“Motor vehicle injuries are the greatest public health problem facing children today” Center for Disease Control a P A on r pe the d n a y t e f a S e l ic h e V n e r ld i h C firm 5473 Blair Road Dallas, Texas 75231 (214) 324-9000 [email protected] Introduction Thousands of children each year are catastrophically injured or killed on America's roadways, parking lots and driveways. On some occasions, no design principle would have prevented the tragedy. On the vast majority of others however, safety designs directed toward protecting children would have prevented these tragedies. Yet, the vehicle and child safety industries refuse to take responsibility for these needless injuries and deaths. Instead, they choose to routinely blame parents and others for safety problems they have created. Who should be held responsible when a child dies or is maimed when his child seat fails to provide adequate restraint? Who should bear the financial burden when a seven year old, rear seated passenger submarines under the lap belt or rolls out of the shoulder belt and is paralyzed because the restraint system was designed for a 170 lb. adult male, rather than a 70 lb. female child? Who is to blame when a power window fatally strangles a child because the child placed her knee on the rocker switch and raised the window? Even more importantly then who bears responsibility is the following question: HOW SAFE ARE OUR CHILDREN IN OUR VEHICLES? Page 2 Children are the most precious cargo we will ever place in a vehicle. As such, no child should be left behind when it comes to vehicle safety. If the vehicle and child safety industries are not going to protect children equally, then the government should intervene. After all, Thomas Jefferson once wrote that “the care of human life and happiness, and not their destruction, is the first and legitimate object of good government.” the firm Child Seats According to the NHTSA, "child restraints are highly effective in reducing the likelihood of death or serious injury in motor vehicle crashes." However, statistics contained in a recent Notice of Proposed Rule Making (NPRM) Change 2002-11707-20 indicate that child restraint effectiveness for children ages 1-4 is cited as 54 percent in passenger cars and 59 percent in light trucks. A good friend of mine, Dr. Martha Bidez, in responding to this NPRM queried "assuming that these data represent survivable crashes, what other business can survive, much less prosper, with an apparent 40% failure rate?” NHTSA's admission that children die in 40% of all crashes causes me grave concern as a parent. I am disgusted since I know other design opportunities are available but are not used. Why are child seats so ineffective? There are five answers to this question; First, parents simply do not realize that children need something other than an adult seat belt up to age eight or 80 lbs. Second, child seat inadequacy can be traced to the federal standard that governs child seat safety. Prior to 2002, Federal Motor Vehicle Safety Standard (FMVSS 213) was an antiquated regulation that did not insure that child seats would perform properly in real world type tests. (For the record, 213 has been improved, but it remains woefully inadequate). For example, there was no requirement for angled or offset frontal impacts, side impacts, rear impacts or rollovers. The standard also allowed for 32 inches of forward head excursion despite the fact that oftentimes there was not 32 inches of rear seat space due to downsized vehicle interiors. Also, there was no lateral head excursion provision. Third, the child seat manufacturers themselves have historically been unsophisticated and under-funded entities that had little to no biomechanical expertise. Fourth, vehicle manufacturers are not testing child seats in their own vehicles to determine child seat effectivness. Lastly, until the LATCH system there was not any requirement that mandated child seat compatibility with the vehicle. Hence, you might have the safest child seat ever built but since it does not fit in your vehicle properly, it is rendered dangerous. 5 lb 10 lb 20 lb 30 lb 40 lb 50 lb 60 lb 70 lb 80 lb Infant-only seat, rear facing, never in front seat with passenger side airbag. Car bed if medically necessary. Convertible safety seat, rear facing until child is at least 1 yr. of age and at least 20 lb, then forward facing to the maximum weight and height allowed by seat. Combination seat with internal harness that transitions to a belt-positioning booster seat; seat forward facing only, weight varies. Forward facing seat with internal harness, weight varies. Integrated child seat; toddler seat with harness (20-40 lb) or some as beltpositioning booster seat with lap/shoulder belt (more that 35-40 lb), as long as child fits. Belt positioning booster seat with lap/shoulder belt as long as child fits. the firm Page 3 Too many parents and caregivers rush children out of child seats and into the vehicle’s 3-point seat belt. The chart above was proposed by the American Academy of Pediatrics. Notice that weight, not age, is the determining factor. Seats & Harnesses Now that you know why child seats are so ineffective in real world crashes, one must understand the types of child seats that are available to consumers to determine if better education, testing, resources and vehicle compatibility would make a difference. Types of Safety Seats Child seats are specifically designed to protect children within certain weight, height, physical and developmental parameters. Some seats only accommodate infants, while others protect older toddlers, preschoolers, and school-age children, as well as children with special needs. The following is a brief description of the types of safety seats currently available. There are four basic designs of internal harness systems that secure children in their safety seats. If the seat meets or exceeds all applicable U.S. Federal Motor Vehicle Safety Standards, then the type of harness chosen becomes a matter of personal preference, although most child seat passenger safety experts agree that the five point harness generally provides the best protection for the widest range of children. Harness Types Five-Point. This harness type has straps that are worn over each shoulder, over each hip and the midline over the crotch where they meet and are buckled together. Because the child safety seats with a five-point harness are frequently less expensive than ones with a tray-shield, caregivers might mistakenly believe that this indicates that five-point harness seats are of “lesser quality” or provide less protection. In fact, purchasing a seat with a five-point harness could be considered a situation where you get “more than you pay for”. The straps on these seats do tend to twist, however making it very important to be sure they are lying flat during use. Shield Infant-only. These seats are designed to be used from birth until 20 to 22 pounds (depending on the model) or until the top of the child’s head is within one inch of the top of the seat shell, whichever occurs first. An infantonly seat must never be used forward facing. Booster Seats are available in two types: A:)Removable-shield boosters, which are not recommended unless the shield is removed and the base alone is used with a shoulder/lap belt and B:) Belt-positioning boosters, which come in two styles: high back and backless Belt positioning booster seats are designed to be used with the vehicle shoulder/lap belt, elevating the child so the safety belt fits properly over the thighs and shoulders (rather than the abdomen and neck). A belt positioning booster is not recommended until a child is at least 3 years old and weights 30-40 puonds. Children are generally safest using safety seats with full harness systems until they are more than 40 pounds or their shoulders are above the top harness slots of both convertible and combination child seat/booster seats. Shield. This harness has two straps that are worn over the shoulders and attach to a flat plastic “shield” that fits over the lower torso. The straps tend to lie flat, and the harness is easily buckled with one hand. The T-shield cannot be adjusted properly to fit a newborn since the shield is in front of the baby’s face or chest instead of the hips. Three Point Three-Point. Found on most infant-only seats, this harness system features a strap worn over each shoulder and midline over the crotch. Convertible. Before the weight or height limit of an infant only seat has been reached, the child should be switched to a convertible seat, generally to continue rear-facing. Weight limits for rear and forward-facing. vary by seat model, but all models can be used only until a child weights 40 pounds. Convertible seats are so named because they can face either direction. The safer, rear facing position is recommended for as long as possible. Built-in seats. A forward-facing seat with a full internal harness that fits children at least 1 year old and more than 20 pounds may be part of the vehicle seat design. Some vehicles have a built-in belt-positioning booster which may be used by children at least 3 years old who weigh at least 30 to 50 pounds, depending on the manufacturer’s recommendations. Tray-Shield. With this system, the shoulder harness straps are attached to a wide, padded shield that snaps into the seat at the crotch. Since the shoulder straps loosen each time the shield is brought over the child’s head, caregivers need to be certain to adjust the straps for a snug fit each time their child is buckled into the seat. This style also does not fit infants as well. Tray Shield Combination Child Seat/Booster. Some child safety seats are designed to function as a forward-facing seat with an internal harness when a child is under 40 pounds and then as a belt-positioning booster (with the harness removed) when the child reaches 40 pounds. Both lower and upper weight limits vary among models There is no debate about this fact: rear facing is safest for both adults and children, but especially for babies. Rear facing car seats spread frontal crash forces over the whole area of a baby's back, head and neck; they also prevent the head from snapping relative to the body in a frontal crash. Rear facing child seats also allow for a longer ride-down period so that there is less energy transferred to the child. Hence, parents should keep their children in rear facing child seats for as long as possible. Some rear facing child seats have a 35 lb. maximum weight. A child is too tall for a rear facing child seat when the top of his head is at the level of the child seat shell. In Sweden, children often remain in rear facing child seats through age four. 5-Point Harness Page 4 The American Academy of Pediatrics has concluded that a rear facing child seat is safest. the firm Child Seat Safety Related Issues Angle of recline for a rear facing seat, the seat should be reclined so that the angle of the back surface is not more than 45 degrees from vertical. As the baby grows, the angle should be decreased. For a forward facing seat, the most upright position is the safest in terms of load distribution. Newer model child seats have a level, which advises users the correct angle of recline. Some manufacturers mislabeled their instructions which allowed for excessive reclination. Chest clip holds the shoulder straps together. If not spring loaded, the clip could slide down allowing the child's shoulders to slip out which could lead to complete or partial ejection. The clips that are not spring loaded also have a tendency to be flimsy and one of the teeth can shear rendering the shoulder straps ineffective. Spring Loaded Tray shield- located on a convertible child seat. The tray breaks off and impacts the child or the child impacts the tray and suffers injury because the tray was not adequately padded. Testing has shown that tray shields result in 35% higher head peak acceleration forces than 5-point harnesses. T-shields- shoulder straps are attached to a flat, plastic pad on a fairly rigid stalk that buckles into the child seat shell between the child's legs. Testing has revealed that a child's throat can impact the top of the T-shield. Also, neck forces are 40% higher on Tshields compared to 5-point harnesses. Plastic shell fracturing - over the years, shell deformation has resulted in unnecessary child injury. Friction Loaded Shoulder harness slots - two common problems. Mislabeling which slot to put the shoulder belt through is most common. For rear facing child seats, the shoulder straps should be at or just below the child's shoulders. For forward facing child seats, put the shoulder strap in the slot at or above the child's shoulders. The slots also have a tendency to be weak and un-reinforced such that the slots tear out under load ejecting the child. Mislabeled by a Major Child Seat Manufacturer Head excursion- before September 1999, the forward head excursion was 32 inches forward of a point located five inches rearward of the seat bight. After September 1999, the head excursion has been reduced to 28 inches from that point but with a tether device. There is still no lateral head excursion requirement. Lateral child seat excursion- Vehicle safety belts are not properly designed to laterally restrain a child seat. Lateral movement places the child in harm's way from intruding components. The top tether and LATCH system have minimized this problem. Wrong Way Cracks Due To Weak and Un-reinforced design Harness strap tightness- this is a major problem because users will wrap the child in bulky clothing or a blanket then the harness is not tight enough. However, nothing advises parents about swaddling a child in a blanket. Also some manuals differ in how they define tightness. Some say one finger between the straps. Some say two, others say three fingers. 3-point harness- this harness configuration has two straps over the shoulders and a single crotch strap. A child is susceptible to ejection or submarining with this design because there is no pelvic support. Safe Passage Brochure: From Leading Child Seat Manufacturer “You must also use a top tether strap if you can pull the top of the child restraint more than one inch forward or one to two inches to the side”. Lateral head excursion- focuses on the failure to use a winged seat design to help minimize head excursion in side impacts. Twisted harness belt- the load carrying capacity of the straps is decreased to the point the harness can separate under otherwise survivable accidents. Page 5 Correct Way Low shield booster seats- these were first introduced in the US in 1979 and problems quickly followed because there is no harness restraint to retain the upper torso. As a result, children in shield boosters can be ejected or injured due to head contact or abdominal loading. One company recommended to its US customers that it was safe to use a shield booster seat for children under 40 lbs. This was contrary to the message it gave its Canadian customers. In 1991, the NHTSA wrote that "shield boosters may not provide adequate protection because they don't offer adequate upper body restraint and children can be ejected from them." US Version Vehicle seat incompatibility- due to the angle of the seat rake and seat bight location, the child seat cannot be placed securely to the vehicle. Canadian Version Design Fixes Top Tethers- a top tether is the supplemental attachment now standard on almost every new vehicle sold in the US. A top tether is a strap that connects the top of the child seat to an anchor mounted in the vehicle at a location behind the child seat. It is designed to prevent the forward or lateral excursion of the child seat. Most vehicles sold since 1989, have factory locations for the installation of a tether anchor. In comparison crash testing, child seats with top tethers reduce head excursion. More importantly, tethered child seats tend to reduce head accelerations and neck loads. 30-40 The GM Love Seat was introduced in 1973. It incorporated a top tether strap because it resulted in a reduction of head excursion of approximately 12 inches. (40 and 60 lbs) Unstable base- a narrow or unstable base that allows the child seat to move excessively sideways due to the vehicle belt placement can allow a child to impact the striking object or vehicle interior. No positive belt capture feature- this has been seen primarily on no-back booster seats. The vehicle's belt routed around the booster but was not captured or locked in place. As such, the booster seat could slip out from under the vehicle's belt allowing the child to be ejected. On more conventional child seats the vehicle’s belt is routinely not capable of being locked to the child seat. This lack of retention can allow excessive lateral movement. Page 6 Rear Facing Front Facing Booster Seat Rolls Out from Under Belt LATCH- this stands for lower anchors and tethers. LATCH became mandatory on new cars September 1, 2002. With the LATCH system, there is no need to use the vehicle belts. The goal behind the LATCH system was to eliminate misuse through loose seats and misrouted belts. LATCH has not been the panacea however. Multiple configurations of how to affix child seats have been produced which have lead to confusion in how to affix the child seat to the latch in the vehicle. The safety principle behind a top tether and the LATCH system is to couple the child seat to the vehicle as tightly as possible. Eliminating looseness also explains why all child seats now use a 5-point harness rather than a 3-point harness. Coupling the seat and the child allows for a longer ride-down period, eliminates excessive forward and lateral excursion and decreases deadly forces on the child's head, neck and torso. Forgotten Child Comparison of a 8 1/2 -9 1/2 yr old 50th percentile Girl & Boy Anthropometry to the 5th percentile Female & 50th Percentile Male Adult Over 500 children a year are killed because they are either unrestrained or effectively unrestrained because of poor belt fit and improper restraint. Most parents allow their children to stop using any form of child seat after age four. These parents are making a potentially life altering mistake. Unless your child can meet the following criteria, they need to stay away from adult seat belts: · · · · · · They are tall enough so that their legs bend at the knees at the edge of the seat when seated; They are mature enough to remain seated with their backs flat against the back of the seat (no slouching); The lap belt sits high on the thighs or low on the hips; The shoulder belt crosses the shoulder and chest; The latch plate is as far as possible from the occupant center line; and The buckle is close to the child’s hip. Adult seat belts do not protect children properly because the seat belt fails to fit them correctly. As a consequence, children are maimed or die. Why do adult seat belts not fit children properly? Shoulder belt anchor too high. Shoulder belt cuts across neck or chest. Children between the ages of four to eight are typically less than 48 inches tall and under 80 lbs. These sized children are exposed to a high risk of severe injury or death because they are strapped into adult safety belts that are designed to protect adults, not small children. Lap belt anchors too far apart Comparison of a 4 1/2 -5 1/2 yr old 50th percentile Girl & Boy Anthropometry to the 5th percentile Female & 50th Percentile Male Adult Stalk too tall. Too much gap between buckle and pelvis. Consequences of Improper Seat Belt Fit Shoulder Belt Rollout Sequence the firm Page 7 Submarining Rollout Mis-Positioning Belt Behind Back A 1996 NHTSA study showed that only 6.1 percent of the children who were weight eligible were actually restrained in a booster seat. This small percentage could be explained by state laws. Even though adult seat belts do not fit children four to eight properly, as of 2002, 26 states allowed parents to place children in an adult seat belt after the child reached age four. Four allowed children to use an adult seat after age three. Two allowed children to use an adult seat belt after age two. Child Passenger Protection Laws Age of Effect vs. Number of States Number of States 40 30 20 26 13 10 5 0 2 2 4 3 1 4 Age (& Under) 5 6 Knowing that 32 states allow parents and caregivers to place four year old and younger children in adult seat belts, vehicle manufacturers have advocated the use of booster seats for children ages four to eight. In April 2000, former Ford CEO Jacques Nasser touted the safety benefits of booster seats in announcing Ford's Boost America campaign: "We have made great progress in protecting infants in car crashes, but now we need to focus on older children between the ages of 4 to 8. They are too big for a regular child safety seat and too small for adult safety belts. The child safety gap must and will be closed." A year later in front of a Senate Subcommittee hearing, Ford's Director of Automotive Safety testified about the safety benefits of booster seats: the shoulder belt portion of the lap-shoulder belts should not be used if it contacts the childs face, chin, neck or throat. WARNING - If the shoulder belt portion contacts or remains in front of the child’s face, chin, neck or throat, move the child to a seat with a lap belt only, if available. Otherwise, place the shoulder belt portion behind the child’s face. Once the shoulder portion of the restraint system is defeated, the restraint system is rendered dangerous since the upper torso is no longer restrained. Without the upper torso restraint, the child will hyperflex over the lap belt and sustain paralyzing injuries because the 3-point belt has become a lap belt only design. "We have increased our focus recently on the need to improve the effectiveness of restraint systems for children aged 4 to 8. In a crash, poor belt fit can reduce the protection that the safety belts should provide against the risk of serious or fatal injuries.” However, when faced with litigation, these same vehicle manufacturers argued in court that booster seats were not safety related items at all but were used merely to improve comfort. In fact, Ford's retained experts argued in a Florida trial that booster seats are a matter of comfort and convenience, not safety. CEO Nasser testified, contrary to his Boost America comments, that booster seats were intended to increase seat belt use based on comfort issues, not safety issues. Page 8 So, are four to eight year old children adequately protected by adult seat belts or do they need booster seats? Vehicle manufacturers for years have recommended that the shoulder portion of the belt be placed behind the back of a child if the seat belt did not fit properly. In short, they encouraged belt mispositioning. the firm Lap Belt Only Kinematic Sequence Further, by placing the shoulder belt behind the back, the injury producing consequences of submarining are increased. Submarining injuries devastate the internal organ injuries and can cause lower spine fractures. Lap Belt Submarining Sequence In September 1996, the NTSB issued a safety report recommending that the NHTSA revise FMVSS 213 to create a performance standard for child seats for children up to 80 lbs. Until 2002, the only safety standard designed to protect children limited its protection to children up to 50 lbs. By June 2003, the revised FMVSS 213 extended protection to children who weigh up to 65 lbs. However, the NHTSA acknowledges that "children must weigh approximately 80 lbs. to fit properly in a safety belt without a booster seat." Why not protect children between 65-80 lbs.? Don’t they deserve protection? What injuries are four to eight year old children exposed to even when they properly use an ill-fitting adult seat belt? If the lap belt fails to properly restrain a child's pelvis, the forces of the crash will be distributed into the abdomen rather than the bony pelvis. Abdominal tears, paralysis and death are common injuries when a child submarines under the lap belt. Because so much space exists between the lap belt anchors, a child can literally be ejected from under the lap belt. Because the shoulder belt anchor is so high and so far forward, the shoulder belt can literally strangle a four to eight year old child or create a fulcrum causing spinal injuries. Other times, the child will slip out of the shoulder belt and be exposed to lap belt only type injuries. Despite decades of research that demonstrate that four to eight year old children are not adequately protected by adult seat belts, only a handful of vehicle manufacturers have provided integrated child seats. 2002 Model Year Vehicles with Standard Built-In Child Seat Chevrolet Venture 2002 Model Year Vehicles with Optional Built-In Child Seat Saab 9-3, 9-5; Subaru Legacy; Volvo S40, S60, S80, V40, V70, V70XC; Chrysler Town and Country, Voyager, Caravan, Grand Caravan; Nissan Quest The time is now to protect children age four to eight from the illfitting consequences of adult seat belts. four to eight year old children who are using adult seat belts are being maimed and killed at a staggering rate. In 1997 alone, over 10 times the number of children who were ever killed by airbags were killed while using an adult seat belt. Adult seat belts and children four to eight are a deadly combination. As long as four to eight year old children remain a forgotten priority, deaths and catastrophic injuries will continue to rise at epidemic proportions. Knowing that vehicle manufacturers were taking inconsistent positions on the need to protect four to eight year old children and knowing that the safety of four to eight year old children remains ignored, Public Citizen, in April, 2002, urged the vehicle industry, NHTSA and Congress to require integrated, built-in child restraints for children four to eight. Airbags and Children are a Deadly Combination Hope may be on the horizon however. The NHTSA announced its 2003-2006 Rulemaking Priorities and Supporting Research recently. One of the special populations the NHTSA intends to focus on is the protection of children. This is certainly well overdue. Unfortunately, it could be another 10 years before any meaningful required legislation is adopted. In the meanwhile, safety advocates will have to keep encouraging manufacturers to implement safety features even before legislation requires them to do so. Conventional Child Seat vs. Integrated Booster the firm Page 9 Public Citizen's request is well-founded. Various integrated child seats have been available since the 1980's. In fact, Ford has indicated in internal engineering notes that for children between four to eight, the integrated child seat with 5-point harness is the "safest form" of restraint system to use because it is both "safe" and convenient." EXTENDING THE RESTRAINT DESIGN PROTECTION ENVELOPE TO CHILDREN UP TO 14 UNICEF reported in 2001 that injury from motor vehicle accidents is the principal cause of child death in all developed nations accounting for almost 41 percent of deaths in the age group one to 14. The total annual costs of motor vehicle occupant related injury and death is more than $25.8 billion for all children ages 14 and under. Even though the United States is the strongest political power in the world, it is ironic that when ranked according to deaths per 100,000 children (ages 1-14 yrs.), The US ranked 21st out of the 25 richest industrialized nations in the world during the early 1990’s. Most safety advocates argue that children reach a certain age before they can safely use an adult seat belt. The age threshold position is flawed even though it is recommended by state restraint laws, the NTSB (National Transportation Safety Board), the vehicle industry and the child safety industry. The proper method by which to determine when a child can safely use an adult seat belt is based on anthropometry. Based on the biomechanical research conducted to date, a child should only use an adult 3-point belt if they are 80 lbs., have a seated height of 29 inches and a standing height of 4 foot 7 inches. These sizes are larger than almost 70% of the children under age 14. Page 10 Age and Associated Body Weight Required to Reach Threshold Seated Height to Use 3-point Belts 5th Percentile Boy or Girl 5th Percentile Boy or Girl 5th Percentile Boy or Girl 13.5 - 14.5 81 lbs. 10.5 - 11.5 78 lbs. 8.5 - 9.5 89 lbs. the firm There is good reason for concern that the nine to 14 year old is unprotected. Motor vehicle crashes are the leading cause of death in the US for children ages four to14. In May 2003, the NHTSA partnered with the National Committee on Uniform Traffic Laws and Ordinances, the Air Bag & Seat Belt Safety Campaign, the Automotive Coalition for Traffic Safety and the Governors Highway Safety Association to create a model law that will help eliminate the gaps that often occur in occupant protection litigation. Here are a few key points of the model law: · · · Cover all occupants up to age 16 in all seating positions; Require child occupants to be restrained in age and size appropriate restraint systems; Require all vehicles to have uniform restraint systems; and Require all occupants be belted, not just front seat occupants. Why is this model law necessary? As is seen with children ages four to eight, adult seat belts simply do not fit children ages nine to 14 properly. Just like with children age four to eight, many children age nine to 14 who do not weigh 80 lbs., do not have a seated height of 29 inches and are not 4 foot 10 inches tall are susceptible to submarining, shoulder belt rollout and other dangers associated with ill-fitting belts. However, unlike for children age four to eight, a built-in booster seat is not practical for a nine to 14 year old. Manufacturer testing with child sized dummies demonstrates that belt strangulation is a real world possibility So, what can be done to protect children age 9-14 who are too light and too short to use a vehicle’s 3-point belt while at the same time protecting all sized adults? The answer is simple- provide a restraint system that couples all occupants more closely to the seat rather than the vehicle. Several designs alternatives have existed for decades that allow for better seat belt fit. These include: Rollout ·Adjustable anchors in the rear like in the front seat. ·Pretensioners which remove slack and cinch the occupant closer to the seat. ·ABTS (All Belts to Seat) helps correct belt geometry issues. ·Anti-submarining seats help keep buttocks from sliding off seat so that belt geometry stays consistent. Strangulation Unfortunately, these designs have not been tested to date on children who are beyond the weight and seating height limit of a booster seat. A battery of tests needs to be conducted to insure that children who can no longer use a booster seat will be protected when they ride in a rear seat. At the same time, the design needs to protect the 95th percentile male in the worst possible scenario. A wonderful organization called Voices for Alabama’s Children is actively trying to put a test protocol together to verify how these design improvements will help extend the design envelope to children over age eight. Submarining I would like to thank Dr. Martha Bidez and Autumn Alexander for their tireless efforts, positive criticisms and technical insights into making vehicles safer for all children. the firm Page 11 · Ford has acknowledged in a recent filing with the NHTSA in 1980 that shoulder harness fit is critical. Hidden Dangers to Children Inside and Outside Vehicles Children should never be left unattended inside or even near parked vehicles because there are a host of hidden dangers that can kill a child. Since 1990, every state has experienced child injuries and fatalities because children were left unattended near vehicles. Two wonderful organizations were born out of tragedies associated with hidden vehicle dangers: www.kidsincars.org and www.kidsandcars.org. The Struttman and Fennell families realized following lifealtering events that a public forum was needed to educate parents and caregivers on the dangers of vehicles and children. These families have also tirelessly lobbied for creation of laws to protect children. The following are examples of hidden dangers that have claimed the lives of children. Education, legislation and vehicle safety enhancements would have prevented most of these deaths. Children Left in Vehicles 37% of all children killed in the last 5 years in non-traffic accidents died while left inside a hot vehicle Each year when summertime temperatures outside soar to 100 degrees, the temperature inside a vehicle can reach 150 degrees. A locked vehicle is clearly no place to leave a child alone. But, it happens and frequency is on the rise. To prevent these numbers from rising, parents and caregivers should take the following steps to insure child safety: · Always lock your vehicle; · Teach your children not to play in or around vehicles, they are not toys; · Never leave your child inside a vehicle, even if it is running with the air conditioner or heat on; · Teach your children about the dangers of playing in and around vehicles; and · Do not be afraid to tell parents or caregivers about the dangers of leaving a child unattended if you see a child left inside a vehicle. Page 12 There is no federal or state database that collects information related to deaths and injuries that occur as non-traffic related incidents. The following data was collected from news sources. the firm Caregivers must also be educated on the hazards of leaving children unattended in a vehicle. If you see a child inside a vehicle, it is hot and the engine is not running, break the window and save the child. If you see a child inside a vehicle, it is hot and the engine is running, put a note on the windshield that reminds people of the dangers of leaving a child unattended inside a vehicle. A sample note has already been prepared by www.kidsincars.org. What exposure do vehicle manufacturers face when this appears to be a situation where the parents and caregivers are exclusively to blame? Imagine this scenario. A father who never takes his child to school is asked to take his child to school. The father loads up his child in the rear facing child seat where the child quickly returns to sleep. Before he leaves the house, a business call comes into the house that requires the dad to rush into work like he routinely does every day. The dad parks in the parking lot and goes into his office. The dad receives a call from his wife several hours later asking how dropping the child off at school went. The dad then realizes that he forgot his child in his vehicle. Upon returning to the parking lot, the father finds his child dead in his child seat. Because of the father's innocent oversight, his child is dead. For those of you who believe this could never happen to them, I encourage you to watch the movie the Key Man. The story is telling. the Rather than blame solely that innocent father, I believe the vehicle manufacturer should be held partly responsible. Vehicle manufacturers provide warnings when our seat belts are not on, when we leave our lights on, when we leave keys in the ignition, when our doors are ajar, when our trunk is ajar, when our windshield washer fluid is low, when our engine's oil, water, and brake fluid levels are low. Why not provide a reminder sensor when our children are left unattended in our vehicle? Why not provide an alarm that goes off when an occupant remains in the vehicle over a minute after the vehicle is turned off? Children Run Over by a Backing Vehicle 32.1% of all children killed in the past 5 years were run over in a driveway Each day parents take all kinds of precautions to insure that children are protected from injury or death should they be involved in a traffic accident. Few parents would ever envision that their own driveways are oftentimes more dangerous than highways. As vehicles get larger and larger, and Sport Utility Vehicles become more prevalent, the blind spot on vehicles increases. As such, the risk of running over a child in a driveway has increased. According to the Center for Disease Control, vehicle backing accidents resulted in more than 2,700 emergency room treatments between July 2000-June 2001. From January 1October 21, 2002, there were 349 backover incidents involving children, 104 resulting in death. firm Page 13 A child left alone in a vehicle when the temperature outside is 90 or above can die within five minutes. However, in most states, there is no law that punishes people who leave children unattended in vehicles and an injury or fatality occurs. Only three states have laws that punish people for leaving a child unattended in a vehicle that results in injury or death: Kentucky, Missouri and Texas. Seven states have laws that provide for a fine for leaving a child unattended in a vehicle: Connecticut, Florida, Illinois, Maryland, Nebraska, Pennsylvania, and Washington. It should be noted that Texas allows a child to be unattended for up to five minutes and Illinois up to 10 minutes before any criminal wrongdoing has occurred. Safety advocates have proposed model legislation to prevent leaving a child unattended in a vehicle even for a minute. Blind spots exist on all vehicles. A blind spot is defined as the area of the vehicle that you cannot see from the driver's seat. A blind spot can be as high as three feet. Consumer Reports reported that a 5 foot 8 inch driver would have to drive forward 12 feet to see a 28 inch traffic cone behind him if driving a Honda Accord. In a Chevrolet Avalanche, that same driver had to drive forward 29 feet. In a Ford Expedition the blind spot was 30 ft. Safety risk Taller vehicles have big blind spots which make it difficult for drivers to see behind them, particularly the area closest to the ground. So, what is a driver to do if he checks his side mirrors, his rearview mirror and has turned around to look for potential threats? Purchase a vehicle with rear sensors. The technology is being used today as standard equipment on vehicles like the Lincoln Navigator which detects both moving and stationary objects up to 20 feet behind the vehicle. An alarm inside the vehicle Danger Zone sounds when the vehicle is backing up and Being backed over by a vehicle gets closer to an object. The alarm beeps is the second-leading cause of auto-related child deaths. faster as the object becomes closer. Ford PERCENTAGE OF FATALITIES BY INCIDENT: claims however that the feature is for Fire inside Trunk convenience and should not be considered the vehicle entrapment 3.1% 3.9% a safety feature according to Ford Product design engineer Bob Kwiecinski. Nissan is Power Car put in offering an optional camera that shows accessory motion by strangulation child behind the vehicle in its Infiniti Q45 sedan. 10.1% Honda has a standard camera system on its 3% Acura MDX SUV and charges $900 for it Other 11.3% on the Honda Pilot SUV. A growing after market industry sells various alarms, Left in car Backed sensors and cameras to prevent backover in hot weather over incidents. 36.7% 32.1% Kids in Cars In the past five years, over 200 children have died in driveway, backover related incidents. By November 2003, 55 children had died in backover incidents. Most of the children were four years old or younger. At least 60% of the vehicles involved were light trucks, SUV's and minivans. Amazingly, however, according to Kids and Cars founder Janette Fennell, "not a single surveillance system in the US captures data on the number of children that are killed each year in backover incidents." According to the NHTSA, "traditionally we have not tracked non-traffic related fatalities of any kind." This is about to change. The Senate Commerce Committee voted in June 2003 on a bill to begin collecting data on how many backover deaths occur each year in driveways. SUV, light truck and minivan sales have increased dramatically in the last 10 years. Here are a sample of manufacturers that have products to help prevent backover accidents. 50.0 45.0 Market Share (%) 40.0 35.0 30.0 25.0 20.0 15.0 10.0 5.0 0 Page 14 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 Year U.S. Sales of LTV’s from 1980-1996 expressed as a fraction of light vehicle market share (Automotive News Market Data Book) the firm Vehicles put into motion by Children Left Unattended A brake shift interlock or park shift interlock is a safety device that prevents a vehicle with an automatic transmission from being moved out of "park" and into "neutral" or "drive" until the driver depresses the brake pedal. 10.1% of all children killed in the last 5 years were killed by a child putting a vehicle into motion. Children should never be left alone in vehicles, because if the vehicle does not contain a brake shift interlock device, the child can move the gear shift and have the vehicle roll away even without the keys in the ignition. As the vehicle is rolling, children in front or behind can be struck and killed. The child in the vehicle may also panic and be struck by the rolling vehicle if he tries to exit the vehicle. For those of you who think that this is a freak accident, consider the numbers. 75 children have died due to unwanted gear shift engagement. The best selling minivan of all-time was investigated by the NHTSA for model years 1981-1990. The NHTSA found startling results: · · · 212 roll-aways 111 injuries 7 fatalities Technology has existed for almost 100 years to prevent deaths caused by vehicle rollaway. From 1914-1930, three interlock devices were patented to prevent a vehicle from going into motion unless a series of safety steps were first undertaken. Between 1930-1934, GM alone acquired 4 interlock patents. All three domestic vehicle manufacturers had their own modern interlock patents by the early 1970's. Safety improvements were proposed by many others. The 1963 Human Engineering Guide To Equipment Design, dedicated a whole chapter to methods of preventing accidental activation of controls. Operation sequencing was the key design element to prevent unwanted activation. This is the classic definition of an interlock device. Patent no. 3,434,315 issued in 1969 provided that "as is often the case, a child is left in the vehicle while the adult driver must leave for a few moments to accomplish a particular task. Many cases are known where a child has accidentally placed the gear selector in a neutral position causing the car to roll with subsequent injury to the child and damage to the motor vehicle.” In 1991, the Department of Pediatrics at the University of California Irvine wrote that “the most common injury to a child in a non-traffic related incident occurred when a child moved the vehicle out of gear.” In 1992, the Human Factors Society wrote that a shift interlock system that required the driver to depress the brake before shifting out of park would eliminate potentially dangerous shifting habits. Despite having technologically feasible designs to cure a hazard that was foreseen earlier, vehicle manufacturers have been slow to adopt brake shift interlocks as standard equipment. · · · the AS-body 1984-1995 NS-body 1996-2000 RS-body 2000- present firm Page 15 Considering all of the patents and technical literature, why would a company not use a device with such a useful purpose? The answer lies with the NHTSA. Even though the number of vehicle rollaways continues to climb, the NHTSA has never required brake shift interlocks. This certainly does not suggest that the NHTSA believes shift interlocks are not helpful however. In fact, the NHTSA wrote a report in 1989 entitled An Examination of Sudden Acceleration wherein the NHTSA proposed the use of automatic shift locks which would require the driver to depress the brake pedal before the vehicle can be shifted out of gear. The NHTSA concluded that shift locks would "prevent unattended children from shifting the car out of park." Furthermore, minivans which were classified as multipurpose passenger vehicles were initially exempt from having to comply with the same federal standards as passenger automobiles. Using this loophole, Chrysler marketed its minivans as family vehicles and encouraged the transportation of small children. There were three generations of Chrysler minivans: In 1992, Chrysler bought a full-page ad in the Wall Street Journal which included the following headline: Yet, Chrysler did not include brake interlocks on it’s 1992 minivans. Chrysler bragged that its 1996 Dodge Caravan was a leader in safety. In its 1996 Town and Country brochure, Chrysler commented that it had unprecedented emphasis on research and development. Yet, Chrysler did not use a brake shift interlock on its minivan until the RS-body which came out in 2000. This was well after its competitors had started using brake shift interlocks in 1993. 1993 Ford Aerostar, 1993 Mercury Villager 1994 Mercury Villager, 1995 Honda Odyssey all had brake shift interlocks as standard equipment Even more important, however is the fact that Chrysler was installing brake shift interlocks on its 1993 Mitsubishi Eagle Summit. In 1997, Chrysler offered a retrofit to owners of 19841995 Jeep Cherokee and Wagoneer vehicles for the installation of a brake shift interlock. Vehicle manufacturers and others argue that if parents and caregivers watch their children and prevent them from playing inside a vehicle that brake shift interlocks are unnecessary. In a perfect world this is true. But, parents cannot possibly watch their children every second of the day. Parents will also sometimes make mistakes and forget to lock a vehicle that is sitting in a driveway. Knowing that people make mistakes, it is incumbent on manufacturers to provide the last line of defense for children. The mechanics of an electric window are simple. By applying a two pound force on a power window toggle switch, the window motor is activated to exert an upward raising force of between 50-80 pounds. Since only 8-12 pounds of force is needed to raise the average vehicle window, the excess available force (4268 pounds) is more than enough to lift and strangle or crush a child between the glass and the upper window frame. The hazards of power windows closing on occupants has been known in the industry for years. In response to two separate proposed rulemaking changes by the NHTSA in 1969 that addressed ways to minimize the likelihood of personal injury when a power window is inadvertently operated and a person is caught between the window that is closing and the framework that encloses the window, the industry responses were surprising. One such design fix touted by the NHTSA was a pressure sensitive device that would contain an automatic reverse feature. Ford admitted that it had developed a system that would interrupt, stop or reverse the direction of windows when a predetermined force is exerted on an object interposed between the glass and the frame channel. However, "the high indicated minimum cost of such a system appeared to far outweigh the resultant benefits, particularly in view of the existing Ford safeguards." By the time the NHTSA had adopted its power window safety regulation, FMVSS 118, in 1970, it had been watered down. Specifically, the NHTSA no longer required a pressure sensitive device. The NHTSA seemed to buy into the industry's position-"a requirement for these devices cannot be justified on the basis of safety benefits, cost effectiveness and economic impact." Power windows were not permitted to be operable when the key was not in the ignition. The NHTSA had another chance in 1975 to mandate pressure sensitive devices. Again, it refused. In 1987, the NHTSA had another chance to mandate pressure sensitive devices. Again, it refused. Interestingly, however, the NHTSA raised the issue of unsupervised children being strangled by power windows. Also in 1987, the NHTSA investigated 140,000 Jeep Wagoneers and Cherokees after several children had been strangled in those vehicle's rear tailgate power window. Even after Chrysler recalled 180,000 of these vehicles, the NHTSA did nothing. By 1991, the NHTSA mandated that reverse window direction features be used so that the window will reverse direction upon its meeting an obstruction. However, before the industry was required to implement the new rule, the NHTSA again softened its position and modified the force resistance specification and the size of the opening permitted before reversal was required. No further safety improvements have been made. Auto reverse is still not required (except on vehicles with remote window activation and one-touch automatic) nor are pressure sensitive devices. Power Window Dangers Page 16 Electric windows are a decades-old convenience feature. People use them everyday, but few know how dangerous these devices can be to children. Since power windows were introduced in the early 1960's, children have been injured and killed each year due to power window related injuries. In the last twenty years, 53 children have died in power window accidents. Many of these injuries and deaths were strangulation or crush related. the firm What makes the NHTSA's unwillingness to adopt meaningful safety legislation even more disturbing is that workable solutions have been available for years to prevent these deaths. Au to ma ti c po we r wi nd ow re ve rs in g mechanisms exist in several forms: · Since 1970, 1,250 people have been victims of trunk entrapment. Victims of trunk entrapment fall into two categories: people who are intentionally locked in a vehicle in a criminal incident and people, usually children, who unintentionally lock themselves in a trunk. Unintentional entrapment occurs during children's games or exploration. The average age of the 37 children who have died since 1970 were four or younger. The cause of death is usually heat related as trunk temperatures can reach 172 degrees in the summer. Optical sensors to detect an object in the window path; Voltage load buildup sensors which reverse at contact with an object; and Infrared sensors which reverse even before contact. The fix for trunk entrapment is an interior trunk release device. Patents for this device date back to the 1950's. The NHTSA had even considered an inside trunk release but denied requiring such devices in the 1970's after the vehicle industry argued that such incidents are rare. In Europe, 80% of all vehicles are equipped with a power window auto-reverse feature. This includes vehicles sold by American manufacturers. The cost for this feature is eight dollars. Sadly, as of January 2002, only the Cadillac line and Lincoln platform were the only American vehicles sold in the US that have an autoreverse feature. Since vehicle manufacturers are not providing the safety fix for power windows, the question that must be asked is what power windows are dangerous and why? The answer lies in the switch itself. The majority of American vehicles use a rocker or toggle switch, which rest on a central pivot, usually near the armrest. To raise the window, the switch is depressed or pushed forward. If a knee or foot contacts a rocker or toggle switch, the window raises up and can strangle a child. GM engineers have acknowledged in depositions that it would be safer to design a window to go down when the switch is pressed down. The lever switch requires that the user deliberately pull upward on the switch to raise the window. These devices were used by Ford from the 1980's through 1994. Some manufacturers have even touted how its vehicles have lever switches for safety. In 1998, the Center for Disease Control reported that between 1987-1998, 19 children died in car trunks. After learning of the CDC numbers, the NHTSA commissioned a study on the benefits of an interior device to release the trunk lid. The NHTSA's expert panel recommended that trunk release devices would increase safety. In commending the expert report, NHTSA's Director indicated that "the Department holds safety-especially the safety of young children-as its highest priority. In October, 2000 the NHTSA announced that all passenger cars with trunks must have a release or other automatic system inside to allow people to escape effective September 1, 2001. In announcing the new standard, the NHTSA noted that "there have been too many deaths of children caught in trunks in hot weather with no way out-this will provide them a means of escape." Unsafe Horizontal Rocker Toggle Switch Safe Lever Switches have to be pulled up to raise a car window. Even though the interior trunk release glows in the dark, some children will panic and will never pull the release handle, others will be too small to pull the handle. As a first line deterrent, children should not be able get into a trunk in the first place. For example, most vehicles today allow the trunk to be opened without the use of a key. Hence, the vehicle keys can be locked away yet the trunk can still be opened. Vehicle manufacturers should require that the only way a trunk can be opened is with a key. This would eliminate the opening of the trunk in the first place. As for seats that can be laid down so that there is passthrough between the rear seat and the trunk, the locking mechanism for the rear seat should be found in the trunk. Ford's L.W. Camp wrote the NHTSA in 1996 stating that "closing the window requires the switch to be pulled and held…The intent of these features is to minimize the chance of unintentional activation of a power window closing that could, with other switch design configurations, result from a child leaning or resting a foot on the switch." Ford re-introduced them in its 2003 Lincoln Navigator. The interior trunk release will save lives. However, others will be lost because the trunk could be opened without a key. Convenience must take a backseat to safety occasionally. As such, trunk designs should prevent access to the trunk. Safe Switches the firm Page 17 · · Trunk Entrapment Stop the Blame Game A fundamental part of engineering is to identify potential risks, hazards and dangers through Design Failure Mode Analysis, Failure Mode EffectsAnalysis and fault tree analysis. The engineer’s job should include evaluating every potential use and misuse of the product. Once the identification of potential risks, hazards and dangers is conducted, then the engineer can address ways to design away, guard against and warn users of the identified risks, hazards and dangers of a given product. WARN Against Risks, Hazards and Dangers GUARD Against Risks, Hazards and Dangers DESIGN AWAY Risks, Hazards and Dangers Engineering Triad Nowhere does the concept of blame the consumer or user enter the engineering triad. Engineers need to get back to the basics of protecting everyone equally who ride in vehicles regardless of whether or not it is mandated by Federal Safety standards. The code of ethics for engineers is simple: Engineers, in the fulfillment of their professional duties, shall hold paramount the safety, health and welfare of the public. Page 18 Applying the engineering triad to child safety issues requires that children and adults be protected equally. the firm Conclusion There are hidden dangers inside vehicles that are killing and maiming children every day. Rather than focusing on blaming parents and caregivers when a child dies, the vehicle and child safety industry should work together to help protect our children. These same industries should work with state and federal officials to draft legislation that will provide meaningful safety standards for children. If children are truly the most precious cargo we carry in vehicles, why is it that they seem to be neglected after age four? Children of all ages deserve equal protection in the event of a vehicle accident. Parents and caregivers cannot be prison guards to children. Knowing this, the vehicle industry should take design steps to insure that no child can be hurt due to an innocent mistake. The organizations that I have listed in this brochure are staffed by wonderful volunteers. And, like most organizations, are always looking for contributions. Organizations like Kids-and-Cars, Kids-in-Cars and VOICES for Alabama’s Children are helping parents and caregivers alike to realize that there are numerous hidden dangers inside the vehicle sitting in your driveway right now. With time, they will convince legislators. With our help, we can help them convince the vehicle and child safety industry that hidden dangers inside our vehicles are unacceptable. the firm Page 19 Our children are the most precious cargo we will ever place in a vehicle. All reasonable steps should be taken to leave no child behind when it comes to vehicle safety. Wouldn’t it be nice to wake up to a new policy which actually takes steps to keep any more children from being killed on our nation’s highways. iveways r d n w o ir ed in the l l i k n e r ild more ch o w t k e i s we ATION: Th r e t s i g e R HE N l a n AROUND T o lication i b t u P a A S N AU y l i a D The wn USA Any To 3 n, 200 l Editio Specia ed See relat paper g News Leadin ’s n o ti The Na s n g i S t Presiden New Law articles ats Child Se Page 3 - Design Fixes Page 6 - Hidden Dangers e Page 12 Inside and outsid . Vehicles o be t d l i h C “No d In n i h e B t f Le ty” e f a S e l c i Veh d and chil le ic h e v d “The e delaye v a h s ie the dustr safety in d too long”, said our e of and stall oo many s , o u r T “ t. n Preside e c i o u s a s s e t ly”. r m o s t p ave died needless SA, T h ng small o children, cording to NH e of m a te a Ac charg death r s time that th is ency in ardization, the g It’ a l a r e elming. tions. By an h w r the fed fety and stand e v o er na d les is a vehicle s and around vehic ndards set in oth both houses an t in in ta umen children me up to the s law was passed d the doc nger e n ig o s c is e y h As in, th no lo countr ing marg by the President. ally. There will lm ay e h w r e e ov m this d t equ ang o d h r c F te t c u . te o e o h g r a it a signed w hildren must be p ight, weight or ddress this issue e a C h “ d n to due eyes a he said in safety ety will open its p a g a be af vehicle s forward, vehicle design”. e, the sourc the ts 50 cen firm 5473 Blair Road Dallas, Texas 75231 (214) 324-9000 [email protected]
© Copyright 2024