Regulatory comments
Comments submitted by the Institute to regulatory agencies regarding various highway safety issues
All files 
| 2010 | Agency/Docket No. | Standard/part | Topic |
|---|---|---|---|
| February 1 | NHTSA-2009-0183 | 49 CFR 571.214: Side impact protection 49 CFR 571.216: Roof crush resistance 49 CFR 571.226: Ejection mitigation |
IIHS supports new safety standard to reduce partial and complete ejection of vehicle occupants through side windows in crashes, particularly rollover crashes |
| 2009 | |||
| December 1 | NHTSA-2009-0059 | 40 CFR 86: Control of emissions from new and in-use highway vehicles and engines 40 CFR 600: Fuel economy of motor vehicles 49 CFR 531: Passenger automobile average fuel economy standards 49 CFR 533: Light truck fuel economy standards 49 CFR 537: Automotive fuel economy reports 49 CFR 538: Manufacturing incentives for alternative fuel vehicles |
IIHS supports establishment of greenhouse gas emission standards and corporate average fuel economy standards for 2012-16 light-duty vehicles |
| August 21 | National Conference of Insurance Legislators | Proposed model act regarding auto airbag fraud | IIHS does not support the use of salvaged airbags in vehicle repair unless done under tightly controlled conditions |
| August 14 | NHTSA-2009-0047 | 49 CFR 581: Bumper standard | IIHS supports amendments to federal standard to require compliance by SUVs, pickups, and vans with same bumper performance standards applicable to passenger cars |
| July 1 | NHTSA-2009-0106 | OMB Control No. 2127–0021 | IIHS supports the continuation of the National Automotive Sampling System/Crashworthiness Data System as well as expansion of the program to increase the scope of data collection and ensure the accuracy and completeness of the data collected |
| May 1 | NHTSA-2009-0041 | 49 CFR 571.111: Rearview mirrors | IIHS supports proposed amendments to rearview mirrors standard and no-blind-spot requirement to reduce deaths and injuries associated with backover crashes. |
| 2008 | |||
| December 1 | NHTSA-2008-0157 | 49 CFR 571.218: Motorcycle helmets | IIHS supports proposed amendments to motorcycle helmets standard to assist enforcement of state helmet use laws by reducing misleading labeling of novelty helmets |
| November 17 | NHTSA-2008-0150 | 49 CFR 571.122: Motorcycle brake systems |
IIHS supports proposed amendments to motorcycle brake systems standard to add and update requirements and test procedures and to harmonize with global technical regulations |
| November 12 | NHTSA-2008-0149 | 49 CFR 571.208: Occupant crash protection 49 CFR 571.213: Child restraint systems 49 CFR 571.225: Child restraint anchorage systems |
IIHS supports the proposed removal of sunset provision in occupant crash protection standard so that the requirement that lap belts be lockable to secure child restraints in LATCH-equipped seating positions would continue to apply to new vehicles. |
| August 27 | NHTSA-2008-0124 | 49 CFR 571.219: Windshield zone intrusion | Proposed rescission of windshield zone intrusion standard because of successful compliance and redundancy with other vehicle safety standards |
| August 19 | Transport Canada | CMVSR 115: Vehicle identification numbers | Proposed amendments to Canada's vehicle identification numbers standard that do not adequately address motorcycles and pickup trucks with gross vehicle weight ratings greater than 10,000 pounds |
| June 30 | NHTSA-2008-0015 | 49 CFR 571.216: Roof crush resistance | Response to critique funded by the Alliance of Automobile Manufacturers about the Institute's study on roof strength and injury risk in rollover crashes |
| June 27 | NHTSA-2008-0089 | 49 CFR 523: Vehicle classification 49 CFR 531: Passenger automobile average fuel economy standards 49 CFR 533: Light truck fuel economy standards 49 CFR 534: Rights and responsibilities of manufacturers in the context of changes in corporate relationships 49 CFR 536: Transfer and trading of fuel economy credits 49 CFR 537: Automotive fuel economy reports |
Proposed increases in fuel economy standards for 2011-15 model year passenger cars and light trucks including use of a vehicle attribute-based system to encourage automakers to use new fuel efficiency technologies |
| May 13 | NHTSA-2008-0015 | 49 CFR 571.216: Roof crush resistance | Response to comment by Padmanaban and Moffatt containing misleading statements about IIHS study, "Roof Strength and Injury Risk in Rollover Crashes" |
| April 22 | Transport Canada | CMVSR 215: Bumpers | Proposed amendments to Canada’s vehicle bumper standard that do not adequately address pedestrian protection, insurance claims, and global harmonization |
| March 27 | NHTSA-2008-0015 | 49 CFR 571.216: Roof crush resistance |
Proposed upgrades to roof crush resistance standard including increased minimum roof strength, headroom criterion, and results of IIHS study, “Roof Strength and Injury Risk in Rollover Crashes” |
| March 6 | FMCSA-2004-19608 | 49 CFR 385: Safety fitness procedures 49 CFR 395: Hours of service of drivers |
Interim final rule to permit 11 hours of consecutive driving and 34-hour restart provision for commercial truck drivers |
| March 5 | NHTSA-2008-0016 | 49 CFR 571.202: Head restraints |
Agency's activities under the UN Economic Commission for Europe's 1998 global agreement on head restraints including compliance with dynamic test requirements |
| 2007 | |||
| December 28 | Transport Canada | CMVSR 215: Bumpers | Proposed amendments to Canada’s vehicle bumper standard that do not adequately address pedestrian protection, bumper strength and weight, and vehicle compatibility |
| April 18 | FMCSA-2004-18940 | 49 CFR 350: Commercial motor carrier safety assistance program 49 CFR 385: Safety fitness procedures 49 CFR 395: Hours of service of drivers 49 CFR 396: Inspection, repair, and maintenance |
Mandate for electronic on-board recorders in all large trucks for hours-of-service compliance by commercial truck drivers |
| April 10 | NHTSA-2006-26555 | 49 CFR 571: Federal motor vehicle safety standards | Suggested approaches for enhancing the New Car Assessment Program including front, side, and rear tests; rollover crashes; and crash avoidance technology |
| March 27 | NHTSA-2006-26486 | 49 CFR 571.208: Occupant crash protection | Review of agency’s evaluation report on the benefits of redesigned airbags to vehicle occupants |
| March 27 | NHTSA-2007-26851 | 49 CFR 390.5: Definitions 49 CFR 396: Inspection, repair, and maintenance |
Support for petitions requiring devices on large trucks to limit maximum speeds and prohibit owners and operators from adjusting the devices |
| February 8 | NHTSA-2006-25442 | 49 CFR 572: Subpart V SID-IIsD side impact crash test dummy, small adult female | Support for petitions requesting reconsideration of SID-IIs final rule and adoption of updated SID-IIs iliac wing design |
| 2006 | |||
| October 19 | NHTSA-2006-25801 | 49 CFR 571.126: Electronic stability control systems 49 CFR 585: Phase-in reporting requirements |
Proposed requirement for standard installation of electronic stability control systems in all passenger vehicles and availability of on/off switch |
| June 15 | FMCSA-2005-23151 | 49 CFR 391: Qualifications of drivers and longer combination vehicle (LCV) driver instructors | Proposed amendment to medical qualifications standards to allow commercial truck drivers with insulin-treated diabetes mellitus to operate in interstate commerce |
| April 14 | NHTSA-2005-21462 | 49 CFR 571.121: Air brake systems | Proposed 30 percent reduction in required stopping distances for air-braked truck tractors |
| March 22 | NHTSA-2005-23216 | 49 CFR 575: Consumer information 49 CFR 583: Automobile parts content labeling |
Proposed use of comparative vehicle crashworthiness ratings on the information labels required for new passenger vehicles |
| March 9 | FHWA-2005-22706 | 23 CFR 420: Planning and research program administration | Quality, timeliness, and comprehensiveness of motor vehicle registration and licensed driver information |
| 2005 | |||
| November 29 | NHTSA-2005-22223 | 49 CFR 523: Vehicle classification 49 CFR 533: Light truck fuel economy standards 49 CFR 537: Automotive fuel economy reports |
Proposed changes to average fuel economy standards for 2008-11 model year light trucks including ways in which fuel economy targets are calculated for manufacturers |
| November 18 | NHTSA-2005-22143 | 49 CFR 571.216: Roof crush resistance | Proposed changes to roof crush resistance standard including roof crush requirements, quasi-static and dynamic test procedures, and real-world data |
| October 31 | NHTSA-2005-21245 | 49 CFR 571.213: Child restraint systems | Proposed changes to child restraint standards including test dummies, booster seat weight and fit, and belt-positioning devices |
| October 18 | FMCSA-2004-18940 FMCSA-2004-17286 |
49 CFR 395: Hours of service of drivers | Institute study of hours-of-service compliance by long-distance commercial truck drivers and the need for electronic on-board recorders |
| August 22 | NHTSA-2005-21600 | 49 CFR 571.3: Definitions 49 CFR 571.210: Seat belt assembly anchorages |
Proposed changes to definition and number of designated seating position to ensure sufficient numbers of restraint systems for all occupants |
| July 15 | FMCSA-2005-21338 | 49 CFR 381: Waivers, exemptions, and pilot programs 49 CFR 395: Hours of service of drivers |
Exemption of Xora Inc. from design requirements for on-board recording devices to monitor hours of services by commercial truck drivers |
| June 15 | FMCSA-2004-19608 FMCSA-2004-18940 FMCSA-2004-17286 |
49 CFR 385: Safety fitness procedures 49 CFR 390: Federal motor carrier safety regulations, general 49 CFR 395: Hours of service of drivers |
Recommendations from Inspector General Mead for increased enforcement of hours-of-service regulations including requirement for electronic on-board recorders |
| March 28 | FMCSA-2004-19185 | Motor Carrier Safety Improvement Act, 1999 | Collection of new information for the agency’s bus crash causation study and inadequacies of proposed data sets |
| March 10 | FMCSA-2004-19608 | 49 CFR 385: Safety fitness procedures 49 CFR 390: Federal motor carrier safety regulations, general 49 CFR 395: Hours of service of drivers |
Institute study on effects of hours-of-service rule on truck driver fatigue and and safety including daily driving limits, restart rule, and enforcement |
| March 4 | NHTSA-2004-18865 | 49 CFR 571.214: Side impact protection 49 CFR 572: Anthropomorphic test devices |
Proposed requirements for a small adult female test dummy used in side impact tests including floating rib guide version of SID-IIs dummy |
| January 3 | FMCSA-1998-3706 | 49 CFR 379: Preservation of records 49 CFR 381: Waivers, exemptions, and pilot programs 49 CFR 385: Safety fitness procedures 49 CFR 390: Federal motor carrier safety regulations, general 49 CFR 395: Hours of service of drivers |
Proposed supporting documents required by motor carriers to verify the accuracy of commercial truck drivers' hours of duty status including exemption criteria and requests |
| 2004 | |||
| December 13 | NHTSA-2004-18765 | 49 CFR 571.208: Occupant crash protection | Proposed changes to New Car Assessment Program including frontal test procedures and rating system |
| December 8 | FMCSA-2004-18940 FMCSA-2004-17286 |
49 CFR 395: Hours of service of drivers | Canadian Trucking Alliance's endorsement of electronic on-board recorders for Canadian hours-of-service compliance |
| November 30 | FMCSA-2004-18940 FMCSA-2004-17286 |
49 CFR 395: Hours of service of drivers | Use of electronic on-board recorders for hours-of-service compliance including capabilities, costs and benefits, and enforcement |
| October 14 | NHTSA-2004-17694 | 49 CFR 571.201: Occupant protection in interior impacts 49 CFR 571.214: Side impact protection 49 CFR 598: Side impact phase-in reporting requirements |
Proposed upgrades to side impact protection standards including barrier and pole tests, side impact dummies, and performance criteria |
| August 18 | NHTSA-2004-18029 | 49 CFR 563: Event data recorders | Proposed installment and use of event data recorders in all passenger vehicles including minimum data requirements |
| July 13 | NHTSA-2003-16128 | 49 CFR 533: Light truck fuel economy standards | Proposed reforming of the automobile fuel economy standards program including fleet average requirements, weight- and size-indexed standards, and vehicle classifications |
| July 2 | NHTSA-2003-15715 | 49 CFR 571.208: Occupant crash protection | Proposed high-speed frontal offset crash test requirement for passenger vehicles including vehicle stiffness and aggressivity |
| January 12 | FMCSA-2003-15818 | 49 CFR 381: Waivers, exemptions, and pilot programs 49 CFR 395: Hours of service of drivers |
Exemption of Werner Enterprises to pilot test global positioning system technology to monitor and document drivers’ hours of service |
| 2003 | |||
| October 6 | NHTSA-2003-15732 | 49 CFR 571.208: Occupant crash protection | Proposed increase in impact speed for frontal full-width barrier tests involving small adult female dummies |
| September 8 | NHTSA-1999-5098 | 49 CFR 571.214: Side impact protection 49 CFR 572: Anthropomorphic test devices |
Joint letter concerning recommended procedures for evaluating occupant injury risk from deploying side airbags |
| August 25 | NHTSA-2003-14838 | 49 CFR 571.208: Occupant crash protection | Review of agency's report on improvements in New Car Assessment Program test results due to seat belt pretensioners and load limiters |
| August 11 | NHTSA-2003-14623 | 49 CFR 571.208: Occupant crash protection | Review of agency's report on initiatives to address vehicle compatibility |
| August 11 | NHTSA-2003-14622 | 49 CFR 571.214: Side impact protection 49 CFR 571.216: Roof crush resistance |
Review of agency's report on initiatives to address the mitigation of vehicle rollover |
| May 23 | FMCSA-2002-12334 | 49 CFR 383: Commercial driver's license standards; requirements and penalties | Inquiries concerning graduated commercial driver's licensing; qualifications, testing, and licensing standards |
| April 14 | NHTSA-2002-13957 | 49 CFR 571.108: Lamps, reflective devices, and associated equipment | Potential costs of adaptive frontal-lighting systems including costs associated with low-speed crashes |
| March 5 | NHTSA-2003-14395 | 49 CFR 571.206: Door locks and door retention components | Development of a global technical regulation on door locks and door retention components |
| February 12 | NHTSA-2002-11419 | 49 CFR 533: Light truck fuel economy standards | Proposed corporate average fuel economy standards for 2005-07 model year light trucks |
| January 13 | NHTSA-2002-13546 | 49 CFR 563: Event data recorders | Continued development and installation of event data recorders in motor vehicles |
| 2002 | |||
| November 21 | NHTSA-2001-9663 | 49 CFR 575: Consumer information | Proposed dynamic rollover test to determine vehicle rollover resistance and dissemination of results to inform consumers of rollover injury risk among passenger vehicles |
| October 23 | Agriculture and Transportation Barriers Compliance Board | Draft Guidelines for Accessible Public Rights-of-Way | Installation of traffic signals on pedestrian crosswalks at all roundabouts to replace less safe and less efficient stop sign-controlled intersections |
| October 15 | FMCSA-2002-11650 | 49 CFR 177: Carriage by public highway 49 CFR 397: Transportation of hazardous materials; driving and parking rules |
Proposed security requirements for motor carriers transporting hazardous materials including use of automated tamper-resistant on-board recorders |
| September 10 | NHTSA-2002-12538 | 49 CFR 571.500: Low-speed vehicles | Proposed changes to federal standards concerning the operation and conspicuity of low-speed vehicles including reflective devices and occupant protection |
| August 22 | NHTSA-2002-12151 | 49 CFR 571.201: Occupant protection in interior impacts 49 CFR 571.213: Child restraint systems 49 CFR 571.214: Side impact protection 49 CFR 571.225: Child restraint anchorage systems |
Proposed test procedures and injury criteria to determine injury mechanisms and countermeasures for restrained children in side and rear impact crashes |
| August 19 | FHWA-2001-11159 | 23 CFR 655 Traffic operations | Proposed revisions to the Manual on Uniform Traffic Control Devices concerning supplemental plaques for right turn on red and signs for photo enforcement |
| July 1 | NHTSA-2002-11707 | 49 CFR 571.213: Child restraint systems 49 CFR 571.225: Child restraint anchorage systems 49 CFR 572: Anthropomorphic test devices |
Proposed changes to child restraint test procedures including test dummies and injury criteria, crash pulse of dynamic test, and belt-positioning boosters |
| June 7 | FMCSA-1997-2350 | 49 CFR 385: Safety fitness procedures 49 CFR 390: Federal motor carrier safety regulations, general 49 CFR 395: Hours of service of drivers |
Comparison of hours-of-service rules for commercial drivers operating in the European Union and the United States and use of digital tachographs to monitor hours-of-service compliance |
| May 8 | NHTSA-2002-11419 | 49 CFR 533: Light truck fuel economy standards | Establishment of corporate average fuel economy standards for 2005-10 vehicles base on review of National Academy of Science study |
| February 26 | FMCSA-2001-9688 FMCSA-1997-2350 |
49 CFR 395: Hours of service of drivers | Use of electronic onboard recorders to collect information required for record of duty status for drivers of commercial motor vehicles |
| January 7 | NHTSA-2001-10053 | 49 CFR 571.201: Occupant protection in interior impacts 49 CFR 571.213: Child restraint systems 49 CFR 575: Consumer information |
Establishment of safety rating program for child restraint systems to help consumers make informed buying decisions including ease-of-use ratings and dynamic testing |
| 2001 | |||
| December 19 | NHTSA-1999-5572 | 49 CFR 571.216: Roof crush resistance | Proposed upgrades to roof crush resistance standard including alternative test procedures and real-world benefits of limiting headroom reduction |
| October 25 | FMCSA-2001-9709 | 49 CFR 350: Commercial motor carrier safety assistance program 49 CFR 383: Commercial driver's license standards; requirements and penalties 49 CFR 384: State compliance with commercial driver's license program |
Proposed changes to commercial driver’s license program including disqualifcation of drivers who have committed serious traffic violations in private or commercial vehicles |
| October 1 | FMCSA-2001-9800 | 49 CFR 381: Waivers, exemptions, and pilot programs 49 CFR 383: Commercial driver's license standards; requirements and penalties 49 CFR 391: Qualifications of drivers and longer combination vehicle (LCV) driver instructors |
Proposed exemption for certain insulin-using diabetic truck drivers to operate commercial motor vehicles provided adequate testing of blood-glucose levels and reporting of hypoglycemic events |
| September 27 | NHTSA-2001-10359 | 49 CFR 571: Federal motor vehicle safety standards | Use and effectiveness of booster seats for improving the fit of adult seat belts for children |
| August 27 | EPA-Air A-2000-49 | 40 CFR 86: Control of emissions from new and in-use highway vehicles and engines | Publication of information by vehicle manufacturers for emission-related repairs that could weaken deterrence value of antitheft devices |
| August 22 | NHTSA-2001-9663 | 49 CFR 575: Consumer information | Proposed dynamic rollover test to determine vehicle rollover resistance and dissemination of results to inform consumers of rollover injury risk among passenger vehicles |
| August 9 | NHTSA-2001-8953 | 49 CFR 571: Federal motor vehicle safety standards | Agency's plan for monitoring and evaluating performance of depowered and advanced airbags and developing data for potential future airbag rulemakings |
| July 2 | FMCSA-1998-3298 FMCSA-1998-3299 |
49 CFR 365: Rules governing applications for operating authority 49 CFR 368: Application for a certificate of registration to operate in municipalities in the United States on the United States-Mexico international border or within the commercial zones of such municipalities 49 CFR 382: Controlled substances and alcohol use and testing 49 CFR 383: Commercial driver's license standards; requirements and penalties 49 CFR 385: Safety fitness procedures |
Proposed changes to regulations governing applications by Mexican carriers to operate beyond municipalities and commercial zones at the United States-Mexico border including adequate inspection program, equipment and driver violations, and subsequent crash risk |
| May 21 | FMCSA-2000-8410 | 49 CFR 381: Waivers, exemptions, and pilot programs 49 CFR 383: Commercial driver's license standards; requirements and penalties 49 CFR 391: Qualifications of drivers and longer combination vehicle (LCV) driver instructors |
Proposed pilot program to allow carefully selected, screened, trained, and monitored truck drivers ages 18-21 to operate in interstate commerce |
| March 5 | NHTSA-2000-8570 | 49 CFR 571.202: Head restraints 49 CFR 572: Anthropomorphic test devices |
Proposed upgrades to head restraint standard including requirements for hight and backset, rear seating positions, and harmonization with European standards |
| February 12 | NHTSA-2000-8248 | 49 CFR 571.214: Side impact protection 49 CFR 571.301: Fuel system integrity 49 CFR 587: Deformable barriers |
Proposed upgrades to fuel system integrity standard including front, side, and rear impact tests; side impact barrier; component testing; and fuel leakage |
| January 19 | FMCSA-1997-2350 | 49 CFR 385: Safety fitness procedures 49 CFR 390: Federal motor carrier safety regulations, general 49 CFR 395: Hours of service of drivers |
Results from national public opinion survey on trucks and highway safety including support for electronic data recorders to monitor driving hours of commercial truck drivers |
| January 4 | NHTSA-2000-8446 | Transportation Recall Enhancement, Accountability, and Documentation (TREAD) Act | Proposed study of insurance data mandated by Congress including safety-related defects, noncrash fires, subrogation, and vehicle testing |
| 2000 | |||
| December 15 | FMCSA-1997-2350 | 49 CFR 385: Safety fitness procedures 49 CFR 390: Federal motor carrier safety regulations, general 49 CFR 395: Hours of service of drivers |
Revision of agency's cost estimates to reflect availability of inexpensive automated recording devices that meet proposed specifications |
| August 4 | FMCSA-1997-2350 | 49 CFR 385: Safety fitness procedures 49 CFR 390: Federal motor carrier safety regulations, general 49 CFR 395: Hours of service of drivers |
Opposition to some aspects of proposed hour-of service rules including fatigued-impaired driving, tamper-resistant automated recording, and required work-limit and off-duty times |
| July 31 | NHTSA-2000-6859 | 49 CFR 575: Consumer information | Development of comparitive rating system for rollover risk among passenger vehicles as part of the New Car Assessment Program |
| April 26 | FHWA-1999-6575 | 23 CFR 655: Traffic operations | Revisions to the Manual on Uniform Traffic Control Devices concerning general provisions, markings, and signals |
| April 26 | FHWA-1999-6576 | 23 CFR 655: Traffic operations | Revisions to the Manual on Uniform Traffic Control Devices concerning temporary traffic control |
| March 17 | NHTSA-1999-6407 | 49 CFR 552: Petition for rulemaking, defect, and noncompliance orders 49 CFR 571.208: Occupant crash protection 49 CFR 585: Phase-in reporting requirements 49 CFR 595: Make inoperative exemptions |
Submission of published and corrected version of Institute study on driver fatalities provided in previous comment (December 30, 1999) |
| March 6 | NHTSA-1999-6407 | 49 CFR 552: Petition for rulemaking, defect, and noncompliance orders 49 CFR 571.208: Occupant crash protection 49 CFR 585: Phase-in reporting requirements 49 CFR 595: Make inoperative exemptions |
Institute’s analysis of two fatal crashes from the National Automotive Sampling System cited by Center for Auto Safety as being airbag related |
| February 25 | NHTSA-1999-6407 | 49 CFR 552: Petition for rulemaking, defect, and noncompliance orders 49 CFR 571.208: Occupant crash protection 49 CFR 585: Phase-in reporting requirements 49 CFR 595: Make inoperative exemptions |
Response to assertions by the Center for Auto Safety concerning the Institute's comment (December 30, 1999) on occupant crash protection |
| February 11 | NHTSA-1999-6407 | 49 CFR 552: Petition for rulemaking, defect, and noncompliance orders 49 CFR 571.208: Occupant crash protection 49 CFR 585: Phase-in reporting requirements 49 CFR 595: Make inoperative exemptions |
Fundamental flaws in agency’s analyses of its 30 mph rigid-barrier test to assess risk from inflating airbags to unbelted out-of-position occupants |
| 1999 | |||
| December 30 | NHTSA-1999-6407 | 49 CFR 552: Petition for rulemaking, defect, and noncompliance orders 49 CFR 571.208: Occupant crash protection 49 CFR 585: Phase-in reporting requirements 49 CFR 595: Make inoperative exemptions |
Proposed upgrades to occupant protection standard including to minimize risks from inflating airbags including dummy injury criteria, alternative test procedures, and technological advances |
| September 15 | FHWA-1999-5942 | 49 CFR 383: Commercial driver's license standards; requirements and penalties | Proposed survey for graduated commercial driver's licensing system |