NHTSA Standards Inadequate?

rammer91 · Oct 28, 2015

Saw an interesting piece this morning about front seats that pass the NHTSA "pull test" which, in all practicality, is useless in determining whether or not a front seat will collapse backward if you are rear ended, potentially killing a child sitting in the back seat.

NHTSA requirements for car crash tests inadequate for testing fatalities from car seats - CBS News

I know the Model S is a very safe car, and I know one can't protect from all injuries or fatalities in a car accident, but I was struck by the fact that your standard metal-frame, card-table chair would actually pass the pull test, indicating it's not really useful for determining safety in a real life scenario. Even more shocking is that this issue has gone all the way back to the early 90's and nothing has changed since then.

I'm curious if anybody has any insights into how safe the Model S against this sort of "seat collapse" scenario?

Loving my 85D.

JohnQ · Oct 28, 2015

I thought that this quote from the agency was particularly well thought out:

It's important to keep in mind the requirements NHTSA and other government agencies must follow as we promulgate regulations such as the Federal Motor Vehicle Safety Standards. Those requirements are contained in statutes such as the Administrative Procedures Act and in Executive Orders issued by the President. Of particular interest here is the requirement that in "significant" rulemakings (a specific designation in the law), we are required to demonstrate benefits, and to consider whether the costs of a regulation would outweigh the benefits. These requirements are in place to ensure that federal agencies to not impose requirements without providing careful justification.

NHTSA has considered changes to its seating standards for years. The agency recognizes that the current standard is decades old, and it has received requests and formal petitions over the years to amend or strengthen the standard. In 2004, after several years of research and analysis, the agency formally terminated a rulemaking proceeding aimed at changing the standard. The agency did so for several reasons, but fundamentally the decision rested on the difficulty of providing data, as opposed to anecdotal evidence, for safety benefits of a change to the standard. This is an enormous challenge because the kind of high-impact rear-end crashes that are generally cited as justifying a change are relatively uncommon. For example, rear-impact crashes account for roughly 3 percent of all traffic fatalities; fatal crashes in which seat failure occurs and results in injury or death are even less common. Bottom line: The absence of data demonstrating real-world benefits meant the agency could not pursue a rule making.

Added emphasis is mine.

Gizmotoy · Oct 28, 2015

I have a 15 month old, and now I'm teary at work. "I thought maybe she had just fallen asleep." :crying: That family's story is terrible. Further argument for the center seating position, I suppose.

JohnQ said:
I thought that this quote from the agency was particularly well thought out

This one less so, in response to investigation showing more children killed by seat failures than by the huge defective airbag recall:

"You know - or should know - that the laws we must follow on rulemaking are significantly different than those involving safety defects. We do not have to provide cost-benefit analysis for defect determinations. That's not NHTSA's choice. That's the law. If you choose to mislead your viewers by comparing apples and hand-grenades, that is not NHTSA's fault. That is yours and yours alone. And if in misleading your readers you create the false impression that these two situations are in anyway comparable, and discourage them from addressing a safety defect that could cost their lives or the life of someone in their family, then you're failing them. The Takata comparison is specious and misleading, it harms rather than helps safety, and you should remove it from the story."

I get that the situations are different, but they're not that different. The result of both defects being dead humans, and the difference being one violated a current rule and another didn't. I'm not sure I buy that one of those is an apple and the other is a hand grenade, as the NHTSA put it.

EarlyAdopter · Oct 28, 2015

I'm glad there are at least two other agencies testing cars, and hopefully seats - IIHS and NCAP.

- - - Updated - - -

Fortunately, the Model S has had at least one real world test of a major rear end collision, in this case getting hit from behind by an 18 wheeler and knocked 100 feet off the road up an embankment, and came through fine. No mention of drivers seat collapse and in fact he was even able to drive it home, while the semi was disabled and had to be towed.

Vitold · Oct 29, 2015

After watching the video, I'm thinking that maybe non-folding seats on Model X maybe safer than if they were folding. It's incredible that seat standards are lacking like that. I wonder if European standards are the same?

From another article I found:

Ironically, the rear barrier impact crash testing required by FMVSS 301, the standard for fuel system integrity, demonstrates the inadequacy of FMVSS 207. During 301 rear impact tests at 30 mph, almost all bucket seatbacks and split bench seatbacks fail and strike the rear seats.[SUP][15][/SUP] Some manufacturers readily concede that their seatbacks are not designed to withstand dynamic rear sled or moving barrier tests at 30 or 35 mph, such as those encountered in NHTSA 30 mph compliance and NCAP 35 mph tests.[SUP][16][/SUP]

Vitold · Oct 29, 2015

JohnQ said:
I thought that this quote from the agency was particularly well thought out:
[...]
the difficulty of providing data, as opposed to anecdotal evidence, for safety benefits of a change
[...]
Added emphasis is mine.

If seats collapse during rear barrier impact crash test required by FMVSS 301, yet pass FMVSS 207 seat test, it is enough proof that FMVSS207 is inadequate and needs to be changed.

JohnQ · Oct 29, 2015

Vitold said:
If seats collapse during rear barrier impact crash test required by FMVSS 301, yet pass FMVSS 207 seat test, it is enough proof that FMVSS207 is inadequate and needs to be changed.

Wouldn't argue with that at all. They would simply need to demonstrate that injuries are the result of the failed seat alone and have sufficient data points that the statistics are reliable. Not that it should be too hard to do but without that correlation the industry could push back based on the requirements. Speaking callously, it's not just about the fact that the seats will fail, causing injury, but that the cost of the regulation exceeds the benefits of it being in place. Speaking personally, if that was my child I'd be driving this as hard as possible, including using the press to bully the NHTSA into a change and creating negative publicity for the auto companies.

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NHTSA Standards Inadequate?

rammer91

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Gizmotoy

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