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Status Report, Vol. 40, No. 2 | January 31, 2005 Subscribe

NHTSA considers major changes to side impact compliance testing

This is the barrier NHTSA should use for side impact compliance testing. It's the one the Institute uses in its crash test program for consumer information. It does a better job, compared with NHTSA's current barrier, of representing the front ends of pickups and SUVs, which are the vehicle types most likely to cause injuries to occupants in the vehicles they strike.

The National Highway Traffic Safety Administration's (NHTSA) proposed upgrade of Federal Motor Vehicle Safety Standard 214 would add a pole impact and change the dummies used in the current moving deformable barrier tests. In all the agency would go from specifying one compliance test to four.

"This is a huge regulatory proposal," Institute chief operating officer Adrian Lund points out. "NHTSA is headed in the right direction with the pole tests because crashes into poles and trees are deadly. Upgrading the dummies also is long overdue, as NHTSA itself has acknowledged ever since it last upgraded this regulation back in 1990" (see "Side impact standard will reduce deaths," Nov. 17, 1990).

As the agency now considers further upgrades, "it needs to rethink some of the specifics about the barrier tests," Lund adds.

Which barrier?

NHTSA would retain the moving deformable barrier it has been using in side impacts. This barrier, designed to represent the front end of a typical 1980-vintage car, "is representative of no current vehicles in terms of the way it spreads the load of an impact," the Institute told NHTSA late last year.

In contrast is the barrier the Institute uses in tests conducted for consumer information (see Status Report special issue: side impact crashworthiness, June 28, 2003). This barrier represents the height and front contour of a pickup or SUV, the types of vehicles most likely to cause serious injuries in the vehicles they strike. The Institute's barrier intrudes more than NHTSA's into the door areas of struck vehicles, and because it's higher than the NHTSA barrier it poses more risk to the head.

This is the barrier NHTSA should use, the Institute told the agency. Other groups including the Advocates for Highway and Auto Safety, Consumers Union, and Public Citizen endorsed the same barrier.

Side impact tests under consideration for compliance with FMVSS 214

Test dummies
Configuration Driver seat Rear Seat Striking/struck object Impact speed Impact angle
Oblique pole average-size man none 10-inch pole 20 mph 75°
Oblique pole small woman (modified) none 10-inch pole 20 mph 75°
Barrier* average-size man average-size man current 214 barrier 33.5 mph 27° crabbed
Barrier* small woman (modified) small woman (modified) current 214 barrier 33.5 mph 27° crabbed
* Barrier tests are conducted with a moving deformable barrier.
Note on striking/struck object: In pole tests, the test vehicle strikes the pole at 20 mph. In barrier tests, a moving deformable barrier strikes the test vehicle at 33.5 mph. "Current 214 barrier" refers to the one NHTSA now specifies for tests to comply with FMVSS 214. The agency uses the same moving deformable barrier in side impact tests for consumer information.

Which side impact dummies?

NHTSA proposes to replace the dummy it currently uses, which was the first one developed for side impact testing in the late 1970s. The agency proposes to use a dummy that's more biofidelic and capable of recording more injury measures. Dummies representing both average-size men and smaller women would be specified.

"With one big exception, these are good changes," Lund says. "We question NHTSA's intention to use a modified version of the dummy representing a small woman." The Institute advises NHTSA to go ahead and use the dummy it's proposing — the same one the Institute uses — but not to modify it for compliance testing because the modifications to enhance the dummy's durability would compromise its biofidelity.

The Institute also asked the agency to position the dummies in all of its crash tests, including side impacts, closer to where people choose to sit in their vehicles. This isn't the first time the Institute has submitted such a request (see "NHTSA crash test procedures don't reflect real-world driver positions," Aug. 28, 2004).


SID IIs is what NHTSA should use, without modifications, in side impact tests to comply with FMVSS 214.

Measure chest deflection

"We are dismayed that NHTSA proposed this new standard without deflection-based injury metrics" for the dummy representing a small woman, Lund says. Overwhelming biomechanical data indicate that chest deflection is a superior predictor of injury risk compared with the acceleration-based metrics NHTSA uses and proposes to continue using. Adding deflection would bring the U.S. standard in line with what's required in Europe and elsewhere.

NHTSA has extended the comment period for these proposals until April 2005.

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