ● Lower anchors that are easy to access with sufficient area surrounding them that is devoid of cushion foam, fabric or other hardware ● Lower anchors that are present in additional seating positions including third row seats ● Lower anchors for rear center seating positions or allowances for center installations using “borrowing” of outboard inner anchors ● Tether anchors that can be accessed from the rear seat without having to go through the cargo area, remove the cargo cover, or remove the rear head restraint ● If vehicle geometry allows, space to fit three child seats across the second row (rear-facing infant seat, highback booster, and forward-facing convertible seat) ● Vehicle owner’s manual instructions for child seat installations should match rear seat geometry and reference U.S. child-seat categories (rear-facing only, convertible, etc.), rather than European weight/seat types (0/0+, 1 etc.) __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 6
Booster Use CR’s booster use evaluation examines fit and buckle access in each unique seating position using a highback booster. Each seating position is treated as an isolated position as if there are no other rear passengers currently seated alongside. Best Practice Recommendations: Booster Use Booster use is also subject to many contributing variables, all of which cannot be accounted for by defining best practice criteria. Therefore we propose the following guidelines: ● Easy, one-handed buckle access—easier with rigid rather than flexible buckle stalks ● Booster can sit stably on the vehicle seat cushion ● Booster can sit flush against the vehicle seat back ○ Head restraint design that doesn’t interfere with highback booster designs and that doesn’t require the removal of the head restraint ● Booster fits between seating position’s belt anchor spacing without overlapping with adjacent seat buckles ● Vehicle owner’s manual booster installation instructions should match rear-seat geometry Proposed Policy Countermeasure: Updated Child Restraint Related Standards ● The current Federal Motor Vehicle Safety Standard (FMVSS) that governs compliance for child seats, FMVSS 213, is based on vehicle geometries from the 1970s and crash pulses that may not reflect the pulse characteristics from current model vehicles. The dynamic testing elements of the 213 standard should be reviewed and overhauled so that child-seat performance reflects testing that better reflects current model vehicles. ● Only recently were changes proposed to that standard that include elements such as a 3-point lap-and-shoulder belt rather than a lap-belt only. ● The current standard also lacks a dynamic test ensuring child-seat performance in side impact crashes as mandated by the Transportation Recall Enhancement, Accountability, and Documentation Act (TREAD) in November 2000. ● The standard that governs child restraint anchorage systems in motor vehicles (FMVSS 225) is also in need of updating. While the IIHS ratings for LATCH accessibility have improved ease-of-use, they are a consumer information program and not a mandate. Updated language to assure easier use, including providing a larger area surrounding LATCH anchors and improved labeling for top-tether anchorage points, should be pursued. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 7
II. Safety Issue: Non-Belted Rear Seat Occupants ● Seat-belt usage is an occupant’s first line of defense in a crash. However, rear seat-belt usage is reportedly lower than front seat-belt usage (79.6% vs 89.1%, respectively, NHTSA 2019). ● Seat-belt use is key to assuring non-fatal outcomes as evidenced by the fact that 58% of rear occupants killed in passenger cars in 2019 were unrestrained (NHTSA Traffic Safety Facts - Occupant Protection 2019). ● NHTSA data suggests that seat belts saved 329,715 lives between 1960 and 2012. More recently, IIHS estimates that seat belts saved an estimated 14,955 lives in 2017. ● An unbuckled occupant also puts other occupants in the vehicle at risk. Research shows that exposure to unbelted occupants increases the risk of injury or death to other occupants in the vehicle by 40% (MacLennan et al., 2004). In a frontal crash, an unbelted rear-seat passenger sitting behind a belted driver increases the risk of fatality for the driver by 137% compared with a belted rear-seat passenger (Bose et al., 2013). ● Belt use is also critical for the protection of children. The NHTSA Fatality Analysis Reports System (FARS) 2019 data shows that 43% of 8-12 year olds (booster-aged) and 55% of 13-14 year olds (seat-belt only) were unrestrained when killed in motor vehicle crashes. ● It is also recommended that children remain seated in the rear seat until they are at least 13 years old. Therefore, for rear occupants between the ages of 6 and 13 years old, a rear belt minder would be most beneficial. Notes: Children are defined as 14 years old and younger. “Child occupants” includes both passengers and drivers. Percentages represent only child passenger vehicle occupants whose restraint use is known. Sources: NHTSA, Fatality Analysis Reporting System (FARS) 2019 Annual Report File Additional Resources: NHTSA, Car Seats and Booster Seats __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 8
Proposed Technology Countermeasure: Rear Seat-Belt Minders/Reminder ● Seat-belt minders that prompt occupants to buckle their seatbelts are required for the driver and are nearly ubiquitous for the front passenger seat of current model vehicles, but this technology is only found in a handful of models for rear-seat positions. ● The presence of front belt minders has shown to be effective at increasing belt use, with estimates that around 80% (82.2% +/− 8.6%) of the drivers that do not buckle up when there is no seat belt reminder do buckle up when in cars equipped with a seat belt reminder that has a light signal and an associated loud and clear audible warning (A. Lie et al., 2008). The following tables indicate the percentage of Consumer Reports rated vehicle models per brand that come equipped with rear belt minders. Current Market Penetration: Rear Belt Minders 2021 Model Year Table 1: Rear Belt Minder Availability by Brand (MY2021 Consumer Reports rated models) (Data source: NHTSA Safer Car Database, FTP upload dated July 13, 2021) __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 9
Best Practice Recommendations: Rear Belt Minders ● In order to be most effective, rear belt minders should be implemented as a two-tier system: buckle-up reminder and unbuckled status alert. Both of these systems should be factory default on and standard equipment across all trims. The buckle-up reminder is an ignition-on alert for rear passengers. Ideally the system should detect an occupant in each rear seating position and alert accordingly. The alert should be: ● Multimodal: have both a visual and audible component ● Multistage: the audible alert increases in frequency and/or volume and, thus, escalates if the passenger does not buckle up ● Prominently visible: The visual alert should be placed in a prominent location visible to the driver—in the driver’s “line of sight” rather than offset from gauges. The unbuckled status alert occurs if a rear passenger unbuckles at any point during the trip and would ideally be specific to each rear seating position. The alert should be: ● Multimodal: have both a visual and audible component; the alert should be multimodal at all speeds, including when at a stop or parked ● Multistage: the audible alert increases in frequency and/or volume (escalates) if the passenger does not buckle up ● Prominently visible: the visual alert should be placed in a prominent location visible to the driver ● Not turn off independently: the system should require action to turn off the alert completely or dismiss the alert from the driver’s view Only 13 of 35 CR rated MY21 & MY22 test vehicles are equipped with rear belt minders. Proposed Policy Countermeasure: Standard Rear Belt Minder ● The Moving Ahead for Progress in the 21st Century Act of 2012 (MAP-21) directed NHTSA to initiate a rulemaking proceeding to amend FMVSS No. 208, “Occupant crash protection,” to require a seat-belt use warning system for rear seats. NHTSA initiated a rulemaking proceeding in 2013, and has continued with an Advanced Notice of Proposed Rulemaking (ANPRM) in September 2019. CR supported the addition of belt minders for the rear seats and shared aspects of its “best practices” in public comments to the proposed rulemaking docket. CR supported NHTSA moving expeditiously to a proposed rulemaking, but that has not happened yet. ● All U.S. states, except New Hampshire, currently require seat-belt use in the front seats. But the level of enforcement varies. According to IIHS, belt laws have been shown to increase belt use, especially with publicized enforcement. Belt use rates are higher in states with primary enforcement laws, which allow police to stop a driver solely for not using a seat belt. In states with secondary enforcement, police can only enforce the belt law if they have pulled over the driver for another violation first. Primary enforcement should be considered at the state level for all states. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 10
The graphic below indicates the current state laws requiring seat belt use: Source: IIHS __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 11
III. Safety Issue: Lack of Advanced Rear Seat Belt Systems ● While seat belts alone are a key injury and fatality prevention measure, features of advanced seat belts can actually help them improve injury outcomes in frontal crashes still further, and reduce some less life-threatening injuries caused by the seat belts themselves. ● Adjustable upper shoulder belt anchors can help improve belt fit and comfort, likely encouraging greater use. ● Pretensioners and load-limiters are technologies designed to make seat belts more effective. Pretensioners retract the seat belt to remove excess slack almost instantly upon sensing the vehicle has crashed. Load-limiters allow the belt to “give” or yield when forces on the belt rise above a predetermined level by allowing some webbing to loosen as a vehicle occupant moves forward. ● Like belt minders, adjustable upper anchor locations, pretensioners and load-limiters are nearly ubiquitous in current model vehicles for the front seats but are not often found for rear seats. ● NHTSA research compared fatality data for vehicles with model years between 1986 to 2011 to determine the fatality-reducing effectiveness of seat belts with and without pretensioners and load-limiters. In passenger cars, crossover SUVs (CUVs), and minivans, a belted driver or right-front passenger has an estimated 12.8% lower fatality risk if the belt is equipped with a pretensioner and a load-limiter than if it is not equipped with either (DOT HS 811 835 November 2013: Effectiveness of Pretensioners And Load-Limiters for Enhancing Fatality Reduction By Seat Belts). ● In comparing potential benefits for head injury specifically, additional research in 2015 found that seat belts with pretensioners reduced head injury criteria—HIC 15 and HIC 36—by 50% or more compared to non-pretensioned belts on 5th percentile females and 50th percentile males in the rear seat. Load-limiters in conjunction with pretensioners resulted in another 10% reduction in HIC. (Tavakoli et al., 2015) ● While never required by federal standards, NHTSA has encouraged implementation; the understanding is that pretensioners have potentially contributed to improved ratings in frontal crash evaluations. Proposed Technology Countermeasure: Rear Advanced Restraint Systems ● There is a wide variability across rear occupant types including children, adults, and the elderly. The physiological and anthropometric (body measurements) differences across these passenger types must be considered as well as their varying injury thresholds. ● Additionally, advanced restraint systems must also be compatible with child-seat installations. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 12
Best Practice Recommendations: Rear Advanced Seat Belts These seat belt features would be evaluated in two phases: phase 1 (P1) would be for rear outboard seats and phase 2 (P2) would be the rear center seat. They address both occupant comfort and crash protection and should be standard equipment across all trims. ● Adjustable upper shoulder belt anchors (P1) ○ Belt discomfort (caused by improper belt fit) is often cited as a reason for why rear occupants don’t wear their seat belts or wear the belt incorrectly, i.e., the shoulder belt under the arm or behind the back. ○ The ability to adjust the upper shoulder belt anchor can improve belt fit, thereby improving belt comfort and increasing belt usage. ● Seat belt pre-pretensioners (electromechanical seat belt retractors) (P1, P2) ○ These reversible, pre-crash systems remove slack in the seat belt and improve belt fit; examples include the BMW/Mercedes-Benz Pre-Safe system that snugs up the belt when a passenger buckles up. ● Seat belt pretensioners (P1, P2) ○ Pretensioners are typically a non-reversible, pyrotechnic seat belt retractor system that fires at the early stages of a crash to remove slack from the seat belt. This ultimately ties the occupant to the vehicle seat and helps to reduce the transfer of crash forces to the occupant. This system, while not required for the front seat, is largely implemented for the driver and front passenger seats and has shown to reduce their injury risk. ● Seat belt load-limiters (P1, P2) ○ Load-limiters are designed to decrease the maximum seat belt force applied to the chest during a crash; they accomplish this by releasing a controlled amount of seat belt webbing. Only 15 of 35 CR rated MY21 & MY22 test vehicles are equipped with advanced rear seat-belt features. [next page] __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 13
Current Market Penetration: Rear Seat Belt Pretensioners 2021 Model Year Table 2: Rear Seat Belt Pretensioner Availability by Brand (MY2021 Consumer Reports rated models) (Data source: NHTSA Safer Car Database, FTP upload dated July 13, 2021) Current Market Penetration: Rear Seat Belt Load Limiters 2021 Model Year Table 3: Rear Seat Belt Load Limiter Availability by Brand (MY2021 Consumer Reports rated models) (Data source: NHTSA Safer Car Database, FTP upload dated July 13, 2021) __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 14
Proposed Policy Countermeasure: Rear Advanced Restraint Systems ● Consumer information programs such as the U.S. NCAP should be expanded to include rear-seat evaluations which in turn can help promote rear-advanced seat belts as an effective countermeasure. ● Current NCAP proposals include updates to the current full frontal barrier test that would add the Hybrid III 5th female in the second row behind the right front passenger. Both Hybrid III 5th females (the one for the front passenger seat and the new one in the rear seat) will be instrumented with the new RibEye Instrumentation for measuring chest deflection. Along with head contact to the vehicle interior, chest injury is a common injury for rear seat passengers. Those proposals have not yet been implemented as of this writing, however. ● The Insurance Institute for Highway Safety (IIHS) says that it plans to introduce new dynamic frontal tests that will include rear seat dummies in 2021. [next page] __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 15
IV. Safety Issue: Lack of Rear-Seat Airbag Systems ● According to NHTSA, frontal airbags have saved an estimated 42,856 lives (1960–2012). ● While frontal airbags that minimize injury and death have grown significantly to include side torso and knee airbags, currently only side curtain airbags that protect against head injury and ejection in side impact crashes are commonplace for the rear seats. ● Most rear seats lack frontal and side torso airbag countermeasures. The lack of “housing” for frontal airbags, such as the dash, and the variation in spacing between front and rear seats, makes airbag implementations for rear seats more challenging. Current Market Penetration: Rear Seat Airbags ● As of the 2021 model year, only Mercedes-Benz has included frontal airbags for rear seat occupants in their S-Class sedans. As with other safety advances, the hope would be that proven effectiveness and additional adoption would both improve safety and reduce costs for more mainstream vehicle classes. The 2021 Mercedes-Benz S-Class is the first vehicle to include frontal airbags in the rear. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 16
Current Market Penetration: Rear Side Torso Airbags 2021 Model Year Table 4: Rear Side Torso/Pelvis Airbag Availability by Brand (MY2021 Consumer Reports rated models) (Data source: NHTSA Safer Car Database, FTP upload dated July 13, 2021) Best Practice Recommendations: Rear-Seat Airbags Airbags for the rear seat are another restraint technology that can reduce the risk of injury for rear occupants. These solutions may require more time and testing, therefore CR will look for them in phase 2 (P2) evaluations. Recommendations, which should also be standard equipment across trims, include: ● Side torso/pelvis airbags (P2) ○ These airbags provide protection to the torso and pelvis on the struck-side of the vehicle from contact with the hard surfaces of the vehicle door or any intrusion. ● Inflatable seat belts and/or frontal airbags (P2) ○ Inflatable seat belts provide head and neck protection during a frontal or oblique impact. ○ Other types of frontal airbags could also provide head protection from contact with the front seatback or occupant-to-occupant contact. ● Center airbags (P2) ○ These airbags would reduce occupant-to-occupant contact. Only 16 of 35 CR rated MY21 & MY22 test vehicles are equipped with rear airbags. The 2021 Kia Sorento & 2022 Mitsubishi Outlander lack a side curtain airbag (SCAB) in the third row. Proposed Policy Countermeasure: Rear Advanced Restraint Systems ● Consumer information programs such as the U.S. NCAP should be expanded to include rear seat evaluations, which, in turn, can help promote rear airbags as an effective countermeasure. Current U.S. NCAP proposals to include rear passengers may help to drive rear seat airbags as an injury countermeasure or other innovations for improving rear seat safety. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 17
V. Safety Issue: Lack of Effective Rear-Seat Head Restraints ● Head restraints are a key feature in the mitigation of whiplash-related injuries. By limiting the head movement rearward, they reduce the amount of whiplash of the head and neck forward. To do so, the head restraint must be of sufficient height for the seated occupant. ● According to the IIHS, an estimated 4 million rear collisions occur each year in the U.S. Neck sprain or strain is the most serious injury in one-third of insurance claims for injuries in all kinds of crashes. The annual cost of these claims exceeds $8 billion annually. ● Current federal safety standards require that all front and rear outboard seating positions have head restraints with a minimum height of 29.5 inches, but those requirements can be met with adjustable head restraints that require occupants to adjust them upward and do not apply to center rear seating locations. ● Some manufacturers use stowable head restraints to improve the driver’s rear visibility. These stowed designs flip the head restraint forward or overlap the seatback and are uncomfortable while stowed so they do force the passenger to adjust the head restraint. Other stowed restraints flip backward, are comfortable and don’t force the passenger to adjust the head restraint. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 18
Best Practice Recommendations: Rear Head Restraints Rear head restraints pose a dual challenge of balancing rear-impact protection and driver visibility. Recommendations include: ● At least 29.5 inch minimum height for all rear seating positions (as measured from the seat cushion to the top of the restraint). ● “Stowed” head restraints should be uncomfortable in their stowed position, forcing the passenger to adjust the head restraint into an appropriate use position that when in place— even in its lowest position—would be at least 29.5 inches. ● Rear head restraint design should encourage use but not be prohibitive to obtaining a secure child seat installation. If the head restraint has to be removed because of interference with a child restraint, then it is likely that the head restraint will either be kept loose somewhere in the vehicle (making it a projectile in a crash) or it will be stored away and not reinstalled when needed for an adult occupant. 22 of 35 CR rated MY21 & MY22 test vehicles have a rear head restraint height less than or equal to 29.5 inches. Proposed Policy Countermeasure: Rear Head Restraints ● Consumer information programs such as the U.S. NCAP should be expanded to include rear seat head restraint evaluations which in turn can help promote sufficient rear seat head restraints as an effective countermeasure against whiplash injury. ● NHTSA should expand the head restraint height mandate in FMVSS to include the rear center seating position. [next page] __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 19
VI. Safety Issue: Vehicular Heatstroke for Child Occupants ● While deaths from vehicle-related heatstroke happen less frequently than those resulting from crashes, the nature of these deaths deserves special attention. ● Vehicular heatstroke is the leading cause of non-crash, vehicle-related deaths for children younger than 14 years old (healthychildren.org). ● There have been 887 pediatric vehicular heatstroke (PVH) deaths since 1998 in the U.S. (noheatstroke.org). ○ 2021: 4 deaths / 2020: 25 deaths / 2019: 52 deaths / 2018: 53 deaths ○ U.S. average since 1998: 38 deaths/year ● Typically, these vehicular heatstroke deaths most commonly result from children unknowingly left in vehicles. However, reduced travel and more kids and families at home during the COVID-19 pandemic has meant an increased percentage of cases from children gaining access to the vehicle. Circumstances resulting in pediatric vehicular heatstroke deaths (1998-2020). Source: NoHeatStroke.org. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 20
Technology Countermeasure: Rear Occupant Alert/Reminder Systems ● While features such as auto-locking doors can prevent gained access scenarios, occupant reminder systems can reduce the chance of heatstroke events by detecting the child’s presence regardless of the means in which they entered the vehicle. ● Consumer Reports strongly advocates for vehicle-integrated heatstroke prevention technology. Some vehicle manufacturers have already begun to implement these types of systems into their vehicles, but there is room for improvement. Current Market Penetration: Rear Occupant Alert 2021 Model Year Table 5: Rear Occupant Alert Availability by Brand (MY2021 Consumer Reports rated models) Best Practice Recommendations: Rear Occupant Alert In order for these preventative technologies to be most effective, they should be factory-enabled and standard equipment across all trims. The alert should meet the following criteria: ● Occupant sensing/detection—gross movement and physiological movements for rear-facing and forward-facing children. Sensing capabilities should also extend to the cargo space. ● Multimodal (visual and audible) alert before exiting the vehicle ● Audible external alert after exiting the vehicle for end-of-trip reminder and for occupant sensing ● Multimodal alert at end of trip (ignition off), even if the rear door has been opened again during the trip ● Provide driver notification to email or phone (this option should be default set to notification ON and free) ● Technology to prevent gained-access scenarios (e.g., auto-locking for the vehicle doors) 29 of 35 CR rated MY21 & MY22 test vehicles are equipped with integrated heat stroke prevention technology. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 21
Proposed Policy Countermeasure: Rear Occupant Alert Systems ● There are multiple pending legislative proposals for a NHTSA rule on rear occupant alert systems. A bill passed by the U.S. House of Representatives in July 2021 included a requirement for all new passenger vehicles to come standard with a rear occupant detection and alert system. The Senate’s bipartisan infrastructure bill, which passed the chamber in August 2021 and is pending before the House, includes a requirement for all new passenger vehicles to come standard with a rear occupant reminder system; however, it would not specifically require an occupant detection system or similar technology that would address the risk of children gaining access to the vehicle on their own. Currently, it is unclear which measure will be enacted. ● Consumer information programs such as the U.S. NCAP should be expanded to include rear occupant alert evaluations as a recommended technology. ● Currently, the Euro NCAP 2025 roadmap contains a plan to reward manufacturers that include technological solutions for detecting the presence of a child in a car and alerting the car owner or emergency services as a means for mitigating child heatstroke occurrences. The Child Presence Detection evaluation will be effective in 2022. __________________________________________________________________________________________________________________________________________________ © 2021 Consumer Reports, Inc. DO NOT REPRINT WITHOUT PERMISSION 22
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