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ews Protecting Children in Traffic

NHTSA Priority Plan, 2011-2013

At one time or another, each of us in CPS has identified an aspect of the field that needs a fix and perhaps even thought, “There oughta be a law!” Since its creation in the mid-1960s, NHTSA has set standards and instituted many important regulations in response to safety legislation and research findings. However, there’s always more to be done, and NHTSA keeps track of the areas it sees as being of greatest concern via its “Rulemaking and Research Priority Plan.” Anyone wondering what NHTSA is tackling next can gain insights into the agency’s efforts and intentions by viewing this public document. The most recent plan was released in March, covering 2011-2013, and can be found by going to www.regulations. gov and entering docket number NHTSA-2009-0108. (It is also a “Quick Click” on the NHTSA homepage.) In it, NHTSA identifies projects that are broken down by its key program areas: light-vehicle crash avoidance and mitigation advanced technologies, motorcycles, rollovers, front-impact occupant protection, sideimpact occupant protection, children, older people, global technical regulations (harmonization), heavy vehicles, and others (a catchall category). NHTSA is also responsible for CAFE, or Corporate Average Fuel Economy, standards. For each program area, there are two priority levels, which are determined based on how critically the problem impacts large groups, vulnerable populations, high-occupancy vehicles, or any other special aspect. As the name implies, “Priority Programs and Projects” Continued, page 4

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July/August 2011 • Vol. XXIX, No. 4

Exploring Some Angles of the Angle Issue (This article, part one of a two-part series, looks at how proper rear-facing angle is assessed, especially for older children, and how to use “level to ground” lines on labels. In the next issue, SRN will explore issues related to rear-facing CRs touching front seatbacks.) After many years of knowing, from The basics research and Swedish crash experience, Beginning with the standardized certithat keeping children rear facing as long fication curriculum, CPST candidates are as possible is best, the CPS community taught that CRs for young children have to now has strong support for this best recline because infants’ heads are heavy practice from the American Academy of and babies have limited neck muscle Pediatrics’ April policy statement on child control. As described in the curriculum, passenger safety. Armed with that re- if a baby’s CR is installed too upright, the spected organization’s advice to keep kids heavy head might flop forward, which rear facing until at least age 2, if possible, could block the airway. or even longer if they still fit, the community is doubly blessed by the accessibility of numerous CR models that will hold children up to these higher weight limits. Such models are even available in today’s marketplace across all price levels. One persistent (and, perhaps, worsening) problem plagues these otherwise heady times—the problem of fore-aft space with a tall, reclined, rear-facing CR. As CR weight limits grow, the CR seatback naturally lengthens to fit the also-taller The curriculum also notes: “As baby child. In the meantime, vehicle space has ages and obtains better head control, he/ not grown, and, in fact, may have gener- she may sit more upright. This can actualally shrunk. In many cases, therefore, the ly provide for improved crash protection.” challenge of keeping kids rear facing to This alludes to the fact that the more uphigher weights isn’t convincing the par- right a rear-facing CR is during a crash, ents to do so or even finding a suitable the more the force will be spread evenly and affordable CR. Now, more and more across the back of the child (and less on often, the difficulty is getting the CR to fit the shoulders loading the harness). Also, in the vehicle while still following manu- the head is less likely to ride up and out of facturer’s installation instructions for the the protective shell. Continued, page 6 angle of recline. Fore-aft space is mainly a problem beContents cause a rear-facing CR has to recline. For a NHTSA Priority Plan . . . . . . . . . . . . . . . 1 matter that may simply be the difference Angle Issues Explored . . . . . . . . . . . . . 1 of a few degrees, the issue of rear-facing Editorial: Use Care with New CRs . . . . 2 angle is rather complex. CPSTs have been New Britax, BubbleBum CRs . . . . . . . . 3 taught the basics of general crash dynamInflatable Belts in More Vehicles . . . . 3 ics, but also have to take into account the Disposing of Unsafe CRs . . . . . . . . . . . 5 varied directions from CR manufacturers. New Wheelchair Standards . . . . . . . . 7 With the advent of the advanced air bag Advocates President Retires. . . . . . . . 7 and concern for pressure on the back of Resources: 213 Outline, Preventing . . 8 the vehicle front seat, even some vehicle Heat Stroke, CPS Week, Combi Info manufacturers weigh in on this subject. Calendar. . . . . . . . . . . . . . . . . . . . . . . . 8

The National Child Passenger Safety Resource for Health and Safety Professionals & Advocates

Deborah Davis Stewart, Editor & Publisher

Safe Ride News is a subscribersupported bimonthly publication for health and safety professionals and advocates. Mention of products in this newsletter does not signify a recommendation or endorsement by the publisher.

Publisher & Editor: Deborah Davis Stewart Managing Editor: Denise Donaldson Graphic Design: Nancy Beaumont Writers in this issue: Joe Colella, Betty Mason, Jean Zimmerman Photos: Cesi Velez, Britax, NHTSA Editorial Advisory Board: Marilyn Bull, MD, FAAP, Auto Safety Program, James Whitcomb Riley Hospital for Children, Indianapolis, IN David Campbell, David Campbell & Associates Joseph M. Colella, Traffic Safety Projects Audrey Eagle, Child Passenger Safety Advocate, Chrysler Group LLC Kathy Furneaux, Pupil Transportation Safety Institute Bill Hall, Highway Safety Research Center, University of North Carolina Nancy Lang, Child Passenger Safety Consultant Miriam Manary, Senior Research Associate, Biosciences Division, University of Michigan Transportation Research Institute Richard Stalnaker, PhD, Ristal Engineering Stephanie Tombrello, LCSW, SafetyBeltSafe U.S.A. Lorrie Walker, Safe Kids Worldwide Elaine Weinstein, formerly with NTSB Howard Willson, Safety Engineer, formerly with DaimlerChrysler Corp. © 2011 Safe Ride News Publications, The Willapa Bay Company, Inc. This newsletter is copyrighted (ISSN #15238261). Articles may not be copied for distribution without permission of the publisher. If readers find a need to share this publication with others on a regular basis, please consider purchasing a discounted group subscription.

Safe Ride News Publications PO Box 38 Edmonds, WA 98020 800-403-1424 • 425-640-5710 [email protected] www.saferidenews.com

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2 • July/August 2011

Editorial When It Comes to Innovative Products, U.S. System Requires Us to Look Before We Leap Consumers and CPSTs are wise to be open-minded to innovative CPS products, but also wary. Doing some homework is well-advised before adopting CR products that are new and/or very unusual. Remember—to sell a CR in the U.S., the manufacturer must self-certify that it meets FMVSS 213. Certification is not provided by a third party or by NHTSA. In fact, a manufacturer is not even required to alert NHTSA to its new product introduction. (NHTSA does perform compliance testing; see box at right.) In the case of the BubbleBum inflatable booster, described on the next page, the company states that the product meets all U.S. standards, and the high-profile manner in which the booster has been introduced to our market (announcement through press release, participation in industry conferences, offer for a discount for sample products for instructors) inspires a sense of confidence. It may be reasonable under these circumstances for us to accept the company’s claims that it meets our standard, though, given the very unusual design of this product, it seems prudent nonetheless to keep a watchful eye on NHTSA for any new information. To date, it does not appear on the list of CRs that NHTSA has tested for compliance. Continuing to get more familiar with the company and the product makes sense. Unfortunately, not every manufacturer is equally trustworthy. CR products continue to pop up, especially via the Internet, that make similar claims of meeting FMVSS 213, but no solid proof of this is required. For example, there is currently an inflatable highback booster, made by a Czech company and sold in the U.K. with the name Easycarseat, which consumers can make arrangements to order online here in the U.S. The company website emphatically and frequently states that the product meets all U.S. standards. What the unsuspecting consumer wouldn’t know is that the Easycarseat booster has already been under NHTSA’s scrutiny. Crash test footage (posted by Easycarseat on its own website, but later pulled off) shows a crash sequence in which the dummy submarines significantly, causing extreme knee excursion. As the dummy submarines, the lap belt rides high on the dummy abdomen. According to NHTSA, it

contacted Easycarseat this spring to get more information. Rather than provide that information, Easycarseat indicated to NHTSA that it has no intention of selling restraints in the U.S. until additional testing is done. NHTSA said it further stated that some boosters had been “incorrectly sold to U.S. customers,” but that the company was voluntarily recalling those units. NHTSA Compliance Testing Database To find out which CRs have been tested by NHTSA (and see test results), go to: http://www.nhtsa.gov/cars/problems/ comply. Select “Equipment” and then “FMVSS 213.” Search can then be narrowed by date and manufacturer. Now, several months later, the company is displaying its “Seal of Approval” from the U.S.-based National Parenting Center on its website and Facebook page, and a simple search on the Internet turns up a Chinese distributor that will sell this product online to U.S. consumers. Based on promotional images, the booster also seems to be marketed here online under the pseudonym Travel Car Seat. Most telling, the company’s website has a prominent notice stating that the company is “actively looking for U.S. distributors.” These days, consumers are accustomed to shopping for deals on the Internet, and almost anyone can become a retailer if he can set up a webpage, so it has become more necessary than ever to be vigilant. Anyone can broadcast claims of passing standards with very little risk of serious repercussions if this claim is false. We certainly don’t discourage innovation. However, we have no choice but to use caution with new products and manufacturers. With so many ways to market products, we can’t just assume NHTSA has heard of every CR out there for sale. We can help by reporting concerns to NHTSA using the online form at https://www-odi.nhtsa.dot.gov/ ivoq or by calling (800) 424-9393. As for the Easycarseat, NHTSA has informed us that it is continuing to look into the matter, though apparently it has not yet run its own compliance tests. We will report more as we learn of new details.

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CR Products New Britax CRs and CEU Opportunities

Britax has recently started shipping its two newest CR products.

 The B-Safe infant CR is rated for children 4-30 pounds and up to 32 inches. At a suggested retail price that is $50 less than Britax’s other infant CR, the Chaperone, the B-Safe has a different base that does not have a reboundmitigation bar. It is similar to the Chaperone in other ways, but does not have a no-rethread harness adjustment mechanism nor the sideimpact head insert. Britax B-Safe (For those who are w o n d e r i n g — ye s , this marks the first time that Britax has had more than one infant CR on the U.S. market at the same time.) The Frontier 85 SICT (side impact cushion technology) is a combination CR that is rated for children 2 years of age AND 25 pounds to 85 pounds in harness mode and 40 to 120 pounds in booster Britax mode. All of its fea- Frontier SICT tures are the same as a regular Frontier 85 except the impact cushions along its exterior (which are like those on the Britax Advocate). The Britax website describes the impact cushions by saying that they “reduce side impact crash energy by 45 percent by diverting crash forces away from your child and providing extra protection for the adjacent passenger.” Also, a new CEU opportunity will become available on the Britax Advocate Extranet in early September that will cover the features and installation of its two infant seats. To access the Britax Extranet: 1. Log in to your account at cert.safekids. org. 2. Scroll down to “action items” and select on-line CEUs (under #8). 3. Select Britax tech site, #3. 4. From the Britax Extranet, select “Obtain CEUs” from the menu at left. Contact Sarah Tilton at Britax (Sarah. [email protected]) with any questions.

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British Invasion—The BubbleBum Arrives in the U.S. An innovative concept to chew on, the BubbleBum is an inflatable, backless booster that originated in England, has been selling well across Europe, and is now available in the U.S. The concept of an inflatable car seat, though always an eyebrow-raiser, has been tried a few times over the years. As the latest of these products, the company says the BubbleBum has been tested and passes both the European standard and FMVSS 213. In addition to the inflated air chamber, the booster construction also includes memory foam, an internal seating structure made of webbing, and innovative lap belt guides. Though ideally all the parts work together, the company says that, if the booster were to be deflated, these other parts would still function to position the vehicle belts. The booster weighs under a pound and can be rolled into a small stuff-sack that easily fits into a purse or backpack. Proponents of the BubbleBum note that it solves many booster seat problems. Because it’s lightweight and small when deflated, it is easy to take on trips or transfer with the child in a carpool. (It blows up in only three or four breaths.) The company indicates that kids say the seat is both comfortable and more likely than a regular booster to be viewed as cool. Since it lacks armrests, it is very narrow — only about 13 inches wide. Two benefits to this are that it makes it more likely to fit in tight spots between other occupants/CRs, and it may be easier for a child to access the buckle

BubbleBum booster, promotional photo

and attach the seat belt himself. The typical disadvantage of many designs that lack armrests—that the lap belt tends to ride up on the abdomen—is addressed by the plastic lap belt guides on each side of the seat. Like any backless booster, it lacks upper body support or potential side-impact protection, and at $39.99 plus shipping/ handling, it is roughly twice the price of some other backless boosters. However, in its ability to meet many needs of families in a unique way, it should be an interesting new option on the U.S. market. Dr. Alisa Baer has a thorough review on her blog, http://thecarseatlady.wordpress.com, which includes a video. (Enter BubbleBum in the search tool found on the homepage to find this post.) Based in New York City, she sees potential for these boosters to be of special use to families when traveling or when riding in taxis. BubbleBum will be an exhibitor at the KIM conference in August, and you can learn more about it at http://www. bubblebum.us/cspt.

More Cars Will Have Inflatable Seat Belts Ford Motor Company has announced that more of its vehicles will optionally include rear-seat inflatable seat belts. The first inflatable seat belt was offered by Ford as an option in certain of its Explorer SUVs beginning earlier this year. Ford says it will expand that option to Ford Flex crossovers and two yet-unnamed Lincoln models by summer 2012. Ford reports that 40 percent of Explorer XLT buyers have chosen to add the $195 option. Ford is also considering whether a safety benefit would be gained by adding inflatable seat belts to the front seats of vehicles, as well.

Though Ford shares a patent for its inflatable belt with one of its suppliers, Toyota has since added inflatable seat belts made by a different company, Takata Corporation, to its 2012 Lexus LFA. However, in the Lexus LFA, an upscale sports car with a limited production run, the inflatable belt is a standard front-seat feature. SRN’s Jan/Feb 2011 issue includes a report that explores the CPS ramifications of inflatable seat belts. To date, Britax and Combi have prohibited use of these belts with their products, while Chicco has provided certain specifications for their use with the Key Fit and Strada CR models (see May/June 2011 SRN). July/August 2011 • 3

NHTSA

Priority Plan, from p. 1 are the projects that top the list in terms of importance. The second type, “Other Significant Programs and Projects,” are also important, but their schedule is more likely to be impacted by competing projects, such as petitions that require immediate attention or requests made by Congress or the DOT. In total, there are 53 NHTSA projects in both categories for 2011-2013. Though the plan is titled 2011-2013, it indicates direction more than a to-do list, as few items are likely to be neatly checked off by the end of 2013. The process of assessing a situation, identifying countermeasures, and promoting a solution can take months and often years for a variety of reasons, including the time required to col-

lect and analyze data and to process feedback from the public comments. The current plan summarizes the progress made in the former priority plan (2009-2011), and it is clear that most projects are expected to progress but not be completed during the years of the current plan. In a strongly-worded letter to Transportation Secretary Ray LaHood last March, Sen. Jay Rockefeller, D-W. Va., chairman of the Senate Committee on Commerce, Science and Transportation, was nonetheless critical of the slow pace of progress made over the past two years. Saying, “I have continuing concerns that more needs to be done to protect children from injury or death in car crashes,” he specified lack of improvement in the areas of side-impact

testing, more realistic crash testing, and development of a biofidelic 10-year-old dummy as especially troubling. The following boxes list the projects that are included under the “vulnerable population” program area of “Children” in the Priority Projects and Other Significant Projects categories. In addition to these projects that are categorized under “Children,” there are many other NHTSA actions that will have an impact on children, if perhaps less directly. Among these are the upcoming decision, targeted by 2012, concerning whether to require lap-shoulder belts in all motorcoaches, and whether a performance requirement for sound should be added to very quiet hybrid and electric vehicles.

2011-2013 NHTSA Plan “Priority Projects” Regarding Children • Child Restraints in Side Impacts: This project aims to develop and propose test procedures for near-sideimpact testing that will be incorporated into FMVSS 213. The project would also require the amendment of Part 572 (Anthropomorphic Test Dummies) to include dummies that are appropriate for this type of testing. In the plan, NHTSA specifies that the 3-year-old side-impact version of the Q-series of dummies, developed in Europe for omnidirectional tests, will be proposed. The plan tells us we can expect to see a Notice of Proposed Rulemaking (NPRM) on this in 2012. (An NPRM spells out exactly NHTSA’s proposal for a final rule, provides the rationale, and signals the opening of a public comment period.)

• Vehicle-CRS Fit Program within the New Car Assessment Program: NHTSA requested comments during the first months of 2011 on this proposal, which aims to provide suggestions for CRs that fit each vehicle via a voluntary vehicle manufacturer program. (See SRN March/ April 2011’s editorial.) NHTSA is deliberating and indicates that a final rule will be published in 2012. • Rear Visibility of Vehicles and Power Windows: Both of these projects were spurred by the Cameron Gulbransen Kids Transportation Safety Act of 2007, which was passed by Congress to prevent children from being injured or killed in or around vehicles in noncrash situations. The administration promises a final rulemaking on the rear visibility

issue by December 2011. Its review of the power window project, which would have required technology to make the window reverse direction when an obstruction was detected upon closing, led to the withdrawal of this rulemaking action because the agency determined that the most serious types of injury were addressed by prior rules for safer switches. (Another component of this act, the Brake-Transmission Shift Interlock, which is technology that prevents a child from accidentally setting the vehicle in motion, was one of the few projects from the 2009-2011 priority plan that was completed during that planning cycle.)

“Other Significant Projects” Regarding Children

The three projects identified under the category of Other Significant Projects all relate to the subcategory of “Improved Frontal Protection for Children.” They are: • Boosters: NHTSA is currently considering comments on its latest Supplemental Notice of Proposed Rulemaking (SNPRM) on a proposal to update FMVSS 213 to include testing of boosters with the Hybrid III 10-year-old (H3-10C) and the addition of that dummy to the arsenal of dummies for testing. The 4 • July/August 2011

overall effort was first proposed in 2005 in response to Anton’s Law of 2002. The plan estimates a final rule will be published by the end of this year. (See SRN Jan/Feb 2011 for more details on this situation.)

• Lower Anchors and Tethers for Children: The agency states that, after an assessment of the status of LATCH, it will decide by the end of 2011 whether to initiate rulemaking to address LATCHrelated issues. Issues it will consider include LATCH installation in the center

rear, TA locations, weight limit differences between CRs and tether anchors, and anchorage labeling. • Test requirements: NHTSA aims to examine how well the current FMVSS 213 test parameters, including test pulse, velocity, excursion limits, and test seat, replicate real conditions in today’s vehicles. The agency plans to assess research data, existing requirements, and potential countermeasures. It will decide on next steps by some time in 2013.

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Getting Unsafe Car Seats Out of Circulation— Often Cutting the Straps is Not Enough Experts agree that the key to the proper disposal of an unsafe CR is to make it unusable, but the definition of unusable and the method of destruction has been left to individual discretion. Owner’s manuals may say to destroy an unsafe CR, but don’t say how to do so. The standardized CPS certification curriculum provides no detailed clarification on this subject. Often technicians or parents merely cut the straps or remove the padding of an unsafe CR and consider it to be unusable once put into a dumpster or set out for curbside garbage pickup. Few people realize, however, that some individuals in the community may, nonetheless, be motivated to take what seems to them to be a serviceable plastic CR shell and reclaim it for their own use or financial gain. Manufacturers report that it is not uncommon for people to call their customer service departments for new straps and/or padding so these shells can be reused—or even resold in a second-hand store or online. Some CRs have also been found at checkup events that have parts pieced together from multiple manufacturers or models. Even worse, in some cases, strapless or padless CRs are used “as is” or employed as make-shift boosters. When to destroy a CR A CR should be destroyed if: • It has been involved in a crash that requires replacement, as defined by the specific manufacturer for the specific model. Although NHTSA may offer guidance for circumstances in which a CR that has been in a crash definitely needs to be replaced (view these guidelines at http:// www.nhtsa.gov/people/injury/childps/ childrestraints/reuse/restraintreuse. htm), most manufacturers would advise replacing the CR regardless of the crash severity—and even regardless of whether it was occupied at the time of the crash. This information is often contained in the warnings section of manufacturer instructions, and many manufacturers repeat it on their websites or through their customer service departments. • It is beyond its expiration date, as defined by the manufacturer. While the Juvenile Products Manufacturers Association generally recommends six years from the date of manufacture, each mod-

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el has its own expiration date. The useful life varies from around six to as many as nine years, and further exceptions have been made for specific models. That information is typically found molded into the shell, on labels, or in the warnings of the instructions. When in doubt, contact the manufacturer. • It is recalled for crashworthiness reasons and the manufacturer says to destroy it. Most recall problems can be fixed by applying a repair kit and do not require the car seat to be destroyed. However, some may require destruction and replacement of the CR. • It has damaged or missing parts that can’t be replaced. Manufacturer warnings usually state that damaged CRs should be replaced. If there are questions about whether the situation requires replacement parts, contact the manufacturer’s customer service department. How to dispose of unsafe CRs Check with the local recycler to find out what parts of a CR may be recycled in a given area. Some parts may qualify for curbside recycling and can be cut off the CR and sorted into the appropriate collection canister, or other arrangements can be made with the recycler. Any parts that cannot be recycled should be properly destroyed before disposal. To make a CR unusable, the manufacturers SRN surveyed suggest the following steps: • Remove and cut the harness straps, crotch strap, and padding. (Scissors work, but a good belt cutter is better.) • Destroy the plastic shell by crushing or cutting it. (See next section.) • Recycle the harness, padding, and plastic shell parts through a local recycling facility, if possible.

CR Disposal If you are unable to destroy a CR shell entirely to prevent reuse, some suggestions include using a permanent marker to prominently declare the seat as unfit for reuse, marking out the model number so that new parts can’t be ordered, and using a dark garbage bag when placing it in the trash. How to crush a plastic shell One might rightly wonder, “How do I crush plastic that was made to withstand crash forces?” The old-fashioned way, striking it with a tool like a sledgehammer, might work. Anyone trying this approach should be comfortable with the effort required and take safety precautions, like wearing protective eyewear. If you are not one to attack a CR (even an unsafe one) with a sledgehammer, a better option might be to seek out a place that has a crushing machine. Many organizations, including major retailers (such as Target, Walmart) and some hospitals, have industrial-grade crushers at their facilities. CPSTs can develop relationships with these organizations to get permission to occasionally add unsafe CRs to their items being crushed, something they may be willing to do as a service to their community. (Note, however, that if the CPST is not there to actually see the item being crushed, it is still a good idea, before dropping it off, to permanently mark the plastic with instructions that say the shell is unsafe and is there to be destroyed. Also, obscuring the manufacture date and model number would make it impossible for someone to order replacement parts.) This sounds like a lot of work, but developing a system for disposing of unsafe CRs is the best way to ensure that families do not unwittingly reuse them to restrain a child. —Joe Colella What looks like trash to one person may look like a resale opportunity to another, so it is important to completely destroy unsafe CRs.

July/August 2011 • 5

Recline Angle Angle, from p. 1 So, CPSTs learn that identifying the correct angle involves a trade-off between reclining just enough for safety during normal driving and not being reclined to an extent that the CR does not function properly during a crash. The range of appropriate recline angles is commonly understood to be 30 to 45 degrees from vertical (also noted in the curriculum). Candidates are also taught to follow CR manufacturer advice regarding specific models. (Interestingly, the curriculum instructor notes also say, “Inform students to also look to be sure [the] angle is correct as some indicators may not give a true reading.”)

Manufacturers’ Instructions Vary

The curriculum aims to give CPSTs a good understanding of general principles, but makes it very clear that it is important to follow the instructions provided by manufacturers. A survey of actual models makes it clear that there is little that can be generalized. For any given CR model, angle guidance can be found in a number of places: depicted in the owner’s manual, on the label (usually in the form of a “level to ground” line), and/or on an angle indicator gauge on the CR or base. The angle indictor feature (dial, bubble, etc.) is nowadays found on most infant seats, but usually not on convertible CRs. A few rare models, such as the Learning Curve True Fit Deluxe and Baby Trend Flex-Loc, specify one range for the youngest occupants and a second, more-upright range for older babies/toddlers. These days, the taller, convertible CRs more commonly have a line on the label with instructions that the line should be parallel to the ground or vehicle floor— the so-called “level to ground” line. This angle guidance line has one important advantage: it is extremely inexpensive. This is a huge consideration these days, when price matters, but many user-friendly CR features tend to force prices upward. However, a disadvantage is that a line that must be parallel to the ground does not provide a range of acceptable angles—it dictates only one angle. It is important to consult all manufacturers’ instructions, since the manual and label wording may provide details beyond the indicators on the CR. 6 • July/August 2011

Manufacturers Surveyed About “Level to Ground” Lines

The crux of many problems involves situations in which the CR has a tall seatback, and there’s not enough fore-aft space to fully recline to the angle indicated by the “level to ground” line. Even in vehicles that do have enough space, some older babies/toddlers, who still fit rear facing, nonetheless object to being secured at an angle as reclined as 45 degrees. In either of these cases, the caregiver or CPST often questions a “level to ground” line that reclines the CR to an angle that seems to be excessive for an older child. The caregiver may be tempted to either ignore the angle line or turn the child forward facing. SRN surveyed manufacturers to find out what additional advice they could give on this matter. Though the individual responses varied, the message from those who responded was clear: Do not secondguess the instructions. Here are some other details:

Britax

On the current platform of convertible CRs, Britax provides a blue line on each side of the CR, which it calls an “angle guide line.” The label and the owner’s manual indicate that the CR, when rear facing, can be installed between 30 and 45 degrees. When the blue line is level to the ground, this is in the middle of that range. So, on the current platform of Britax CRs, the blue line gives a guide for the center of the acceptable range, and the CR may be installed off-level a bit in either direction, so long as the CR is reclined between 30 and 45 degrees. (Editor’s Note: It would be prudent to allow the seat to be more upright only for babies who can sit up well.) On discontinued and Classic versions of Roundabout 50 and Marathon (still sold at Target), some models have wording in the owner’s manual like that in the current platform that says the CR, when rear facing, can be used between 30 and 45 degrees. If that wording exists, and there is a “level to ground” line, follow the range as described in the guide. Otherwise, if there is only a “level to ground” line, follow that exactly. Though Britax has angle indicator devices on its infant seats, both the new B-Safe (see article on page 3) and Chaperone have “level to ground” lines on the

CR for use when it is installed without the base. Britax is very clear that, on these CRs without the base, this is a true “level to ground” line – not an “angle guide line,” as on the convertibles. The subtle but important distinction between the two is that a “level to ground” line must be followed strictly, while an “angle guide line” allows some leeway as described in the convertibles above. When using the infant CRs without the base, the line MUST be parallel to the ground; when used with the base, follow the angle indicator bubble. Sarah Tilton of Britax made a point that was echoed by the other manufacturers when asked why instructions are so specific: because this is how the manufacturer has tested the CR and found its performance to be acceptable.

Evenflo

Evenflo strives to keep instructions simple to reduce confusion. The instructions say to “adjust the restraint so that the level line is parallel with the vehicle floor.” Evenflo urges CPSTs to continue to follow these guidelines and to not vary from them, because the instructions reflect how the CR has been tested.

Sunshine Kids

Sunshine Kids Radian convertibles do not have a “level to ground” indicator on the label, since the company says this is not needed. According to Sunshine Kids, as long as the CR is used properly with the rear-facing base/foot properly attached, the CR cannot be installed at an incorrect/ unsafe angle.

Dorel

SRN was especially interested to hear from Dorel on this subject, due to the frequency with which vehicle fore-aft issues come up with its CRs, such as the Alpha Omega models. The “level to ground” line is embossed on these CRs into the plastic of the booster-mode’s shoulder belt guide. Many CPSTs find that strictly following this line places the CR at what seems to be an extremely reclined angle and often wonder if this should be considered an indicator of maximum recline only. Though Dorel did not respond to SRN’s survey, important feedback on this subject was shared during Dorel’s July 15th webinar offered through Safe Kids. According to Dorel’s Ryan Hawker, the line is to Continued, next page

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Retirement Angle, from p. 6

be followed exactly, not as an indicator of maximum recline, and added that he could not elaborate on why a more-upright angle could not be used for older children riding rear facing, other than to say that Dorel has been experimenting with this and has determined that using its CRs too upright could lead to “different problems.” He added that Dorel is “working on it diligently here, and may have an announcement in the future.” In the meantime, he notes that setting the angle so the lines are level to the ground may be accomplished using either noodles or towels. One Dorel product that shows promise as a design solution to this problem is the new Maxi-Cosi Pria 70. This convertible CR, described in the March/April 2011 SRN, has a special structural insert that Dorel calls “Tiny Fit.” With the CR installed in the more upright position preferred for older babies, the insert can be added to provide a more reclined seating position within the overall shell for younger ones. Though other CRs have had inserts that reposition a baby (especially preemies or newborns), the Pria 70 insert is much more substantial than a typical padded insert. Therefore, it allows a significantly more upright installation for the shell than a typical convertible, while optionally creating the needed reclined position within the shell for the period of time that the CR is used by a young baby. Next issue: We’ll explore the subject of recline and why some CRs require clearance between the CR and the front seat seatback.

Wheelchairs

Look for Upcoming Improvements to Voluntary Standards for Wheelchairs This fall, the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) and the American National Standards Institute (ANSI) plan to announce several changes and improvements to voluntary standards for transporting wheelchair-seated passengers. There are three parts of the wheelchair transport system that each play a critically important role in occupant protection: the wheelchair frame, the wheelchair seating system attached to the frame, and the tiedown system for the wheelchair. Due to the complex nature of wheelchair customization, these parts have been addressed separately. The existing wheelchair (frame) standard, WC19, will see enhancements to address gaps that have been found in the years since that standard was published in May 1988. Improvements will include changes in crash test methodology and new requirements, such as integrated five-point harnesses for wheelchair-seated passengers between 25 and 50 pounds. Simultaneously, the Society of Automotive Engineers’ Recommended Practice J2249, which addresses wheelchair tiedowns and occupant restraint systems (WTORS), will be upgraded. Going forward, this revised standard will be referred to as WC18. In addition to these changes in existing standards for wheelchairs and WTORS, a new RESNA standard has been developed for wheelchair seating systems. These are often made separately to provide a seat

cushion, back support, and attachment hardware that meet the specific needs of the occupant. That new standard will be known as WC20. Seating that meets WC20, when paired with a wheelchair frame that meets WC19 and attached with WTORS that meet WC18, will create a complete crashworthy wheelchair system.

Wheelchair system parts that meet the upgraded voluntary standards will feature this new symbol.

These new standards will improve the safety of transporting individuals who may already be at greater risk for injury due to their physical and medical conditions. For the CPS community, the addition of the wheelchair integrated five-point harness system may provide a solution for safely transporting smaller children who cannot be moved from their wheelchairs to CRs. Safe Ride News will report further details as they become available. Information on wheelchair transportation safety from the University of Michigan Transportation Research Institute can be found at www.travelsafer.org. —Betty Mason and Jean Zimmerman

Celebrating 22 Years of Accomplishment— Advocates for Highway and Auto Safety President Retires

As president and executive director of Advocates for Highway and Auto Safety for the past 22 years, Judith Lee Stone has been actively involved in improving road safety standards, laws, and more. Her recent retirement created quite a buzz in Washington, D.C., traffic safety circles. Joe Colella, reporting for SRN and honoring Stone as a colleague, attended her small retirement gathering this summer. Other guests comprised a who’s who of traffic safety policymakers. Current U.S. Department of Transportation Secretary Ray LaHood and NHTSA Administrator David Strickland were in attendance, as were

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Adrian Lund from IIHS, Chuck Hurley from MADD, and Jack Gillis from Consumer Federation of America. Even more telling of Stone’s longtime influence on traffic safety was the fact that two former NHTSA administrators, Joan Claybrook and Elizabeth Dole, and consumer advocate Ralph Nader also attended. These were just a few of the people who publicly spoke at her reception and shared stories of the past and visions for the future. “What a great movement is the highway safety movement,” said Judie Stone, during an emotional speech. “We have done so much. How blessed am I to have

been a part of it.” Advocates for Highway and Auto Safety is an alliance of consumers, health and safety groups, and insurance companies. The group, primarily funded by the insurance industry, works to advance state and federal highway and vehicle safety laws, programs and policies. Each year, it produces a report on the state of safety legislation, the “Roadmap to State Highway Safety Laws” (see SRN Jan/Feb 2011). The group is a friendly-but-firm adversary as it challenges NHTSA, the U.S. DOT, Congress, state legislatures, and others to make needed improvements. July/August 2011 • 7

Resources

FMVSS 213 Outline Available at SRN Website Though CPSTs must often refer to FMVSS 213, even NHTSA employees agree that the long and complicated standard can be cumbersome to read. In preparation for an upcoming KIM Conference presentation, Emilie Crown and SRN’s Denise Donaldson summarized the standard into outline form so that it was easier to navigate. The pair found their new resource to be so useful that they’ve now posted it on the SRN website as a free resource for anyone else who is interested in looking more closely at the child safety restraint standard. The outline is detailed enough to stand alone for the casual user, but also serves as a helpful companion to the full text of the standard. The outline can be used to find subjects of interest, and page numbers that are provided in the margin help the reader locate the full text in the most-current version (10/1/10). Other features that are helpful include: • Outline format: As printed in the Federal Register, FMVSSs are aligned evenly

along the left-hand margin. The SRN outline uses NHTSA’s same outline notations, but indents them into true outline form. • Color coding: The ten major sections of the standard are identified in the margin using different colors, and a key at the beginning helps readers find particular sections. • Clarifications: A careful reading of FMVSS 213 reveals some passages that are unclear or confusing, whether due to the terminology or because the passage is an outdated remnant that pertains to earlier versions of the standard. In these cases, Crown and Donaldson obtained clarification from NHTSA. So that the outline continues to reflect the words of the standard as written, these clarifications are included in the outline as parenthetical comments, each identified as an “Editor’s Note.” To view and/or download this PDF, go to www.saferidenews.com and look for “FMVSS 213 Outline” under “CPSTs/Professionals.”

Free “Look Before You Lock” Cards Help Prevent Heat Stroke KidsAndCars.org has launched a pilot program to distribute safety cards through hospitals to raise awareness among new parents of the risks of leaving a child alone in an automobile. In particular, the program aims to point out the very real possibility that a memory lapse can result in a child being accidentally left behind in a vehicle, which can result in the child suffering heat stroke and even death in a hot car. Through a grant from Toyota Motor Sales, USA, the program will provide cards in English and Spanish to be distributed with the free information packets that hospitals distribute to new parents when leaving the hospital. To request cards, hospital representatives should go to KidsAndCars.org and indicate the number of babies that are born at their facilities. Individuals may also download and print copies of the card at http://www. KidsAndCars.org/pr/parent-card.pdf. 8 • July/August 2011

Safety tips on the “Look Before You Lock” card include the memory device, BE SAFE: Back seat—Put something in the back seat of your vehicle that requires you to open the back door when you park, like a cell phone, employee badge, handbag, etc. Every child should be correctly restrained in the back seat.

Stuffed animal—Keep a stuffed animal

in your child’s car seat. Place it on the front passenger seat as a reminder when your baby is in the back seat. Ask your babysitter or child care provider to call you if your child hasn’t arrived on time. Focus on driving—Avoid cell phone calls and texting while driving. Every time you park, make it a routine to open the back door of your car to check that no one has been left behind.

Calendar 2011 CPS Week—September 18-24 Seat Check Saturday—September 24 National Association for Pupil Transportation (NAPT) Annual Summit October 22–27, 2011 Cincinnati, Ohio www.naptonline.org Lifesavers Conference—DATE CHANGE June 14–16, 2012, Orlando, Florida www.lifesaversconference.org Call for abstracts by August 22, 2011, to Lorrie Walker at [email protected]

Free CPS Week Materials Available

NHTSA has developed copyrightfree marketing materials and outreach templates to help you promote car seat safety during Child Passenger Safety Week and National Seat Check Saturday, coming up September 18–24. The agency also notes that programs should remember that these free materials may be helpful in efforts throughout the year. Materials may be tailored to fit individual program needs. Resources available in English and Spanish include: • Fact Sheet • Talking Points • Pre-Event News Release • Post-Event News Release Additional resources in English include: • Proclamation • Proclamation Letter • OpEd: CPS Guidelines • OpEd: Car Seat Inspections To access these and other NHTSA marketing materials, go to http://www. trafficsafetymarketing.gov.

Combi Harness Slot Exception

Though mention is not included in the owner’s manual for the Combi Shuttle 33, Shuttle 35, or Navette 22, Combi USA makes an exception regarding harness slot position for small newborns. Combi DOES permit newborns to use these CRs when their shoulders are below the lowest-most harness slots. Consumers can get this in writing, in the form of a letter that includes additional usage reminders and warnings, by contacting Vera Fullaway at vfullaway@ comcast.net.

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