Analysis for the development of legislation on child occupant
Transcription
Analysis for the development of legislation on child occupant
Transport Research Laboratory Analysis for the development of legislation on child occupant protection by M Hynd, M Pitcher, D Hynd, B Robinson and JA Carroll (TRL) CPR821 Specific Contract No: SI2.555655 Framework Contract No: ENTR/05/17.01 CLIENT PROJECT REPORT Transport Research Laboratory CLIENT PROJECT REPORT CPR821 Analysis for the development of legislation on child occupant protection by M Hynd, M Pitcher, D Hynd, B Robinson and JA Carroll (TRL) Prepared for: Project Record: Specific Contract No: SI2.555655 Framework Contract No: ENTR/05/17.01 Provision of information and services on the subject of accident analysis for the development of legislation on Child Occupant Protection Client: European Commission, DG Enterprise and Industry (Peter Broertjes) Copyright Transport Research Laboratory July 2010 This Client Report has been prepared for the European Commission, DG Enterprise and Industry . The views expressed are those of the authors and not necessarily those of the European Commission. Name Date Approved Project Manager William Donaldson 19/07/2010 Technical Referee Mervyn Edwards 19/07/2010 Client Project Report When purchased in hard copy, this publication is printed on paper that is FSC (Forest Stewardship Council) registered and TCF (Totally Chlorine Free) registered. TRL CPR821 Client Project Report Contents List of Figures vi List of Tables ix Executive summary xii 1 Introduction 1 2 Project Objectives 3 3 Summary of Results 4 3.1 Collection of Market Research Information 4 3.2 Test Bench 3.2.1 Cushion 3.2.2 Anchorages 5 5 5 3.3 Front Impact 3.3.1 Pulse 3.3.2 Installation of CRS and dummy 3.3.3 Rearward facing integral restraints 3.3.4 Forward facing integral restraints 3.3.5 Non-integral restraints 6 6 6 6 7 8 3.4 Rear Impact 10 3.5 Side Impact 3.5.1 Test conditions 3.5.2 Reproducibility 3.5.3 Repeatability 3.5.4 Criteria 3.5.5 Friction of Anchorages 11 11 12 13 13 13 3.6 Dummies and Criteria 3.6.1 Biofidelity 3.6.2 Criteria 13 13 14 3.7 Implementation 3.7.1 Issues for consumers 3.7.2 Issues for CRS manufacturers 3.7.3 Issues for OEMs 14 14 14 15 3.8 Indication of costs and benefits Option 2 – plus a side impact test Option 3 – with a new, more representative frontal impact test 15 15 15 4 TRL Conclusions 17 4.1 Test Bench 17 4.2 Front Impact 17 4.3 Rear Impact 20 4.4 Side Impact 21 4.5 Dummies and Criteria 23 4.6 Implementation 23 4.7 Indication of costs and benefits 24 i CPR821 Client Project Report 5 Recommendations 25 5.1 Test Bench 25 5.2 Front Impact 25 5.3 Rear Impact 27 5.4 Side Impact 27 5.5 Biofidelity and Criteria 28 5.6 Implementation 28 5.7 Indication of costs and benefits 29 Acknowledgements 30 Appendix A 31 A.1 A.2 A.3 A.4 A.5 A.6 A.7 Appendix B B.1 B.2 B.3 B.4 TRL Review of Accident Studies Objectives Types of accidents General injury mechanisms in accidents Front impact A.4.1 Front impact accident severity A.4.2 Body regions injured in front impacts A.4.3 Injury mechanisms in front impact Rear impact A.5.1 Rear impact accident severity A.5.2 Body regions injured in rear impact A.5.3 Injury mechanisms in rear impact Side impact A.6.1 Side impact accident severity A.6.2 Body regions injured in side impact A.6.3 Injury mechanisms in side impact Summary A.7.1 Front impact A.7.2 Rear impact A.7.3 Side impact Proposals for the New Procedures Test Bench B.1.1 Cushion Geometry B.1.2 Cushion Material Properties B.1.3 Co-ordinate System B.1.4 Anchorages B.1.5 Summary of anchorage locations Front Impact B.2.1 Test bench B.2.2 Sled pulse B.2.3 Test devices B.2.4 CRS installation B.2.5 Assessment criteria Rear Impact B.3.1 Test Bench B.3.2 Sled pulse B.3.3 Test devices B.3.4 CRS installation B.3.5 Assessment criteria Side Impact B.4.1 Test bench ii 31 31 35 37 37 39 43 43 43 44 45 45 45 46 50 50 51 51 51 53 53 53 55 57 58 66 67 67 67 73 74 74 76 76 76 77 78 78 79 79 CPR821 Client Project Report B.5 Appendix C C.1 C.2 C.3 C.4 C.5 C.6 Appendix D D.1 D.2 D.3 D.4 Appendix E E.1 E.2 E.3 TRL B.4.2 B.4.3 B.4.4 B.4.5 B.4.6 Dummies B.5.1 B.5.2 B.5.3 B.5.4 Door Test devices Intrusion CRS installation Assessment criteria and performance requirements Dummy design EEVC Q-dummy injury criteria and performance criteria GRSP informal group discussion on performance criteria Bending moment – lateral bending 80 81 83 84 85 87 87 89 92 94 Practical assessment of proposed procedures 95 Introduction 95 Child restraint selection 95 Test Bench 97 Assessment of front impact proposals 99 C.4.1 Criteria Evaluation 100 C.4.2 Assessment of proposed protocols using an alternative pulse 112 C.4.3 Future work 121 C.4.4 Front impact summary 122 Assessment of rear impact proposals 124 C.5.1 Introduction 124 C.5.2 Effect of the proposed test bench 124 C.5.3 Evaluation of proposed dummy performance criteria 128 C.5.4 Rear Impact Summary 131 Assessment of side impact proposals 133 C.6.1 Introduction 133 C.6.2 Anchorages 133 C.6.3 Test conditions 133 C.6.4 Restraint system loading 137 C.6.5 Repeatability and reproducibility 143 C.6.6 Evaluation of proposed dummy performance criteria 147 C.6.7 The effect of varying friction in the ISOFix anchorages 155 Testing observations and possible restraint regulation nonconformities Rearward facing integral restraints D.1.1 Low rated restraint – IWH Babymax D.1.2 High sales restraint – Maxi-Cosi Cabriofix Forward facing integral restraints D.2.1 Low rated restraint – Nania Cosmo D.2.2 High rated restraint – Maxi-Cosi Priorifix D.2.3 High sales restraint – Bebe Confort Iseos Forward facing non-integral restraints D.3.1 Low rated restraint – Jane Monte Carlo Side impact Review of the Implementation Phasing of the new Regulation Introduction Definitions Implementation phases E.3.1 Phase 1 E.3.2 Phase 2 E.3.3 Phase 3 158 158 158 158 158 158 159 159 159 159 159 160 160 160 161 161 162 162 iii CPR821 Client Project Report E.4 E.5 E.6 Approval routes E.4.1 Single approval E.4.2 Dual approval Specific areas of concern E.5.1 Semi-universal category E.5.2 Vehicle specific category E.5.3 i-Size E.5.4 Labelling E.5.5 ISOFix vehicle compatibility Summary Appendix F F.1 F.2 F.3 F.4 F.5 F.6 163 163 164 169 169 169 169 169 170 171 Indications of the potential costs and benefits 175 Introduction Casualty valuations Options for assessment F.3.1 Option 1 – Q series dummies, existing frontal impact test F.3.2 Option 2 – plus a side impact test F.3.3 Option 3 – with a new, more representative frontal impact test Target populations F.4.1 GB casualty data F.4.2 EU27 casualty data and estimates F.4.3 EU27 Estimate Method 1 – GB data weighted by all road user fatalities F.4.4 EU27 Estimate Method 2 – GB data weighted by car occupant fatalities F.4.5 EU27 Estimate Method 3 – GB data weighted by EU18 child car occupant fatalities and EU27 child road user fatalities F.4.6 Summary of EU casualty estimates Benefits estimate F.5.1 Effects of previous legislative changes F.5.2 Usage rates F.5.3 Option 1 – Q series dummies, existing frontal impact test F.5.4 Option 2 – plus a side impact test F.5.5 Option 3 – with a new, more representative frontal impact test F.5.6 Summary of benefits estimates F.5.7 Costs estimate F.5.8 Market size F.5.9 Marginal (per unit) costs to manufacturers F.5.10 Summary of cost estimates F.5.11 Benefit:Cost ratios Summary 175 175 176 176 176 176 177 177 178 178 179 179 180 180 181 181 181 182 183 184 184 184 184 185 185 186 Bibliography 189 References 191 Regulations and Standards 193 GRSP Working Group documents 194 TRL iv CPR821 Client Project Report TRL v CPR821 Client Project Report List of Figures Figure 1: European child fatalities 2005, Care database (n=585) .............................. 31 Figure 2: Distribution of accident type, GIDAS 1999-2009 data ................................ 32 Figure 3: Distribution of accident type, STATS19 1998-2003 data ............................. 32 Figure 4: Child casualties in cars by injury severity, STATS19 1998-2003 data ........... 33 Figure 5: Distribution of injury severity, per accident type, STATS19 1998-2003 data . 33 Figure 6: Distribution of accident type, FARS & NASS 1996-2005 data....................... 34 Figure 7: Relative risk of fatality for 0-7 year-olds (Viano, 2008) .............................. 34 Figure 8: Injury mechanism breakdown, GIDAS data 1999-2009 .............................. 36 Figure 9: Front impact change in velocity (reproduced from Cheung and Le Claire, 2006) ................................................................................................................... 37 Figure 10: All injured children on roads by posted speed limit CCIS data (reproduced from Cheung and Le Claire 2006).................................................................... 38 Figure 11: Number of KSI children by road speed limit (N = 3,399) (reproduced from Cheung and Le Claire 2006) ........................................................................... 38 Figure 12: Front impact child injuries (reproduced from Cheung and Le Claire 2006)... 39 Figure 13: Body regions to protect (reproduced from EEVC, 2008)............................ 40 Figure 14: Frequencies of injured body regions of children using CRS, Hannover data . 41 Figure 15: AIS 2+ injury distribution in front impact for children 6-12 years-old, CCIS data ............................................................................................................ 41 Figure 16: Body region injury distribution of MAIS 2+ injuries in front impacts, NASS 1993-2007 data ............................................................................................ 42 Figure 17: Rear impact change in velocity (reproduced from Cheung and Le Claire 2006) ................................................................................................................... 44 Figure 18: CSFC-96 rear impact injury distribution (reproduced from EEVC, 2006)...... 44 Figure 19: Side impact change in velocity (reproduced from Cheung and Le Claire 2006) ................................................................................................................... 45 Figure 20: Children using CRS in side collisions on struck side (n=28) (reproduced from Czernakowski, 2001) ..................................................................................... 46 Figure 21: Serious injury distribution for side impact, CIREN data............................. 47 Figure 22: CSFC-96 side impact injury distribution (reproduced from EEVC, 2006)...... 47 Figure 23: CREST accident database AIS 3+ side impact injuries (reproduced from EEVC, 2006) .......................................................................................................... 48 Figure 24: Frequencies of injured body regions of children using CRS, Hannover University data ............................................................................................. 48 Figure 25: AIS 2+ injury distribution in side impact for children 6-12 years-old, CCIS data ............................................................................................................ 49 Figure 26: Injury severity percentage for different amounts of side impact intrusion (reproduced from Lesire, 2006)....................................................................... 50 Figure 27: Test bench mounted on a sled............................................................... 53 Figure 28: NPACS test benches............................................................................. 54 TRL vi CPR821 Client Project Report Figure 29: Isometric view of the new regulation test bench cushions......................... 54 Figure 30: Dimensions of the new regulation test bench cushions ............................. 55 Figure 31: Drop test positions on the NPACS seat cushion........................................ 55 Figure 32: Bench co-ordinate system .................................................................... 57 Figure 33: 3rd ISOFix attachment point measurements ............................................ 60 Figure 34: Front impact test rig ............................................................................ 67 Figure 35: Euro-NCAP front impact test - 64 km/h, 40% offset deformable barrier test 69 Figure 36: R94 front impact test - 56 km/h, 40% offset deformable barrier test ......... 69 Figure 37: PDB front impact test - 60 km/h, 40% offset deformable barrier test ......... 69 Figure 38: Front impact average pulse comparison ................................................. 69 Figure 39: Euro-NCAP front impact test - 64 km/h, 40% offset deformable barrier test 71 Figure 40: PDB front impact test - 60 km/h, 40% offset deformable barrier test ......... 71 Figure 41: Front impact pulse comparison – R94 (56 km/h) & EEVC (60 km/h) test pulses.......................................................................................................... 71 Figure 42: Front impact pulse............................................................................... 72 Figure 43: Rear impact sled ................................................................................. 76 Figure 44: Rear impact pulse................................................................................ 77 Figure 45: Original side impact test rig (CRS-14-4) ................................................. 79 Figure 46: Side impact test rig ............................................................................. 80 Figure 47: Test cushion dimensions....................................................................... 80 Figure 48: Door specification ................................................................................ 81 Figure 49: Side impact velocity corridor................................................................. 82 Figure 50: Original intrusion specifications ............................................................. 83 Figure 51: Intrusion depth measurements R95 tests (reproduced from ISO/PDPAS 13396, 2009) ............................................................................................... 84 Figure 52: Intrusion specifications evaluated by TRL ............................................... 84 Figure 53: Q-series instrumentation ...................................................................... 87 Figure 54: Q-series dummies ............................................................................... 88 Figure 55: Forward facing child restraints – head excursion...................................... 93 Figure 56: Rearward facing child restraints – head excursion.................................... 94 Figure 57: Seat foam impact responses for two sets of uncovered foam .................... 98 Figure 58: Seat foam impact responses for two sets of covered foam ........................ 99 Figure 59: Front impact test sled .......................................................................... 99 Figure 60: Proposed Deceleration Pulse Envelope, with deceleration pulses from the experimental front impact testing...................................................................100 Figure 61: Scaling ratios used in the development of the head acceleration performance thresholds ...................................................................................................103 Figure 62: Non-integral CRSs, dummy and belt interaction .....................................109 Figure 63: NHTSA vehicle accelerations, 50km/hr, 100% overlap barrier test ............112 Figure 64: Testing conditions using the higher pulse ..............................................113 TRL vii CPR821 Client Project Report Figure 65: FMVSS 213 front impact pulse corridor, compared to new regulation pulse corridors .....................................................................................................121 Figure 66: Rear impact test.................................................................................125 Figure 67: Test bench comparison .......................................................................127 Figure 68: P1.5 test comparison ..........................................................................127 Figure 69: TRL sled velocity data (28 tests) ..........................................................134 Figure 70: Dorel sled velocity data (6 tests) ..........................................................134 Figure 71: TRL sled deceleration data (28 tests) ....................................................135 Figure 72: Dorel sled deceleration data (6 tests)....................................................136 Figure 73: TRL sled deceleration data (6 reproducibility tests only) ..........................136 Figure 74: Anchorage displacement vs. initial distance between the door and the CRS in the TRL test series........................................................................................142 Figure 75 – new Regulation implementation Phase 1 ..............................................162 Figure 76 – new Regulation implementation Phase 2 ..............................................162 Figure 77 – new Regulation implementation Phase 3 ..............................................162 Figure 78 – Three phases of the single approval option...........................................167 Figure 79 – Three phases of the dual approval option .............................................168 TRL viii CPR821 Client Project Report List of Tables Table 1. Summary of benefits and costs for each option .......................................... 16 Table 2: Injury mechanisms ................................................................................. 35 Table 3: Frequency of side impact angle ................................................................ 46 Table 4: Drop test matrix..................................................................................... 56 Table 5: Material properties of the test bench foam................................................. 57 Table 6: ISOFix anchorage locations...................................................................... 58 Table 7: Floor positioning versus H point ............................................................... 59 Table 8: X and Z coordinates of potential alternative 3rd attachment point (reproduced from VTI, CRS-10-06).................................................................................... 60 Table 9: Top tether locations................................................................................ 61 Table 10: Belt anchorage locations........................................................................ 61 Table 11: Loads measured in anchorages Reg.44 pulse ........................................... 62 Table 12: Loads measured in ISOFix anchorages Euro NCAP pulse ............................ 63 Table 13: Loads measured in anchorages Reg.44 pulse ........................................... 64 Table 14: Loads measured in anchorages Reg.44 pulse, Euro-NCAP comparison ......... 64 Table 15: Anchorage loads during dynamic test ...................................................... 65 Table 16: Anchorage locations.............................................................................. 66 Table 17: Front impact pulse coordinates............................................................... 73 Table 18: Front impact deceleration sled requirements ............................................ 73 Table 19: Rear impact pulse coordinates................................................................ 77 Table 20: Rear impact deceleration sled requirements ............................................. 78 Table 21: Side impact velocity corridor coordinates ................................................. 82 Table 22: Side impact deceleration sled requirements ............................................. 83 Table 23: Q-series instrumentation ....................................................................... 88 Table 24: Q dummy performance criteria for 20% risk of AIS3+ injury (calculated using logistic regression) ........................................................................................ 90 Table 25: Q dummy performance criteria for 50% risk of AIS3+ injury (calculated using logistic regression) ........................................................................................ 90 Table 26: Q dummy performance criteria scaled from UNECE R94 adult performance criteria......................................................................................................... 90 Table 27: AIS3+ 20% ......................................................................................... 91 Table 28: AIS3+ 50% ......................................................................................... 91 Table 29: Proposed dummy performance criteria .................................................... 92 Table 30: Rearward facing integral CRSs (Group 0+) short-list ................................. 96 Table 31: Forward facing integral CRSs (Group I) short list ...................................... 96 Table 32: Forward facing non-integral CRSs (Group II/III) short list.......................... 96 Table 33: CRSs selected to assess protocols........................................................... 97 TRL ix CPR821 Client Project Report Table 34: Front Impact assessment matrix – rearward facing integral CRSs ..............101 Table 35: Scaling ratios used in the development of the head acceleration performance thresholds ...................................................................................................102 Table 36: Front impact results table – rearward facing integral CRSs........................104 Table 37: Front impact assessment matrix - forward facing integral CRSs .................105 Table 38: Front impact results table – forward facing integral CRSs..........................106 Table 39: Front impact assessment matrix - forward facing non-integral CRSs ..........107 Table 40: Scaling factor ratio for the sternal deflection measurements .....................108 Table 41: Front impact results table – forward facing non-integral CRSs ...................110 Table 42: Front impact alternative pulse coordinates..............................................113 Table 43: Assessment Matrix to assess the effects of an alternative pulse .................114 Table 44: Stopping distance comparison ...............................................................114 Table 45: Higher pulse tests – Rearward facing integral CRSs..................................116 Table 46: Higher pulse tests – Forward facing integral CRSs....................................118 Table 47: Higher pulse tests – Forward facing non-integral CRSs .............................120 Table 48: Rear impact assessment matrix – test bench evaluation ...........................124 Table 49: Rear impact results table - test bench evaluation.....................................126 Table 50: Rear impact assessment matrix – test bench evaluation ...........................128 Table 51: Rear impact results table - criteria evaluation..........................................130 Table 52: Side impact anchorage locations............................................................133 Table 53: Summary of TRL test conditions and anchorage displacement ...................138 Table 54: Summary of TRL test conditions and anchorage displacement - rear facing integral CRSs...............................................................................................138 Table 55: Summary of TRL test conditions and anchorage displacement - forward facing integral CRSs...............................................................................................139 Table 56: Summary of TRL test conditions and anchorage displacement - forward facing non-integral CRSs ........................................................................................139 Table 57: Anchorage displacement in the Dorel – forward and rearward facing integral CRSs ..........................................................................................................140 Table 58: Test matrix for the assessment of repeatability and reproducibility ............143 Table 59: Repeatability results from the TRL sled tests ...........................................145 Table 60: Repeatability results from the Dorel sled tests.........................................146 Table 61: Reproducibility results for the sled tests with the Q1 dummy in a forward facing CRS...................................................................................................147 Table 62: Reproducibility results for the sled tests with the Q1.5 dummy in a rearward facing CRS...................................................................................................147 Table 63: Test matrix for criteria evaluation - rearward facing integral CRSs .............148 Table 64: Test results for criteria evaluation - rearward facing integral CRSs1 ............149 Table 65: Test matrix for criteria evaluation - forward facing CRSs...........................151 Table 66: Test results for criteria evaluation - forward facing CRSs1 .........................152 TRL x CPR821 Client Project Report Table 67: TRL Test matrix for investigation into the effects of increased friction on the lateral movement of ISOFix anchorages ..........................................................155 Table 68: Test results for evaluation of the effect of friction 1, 2 .................................156 Table 69: Restraint type categories ......................................................................160 Table 70: Definitions ..........................................................................................161 Table 71: Reg.16 ISOFix size category .................................................................170 Table 72: Potential benefits and disbenefits if the proposed single approval or dual approval routes are used...............................................................................173 Table 73: UK casualty valuations, 2008 (DfT, 2009)...............................................175 Table 74: Estimated EU casualty valuations...........................................................176 Table 75: GB casualty data, 2006-2008................................................................177 Table 76: Lower and upper annual GB casualty estimates, child car occupants <12 year old .............................................................................................................178 Table 77: Lower and upper annual EU casualty estimates, child car occupants <12 years old, Method 1 ..............................................................................................179 Table 78: Lower and upper annual EU casualty estimates, child car occupants <12 years old, Method 2 ..............................................................................................179 Table 79: Lower and upper annual EU casualty estimates, child car occupants <12 years old, Method 3 ..............................................................................................180 Table 80: Lower and upper annual EU casualty estimates, child car occupants <12 years old .............................................................................................................180 Table 81: Step change effects in GB of previous legislative changes .........................181 Table 82: Likely casualty and monetary benefit estimates of option 1, EU27 .............182 Table 83: Likely casualty and monetary benefit estimates of option 2, EU27 .............182 Table 84: Likely casualty and monetary benefit estimates of option 3, EU27 .............183 Table 85: Summary of benefits and costs for each option .......................................185 Table 86: Summary of benefits and costs for each option .......................................187 TRL xi CPR821 Client Project Report Executive summary A Working Party on Passive Safety (GRSP), Informal Group on Child Restraint Systems (“Informal Group”) was created by the World Forum for Harmonisation of Vehicle Regulations (Working Party 29) on 16th July 2007. This Informal Group was tasked with developing a new regulation for, ‘Restraining devices for child occupants of power-driven vehicles’, for consideration by GRSP. The aim is that this new regulation will include front, side and rear dynamic impact assessments of Child Restraint Systems (CRSs) and will utilise a new family of child anthropometric test devices (dummies) for acquiring measurements. The work of the Informal Group is to be achieved in a number of steps, with the first phase to develop performance criteria and test methods for ISOFix Integral “Universal” CRSs. The Informal Group developed a number of proposals, for test methods for the new regulation. However, the evidence base for some of these proposals was unclear and hence the consequences of their potential implementation are not well understood. The objective of this project was to assess the proposals made by the Informal Group and to make recommendations for the way forward. The approach taken in this project included a review of literature on accident studies involving children, to identify the important body regions to protect, for each type of CRS and the associated injury mechanisms. This information was used in the subsequent dynamic test programme, which was designed to assess the proposed procedures and to check that the dummies, proposed, were suitable for recording the required measurements in the dynamic assessments. The CRSs chosen for the practical assessment of the procedures were selected with consideration to three different criteria; low reported rating in dynamic performance, high reported rating in dynamic performance and high reported volume sales. In total 21 front impact tests were conducted using the proposed pulse. The measurements recorded in these tests were compared to the proposed injury criteria limits. A further 6 front impact tests were conducted using a more severe pulse. This pulse was created from an average of deceleration pulses from modern vehicles in a 50 kph 100% overlap test. The results from these tests were compared to those conducted to the proposed pulse and the specified injury criteria limits. A total of 11 rear impact tests were conducted using the proposed pulse with the Qseries dummies. In addition, tests using the P-series dummies were conducted to understand the relative effect of the geometry and cushion properties on CRSs compared to those of the test bench specified in UNECE Reg.44. The project completed 34 side impact tests. The aims of these tests were to assess the side impact procedure for repeatability and for reproducibility and to identify how it loads restraint systems and how this relates the accidents in the real world. The criteria limits set for front impact were assessed for their applicability to side impact assessment. In addition to these assessments the affect of varying the friction of the sliding ISOFix anchorages was evaluated. This limited investigation was designed to give an indication of whether the level of friction allowable in the ISOFix anchorages warranted further investigation. The project went on to evaluate the implications of the three phases proposed for implementation of the new regulation, for two scenarios; single approval and dual approval of child restraint systems. The different approval routes and the issues arising from them have implications for three key groups of stakeholders: consumers, CRS manufacturers, and car manufacturers (OEMs). A high level, indicative, cost-benefit analysis of the various regulatory proposals and options has been carried out. It assumes that all children use CRSs and that they are appropriate for the child and correctly fitted. The analysis draws together available TRL xii CPR821 Client Project Report information on European child car occupant accident statistics, along with more detailed GB casualty data, and data gained on volume sales to provide an indication of the possible likely costs and benefits of the new regulation. TRL xiii CPR821 Client Project Report TRL xiv CPR821 Client Project Report 1 Introduction Child occupant protection is currently legislated for by European Directive 2003/20/EC, which states that occupants of motor vehicles must wear seat belts and children who are under 12 years of age and below 1.5m in height must be seated in a child restraint. The Directive currently allows countries to restrain children with the minimum height of 1.35m by the adult seatbelt; however, Germany, Italy, Austria, Ireland, Luxembourg, Greece, Hungary, Poland and Portugal have enforced child restraint use under 1.50m. The performance of the child restraint is legislated for by United Nations Economic Commission for Europe (UNECE) Regulation No. 44, which specifies minimum performance requirements for Child Restraint Systems (CRSs) used in power-driven vehicles. On 16th July 2007 the World Forum for Harmonization of Vehicle Regulations (Working Party 29) agreed to the establishment of a new Working Party on Passive Safety (GRSP) Informal Group on Child Restraint Systems (“Informal Group”). The remit of this Group is to consider the development of a new regulation for, ‘Restraining devices for child occupants of power-driven vehicles’, for consideration by GRSP. The aim is that this new regulation will contain front, side and rear dynamic impact assessments and will utilise a new family of child anthropometric devices for the assessment of the performance of CRSs. The Informal Group was tasked to include, amongst others, the technical expertise from European Enhanced Vehicles Committee (EEVC) Working Group (WG) 18, EEVC WG12, ISO TC22/SC12 and NPACS as well as the results of discussions held in the Informal Group and at GRSP. The work of this Group is to be achieved in a number of steps with the first phase to develop performance criteria and test methods for ISOFIX Integral “Universal” CRSs. To date, the Group has developed a number of proposals for test methods for the new regulation. However, the evidence base for some of these proposals is not solid and hence the consequences of their potential implementation are not well understood. Therefore a review of the available scientific evidence behind the test methods proposed along with any additional supporting information is required in order to identify the strengths and weaknesses of each proposal and make recommendations for the way forward. In addition a review of the relevance of the performance criteria proposed for use in these test methods is required, with particular consideration to the work of the EEVC WGs 12 and 18 and the NPACS research for the new family of child dummies, proposed for use in these test methods is required. TRL 1 CPR821 Client Project Report TRL 2 CPR821 Client Project Report 2 Project Objectives The objective of this project was to review proposals made by the GRSP Informal Group and to make recommendations for the way forward. The remit of the Informal Group is to consider the development of a new regulation for, ‘Restraining devices for child occupants of power-driven vehicles’, for consideration by GRSP. The aim is that this new regulation will contain front, side and rear dynamic impact assessments and will utilise a new family of child anthropometric test devices (ATDs, or dummies) for the assessment of the performance of CRSs. The TRL review includes assessments of: • How well the proposals will address the needs identified in accident studies; • The new dummy performance criteria and performance limits; • How the proposal would be implemented into regulation, i.e. how it would be phased in; • Any potential unintended consequences; • Assessment of the practicality, repeatability and reproducibility of the favoured side impact procedure; • Potential costs and benefits. TRL 3 CPR821 Client Project Report 3 3.1 Summary of Results Collection of Market Research Information This task involved the collection of Child Restraint System (CRS) market research information to obtain an up to date indication of the best selling seat models sold in Europe. The main purpose for this analysis was to inform the choice of CRSs to be used in the practical assessment studies. The market research information was obtained from the NPD Group, which is a global provider of consumer and retail market research information for a wide range of industries. They used a network of retail partnerships to obtain information for the UK and France. The information obtained provided the following: UK Car Seats category: • Total Car Seats sales by month (in value and volume) • Category performance • Top 10 manufacturers groups • Top 10 brands • Top 10 products • ISOFix sales by month Time period covered: January 2009 – December 2009 France Car Seats category: • Total Car Seats sales by month (in value and volume) • Category performance • Top 10 manufacturers groups • Top 10 brands • Top 10 products Time period covered: July 2008 – June 2009 The information on market sales, market share and pricing information has been used to help with providing information for the study of the ratio of benefit to costs of the different proposals, detailed in Section Appendix F. The information on sales figures for particular CRSs has provided information to help in the selection of CRSs for the practical assessment, detailed in Section C.2. It was important to include CRSs in our assessment programme that have had a high volume of sales and hence, have a wide history of use in the European vehicle fleet. CRS models generally have at least five years in the market before they are discontinued as a product. By including these products it provides us with a certain level of confidence that if these products are likely to cause injury to children in the way they provide restraint under crash conditions, this will show up in the accident studies, in the body regions that need to be protected. In addition to the market research information, the dynamic performance of child restraint systems, taken from various consumer testing schemes, was also considered TRL 4 CPR821 Client Project Report when selecting the child restraint systems for the practical assessment programme. This information was used to identify restraints in each group that were reported to have poor or good dynamic performance (detailed in Section C.2). 3.2 Test Bench The test bench consists of a seat frame and seat cushions, representing the back and base of the vehicle seat, and the ISOFix and seat-belt anchorages The current proposal for the test bench design is that it is to be based on the NPACS frontal test bench. This was developed during the NPACS (New Programme for the Assessment of Child restraint Systems) research phase. 3.2.1 Cushion The original NPACS test bench designs used a different cushion design for ISOFix attached restraints and belted seats. The test bench proposed for the new regulation has a modified cushion to allow the attachment of non-integral ISOFix CRSs. The foam for the proposed cushion to be used for the dynamic testing will have the same properties as the foam used for the NPACS front impact test bench seat cushion (T75500 foam). It seems reasonable that the cushions should be wider than the narrow NPACS cushion and 800 mm has been agreed. The same cushion design will be used for in front and rear impact testing and a small modification to the backrest cushion is required for side impact testing. A preliminary foam specification has been proposed based on impact response corridors constructed by TRL. Further work is required to define the cushion characteristics, including: 3.2.2 o The dataset should be enlarged with tests of other exemplar foam cushions and new performance requirement should be generated from these data. o It should be decided whether angled impacts are required in order to adequately control the cushion performance. o It should be decided whether more than one impact speed is required in order to adequately control the cushion performance. o Tolerances on the dimensions of the cushions should be agreed. Anchorages ISOFix anchorage locations have been proposed, based on those defined in NPACS, which were based on the worst case geometries identified in the vehicles reviewed in that project. The comparison data that has been presented to the Informal Group is limited and there remains a compatibility issue for the use of non-integral CRSs in vehicles with ISOFix anchorages that are off-set from the belt anchorages. This needs to be addressed in Reg.14 if non-integral CRSs are to be approved as Universal. An envelope for the alternative third attachment point must also be agreed for the test bench and in Reg.14. ISOFix top tether locations and seat-belt anchorage locations have been proposed based on those defined in NPACS. Evidence has been presented to the Informal Group that the current Reg.14 anchorage strength test requirements may be inadequate for some dummy and CRS combinations allowed under the proposed i-Size categorisation scheme. This suggests that either the ISOFix anchorage strength requirement in Reg.14 may need to change, or vehicles may not be able to accommodate integral CRSs designed for older children. This is also relevant for specifying the test bench for the new regulation, because the ISOFix mounts TRL 5 CPR821 Client Project Report on the test bench must be strong enough for repeated testing and be of a size that is representative of those used in cars. It is recommended that an investigation is conducted with heavier occupants in front impact tests under Reg.44 conditions (or the conditions agreed for the new regulation) to investigate the increased anchorage loading. It is also recommended that comparative tests are carried out to assess the relative effects of static (as used in Reg.14) and dynamic loading (as applied in car crashes) to the vehicle anchorages. 3.3 3.3.1 Front Impact Pulse The pulse information presented to the Informal Group, for impacts at 50km/hr has been based on 40% overlap offset frontal impact test data. This is in contrast to the Reg.44 pulse which was developed to represent full-width crash pulses, to encourage improved occupant restraint systems. The objective of the offset frontal test was specifically to encourage improved integrity of the passenger compartment of vehicles in order to prevent serious crush injuries and to provide a survival space for the occupants. Other regulatory regimes, such as FMVSS in the USA, require full-width car crash tests and these are considered to be a more challenging test of the restraint systems in the vehicle. The TRL project developed a crash pulse based on some full scale tests at 50 km/hr with a full-width barrier and compared CRS performance in tests at this more severe pulse with tests to the current Informal Group proposal (see Section C.4.2). It is recommended that the Informal Group decides which frontal impact configuration would represent a better assessment of a restraint system, to be represented in the sled tests. If the impact configuration is full-width, additional information on full-width vehicle crash pulses will be required. A parallel investigation would be worthwhile, into a pulse representative of modern vehicles in the USA. The vehicle fleets in Europe and the USA have changed since the development of R44 and FMVSS213 and there may be scope to harmonise these requirements. 3.3.2 Installation of CRS and dummy The installation of a CRS and test dummy in the new regulation is heavily based on the procedures in the current Reg.44, with clarification in places. However some of this process is open to interpretation, which can lead to inconsistency across Technical Services. 3.3.3 Rearward facing integral restraints The review of accident studies has shown that, for children injured in front impacts, the head is the priority body region to protect. The majority of head injuries are caused by contact with parts of the vehicle interior or other external objects. The rearward facing integral CRSs passed all of the criteria proposed for the new regulation. Head excursion is an important factor and the range of horizontal head excursions were well inside the thresholds proposed for the dummies. Head excursion is an issue for child protection in the field and therefore the performance thresholds for the testing may need to be changed, to encourage less forward movement of these products. The limit currently proposed is 700mm and the maximum forward excursion across in the tests was less than 500mm. These results, however, did not include any large rear facing CRSs and one could argue that a larger CRS with a larger dummy would need more space. However, the space TRL 6 CPR821 Client Project Report allowed for excursion should be based on the space available in the vehicle, which is variable, and not based on dummy size. The value for head excursion should be reviewed and based on the excursion space available to children in modern vehicles, taking into account realistic vehicle front seat positions. The values for the linear head acceleration thresholds have been taken directly from the work of the EEVC Working Groups 12 & 18 (Wismans et al., 2008). The composition of the scaling formula and the progression of the ratios for failure stress and head length seem sensible. However, it may not be a realistic representation of injury risk for children under the age of one. Therefore it is suggested that the head acceleration threshold criterion for the different Q dummy ages needs to be reviewed. The results of the assessment with the rearward facing integral CRSs at the higher pulse showed that, with the exception of neck moments and chest compression, both of which are well below the criteria limit, the other injury criteria significantly increased in comparison to the tests using the proposed pulse. As previously mentioned the main body region to protect for rearward facing restraints is the head. This means head accelerations and excursions should be kept to a minimum. The increase in pulse severity had a significant effect on the important body regions for both of the dummies tested. The horizontal head excursions increased to exceed the forward facing limit (550mm) with the larger dummy. However the effect on the smallest occupant for this type of restraint (Q0) should also be evaluated prior to the changing of any limits if this more severe pulse was to be adopted. Head excursion is measured from the film of the test. In Reg.44 the testing laboratories must apply procedures for estimating uncertainty of measurement (U of M) of the displacement of the manikin's head. The confidence intervals should be specified and the method of applying these confidence intervals to the U of M needs to be clearly defined. It is not always possible to measure the head excursions using the side view of the test. In some cases the top camera view has to be used. There are limitations with measuring the excursions from the top view, as the dummy is constantly changing to a different measurement plane during the test. The visual measurement alone, is incorrect and a correction factor has to be applied. The correction factor is calculated by using results from the tests where the difference between the measurement views is known. This is also an issue for type approval and the assessment method should be defined more clearly. The actual measured excursions must be known in order to carry out Product Qualification testing and for Conformity of Production testing. 3.3.4 Forward facing integral restraints The review of accident studies indicated that head protection is the highest priority for children travelling in forward facing integral CRSs, followed by chest protection. The injury mechanism associated with these CRSs is head contact with parts of the vehicle interior, so head excursion is the most important criteria. However in optimising a CRS to achieve low head excursions, this can result in high head and chest accelerations, so it is important to have a balance of performance across all three criteria. All horizontal head excursions were both below the proposed limit of 550mm and below 500mm, the limit currently set for ISOFix integral restraints in Reg.44. One CRS exceeded the threshold for head acceleration (by 1%), with the Q1 dummy. The product performance ranged from 84%-101% of the limit for this criterion with the Q1 dummy. The product performance ranged from 97%-101% of the limit for vertical head excursion with the Q3 dummy. This shows that the 800mm head vertical excursion limit is about right for this type of restraint. TRL 7 CPR821 Client Project Report From their use in the field, the CRSs tested in this programme are considered as relatively safe with respect to the likelihood of neck injuries occurring in real world accidents. However, in all the tests with the Q1 or Q3 in integral CRSs, the dummy produced upper neck tensile forces which exceed the proposed threshold (they were on average 149% of the threshold). This limit relates to an expected 50 % risk of AIS • 3 neck injury (as scaled for the child size; EEVC, 2008). Therefore it seems to be the case that the proposed equipment, measurement tools or procedures do not lead to an accurate assessment of injury risk for this body region. The results of the assessment with the forward facing integral CRSs at the higher pulse showed that the Q1 exceeds the HIC limit (150% of the limit), although there was no head contact. The chest resultant criteria limit was exceeded (104%), as well as the upper neck force (by 66%), which was also exceeded during the test with the proposed pulse. In addition the head resultant acceleration reached 99%. The Q3 exceeds the head vertical excursion limit as well as exceeding the limit of the upper neck force, which was also exceeded during the test with the proposed pulse. In addition, the chest resultant acceleration increased by 43% (to 91% of the limit) and the head resultant acceleration increased by 19% (to 99% of the limit). These results show that in addition to exceeding the neck force criteria limit, the criteria limits of the important body regions, the head and chest were also exceeded. Although the head horizontal excursions increased they are well below the limit. However the larger dummy does exceed the vertical excursion limit. 3.3.5 Non-integral restraints Head excursion is an important criteria for children restrained in non-integral CRSs. The limit proposed for horizontal head excursion is 550mm. The head excursion results were well below 500mm, so there is scope for reducing the threshold for horizontal head excursion, in line with the space available in the vehicle. The limits for chest compression were exceeded in the tests with the Q6 dummy. The smaller dummies have greater thresholds than the larger dummies and it is unclear why. The limits for chest compression were taken from the work of EEVC WGs 12 & 18 (Wismans et al., 2008), modified for the position of deflection measurement sensors. In the threshold scaling, each of the material property parameters varies with age in a sensible manner. However, the output of the scaling formula produces an unexpected progression, where the sternal deflection for a one-year-old is greater than for an adult. It seems unlikely that a one-year-old can sustain more sternal deflection than an adult without injury. The scaling factor used related to the risk of rib fracture and did not account for visceral injuries. Smaller children may sustain large thoracic deformations before rib fracture occurs, however they may also sustain visceral injuries without rib fracture. Therefore these scaling ratios are unsuitable for use in relation to all AIS 3+ thorax injuries to children, caused by restraint system loading to the chest. Chest injuries are an issue for children in non-integral CRSs and the mechanism is associated with the adult belt loading the chest. More research is needed in this area to set appropriate thresholds for the criterion. In addition to the head and chest region, the abdomen is also a high priority area to protect for children using non-integral CRSs, however there is nothing on the Q dummy that measures this. The injury mechanism associated with abdominal loading is “submarining” and loading from the adult belt. The kinematics of ISOFix attached non-integral CRSs can be different to the equivalent belt attached systems and there is more potential for poor belt interaction and the possibility of an increase in abdominal injuries. When the proposed procedures are extended to include non-integral systems this will be a key area to monitor. TRL 8 CPR821 Client Project Report The proposed procedures specify that a measure of abdominal penetration should be a calculation of the forces measured in the lumbar spine and the lap belt. The suggestion is that during the frontal impact the lumbar spine resultant of Fx and Fz shall not exceed [undetermined] per cent of the lap belt force. From the results of the testing, it is unclear what this measurement represents. In all the tests with non-integral CRSs, the lap portion of the adult belt became wedged into the gap at the top of the dummy legs. There are serious limitations with the ability of the Q-series dummies to assess non-integral CRSs. It is essential that the lap portion of the adult belt is able to take the path of travel over the dummy in the same way that it would with a child. In addition to this the submarining motion should at least be detectable and ideally should be measurable. For non-integral CRSs, where abdominal injuries are a priority, the P series dummies, even with their limitations may be a better option. The CRSs tested in this programme are considered as relatively safe with respect to the likelihood of neck injuries occurring in real world accidents. However, in all the tests with the Q3 in the non-integral CRSs, the dummy produced upper neck tensile forces which were on average 179% of the threshold. This limit relates to an expected 50 % risk of AIS • 3 neck injury. Therefore it seems to be the case that the proposed equipment, measurement tools or procedures do not lead to an accurate real world injury risk for this body region. The peak tensile forces measured at the lower neck are lower than those measured at the upper neck. Therefore, if one was to assume a consistent injury threshold for tensile force at the upper and lower neck, then the lower neck measurements would not provide any additional information, when considering peak values. However research has shown that for the older (> five months post-natal) cohort, the upper cervical spine is significantly stronger then the lower cervical spine, which may support the implementation of a lower neck tensile force threshold which is lower than the threshold at the upper neck. In adults, the neck musculature adds greater force tolerance to the lower neck than the upper neck and consideration of the cervical musculature would shift the predicted site of injury (under tensile loading) from the lower to the upper cervical spine. However, the effect of musculature on neck strength may be much less in the necks of children. This research should be taken into account when proposing a tolerance criterion for the lower neck. No limit has been set for the upper neck extension moments. The work of Mertz et al. suggested that the tolerance to extension moments was just over half of the flexion values. Adopting an upper neck extension moment limit that was half of the flexion limit would result in failures for some of the current CRSs tested with a Q1 dummy. Therefore, the flexion to extension relationship for use with dummies representing small children requires further investigation before it could be adopted. Currently the lower neck does not have bending moment criterion in the new regulation. The measured lower neck bending moment peak values are significantly higher than the upper neck. This difference means if the criteria limits for the upper neck were applied, these limits would be exceeded. Research has suggested that it may be appropriate to multiply the upper neck threshold by a factor of two to generate bending moment IARVs for the lower neck. If this approach was applied all of the CRS would pass the criterion. However, the biomechanical basis for adopting such an approach is limited. Some non-integral CRSs were assessed the higher pulse. The data show that as with the test with the proposed pulse, the Q3 test exceeds the limit of the upper neck force with the higher pulse. The Q3 dummy head and chest resultant acceleration remained the same under both sets of conditions, close to the criteria limit (95% and 88%). However, the head excursions of the Q3 increased by around 15%. The Q6 exceeded the upper neck force criteria (115%) and continued to exceed the limit of the chest compression (121%), as in the test with the proposed pulse. However, the TRL 9 CPR821 Client Project Report Q6 results show a 15-25% increase in injury criteria results and a 5% increase in head excursions. The results show that the Q3 was not significantly affected by the increase in pulse severity, with the same criteria exceeding the limits as the proposed pulse. The results from the Q6 show a greater effect on the important body regions. The horizontal head excursion limit could be revised as all dummies were well below the 550mm limit. However it should be remembered that the largest dummy (Q10.5) was not tested, as it is not currently available, and it is likely to have greater excursions. Though a different head excursion limit could be set for this dummy, as in the current Reg.44. 3.4 Rear Impact There is very little change in test conditions for rear impact between Reg.44 and the proposed new regulation, other than the geometry and properties of the test bench. The effects of these are reported in Section C.5.2. The rear impact test programme was designed to assess the rear impact procedure proposed by the GRSP Informal Group. The test conditions proposed remain the same as for Reg.44. The main differences between UNECE Reg.44 and the proposal for the new regulation are the test bench and the dummies. This rear impact test programme was designed to gain an understanding of the relative effect of the geometry and cushion properties of the new proposed test bench on the performance of CRSs and to assess the implications of using the Q-series ATD criteria and limits, proposed by the Informal Group. The review of rear impact accidents showed that a 30 km/h impact represents a large proportion of rear impact accidents involving children, which supports the proposed test conditions. The head was shown to be the priority body region for protection of children in rear impacts. The injury mechanisms that cause these head injuries are not well defined. Injuries to the neck and abdomen were also shown to be present, though these only represented a small number of accident cases in the data analysis. An assessment using the P series dummies was carried out to gain an understanding of the relative effect of the geometry and cushion properties of the proposed test bench on the performance of CRSs. The P-series dummy criteria were compared using the two test environments and the limits specified in Regulation 44. The P0 represents a new born child. It has no instrumentation and therefore the comparison is limited to the horizontal and vertical head excursions. The P1.5 was instrumented to the requirements of Regulation 44. Chest resultant and chest vertical acceleration were compared using the instrumentation and potential injuries to the head were compared by looking at the dummy head excursions. The vertical excursion was seen to be less in the tests on the newly proposed test bench. However, the proposed test bench allowed more rotation of the CRSs, towards the seatback, allowing more movement of the dummy. The results showed increased resultant and vertical chest accelerations. This may be due to the greater stiffness of the proposed cushion and the increased angle of the backrest. The new test bench cushion has been proposed as more representative of current vehicle seats and with this being the case, it seems that the stiffness and the angles of the test bench cushions have an effect on CRS performance. CRSs assessed on this new test bench may, as a result, perform better over a wider range of vehicles. The stiffer foam of the proposed test bench made it impossible to connect the ISOFix attachments to the test bench anchorages, with one of the CRSs. The anchorages on the test bench were moved forward to complete the test programme. If a CRS design is incompatible with the new test bench, then it may have compatibility issues in the field. The proposed test bench is more representative of modern vehicles and may therefore provide a better assessment of the compatibility of CRSs in the field than the Reg.44 test bench. TRL 10 CPR821 Client Project Report An evaluation was carried out to assess the implications of using the Q-series ATD criteria and limits, proposed by the Informal Group. As stated previously, the accident review showed that the head is the priority body region to protect in rear impact. The injury mechanisms that cause these head injuries in rear impact were not well defined. The P0 dummy does not have the capability of measuring head acceleration and this is not assessed in current type approval of CRSs. However, during this evaluation, two of the CRSs tested with the Q0 dummy failed the limits proposed for the 3ms head resultant acceleration requirement. If the Q series dummies were used as a measurement device in type approval testing of CRSs, the head accelerations could be assessed and this may lead to safer CRSs for young babies. The P0 has no capability to measure chest acceleration and this is not assessed, with the smallest dummy, in current type approval testing of CRSs. The resultant chest acceleration was on the limit of the proposed criteria with the Q0 in the high rated CRS. Again, if the Q series dummies were used in type approval testing and chest acceleration could be assessed, this may lead to safer seats for new born children. The tests where all three dummy sizes were assessed in the same CRS show that the smallest dummy recorded the highest accelerations in the head, chest and pelvis, which agrees with the philosophy that testing with the smallest dummy will be the worst case test in terms of dummy loading. This suggests that type approving with the smallest dummy instrumented could lead to safer CRSs. Injuries to the neck were also found to occur in the rear impact review. The largest dummy had the highest neck forces and moments, which is probably due to its larger head mass. All the neck force and moment recorded values were well below the proposed limits. The accident review showed a very small number of abdominal injuries. It is not possible to ascertain whether the CRSs protect the dummy from abdomen injuries in rear impact using the current measurements available on the Q-series dummies. 3.5 Side Impact The side impact procedure has been presented to the informal group on the basis that, although the procedure is not representative of the real world accident, it is simple to apply and it will improve the safety of CRSs. The practical assessment programme was designed to assess the proposed procedure for repeatability and reproducibility. The test procedure was assessed for repeatability based on three repeat tests of some of the CRSs evaluated. Reproducibility of the test procedure was also evaluated by comparison with the results of six side impact tests (three with a rear facing integral CRS (Group 0+) and three with a forward facing integral CRS (Group I) at the Dorel test facility in Cholet, France. Furthermore, the procedure was assessed to evaluate the effect of applying the front impact injury criteria to side impact and to evaluate, where possible, how the dummy loading in the procedure relates to loading in the vehicle. Finally, the effect of varying friction in the ISOFix anchorage, on dummy loading, was evaluated. 3.5.1 Test conditions The change of velocity was close to the middle of the target corridor for the TRL and the Dorel tests, and the repeatability was very good. The reproducibility of the pulses between the two laboratories was good. The range of TRL sled velocity was wider as it contained tests carried out across a much wider range of CRSs. TRL 11 CPR821 Client Project Report The TRL pulse is flatter and more consistent in the first 150 ms. The last part of the pulse however, is slightly less consistent, about the time that the sled changes direction to rebound. This part of the pulse partially overlaps the time frame during which the resultant head accelerations reached their maximum value. However, the variation in sled acceleration did not influence the repeatability of this measure. The phasing of the loading to the CRS has an effect on the loading to the child. The side of the struck vehicle is loaded by the striking vehicle and within 20ms the velocity of the intrusion into the vehicle is in excess of 30km/hr. At this point the chassis velocity of the struck vehicle is about 5km/hr. The chassis velocity of the struck vehicle builds relatively slowly and the velocity of the intrusion slows down and meets the rising chassis velocity at about 60ms. The proposed test procedure provides a good representation of the speed of the struck vehicle chassis, however it does not reproduce the speed of the intrusion into the struck vehicle. Once loaded by the intruding structure, at no point does the vehicle seat lose contact with the intruding structure. During the proposed test procedure the ISOFix anchorages are allowed to move away from the intrusion panel. The phasing of the CRS-to-door contact is different in the tests performed at TRL and Dorel and hence the maximum resultant head and chest accelerations occur at different times. 3.5.2 Reproducibility The impact velocity and stopping distance were very repeatable throughout the TRL testing. A specification of 295 to 300 mm was used for calibration runs. Despite this, the stopping distance in testing ranged from 293-305 mm, including five tests that exceeded 300 mm stopping distance and which would therefore have experience slightly greater intrusion than was intended. The stopping distances in the TRL side impact tests would easily have met a requirement of 300±10 mm. Nevertheless, the stopping distance may be more critical for the side impact test procedure because it directly influences the intrusion of the door. It is recommended that the tolerance on the stopping distance is considered further, particularly with respect to the level of intrusion applied to the CRS. The anchorage displacement in the side impact procedure was very variable. In the Dorel tests the rear facing integral CRSs remained in contact with the intrusion panel, although the anchorage displacement was considerably greater than in the TRL tests. The three forward facing integral CRSs in the Dorel tests had very different anchorage displacements and all three seats lost contact with the intrusion panel. There was a considerable difference in the effective door intrusion between the Dorel and TRL tests on the same CRS, due to differences in the lower anchorage performance. The neck and pelvis measurements were generally much greater in the TRL tests than in the Dorel tests. The anchorage displacement should be controlled to ensure consistent loading of the CRS and good reproducibility of the test conditions. In a vehicle it is possible that the out-board anchorage (nearest the door) could displace as the vehicle seat is crushed, however it is unlikely that the inboard anchorage is likely to displace substantially, thus limiting the displacement of the lower outer anchorage by the amount that the CRS is crushed in the impact. Many of the anchorage displacements observed in the tests were excessive, it is recommended that consideration be given to limiting, and possibly eliminating, anchorage displacement in the tests. Whether ISOFix anchorages move to the extent that an ISOFix CRS will translate to the degree observed in these tests is questionable and needs to be verified. The real-world accident analysis showed that injury increased with increasing intrusion and that this was the most important factor affecting injury outcome. However, the reproducibility results show either no influence of intrusion, or a reduction of injury measures with increasing intrusion, which is opposite to the real-world observation. TRL 12 CPR821 Client Project Report The position of the CRS on the test bench was defined by measuring the distance from the inner door trim to the centre of a CRS in a number of vehicles. Defining the initial door position relative to the bench may encourage narrower CRSs that may perform well in a test procedure and not so well in a small vehicle, which could then perform much worse in a narrower car. The effect of CRS positioning with fixed anchorages should be investigated, so that the test set-up represents the worst case scenario and CRSs cannot perform artificially well. 3.5.3 Repeatability ISO define good repeatability as a CV lower than 7%, and acceptable repeatability as a CV lower than 10%, for all dummy performance criteria in certification and other test procedures. The CV’s from the TRL and from the Dorel tests were generally well within the acceptable range. The peak values for the neck forces and moments in the forward facing seat, and the pelvis acceleration in the rearward facing seat, were generally much higher in the TRL tests. It was observed that the CRS typically moved away from the intrusion panel relatively easily in the Dorel tests, but was driven sideways in the TRL tests. 3.5.4 Criteria For children injured in side impact protecting the head is the main priority. Injuries to the head are caused by contact with the vehicle interior or the intruding object. The head was contained in all cases, however the resultant head acceleration limit was exceeded in all tests. The injury criteria need to be set at a level that will improve CRS design. If the proposed head criteria for front impact are applied to the side impact test procedure it is likely to lead to CRSs that absorb the loading more effectively in lateral impacts. Chest and abdomen account for a significant proportion of AIS 3+ injuries to children in side impact. These injuries have been found to be caused by compression of the child by the door panel of the vehicle. The chest compressions all passed the limits but the resultant chest accelerations all failed. If the chest criteria proposed for front impact are applied to the side impact test procedure it is likely to lead to CRSs that absorb the loading more effectively in the chest area. 3.5.5 Friction of Anchorages The amount of friction allowed in the ISOFix anchorages has an effect on the test procedure. It is recommended that further investigation is carried out to allow the set-up procedure to be more representative of the CRS when attached to anchorages in the vehicle. 3.6 3.6.1 Dummies and Criteria Biofidelity For the dummy measurements to be valid, the dummy must interact with a restraint system in a realistic way in order to display humanlike motion. This can only be achieved if all parts of the dummy are biofidelic, because the behaviour of one body part can influence another. For example, the motion of the head is influenced by the stiffness of the neck and the torso. TRL compared the Q3 dummy measurements in quasi-static tests with targets proposed in the literature (Visvikis et al., 2007). This revealed that the Q3 did not meet all of its performance targets. The greatest deviations were found in the chest and the shoulder. The chest was too stiff in both the front and side impact directions, while the shoulder was too stiff to meet the side impact target. This needs to be taken into consideration when using criteria limits that have been set by using scaled TRL 13 CPR821 Client Project Report adult injury information. If these dummies prove to be the best current ATDs available, a more pragmatic approach to assessment criteria and the associated limits may need to be taken, based on the performance of CRSs with a known history in the field. 3.6.2 Criteria The criteria that have been set have been assessed and discussed in the front, rear and side impact sections of this report. The Informal Group has proposed that lower-neck forces and moments, pelvis acceleration, lower-lumbar forces and moments, lap belt forces (front impact), and head containment (side impact) should be assessed, but no performance requirements have been either proposed or agreed for these measurements. Furthermore, no procedure for assessing head containment in side impact has been agreed for the draft new regulation. 3.7 Implementation The project evaluated the implications of the three phases proposed for implementation of the proposed new regulation, for two scenarios; single approval and dual approval of child restraint systems. The different approval routes and the issues arising from them have different implications for three key groups of stakeholders: consumers, CRS manufacturers, and car manufacturers (OEMs). 3.7.1 Issues for consumers It may be complex to understand the labelling and instructions, and how they apply to particular vehicles. This is likely to be considerably more of a problem with dual approval, which could require up to three sets of labels, multiple instructions and multiple mass limits for a single CRS. Car manufacturers will have to label which size of CRS and which CRS Regulation each seating position is compatible with. This is likely to be very difficult for consumers to understand and would apply for both single and dual approval routes. Both routes lead to different types of restraint being approved to different Regulations at different times, and therefore offering different levels of safety. The potential combination of different vehicle seat labelling on each seat in multiple vehicles; different CRS mass limits, CRS labels and instructions; and different approvals for a single CRS is unlikely to reduce the already high incidence of misuse of CRSs. 3.7.2 Issues for CRS manufacturers For belt-attached integral or non-integral CRSs there is no difference between the single and dual approval routes. It is not known how the belt-attached option would be approved under the new Regulation once this becomes mandatory in Phase 3. ISOFix integral CRSs - There is no obvious benefit to dual approval that would be sufficient to justify the cost of meeting two sets of approval requirements and of demonstrating conformity of production for both. ISOFix-or-belt-attached integral CRSs - The most straightforward route is for manufacturer’s to choose to continue to approve to Reg.44, because the alternative requires multiple approvals and multiple CoP, as well as multiple labelling and instructions which could be confusing to consumers and may therefore lead to an increase in complaints and enquiries. The only obvious benefit to dual approval for this CRS category would be if approval to the new Regulation was considered to be prestigious. Overall, if Reg.44 is considered to be the more straightforward, lower-cost option, CRSs may not be improved until Phase 3 is implemented, which will not encourage design improvements in the short to medium term. TRL 14 CPR821 Client Project Report ISOFix non-integral CRSs - It is not known how the belt-attached option would be approved under the new Regulation. 3.7.3 Issues for OEMs ISOFix or belt-attached integral CRSs - Car manufacturers will have to label the size of CRS and the CRS Regulations that each vehicle seating position is compatible with (Reg.14 and Reg.16 will need amending). 3.8 Indication of costs and benefits An indicative cost-benefit been carried out. It draws accident statistics, along volume sales to provide regulation. analysis of the various regulatory proposals and options has together available information on European child car occupant with more detailed GB casualty data, and data gained on an indication of the likely costs and benefits of the new Three regulatory options have been assessed: Option 1 – Q series dummies, existing frontal impact test This option involves keeping the existing (UNECE Regulation 44) frontal impact test, but replaces the P-series dummies with the more bio-fidelic Q-series devices, and makes use of this enhanced bio-fidelity by setting performance criteria for the neck loadings and chest compression. In terms of injury prevention, this option would thus help to reduce neck and chest injuries in frontal impacts only. This option would also, it is assumed, implement changes to the head excursion limits currently permitted, thus also helping to prevent some head and face injuries in frontal impacts. Option 2 – plus a side impact test This option is the same as option 1 except for the addition of a side impact test procedure (the existing regulation 44 has a frontal and rear impact impact test only). This would thus have additional benefit (over and above Option 1) for casualties involved in side impacts only. Option 3 – with a new, more representative frontal impact test The impact absorbing structures and occupant protection systems of cars have changed radically over the last three or four decades. It is, therefore, unlikely that the crash pulse (50 km/h frontal impact) used in the existing Regulation 44 (based on data from crash tests carried out in the 1970s) is representative of crash pulses typically experienced by occupants of modern vehicles. This option corrects this anomaly, and can thus be expected to offer some additional casualty reduction benefit (over and above Option 1) in frontal impacts only. Three different methods of estimating the numbers of child (aged under 12) car occupant casualties each year in the EU27 have been used, all based on applying weighting factors to GB data. Applying casualty valuations to the overall range estimated, also derived from GB data, indicates a societal cost of somewhere between €2.5billion and €3.9billion per year. Data from child restraint usage surveys and accident analyses are used to estimate that 50% of child car occupant casualties are from frontal impacts, 20% are from side impacts, and to speculate that an overall future usage rate of 60% is a reasonable assumption for the EU27. These data are combined with the measured casualty reduction effects of previous legislative changes to produce EU27 estimates of the benefits of the various options. TRL 15 CPR821 Client Project Report Demographic data and information provided by the CRS industry are combined to produce estimates of the likely costs (to consumers) of implementing the various options, based on costs incurred by manufacturers for new product development and testing. Combining the benefit and cost estimates gives the overall ranges of estimated benefitcost ratios shown in Table 1. Table 1. Summary of benefits and costs for each option Option Option 1 Option 2 Option 3 Benefits (€m) Lower Upper 48.7 69.7 66.3 97.2 96.0 140.1 Costs (€m) Lower Upper 4.7 16.8 14.2 28.0 18.9 55.9 Benefit:Cost ratios Lower Upper 2.9 :1 14.8 :1 2.4 :1 6.8 :1 1.7 :1 7.4 :1 These figures and ratios are necessarily based on various assumptions (described in Appendix F) and are subject to considerable uncertainty. It is apparent, however, that the broad indications from this study are that the benefit to cost ratios of all the options being considered are likely to be positive, i.e. the benefits derived from reduced casualties are likely to exceed the extra costs incurred by EU27 consumers, by a factor of somewhere between 2 and 15 to one, depending on which option is chosen. TRL 16 CPR821 Client Project Report 4 Conclusions 4.1 Test Bench The current proposal for the test bench design is that it is to be based on the NPACS frontal test bench, developed during the NPACS (New Programme for the Assessment of Child restraint Systems) research phase, with the following modifications: • The cushions should be wider than the narrow NPACS cushion and 800 mm has been agreed. • The cushion should be the modified version that allows the attachment of nonintegral ISOFix CRSs. • The same cushion design will be used for in front and rear impact testing and a small modification to the backrest cushion is required for side impact testing. The foam for the proposed cushion will be the FTSS T75500 foam. Further work is required to define the cushion characteristics, including: • The dataset should be enlarged with tests of other exemplar foam cushions and new performance requirement should be generated from these data. • It should be decided whether angled impacts are required in order to adequately control the cushion performance. • It should be decided whether more than one impact speed is required in order to adequately control the cushion performance. • Tolerances on the dimensions of the cushions should be agreed. ISOFix anchorage locations have been proposed based on those defined in NPACS. The data that have been presented to the Informal Group are limited and there remains a compatibility issue for the use of non-integral CRSs in vehicles with ISOFix anchorages that are off-set from the belt anchorages. This needs to be addressed in Reg.14 if nonintegral CRSs are to be approved as Universal. An alternative third attachment point or volume must be defined for the test bench and in Reg.14. ISOFix top tether locations and seat-belt anchorage locations have been proposed based on those defined in NPACS. The current Reg.14 anchorage strength test requirements may be inadequate for some dummy and CRS combinations allowed under the proposed i-Size categorisation scheme. The ISOFix anchorage strength requirement in Reg.14 needs to change, or vehicles may not be able to accommodate integral CRSs designed for older children. The ISOFix mounts on the test bench must be strong enough for repeated testing and be of a size that is representative of those used in cars. 4.2 Front Impact Test Conditions The relevant pulse information presented to the Informal Group, for impacts at 50km/hr, has been based on 40% overlap offset frontal impact test data, appropriate for encouraging improved integrity of the passenger compartment of vehicles. The Reg.44 pulse was based on full-width crash test pulses, appropriate for encouraging improved occupant restraint systems within the vehicle. TRL 17 CPR821 Client Project Report The pulse for the new regulation should be based on 50km/hr full-width crash test pulses representing modern vehicles. TRL carried out a limited study to develop a crash pulse based on some full-width crash tests at 50 km/hr for comparison with the current Informal Group proposal. Parts of the specification for installing the CRS and dummy on the test bench are open to interpretation, which can lead to inconsistency across Technical Services. Rearward facing integral CRSs For children injured in front impacts, the head is the priority body region to protect. The majority of head injuries are caused by contact with parts of the vehicle interior or other external objects. Head excursion is an issue for child protection in the field. The rearward facing integral CRSs passed all of the criteria proposed for the new regulation, including the current head excursion limit of 700mm. The maximum forward excursion in the tests with the rear facing integral CRSs was less than 500mm. The tests did not include any large rear facing CRSs, which may need more space. The space allowed for excursion should be based on the space available in the vehicle, which is variable, and not based on dummy size. The values for the linear head acceleration thresholds may not be a realistic representation of injury risk for children under the age of one. The results with the rearward facing integral CRSs, at the higher pulse, with the exception of neck moments and chest compression, significantly increased in comparison to the tests using the proposed pulse. The horizontal head excursions increased to exceed the forward facing limit (550mm) with the larger dummy. The increase in pulse severity had a significant effect on the important body regions for both of the dummies tested. Head excursion is measured from the film of the test. In Reg.44 the testing laboratories must apply procedures for estimating uncertainty of measurement (U of M) of the displacement of the manikin's head. The confidence intervals are not specified and the method of applying these confidence intervals to the U of M is not clearly defined. In some cases the top camera view has to be used to measure the head excursions. The visual measurement alone, is incorrect. This is a an issue for type approval as the measured excursions must be known in order to carry out Product Qualification testing and for Conformity of Production testing. Forward facing integral restraints Head protection is the highest priority for children travelling in forward facing integral CRSs, followed by chest protection. The injury mechanism associated with these CRSs is head contact with parts of the vehicle interior, so head excursion is the most important criteria. Optimising a CRS to achieve low head excursions can result in high head and chest accelerations, so it is important to have a balance of performance across all three criteria. All horizontal head excursions were below the proposed limit of 550mm and below 500mm, the limit currently set for ISOFix restraints in Reg.44. TRL 18 CPR821 Client Project Report The product performance ranged from 84%-101% of the limit for head acceleration with the Q1 dummy. The product performance ranged from 97%-101% of the limit for vertical head excursion with the Q3 dummy. This shows that the 800mm head vertical excursion limit is about right for this type of restraint. From their use in the field, the CRSs tested in this programme are considered as relatively safe with respect to the likelihood of neck injuries occurring in real world accidents. In all the tests with the Q1 or Q3 in integral CRSs, the dummy produced upper neck tensile forces which exceed the proposed threshold. Therefore it seems to be the case that the proposed equipment, measurement tools or procedures do not lead to an accurate assessment of injury risk for the upper neck force. The forward facing integral CRSs were reaching or exceeding their limit for protection when tested at the higher pulse. The results with the Q1 in the forward facing integral CRSs, at the higher pulse, exceeded the HIC limit, although there was no head contact. The chest resultant acceleration limit was exceeded and the head resultant acceleration reached 99% of the limit. The Q3 exceeded the head vertical excursion limit, the chest resultant acceleration increased by 43% (to 91% of the limit) and the head resultant acceleration increased by 19% (to 99% of the limit). Forward facing non-integral restraints Head excursion is an important criteria for children restrained in non-integral CRSs. The limit proposed for horizontal head excursion is 550mm. The head excursion results were well below 500mm, so there is scope for reducing the threshold for horizontal head excursion, in line with the space available in the vehicle. The limits for chest compression were exceeded in the tests with the Q6 dummy. The smaller dummies have greater thresholds than the larger dummies. The limits for chest compression were taken from the work of EEVC WGs 12 & 18 (Wismans et al., 2008). The output of the scaling formula produces a sternal deflection for a one-year-old greater than for an adult. It is unlikely that a one-year-old can sustain more sternal deflection than an adult without injury. The scaling factor used related to the risk of rib fracture and did not account for visceral injuries. Smaller children can sustain large thoracic deformations before rib fracture occurs and they can sustain visceral injuries without rib fracture. The scaling ratios are unsuitable for use in relation to all AIS 3+ thorax injuries to children, caused by restraint system loading to the chest. Chest injuries are an issue for children in non-integral CRSs and the mechanism is associated with the adult belt loading the chest. More research is needed in this area to set appropriate thresholds for the criterion. The abdomen is also a high priority area to protect for children using non-integral CRSs and the injury mechanism associated with abdominal loading is “submarining” and loading from the adult belt. There is nothing on the Q dummy that measures “submarining”. TRL 19 CPR821 Client Project Report There is more potential for poor belt interaction in an ISOFix attached non-integral CRS. When the proposed procedures are extended to include non-integral systems this will be a key area to monitor. The proposed procedures specify that a measure of abdominal penetration should be a calculation of the forces measured in the lumbar spine and the lap belt. From the results of the testing, it is unclear what this measurement represents. There are serious limitations with the ability of the Q-series dummies to assess nonintegral CRSs. The lap portion of the adult belt must be able to take the path of travel over the dummy in the same way that it would with a child. Submarining motion should be detectable and ideally should be measurable. For nonintegral CRSs, where abdominal injuries are a priority, the P series dummies may be a better option. The CRSs tested in this programme are considered as relatively safe with respect to the likelihood of neck injuries occurring in real world accidents. The proposed equipment, measurement tools or procedures do not lead to an accurate real world injury risk for upper neck loading. The peak tensile forces measured at the lower neck are lower than those measured at the upper neck. Applying the same limits to the lower neck measurements would not provide any additional information, when considering peak values. For necks greater than five months post-natal, the upper cervical spine is significantly stronger then the lower cervical spine. In adults, the neck musculature adds greater force tolerance to the lower neck than the upper neck. Consideration of the cervical musculature shifts the predicted site of injury (under tensile loading) from the lower to the upper cervical spine. The effect of musculature on neck strength will be much less in the necks of children. No limit has been set for the upper neck extension moments. The flexion to extension relationship for use with dummies representing small children requires further investigation before it could be adopted. Some non-integral CRSs were assessed at the higher pulse. The Q3 dummy head and chest resultant acceleration remained the same under both sets of conditions, however the head excursions increased by around 15%. The Q6 results show a 15-25% increase in injury criteria results and a 5% increase in head excursions. The horizontal head excursion limit could be revised as all dummies were well below the 550mm limit. The largest dummy (Q10.5) is not currently available, and it is likely to have greater excursions. A different head excursion limit could be set for this dummy, as in the current Reg.44. 4.3 Rear Impact There is very little change in test conditions for rear impact between Reg.44 and the proposed new regulation, other than the geometry and properties of the test bench. The main differences between Reg.44 and the proposal for the new regulation are the test bench and the dummies. The review of rear impact accidents showed that a 30 km/h impact represents a large proportion of rear impact accidents involving children, which supports the proposed test conditions. TRL 20 CPR821 Client Project Report The new test bench cushion has been proposed as more representative of current vehicle seats and with this being the case, it seems that the stiffness and the angles of the test bench cushions have an effect on CRS performance. CRSs assessed on this new test bench may, as a result, perform better over a wider range of vehicles. The proposed test bench is more representative of modern vehicles and may therefore provide a better assessment of the compatibility of CRSs in the field than the Reg.44 test bench. The head was shown to be the priority body region for protection of children in rear impacts. If the Q series dummies were used as a measurement device in type approval testing of CRSs, the head accelerations could be assessed and this may lead to safer CRSs for young babies. Again, if the Q series dummies were used in type approval testing and chest acceleration could be assessed, this may lead to safer seats for new born children. The tests where all three dummy sizes were assessed in the same CRS show that the smallest dummy recorded the highest accelerations in the head, chest and pelvis, which agrees with the philosophy that testing with the smallest dummy will be the worst case test in terms of dummy loading. Type approving with the smallest dummy instrumented could lead to safer CRSs. 4.4 Side Impact The side impact procedure has been presented to the informal group on the basis that, although the procedure is not representative of the real world accident, it is simple to apply and it will improve the safety of CRSs. The practical assessment programme was designed to assess the proposed procedure: • For repeatability and reproducibility. • To evaluate the effect of applying the front impact injury criteria to side impact • To evaluate, where possible, how the dummy loading in the procedure relates to loading in the vehicle. • To assess the effect of varying friction in the ISOFix anchorage, on dummy loading. Test conditions The change of velocity was close to the middle of the target corridor for the TRL and the Dorel tests, and the repeatability was very good. The reproducibility of the sled velocity across the two laboratories was good. The TRL pulse is flatter and more consistent in the first 150 ms. The last part of the pulse however, is slightly less consistent, about the time that the sled changes direction to rebound. The variation in sled acceleration did not influence the repeatability of the head accelerations. The proposed test procedure provides a good representation of the speed of the struck vehicle chassis, however it does not reproduce the speed of the intrusion into the struck vehicle. Once loaded by the intruding structure the vehicle seat remains in contact with the intruding structure. This is not reproduced by the proposed procedure, which allows the ISOFix anchorages to move away from the intrusion panel. TRL 21 CPR821 Client Project Report The phasing of the CRS-to-door contact was different in the tests performed at TRL and Dorel and hence the maximum resultant head and chest accelerations occured at different times. Reproducibility The impact velocity and stopping distance were very repeatable throughout the TRL testing. The stopping distances in the TRL side impact tests would easily have met a requirement of 300±10 mm. The stopping distance may be more critical for the side impact test procedure because it directly influences the intrusion of the door. The anchorage displacement in the side impact procedure was very variable and not reproducible across the two labs. The CRS contact with the intrusion panel was variable not reproducible across the two labs. There was a considerable difference in the effective door intrusion between the Dorel and TRL tests on the same CRS, due to differences in the lower anchorage performance. The neck and pelvis measurements were not reproducible across the labs. In a vehicle it is possible that the out-board anchorage (nearest the door) could displace as the vehicle seat is crushed, however it is unlikely that the inboard anchorage is likely to displace substantially, thus limiting the displacement of the lower outer anchorage by the amount that the CRS is crushed in the impact. Many of the anchorage displacements observed in the tests with the proposed procedure appeared to be excessive. The real-world accident analysis showed that injury increased with increasing intrusion and that this was the most important factor affecting injury outcome. The reproducibility results show either no influence of intrusion, or a reduction of injury measures with increasing intrusion, which is opposite to the real-world observation. Defining the initial door position relative to the bench may encourage narrower CRSs that may perform well in a test procedure and not so well in a small vehicle, which could then perform much worse in a narrower car. Repeatability ISO define good repeatability as a CV lower than 7%, and acceptable repeatability as a CV lower than 10%, for all dummy performance criteria in certification and other test procedures. The CV’s from the TRL and from the Dorel tests were generally well within the acceptable range for repeatability within the respective labs. Criteria For children injured in side impact protecting the head is the main priority. Injuries to the head are caused by contact with the vehicle interior or the intruding object. The head was contained in all cases, however the resultant head acceleration limit was exceeded in all tests. If the proposed head criteria for front impact are applied to the side impact test procedure it is likely to lead to CRSs that absorb the loading more effectively in lateral impacts. Chest and abdomen account for a significant proportion of AIS 3+ injuries to children in side impact. If the chest criteria proposed for front impact are applied to the side impact TRL 22 CPR821 Client Project Report test procedure it is likely to lead to CRSs that absorb the loading more effectively in the chest area. Friction of Anchorages The amount of friction allowed in the ISOFix anchorages has an effect on the test results and will contribute significantly to the effectiveness of the side impact procedure. 4.5 Dummies and Criteria Biofidelity For the dummy measurements to be valid, the dummy must interact with a restraint system in a realistic way in order to display humanlike motion. This can only be achieved if all parts of the dummy are biofidelic, because the behaviour of one body part can influence another. The Q dummy may not meet all of its performance targets, particularly in the chest and the shoulder. The chest may be too stiff in both the front and side impact directions, while the shoulder may be too stiff to meet the side impact target. Criteria The criteria that have been set have been assessed and discussed in the front, rear and side impact sections of this report. The Informal Group has proposed that lower neck forces and moments, pelvis acceleration, lower lumbar forces and moments, lap belt forces (front impact), and head containment (side impact) should be assessed, but no performance requirements have been either proposed or agreed for these measurements. Furthermore, no procedure for assessing head containment in side impact has been agreed for the draft new regulation. 4.6 Implementation The project evaluated the implications of the three phases proposed for implementation of the proposed new regulation, for two scenarios; single approval and dual approval of child restraint systems. The different approval routes and the issues arising from them have different implications for three key groups of stakeholders: consumers, CRS manufacturers, and car manufacturers. Issues for consumers It may be complex to understand the labelling and instructions, and how they apply to particular vehicles. This will be more of a problem with dual approval, which could require up to three sets of labels, multiple instructions and multiple mass limits for a single CRS. Car manufacturers have to label the size of CRS and the CRS Regulation each seating position is compatible with. This is likely to be very difficult for consumers to understand. Both routes lead to different types of restraint being approved to different Regulations at different times, offering different levels of safety. The potential combination of vehicle seat labelling on each seat in multiple vehicles; different CRS mass limits, CRS labels and instructions; and different approvals for a single CRS is unlikely to reduce the misuse of CRSs. TRL 23 CPR821 Client Project Report Issues for CRS manufacturers It is not known how the belt-attached option would be approved under the new Regulation once this becomes mandatory in Phase 3. There is no obvious benefit to dual approval of ISOFix integral CRSs to justify the cost of meeting two sets of approval and conformity of production requirements. The most straightforward route for ISOFix-or-belt-attached integral CRSs is for manufacturer’s to choose to continue to approve to Reg.44. The only obvious benefit to dual approval for this CRS category would be if approval to the new Regulation was considered to be prestigious. Issues for OEMs Vehicle manufacturers, in consideration of integral CRSs that can be attached by ISOFix or the adult belt, will have to label the size of CRS and the CRS Regulations that each vehicle seating position is compatible with (Reg.14 and Reg.16 will need amending). 4.7 Indication of costs and benefits Three regulatory options have been assessed: Option 1 involves keeping the existing Reg.44 frontal impact test, but replaces the Pseries dummies with the Q-series and sets performance criteria for the neck loadings and chest compression. This option would help to reduce neck and chest injuries in frontal impacts only. This option would also implement changes to the head excursion limits currently permitted, thus also helping to reduce head and face injuries in frontal impacts. Option 2 is the same as option 1 except for the addition of a side impact test procedure. This would have additional benefit, over and above Option 1, for casualties involved in side impacts only. Option 3 is the same as option 2 with the addition of a more representative frontal impact test. The broad indications from this study are that the benefits derived from reduced casualties are likely to exceed the extra costs incurred by EU27 consumers, by a factor of somewhere between 2 and 15 to one, depending on which option is chosen. The figures for costs and benefits and ratios are necessarily based on various assumptions, as described in the main body of this report, and are subject to considerable uncertainty. TRL 24 CPR821 Client Project Report 5 Recommendations 5.1 Test Bench The proposal for the test bench design, based on the NPACS frontal test bench, should be used, with the following modifications: • The cushions should be 800 mm wide. • The cushion should be the modified version that allows the attachment of nonintegral ISOFix CRSs. • The same cushion design should be used for in front and rear impact testing and with a small modification to the backrest cushion for side impact testing. Further work is required to define the cushion characteristics, of the selected foam (FTSS T75500): • The dataset should be enlarged with tests of other exemplar foam cushions and new performance requirement should be generated from these data. • It should be decided whether angled impacts are required in order to adequately control the cushion performance. • It should be decided whether more than one impact speed is required in order to adequately control the cushion performance. • Tolerances on the dimensions of the cushions should be agreed. A compatibility issue remains, for the use of non-integral CRSs in vehicles with ISOFix anchorages that are off-set from the belt anchorages. This needs to be addressed in Reg.14 if non-integral CRSs are to be approved as Universal. The ISOFix top tether locations and seat-belt anchorage locations, for the test bench should be based on those defined in NPACS. An alternative third attachment point or volume must be defined for the test bench and in Reg.14. The current Reg.14 anchorage strength test requirements may be inadequate for some dummy and CRS combinations allowed under the proposed i-Size categorisation scheme. It is recommended that an investigation is conducted with heavier occupants in front impact tests under Reg.44 conditions (or the conditions agreed for the new regulation) to investigate the increased anchorage loading. It is also recommended that comparative tests are carried out to assess the relative effects of static (as used in Reg.14) and dynamic loading (as applied in car crashes) to the vehicle anchorages. The ISOFix mounts on the test bench must be strong enough for repeated testing and be of a size that is representative of those used in cars. 5.2 Front Impact Test Conditions The pulse for the new regulation should be based on 50km/hr full width crash test pulses representing modern vehicles, to provide an appropriate assessment of restraint systems. The vehicle fleets in Europe and the USA have changed since the development of R44 and FMVSS213 and there may be scope to harmonise these requirements. A parallel investigation into a pulse representative of modern vehicles in the USA, would be worthwhile. TRL 25 CPR821 Client Project Report The specification for installing the CRS and dummy on the test bench should be clarified to minimise misinterpretation, which can lead to inconsistency across Technical Services. Rearward facing integral CRSs For children injured in front impacts, the head is the priority body region to protect. The majority of head injuries are caused by contact with parts of the vehicle interior or other external objects. Head excursion is an issue for child protection in the field. The horizontal head excursion limit should be revised to reflect the excursion space available to children in modern vehicles, taking into account realistic vehicle front seat positions. The values for the linear head acceleration thresholds should be revised, particularly for the smaller dummies, where the thresholds may not be a realistic representation of injury risk for children under the age of one. Head excursion is measured from the film of the test. The testing laboratories must apply procedures for estimating uncertainty of measurement (U of M) of the excursion of the dummy's head. The confidence intervals should be specified and the method of applying these confidence intervals to the U of M must be clearly defined. In some cases the top camera view has to be used to measure the head excursions. The visual measurement alone, is incorrect. The procedure for this should be clearly defined in the proposal. These measured excursions must be known in order to carry out Product Qualification testing and for Conformity of Production testing. Forward facing integral restraints Head protection is the highest priority for children travelling in forward facing integral CRSs, followed by chest protection. The majority of head injuries are caused by contact with parts of the vehicle interior or other external objects. The horizontal head excursion limit should be revised to reflect the excursion space available to children in modern vehicles, taking into account realistic vehicle front seat positions. The proposed equipment, measurement tools or procedures do not lead to an accurate assessment of injury risk for the upper neck force. Neck injury is relatively rare, so the majority of current products should pass any proposed criteria. Criteria for upper neck protection should be devised to prevent new restraint designs that may lead to neck injury. Forward facing non-integral restraints Head protection is a high priority for non-integral CRSs. The horizontal head excursion limit should be revised to reflect the excursion space available to children in modern vehicles, taking into account realistic vehicle front seat positions. The largest dummy (Q10.5) is not currently available, and it is likely to have greater excursions. A different head excursion limit may need to be set for this dummy. The limits for chest compression should be revised for all dummy ages to take into consideration visceral injuries without rib fracture. If the Q dummy is to be used for the assessment of non-integral CRSs it needs to be modified to allow a “submarining” motion. In addition, the submarining motion should be detectable and ideally should be measurable. The P series dummy should be evaluated for it’s ability to assess forward facing nonintegral CRSs. The CRSs tested in this programme are considered as relatively safe with respect to the likelihood of neck injuries occurring in real world accidents. Neck injury is relatively rare, so the majority of current products should pass any proposed criteria. Criteria for upper TRL 26 CPR821 Client Project Report neck protection should be devised to prevent new restraint designs that may lead to neck injury. 5.3 Rear Impact The review of rear impact accidents showed that a 30 km/h impact represents a large proportion of rear impact accidents involving children, which supports the proposed test conditions. The head was shown to be the priority body region for protection of children in rear impacts. It is recommended that, the proposed test bench is used for the assessment of rear impact in the new regulation. It is more representative of current vehicle seats and with this being the case, CRSs assessed on this new test bench may, as a result, perform better over a wider range of vehicles. The Q series dummies should be used as a measurement device in type approval testing of CRSs, so that the head and chest accelerations could be assessed, which this may lead to safer CRSs for young babies. 5.4 Side Impact Test conditions The proposed test procedure provides a good representation of the speed of the struck vehicle chassis, but it does not reproduce the speed of the intrusion into the struck vehicle. In addition to this, at no point does the vehicle seat, to which an ISOFix seat would be rigidly mounted, lose contact with the intruding structure. During the proposed test procedure the ISOFix anchorages are allowed to move away from the intrusion panel. The movement of these anchorages must be more controlled. The phasing of the CRS-to-door contact is different in the tests performed at TRL and Dorel and hence the maximum resultant head and chest accelerations occur at different times. The phasing will be effected by the speed of the intrusion and the movement of the anchorages on the test bench. If the ISOFix anchorages in the vehicle move, it is likely to be worst case for the front passenger seat or the middle row of seats in an mpv. This needs further validation with information from full scale testing. Reproducibility It is recommended that the tolerance on the stopping distance is considered further, particularly with respect to the level of intrusion applied to the CRS. The anchorage displacement should be considered further to maintain the relevant CRS to intrusion contact conditions seen in the vehicle, to improve the reproducibility of the procedure. The real-world accident analysis showed that injury increased with increasing intrusion and that this was the most important factor affecting injury outcome. However, the reproducibility results show either no influence of intrusion, or a reduction of injury measures with increasing intrusion, which is opposite to the real-world observation. When the anchorage displacement is revised the procedure needs to be validated to check that the that injury measurements increase with increasing intrusion. The position of the CRS on the test bench was defined by measuring the distance from the inner door trim to the centre of a CRS in a number of vehicles. Defining the initial door position relative to the bench may encourage narrower CRSs that may perform well in a test procedure and not so well in a small vehicle, which could then perform much worse in a narrower car. The effect of CRS positioning with fixed anchorages should be investigated, so that the test set-up represents the worst case scenario and CRSs cannot perform artificially well. TRL 27 CPR821 Client Project Report Repeatability ISO define good repeatability as a CV lower than 7%, and acceptable repeatability as a CV lower than 10%, for all dummy performance criteria in certification and other test procedures. The CV’s from the TRL and from the Dorel tests were generally well within the acceptable range. As stated above, validation of the anchorage movement should address differences between laboratories. Criteria The criteria will need to be reviewed when the movement of the ISOFix anchorages is more controlled. If the movement of the ISOFix anchorages can be controlled, such that the procedure can reproduce the phasing of the loading events that is seen in the vehicle, albeit at a lower severity through simplification of the procedure, it may be appropriate to adjust the levels of the assessment criteria to compensate for the diminished loading. It is recommended that further work is undertaken to assess this approach. Friction of Anchorages The amount of friction allowed in the ISOFix anchorages has an effect on the test procedure. It is recommended that further investigation is carried out to allow the set-up procedure to be more representative of the CRS when attached to anchorages in the vehicle. 5.5 Biofidelity and Criteria For the dummy measurements to be valid, the dummy must interact with a restraint system in a realistic way in order to display humanlike motion. This can only be achieved if all parts of the dummy are biofidelic, because the behaviour of one body part can influence another. The Q dummy may not meet all of its performance targets. If these dummies prove to be the best current ATDs available, a pragmatic approach to assessment criteria and the associated limits will need to be taken, based on the performance of CRSs with a known history in the field. A procedure for assessing head containment in side impact must be agreed for the draft new regulation. 5.6 Implementation i-size adds to the factors that parents already need to take into account, when selecting a CRS appropriate for their child and vehicle/seat. Whilst it adds new factors, it doesn’t remove existing factors, i.e. the parent still needs to know the weight of their child. It is recommended that the rationale behind the proposal to use i-size is reviewed. For both approaches, and indeed for any conceivable approach, mass is required in order to ensure that the CRS is not overloaded. The implementation plan should be clarified. For example, the implementation section assumes that the new regulation will come into force in three stages, as discussed in the Informal Group. An alternative would be to fully develop the new regulation to include all three stages before the regulation comes into force. The disadvantage to this approach is that it will delay improving the performance of CRSs that have been selected appropriately and used correctly by the consumer. TRL 28 CPR821 Client Project Report 5.7 Indication of costs and benefits The benefit to cost ratio calculated for the effectiveness of the new regulation assumes that consumers will select appropriate CRSs and use them correctly, hence deriving the full benefits of the improved CRSs. It is recommended that, when the specification for isizing is fully developed and the implementation route is clarified, the benefit to cost ratio is recalculated to include issues associated with appropriate use and correct use of CRSs. TRL 29 CPR821 Client Project Report Acknowledgements The work described in this report was carried out by the TRL Child Safety Centre of the Transport Research Laboratory. The authors are grateful to Mervyn Edwards who carried out the technical review and auditing of this report. TRL 30 CPR821 Client Project Report Appendix A Review of Accident Studies A.1 Objectives The review of accident studies was carried out with the main objective to identify the injury mechanisms involved in front, rear and side impacts and to identify the body regions that are important to protect for child vehicle occupants. In addition to this information was gathered to gain a comprehension of side impact crash configurations relative to the protection of children in restraints. Broader information about European car occupant accident statistics for front, side and rear impacts was reviewed, with the objective of providing information relevant to the study of costs and benefits, reported in Section Appendix F. A.2 Types of accidents The CARE database contains the recorded child fatalities from road traffic accidents for the majority of European countries. It should be noted that data from Germany is missing from the database. Figure 1 shows that the largest proportion of fatalities occurs in Spain, France, Italy and Poland with over 80 fatalities per annum. However it is also important to remember that these data have not been adjusted to reflect the size of population in these countries and these countries are among the largest in population among Europe. Figure 1: European child fatalities 2005, Care database (n=585) The relative importance of front, side and rear impact protection for children has been analysed frequently in recent years. Jansch et al. (2009) presented information from the German In-Depth Accident Study (GIDAS). This database contains information about vehicle accidents involving children in the areas around Dresden and Hannover. The analysis covered a time period between July 1999 and July 2009. Figure 2 shows that front impacts were the most common type of accident (37%) involving children. Side impacts (20%), rear impacts (19%) and multiple impacts (23%) were fairly similar in frequency. This suggests that, the new regulation may need to consider including performance requirements for assessing child restraint systems in side impacts. This is also dependent on the frequency and severity of injuries to children in these accidents. TRL 31 CPR821 Client Project Report Figure 2: Distribution of accident type, GIDAS 1999-2009 data Cheung and Le Claire (2006) analysed STATS 19 data, which contained information of road accident casualties from Great Britain. The study spanned the period between 1998 and 2003, covering 57,647 cases involving injuries to children under 12. Figure 3 shows that front impacts again represent the largest proportion of accident (50%) and although rear impacts (24%) account for a slightly larger proportion of accidents than side impact (20%), protection of children in these accidents may need to be considered. Figure 3: Distribution of accident type, STATS19 1998-2003 data The severity of the injuries to children in the STATS19 data for all types of accident was also analysed (Figure 4). This shows that the large majority (94.1%) of children who are injured in road accidents receive only slight injuries, with 5.6% being seriously injured and less than 1% being killed. TRL 32 CPR821 Client Project Report 94.1% 0.3% Slight injuries Serious injuries 5.6% Fatalities Figure 4: Child casualties in cars by injury severity, STATS19 1998-2003 data Cheung (2006) further analysed the STATS19 data to identify in which type of impacts the different injury types were caused (Figure 5). This shows that all types of injuries are caused in front impact accidents. The GB data also showed that the proportion of children seriously injured is greater for side impacts (21%) than for rear impacts (11%), even though they occur less frequently. This also shows that of the children killed or seriously injured 57% occur in front impacts. The figure shows that the proportion of side impact injuries increases as the injury severity increases whether as the proportion of rear impact serious and fatal injuries decreases. Slight injuries (n=54,248) Serious injuries (n=3202) Killed (n=197) Figure 5: Distribution of injury severity, per accident type, STATS19 1998-2003 data A study by Viano et al. (2008) analysed 1996-2005 USA accident data from the Fatality Analysis Reporting System database (FARS) and the National Automotive Sampling System (NASS) crashworthiness data system. 5,219 road accident child fatalities were found in the FARS database and 1,531,327 road accidents found in NASS database. TRL 33 CPR821 Client Project Report These databases recorded impact angle of each of the vehicle collisions (Figure 6). This shows that the proportions of side and rear impacts are similar to the GB 1998-2003 data. The proportion of front impacts has increased significantly, but this could include multiple impact accidents, as this category does not exist in the database. Figure 6: Distribution of accident type, FARS & NASS 1996-2005 data Viano also used the data from FARS and NASS to calculate the fatality risk for each seating position for each type of impact. The analysis showed that children travelling in the second row (0.3%) have a 43% lower risk of fatality than the front row (0.53%) and that the third row risk has an even lower comparative risk of fatality (0.22%). Figure 7 shows the overall relative fatality risk for each seating position in the vehicle, relative to the driver. This shows children in the second row were found to have 65-71% lower risk of fatality than the driver. Front Row Driver (1) 2.44 0.54 Row 2 0.32 0.29 0.35 Row 3 0.21 0.33 0.16 Figure 7: Relative risk of fatality for 0-7 year-olds (Viano, 2008) This agrees with the current recommendation that children should, where possible, be restrained in the rear of the vehicle. However, the information also showed that, in the second and third rows, children have a greater fatality risk from side impact than for front impacts, compared to that of the driver. This again suggests the need to incorporate a side impact test into the new regulation. TRL 34 CPR821 Client Project Report A.3 General injury mechanisms in accidents Child injury mechanisms were analysed by Jansch (2009) who presented information from the GIDAS database, between July 1999 and July 2009. Table 2 shows the documented injury mechanisms in the GIDAS database for each body region, however they are not specific to front, side or rear impacts. Table 2: Injury mechanisms Head Neck Chest Abdomen Pelvis Window Glass A-B pillar Body Kinematics Front seat backrest Body Kinematics Seat belt Window Glass B-C pillar Seat belt Rear seat backrest Seat belt Front seat headrest Front seat backrest Rear seat backrest Rear side panel Rear side panel CRS Body Kinematics Seat belt Rear side panel Loose Objects Vehicle Roof CRS Figure 8 shows the proportion of each type of injury mechanism per body region for the instances where injuries occurred. This shows that head injuries were caused by contact with external objects. The seat belt is the predominate cause of chest, abdomen and pelvis injuries. The kinematics of the occupant was the main cause of neck injuries and a small proportion of chest and abdomen injuries. Head TRL Neck 35 CPR821 Client Project Report Chest Abdomen Figure 8: Injury mechanism breakdown, GIDAS data 1999-2009 TRL 36 CPR821 Client Project Report A.4 Front impact A.4.1 Front impact accident severity Cheung and Le Claire (2006) reported on accident data from the Co-operative Crash Injury Study (CCIS) database. This database was queried for the period between 1996 and 2004 for accident information involving all children under 12 years old. The change in velocity for front impact accidents, where children were injured is shown in Figure 9. This shows that 85% of front impacts where children are injured have a change in velocity of less than 50 km/h. Figure 9: Front impact change in velocity (reproduced from Cheung and Le Claire, 2006) Cheung (2006) also analysed the type of roads that children were injured using the CCIS database. Figure 10 shows the proportion of injuries to children related to the speed limit of the road on which the accident occurred. This shows that the largest percentage of children injured in road accidents (52%) occur on roads with a speed limit of 30 mph (48 km/h). Cheung analysed the data further to identify the road speed limit for the KSI casualties (Figure 11). This shows that the highest proportion of KSI casualties occur on 30 mph roads and 60 mph roads. TRL 37 CPR821 Client Project Report Figure 10: All injured children on roads by posted speed limit CCIS data (reproduced from Cheung and Le Claire 2006) Figure 11: Number of KSI children by road speed limit (N = 3,399) (reproduced from Cheung and Le Claire 2006) Cheung (2006) also investigated the relationship between front impact severity and injury from the CCIS data. From this Cheung presented Figure 12, which shows that for front impact: TRL • 50% of slight injuries occur at a change in velocity <35 km/h • 90% of slight injuries occur at a change in velocity • 50 km/h • 50% of serious injuries occur at a change in velocity • 50 km/h 38 CPR821 Client Project Report Figure 12: Front impact child injuries (reproduced from Cheung and Le Claire 2006) A.4.2 Body regions injured in front impacts Several previous European research projects have investigated, in detail, the priority body regions for child injuries in front impact. The European Enhanced Vehicle-safety Committee (EEVC) Working Group 18 Report: Child Safety - February 2006 (EEVC, 2006) produced a summary review of research from around Europe, combined with analysis of accident database information with respect to child car occupants and injuries. The sources included: • International Road Traffic Accident Database (IRTAD) European accident data • National accident data from Germany, France, UK, Sweden, Italy and Spain • CREST (Child REstraint STandards) • CHILD (CHild Injury Led Design) • CCIS (Co-operative Crash Injury Study) • GIDAS (German In-Depth Accident Study) • Questionnaire study (UK), • CSFC 96 (LAB-CEESAR) • CASMIR (LAB-CEESAR) This research concluded that the high priority body regions for each type of restraint, in front impacts were as follows: Group 0/0+ (Rearward facing) For children travelling in rearward facing infant carriers severe head injuries were found to be the most frequent injury. A high number of limb injuries were observed, but these were thought to be less of a priority as they are less life threatening. TRL 39 CPR821 Client Project Report Group I (forward facing) Head injuries were found to be the most frequent injury sustained, by children restrained in integral safety seats. The neck had a low frequency of injury, although it was still deemed to be an area to protect. Chest and abdominal injuries were also found to be not very frequent for children in integral safety seats. Group II/III (booster seats or booster cushions with adult seat belt) For children travelling on booster systems head injuries were again found to be the most frequently injured body region and the importance of abdominal injuries increased compared to integral restraints. Chest injuries were not very frequent, but it was still deemed a priority body region because the chest provides protection to vital organs. Adult seat belt For children restrained by the adult seat belt, it was reported that the body regions most frequently injured were the same as for Group II/III booster systems, i.e. head injuries. However this method of restraint resulted in higher severity injuries, especially in the abdominal region. The EEVC Working Group 12 & 18 Report: Q-dummies report - April 2008 (EEVC, 2008) used the information from the EEVC WG18 Child Safety Report (2006) to produce diagramic body regions to highlight the main areas that they considered needed protecting in front impact, for the different types of child restraint (Figure 13). This shows that the head is the priority body region to protect for all types of restraint. The abdomen becomes a high priority with increasing age, where children progress into non-integral restraint systems. It is questionable whether the neck should be a priority body region as injuries to this body region were infrequent. The chest is well protected for younger aged children using an integral restraint, but becomes a greater priority for occupants using the adult seat belt. Group 0/0+ Infant Carrier Group I 5pt Harness Group I/II/III (Harness Grp I, Booster Grp II/III) Group II/III Booster Seat Group II/III Booster Cushion Adult Seat Belt Figure 13: Body regions to protect (reproduced from EEVC, 2008) Czernakowski et al. (2001) conducted a study to investigate the affect of interface conditions on injury severity of children in crashes. Information collected, from the accident scene of 241 accidents involving children, by the Research Unit at Medical University Hannover Germany, was analysed. The distribution of injuries across all types of restraint, taken from the Hannover data is shown in Figure 14. As with the EEVC report, this also shows that the head is the most frequently injured body region. However this is followed relatively closely by chest injuries. TRL 40 CPR821 Client Project Report Figure 14: Frequencies of injured body regions of children using CRS, Hannover data Visvikis et al. (2009) analysed the CCIS database for injuries to older children in front impact as part of the EPOCh project. 277 cases, involving children aged 6-12 years-old were identified. Of these, 15 accident cases, where the child occupant received AIS 2+ injuries, were analysed further. Figure 15 shows the injury distribution for the 15 cases (18 injuries). This shows that the head, abdomen and upper limbs receive the largest percentage of injuries. This agrees with the EEVC (2008) body region diagrams (Figure 13), showing that the main areas to protect for older children in front impact are the head, abdomen and upper limbs. Figure 15: AIS 2+ injury distribution in front impact for children 6-12 years-old, CCIS data The relationship between frequency of injury and severity of injury is also important. Digges K, (2009) presented child injury data for front impact accidents, taken from the NASS database between 1993 and 2007. Figure 16 shows the body region distribution of MAIS 2+ injuries, for three different age groups. TRL 41 CPR821 Client Project Report The report combines body regions into four bands, which makes it difficult to comment on the individual body regions within the bands. For example, we know from the earlier studies that the head is the most important body region to protect for all age groups. However, the NASS combines head data with the neck data, giving the impression that the neck is a high priority area, when the sample may in fact be mostly injuries to the head. The band which includes the head, face and neck is the most frequently injured body region in all three age groups. For under 4 year-olds, where children a more likely to be restrained by an integral restraint, the relative frequency of injuries to other body regions is low. However, the frequency of injuries to the chest and limbs become more proportional with increase in age group, where children are likely to be restrained by the adult belt or possibly on a booster system. This information would agree with the EEVC (2008) body region diagrams (Figure 13). Figure 16: Body region injury distribution of MAIS 2+ injuries in front impacts, NASS 1993-2007 data TRL 42 CPR821 Client Project Report A.4.3 Injury mechanisms in front impact EEVC (2006) investigated the mechanisms behind injuries to children, by reviewing accident databases and previous research from around Europe. The EEVC concluded that the mechanism behind the main injuries for each type of restraint was: Group 0/0+ (Rearward facing) In front impacts severe head injuries were found to be caused by either CRS impact with the vehicle dashboard, direct impact of the head on a supporting object or during the rebound phase. This latter mechanism was not specified any further, but it could mean when the infant carrier rebounds after a front impact, the head may come into contact with the restraint or vehicle seat. Group I (forward facing) In front impact, head injuries were found to be caused by direct contact between the head and an object or were found to be diffuse brain injuries caused by angular acceleration. Group II/III (booster seats or booster cushions with adult seat belt) In front impacts, head injuries were again found to be caused by head contact with the vehicle interior. Abdominal injuries to the liver, spleen and kidneys were thought to be caused by poor location of the lap section of the adult seat belt. Visvikis (2009) used information from the CCIS database and the CARE database to indentify the injury mechanisms behind the injuries to older children (6-12 years) in front and side impacts. Visvikis concluded that for front impact: • Head injuries are caused by direct contact with rigid parts of the vehicle interior • Abdomen injuries are caused by the child submarining under the lap section of the seat belt • Chest injuries are caused by the diagonal section of the adult seat belt • Upper and lower limb injuries are caused by direct contact with parts of the vehicle interior. A.5 Rear impact A.5.1 Rear impact accident severity Cheung (2006) reported on the rear impact accident data from the Co-operative Crash Injury Study (CCIS) database. The change in velocity for rear impact accidents, where children were injured is shown in Figure 17. This shows that 45% of rear impacts that cause injuries to children have a change in velocity between 25-29 km/h. TRL 43 CPR821 Client Project Report Figure 17: Rear impact change in velocity (reproduced from Cheung and Le Claire 2006) A.5.2 Body regions injured in rear impact The EEVC (2006) reported that the CSFC-96 database was the only information source to provide a distribution of body region injuries in rear impact compared to the injury risk per body segment for all types of child restraint (Figure 18). The figure shows that the head is the most injured body region to be injured, followed by limb injuries. Injuries to the chest and pelvis are very infrequent. However it should be noted that this database only contained 83 rear impact cases, 60% (50) of which sustained no injury. Of the 33 children who were injured 76% (25) had slight injuries and only 24% (8) had severe injuries. Figure 18: CSFC-96 rear impact injury distribution (reproduced from EEVC, 2006) TRL 44 CPR821 Client Project Report A.5.3 Injury mechanisms in rear impact The information about the injury mechanisms that cause injuries to children in rear impact is limited. This is because European research programmes such as the CHILD project and the NPACS project found the amount of serious injuries as a result of rear impacts to be very low. The Great Britain STATS19 showed that there was around 354 KSI casualties cases (0.6% of total injuries) in rear impact and a further 13,500 cases with slight injuries (23% of total injuries). The NPACS rear impact research (Cheung and Le Claire, 2006) concluded that there were not enough cases in the field to require a higher severity impact tests and as the Regulation test was deemed to be currently suitable. EEVC (2006) reported that it is most likely that the injuries to the head are cause by similar mechanism to those that cause injuries to children in rearward facing Group 0+ restraints in front impact (A.4.3). The rear impact could cause the head of the child to contact the vehicle interior or the restraint itself. A.6 Side impact A.6.1 Side impact accident severity Cheung (2006) reported on side impact accident data from the Co-operative Crash Injury Study (CCIS) database. The change in velocity for side impact accidents, where children were injured is shown in Figure 19. This shows that 65% of side impacts that cause injuries to children have a change in velocity of the struck vehicle chassis of between 15-25 km/h. Figure 19: Side impact change in velocity (reproduced from Cheung and Le Claire 2006) Czernakowski et al. (2001) plotted injury severity related to the struck vehicle delta-v for side impacts using the data collected from 241 accidents by Hannover University. The data shown in Figure 20 shows the trend that injury severity increases directly with the delta-v. The proportion of MAIS 2-4 and MAIS 5/6 injuries begins to become significant between 21-40 km/h. The current proposed side impact test has a change in velocity of 26(+/-1) km/h, which fits into this higher category, where severe injuries begin to occur in the field. However, it has been well documented that the velocity of the intrusion of the vehicle structure onto the occupants is greater than the change in velocity of the struck vehicle chassis. TRL 45 CPR821 Client Project Report Figure 20: Children using CRS in side collisions on struck side (n=28) (reproduced from Czernakowski, 2001) Viano (2008) categorised the impact angle of accidents using 1996-2005 data from the FARS database and NASS crashworthiness data system. Table 3 shows the frequency of side impacts by angle, for this data. This shows that around 60% of the side impacts occurred at around 60o impact and 30% occurred at 90o impact angle. However, Viano found that the risk of fatality from a 90o angled side impact (1%) was significantly greater than a 60o angled impact (0.1%), or a 120o impact (0.7%). Table 3: Frequency of side impact angle Impact angle Cases % 60/300 207,881 61% 90/270 102,787 30% 120/240 28,802 9% (deg) 300 o 60o 270 o 90 o 240 o 120 o A.6.2 Body regions injured in side impact Brown et al. (2006) analysed data from the Crash Injury Research Engineering Network (CIREN) database. The database contained 232 severe side impact injury cases (AIS 3+). Figure 21 shows the distribution of injuries per body region that was created from the serious injury data. This shows that injuries to the head are the most frequent AIS 3+ injuries (34%) in side impact and are therefore the most important body area to protect. The chest region also sustained a significant amount of AIS 3+ injuries (27%) followed by the abdomen (17%). TRL 46 CPR821 Client Project Report Figure 21: Serious injury distribution for side impact, CIREN data The EEVC (2006) used the CSFC-96 database to create a body region injury distribution for side impact, for all types of child restraint (Figure 22). This shows a similar percentage of abdomen injuries to the CIREN data. There are more head injuries in the sample and the percentage of chest injuries differs hugely between the two sets of data. There were no pelvis injuries reported from the CSFC data. Figure 22: CSFC-96 side impact injury distribution (reproduced from EEVC, 2006) EEVC (2006) used side impact AIS 3+ injury data from the CREST project to create a body region injury distribution for side impact (Figure 23). The accidents contained in the CREST database are not representative of all accidents, as the project focussed on the collection of data from more serious accidents only. This sample shows a much larger proportion of head injuries compared to the CSFC and CIREN databases. Chest and abdomen injuries are again shown to be important, with a small amount of neck injuries, which corroborates the CIREN data. TRL 47 CPR821 Client Project Report Figure 23: CREST accident database AIS 3+ side impact injuries (reproduced from EEVC, 2006) Czernakowski (2001) analysed the distribution of injuries in side impact, using information taken from the Medical University Hannover Germany. The distribution of injuries across all types of restraint, taken from the Hannover University data was shown in Figure 24. The struck side injury distribution shows that the head is the most frequently injured body region (60%) and a priority for protection. The frequency of neck injuries from these data was 20%. The injuries to children seated on the non-struck side of the vehicle are predominately head injuries (75%), with 25% injuries to the upper limbs, though there were only 15 cases in the database. These data again show a high frequency of head injuries, as in the previous data, but a proportion of neck injuries are also seen. All restraint types, struck side All restraint types, non-struck side Figure 24: Frequencies of injured body regions of children using CRS, Hannover University data Visvikis (2009) analysed the CCIS database for injuries to older children in side impact. 127 cases, involving children aged 6-12 years-old were identified. Of these, 5 accident TRL 48 CPR821 Client Project Report cases where the child occupant received AIS 2+ injuries were analysed further. Figure 25 shows the injury distribution for the 5 cases (8 injuries). This shows that for older children the head has the largest percentage of injuries, with significant injuries also to chest, pelvis and lower limbs. Figure 25: AIS 2+ injury distribution in side impact for children 6-12 years-old, CCIS data Lesire (2006) investigated the relationship between vehicle intrusion and injury severity in side impacts, using accident data from the CREST and CHILD databases. The data showed that vehicle intrusion has a direct influence on the severity of injuries to children. The data showed that for restrained children, seated on the struck side of the vehicle where there was no direct intrusion, 81% received no injuries or slight injuries and few, less than 14%, received serious injuries. Where direct intrusion was present, 33% of children were uninjured or slightly injured, with a further 33% receiving moderate injuries and 33% were seriously injured or killed. The direct influence of intrusion on injury severity is further corroborated by the breakdown of injury severity compared to maximum intrusion (Figure 26). The graph shows that over 300mm intrusion will result in over 50% MAIS 4+ injuries for the occupant. Below 200mm intrusion the MAIS 4+ percentage is less than 20%. TRL 49 CPR821 Client Project Report 100% 90% 80% 70% 60% 50% MAIS 4+ 40% MAIS 2-3 30% MAIS 0-1 20% 10% 0% 0-99 100-199 200-299 300-399 400-499 >500 Maximmum Intrusion (mm) Figure 26: Injury severity percentage for different amounts of side impact intrusion (reproduced from Lesire, 2006) A.6.3 Injury mechanisms in side impact Visvikis (2009) used information from the CCIS database and the CARE database to indentify the injury mechanisms behind the injuries to older children in side impacts. Visvikis concluded that for side impact: • Head injuries are caused by direct contact with rigid parts of the vehicle interior or an intruding object • Chest and abdomen injuries are caused by compression of the child by the vehicle door panel • Upper and lower limb injuries and pelvis injuries are also caused by contact with the vehicle door panel Lesire et al. (2006) conducted analysis of the CREST and CHILD accident data related to side impacts. The injury causations for all children under 12 involved in side impact accidents was investigated. Lesire concluded that in side impact the injury causations for children on the struck side of the vehicle were: • Head injuries are the most frequent injuries and occur due to head contact with rigid parts of the vehicle interior • Chest and abdomen injuries are the next most frequently injured body regions and occur due to compression through door panel contact • Upper limb injuries are more frequent for children using booster type restraints and are also usually caused by door panel contact • Pelvis and lower limb injuries become sufficiently more frequent for children only restrained by the adult seat belt as the is no protection from intrusion. A.7 Summary TRL 50 CPR821 Client Project Report Front impacts have been reported to be the largest proportion of accidents that result in injuries to children (50%-60% of accidents). Rear impacts were reported to make up 14%-24% and side impact accidents were found to be 20%-26% of accident types. This shows side impact accidents make up a significant percentage of accidents involving children and therefore it is important that a side impact test procedure is included in the new regulation. A.7.1 Front impact The front impact accident data showed that the majority of injuries to children occur in accidents where the change in velocity is 50 km/h or less. The data has shown that 90% of slight injuries and 50% of serious injuries to children occur below 50 km/h. The STATS19 data also showed that the 94% of injuries to children in road accidents are only slight injuries. This therefore shows that a 50 km/h test would represent a large majority of accidents where children are injured. If only one front impact pulse is to be used to assess the performance of CRSs, it needs to be carried out under these conditions. If a test procedure was designed to optimise CRS performance only under the more severe conditions, representative of half of the small number of serious injuries, it may lead to stiffer CRSs, which may not perform so well in the majority of accidents where children are being injured. The data for children injured in front impacts has shown that the head is the priority body region to protect. The majority of head injuries are caused by contact with parts of the vehicle interior or other external objects. Chest and abdomen injuries become more significant with increasing age of the occupant, along with pelvic injuries. Chest and abdomen injuries were found to be predominately caused by the vehicle seat belt. Protection of the neck was not shown, by the accident review, to be an issue. However, it is important that any future changes in restraint design, associated with the new regulation do not introduce an injury mechanism into an area that may be vulnerable. Therefore it would be worthwhile providing a reasonable limit, reflecting the performance of current CRSs, to criteria for the neck. A.7.2 Rear impact The rear impact change in velocity data has shown that a 30 km/h impact represents a large proportion of rear impact accidents involving children. The data for injuries to children in rear impact shows that the head is the priority body region. The injury mechanisms that cause these head injuries are not well defined, however it is presumed that these will be similar to those that cause injuries to rearward facing children in front impact. Injuries to the neck and abdomen were also shown to be present, though only a small number of accident cases were included in the data analysis. A.7.3 Side impact The side impact data showed that the majority of injuries to children occur in accidents where the change in velocity of the struck vehicle chassis was less than 25 km/h impact. The impact angle analysis has shown that the largest proportion of side impacts occur of at 60o, followed by 90o. However the risk of fatality for a 90o impact is significantly greater. Analysis of the injured body regions in side impact has shown that protecting the head is again the main priority. Injuries to the head are caused by contact with the vehicle interior or the intruding object. Chest, abdomen and neck injuries have been shown to vary in importance between data sets. However, chest and abdomen account for a significant proportion of AIS 3+ injuries to children in side impact. These injuries have been found to be caused by compression of the child by the door panel of the vehicle. TRL 51 CPR821 Client Project Report TRL 52 CPR821 Client Project Report Appendix B Proposals for the New Procedures This section presents the proposals for new procedures tabled to the Informal Group with any immediate comments, and identifies where this research programme may provide some evaluation of the proposals. The proposals are described and the available evidence base is presented. The section identifies some of the issues that need clarification or further work and references work in the other parts of the report that may address these issues. The subjects covered in this section include: • The specification of the test bench, including cushion geometry, cushion material properties, ISOFix and seat-belt anchorage locations, and ISOFix anchorage strength • Front impact, including: the proposed sled pulse, additional requirements for deceleration and acceleration sleds, CRS installation, and assessment criteria • Rear impact, including: the proposed sled pulse, additional requirements for deceleration and acceleration sleds, CRS installation, and assessment criteria Side impact, including: the proposed sled pulse, additional requirements for deceleration and acceleration sleds, CRS installation, and assessment criteria. B.1 Test Bench The test bench consists of a seat frame and seat cushions, representing the back and base of the vehicle seat, and the ISOFix and seat-belt anchorages. Figure 27 shows an example of the front impact test bench mounted onto a deceleration sled. The following sections define the geometry and material properties of the seat and backrest cushions, the locations of the anchorages, and the results of investigations by the Informal Group into the strength requirements for ISOFix anchorages. Figure 27: Test bench mounted on a sled B.1.1 Cushion Geometry The current proposal is for the test bench design for all impact tests to be based on the NPACS frontal test bench. This was developed during the NPACS (New Programme for the Assessment of Child restraint Systems) research phase. The original NPACS test TRL 53 CPR821 Client Project Report bench designs are shown in Figure 28. There was a different cushion design for ISOFix attached restraints and belted seats. ISOFix-attached cushion Belt-attached cushion Figure 28: NPACS test benches During the NPACS validation phase (Cheung and Le Claire, 2006), it was recommended that the width of the bench was extended to enable the testing of wider restraints, such as carrycots, and the rear of the seat cushion was profiled to accept semi-universal CRSs. The width of the bench has been extended to 800 mm and the cut-outs at the rear of the cushion have been made so that restraints installed with ISOFix or the seat belt or both can all be tested using the same cushion design (see Figure 29). Figure 29: Isometric view of the new regulation test bench cushions TRL (CRS-06-02) presented the extended-width NPACS test bench cushions shown in Figure 30. The cushion foam shall be covered by sun shade cloth made of poly-acrylate fibre, the same as currently used for the test bench in Reg.44. TRL 54 CPR821 Client Project Report Measurements ±2mm Angles ±0.5o Figure 30: Dimensions of the new regulation test bench cushions B.1.2 Cushion Material Properties The foam for the proposed cushion to be used for the dynamic testing will have the same properties as the foam used for the NPACS front impact test bench seat cushion (T75500 foam). The properties of this cushion were chosen based on the results of head form drop tests conducted on a series of different European M1 vehicles during the NPACS project (Cheung and Le Claire, 2006). TRL (CRS-03-05) presented the findings of this testing to the GRSP Informal Group, after which these properties were accepted. Further reference to the drop test work conducted by TRL during the NPACS project can be found in Annexe 12 of the NPACS Final Report (Cheung and Le Claire, 2006). TRL (CRS-09-09) conducted drop tests on the existing (narrow) NPACS cushions to help the Informal Group characterise the T75500 foam to be used for the test bench. The Reg.44 2.75 kg headform was dropped from three different heights (250 mm, 500 mm and 750 mm) in three different positions on the cushion as shown in Figure 31. Figure 31: Drop test positions on the NPACS seat cushion TRL 55 CPR821 Client Project Report The Informal Group decided that, once the 800mm wide cushion was available, further drop tests would be carried out by members of the Group. FTSS were asked to lead this item and they have supplied a drop test method for assessing the dynamic properties of the foam: • • • The tests should use the calibration set-up as defined in section 8.3 of Reg.44 o 2.75 Kg impactor (see annex 17 of Reg.44) o Drop height 500 mm o Three impact locations as defined in Reg.44 8.3.2 Three different configurations of the bench foam o Foam only, without cloth o Cloth wrapped around the foam but not glued to the bench o Cloth installed according to Reg.44 (glued to the bench) Two angles for the bench foam o Bench laid down horizontally under 0• o Bench installed on sled under 15• The test matrix proposed by FTSS is shown in Table 4. Table 4: Drop test matrix Bench angle Cloth installation 0• 15• (on bench at (horizontal) sled) Foam only 3 repeats 3 repeats Cloth wrapped around foam but not glued to bench 3 repeats 3 repeats Cloth installed according to Reg.44 (glued to bench) 3 repeats 3 repeats TRL have contributed to the dataset by carrying out drop tests on two separate cushions. These drop tests were out of the scope of this project; however, in order to consider the test bench foam, the results from a number of these drop tests are analysed and discussed in Section C.3. The material properties of the foam are shown in Table 5. TRL 56 CPR821 Client Project Report Table 5: Material properties of the test bench foam Density according to ISO 485 (kg/m3) 43 Bearing strength according to ISO 2439B (N) p – 25 per cent 125 p – 40 per cent 155 Bearing strength factor according to ISO 3386 (kPa) 4 Elongation at rupture according to ISO 1798 (per cent) 180 Breaking strength according to ISO 1798 (kPa) 100 Compression set according to ISO 1856 (per cent) 3 B.1.3 Co-ordinate System The co-ordinate system for the sled tests is defined according to SAE J211-1:Dec2003. The co-ordinates system is defined relative to the bench seat for all front, rear and side impact sled tests, and is therefore aligned with the vehicle that the test represents. This gives a consistent co-ordinate system for front, rear and side impact bench tests, as well as for front and rear impact tests of CRSs that are in the specific vehicle category that are performed with a body on white mounted on the sled. No side impact test has yet been defined for CRSs in the specific vehicle category, but the same co-ordinate system would apply if such a test is developed. The origin for the co-ordinate system is at the centre of the test bench cushion and on the Cr line (the line where the seat back plane and seat cushion plane meet) as shown in Figure 32. Co-ordinate system sits in the centre of the test bench and on the CR line -y -z +x Figure 32: Bench co-ordinate system TRL 57 CPR821 Client Project Report B.1.4 Anchorages B.1.4.1 ISOFix Anchorage Locations TRL (CRS-05-03) presented the location of the ISOFix anchorages defined, for the front impact test bench, in the NPACS project (Cheung and Le Claire, 2006) which have been adopted in the current proposal for the test bench design. These anchorages represent the location of the most rearward ISOFix anchorages in vehicles, based on measurements data taken from 30 European vehicles. The most rearward position was chosen as it is viewed to be the worst case position in terms of the compatibility and dynamic assessment of ISOFix CRSs. The ISOFix anchorage locations are shown in Table 6. Table 6: ISOFix anchorage locations Location x (mm) y (mm) z (mm) Lower Left -65 -140 -2 Lower Right -65 140 -2 Only one set of comparison data has been presented to the Informal Group. MercedesBenz (CRS-03-06) investigated the location of the ISOFix anchorage bars in their current vehicle range. They reported that: • In the x-axis, the bars ranged from 9-34 mm behind the CR line; • In the y-axis the modal anchorage position was 140 mm either side of the centre of the CR line, although one vehicle did have offset anchorages (+125 mm and -150 mm); • In the z-axis a large variation was observed ranging from -9 mm below to +6 mm above the CR line. These data show that the location of the ISOFix anchorages in the x-axis is very rearward compared to the Mercedes-Benz vehicles. However the sample included only a small number of vehicles (seven). The data also shows that there are vehicles where the ISOFix anchorages are off-set to the belt anchorages. This may result in a compatibility problem, where a restraint is installed into the ISOFix attachment points, but is then unable to use the seat belt properly as it is offset of the ISOFix anchorages in the vehicle, as it creates a poor fitment of the seat-belt across the occupant. There was a large variation in the location of the anchorages in the measured z-axis. However, the chosen z-axis location represents the median of the data from the measurements taken during the NPACS research phase. B.1.4.2 Alternative, third ISOFix Attachment Point Reg.44 currently allows type approval of Universal ISOFix CRSs that are attached to the vehicle by two lower rigid anchor points in addition to a top tether (third) anchorage point, which acts as an anti-rotational device. The new regulation proposes to allow ISOFix child restraints to be categorised as “universal”, with the use of an alternative third attachment point as the anti-rotational device, namely a support leg. Therefore an envelope for this 3rd attachment point will need to be defined in Reg.14. The CRSs that use the alternative third attachment point will need an adjustable support leg that is compatible with the envelope defined for Reg.14. The test bench that assesses these CRSs will need to be adjustable to both ends of the range of movement TRL 58 CPR821 Client Project Report of the foot. This option requires investigation into the range of floor depths in the current European fleet. TRL (CRS-05-03) presented the NPACS floor location which is the current proposal for the test bench design. The floor specifications are: • 210 mm below Cr axis (adjustable) • Surface hardness •120 HB, according to EN ISO 6506-1:1999 • Surface roughness •Ra 6.3, according to ISO 4287:1997 • Withstands 5 kN vertical concentrated load o Vertical movement •2 mm (relative to Cr axis) o No permanent deformation The International Organisation of Motor Vehicle Manufacturers (OICA) (CRS-03-07) presented data on their investigation into various floor positions. Measurements in the xdirection and z-direction were taken between the hip point and the heel point of the adult male 50th percentile (J Male 50th percentile for superminis). The measurements are shown in Table 7. It is unclear from the reference how many vehicles were measured and how representative these measurements are of a wide variety of vehicles. Table 7: Floor positioning versus H point Vehicle Type Average X (mm) Average Z (mm) Supermini 433 387 Small Family Car 537 359 Small MPV 515 394 Small Off-road 563 341 VTI (CRS-10-06) also presented information to the Informal Group, from measurements of several vehicles with the aim of identifying a potential geometric zone, relative to the present two rigid ISOFix anchorages, where an alternative third ISOFix anchorage may be positioned. A measurement fixture, based on the envelopes R2 (and R3) defined in ISO 132163:2006 (UNECE Reg.16 Annex 17) was used. The x and z coordinates were calculated to provide these measurements relative to the centre line for the two rigid ISOFix anchorages (Figure 33). The measurements recorded during the study are shown in Table 8. VTI however recognised that this sample was too small to draw any conclusions and therefore are continuing to measure vehicles to add to these data. It is clear that there is not yet enough VTI evidence to start creating a defined design requirement for the 3rd attachment point at this point in time. TRL 59 CPR821 Client Project Report Figure 33: 3rd ISOFix attachment point measurements Table 8: X and Z coordinates of potential alternative 3rd attachment point (reproduced from VTI, CRS-10-06) Alternative 3rd attachment point coordinates Measurements Vehicle type A (mm) B (mm) • (deg) • (deg) X (mm) Z (mm) MPV 495 440 11.9 90 -475 -294 Small family 565 410 10.8 90 -547 -260 Small family 545 330 10.8 89 -521 -184 Small family 535 250 10.8 80 -474 -102 Off-road 575 455 18.7 90 -530 -228 Off-road 590 480 18.7 86 -511 -247 Small family 550 465 16.4 90 -515 -267 Small family 575 420 16.4 85.6 -507 -213 Small family 590 330 16.4 84.2 -520 -119 Family 570 435 14.6 90 -540 -248 Family 570 340 14.6 86 -517 -152 Family 560 420 8.3 90 -548 -295 Family 580 300 8.3 83.7 -535 -170 The envelope for the alternative third anchor point is being led by OICA and is ongoing in the Informal Group. The test bench floor will need to adjustable to the two extremes of TRL 60 CPR821 Client Project Report anchorage position, so that Universal CRSs are designed to perform across a wide range of vehicles. B.1.4.3 ISOFix Top Tether Anchorage Locations TRL (CRS-05-03) presented the location of the top tether anchorages from the NPACS project (Cheung and Le Claire, 2006), which have been used in the current proposal for the test bench design. These are the same locations as currently used in Regulation 44. The top tether anchorage locations are shown in Table 9. Table 9: Top tether locations Location X (mm) y (mm) z (mm) Smallest dummy (G1) -550 0 -475 Largest dummy (G2) -1450 350 0 B.1.4.4 Seat Belt Anchorage Locations TRL (CRS-05-03) presented the location of the seat belt anchorages from the NPACS project (Cheung and Le Claire, 2006), which have been used in the current proposal for the test bench design. These locations were chosen based on measurements taken from the belt anchorage positions of the front and rear seats, of 30 different sized European vehicles. The belt anchorage locations are shown in Table 10. Table 10: Belt anchorage locations Location x (mm) y (mm) z (mm) Upper (D-ring) -240 -250 -630 Lower (buckle) -29 200 59 Lower (outer) 10 -200 14.5 B.1.4.5 Seat belt Retractor The seat belt retractor must be a diameter of 33 ±0.5 mm and be capable of locking once the correct belt tensions have been achieved in the lap section (50±5N), shoulder section (50±5N) and on the reel (4±3N). B.1.4.6 i-Size ISOFix CRS Categorisation “i-Size” is a category of CRS, for use in i-Size ready vehicles (not necessarily on all vehicle positions) approved according to Reg.16 (Reg.16 will need to be amended). An i -Size CRS must also meet some general requirements to make it suitable as an i -Size CRS. An i -Size CRS attaches to the vehicle by means of two rigid ISOFix attachments and an anti-rotational device. The anti-rotational device is either a top tether or a connection that attaches to the alternative third anchor point (yet to be defined). The dimensions of an i -Size CRS are defined by the Vehicle Seat Fixtures (VSF) as defined in Regulation 16 as follows: TRL 61 CPR821 Client Project Report i -Size forward facing integral CRSs must fit in ISO/F2x envelope dimensions for a full-height forward-facing toddler CRS (height 720 mm) ISOFIX SIZE CLASS A (not yet agreed). An integral CRS is where the child is restrained in the CRS independently of the CRS to vehicle attachment. Non-integral i -Size CRSs have not been defined. i -Size rearward facing integral CRSs must fit in ISO/R2 envelope dimensions for a reduced-size rearward-facing toddler CRS ISOFIX SIZE CLASS D (not yet agreed). The combined mass of an integral i-Size CRS plus the mass of the heaviest child intended to use the CRS must not exceed 33 kg (not yet agreed). B.1.4.7 ISOFix Anchorage Strength The anchorages on the test bench must be strong enough to assess i -Size CRSs. With the introduction of i -Size categorisation in the new regulation, the question whether an older, heavier child can use an ISOFix integral CRS has been raised as this has implications for the test bench and for UNECE Reg.14. The current specification in Reg. 14 relating to the ISOFix anchorages supplied in the vehicle was based on a child with a mass of 18 kg in a CRS with a mass of 15 kg, giving a total mass for the CRS and occupant of 33 kg. Currently a pair of ISOFix anchorages, in the vehicle, has to be capable of withstanding a static load of 8 kN without deforming. Members of the Informal Group from CLEPA and OICA have been investigating the effect that different combinations of occupant and CRS mass, allowed within the proposed i Size categories, would have on ISOFix anchorage loads. To date, they have assessed the effects of having different combinations of child verses product mass, within the overall mass restriction of 33 kg, particularly looking at lighter CRSs with heavier occupants, thus keeping the total mass the same. DOREL Europe (CRS-03-17), for CLEPA, investigated the forces measured by the ISOFix anchorages using different anti-rotational devices. Two different Group I ISOFix child restraints with top tether were compared to a Group I child restraint with a support leg. A rear facing Group 0+ ISOFix seat with support leg was also tested. Each seat was subjected to a Reg.44 front impact pulse using the maximum sized dummy for the restraint; P1.5 (11 kg) Group 0+, P3 (15 kg) Group I). The loads recorded are shown in Table 11. Table 11: Loads measured in anchorages Reg.44 pulse Seat Antirotation Device Total Mass (seat mass) ISOFix Location (kg) Left Anchorage Right Anchorage Top Tether (N) (N) (N) Seat A Top Tether 26 (11) Rear 2418 - 3870 Seat A - 26 (11) Rear 3468 - - Seat B Top Tether 24 (9) Forward 1487 2387 3760 Seat B - 24 (9) Forward 2259 3497 - Seat C Support Leg 29.6 (14.6) Rear 3271 - - Seat D Support Leg 23.2 (12.2) Rear 2928 4243 - TRL 62 CPR821 Client Project Report The results show that, where measured, there was an imbalance between the left and right ISOFix anchorages; however, the authors did question whether this was correct in their conclusions. The imbalance may have been because the top tether was offset from the centre line of the bench in the tests. The results also appear to show that the addition of the top tether significantly reduced the loading on the ISOFix anchorages (by 43-52%), but cannot be used to show whether the support leg has a similar effect. DOREL Europe (CRS-05-04) continued their work by investigating the loads on the ISOFix anchorages using an ATD representing a 6 year-old child (P6), tested to a higher severity pulse. A Euro NCAP type pulse was used to test a Group I integral child restraint with and without a top tether anti-rotation device. All the tests were conducted using the rearward anchorage position. The loads recorded in the testing are shown in Table 12. Table 12: Loads measured in ISOFix anchorages Euro NCAP pulse Total Mass (CRS mass) Left Anchorage Right Anchorage Top Tether Antirotation Device Dummy Reg.44 - P3 24 (9) 2990 4685 - Euro NCAP Top Tether P6 31 (9) 2878 ? 5380 Euro NCAP - P6 31 (9) 5198 ? - Pulse (N) (kg) (N) (N) These results show that the load on the anchorages measured in the test using the P6 without the top tether, were significantly greater than those with the P6 with a top tether. The results with the P6 in a CRS with top tether at the higher pulse were compared to tests with a smaller dummy (P3) in the CRS without a top tether, at a lower pulse (Reg.44) and the loadings to the anchorages were still lower from the CRS with the larger dummy (P6) and the top tether. This again shows that the addition of the top tether, removes a significant amount of loading from the ISOFix anchorages. However, the test with the P6 in the CRS without the top tether loaded over 10 kN through the ISOFix anchorages, assuming symmetrically loading. However the Reg.44 test data shows that the right anchorage experience 57% more load than the left and therefore the anchorage total load in the P6 tests could have potentially been greater than just double the load on the left anchorage. Britax (CRS-07-02), for CLEPA, investigated the forces measured by the ISOFix anchorages using Group I integral restraints with different anti-rotation devices. Three different installation types of Group I ISOFix were tested: without an anti-rotation device, with top tether, and with a support leg. Each seat was tested using the Reg.44 front impact pulse with the ISOFix anchorages in their rearmost position, and the force on the left ISOFix anchorage was measured. The loads recorded in the tests are shown in Table 13. TRL 63 CPR821 Client Project Report Table 13: Loads measured in anchorages Reg.44 pulse Total Mass (seat mass) Left Anchorage Top Tether (N) (N) Rear 6729 - 27.1 (12.1) Rear 3497 4528 P3 28.4 (13.4) Rear 6287 - Top Tether P3 23.7 (8.7) Rear 3516 ? Seat C - P3 23.7 (8.7) Rear 5334 - Seat D Support Leg P3 29.6 (14.6) Rear 5157 - Antirotation Device Dummy Seat A - P6 34.1 (12.1) Seat A Top Tether P3 Seat B Support Leg Seat C Seat ISOFix Location (kg) The results showed that a 6 year-old in an integral ISOFix seat could result in 13.5 kN of overall loading to the ISOFix anchorage points (assuming symmetrical loading), compared with the 8 kN static load to which the anchorages are tested in Reg.14. Britax commented that their connectors are therefore capable of handling this amount of force as no sign of damage was seen during the tests. Britax also noted that the top tether significantly reduces the loads in the ISOFix anchorages. The overall load to the ISOFix anchorages, from seat B (> 12.5 kN) were also well above 8 kN (assuming symmetrical loading). This suggests that either the ISOFix anchorage strength requirement in UNECE Reg.14 may need to change or vehicles may not be able to accommodate integral CRSs designed for older children. DOREL Europe (CRS-07-03) conducted a comparison between the forces recorded at the ISOFix anchorages in a Reg.44 impact test and those measured using a Euro-NCAP frontal impact crash pulse. Two different restraint types were compared; a Group 0+ integral CRS (seat A) and a Group I integral CRS (seat B), both with support legs. The maximum loads measured in the ISOFix anchorages during the tests are shown in Table 14. Table 14: Loads measured in anchorages Reg.44 pulse, Euro-NCAP comparison Seat Antirotation Device Pulse (kg) Seat A Support Leg Reg.44 Seat A Support Leg Euro NCAP Seat B Support Leg Reg.44 Seat B Support Leg Euro NCAP TRL Dummy Total mass (seat mass) ISOFix Location Left Anchorage Support Leg (N) (N) P1.5 23.2 (12.2) Rear 2847 3699 Q1.5 23.3 (12.2) Rear 2968 3119 P3 29.6 (14.6) Rear 3221 4065 Q3 29.2 (14.6) Rear 3761 4622 64 CPR821 Client Project Report The results show that the forces in the anchorages of the forward facing seat (seat B) significantly increase with the increase of test severity. However the rearward facing infant carrier (seat A) is less affected by the increase in test severity. JPMA and Vehicle Manufacturers LATCH Working Group (CRS-03-12) have investigated the loads on the anchorages from three different types of CRS installation; LATCH, lap belt only and 3pt seat belt. Each installation type was subjected to a 35mph frontal US NCAP pulse with a Hybrid III 6 year-old (65 lbs, or 29.5 kg) and a child restraint (•21 lbs, or 9.5 kg) on the FMVSS213 test bench. The loads recorded in the tests are shown in Table 15. Table 15: Anchorage loads during dynamic test Installation Left ISOFix Anchor (N) Right ISOFix Anchor (N) Left Lower Anchor (N) Right Lower Anchor (N) Top Tether (N) Shoulder Belt LATCH 8250 8500 - - 10000 - 3pt Belt - - 8000 8250 7900 5000 Lap Belt - - 8500 8750 8750 - This shows that the ISOFix anchorages received symmetrical loading with the top tether receiving the largest proportion of the load. Mercedes-Benz (CRS-06-03) investigated the relationship between the static strength test of the ISOFix anchorages in a vehicle and the dynamic load they are subjected to during a vehicle crash. The aim was to see whether it is possible to increase the permissible mass of the child for the current anchorage systems. Currently: • In Europe, Reg.14 applies a static strength test with load level of 8 kN • In North America, FMVSS 225 applies a static strength test with load level of 15 kN Mercedes-Benz attached a 40 kg force application device, which represented a 6 year-old (30 kg) and a child restraint (10 kg) to the ISOFix and top tether anchorages in a vehicle. The vehicle was then crashed according to US-NCAP, 56 km/h barrier with 100% overlap. The results showed that anchorages deformed under the applied load. Mercedes-Benz therefore recommended that as anchorages rated to 15 kN could only just restrain the required level of force, the European anchorages would not be able to due to their lower rating (8 kN). The fact that the child is not perfectly coupled to the restraint also has to be considered, i.e. an occupant and restraint mass of 25 kg and 10 kg does not give the same anchorage forces as an occupant and restraint mass 20+15 kg, even though the total mass is the same in each case. This means a 6 year-old in a light restraint will create substantially larger anchorage loads, than the equivalent total mass combination of a 3 year-old and CRS (as shown by the P6 test data). Some of the ISOFix anchorage load data show that the CRSs with support legs already put in excess of 10 kN into the anchorages. Currently it is not known whether these large restraints with support leg (typically around 15 kg) are causing anchorage failures in the field as they have only been introduced to the market in the last few years. TRL 65 CPR821 Client Project Report It is also very important to consider the relation between the tested static load of 8 kN and the dynamic load. The duration of the recorded dynamic loading will be comparatively shorter. It is recommended that further testing is carried out to assess heavier occupants in front impact tests under Reg.44 conditions, to investigate the anchorage loading. Also, it is recommended that comparative tests are carried out to assess the relative effects of static and dynamic loading to the vehicle anchorages. B.1.5 Summary of anchorage locations The ISOFix and seat-belt anchorages for the impact testing are located at the positions shown in Table 16, using the sign convention shown in Figure 32. Table 16: Anchorage locations Direction x y z Lower Left -65 -140 -2 Lower Right -65 140 -2 Smallest dummy (G1) -550 0 -475 Largest dummy (G2)1 -1450 350 0 Upper (D-ring) -240 -250 -630 Lower (buckle) -29 200 59 Lower (outer) 10 -200 14.5 ISOFix anchorages Top tether locations Belt anchorage locations 1 Only tether point G1 is used for side impact TRL 66 CPR821 Client Project Report B.2 Front Impact The front impact test proposed in the new regulation is based on the Reg.44 front impact test with some minor equipment and assessment changes. B.2.1 Test bench The test procedure uses the test bench and cushions described in Section B.1, the coordinate system defined in Section B.1.3 and the anchorage positions defined in Section B.1.5. The TRL front impact sled test rig is shown in Figure 34. Figure 34: Front impact test rig B.2.2 Sled pulse The question of which pulse to use in the front impact test was discussed during several of the GRSP Informal Group meetings. The main reason for the discussion was to ascertain whether the Reg.44 front impact pulse, which was created in the 1970’s and based on vehicle data at the time, is still representative of modern vehicles. The Reg.44 front impact corridor was created from impact data from full width barrier, 50 km/h front impact tests of a range of vehicles at the time. The design of vehicles has progressed significantly since then, especially as the stiffness of vehicles has increased, firstly with the introduction of the front impact test procedure in Reg.94 (56 km/h) and then with the introduction of the higher severity Euro-NCAP test (64 km/h). Therefore it has been suggested that the corridor may not be representative of the modern, stiffer vehicles. Several pulses from front impact whole vehicle tests at different test speeds were presented during GRSP Informal Group meetings. UTAC (CRS-04-03) presented the vehicle pulses from three different types of impact, comparing each one to the current Reg.44 corridor. Unfortunately the size, model or type of the vehicles tested and presented to the Group are not known. Figure 35 shows the vehicle pulses from nine different vehicles tested using the Euro NCAP 64 km/h, 40% offset deformable barrier test. Comparing the average of the vehicle pulses to the Reg.44 corridor shows that the initial deceleration gradient is not as severe (steep) as the Reg.44 corridor. The initial gradient is less steep for the Euro NCAP TRL 67 CPR821 Client Project Report vehicles even though they are much more recent designs than were used to define the Reg.44 corridor, which is likely to be because the Euro NCAP data is from 40% overlap offset frontal impacts, and the Reg.44 corridor is based on full-width impacts. Also the peak, although outside the higher limit of Reg.44, occurs around 15ms later than the Reg.44 corridor peak, at the point that the Reg.44 corridor is returning to zero, as the impact sled would come to rest. Figure 36 shows the vehicle pulses from eight different vehicles tested using the Regulation 94 56 km/h, 40% offset deformable barrier test. Comparing the average of the vehicle pulses to the Reg.44 corridor shows that the initial deceleration gradient is not as severe (steep) as the Reg.44 corridor. Again, this is likely to be due to the difference between full-width and offset frontal impacts. The peak does occur within the Reg.44 corridor, but the deceleration decay then takes a longer time to reach zero, thus increasing the stopping distance of a sled test. Figure 37 shows the vehicle pulses from two different vehicles tested using a Progressive Deformable Barrier (PDB), assumed to be a 60 km/h, 40% offset deformable barrier test. Comparing the average of the vehicle pulses to the Reg.44 corridor shows that the initial deceleration gradient is within the Reg.44 corridor until it drops below the lower corridor just prior to the peak. The peak does occur around the maximum higher deceleration limit of the Reg.44 corridor. The deceleration decay does match the gradient of the Reg.44 corridor, however it is just beyond the outer limit of the corridor, as the peak occurred towards the end of the higher corridor. Figure 38 shows a comparison of the average pulses from Figure 35, Figure 36 and Figure 37 with the Reg.44 corridor. This shows clearly that both the Euro NCAP pulse and the R94 pulse do not match the current Reg.44 corridor very well and both would require a longer stopping distance to be introduced as well as an increase in impact speed. The PDB tests are the closest to fitting the corridor, however this pulse data is only based on two vehicle tests, and the types of vehicles are unknown. TRL 68 CPR821 Client Project Report Figure 35: Euro-NCAP front impact test - 64 km/h, 40% offset deformable barrier test Figure 36: R94 front impact test - 56 km/h, 40% offset deformable barrier test Figure 37: PDB front impact test - 60 km/h, 40% offset deformable barrier test Figure 38: Front impact average pulse comparison TRL 69 CPR821 Client Project Report UTAC (CRS-07-07) presented some more vehicle pulses from three different types of impact, showing a comparison of pulses from small vehicles to pulses from large (referred to as “Berline” in the figures) vehicles, to the current Reg.44 corridor. Figure 39 shows the vehicle pulses from four different vehicles (2 small, 2 large) tested using the Euro NCAP 64 km/h, 40% offset deformable barrier test. The vehicle pulses from the small vehicles show that the initial deceleration gradient is within the Reg.44 corridor, until the peak. However the peak occurs outside the corridor both in duration and magnitude. The deceleration decay does then match the gradient of the Reg.44 corridor; however, it is just beyond the outer limit of the corridor. However, the larger vehicles have an initial deceleration gradient which is not as severe (steep) as the Reg.44 corridor. The peaks also occur later than required by the Reg.44 corridor and the deceleration decay then takes a longer time to reach zero. Figure 40 shows the vehicle pulses from four different vehicles (2 small, 2 large) tested using a Progressive Deformable Barrier (PDB), 60 km/h, 40% offset deformable barrier test. The vehicle pulses from the small vehicles show that the initial deceleration gradient is within the Reg.44 corridor until the peak, which occurs earlier than the Reg.44 corridor peak and with greater magnitude. The deceleration decay does then match the gradient of the Reg.44 corridor. The larger vehicles have an initial deceleration gradient also inside the Reg.44 corridor for the majority of the test and only slightly exceed the Reg.44 maximum corridor at the peak. The deceleration decay does match the gradient of the Reg.44 corridor, however it is just beyond the outer limit of the corridor. Figure 41 shows the vehicle pulses from four different vehicles (2 small, 2 large) tested using the Regulation 94 56 km/h and the EEVC 60 km/h, 40% offset deformable barrier tests. This shows that the increase in impact speed has little effect on the initial deceleration gradient of all the vehicles. Two of the vehicles have little increase in the maximum deceleration experienced by the vehicle between the two different test speeds. However the other two vehicles (1 small, 1 large) see a 6-10g increase in peak deceleration with increased impact speed. TRL 70 CPR821 Client Project Report Figure 39: Euro-NCAP front impact test - 64 km/h, 40% offset deformable barrier test Figure 40: PDB front impact test - 60 km/h, 40% offset deformable barrier test Figure 41: Front impact pulse comparison – R94 (56 km/h) & EEVC (60 km/h) test pulses TRL 71 CPR821 Client Project Report The information presented to the Informal Group has shown that the Euro NCAP pulse (64 km/h) would subject the restraint to a higher severity for a longer duration and is therefore not representative of the Reg.44 pulse. The R94 pulse (56km/h) typically has a less severe initial deceleration compared with the Reg.44 pulse, although the peaks have a similar magnitude. The overall duration of the R94 pulse is similar to the upper limit of the Reg.44 pulse. The information from the PDB pulses seems to show a similar severity to the Reg.44 corridor. However this is only based on the data from four vehicles, and there is a variation in pulse depending on the size of the vehicle. Based on this evidence it was proposed by the Informal Group that the current Reg.44 pulse shown in Figure 42 will be used for the front impact testing. A valid calibration run must be conducted before each set of testing which must meet the corridor and the defined input criteria specified for deceleration devices (Table 18). Table 17 shows the coordinates of the upper and lower corridors of the front impact pulse. It was recognised that further investigation was required and this was added to the scope of this project. The lack of information from 50 km/h, full width barrier tests, needs to be rectified to allow a true evaluation as to whether the Reg.44 corridor is still representative of modern vehicles to be conducted. In order to investigate this further, an alternative pulse was developed within the project based on full-width accident data available from NHTSA. This resulted in a pulse with a higher peak deceleration and steeper initial deceleration than the Reg.44 pulse, which was therefore very different to the offset pulses presented to the Informal Group and summarised above. More discussion of this pulse and the results of tests using both the alternative pulse and the standard Reg.44 pulse may be found in Section C.4.2. Figure 42: Front impact pulse TRL 72 CPR821 Client Project Report Table 17: Front impact pulse coordinates Time (ms) Deceleration Deceleration lower corridor upper corridor (g) (g) 0 20 0 10 - 50 20 28 65 20 - 80 - 28 100 0 - 120 - 0 In addition to this, as part of this project, information from full scale testing has been reviewed to provide evidence for an alternative front impact pulse. This work is discussed in C.4.2. B.2.3 Test devices B.2.3.1 Deceleration test device Front impact tests can be conducted using a deceleration device as long as the criteria in Table 18 are achieved. The sled must weigh in excess of 380 kg (the TRL sled weighed over 1000 kg to minimise any potential inertia effects of different CRSs) and remain horizontal throughout the test. Table 18: Front impact deceleration sled requirements Stopping distance (mm) Speed (km/h) Test Restraint type Forward facing 50 +0 Trolley with test seat /-2 650±50 */ Rearward facing 50 +0 /-2 650±50 */ B.2.3.2 Acceleration test device Alternatively the front impact testing can be conducted using an acceleration device as long as the following dynamic testing conditions are met: • The total velocity change (•V) of the trolley must be 52 • The acceleration curve is within the hatched area shown in Figure 42 • The curve must also stay above the segment defined by the coordinates (5g, 10ms) and (9g, 20ms), shown in Figure 42. */ During calibration, the stopping distance should be 650 TRL 73 +0 /-2 km/h ± 30 mm CPR821 Client Project Report • The start of the impact (T0) is defined, according to ISO 17 373 for a level of acceleration of 0.5g • The mass of the trolley, equipped with its seat, must be greater than 380 kg However, if the tests were performed at a higher speed and/or the acceleration curve has exceeded the upper level of the hatched area and the child restraint meets the requirements, the test shall be considered satisfactory. B.2.4 CRS installation The installation of a CRS and test dummy in the new regulation is based on the procedures in the current Reg.44. However some of this process is open to interpretation, which can lead to inconsistency across Technical Services. Many ISOFix CRSs have adjustable anchorages, allowing the CRS to be fitted tightly to the vehicle seat cushion. Reg.44 specifies that ISOFix restraints should be installed using a procedure that relies to an extent on the CRS to ratchet towards the seat bight. Application of a small additional force is allowed, below a certain height. However there are many CRS designs that require a lever to be held open while the force is applied to the restraint, in order to activate the ratchet feature. This can therefore create differences, in the way these CRSs are attached to the test bench, across different Technical Services. If the child restraint system uses a top tether Reg.44 specifies that the top tether should be installed after the ISOFix attachments have been latched and tightened. The action of tensioning the top tether can result in the front of the CRS lifting from the test seat cushion, which can result in a set-up that is not recommended by the manufacturer and this may lead to differences with installation. In the case of a support leg with adjustable steps, the support leg length must be adjusted such that the support leg is in contact with the test bench floor and adjusted to its maximum and minimum position, compatible with the floor pan. Ensuring good footfloor contact can vary depending on the angle of the support leg. However, the angle of support leg placement is not always defined by the manufacturer. Therefore an estimate may have to be made, which can lead to a variation in set-up across Technical Services. The proposal in the current new regulation for positioning the dummy is an improvement compared to Reg.44, but needs completing with a setting-up procedure that is measurable, where possible. For example when setting a dummy into a rearward facing infant carrier, the dummy foot position can affect the results in rear impact. The foot position and leg positioning are undefined. For forward facing CRSs the new regulation recommends placing the dummy’s arms on the legs, however the Q1 dummy arms aren’t long enough to reach the legs. B.2.5 Assessment criteria The front impact criteria to be assessed in the new regulation are: TRL • HIC15 (where there is hard contact – in bodyshells) • Cumulative 3ms resultant Head Acceleration • Upper Neck Tension Force Fz • Upper Neck Moment My • Thorax Acceleration Cumulative 3 ms • Thorax Chest Deflection Dx • Lower Lumbar Load Cell Force • Lap belt force (booster seats only) 74 CPR821 Client Project Report • Horizontal and Vertical Head Excursion The performance limits for these criteria proposed by the Informal Group are detailed in Section B.5.3. Although it should be noted that for the purposes of this evaluation project, extra data were acquired, namely lower neck forces and moments and pelvis acceleration. The lower lumbar forces and moments, and lap belt forces do not yet have proposed performance limits. TRL 75 CPR821 Client Project Report B.3 Rear Impact The rear impact test proposed in the new Regulation is based on the Reg.44 rear impact test with some minor equipment and assessment changes. B.3.1 Test Bench The rear impact test in the new regulation uses the front impact bench rotated 180o (Figure 43: Rear impact sled). The test procedure uses the test bench and cushions described in Section B.1, the co-ordinate system defined in Section B.1.3 and the anchorage positions defined in Section B.1.5. Figure 43: Rear impact sled B.3.2 Sled pulse The current proposal in the new regulation is to use the Reg.44 rear impact pulse (Figure 44). A valid calibration run, which must meet the corridor and the defined input criteria specified for test devices, must be conducted before each set of testing (Table 18). Table 18 shows the coordinates of the upper and lower corridors of the rear impact pulse. Acceleration devices have different requirements to deceleration devices and these differences are shown in B.3.3. TRL 76 CPR821 Client Project Report Figure 44: Rear impact pulse Table 19: Rear impact pulse coordinates Time (ms) Deceleration Deceleration lower corridor upper corridor (g) (g) 0 - 21 10 0 10 7 - 20 14 - 37 14 - 52 7 - 52 0 70 - 21 70 - 0 B.3.3 Test devices B.3.3.1 Deceleration test device Rear impact tests can be conducted using a deceleration device as long as the criteria in Table 20 are achieved. The sled must weigh in excess of 380 kg (the TRL sled weighed over 1000 kg to minimise any potential inertia effects of different CRSs) and remain horizontal throughout the test. TRL 77 CPR821 Client Project Report Table 20: Rear impact deceleration sled requirements Test Restraint type Trolley with test seat Rearward facing Stopping distance (mm) Speed (km/h) 30 +2 /-0 275±25 **/ B.3.3.2 Acceleration test device Alternatively the rear impact testing can be conducted using an acceleration device as long as the following dynamic testing conditions are met: • The total velocity change (•V) of the trolley must be 30 • The acceleration curve is within the hatched area shown in Figure 44 • The curve must also stay above the segment defined by the coordinates (5g, 5ms) and (10g, 10ms), shown as a red line in Figure 44. • The start of the impact (T0) is defined, according to ISO 17 373 for a level of acceleration of 0.5g • The mass of the trolley, equipped with its seat, must be greater than 380 kg +2 /-0 km/h However, if after calibration, the tests are performed at a higher speed and/or the acceleration curve has exceeded the upper level of the hatched area and the child restraint meets the requirements, the test shall be considered satisfactory. B.3.4 CRS installation The installation issues for the rear impact test along the same lines as the examples given in B.2.4 for front impact set-up. B.3.5 Assessment criteria The rear impact criteria to be assessed in the new regulation are: The front impact criteria to be assessed in the new regulation are: • HIC15 (where there is hard contact – in bodyshells) • Cumulative 3ms resultant Head Acceleration • Upper Neck Tension Force Fz • Upper Neck Moment My • Thorax Acceleration Cumulative 3 ms • Thorax Chest Deflection Dx • Horizontal and Vertical Head Excursion The performance limits for these criteria proposed by the Informal Group are detailed in Section B.5.3. Although it should be noted that for the purposes of this evaluation project, extra data were acquired, namely lower neck forces and moments and pelvis acceleration. **/ During calibration, the stopping distance should be 275 ± 20 mm TRL 78 CPR821 Client Project Report B.4 Side Impact The side impact test procedure is not yet finally defined in the proposed regulation. The proposal for future inclusion in the new Regulation is based on a test method devised by DOREL France (CRS-10-03). The test is intended to be simplified and not representative of a vehicle impact. The test speed is 26 km/h side impact with linear intrusion. B.4.1 Test bench The proposed side impact test procedure originally used the Reg.44 test bench and cushions mounted 90o on the test rig (Figure 45). The child restraint was attached to sliding ISOFix anchorages, which are able to move laterally away from the intruding door during an impact. The coefficient of friction of these anchorages has yet to be defined. Figure 45: Original side impact test rig (CRS-14-4) The bench design was revised to use the widened NPACS bench dimensions and cushions that have been proposed for the front and rear impact tests (see Figure 46 and Figure 47). For the side impact tests, a small modification to the backrest cushion; a 50 mm cut-out has been made to allow the ISOFIX anchorages to slide without interference. Currently the distance that the ISOFix anchorages can slide and the friction coefficient, has yet to be defined in the draft Regulation. The DOREL sled design allowed the anchorages to slide 195 mm, which was mimicked, to allow comparison, by the TRL test sled. On both test sleds the ISOFix anchorages were fixed together, so that the anchorages displaced an equal amount. This means the test bench design and cushion properties are harmonised as far as is possible for the three test configurations in the proposed new regulation. The 50mm cutout will need to be replaced in the cushion when testing CRS attached by only the seat TRL 79 CPR821 Client Project Report belt to prevent the restraint interacting with the cushion gap, which would not exist in a vehicle. Figure 46: Side impact test rig Measurements ±2mm Angles ±0.5o 50 50 Figure 47: Test cushion dimensions B.4.2 Door The dimensions of the door panel are shown in Figure 48. The door is made from a rigid material and mounted off-board the sled. The face of the door is covered by 35 mm of rubber foam (Polychloropren CR4271), on top of which a 20 mm Styrodur C2500 sheet is attached. The Styrodur sheet should be replaced after each side impact test. TRL 80 CPR821 Client Project Report 20 mm Figure 48: Door specification B.4.3 Test devices B.4.3.1 Deceleration test device Figure 49 shows the sled velocity corridor proposed for deceleration sleds in the new regulation. It is recognised that this corridor is representative of the vehicle chassis velocity of the struck vehicle in a side impact test and does not represent the velocity of the intruding door in the struck vehicle. The implications of this are discussed further in Section C.6.4. A valid calibration run must be conducted before each set of testing, which must meet the corridor and the defined stopping distance (300mm). The relative velocity between the door panel and the test bench must not be affected by contact with the CRS. The requirements for deceleration devices are listed in B.4.3. Table 21 shows the coordinates of the upper and lower corridors of the side impact velocity corridor. TRL 81 CPR821 Client Project Report Figure 49: Side impact velocity corridor Table 21: Side impact velocity corridor coordinates Time (ms) Velocity lower Velocity upper corridor corridor (km/h) (km/h) 0 15 25.20 23.40 27.00 18 - 25.56 65 - 70 0.00 - 80 - - 2.16 0.00 In addition to meeting the velocity pulse above, for deceleration sleds the criteria in Table 22 must achieved. The sled must weigh in excess of 380 kg (the TRL sled weighed over 1000 kg to minimise any potential inertia effects of different CRSs) and remain horizontal throughout the test. It should be noted that there is no tolerance on the stopping distance and that for the purposes of calibration tests at TRL a stopping distance of 295-300 mm was used. TRL 82 CPR821 Client Project Report Table 22: Side impact deceleration sled requirements Test Restraint type Speed (km/h) T0 Intrusion (mm) Stopping distance (mm) Side Impact All 26 +/-1 -50 300* *No tolerance has been set, therefore for the calibration run, 295-300mm was accepted B.4.3.2 Acceleration test device At present no acceleration device specifications have been created for the side impact test. The question whether it is even possible to recreate this test on an acceleration device needs to be investigated. B.4.4 Intrusion The original, Dorel, proposal for the door intrusion is shown in Figure 50. This shows that originally it was proposed that at T0 the door should have already travelled 50 mm over the cushion (350 mm from the bench centre). The door should then be allowed to travel up to 300 mm further, therefore achieving 350 mm intrusion from T0. Figure 50: Original intrusion specifications However as discussion in the GRSP Informal Group progressed, it was proposed that the door should only intrude 250 mm. This was because evidence from whole vehicle crash tests presented in the ISO TC22/SC12 document ISO/PDPAS 13396 (2009), showed that 250 mm was a more realistic intrusion depth for the severity of accident being represented in the test. Figure 51 shows the intrusion depth measured from cars representing different sizes and different manufacturing dates in the UNECE side impact type approval test (R95) (ISO TC22/SC12, 2009). The R95 test involves impacting the test vehicle with a Mobile Deformable Barrier at 50 km/h. The lateral intrusion was measured close to the dummy’s head. This shows the average intrusion depth of the corridor is 250mm. The implications of this are discussed further in Section C.6.4. TRL 83 CPR821 Client Project Report Figure 51: Intrusion depth measurements R95 tests (reproduced from ISO/PDPAS 13396, 2009) Figure 52 shows that at T0 the door is 50mm off board of the bench, and then can travel 300mm, resulting in 250mm intrusion. These conditions were used for the testing conducted by TRL. 250mm 50mm Figure 52: Intrusion specifications evaluated by TRL B.4.5 CRS installation As with front impact, the installation process for the CRS and the dummy has mainly been taken from Reg.44. This needs clearer definition with tolerances on the requirements. In addition to the set-up requirements mentioned in B.2.4 the proposed TRL 84 CPR821 Client Project Report new regulation incorporates some additional requirements that are specific to the installation of the dummy for side impact testing. The proposal requires the following parameters to be controlled: • Alignment of dummy centre line with CRS centre line and CRS centre line with the centreline of the bench • Pre impact stability of the dummy • Arm position relative to the torso The CRS and dummy must be kept stable until t0 and this is to be checked by markers on the dummy, CRS and sled. Any means used to stabilise the dummy before t0 must not influence the dummy kinematics after t0. However this still does not clarify some of the specific positioning aspects of the dummy, although the limb joints, neck and head of the Q-series dummy are "fixed" and are not as variable as the P-series. However this means that if it is necessary to change the position of the dummy, during installation, it can be difficult. As previously mentioned, the arms of some of the dummies are not long enough to rest on the legs when the upper arm is in line with the sternum. B.4.6 Assessment criteria The side impact criteria to be assessed in the new regulation are yet to be defined. The proposal is currently for the main injury assessment criterion to be based on head containment. The proposal is specified such that during the loading phase of the lateral impact (up to [80] ms) the side protection must always be positioned at the level of the centre of gravity of the dummy’s head, perpendicular to the direction of the door intrusion. The containment is to be assessed by a video analysis. One proposal is for assessment by the use of front-on and overhead cameras. This includes judgement of head containment, based on: • • • No head contact with the door panel. Head must not exceed a line on the top of the door (top camera view). Head must not exceed the side wing of the CRS or (options to be selected during evaluation phase) marker on dummies head (side camera view) must not show a complete black circle (from a TUB sticker design). A figure is to be developed to describe the sticker and these head containment criteria. This TUB procedure for assessing the head containment is not yet clearly defined. Therefore the method currently published for NPACS for assessing head containment from the overhead and off-board side video recordings of the tests was used for this project. For the larger dummies (Q3, Q6) a third camera mounted behind the door was also used to assess dummy head containment. 20 mm targets were placed on the side of the dummies’ head, at the centre of gravity, to aid in this assessment. During the dynamic tests, no part of the child restraint system actually helping to keep the child in position shall break (this is, in practise, subjective), and no buckles or locking system or displacement system shall release. It is permissible for parts of the seat to deform provided that, in doing so, it does not directly affect the ability of the seat to protect the occupant (this will also be a subjective assessment). Additional Injury assessment criteria The assessment is to take into account energy absorbtion. HIC36, or resultant head acceleration (3ms) is to be considered. The criteria for front and rear impact are based on HIC15 values. So there should be consistency here and HIC15 should be used. These values are to be established after an evaluation program. It was therefore decided that TRL 85 CPR821 Client Project Report for the purposes of this evaluation the same dummy measurements assessed in front impact would be analysed in side impact. The exception is the dummy neck moment, where Mx positive and negative would be analysed. The full list of assessed dummy criteria for this project was therefore: • HIC15 • Head Acceleration Cumulative 3ms • Upper Neck Tension Force Fz • Upper Neck Moment Mx • Lower Neck Tension Force Fz • Lower Neck Moment Mx • Thorax Acceleration Cumulative 3ms • Thorax Chest Deflection Dy • Pelvis Acceleration Cumulative 3ms • Lower Lumbar Load Cell Force The performance limits for these criteria proposed by the Informal Group are detailed in Section B.5.3. Although it should be noted that lower neck forces and moments, pelvis acceleration, and lower lumbar forces and moments do not yet have proposed performance limits. TRL 86 CPR821 Client Project Report B.5 Dummies and performance requirements B.5.1 Dummy design FTSS (CRS-03-14) presented the Q-series dummies, the history of their development, and the instrumentation available. The list of instrumentation available for the Qdummies is shown in Figure 53 and Table 23. The mass of the dummies is shown in Figure 54. Figure 53: Q-series instrumentation TRL 87 CPR821 Client Project Report Table 23: Q-series instrumentation Location Description Linear accelerations 3-axis accelerometer Ax, Ay, Az Angular accelerations 3-axis accelerometer Wx, Wy, Wz Forces 6-axis upper neck load cell Fx, Fy, Fz Head Upper neck Moments Lower neck Forces 6-axis lower neck load cell Moments Thoracic spine Mx, My, Mz Fx, Fy, Fz Mx, My, Mz Linear accelerations 3-axis accelerometer Ax, Ay, Az Deflections IR-Tracc or stringpot Dx or Dy Linear accelerations 3-axis accelerometer Ax and/or Ay 6-axis lumbar load cell Fx, Fy, Fz Thorax 'ribcage' Lower lumbar spine Pelvis Forces Moments Linear accelerations 3-axis accelerometer Mx, My, Mz Ax, Ay, Az Figure 54: Q-series dummies TRL 88 CPR821 Client Project Report For the dummy measurements to be valid, the dummy must interact with a restraint system in a realistic way in order to display humanlike motion. This can only be achieved if all parts of the dummy are biofidelic, because the behaviour of one body part can influence another. For example, the motion of the head is influenced by the stiffness of the neck and the torso. TRL compared the Q3 dummy measurements in quasi-static tests with targets proposed in the literature (Visvikis et al., 2007). This revealed that the Q3 did not meet all of its performance targets. The greatest deviations were found in the chest and the shoulder. The chest was too stiff in both the front and side impact directions, while the shoulder was too stiff to meet the side impact target. This needs to be taken into consideration when using criteria limits that have been set by using scaled adult injury information. If these dummies prove to be the best current ATDs available, a more pragmatic approach to assessment criteria and the associated limits may need to be taken, based on the performance of CRSs with a known history in the field. B.5.2 EEVC Q-dummy injury criteria and performance criteria EEVC Working Groups 12 and 18 produced a report detailing the development of the Qseries dummies and associated criteria for use in frontal impact (Wismans et al., 2008). FTSS presented the results of this report and their subsequent, further analysis of the data, to the GRSP Informal Group. The original report describes the design and evaluation of the Q-series child dummies. These dummies were developed to replace the P-dummies in the UNECE Regulation and the report provides background on the research and development efforts that resulted in the new Q dummy and its injury assessment reference values. EEVC WG18 reviewed European accident statistics. The study discussed the body areas that needed to be protected for different ages of child, and hence where this new generation of child dummies should have injury assessment capabilities. The EEVC report goes on to describe the research from the CREST and CHILD projects, based on accident reconstructions, that resulted in dummy age/size specific injury assessment reference values (IARVs). The use of the term IARV in the EEVC report differs from that used by ISO: in the EEVC report this simply means a threshold value for a given risk of injury, which could be 50% risk or any other defined value, whereas ISO usually use IARV to mean ‘a human response level below which a specified significant injury is considered unlikely to occur’, i.e. a lower bound for injury thresholds (Mertz, 1993). The IARVs were developed by EEVC WG12/18 using data from 40 validated reconstructions of real world accidents, which were conducted during the CREST and CHILD EC projects. The reconstructions were performed using the Q0, Q1, Q3 and Q6 dummies, as well as the P1.5 dummy, in frontal impacts. The injuries observed in the accident cases were compared with the measurements from the dummies in the reconstructions. All the data were scaled to the Q3 dummy size/age, injury risk functions were calculated, and the resulting performance requirements scaled to the other sizes/ages of dummy. The work resulted in two sets of IARVs, one based on 20% risk of AIS3+ injury (Table 24) and one based on 50% risk of AIS3+ injury (Table 25). WG12/18 also scaled the UNECE R94 front impact, adult 50th percentile performance requirements to the Q-series dummies (Table 26). Note that the HIC derived from the accident reconstruction data is HIC15 and that from R94 is HIC36, so the two are not directly comparable. TRL 89 CPR821 Client Project Report Table 24: Q dummy performance criteria for 20% risk of AIS3+ injury (calculated using logistic regression) Criteria Q0 Q1 Q1.5 Q3 Q6 Head injury criterion HIC15 523 491 578 780 1083 Head acceleration (3 ms exceedence) Ah (g) 85 72 76 81 89 Upper neck tension force1 Fz (N) 498 1095 1244 1555 2101 Upper neck flexion moment1 My (Nm) 17 53 61 79 118 Chest compression Dx (mm) N/A 40 38 36 33 1 Upper neck tension force (Fz) and flexion moment (My) values come from literature scaling and are not specifically associated with the logistic regression results Table 25: Q dummy performance criteria for 50% risk of AIS3+ injury (calculated using logistic regression) Criteria Q0 Q1 Q1.5 Q3 Q6 Head injury criterion HIC15 671 629 741 1000 1389 Head acceleration (3 ms exceedence) Ah (g) 104 88 93 99 109 Upper neck tension force1 Fz (N) 546 1201 1364 1705 2304 Upper neck flexion moment1 My (Nm) 20 64 74 96 143 Chest compression Dx (mm) N/A 59 56 53 49 1 Upper neck tension force (Fz) and flexion moment (My) values come from literature scaling and are not specifically associated with the logistic regression results 2 Chest compressions larger than 55 mm are considered unrealistic from human point of view and physically impossible to measure with the Q-dummies Table 26: Q dummy performance criteria scaled from UNECE R94 adult performance criteria Criteria Q0 Q1 Q1.5 Q3 Q6 Head injury criterion HIC36 477 447 526 710 986 Head acceleration (3 ms exceedence) Ah (g) 79 67 70 75 82 Upper neck tension force Fz (N) 433 951 1080 1350 1824 Upper neck flexion moment My (Nm) 13 42 48 63 94 Chest compression Dx (mm) N/A 52 49 47 42 TRL 90 CPR821 Client Project Report EEVC WG12/18 then undertook a study to quantify the effect of the introduction of the Q-dummies and the above potential new criteria in UNECE Regulation 44 through an assessment program with more than 320 Reg.44 front impact tests (including P- and Qseries tests). This involved assessing the proportion of each CRS group that would fail each of the potential performance criteria, and these results were summarised by FTSS in a document submitted to the UNECE GRSP Informal Group on child restraints (CRS03-14). The Reg.44 tests that were conducted with the Q-series dummies on 30 different CRS models as shown below: • 34 tests on 6 Group 0+ child restraints • 62 tests on 12 Group I child restraints • 25 tests on 6 Group I/II/III child restraints tested as Group I • 37 tests on 9 Group I/II/III child restraints tested as Group II When the calculated injury values were applied to the test results the results showed that the majority of Group 0+ restraints met the proposed performance criteria, but the majority of the Group I and Group II child restraints failed the criteria (Table 27 and Table 28). Table 27: AIS3+ 20% Group Passed Failed (%) Group 0+ 5 (83%) 1 Group I 2 (17%) 10 Group I (I/II/III) 0 (0%) 6 Group II (I/II/III) 0 (0%) 9 Table 28: AIS3+ 50% Group Passed Failed (%) Group 0+ 5 (83%) 1 Group I 4 (33%) 12 Group I (I/II/III) 2 (33%) 4 Group II (I/II/III) 3 (33%) 6 On the basis of this feasibility evaluation, the EEVC recommended the use of the set of performance criteria based on the 50% injury risk level (Table 25), but noted that these limits would be likely to be very challenging for Group I and Group II (and probably Group III) CRSs. TRL 91 CPR821 Client Project Report B.5.3 GRSP informal group discussion on performance criteria Subsequent to the EEVC report, the GRSP Informal Group have given further consideration to the need for the different measurements that are possible with the Qseries dummies, and to the performance criteria that should be used in assessing whether a CRS has been designed in such a way as to mitigate injury to a child. The current draft of the new regulation includes the proposed performance criteria shown in Table 29. It should be noted that the upper neck tension force and flexion moment are in square brackets, indicating that these performance criteria are still under discussion. Table 29: Proposed dummy performance criteria Risk AIS3+ Criterion Abbrev. Unit Q0 Q1 Q1.5 Q3 Q6 Q10 Head Injury Criterion* HIC15 - 523671 491629 578741 7801000 1083 1389 ? 20%50% Head Resultant Acceleration 3ms A head 3ms g 85 72 76 81 89 ? 20% Upper Neck Tension Force Fz N [546 1201 1364 1705 2304 ? 50%] Upper Neck Flexion Moment My Nm [17 53 61 79 118 ? 20%] Thorax Chest Compression D Chest mm N/A 40 38 36 33 ? 20% Chest Acceleration 3ms A chest 3ms g 55 55 55 55 55 ? Reg.44 values *Only assessed if hard contact occurs during in-vehicle testing and in side impact (side impact limits not decided) Head acceleration 3 ms exceedence: Fewer than 10% of the CRSs tested in the EEVC programme failed these criteria, which suggests that this may be a reasonable level for future regulation. However it is well known that infants are at greater risk of head injury than older children, so it doesn’t seem reasonable to have a higher limit for the Q0. Upper neck tension force Fz and flexion moment My: CRS-12-4 notes that the proposed upper neck force criteria would fail most existing CRS, even though a high 50% risk level is recommended. By contrast, all CRSs would pass the My requirement. CRS-12-4 appears to recommend that the performance criterion for both parameters should be set to the 50% risk level. However, the current proposal retains the 20% level for My, and it is important that this is maintained. The accident review showed that there are very few neck injuries in the field with CRS that pass at the 20% level, and introducing a criterion that allowed performance to degrade from Reg.44 levels may lead to neck injuries becoming more common in the future. Furthermore, setting the Fz criterion to a level that fails 50% of current CRS seems unreasonable given the low rate of neck injuries in the field. Chest compression: The chest compression values would fail 20% of the CRS tested in the EEVC work, which does not seem to be unreasonable for a new regulation. However, there needs to be some evaluation of how this measurement and the associated injury risk function work, because the threshold for 50% risk of injury (>55 mm) were greater than that allowed for adult dummies and greater than can be measured with the Q-series dummies. In addition to this, it doesn’t seem reasonable that a 1 year old can sustain more compression than a 6 year old. Consideration should also be given to how TRL 92 CPR821 Client Project Report reliable the chest compression criterion will be for systems where the harness does not load the centre of the chest. The measured head excursions of the dummy are also assessed and must be within the following limits: The limits for forward facing child restraints are (Figure 55): • Horizontal - 550 mm (do not pass the A-B plane) • Vertical - 800 mm (do not pass the A-D plane) • Do not pass the D-Cr plane Figure 55: Forward facing child restraints – head excursion This forward facing limit allows 50mm more than that which is currently allowed for ISOFix CRSs in Reg.44, which bearing in mind that the head is the most important body region to protect for children in forward facing CRSs, seems to be a step backward for child safety. The limits for rearward facing child restraints are (Figure 56): TRL • Horizontal - 700 mm (do not pass F-G plane) • Vertical - 800 mm (do not pass D-F plane) • Do not pass the D-E plane 93 CPR821 Client Project Report D F 800 E G Cr G Dimensions in mm 700 Figure 56: Rearward facing child restraints – head excursion B.5.4 Bending moment – lateral bending No lateral bending moment limits have been proposed for use with the new regulation in side impact testing. A side airbag OOP injury technical working group was set up in the US to develop a common understanding of the risks associated with side airbag deployments and ways to minimise those risks (Lund, 2003). This working group was sponsored by the Alliance of Automobile Manufacturers, Association of International Automobile Manufacturers, Automotive Occupant Restraints Council, and Insurance Institute for Highway Safety. This group recommended that: “The lateral bending moment values were set midway between the extension and flexion values because the amount of muscle and connective tissue that resists lateral bending is greater than the amount that resists extension bending, but not greater that the amount that resists flexion, the neck’s strongest bending mode. (Lund, 2003)” Adoption of this strategy to the forward facing, side impact, CRS results would lead to the peak values measured for lateral bending passing the criterion. This may prove a useful criterion for monitoring in the future. TRL 94 CPR821 Client Project Report Appendix C Practical assessment of proposed procedures C.1 Introduction The proposals made by the GRSP informal working group for front, side and rear dynamic test methods have been presented, with initial comments, in Appendix B. This section of the programme was designed to evaluate the proposals, with a view to providing recommendations for the way forward. The practical assessment of the procedures included child restraint selection C.2. Using these CRSs, the front impact test procedures were assessed, with the addition of an alternative pulse. This assessment evaluated the relevance and limits of the dummy criteria proposed by the informal group. The performance specification for test bench foam was also considered. The rear impact tests were evaluated to gain an understanding of the relative effect of the geometry and cushion properties of the new proposed test bench on the performance of CRSs compared to those of the test bench specified in UNECE Reg.44. The implications of using the Q-series ATD criteria and limits, proposed by the informal group for dynamic assessment of CRSs in rear impact, were also assessed. Side impact tests were carried out to identify how the test procedure loads restraint systems and how this relates to accidents in the real world. The procedure was assessed for repeatability and reproducibility and the dummy criteria and limits for side impact were also evaluated. C.2 Child restraint selection The CRSs for the practical assessment programme were short-listed using a combination of market research information and knowledge about CRS performance. The seats were selected based on reported performance (good and poor) and volume sales. It was important to assess the proposed procedures by using CRSs that have had a high volume of sales and hence, have a wide history of use in the European vehicle fleet. CRS models generally have, at the very least, five years in the market before they are discontinued as a product. By including these products it provides a certain level of confidence that if the products are likely to cause injury to children in the way they provide restraint under crash conditions, the accident studies will reflect this. If the practical assessments show high dummy readings compared to the limits set for the dummy criteria when testing with these products, in a body area that is not considered a priority for protection, then it suggests that there is an issue with the specification rather than an issue for child protection and the CRS. For example, the limit proposed for the criteria may not be set at the correct level, or there may be an issue with the dummy design for the body region in question, or there may be an issue with the testing conditions of the assessment procedure. The reported, dynamic performance of child restraint systems (taken from various consumer testing schemes) was also considered during the selection process, to provide a reasonably representative range of CRS performance across the limited number of products in available within the scope of the programme. The first phase of the work for the new Regulation is focussed on integral ISOFix restraint systems, however the new Regulation will, in the longer term, need to work for all child restraint types and these include adult belt attached systems and adult belt restrained occupants. Belt attached systems may have an impact on test set-up that is not observed for ISOFix systems and it is for this reason that we have included nonintegral systems and an adult belt attached restraint system in our selection. The short-list for the selection of CRSs are detailed in Table 30 to Table 32. TRL 95 CPR821 Client Project Report Table 30: Rearward facing integral CRSs (Group 0+) short-list ISOFix In order of lowest reported performance In order of highest reported performance In order of highest volume sales 1 IWH (Stella), Babymax 2 Emmajunga, First Class 1 2 1 2 3 Britax, Babysafe Recaro, Young Maxi-Cosi, Profi Cabriofix Maxi-Cosi, Cabriofix M&P, Primo Viaggo Britax, Babysafe 1 Belt Petite Star Aluminium Handle 1 Graco, Logico S I'coo C-Care Jane Strata 2 Fisher Price, Safe voyage 3 1 2 3 4 Britax, Babysafe Beltbase Maxi-Cosi, Cabriofix Bebe Confort, Creatis Meggy, Babystart Silver Cross, Ventura Table 31: Forward facing integral CRSs (Group I) short list In order of lowest reported performance In order of highest reported performance In order of highest volume sales 1 2 ISOFix Nania, Cosmo Recaro, Young Expert 1 Maxi-Cosi, Priorifix 2 1 2 3 4 Britax, Duo 1 2 3 4 1 Belt M&P, Protec Chicco, Key 1 Bebe Confort, Axis Britax, Duo Maxi-Cosi, Tobi Britax, King Britax, Safefix Bebe Confort, Iseos Maxi-Cosi, Priorifix Britax, Duo Britax, Safefix 1 2 3 Maxi-Cosi, Priori XP Bebe Confort, Axiss Chicco, Key 1 Table 32: Forward facing non-integral CRSs (Group II/III) short list In order of lowest reported performance In order of highest reported performance In order of highest volume sales 1 ISOFix Jane, Monte Carlo 1 Belt Alpine, Daisy 2 Jane, Indy Plus 3 Sunshine Kids, Monterey 1 Cybex, Solution X-fix 1 Cybex, Solution X 2 Britax, Kidfix 2 Kiddy, Discovery Pro 1 Britax, Kidfix 1 2 3 4 Graco, Junior Maxi Graco, Logico L Nania, Befix Nania, Dreamfix The product selection, based on performance was made first. The volume sales information was then used to ensure the selection included products that had a history in the field. When selecting products based on sales, if the product had already been selected on a performance basis, the next highest volume seller was selected. Table 33 shows the CRSs selected for the practical assessment of the procedures. TRL 96 CPR821 Client Project Report Table 33: CRSs selected to assess protocols Short name Infant 1 (Low Rating) Infant 2 (High Rating) Infant 3 (High Sales 1) Infant 4 (High Sales 2) Infant 5 (High Sales 3) Safety 1 (Low Rating) Safety 2 (High Rating) Safety 3 (High Sales 1) Safety 4 (High Sales 2) Booster 1 (Low Rating) Booster 2 (High Rating) Booster 3 (High Sales 1) Booster 4 (High Sales 2) Product IWF (Stella), Babymax Britax, Babysafe Maxi-Cosi, Cabriofix M&P, Primo Viaggo Maxi-Cosi, Cabriofix Nania, Cosmo Maxi-Cosi, Priorifix Bebe Confort, Iseos Britax, Duo Jane Monte, Carlo Cybex, Solution X-fix Britax, Kidfix Sunshine Kids, Monterey Attachment method ISOFix Base with Support Leg ISOFix Base with Support Leg ISOFix Base with Support Leg ISOFix Base with Support Leg Belt ISOFix & Top Tether ISOFix & Support Leg ISOFix & Top Tether ISOFix & Top Tether Belt & ISOFix Belt & ISOFix Belt & ISOFix Belt & ISOFix C.3 Test Bench The test bench used in the practical assessment was that proposed by the Informal Group (based on the NPACS research) and specified in Section B.1. The type of foam that is required for the test bench is currently specified as a particular parts number, available from FTSS (T75500), but there is no performance specification for the foam so the performance of different batches of foam may differ. It is not known how much this may affect the reproducibility of the test procedure, but it is certainly not good practice to leave this aspect of the test bench performance uncontrolled. Furthermore, it would be useful to have a performance specification to allow the possibility of sourcing the foam from a wider number of suppliers. The performance specification for test bench foam was considered within this project. This section outlines the extent of the TRL assessment, which is expected to contribute to a wider set of results within the GRSP Informal Group. The UNECE Reg.44 test bench calibration rig was used for these tests (section 8.3 of Reg.44) • • Calibration set-up as defined in section 8.3 of Reg.44 o 2.75 kg ball impactor (see annex 17) o Drop height 500 mm o Three impact locations as defined in 8.3.2 of Reg.44 o Bench laid down horizontally at 0° Two different configurations of the bench foam o Foam only, without cloth o Cloth installed according to Reg.44 (glued to the back plate) Figure 57 shows the results of the tests with the uncovered foam and Figure 58 shows the results of tests with the covered foam. For each set of results, the mean of the six impact responses is shown in red. A target corridor is also shown in black. This was calculated by finding the maximum value of the standard deviation throughout the impact event (max SD), and plotting the mean ± max SD. It can be seen that both graphs have spikes in some of the impact responses: these are thought to be due to loose electrical connections, not due to any important characteristic of the foam or impactor, and have been removed from the mean and maximum standard deviation for the purpose of defining this target performance corridor. TRL 97 CPR821 Client Project Report Ignoring the spikes, it can be seen that two out of the six uncovered foam response curves (Figure 57) lie fractionally outside the target response corridor. However, it appears that all the curves may lie within the corridor if more aggressive filtering was used. These data were filtered using CFC 1000, although it is recommended that the data are filtered with CFC 60. 30 Set 1 Foam - Mid 28 Set 1 Foam - Left 26 Set 1 Foam - Right 24 Set 2 Foam - Left 22 Set 2 Foam - Right Set 2 Foam - Mid Set 1-2 Foam: Mean Deceleration (g) 20 Set 1-2 Foam: Mean + Max SD Set 1-2 Foam: Mean - Max SD 18 16 14 12 10 8 6 4 2 0 0 0.01 0.02 0.03 0.04 0.05 0.06 Time (s) Figure 57: Seat foam impact responses for two sets of uncovered foam It can also be seen that two out of the six covered foam impact responses lie outside the target response corridor, and that these are unlikely to be affected by the filtering regime used. However, the graphs show that they are likely to be affected by the tension of the covering fabric. Any drop test procedure, defined to assess and certify the test cushion characteristics, will need to specify two corridors, one for the uncovered foam and one for the covered foam. TRL 98 CPR821 Client Project Report Deceleration (g) 30 Set 1 Covered - Mid 28 Set 1 Covered - Left 26 Set 1 Covered - Right 24 Set 2 Covered - Mid 22 Set 2 Covered - Left 20 Set 2 Covered - Right 18 Set 1-2 Covered: Mean Set 1-2 Covered: Mean + Max SD 16 Set 1-2 Covered: Mean - Max SD 14 12 10 8 6 4 2 0 0 0.01 0.02 0.03 0.04 0.05 0.06 Time (s) Figure 58: Seat foam impact responses for two sets of covered foam C.4 Assessment of front impact proposals The front impact test programme was designed to assess the front impact procedure proposed by the GRSP Informal Group (Figure 62). These tests allowed assessment of the relevance and limits of the dummy criteria proposed by the Informal Group. In addition to this, a small comparison was made with a more severe pulse. Figure 59: Front impact test sled TRL 99 CPR821 Client Project Report The test speed proposed by the Informal Group is specified as 50km/hr +0/-2. Figure 60 shows the deceleration envelope proposed by the Group. This are also the conditions currently used for type approval of CRSs in UNECE Reg.44. The test conditions for the assessment are also shown below. The black acceleration traces represent the mean of the test pulses and one standard deviation away from the mean. These are shown to demonstrate that the test conditions were repeatable. Figure 60: Proposed Deceleration Pulse Envelope, with deceleration pulses from the experimental front impact testing. C.4.1 Criteria Evaluation C.4.1.1 Rearward facing integral restraints The review of accident studies has shown that, for children injured in front impacts, the head is the priority body region to protect. The majority of head injuries are caused by contact with parts of the vehicle interior or other external objects. Chest and abdomen injuries become more significant with increasing age of the occupant, along with pelvis injuries. These were found to be predominately caused by the vehicle seat belt. The test matrix for the practical assessment of the effects of the proposed front impact procedure on rearward facing integral CRSs is shown in Table 34. The assessment used three models of CRS with three dummies. The CRS models represent seats that received low or high ratings in various consumer tests and seats that had high volume sales. TRL 100 CPR821 Client Project Report Table 34: Front Impact assessment matrix – rearward facing integral CRSs Child Restraint System Group 0+ low rating Babymax Group 0+ high rating Babysafe Group 0+ high volume Cabriofix ATD Tests Q0 1 Q1 1 Q1.5 1 Q0 1 Q1 1 Q1.5 1 Q0 1 Q1 1 Q1.5 1 The results of the assessment with the rearward facing integral CRSs are shown in Table 36. The CRSs pass all of the criteria proposed for the new regulation. The review of accident studies indicated that head protection is a high priority for children travelling in rear facing CRSs. The injury mechanism associated with these CRSs is head contact with the vehicle dashboard or the vehicle interior, so head excursion is an important factor. The range of horizontal head excursions were well inside the thresholds proposed for the dummies. Head excursion is measured from the film of the test. In Reg.44 the testing laboratories must apply procedures for estimating uncertainty of measurement (U of M) of the displacement of the manikin's head. The uncertainty has to be within ± 25 mm. Reg.44 references examples of international standards of such procedures (EA-4/02 of the European Accreditation Organization or ISO 5725:1994 or the General Uncertainty Measurement (GUM) method). However, there is no requirement beyond this to control how the visual analysis is carried out and this can lead to large differences between how the laboratories interpret the application of U of M. The confidence intervals should be specified and the method of applying these confidence intervals to the U of M needs to be clearly defined. Where possible, the head excursions were measured using the side view of the test. It is not always possible, however, to see the top of the dummy’s head from the side, so in some cases the top camera view was used. There are limitations with measuring the excursions from the top view, as the dummy is constantly changing to a different measurement plane during the test and the visual measurement, alone, is incorrect. Therefore, a correction factor has been applied to the visual measurement. The correction factor is calculated by using results from the tests where the difference between the measurement views is known, i.e. where the dummy’s head can be seen from both views. This is also an issue for type approval and the assessment method should be defined more clearly. Although there is a pass fail plane, which can be physically represented, in the assessment for type approval, the actual measured excursions must be known in order to carry out Product Qualification testing (section 9 of the proposed regulation) and for Conformity of Production testing (Annexe 13 of the proposed Regulation). The accident review suggests, head excursion is an issue for child protection, therefore the performance thresholds for the testing may need to be changed, to encourage less forward movement of these products in the field. The range for the CRSs with the Q0 was 49-56 % of the threshold; the Q1 was 53-69 % of the threshold and the Q1.5 was in the range of 65-69% of the threshold, so there is scope for reducing the threshold for TRL 101 CPR821 Client Project Report horizontal head excursion. The limit currently proposed is 700mm and the maximum forward excursion across these tests was less than 500mm. These results did not include any testing with large rear facing CRSs and one could argue that a larger CRS with a larger dummy would need more space. However, the space allowed for excursion should be based on the space available in the vehicle, which is variable, and not based on dummy size. A limit of 500mm is used in UNECE Reg.44 for universal forward facing ISOFix CRSs. This was justified, at the time of drafting, by some UK accident reports of children (in forward facing CRSs), who had received head injuries in accidents through contact with the seat in front, where the space for forward excursion in the vehicle was judged to be less than 550mm from the “Cr” line. The value for head excursion should be reviewed and based on the excursion space available to children in modern vehicles, taking into account realistic vehicle front seat positions. One may counter argue that by reducing the head excursion, the head accelerations would increase and this indeed likely to happen, however the head accelerations measured in this assessment were well below the threshold for injury, so there is the potential to achieve a better balance between these two criteria. The values for the linear head acceleration thresholds have been taken directly from the work of the EEVC Working Groups 12 & 18 (Wismans et al., 2008). In particular, the Q3 threshold was derived from the accident reconstructions undertaken by those groups. The value proposed for use as a performance criterion relates to the 20% risk of sustaining an AIS 3+ head injury. This value was then scaled to the other dummy sizes using the relationship shown below. Where: •• is the ratio of head acceleration (at the centre of gravity of the head), ••t is the ratio of head failure stresses (approximated to the failure stress of the calcaneal tendon), and •x is the ratio of head lengths The values of these ratios for the different Q-dummies are shown in (cross ref to table below). They are also graphically illustrated in (cross ref to figure below). Table 35: Scaling ratios used in the development of the head acceleration performance thresholds Scaling parameter Q0 Q1 Q1.5 Q3 Q6 Adult ••t 0.63 0.7 0.75 0.85 0.96 1 •x 0.63 0.84 0.86 0.91 0.93 1 •• 1.00 0.84 0.87 0.94 1.03 1 TRL 102 CPR821 Client Project Report Figure 61: Scaling ratios used in the development of the head acceleration performance thresholds The composition of the scaling formula and the progression of the ratios for failure stress and head length seem sensible. In principle, the head acceleration expected to cause injury would increase with age as, in general, human tissue becomes more resilient to stress. Also experimental observations using animal models have indicated that certain head injuries require higher levels of acceleration to inflict in subjects with smaller heads. However, the particular values used in the approximation to Q-dummies might not be ideal. This is shown by the effect of their combination for the Q0. Here the general reduction in head acceleration ratio, towards the smaller dummies, suddenly reverses and leaps to around one. Based on the values being used in the formula, this effect is understandable. However, it may not be a realistic representation of injury risk for children under the age of one. Therefore it is suggested that the head acceleration threshold criterion for the different Q-dummy ages needs to be reviewed. It may be that a different scaling approximation would provide a more progressive function; one which may be more in line with expectations surrounding injury tolerance for very young children. It should be noted that without experimental data which can confirm the tolerance of children, the discussions surrounding their tolerance can only be based on the engineering judgement of experts in the field. Some validation of this opinion remains a fundamental requirement in the application of child dummy measurements such as head acceleration. TRL 103 CPR821 Client Project Report Table 36: Front impact results table – rearward facing integral CRSs Group 0+ Child Restraint Systems Low rating Babymax High rating Babysafe High volume sales Cabriofix Low rating Babymax High rating Babysafe High volume sales Cabriofix Low rating Babymax High rating Babysafe High volume sales Cabriofix TRL ATD Head Head exc exc HIC15 H V Head res ac 3ms g Upper Neck Fz N Upper Neck My Nm Lower Neck Fz N Lower Chest Chest Neck compression res acc My 3ms Nm mm g mm mm Limits 700 800 523671 85 546 17 N/A N/A N/A 55 Q0 395 512 127 54 165 0.8 N/A N/A N/A 38 Q0 340 428 136 42 173 0.7 N/A N/A N/A 41 Q0 367 524 117 43 99 0.8 N/A N/A N/A 39 Limits 700 800 491629 72 1201 53 N/A N/A 40 55 Q1 485 658 216 49 650 9 N/A N/A 5 37 Q1 374 616 232 50 390 7 N/A N/A 3 35 Q1 432 672 222 52 189 7 N/A N/A 3 39 700 800 578741 76 1364 61 N/A N/A 38 55 Q1.5 483 579 158 42 728 11 N/A N/A 4 41 Q1.5 468 646 215 50 426 6 N/A N/A 2 31 Q1.5 458 667 216 49 350 6 N/A N/A 2 36 104 CPR821 Client Project Report C.4.1.2 Forward facing integral restraints The test matrix for the practical assessment of the effects of the proposed front impact procedure on forward facing integral CRSs is shown in Table 37. The assessment used three models of CRS with two dummies. The CRS models, again, represent seats that received low or high ratings in various consumer tests and seats that had high volume sales. Table 37: Front impact assessment matrix - forward facing integral CRSs Group I Child Restraint Systems ATD Tests Low rating Cosmo Q1 1 Q3 1 High rating Priorifix Q1 1 Q3 1 High volume Iseos Q1 1 Q3 1 The results of the assessment with the forward facing integral CRSs are shown in Table 38. The results in red show where the measured values have exceeded the thresholds for the criteria. The review of accident studies indicated that head protection is the highest priority for children travelling in forward facing integral CRSs, followed by chest protection. The injury mechanism associated with these CRSs is head contact with parts of the vehicle interior, so head excursion is the most important criteria. However in optimising a CRS to achieve low head excursions, this can result in high head and chest accelerations, so it is important to have a balance of performance across all three criteria. The horizontal head excursions for the smallest dummy (Q1) were 63%-69% of the limit and the largest dummy (Q3) excursions were 81%-88% of the limit. All head excursions were below 500mm the limit currently set for ISOFix integral restraints in Reg.44. The CRS selected as “highly rated” slightly exceeded the threshold for head acceleration (by 1%), with the Q1 dummy. The product performance ranged from 84%-101% of the limit for this criterion with the Q1 dummy. The CRS selected for high sales slightly exceeded the threshold for vertical head excursion (by 1%) with the Q3 dummy. The low rated restraint also came close to exceeding the limit excursion (99% of the limit). The product performance ranged from 97%-101% of the limit for this criterion with the Q3 dummy. This shows that the 800mm head vertical excursion limit is about right for this type of restraint. From their use in the field, the CRSs tested in this programme are considered as relatively safe with respect to the likelihood of neck injuries occurring in real world accidents. However, in all the tests with the Q1 or Q3 in integral CRSs, the dummy produced upper neck tensile forces which exceed the proposed threshold (they were on average 149% of the threshold). This limit relates to an expected 50 % risk of AIS • 3 neck injury (as scaled for the child size; EEVC, 2008). Therefore it seems to be the case that the proposed equipment, measurement tools or procedures do not lead to an accurate assessment of injury risk for this body region. TRL 105 CPR821 Client Project Report Table 38: Front impact results table – forward facing integral CRSs Group I Child Restraint Systems Head Head exc exc H V HIC15 Head res ac 3ms g Upper Neck Fz N Upper Neck My Nm Lower Neck Fz N Lower Chest Chest Neck res acc compression My 3ms Nm mm g mm mm Limits 550 800 491629 72 1201 53 N/A N/A 40 55 Low rating Cosmo Q1 344 682 366 60 1636 18 N/A N/A 20 43 High rating Priorifix Q1 348 730 327 73 1391 15 N/A N/A 17 34 High volume sales Iseos Q1 377 701 479 64 1750 22 N/A N/A 19 40 550 800 7801000 76 1364 61 N/A N/A 38 55 Q3 462 799 414 63 2540 10 1106 123 28 35 Q3 447 772 283 55 1713 9 1133 91 24 33 Q3 483 807 449 63 2485 21 1249 110 5† 34 Low rating Cosmo High rating Priorifix High volume sales Iseos † ATD Error in data channel TRL 106 CPR821 Client Project Report C.4.1.3 Forward facing non-integral restraints The test matrix for the practical assessment of the effects of the proposed front impact procedure on forward facing non-integral CRSs is shown in Table 39. The assessment used three models of CRS with two dummies. The CRS models represent seats that received low or high ratings in various consumer tests and seats that had high volume sales. Table 39: Front impact assessment matrix - forward facing non-integral CRSs Group II Restraint Systems ATD Tests Low rating Monte Carlo Q3 1 Q6 1 High rating Solution X-fix Q3 1 Q6 1 High volume Kidfix Q3 1 Q6 1 The results of the assessment of the procedures using non-integral CRSs are shown in Table 41. The results in red show where the measured values have exceeded the thresholds for the injury criteria, and results in brown are 95% or greater of the criteria limit. The review of accident studies indicated that head protection is also the highest priority for children travelling in forward facing non-integral CRSs, followed by chest protection. The injury mechanism associated with these CRSs is head contact with parts of the vehicle interior. The proposed limit for the head excursion of the dummy during testing is currently 550mm. The head excursion range in the tests with the Q3 was 65-79% of the threshold while the range with the Q6 was 76-86% of the threshold and all had an excursion of well below 500mm. The maximum head acceleration for the Q6 was 79% of the threshold for the criterion, so there is scope for reducing the threshold for horizontal head excursion, in line with the space available in the vehicle. The limits for chest compression (33mm) were exceeded in the tests with the Q6 dummy, with a range from 106-112% of the proposed threshold. In the tests with the low rated CRS and the high sales CRS the head of the dummy contacts the chest. This is when the maximum chest compression occurs in these tests. It is unclear why the smaller dummies have greater thresholds than the larger dummies. The limits for chest compression are again taken from the work of EEVC WGs 12 & 18 (Wismans et al., 2008), modified for the position of deflection measurement sensors. In this case, the scaling formula they used is as shown below. Where TRL •• is the ratio of peak sternal deflection; •y is the ratio of rib length; ••t is the ratio of calcaneal tendon failure stress; and •Eb is the ratio of bone modulus. 107 CPR821 Client Project Report The variation of the scaling factor for the Q-series dummy ages is shown in (cross reference to Table below). Table 40: Scaling factor ratio for the sternal deflection measurements Scaling ratio Q0 Q1 Q1.5 Q3 Q6 Adult •• 0.84 1.03 0.98 0.93 0.94 1 As with the head acceleration threshold scaling, each of the material property parameters varies with age in a sensible manner. It is only the output of the scaling formula which produces an unexpected progression. Here, the sternal deflection for a one-year-old is greater than for the adult. When talking about the risk of AIS 3+ thoracic injuries, it seems unlikely that a one-year-old can sustain more sternal deflection than an adult without injury. Instead, we can see that, based on the terms in the scaling equation, this scaling factor relates to the risk of rib fracture. It may be that smaller children can sustain large thoracic deformations before rib fracture occurs. However, the risk of AIS 3+ injury needs to account for visceral injuries as well as those injuries to the rib cage. It is known that younger persons can sustain visceral injuries without an associated rib fracture. Therefore, it seems that these scaling ratios are probably unsuitable for use in relation to all AIS 3+ thorax injuries caused by restraint system loading to the chest. Chest injuries are an issue with older children and the mechanism is associated with the adult belt loading the chest. More research is needed in this area to set appropriate thresholds for the criterion. In addition to the head and chest region, the abdomen is also a high priority area to protect for children using non-integral CRSs, however there is nothing on the Q dummy that measures this. The injury mechanism associated with abdominal loading is “submarining” and loading from the adult belt. The kinematics of ISOFix attached non-integral CRSs can be different to the equivalent belt attached systems. With the belt attached systems, the CRS moves forward into the adult lap and diagonal seat belt. With ISOFix attached systems, the CRS is often held firmly in place against the vehicle seat back, so that only the child moves forward into the adult belt system. With the latter event, there is likely to be more potential for poor belt interaction and the possibility of an increase in abdominal injuries. When the proposed procedures are extended to include non-integral systems this will be a key area to monitor. The proposed procedures specify that a measure of abdominal penetration should be a calculation of the forces measured in the lumbar spine and the lap belt. The suggestion is that during the frontal impact the lumbar spine resultant of Fx and Fz shall not exceed [undetermined] per cent of the lap belt force. The products assessed all achieved a ratio of less than 55% apart from the product that was selected on the basis that it was expected to perform poorly, which achieved a ratio of 94%. However, this product had the lowest lap and diagonal belt loadings and lowest chest compression. So it is unclear what this measurement is representing. In all the tests with non-integral CRSs, the lap portion of the adult belt became wedged into the gap at the top of the dummy legs (Figure 62). There are serious limitations with the ability of the Q-series dummies to assess non-integral CRSs. It is essential that the lap portion of the adult belt is able to take the path of travel over the dummy in the same way that it would with a child. In addition to this, if a dummy is capable of submarining, it should at least be detectable and ideally the extent should be TRL 108 CPR821 Client Project Report measurable. For non-integral CRSs, where abdominal injuries are a priority, the P series dummies even with their limitations may be a better option. Figure 62: Non-integral CRSs, dummy and belt interaction As stated earlier, the CRSs tested in this programme are considered as relatively safe with respect to the likelihood of neck injuries occurring in real world accidents. However, in all the tests with the Q3 in the non-integral CRSs, the dummy produced upper neck tensile forces which exceed the proposed threshold (they were on average 179% of the threshold). This limit relates to an expected 50 % risk of AIS • 3 neck injury (as scaled for the child size; EEVC, 2008). Therefore it seems to be the case that the proposed equipment, measurement tools or procedures do not lead to an accurate real world injury risk for this body region. TRL 109 CPR821 Client Project Report Table 41: Front impact results table – forward facing non-integral CRSs Group II Child Restraint Systems ATD Head Head exc exc H V HIC15 Head res ac 3ms g Upper Neck Fz N Upper Neck My Nm Lower Neck Fz N Lower Chest Chest Neck compre res acc My ssion 3ms Nm mm G Lap belt load N Lumbar Lumbar FxFz FxFz/ Res lap N mm mm Limits 550 800 7801000 76 1364 61 N/A N/A 38 55 N/A N/A N/A Low rating Monte Carlo Q3 360 690 602 71 2375 15 919 98 31 42 1210 670 55% High rating Solution X-fix Q3 434 748 378 61 2174 19 1104 110 32 36 1740 770 44% High volume sales Kidfix Q3 361 621 562 72 2768 12 737 111 34 44 1810 770 43% 550 800 10831389 89 2304 118 N/A N/A 33 55 N/A N/A N/A Q6 443 753 506 70 2128 55 1480 171 data clipped 35 45 1650 1550 94% Q6 475 793 289 54 1487 38 1418 134 35 37 2740 1280 47% Q6 418 784 356 60 2090 44 1308 161 37 40 3230 1410 44% Low rating Monte Carlo High rating Solution X-fix High volume sales Kidfix TRL 110 CPR821 Client Project Report The peak tensile forces measured at the lower neck are lower than those measured at the upper neck. Therefore, if one was to assume a consistent injury threshold for tensile force at the upper and lower neck, then the lower neck measurements would not provide any additional information, when considering peak values. Research, carried out by Luck et al. (2008) studied eighteen PMHS osteoligamentous (bone and ligament, but not muscle) head-neck complexes, ranging in age from 20 weeks gestational to 14 years, which were tested in tension. The spines were cut into three segments (C4-C5, C6-C7, and OC-C2). The results of the destructive part of the tensile testing provided information to show that, for the older (> five months postnatal) cohort, the upper cervical spine was significantly stronger then the lower cervical spine. This may support the implementation of a lower neck tensile force threshold which is lower than the threshold at the upper neck. However, it is expected (based on FE modelling; van Ee et al., 2000) that in adults, at least, the neck musculature adds greater force tolerance to the lower neck than the upper neck. Based on their modelling work, van Ee et al. suggested that consideration of the cervical musculature would shift the predicted site of injury (under tensile loading) from the lower to the upper cervical spine. However, the effect of musculature on neck strength may be much less in the necks of children. This research, on the tolerance of human necks, should be taken into account when proposing a tolerance criterion for the lower neck. Based on the results from the frontal impact tests, it is evident that all of the CRSs pass the flexion bending moment limits assessed at the upper neck, as proposed for use with the new regulation. This is encouraging as neck injuries are not observed frequently in the real world accident data. Therefore, these test results seem to support the notion that current CRS designs are reasonably safe in terms of neck injury protection. The upper neck extension moments are of a similar magnitude though no limit has been set for these values. The work of Mertz et al. in developing Injury Assessment Reference Values (IARVs) suggested that the tolerance to extension moments was just over half of the flexion values. The extension value was based on the maximum moment tolerated in sled tests with a volunteer (Mertz and Patrick, 1971). Adopting an upper neck extension moment limit that was half of the flexion limit would result in failures for some of the current CRSs tested with a Q1 dummy. It is suggested that the sense of the flexion to extension relationship for use with dummies representing small children requires further investigation before it could be adopted. Currently the lower neck does not have bending moment criterion in the new regulation. The measured lower neck bending moment peak values are significantly higher than the upper neck. This difference means if the criteria limits for the upper neck were applied, these limits would be exceeded. Instead of directly transferring the upper neck limit to the lower neck, Mertz et al. (2003) proposed multiplying the upper neck threshold by a factor of two to generate bending moment IARVs for the lower neck. If this approach was applied to the results generated here, then a lower neck limit twice that of the upper neck would allow all of the CRS to pass the criterion. However, the biomechanical basis for adopting such an approach is limited. The Mertz et al. suggestion was based on the recommendation from Prasad et al. (1997) that the lower neck extension moment threshold for ligamentous damage to a mid-size male adult would be in the range between 154 and 186 Nm. The ratio between the lower value of this range and the corresponding Out-of-Position (OOP) peak extension moment in use as an IARV for the Occipital Condyle (OC) / first cervical vertebra (C1) junction (154 divided by 78) was approximately two. It should be noted that the Prasad et al. range came from a very limited number of tests, with only two PMHS (Post-Mortem Human Subjects) and one volunteer (Mertz and Patrick, 1967). TRL 111 CPR821 Client Project Report C.4.2 Assessment of proposed protocols using an alternative pulse As part of the front impact assessment, a small comparison was made with a more severe pulse. The test speed proposed by the Informal Group, 50km/hr +0/-2, is representative of the speed limit where most children have their injuries (see Section A.4.1) on the roads. However, the pulse proposed (UNECE Reg.44), was developed in the 1970s and may not be representative of the current vehicle fleet. The information brought to the GRSP Informal Group showed full scale testing at higher speeds or with an offset (see Section B.2.2). The NHTSA website contains information on full scale tests at 50 km/hr with a full width barrier, which is representative of the type of conditions that are needed to assess CRSs. The crash data from these tests; for small family cars, family cars, superminis, executive cars and sports cars, sold in Europe, was used to investigate the shape of a pulse that would be more representative of the current vehicle fleet. A mean was calculated from these pulses along with plus and minus 2g from the mean. This information was used to create a new pulse corridor, which was higher than the pulse proposed by the Informal Group (Figure 63). The coordinates of the higher severity pulse are shown in Table 42. -50 S.Family -46 Family Supermini -42 Sports -38 Exec Av. -34 -2g -30 g / n io ta -26 r e l e cc -22 A +2g Bottom Corridor Top Corridor -18 -14 -10 -6 -2 0 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09 0.1 0.11 0.12 Time / s Figure 63: NHTSA vehicle accelerations, 50km/hr, 100% overlap barrier test Vehicles are much stiffer than they were when Reg.44 was being developed, so it is not surprising that this pulse is higher in peak g than the Reg.44 pulse. Comparison with the Reg.44 corridor shows that the new pulse has a peak of 25g-32g whereas the Reg.44 pulse has a peak 20-28g. The duration of the corridor is also shorter for the new pulse with the deceleration ending between 85-100ms compared to 100-120ms for the Reg.44 pulse. TRL 112 CPR821 Client Project Report Table 42: Front impact alternative pulse coordinates Time (ms) Acceleration Acceleration lower corridor upper corridor (g) (g) 0 5 0 7.5 - 45 25 32 60 25 32 85 0 - 100 - 0 Using this alternative pulse a small programme of tests were conducted to allow comparison with the front impact results from the testing using the proposed pulse. Figure 64 shows the acceleration traces for the tests that were carried out using the higher pulse. For comparison, the acceleration traces for the earlier testing and the proposed pulse are shown in the background, in grey. Figure 64: Testing conditions using the higher pulse The low rating restraints that had passed the injury criteria at the proposed pulse were chosen to be used for this testing. The exception was the non-integral restraint, where the low rating was not chosen as it had experience structural failures during testing at the proposed pulse. It was assumed that this failure would occur at the higher pulse and possibly invalidate any comparison of the results. Therefore the high sales restraint was TRL 113 CPR821 Client Project Report chosen, as this was shown to be the next poorest performer from the front impact tests. The assessment matrix for this testing is shown in Table 43. Table 43: Assessment Matrix to assess the effects of an alternative pulse Child Restraint System Pulse ATD Tests Group 0+ low rating Babymax Alternative pulse Q1 1 Q1.5 1 Group I low rating Cosmo Alternative pulse Q1 1 Q3 1 Group II low rating Kidfix Alternative pulse Q3 1 Q6 1 Table 66 shows that the higher pulse has a steeper rise for a longer time and a flatter area around the peak compared to the proposed pulse. The figure also shows that although the peak g sled pulse was fairly consistent (26.5g), two of the tests dropped below the lower corridor at around 65ms. The stopping distances for these tests are shown in Table 44. This shows that the stopping distance was an average of 117mm shorter than in the tests with the proposed pulse, which corresponds to the decrease in time duration of the pulse corridors. Table 44: Stopping distance comparison Stopping Child Restraint System ATD Group 0+ low rating Q1 Q1.5 527 520 Cosmo Q1 Q3 Group II high sales Q3 525 Kidfix Q6 525 Mean 524 Mean 641 Babymax Group I low rating Reg.44 pulse Distance (mm) 534 510 C.4.2.1 Rearward facing integral restraints The results of the assessment with the rearward facing integral CRSs at the higher pulse are shown in Table 45. The results in red show where the measured values have exceeded the thresholds for the injury criteria, and results in brown are those close to exceeding the criteria limit (95% of the limit). The results show that with the exception of neck moments and chest compression, both of which are well below the criteria limit, the other injury criteria have all significantly increased in comparison to the tests using the proposed pulse. As previously mentioned the main body region to protect for rearward facing restraints is the head. This means head accelerations and excursions should be kept to a minimum. The Q1 dummy head resultant acceleration is now very close to the criteria limit (97% of the limit). The horizontal excursion of the dummy’s head has increased by 12%, but is TRL 114 CPR821 Client Project Report still well below the limit (78% of the limit). The dummy exceeds the injury criteria limit for both the upper neck force (128%) and chest resultant acceleration (105%). The injury criteria results for the important body regions to protect did increase for the test with the larger dummy. The Q1.5 dummy head resultant acceleration increased by 19%, to 66% of the limit. The horizontal head excursion increased by 16%, to 80% of the limit. The Q1.5 chest resultant acceleration also increased by 22%, to 91% of the limit. These results show that the increase in pulse severity has had a significant effect on the important body regions to protect for both the tested dummies. The horizontal head excursions have increased to exceed the forward facing limit (550mm) with the larger dummy. However the effect on the smallest occupant for this type of restraint (Q0) should also be evaluated prior to the changing of any limits if this more severe pulse was to be adopted. TRL 115 CPR821 Client Project Report Table 45: Higher pulse tests – Rearward facing integral CRSs Child Restraint System Pulse ATD Proposed limits Head Head HIC15 exc H exc V mm mm 700 800 Head Upper Lower Chest Upper Lower Chest res ac Neck Neck res acc Neck Fz Neck Fz compression 3ms My My 3ms g N Nm N Nm mm g 491629 72 1201 53 N/A N/A 40 55 Group 0+ low rating Proposed Babymax Q1 485 658 216 49 650 9 N/A N/A 5 37 Group 0+ low rating Alternative Babymax pulse Q1 544 665 502 70 1542 15 N/A N/A 6 58 700 800 578741 76 1364 61 N/A N/A 38 55 Proposed limits Group 0+ low rating Proposed Babymax Q1.5 483 579 158 42 728 11 N/A N/A 4 41 Group 0+ low rating Alternative Babymax pulse Q1.5 560 685 252 50 919 12 N/A N/A 6 50 TRL 116 CPR821 Client Project Report C.4.2.2 Forward facing integral restraints The results of the assessment with the forward facing integral CRSs at the higher pulse are shown in Table 46. The results in red show where the measured values have exceeded the thresholds for the injury criteria, and results in brown are those close to the criteria limit (95% of the limit). The main body region to protect for children travelling in forward facing integral restraints is the head, specifically head contact with the vehicle’s interior. This means that both head accelerations and excursions should be kept to a minimum. The data show that in the Q1 exceeds the HIC limit (150% of the limit), although there was no head contact. The chest resultant criteria limits (104%), as well as exceeding the limit of the upper neck force by 66%, which was also exceeded during the test with the proposed pulse. In addition the head resultant acceleration is also nearly exceeded (99% of the limit). The Q3 exceeds the head vertical excursion limit as well as exceeding the limit of the upper neck force, which was also exceeded during the test with the test with the proposed pulse. In addition the chest resultant increased by 43% (91% of the limit) and the head resultant acceleration increased by 19% (99% of the limit) and are close to exceeding the limits. These results show that in addition to exceeding the neck force criteria limit, the criteria limits of the important body regions, the head and chest are also exceeded. Although the head horizontal excursions increased they are well below the limit. However the larger dummy does exceed the vertical excursion limit. TRL 117 CPR821 Client Project Report Table 46: Higher pulse tests – Forward facing integral CRSs Child Restraint System Pulse ATD Proposed limits mm mm 550 800 Head Upper Lower Chest Upper Lower Chest res ac Neck Neck res acc Neck Fz Neck Fz compression 3ms My My 3ms g N Nm N Nm mm g 491629 72 1201 53 N/A N/A 40 55 Group I low rating Cosmo Proposed Q1 344 682 585 60 1636 18 N/A N/A 20 43 Group I low rating Cosmo Alternative pulse Q1 383 698 943 72 1993 18 N/A N/A 22 57 Proposed limits 550 800 7801000 76 1364 61 N/A N/A 38 55 Group I low rating Cosmo Group I low rating Cosmo ‡ Head Head HIC15 exc H exc V Proposed Q3 462 799 414 63 2540 10 1106 123 28 35 Alternative pulse Q3 490 818 678 75 3012 16 1567 146 6‡ 50 Error in data channel TRL 118 CPR821 Client Project Report C.4.2.3 Forward facing non-integral restraints The results of the assessment with the forward facing non-integral CRSs at the higher pulse are shown in Table 47. The results in red show where the measured values have exceeded the thresholds for the injury criteria, and results in brown are those close to the criteria limit (95% of the limit). The main body region to protect for forward facing non-integral restraints is the head, specifically due to head contact with the vehicle’s interior and the abdomen, due to poor interaction with the lap section of the seat belt. This means head accelerations and excursions should be kept to a minimum. However there is not a validated method to measure abdomen loading with the Q-series dummies. The data show that the Q3 test exceeds the limit of the upper neck force, which was also exceeded during the test with the proposed pulse, and nearly exceeds the head resultant acceleration criteria limit (95% of the limit). However this remains the same as during the test with the proposed pulse. Although the excursions of the Q3 increase by around 15%, the head and chest resultant accelerations (88% of the limit) remain similar to those recorded in the test with the proposed pulse. The Q6 exceeds the upper neck force criteria (115%) as well as exceeding the limit of the chest compression (121%), which was also exceeded during the test with the proposed pulse. The Q6 results show a 15-25% increase in injury criteria results and a 5% increase in head excursions. The results show that the Q3 was not significantly affected by the increase in pulse severity, with the same criteria exceeding the limits as the proposed pulse. The results from the Q6 show a more significant effect on the important body regions. However only the neck force criteria limit is exceeded. TRL 119 CPR821 Client Project Report Table 47: Higher pulse tests – Forward facing non-integral CRSs Child Restraint System Group II high volume Kidfix Group II high volume Kidfix Group II high volume Kidfix Group II high volume Kidfix § Pulse ATD Head Head HIC15 exc H exc V Head res ac 3ms Upper Upper Lower Lower Neck Neck Neck Neck Fz My Fz My Chest Lumbar Chest Lumbar res acc FxFz/ compression FxFz Res 3ms lap g N Nm N Nm mm g N 7801000 76 1364 61 N/A N/A 38 55 N/A N/A 621 562 72 2768 12 737 111 34 44 770 43% 421 716 597 72 2587 18 901 137 7§ 44 1190 45% Proposed limits 550 800 10831389 89 2304 118 N/A N/A 33 55 N/A N/A Proposed Q6 418 784 356 60 2090 44 1308 161 37 40 1410 44% Alternative pulse Q6 437 767 654 75 2638 41 1274 172 40 45 1640 57% mm mm Proposed limits 550 800 Proposed Q3 361 Alternative pulse Q3 Error in data channel TRL 120 CPR821 Client Project Report C.4.3 Future work Initial discussions in the Informal Group have been made as to whether a Global Technical Regulation (GTR) for front impact could be possible. This would look to creating a harmonised front impact test procedure for child restraint testing throughout the world. Investigating this was outside the scope of this project however a comparison of the pulses is shown in Figure 65. Investigation would have to be conducted as to whether this corridor is also still representative of modern vehicles in the USA. Figure 65: FMVSS 213 front impact pulse corridor, compared to new regulation pulse corridors TRL 121 CPR821 Client Project Report C.4.4 Front impact summary C.4.4.1 Rearward facing integral restraints During the front impact tests of the rearward facing integral restraints with the proposed pulse, none of the injury criteria limits were exceeded. However the smaller dummy (Q1) did exceed the head and chest resultant acceleration criteria in the tests with the higher pulse. The measured horizontal head excursions from all the rearward facing restraint tests were well below the 700mm limit, and only one test exceeded the forward facing excursion limit of 550mm. It therefore could be suggested that if improved restraint performance is desired as a result of implementing the new regulation, that the currently proposed limits could be reduced. Depending on whether the higher severity pulse is adopted or not, will influence by how much the limits should be reduced. Either way the results show that the horizontal head excursion can be significantly reduced, to at least 550mm. This would then harmonise the limit with the forward facing limit. It can also be argued that in a vehicle a rearward facing restraint would not have any larger space in front of it than a forward facing restraint, so why are the limits different? It should also be remembered that eventually belt attached restraint will also be approved by this regulation and that they will struggle to match the same excursions as the ISOFix seats. However this could be solved by using a different excursion limit for belt attached seats or just encourage belt restraint design to improve. If the higher pulse was adopted, tests with the smallest dummy (Q0) should be conducted before revising the limits, as the smallest dummy has the largest accelerations at the lower severity pulse. C.4.4.2 Forward facing integral restraints During the front impact tests of the forward facing integral restraints with the proposed pulse, one restraint failed the head acceleration resultant criteria, but all restraints failed the upper neck force criteria with both dummies. This leads to questioning whether the limits for the upper neck are realistic. However during the tests with the higher pulse the smaller dummy (Q1) did exceed the resultant acceleration criteria limit and also comes close to exceeding the head resultant acceleration criteria limit. All tests exceeded the upper neck force criteria limit. The measured horizontal head excursions from all the forward facing restraint tests were well below the 550mm limit, in all the tests with the proposed pulse and the higher pulse. One restraint did exceed the vertical excursion limit in the higher pulse tests, after nearly exceeding it in the test with the proposed pulse. Therefore it could be suggested that to improve restraint performance that some of the currently proposed limits could be reduced for forward facing restraints. The results show that the horizontal head excursion can be reduced to 500mm, which would be in line with the limit for forward facing integral restraints in Reg.44. The criteria limits when using the proposed pulse could also be reduced to encourage design improvement. However if the higher pulse is to be used, the criteria limits for head and chest accelerations look around the right level. Again it should be remembered that eventually belt attached restraint will also be approved by this regulation and that they will have a vast disadvantage over ISOFix seats, especially in terms of excursions. However again this could be solved by using a different excursion limit for belt attached seats. C.4.4.3 Non-integral restraints During the front impact tests of the forward facing non-integral restraints with the proposed pulse, all the restraints exceeded the upper neck force criteria with the TRL 122 CPR821 Client Project Report smallest dummy (Q3) and the chest compression criteria with the largest dummy (Q6). Neither of these body regions were identified as being extremely important to protect by the accident research and the consistency at which they were both exceeded by all the restraints leads to questioning the criteria limits. The measured horizontal head excursions from all the non-integral restraints tests were well below the 550mm limit, with the largest excursion measured at 475mm. The higher pulse tests did not seem to have a significant effect on the injury criteria for the smaller dummy. Whereas the injury values of the larger dummy did significantly increase, however only the upper neck criteria limit was exceeded (in addition to the chest compression). Therefore it could be suggested that the injury criteria limits could be reduced for both dummies for this type of restraint. Further investigation of the chest compression limit and the upper neck force criteria needs to be conducted. The possibility of introducing lower neck criteria should also be researched. The abdominal protection of the restraint could also not be properly assessed, the proposed method of using the lower lumbar loads as a proportion of the lap belt load needs further investigation. The abdomen was identified as an important body region to protect and therefore it is essential that a robust method for assessing this is devised. The horizontal head excursion limit could also be revised as all dummies were well below the 550mm limit. However it should be remembered that the largest dummy (Q10.5) was not tested, as it is not currently available, and it is likely to have the greater excursions. Though a different head excursion limit could be set for this dummy, as in the current Reg.44. TRL 123 CPR821 Client Project Report C.5 Assessment of rear impact proposals C.5.1 Introduction The rear impact test programme was designed to assess the rear impact procedure proposed by the GRSP Informal Group (see Section 0). The test speed and pulse proposed by the Informal Group remains the same as for Reg.44, with a speed of 30 km/h +0/-2 and using the deceleration envelope in Section B.3.2. The main differences between UNECE Reg.44 and the proposal for the new regulation are the test bench and the dummies. The test programme was designed to gain an understanding of the relative effect of the geometry and cushion properties of the new proposed test bench on the performance of CRSs compared to those of the test bench specified in Reg.44 and to assess the implications of using the Q-series ATD criteria and limits, proposed by the Informal Group. The review of rear impact accidents showed that a 30 km/h impact represents a large proportion of rear impact accidents involving children and the head was shown to be the priority body region for protection. The injury mechanisms that cause these head injuries are not well defined, however it is presumed that these will be similar to those that cause injuries to rearward facing children in front impact. Injuries to the neck and abdomen were also shown to be present, though only a small number of accident cases were included in the data analysis. C.5.2 Effect of the proposed test bench The test matrix for the assessment of the effect of the proposed test bench on the performance of CRSs, compared to those of the Reg.44 test bench is shown in Table 48. The assessment used a different size of P-series dummy with each of the two models of CRS. Each CRS was tested using the two different test bench set-ups; the new proposed test bench (detailed in Section B.1) and the current Regulation 44 test bench. The CRS models represent seats that received low or high ratings in various consumer tests. Table 48: Rear impact assessment matrix – test bench evaluation Group 0+ Child Restraint Systems Test Bench ATD Tests Low rating Babymax Proposed P1.5 1 Reg.44 P1.5 1 High rating Babysafe Proposed Reg.44 P0 P0 1 1 An example of the rear impact test setup is shown in Figure 66. The photograph has been edited digitally, to remove the labels and logos from the CRS. TRL 124 CPR821 Client Project Report Figure 66: Rear impact test The results of the assessment with the rearward facing integral CRSs are shown in Table 49. The P-series dummy instrumentation is very limited and therefore only a few injury criteria can be compared, using the limits specified in Regulation 44. The P0 has no instrumentation and therefore the comparison is limited to the horizontal and vertical head excursions, as well as any noted differences as a result of the difference in test bench geometry. The P1.5 was instrumented to the requirements of Regulation 44; a 3-axis accelerometer in the thorax, allowing the chest resultant to be compared, along with the chest vertical negative acceleration. This means that the injuries to the high risk body region, namely the head, are assessed by looking at the dummy head excursions. The body regions mentioned, considered as less important to protect, namely the neck and abdomen are not measured with the P dummy. The Reg.44 assessment limits are shown in Table 49 along with the results comparing the new proposed test bench with the Reg.44 test bench. TRL 125 CPR821 Client Project Report Table 49: Rear impact results table - test bench evaluation Group 0+ Child Restraint Systems ATD Bench Head Head Head F-G D-E exc V plane plane mm High rating Babysafe High rating Babysafe Low rating Babymax Low rating Babymax Chest Chest Z res acc acc 3ms 3ms g g Reg.44 Limits F-G 800 D-E N/A N/A P0 New Pass 533 Pass N/A N/A P0 Reg.44 Pass 563 Pass N/A N/A Reg.44 Limits F-G 800 D-E 55 30 P1.5 New Pass 637 Pass 38 33 P1.5 Reg.44 Pass 647 Pass 24 14 Although the vertical head excursion measurements were within the limits of Reg.44, the vertical excursion was less in the tests on the newly proposed test bench. The F-G and D-E planes (see Figure 56) are not exceeded by the head of the dummy during any of the tests. However during both the tests with the P1.5 dummy in the low rated CRS, the top of the dummy’s head came very close to contacting the test bench cushion and the handle of the CRS. The adjustable recline mechanism of the head pad broke and rose up allowing extra slack in the harness, as it was pulled through the head pad. The head pad recline mechanism of this CRS broke in all rear impact tests. The results with the P1.5 also show that the chest resultant and chest vertical were both higher in the test on the new regulation bench. The chest vertical negative 3ms maximum exceeded the Reg.44 limit in the test with the P1.5, on the new test bench. This may be due to a number of contributing factors: The stiffness of the proposed cushion is greater than that of the Reg.44 cushion. There is a 5o difference in the angle of the backrest (Reg.44 20o, new bench 25o). The difference in angle meant that the CRS on the new bench was able to rotate more during the impact test and lift up further from the test bench base cushion (Figure 68). TRL 126 CPR821 Client Project Report Reg.44 test bench New regulation test bench Figure 67: Test bench comparison During the test with the new bench the feet of the dummy get caught under the rebound handle of the infant carrier, whereas in the Reg.44 bench test the feet slipped above the handle. This combined with the extra slack introduced in the harness, by the head pad lifting up, enabled the dummy’s bottom to slide towards the cushion. This difference in the kinematics of the dummy in the two tests can explain the variation in chest vertical accelerations and as a result, the difference in chest resultant accelerations. The new test bench cushion has been proposed as more representative of current vehicle seats and with this being the case, it seems that the stiffness and the angles of the test bench cushions have an effect on CRS performance. CRSs assessed on this new test bench may, as a result, perform better over a wider range of vehicles. Reg.44 test bench New regulation test bench Figure 68: P1.5 test comparison The ISOFix anchorages in the tests using the proposed bench had to be moved forward to allow the low rated CRS to be installed The CRS design was incompatible with the new test bench. For the test using the Regulation 44 bench, although the anchorages were in the maximum rearward position, the backrest angle and softer cushion still allowed the CRS to be attached. TRL 127 CPR821 Client Project Report C.5.3 Evaluation of proposed dummy performance criteria The test matrix for the practical assessment of the effects of the proposed rear impact procedure on rearward facing integral CRSs is shown in Table 50. The assessment used three dummies with the high volume sales CRS and the largest and smallest dummy with the high rating and low rating CRSs. Table 50: Rear impact assessment matrix – test bench evaluation Group 0+ Child Restraint Systems Test Bench Low rating Babymax Proposed High rating Babysafe Proposed High volume Cabriofix Proposed ATD Tests Q0 Q1.5 1 1 Q0 1 Q1.5 1 Q0 Q1 1 1 Q1.5 1 The results of the assessment with the rearward facing integral CRSs are shown in Table 51. The accident review showed that the head is the priority body region to protect in rear impact. The injury mechanisms that cause these head injuries in rear impact are not well defined, however it is presumed that these are caused by contact with the vehicle interior. It is therefore important that the horizontal and vertical head excursions of dummies are at a minimum. The results show that all the head vertical excursion measurements are within the required limit and that the F-G and D-E planes (see Figure 56) are not exceeded by the head of the dummies during any of the tests. However the low rating and high rating CRS both fail the head resultant acceleration requirement with the Q0 dummy. In both tests, the initial head resultant acceleration is well below the limit (25-42g), however during the rebound phase, when the dummy falls back into the CRS, its head impacts the back of the head pad and a large spike is seen in the head resultant, exceeding the 85g 3ms limit. Both these CRSs have a plastic adjustable head pad, which has minimal padding behind the head of the dummy to cushion the dummy’s head as it lands back into the CRS. The current regulation does not use instrumentation in the head of the dummies during approval and therefore this problem of high accelerations in rear impact would not be identified during current type approval of the CRSs. The recorded chest resultant acceleration in the high rated CRS with the smallest dummy was also very close to exceeding the limit. Again the initial chest resultant acceleration was well below the limit (•30g), however during the rebound phase, when the dummy lands back down in the CRS a large spike was seen in the chest resultant and was on the 55g limit. The results from the high volume sales CRS, which was tested with all three dummy sizes shows that the smallest dummy recorded the highest accelerations in the head, chest and pelvis, which agrees with the philosophy that testing with the smallest dummy will be the worst case test in terms of dummy loading. The P0 dummy, currently used for type approval, has no instrumentation, so loading is not currently measured for the smallest dummy. However the largest dummy did have the highest neck forces and moments, which is probably due to its larger head mass. TRL 128 CPR821 Client Project Report Injuries to the neck were also found to occur in the rear impact review. All the neck force and moment recorded values were well below the current specified limits. The accident review showed a very small number of abdominal injuries. However it is not possible to ascertain whether the CRSs protect the dummy from abdomen injuries in rear impact using the current measurements available on the Q-series dummies. It should be noted that the high rating CRS may have had an unrealistically good result, when tested with the largest occupant certainly from comparing the chest and pelvis resultant time histories to those of the other CRSs. This is because during the test, the foot of the support leg got caught under the base plate of the test bench cushion and acted as a 3rd attachment point, limiting the rotation of the CRS and then holding the CRS in the air as the dummy landed back into it, thus reducing the rebound of the dummy. TRL 129 CPR821 Client Project Report Table 51: Rear impact results table - criteria evaluation Group 0+ Child Restraint Systems Low rating Babymax High rating Babysafe High volume sales Cabriofix High volume sales Cabriofix Low rating Babymax High rating Babysafe High volume sales Cabriofix TRL ATD Head Head exc. Head HIC15 F-G plane V (mm) D-E plane Head resultant accel (g) Upper neck Fz (N) Upper Chest neck My compression (Nm) (mm) Chest resultant accel (g) Limits F-G 800 D-E 671 85 546 17 N/A 55 Q0 Pass 492 Pass 407 86 423 2 N/A 43 Q0 Pass 490 Pass 567 104 295 5 N/A 55 Q0 Pass 514 Pass 147 50 436 7 N/A 45 Limits F-G 800 D-E 629 72 1201 53 40 55 Q1 Pass 650 Pass 131 40 752 19 6 32 Limits F-G 800 D-E 741 76 1364 61 38 55 Q1.5 Pass 650 Pass 68 33 640 16 7 37 Q1.5 Pass 693 Pass 84 32 707 17 6 25 Q1.5 Pass 674 Pass 132 39 861 23 6 40 130 CPR821 Client Project Report C.5.4 Rear Impact Summary The rear impact test programme was designed to assess the rear impact procedure proposed by the GRSP Informal Group. The test conditions proposed remain the same as for Reg.44. The main differences between UNECE Reg.44 and the proposal for the new regulation are the test bench and the dummies. This rear impact test programme was designed to gain an understanding of the relative effect of the geometry and cushion properties of the new proposed test bench on the performance of CRSs and to assess the implications of using the Q-series ATD criteria and limits, proposed by the Informal Group. The review of rear impact accidents showed that a 30 km/h impact represents a large proportion of rear impact accidents involving children, which supports the proposed test conditions. The head was shown to be the priority body region for protection of children in rear impacts. The injury mechanisms that cause these head injuries are not well defined. Injuries to the neck and abdomen were also shown to be present, though these only represented a small number of accident cases in the data analysis. An assessment using the P series dummies was carried out to gain an understanding of the relative effect of the geometry and cushion properties of the proposed test bench on the performance of CRSs. The P-series dummy criteria were compared using the two test environments and the limits specified in Regulation 44. The P0 represents a new born child. It has no instrumentation and therefore the comparison is limited to the horizontal and vertical head excursions. The P1.5 was instrumented to the requirements of Regulation 44. Chest resultant and chest vertical acceleration were compared using the instrumentation and potential injuries to the head were compared by looking at the dummy head excursions. The vertical excursion was seen to be less in the tests on the newly proposed test bench. However, the proposed test bench allowed more rotation of the CRSs, towards the seatback, allowing more movement of the dummy. The results showed increased resultant and vertical chest accelerations. This may be due to the greater stiffness of the proposed cushion and the increased angle of the backrest. The new test bench cushion has been proposed as more representative of current vehicle seats and with this being the case, it seems that the stiffness and the angles of the test bench cushions have an effect on CRS performance. CRSs assessed on this new test bench may, as a result, perform better over a wider range of vehicles. The stiffer foam of the proposed test bench made it impossible to connect the ISOFix attachments to the test bench anchorages, with one of the CRSs. The anchorages on the test bench were moved forward to complete the test programme. If a CRS design is incompatible with the new test bench, then it may have compatibility issues in the field. The proposed test bench is more representative of modern vehicles and may therefore provide a better assessment of the compatibility of CRSs in the field than the Reg.44 test bench. An evaluation was carried out to assess the implications of using the Q-series ATD criteria and limits, proposed by the Informal Group. The accident review showed that the head is the priority body region to protect in rear impact. The injury mechanisms that cause these head injuries in rear impact were not well defined. The P0 dummy does not have the capability of measuring head acceleration and this is not assessed in current type approval of CRSs. However, during this evaluation, two of the CRSs tested with the Q0 dummy failed the limits proposed for the 3ms head resultant acceleration requirement. If the Q series dummies were used as a measurement device in type approval testing of CRSs, the head accelerations could be assessed and this may lead to safer CRSs for young babies. The P0 has no capability to measure chest acceleration and this is not assessed, with the smallest dummy, in current type approval testing of CRSs. The resultant chest acceleration was on the limit of the proposed criteria with the Q0 in TRL 131 CPR821 Client Project Report the high rated CRS. Again, if the Q series dummies were used in type approval testing and chest acceleration could be assessed, this may lead to safer seats for new born children. The tests where all three dummy sizes were assessed in the same CRS show that the smallest dummy recorded the highest accelerations in the head, chest and pelvis, which agrees with the philosophy that testing with the smallest dummy will be the worst case test in terms of dummy loading. This suggests that type approving with the smallest dummy instrumented could lead to safer CRSs. Injuries to the neck were also found to occur in the rear impact review. The largest dummy had the highest neck forces and moments, which is probably due to its larger head mass. All the neck force and moment recorded values were well below the proposed limits. The accident review showed a very small number of abdominal injuries. It is not possible to ascertain whether the CRSs protect the dummy from abdomen injuries in rear impact using the current measurements available on the Q-series dummies. TRL 132 CPR821 Client Project Report C.6 Assessment of side impact proposals C.6.1 Introduction The side impact procedure has been presented to the informal group on the basis that, although the procedure is not representative of the real world accident, it is simple to apply and it will improve the safety of CRSs. This practical assessment programme was designed to assess the proposed procedure for repeatability and reproducibility. The test procedure was assessed for repeatability based on three repeat tests of some of the CRSs evaluated. Reproducibility of the test procedure was also evaluated by comparison with the results of six side impact tests (three with a rear facing integral CRS (Group 0+) and three with a forward facing integral CRS (Group I) at the Dorel test facility in Cholet, France. Furthermore, the procedure was assessed to evaluate the effect of applying the front impact injury criteria to side impact and to evaluate, where possible, how the dummy loading in the procedure relates to loading in the vehicle. Finally, the effect of varying friction in the ISOFix anchorage, on dummy loading, was evaluated. C.6.2 Anchorages The ISOFix anchorage and top tether locations for the side impact testing proposal are located at the positions shown previously, in Table 16. The side impact proposal uses the G1 top tether position only. The side impact test bench proposal does not include belt anchorage locations. However, as booster seats were included in the TRL test programme these anchorages have been incorporated into the sled design. The anchorage locations were as described in Section B.1.4, with the exception of the lower inner (seat-belt buckle) location, which had to be moved forward in the y-axis, to prevent interference with the sliding ISOFIX anchorages. Table 52: Side impact anchorage locations Direction x y z Upper (D-ring) -240 -250 -630 Lower (buckle) 10 200 59 Lower (outer) 10 -200 14.5 Belt anchorage locations C.6.3 Test conditions Figure 69 and Figure 70 show the sled velocity change for the 28 side impact tests performed at TRL (including forward facing, rear facing, and anchorage friction tests) and the six tests performed at Dorel. It can be seen that the change of velocity was close to the middle of the target corridor for the TRL and the Dorel tests, and that the repeatability is very good. The velocity change at approximately 20 ms was slightly later and sharper in the TRL tests than in the Dorel tests, but overall the reproducibility of the pulses between the two laboratories was good. The range of TRL sled velocity is wider as it contains all the tests carried out at TRL, across a much wider range of CRSs. TRL 133 CPR821 Client Project Report 30 28 26 24 Velocity (km/hour) 22 20 18 16 14 12 10 8 6 4 2 0 0 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.07 0.08 Time (s) Figure 69: TRL sled velocity data (28 tests) 30 28 26 24 Velocity (km/hour) 22 20 18 16 14 12 10 8 6 4 2 0 0 0.01 0.02 0.03 0.04 0.05 0.06 Time (s) Figure 70: Dorel sled velocity data (6 tests) TRL 134 CPR821 Client Project Report Figure 71 and Figure 72 show the sled deceleration pulses for the TRL and Dorel tests. Also shown are the time intervals over which the door contacts the CRS (estimated from the videos), and in which the peak head and chest resultant accelerations occur. Figure 73 shows the same data for the TRL reproducibility tests for direct comparison with the Dorel results in Figure 72. The different shape of the elbow in the velocity plots is reflected in the acceleration plots. The TRL pulse has a flatter, more consistent 2 g pulse in the first 150 ms, followed by a steeper rise in the acceleration to approximately 13 g. The last part of the pulse, however, is less consistent, with peak accelerations ranging from 11 to 16 g. This occurs about the time that the sled velocity reaches zero and changes direction to rebound. This part of the pulse partially overlaps the time frame during which the resultant head accelerations reached their maximum value. However, the variation in sled acceleration does not seem to have influenced the repeatability of this measure. The Dorel sled pulse has a notably less steep rise in acceleration to the plateau at 13 g. CRS-to-door contact occurs markedly earlier (20-22 ms) in the Dorel tests than in the TRL tests (25-35 ms). Maximum resultant chest acceleration occurs slightly earlier in the Dorel tests, and maximum resultant head acceleration occurs much earlier in the Dorel tests than the TRL tests (45-50 ms and 50-60 ms respectively). 18 16 14 Sled deceleration ( g) 12 10 8 6 4 Max chest resultant acceleration CRS-Door Contact 2 Max head resultant acceleration 0 0 -2 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 Time (s) Figure 71: TRL sled deceleration data (28 tests) TRL 135 CPR821 Client Project Report Figure 72: Dorel sled deceleration data (6 tests) 18 16 14 Sled deceleration ( g) 12 10 Max head resultant acceleration 8 6 4 Max chest resultant acceleration CRS-Door Contact 2 0 0 -2 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 Time (s) Figure 73: TRL sled deceleration data (6 reproducibility tests only) TRL 136 CPR821 Client Project Report C.6.4 Restraint system loading C.6.4.1 Comparison with observation of full scale testing The phasing of the loading to the CRS will have an effect on the loading to the child. TRL have analysed this sequence of loading from full scale tests. The side of the struck vehicle is loaded by the striking vehicle and within 20ms the velocity of the intrusion into the vehicle is in excess of 30km/hr. At this point the chassis velocity of the struck vehicle is about 5km/hr. The chassis velocity of the struck vehicle builds relatively slowly and the velocity of the intrusion slows down and meets the rising chassis velocity at about 60ms. The proposed test procedure provides a good representation of the speed of the struck vehicle chassis, however it does not reproduce the speed of the intrusion into the struck vehicle. When the side of the struck vehicle starts to intrude into the interior of the vehicle, it loads the firstly vehicle seat and then the CRS. The CRS goes on to load the dummy. The intruding structure continues to load both the vehicle seat and the CRS. The dummy’s thorax is loaded, through the CRS and then the dummy’s head moves over the top of the intruding structure (supported by the side wing of the CRS). The intruding structure remains in contact with the vehicle seat and the CRS at maximum dynamic intrusion. The intrusion diminishes slightly when the vehicles part and the vehicle seat remains with the intrusion panel. As the intrusion diminishes the belt attached CRS moves away from the vehicle seat, in the direction of the vehicle centre. It is expected that an ISOFix CRS would remain with the vehicle seat. At no point does the vehicle seat lose contact with the intruding structure. This is very different to the events of the proposed test procedure, where the ISOFix anchorages are allowed to move away from the intrusion panel. C.6.4.2 Stopping distance Table 54 to Table 56 show the sled impact velocity, stopping distance and anchorage displacement for the TRL tests, and this information is summarised in Table 53. It is clear from these tables that the impact velocity and stopping distance were very repeatable throughout the testing. As noted in Section B.4.3, there is no tolerance on the stopping distance, but a specification of 295 to 300 mm was used for calibration runs. The upper limit for the calibration runs was set to 300 mm in order to ensure that the intended intrusion was not exceeded. Despite this, the stopping distance in testing ranged from 293-305 mm, including five tests that exceeded 300 mm stopping distance and which would therefore have experience slightly greater intrusion than was intended. The sled velocity and stopping distance in the side impact tests are similar to those in the Reg.44 rear impact tests, which have a specification on the stopping distance of 275±20 mm in calibration runs and 275±25 mm in testing. The stopping distances in the TRL side impact tests were clearly well within these limits, and would easily have met a requirement of 300±10 mm. Nevertheless, the stopping distance may be more critical for the side impact test procedure, compared to the rear impact procedure, because it directly influences the intrusion of the door. It is recommended that the tolerance on the stopping distance is considered further, particularly with respect to the level of intrusion applied to the CRS. TRL 137 CPR821 Client Project Report Table 53: Summary of TRL test conditions and anchorage displacement Mean Max Min SD CV Impact velocity (km/h) 26.05 26.14 25.91 0.06 0.2% Stopping distance (mm) 298 305 293 3.21 1.1% Anchorage displacement (mm) 36.4 65.0 3.0 17.6 48.3% Table 54: Summary of TRL test conditions and anchorage displacement - rear facing integral CRSs Dummy Impact velocity (km/h) Stopping distance (mm) Anchorage disp. (mm) Q1.5 26.03 295 52 Q1.5 26.02 293 45 Q1.5 26.04 299 42 High rating Babysafe Q0 26.13 300 6 High rating Babysafe Q1 26.10 298 6 High rating Babysafe Q1.5 26.06 297 3 High rating Babysafe Q1.5 26.10 296 3 Q1.5 26.10 294 33 Q1.5 26.10 300 N/A Group 0+ CRSs Low rating Babymax Low rating Babymax Low rating Babymax Mean disp. (mm) Comment 46.3 5.0 Modified CRS (degraded) High volume sales Cabriofix High volume sales 3 Belt attached only Cabriofix TRL 138 CPR821 Client Project Report Table 55: Summary of TRL test conditions and anchorage displacement forward facing integral CRSs Group I CRSs Low rating Cosmo Low rating Cosmo Low rating Cosmo High rating Priorifix High rating Priorifix High volume sales Iseos High volume sales Iseos High volume sales 2 Duo High volume sales 2 Duo Dummy Impact velocity (km/h) Stopping distance (mm) Anchorage disp. (mm) Q1 26.08 300 50 Q1 26.11 295 36 Q1 26.14 305 62 Q1 26.08 293 51 Q3 26.02 293 65 Q1 26.09 301 51 Mean disp. (mm) Comment 49.3 58.0 46.5 Q3 25.98 301 42 Q1 26.06 302 40 Q3 25.99 296 38 39.0 Table 56: Summary of TRL test conditions and anchorage displacement forward facing non-integral CRSs Dummy Impact velocity (km/h) Stopping distance (mm) Anchorage disp. (mm) Q6 26.05 296 34 Q6 26.04 300 36 Q6 26.05 302 33 Q3 25.95 300 28 Q6 26.08 298 16 High volume sales Kidfix Q3 25.91 297 27 High volume sales Kidfix Q6 Group II/III CRSs Low rating Jane Low rating Jane Low rating Jane High rating Cybex High rating Cybex TRL Mean disp. (mm) Comment 34.3 22.0 28.5 26.06 300 139 30 CPR821 Client Project Report C.6.4.3 Anchorage displacement Although the impact velocity and stopping distance were very repeatable, the anchorage displacement was very variable in the TRL tests, ranging from 3 to 65 mm across all of the tests, and with a range of 49, 27, and 20 mm for the Group 0+, I and II/III seats respectively. The largest range of anchorage displacements for a single seat was 26 mm (36-62 mm, Group I low rating Cosmo). In contrast, the high rating Babysafe Group 0+ seat translated only 3-6 mm in each of four tests. It should be noted that all of these anchorage displacements were measured post-test and the maximum dynamic displacement during the test may potentially have been larger. The anchorage displacements in the Dorel tests are shown in Table 57. Table 57: Anchorage displacement in the Dorel – forward and rearward facing integral CRSs CRS Low rating Cosmo Low rating Cosmo Low rating Cosmo Low rating Babymax Low rating Babymax Low rating Babymax Dummy Final anchorage disp. (mm) Maximum anchorage disp. (mm) Q1 95 Q1 89 Q1 90 Q1.5 95 195 Q1.5 18 190 Q1.5 146 145 Mean Comment Intrusion in contact with CRS for duration of the test 91 Intrusion in contact with CRS for duration of the test Intrusion in contact with CRS for duration of the test CRS lost contact with intrusion. ISOFix anchorages hit the stops & rebounded 177 CRS lost contact with intrusion. CRS stopped and rebounded CRS lost contact with intrusion. CRS stopped and rebounded In the Dorel tests, the rear facing integral CRSs remained in contact with the intrusion panel throughout the test, although the anchorage displacement was considerably greater than in the TRL tests (89-95 mm in the Dorel tests, compared with 36-62 mm in the TRL tests). This represents a considerable difference in the effective door intrusion between the Dorel and TRL tests on the same CRS, due to differences in the lower anchorage performance. The three forward facing integral CRSs in the Dorel tests had very different anchorage displacements. All three seats lost contact with the intrusion panel after approximately 95 mm of displacement, after which the responses varied considerably: TRL • The first seat hit the stops at the end of the lower anchorage bar and rebounded 100 mm; • The second seat stopped approximately 5 mm before hitting the stops (it apparently jammed on the lower anchorage bar) and rebounded 172 mm; • The third seat stopped approximately 5 mm before hitting the stops (it apparently jammed on the lower anchorage bar) and did not rebound. 140 CPR821 Client Project Report These results are very different to the anchorage displacement range of 42-52 mm in the TRL tests with the same CRS model. This shows a considerable difference in the constraint of the lower anchorages between the TRL and the Dorel tests with this forward facing CRS. The Dorel results also show poor repeatability of the lower anchorage performance for nominally identical CRSs on a single bench. These results may explain why the neck and pelvis measurements were generally much greater in the TRL reproducibility tests than in the Dorel reproducibility tests. At the very least, these results strongly suggest that the anchorage displacement should be controlled to ensure consistent loading of the CRS and good reproducibility of the test conditions. Reg.14 states that the minimum width of each ISOFix lower anchorage is 25 mm, and Reg.44 states that the width of the CRS ISOFix attachment must not exceed 25 mm, but in practice some designs are as narrow as 5 mm. If the lower ISOFix attachment is designed to meet the minimum width, the maximum lateral translation of the CRS attachment in an impact is 25 mm minus the width of the CRS anchorage, i.e. the maximum translation could range from zero to approximately 20 mm. There is no upper limit on the width of the ISOFix lower anchorage, so in theory the attachment displacement could be much greater than 20 mm. However, in practice this is limited by the seat foam and underlying seat structure. In particular, for front seats or individual rear seats, the displacement of the in-board attachment will be limited by the width of the seat and the seat structure and is unlikely to achieve the displacements seen in the side impact testing. It is possible that the out-board anchorage (nearest the door) could displace as the vehicle seat is crushed, however it is unlikely that the inboard anchorage is likely to displace substantially, thus limiting the displacement of the lower outer anchorage by the amount that the CRS is crushed in the impact. Furthermore, it may be difficult to design a large, yet well-controlled displacement (i.e. with consistent friction levels between different sleds), and relatively easy to specify a small displacement with a hard stop, at least for the out-board anchorage, such as may be found in front or individual rear seats. The results of these tests suggest that many of the anchorage displacements observed in these tests were excessive, at least for representing front seats or individual rear seats. It is recommended that consideration be given to limiting, and possibly eliminating, anchorage displacement in the tests in order to better represent front and rear individual seats, and the worst case for rear bench seats. Whether ISOFix anchorages move to the extent that an ISOFix CRS will translate to the degree observed in these tests is questionable and needs to be verified. Section A.7.3 noted that the real-world accident analysis found that the largest proportion of side impacts occur of at 60°, followed by 90°, and that the risk of fatality is significantly greater in a 90° impact. The results of the testing indicated that the ISOFix anchorage sometimes jammed (limiting the lateral displacement of the anchorage), even though the door impact in the tests is at 90°. Limited (or eliminated) anchorage displacement would be more realistic of the real-world loading on the CRS. C.6.4.4 Intrusion The real-world accident analysis in Section Appendix A (see Figure 26) showed that injury increased with increasing intrusion (and that this was the most important factor affecting injury outcome). However, the reproducibility results (see Section C.6.5.2 show TRL 141 CPR821 Client Project Report either no influence of intrusion, or a reduction of injury measures with increasing intrusion - which is opposite to the real-world observation. The position of the CRS on the test bench was defined during ISO investigations and was determined by measuring the distance from the inner door trim to the centre of a CRS in a number of vehicles. This may mean that, to do well in the test procedure, it may be better to have a narrow CRS (door will impact it later, when the sled is slower, but there is less room for padding). Or it may be better to have a wider CRS (will get impacted when the sled is moving faster, but has more space for padding to absorb the impact). Defining the initial door position relative to the bench (see Section B.4.4) may encourage the former, which could then perform much worse in a narrower car. The effect of CRS positioning with fixed anchorages should be investigated, so that the set-up represents the worst case scenario and CRSs cannot perform artificially well. The displacement of the CRS anchorages was variable. There was no obvious relationship between the initial distance between the intrusion panel and the CRS, and the displacement of the anchorages, in the TRL tests (see Figure 74). 70 Anchorage displacement (mm) 60 50 40 30 Linear trendline 20 10 0 150 170 190 210 230 250 Initial distance between door and CRS (mm) Figure 74: Anchorage displacement vs. initial distance between the door and the CRS in the TRL test series TRL 142 CPR821 Client Project Report C.6.5 Repeatability and reproducibility Table 58 shows the sub-set of tests for which repeat tests were performed at TRL and at Dorel to assess repeatability of the test procedure. The forward and rearward facing integral CRSs were tested at both facilities to allow assessment of the reproducibility of the test procedure. Table 58: Test matrix for the assessment of repeatability and reproducibility Child Restraint System ATD No. of Tests Q1.5 3 Q1 3 Q6 3 Q1.5 3 Q1 3 Tests at TRL Group 0+ low rating Babymax Group I low rating Cosmo Group II low rating Monte Carlo Tests at Dorel Group 0+ low rating Babymax Group I low rating Cosmo C.6.5.1 Repeatability The repeatability results from the TRL tests are shown in Table 59 and for the Dorel tests in Table 60. The limits proposed by the Informal Working Group are also shown, although it should be noted that these are front impact limits (see Section C.6.6 for a discussion of the use of these limits in side impact). ISO define good repeatability as a CV lower than 7%, and acceptable repeatability as a CV lower than 10%, for all dummy performance criteria in certification and other test procedures (see e.g. ISO 15830 Part 1). The CV’s from the TRL tests are generally well within the acceptable range, except for the negative upper neck extension moment in the Q1.5 tests, and the positive upper neck extension moment in the Q6 test. For the Q1.5, the negative neck extension moment measurements were very small compared with the proposed limit (mean -8.9 Nm c.f. a limit of -61 Nm). For neck extension moment measurements near the limit, the same absolute variation in measurements would give a much lower CV; however, it cannot be guaranteed that the absolute variation would not increase with increasing measurements. Nevertheless, given that the measurements were very much smaller than the limits suggested by the Informal Working Group, the variability is not expected to be a problem within the test procedure. The same may be said of the positive neck extension moment in the tests with the Q6 dummy. For the Dorel tests, all the dummy measurements showed good or acceptable CV except the chest resultant acceleration for the Q1 test, which had a CV slightly greater than TRL 143 CPR821 Client Project Report 10%. In this case, the mean measurement was greater than the limit proposed by the Informal Working Group. In the discussion of the sled pulses in Section C.6.3 it was noted that the last part of the acceleration pulse on the TRL sled was somewhat inconsistent and that this may affect the repeatability of the head acceleration metrics. However, Table 59 shows that the repeatability of the peak resultant head acceleration and HIC were both very good, with a maximum CV of 4.2 for the two metrics across the three seats that were tested. This compares favourably with a maximum CV of 6.5 for HIC in the Dorel tests, even though the sled acceleration was more consistent during peak head resutlant acceleration in the Dorel tests. TRL 144 CPR821 Client Project Report Table 59: Repeatability results from the TRL sled tests TRL Side Impact Head resultant accel (g) Rearward Facing Integral Q1.5 Limits 76 Mean SD CV 105.5 2.4 2.3% Forward Facing Integral Q1 Limits 72 Mean SD CV 66.7 2.53 3.8% Forward Facing nonintegral Q6 Limits 89 Mean SD CV 54.7 1.00 1.8% TRL HIC15 578741 750 28.1 3.7% 491629 423.8 17.6 4.2% 10831389 267.8 4.66 1.7% Upper neck Fz (N) +ve upper neck Mx (Nm) -ve upper neck Mx (Nm) Chest compression (mm) 1364 61 -61 38 55 1186 38.4 3.2% 20.5 0.62 3.0% -8.9 1.72 -19.4% 19.3 1.13 5.9% 66.5 6.37 9.6% 1201 53 -53 40 55 710 46.85 7.0% 6.3 0.35 5.5% -13.8 0.55 -4.0% 18.9 1.19 6.3% 60.5 1.25 2.1% 106 2.74 2.6% 2304 118 -118 33 55 - 1517 48.73 3.2% 14.8 1.65 11.1% -15.3 0.23 -1.5% 15.1 1.23 8.2% 48.5 2.22 4.6% 72.8 2.30 3.2% 145 Chest resultant accel (g) Pelvis resultant accel (g) 90.0 2.11 2.3% CPR821 Client Project Report Table 60: Repeatability results from the Dorel sled tests Dorel Side Impact TRL Head resultant accel (g) Rearward Facing Integral Q1.5 Limits 76 Mean SD CV 105.6 4.35 4.1% Forward Facing Integral Q1 Limits 72 Mean SD CV 66.2 1.11 1.7% HIC15 578741 795 51.82 6.5% 491629 414 14.60 3.5% Upper neck Fz (N) +ve upper neck Mx (Nm) -ve upper neck Mx (Nm) Chest compression (mm) 1364 61 -61 38 55 847 37.83 4.5% 18.6 1.69 9.1% -9.37 0.64 -6.9% N/A N/A N/A 71.8 6.02 8.4% 1201 53 -53 40 55 611 51.69 8.0% 5.4 0.36 6.7% -11.13 0.78 -7.0% N/A N/A N/A 67.8 6.88 10.1% 146 Chest resultant accel (g) Pelvis resultant accel (g) 73.6 1.62 2.2% 113.6 7.07 6.2% CPR821 Client Project Report C.6.5.2 Reproducibility The reproducibility of the test procedure was evaluated with two sets of three tests at TRL and Dorel. The reproducibility results for the forward facing CRS and the Q1 dummy are shown in Table 61 and for the rearward facing CRS and Q1.5 dummy are shown in Table 62. These results represent the combined variation due to the sled, sled deceleration method, intrusion profile, dummies and restraints, however TRL supervised test set-up in both labs to keep it relatively consistent. ISO define good reproducibility as a CV lower than 10%, for all dummy performance criteria in certification and other test procedures (see e.g. ISO 15830 Part 1). A number of the dummy measurements in these tests at two laboratories exceed this guideline. Most of the neck loads have a reproducibility CV exceeding 10% and in four of these five cases the measurements in the TRL tests were much larger than the measurements in the Dorel tests. Different dummies and test benches were used at two different test laboratories, with different deceleration systems (crush tubes at TRL and a hydraulic system at Dorel). Furthermore, the intrusion profiles were different in the two test configurations, with 100 mm greater intrusion in the Dorel tests compared with the TRL tests (see Section B.4.4). Even though there was 100 mm less intrusion in the TRL configuration than the Dorel configuration, the peak values for the neck forces and moments in the forward facing seat, and the pelvis acceleration in the rearward facing seat, were generally much higher in the TRL tests. It was observed that the CRS typically moved away from the intrusion panel relatively easily in the Dorel tests, but was driven sideways in the TRL tests. Table 61: Reproducibility results for the sled tests with the Q1 dummy in a forward facing CRS Mean SD CV Head resultant accel (g) HIC15 Upper neck Fz (N) 66.5 1.77 2.7% 419 15.37 3.7% 661 69.84 11% +ve Upper neck Mx (Nm) -ve Upper neck Mx (Nm) 5.9 0.61 10.3% -12.5 1.57 -12.6% Chest resultant accel (g) 64.2 5.98 9.3% Pelvis resultant accel (g) 109.6 6.47 5.9% Table 62: Reproducibility results for the sled tests with the Q1.5 dummy in a rearward facing CRS Head resultant accel (g) Mean SD CV 105.5 3.15 3.0% HIC15 Upper neck Fz (N) +ve Upper neck Mx (Nm) -ve Upper neck Mx (Nm) 772 44.76 5.8% 1016 189.06 18.6% 19.5 1.54 7.9% -9.1 1.20 -13.1% Chest resultant accel (g) 69.2 6.26 9.0% Pelvis resultant accel (g) 81.8 9.14 11.2% C.6.6 Evaluation of proposed dummy performance criteria The test matrix for the evaluation of dummy performance criteria for rearward facing CRSs is shown in Table 63, and the dummy measurements for all of the rearward facing CRSs tests are shown in Table 64. TRL 147 CPR821 Client Project Report Table 63: Test matrix for criteria evaluation - rearward facing integral CRSs Lab TRL TRL TRL TRL TRL Dorel Group 0+ Child Restraint Systems ATD No. of Tests Q1.5 3 Q0 1 Q1 1 Q1.5 1 Q1.5 1 Q1.5 1 High volume 3, Cabriofix belted Q1.5 1 Low rating, Babymax Q1.5 3 Low rating , Babymax High rating, Babysafe High volume 1, Cabriofix High rating, Modified Babysafe (degraded) Evaluation of criteria - Rearward facing integral CRSs For children injured in side impact protecting the head is the main priority. Injuries to the head are caused by contact with the vehicle interior or the intruding object. The head was contained in all cases and neck forces and moments all pass, which is likely to be due to head containment. Containment of the head will help minimise the neck loads. However the resultant head acceleration limit was exceeded in all tests. Only one CRS was within the lower HIC limit and six were within the upper HIC limit and five exceeded the upper limit. These results suggest that either the limits are too low or that CRSs need to be improved to provide more energy absorption in a lateral impact. The accident studies suggested that the head is an area that needs to be better protected in lateral impacts and therefore the injury criteria need to be set at a level that will improve CRS design. If these criteria are applied to the side impact test procedure it is likely to lead to CRSs that absorb the loading more effectively in lateral impacts. Chest, abdomen and neck injuries have been shown to vary in importance between different accident studies. However, chest and abdomen account for a significant proportion of AIS 3+ injuries to children in side impact. These injuries have been found to be caused by compression of the child by the door panel of the vehicle. The chest compressions all passed the limits but the resultant chest accelerations all failed. Again, this may suggest that either the limits have been set too low or that CRSs need to improve the way they provide protection to a child’s chest in a lateral impact. If these chest criteria are applied to the side impact test procedure it is likely to lead to CRSs that absorb the loading more effectively in the chest area. There are no limits on pelvis acceleration, as the pelvis region hasn’t been shown to be a priority body region to protect in the accident review. However the pelvis values seem quite high compared with e.g. WorldSID data for defining injury thresholds. TRL 148 CPR821 Client Project Report Table 64: Test results for criteria evaluation - rearward facing integral CRSs1 Group 0+ CRSs Dummy Head resultant accel (g) HIC15 Upper neck Fz (N) +ve upper neck Mx (Nm) -ve upper neck Mx (Nm) Q0 front impact limits 85 523-671 546 17 -17 High rating Babysafe Q0 108 704 211 4 3 N/A 66 Q1 front impact limits 72 491-629 1201 53 -53 40 55 High rating Babysafe 81 541 692 17 6 18 59 76 578-741 1364 61 -61 38 55 Q1 Q1.5 front impact limits TRL Chest compression (mm) Chest resultant accel (g) Pelvis resultant accel (g) 55 84 91 Low rating Babymax2 Q1.5 109 818 815 18 10 N/A 70 72 Low rating Babymax2 Q1.5 107 831 836 21 9 N/A 79 74 Low rating Babymax2 Q1.5 101 735 889 17 10 N/A 67 75 Low rating Babymax Q1.5 108 782 1159 20 9 20 61 91 Low rating Babymax Q1.5 104 736 1230 21 11 20 65 91 Low rating Babymax Q1.5 104 731 1169 21 7 18 73 88 High rating Babysafe Q1.5 83 565 864 21 7 22 66 81 149 CPR821 Client Project Report Group 0+ CRSs Dummy Head resultant accel (g) HIC15 Upper neck Fz (N) +ve upper neck Mx (Nm) -ve upper neck Mx (Nm) Chest compression (mm) Chest resultant accel (g) Pelvis resultant accel (g) High rating Babysafe (degraded)3 Q1.5 98 716 782 20 11 26 64 110 High volume sales Cabriofix Q1.5 98 715 865 22 5 20 71 72 High volume sales 3 Cabriofix (belted) Q1.5 119 990 586 23 8 21 61 67 1 The head was contained in all tests 2 Tests performed by Dorel, no chest compression instrumentation fitted 3 For this test, the Babysafe seat was modified by taking out the energy absorbing liner and cutting away the side wing TRL 150 CPR821 Client Project Report The test matrix for the evaluation of dummy performance criteria for forward facing CRSs is shown in Table 65, and the dummy measurements for all of the forward facing CRS tests are shown in Table 66. Table 65: Test matrix for criteria evaluation - forward facing CRSs Lab Child Restraint System ATD No. of Tests TRL Group I low rating, Cosmo Q1 3 Q1 1 TRL Group I high rating, Priorifix Q3 1 Q1 1 Q3 1 Q1 1 Q3 1 TRL TRL Group I high volume, Iseos Group I high volume 2, Duo TRL Group II low rating, Monte Carlo Q6 3 Group II high rating, Solution Xfix Q3 1 TRL Q6 1 Q3 1 Q6 1 Q1 3 TRL Dorel Group II high volume, Kidfix Group I low rating, Cosmo Evaluation of criteria - Forward facing CRSs For all children injured in side impact protecting the head is the main priority. Injuries to the head are caused by contact with the vehicle interior or the intruding object. The head was contained in all cases and neck forces and moments all pass, which is likely to be due to head containment. As mentioned earlier, containment of the head will help minimise the neck loads. The resultant head acceleration limit was exceeded in 5 out of 19 tests and 4 of these exceeded the lower HIC limit. These results suggest that it is possible to design CRSs that pass the criteria and that, considering head protection is an area that needs improving, if the criteria were set at this level, it would lead to an improvement in CRSs design. The chest is an area that has been identified as a priority to protect. The chest compressions all passed the criteria, however 12 out of 19 CRSs exceeded the limit for resultant chest acceleration. Again, this may suggest that either the limits have been set too low or that CRSs need to improve the way they provide protection to a child’s chest in a lateral impact. If these chest criteria are applied to the side impact test procedure it is likely to lead to CRSs that absorb the loading more effectively in the chest area. There are no limits on pelvis acceleration, as the pelvis region hasn’t been shown to be a priority body region to protect in the accident review. However the pelvis values seem quite high particularly for the Q1 tests. TRL 151 CPR821 Client Project Report Table 66: Test results for criteria evaluation - forward facing CRSs1 CRS Dummy Q1 front impact limits TRL Head resultant accel (g) HIC15 Upper neck Fz (N) +ve upper neck Mx (Nm) -ve upper neck Mx (Nm) Chest compression (mm) Chest resultant accel (g) 72 491-629 1201 53 -53 40 55 Pelvis resultant accel (g) Group I Low rating Cosmo2 Q1 66.4 418 630 6 -11 N/A 65.8 119.8 Group I Low rating Cosmo2 Q1 67.2 427 553 5 -12 N/A 75.5 105.9 Group I Low rating Cosmo2 Q1 65 398 651 5 -11 N/A 62.2 115.1 Group I Low rating Cosmo Q1 69.2 440 763 6 -13 19.7 59. 9 106.1 Group I Low rating Cosmo Q1 64.2 405 673 7 -14 17.5 61.9 102.7 Group I Low rating Cosmo Q1 66.7 427 694 6 -14 19.4 59.6 108.1 Group I High rating Priorifix Q1 92.3 642 859 6 -20 18.0 66.1 102.1 Group I High volume sales Iseos Q1 87.3 594 784 7 -18 20.5 73.9 119.0 Group I High volume sales 2 Duo Q1 84.1 521 631 9 -20 18.2 62.2 108.4 152 CPR821 Client Project Report CRS Dummy Q3 front impact limits Head resultant accel (g) HIC15 Upper neck Fz (N) +ve upper neck Mx (Nm) -ve upper neck Mx (Nm) Chest compression (mm) Chest resultant accel (g) Pelvis resultant accel (g) 81 7801000 1705 79 -79 36 55 - Group I High rating Priorifix Q3 64.9 384 1182 8 -21 21.1 51.6 88.9 Group I High volume sales Iseos Q3 63.4 371 943 12 -20 23.0 63.5 94.9 Group I High volume sales 2 Duo Q3 55.8 422 837 9 -25 22.0 57.0 72.2 Group II High rating Solution X-fix Q3 75 449 1474 7 -13 16.3 55.0 85.7 Group II High volume sales Kidfix Q3 90.2 591 1169 7 -13 16.1 82.1 95.9 89 10831389 2304 118 -118 33 55 - Q6 front impact limits Group II Low rating Monte Carlo Q6 54.8 264 1462 16 -15 14.2 46.9 73.1 Group II Low rating Q6 53.6 266 1555 13 -16 14.5 47.6 70.4 Q6 55.6 273 1535 16 -15 16.5 51.0 74.9 Monte Carlo Group II Low rating Monte Carlo TRL 153 CPR821 Client Project Report CRS Dummy Head resultant accel (g) HIC15 Upper neck Fz (N) +ve upper neck Mx (Nm) -ve upper neck Mx (Nm) Chest compression (mm) Chest resultant accel (g) Pelvis resultant accel (g) Group II High rating Solution X-fix Q6 63.1 332 1543 5 -14 9.6 47.4 78.7 Group II High volume sales Kidfix Q6 65.7 364 1485 11 -14 18.0 59.3 81.0 1 Head contained in all tests 2 Tests performed by Dorel, no chest compression instrumentation fitted TRL 154 CPR821 Client Project Report C.6.7 The effect of varying friction in the ISOFix anchorages The ISOFix anchorages are allowed to move laterally in the proposed test procedure. It is unlikely that the ISOFix anchorages would move in this way in the vehicle. TRL carried out 3 exploratory tests to indicate what the effects of increasing the friction of the ISOFix anchorages may be. The test matrix for this small study is shown in Table 67. Table 67: TRL Test matrix for investigation into the effects of increased friction on the lateral movement of ISOFix anchorages Integral CRSs ATD No. of Tests Group 0+ low rating, Babymax Q1.5 3 Group 0+ low rating, Babymax Q1.5 increased friction 1 Group I low rating , Cosmo Q1 3 Group I low rating , Cosmo Q1 increased friction 1 Group I high rating , Priorifix Q3 1 Group I high rating , Priorifix Q3 increased friction 1 The differences that were seen were not large. The friction was increased from 8-10N to 80-90N. Although no statistical assessment can be made some differences were seen, taking into consideration the repeatability of the relevant body regions: • The upper neck tension and resultant pelvis acceleration were higher with low friction in the tests with the Q1.5 dummy. • The resultant head acceleration and HIC were slightly higher with low friction in the tests with the Q1 dummy. • The HIC, chest compression and resultant pelvis acceleration were lower with low friction in the tests with the Q3 dummy The results indicate that the amount of friction allowed in the ISOFix anchorages would have an effect on the test procedure. With the friction applied in these tests, the ISOFix anchorages were still able to move relatively freely in the test. It is recommended that further investigation is carried out to allow the set-up procedure to be more representative of the CRS when attached to anchorages in the vehicle. TRL 155 CPR821 Client Project Report Table 68: Test results for evaluation of the effect of friction1, 2 CRS Dummy Head resultant accel (g) HIC15 Upper neck Fz (N) +ve upper neck Mx (Nm) -ve upper neck Mx (Nm) Chest compression (mm) Chest resultant accel (g) Limits Q1.5 76 578- 741 1364 61 -61 38 55 Group 0+ low rating Babymax Q1.5 108 782 1159 20 -9 20 61 91 Group 0+ low rating Babymax Q1.5 104 736 1230 21 -11 20 65 91 Group 0+ low rating Babymax Q1.5 104 731 1169 21 -7 18 73 88 105 750 1186 21 -9 19 66 90 76 Mean Group 0+ low rating Babymax (increased friction) Q1.5 104 748 1078 20 -9 17 63 Limits Q1 72 491- 629 1201 53 -53 40 55 Group I low rating Cosmo Q1 69 440 763 6 -13 20 60 106 Group I low rating Cosmo Q1 64 405 673 7 -14 17 62 103 Group I low rating Cosmo Q1 67 427 694 6 -14 19 60 108 67 424 710 6 -14 19 61 106 Mean TRL Pelvis resultant accel (g) 156 CPR821 Client Project Report Group I low rating Cosmo (increased friction) Q1 63 393 706 5 -13 21 61 108 Limits Q3 81 780-1000 1705 79 -79 36 55 - Group I high rating Priorifix Q3 65 384 1182 8 -21 21 52 89 Group I high rating Priorifix (increased friction) Q3 62 364 1250 8 -19 26 54 97 1 The head was contained in all tests 2 Yellow highlights show where the standard friction results were notably different to the increased friction results TRL 157 CPR821 Client Project Report Appendix D Testing observations and possible restraint regulation non-conformities During the course of the dynamic testing on the child restraints, several nonconformities with the regulation were observed. D.1 Rearward facing integral restraints D.1.1 Low rated restraint – IWH Babymax • The ISOFix anchorages had to be moved forward in x-axis to 40mm from CR point in the front and rear impact tests to allow attachment of the base. However this was not required when attaching it to the Reg.44 test bench. This may mean there could be a compatibility issue with vehicle in the current fleet, causing a problem if this CRS was approved as “universal” under the new regulation (as there would not be a vehicle application list). • The stiffness of new regulation cushion and design of restraint base (metal cross bar between anchorages) meant that the carrier had to be attached to the base and then the base was attached to ISOFix anchorages. This means the CRS could not be installed as described by the instructions. • The Regulation 44 approval label was included as an image in the instruction markings on the side of the restraint. • The approval label image was only for a universal CRS and did not include a second semi-universal approval label for use when installed using the ISOFix base. • The instruction markings/approval label was missing on several of the tested CRSs. This is not allowed under the current Reg.44. • There was no approval label on any of the ISOFix bases. This means that a consumer would be using the restraint illegally, as it does not appear to have a Reg.44 approval. • The CRS shell cracked in one of the side impact tests. D.1.2 High sales restraint – Maxi-Cosi Cabriofix • The stiffness of new regulation cushion did not allow base to ratchet into anchorages (when force specified by the regulation 135±15N is applied), however it did connect to the anchorages correctly. D.2 Forward facing integral restraints D.2.1 Low rated restraint – Nania Cosmo TRL • The top tether clip was over 12mm wide, outside of the design requirements specified by Reg.44. • On several of the products the top tether strap contained a twist which was removed before testing. 158 CPR821 Client Project Report • The sticker was incorrectly placed on some ISOFIX anchorages so that it still showed part red when connected correctly. This is contrary to the requirements of Reg.44. • The Regulation 44 approval label was included as an image in the instruction markings on the side of the restraint. • It was quite easy to peel the instruction markings off the product. • The ISOFix anchorages deformed, but did not detach, during the side impact tests and the restraint was difficult to remove from test bench in two of the tests. D.2.2 High rated restraint – Maxi-Cosi Priorifix • The instruction markings were peeling off on one seat prior to test. D.2.3 High sales restraint – Bebe Confort Iseos • The top tether indicator indicated green at around 15N, during the setup of the Q1 test. This means the tether will appear to the consumer to be suitably tightened, when actually it could be significantly tighter, therefore improving the dynamic performance of the CRS. • The adjuster strap appeared to slip through the adjuster by 2mm in the Q3 test. D.3 Forward facing non-integral restraints D.3.1 Low rated restraint – Jane Monte Carlo • The ISOFix anchorages had to be moved forward in x-axis to 55mm from CR point in the front impact tests to allow attachment of the restraint. This may mean there could be a compatibility issue with vehicle in the current fleet, causing a problem if this CRS was approved as “universal” under the new regulation (as there would not be a vehicle application list). • The adjustable head pad split on right hand-side during the front impact with the Q3. • The adjustable head pad split on both sides during the front impact with the Q6. This meant the belt guide was no longer attached to the main part of the restraint. This would be a fail of the current Reg.44 dynamic testing requirements (7.1.4.1.8). D.4 Side impact TRL • The seat back cushion had torn at the “T” join on the impact side • The belt anchorages limit the ISOFix displacement, which may or may not be representative. 159 CPR821 Client Project Report Appendix E Review of the Implementation Phasing of the new Regulation E.1 Introduction It has been proposed by the Informal Group that the new regulation should be introduced in three phases to expedite its progress: • Integral i -Size ISOFix CRSs • Integral and non-integral i -Size ISOFix CRSs • All CRSs In addition to the above, there are potentially two approval routes that could be followed: • Approval of a CRS to either Reg.44 or the new regulation (single approval) • Approval of a CRS to Reg.44 and the new regulation simultaneously (dual approval). This phased introduction may have a number of potential effects and the interactions between the phasing and the approval routes may have implications for consumers and for manufacturers, and these are discussed in the following sections. E.2 Definitions It is proposed by the Informal Group that the implementation of the new Regulation be split into three phases, each incorporating different types of restraints. At this stage, how long each phase will last has not been defined. However, CRS models are estimated to last at least a minimum of 3 years. The restraint type categories for Reg.44 and the proposed new Regulation are shown in Table 69, and the terms used are explained in Table 70. The phases are described in Section E.3. Table 69: Restraint type categories Restraint type New regulation categories Belted-only integral or non-integral universal integral universal or semiuniversal or specific vehicle integral universal or semiuniversal or specific vehicle ISOFixintegral ISOFix or Belted, integral ISOFix-non integral TRL non-integral Reg.44 categories semiuniversal New regulation sizing ? Defined by height range and Child + CRS • [33 kg] Defined by height range and Child + CRS • [33 kg] Defined by height range and Child + CRS • [33 kg] 160 Reg.44 mass Groups Group 0+ Group I Group II/III Description Restraints (with or without an integral restraint), installed using only the adult seat-belt Group 0+ Group I ISOFix-only seats with an integral restraint (no seatbelt attachment) Group 0+ Group I CRSs can be installed using the seat-belt or ISOFix attachments; in both cases the occupant has an integral restraint Group II/III Non-integral CRSs installed using the seatbelt, but with additional anchorages attaching to the ISOFix anchorages CPR821 Client Project Report Table 70: Definitions Term Explanation ISOFix The CRS is installed in a vehicle using the ISOFix anchorages located in a vehicle, defined in Reg.14 Belted The CRS is installed in a vehicle using the vehicle seat-belt Integral The CRS has an integral restraint as the primary means of holding the occupant in the CRS, Non-integral The CRS uses a method external to the CRS as the primary means of restraining the occupant, e.g. seat-belt Universal For Reg.44, the CRS is able to be installed in most positions in the vehicle. For Reg.44 ISOFix the CRS has a top tether anti-rotation device. Semi-universal Examples of semi-universal CRSs: Specific vehicle Anti-rotation device Reception area • Forward facing restraints equipped with support leg • Rearward facing restraints equipped with a support leg or a top tether strap • Rearward facing restraints, supported by the vehicle dashboard, for use in the front passenger seat • Lateral facing position restraint equipped if needed with an antirotation device A CRS that can only be used with specific vehicle types This is a device intended to limit the rotation of the child restraint system during an impact consisting of either: • A top-tether strap fitted top tether anchorages (defined in Reg.14) • A support leg contacting the vehicle floor area (to be defined in Reg.14) This will be a defined volume representing the possible placement positions, of a support leg onto a vehicle floor. This will be defined in Reg.14 and 16. E.3 Implementation phases E.3.1 Phase 1 The first implementation phase will only introduce ISOFix integral CRSs into the new Regulation. This includes the current Reg.44 Group 0+ and Reg.44 Group I CRSs with integral restraint, whether universal, semi-universal or for a specific vehicle. However, to introduce these as “universal” (which requires the CRS to have an anti-rotation device) will mean an alternative 3rd attachment point needs to be defined for CRSs which have a support leg. The proposed first implementation phase of the new Regulation is shown in Figure 75: the first column shows the Reg.44 categories that will remain in force during the first phase, and the second column shows the new Regulation categories that will be introduced to exist in parallel with Reg.44. TRL 161 CPR821 Client Project Report Phase 1 Reg.44 Approval new Regulation Approval Belted only ISOFix integral ISOFix or Belted, integral ISOFix non-integral ISOFix integral Figure 75 – new Regulation implementation Phase 1 E.3.2 Phase 2 The second implementation phase will introduce CRSs that primarily restrain the occupant using the vehicle seat-belt, but which have additional anchorages that also attach to the ISOFix anchorages in the vehicle. These CRSs are typically booster systems (Reg.44 Group II/III). However, to introduce these as “universal” requires the location of the ISOFix and belt anchorages in the vehicles to be aligned so that the restraints can be installed correctly. Integral ISOFix-only and ISOFix non-integral CRSs, will no longer be able to be approved to Reg.44. Figure 76 summarises the implementation for phase 2. Phase 2 Reg.44 Approval new Regulation Approval Belted only ISOFix or Belted, integral ISOFix integral ISOFix non-integral Figure 76 – new Regulation implementation Phase 2 E.3.3 Phase 3 The final implementation phase will incorporate the remaining restraints and will mean that Regulation 44 is no longer used. This means all restraints that are installed using the vehicle seat-belt, and restraints which have the option to use either ISOFix or seatbelt installation will be included into the new Regulation, along with integral and nonintegral ISOFix CRSs. Figure 77 summarises the implementation for phase 3. Phase 3 Reg.44 Approval new Regulation Approval None Belted only ISOFix integral ISOFix or Belted, integral ISOFix non-integral Figure 77 – new Regulation implementation Phase 3 TRL 162 CPR821 Client Project Report E.4 Approval routes There are several different implications for manufacturers and consumers depending on whether CRSs are allowed to have only a single approval, to Reg.44 or the new Regulation, or a dual approval to both Regulations simultaneously. For example, if dual approval was possible, during phase 1 an ISOFix-only integral CRS could be approved to the Reg.44 regulation as well as the new Regulation. If only a single approval is possible, the manufacturer would have to choose which of the two regulations to approve the CRS to. E.4.1 Single approval With the single approval option, a CRS could only be approved to one of the regulations. Figure 78 shows the different approval options for each type of CRS, during each implementation phase of the new Regulation, and these options are discussed in more detail in the following sections. E.4.1.1 Phase 1 Belt-attached integral and non-integral CRSs All belt-attached integral and non-integral CRSs will remain approved to Reg.44 under Phase 1. ISOFix-only integral CRSs Manufacturers would have the choice whether they wish to approve their CRSs to the new Regulation or Reg.44 during Phase 1. After Phase 1, manufacturers would only be able to approve these CRSs to the new Regulation and therefore for products with a long life-span, approving to the new Regulation would be beneficial. However, there will most likely be a phasing-out process, allowing CRSs already approved to Reg.44 time to switch to the new Regulation before they can no longer be sold. Currently, the number of ISOFix-only CRSs is low, and therefore the number of CRSs affected by this Phase may be small. However as the new Regulation aims to improve CRS design by introducing more stringent assessment criteria, CRSs that have the option of being attached with the adult belt may be phased out and replaced by CRSs specifically designed as ISOFix-only. Initially there may also be an attraction for some manufacturers to approve their products to the new Regulation to exploit the marketing value it may bring. However, manufacturers of CRSs with lower performance and low-cost/high-volume sales may avoid approving to the new Regulation until it is compulsory. ISOFix-or-belt-attached integral CRSs Implementation of Phase 1 of the new Regulation will mean that CRSs that can be installed using either ISOFix or the seat-belt will continue to be approved to Reg.44. These CRSs are currently the most common type of ISOFix restraints in the market place. This type of CRS typically contains the belt guides on the CRS itself (Group I), or have a separate base for ISOFix attachment (typically infant carriers). Excluding this type of restraint from Phase 1 could lead to a two-tiered ISOFix structure. The ISOFixonly CRSs may be dynamically better performers (due to the stricter approval requirements), but not as desirable to the consumer, as they are constrained to only fitting into vehicles with ISOFix anchorages and not able to be fitted into a second vehicle using the seat-belt. Vehicle manufacturers will also have to indicate which size of CRSs and which regulation their vehicle seating positions are compatible with. ISOFix non-integral CRSs ISOFix non-integral CRSs will continue to be approved to Reg.44 under Phase 1. TRL 163 CPR821 Client Project Report E.4.1.2 Phase 2 Belt-attached integral and non-integral CRSs All belt-attached integral and non-integral CRSs will remain approved to Reg.44 under Phase 2. ISOFix integral CRSs All ISOFix integral CRSs will be approved to the new Regulation. ISOFix-or-belt-attached integral CRSs These child restraints will still have to be approved to Reg.44. This again could lead to a two-tier ISOFix performance in the market place. It could also lead to a slow take-up of the new regulation if the majority of CRSs continue to be designed so that they can also be attached using the seat-belt. These systems may be preferred by the consumer for the flexibility to use it in a second vehicle. However, it could be argued that by the time this phase is introduced, compulsory ISOFix in vehicles will have been around for sufficient time (since 2006 for new vehicles) that the large majority of the vehicle fleet will have ISOFix anchorages. ISOFix non-integral CRSs These CRSs will only be able to be approved to the new Regulation. These CRSs are currently approved as “semi-universal” in Reg.44. However, in the new Regulation the idea is for them to be “universal”, thus not requiring a vehicle application list. For this to occur, the seat-belt anchorages and the ISOFix anchorages will need to be aligned in the vehicle, to avoid poor fitment of the seat-belt across the occupant. Currently, there are vehicles where the ISOFix anchorages are offset from the seat-belt anchorages. Some products may have compatibility issues with the new Regulation and thus the manufacturers may choose to maintain approval to Reg.44 until it is phased out. This does not encourage design improvement. However, it is thought that new products will be designed to meet the requirements of the new Regulation. E.4.1.3 Phase 3 All remaining CRS types will be approved to the new Regulation, and Reg.44 will cease to exist. However, it may be very challenging for belt-attached CRSs to gain type approval to the increased performance requirements proposed in the new regulation. E.4.2 Dual approval With this option a CRS could be approved to either one of the Regulations or both. Figure 79 shows the different approval options for each type of CRS, during each implementation phase of the new Regulation. E.4.2.1 Phase 1 Belt-attached integral and non-integral CRSs All belt-attached integral and non-integral CRSs will remain approved to Reg.44 under phase 1. ISOFix integral CRSs TRL 164 CPR821 Client Project Report CRS manufacturers would have the choice to approve their CRSs to the new Regulation, to Reg.44, or to both Regulations during Phase 1. As previously mentioned, the number of ISOFix integral CRSs in the market is currently low and it is therefore unclear, during phase 1, how many of these restraints will be approved to the new Regulation. Manufacturers may see an attraction from the marketing value it may bring. However, manufacturers of CRSs with lower performance and low-cost/high-volume sales may avoid approving to the new Regulation until it is compulsory. Whether there will be a benefit for manufacturers to approve new products to both regulations is unclear. It is likely that manufacturers’ of existing CRSs, already with a Reg.44 approval, may also have the CRSs approved to the new Regulation. Manufacturers of new restraint designs may not see the cost-benefit of approving their product to two regulations and therefore may choose only to approve the restraint to the new Regulation. Products that cannot meet the requirements of the new Regulation may have to be approved to Reg.44. Dual approval of products does mean there may be a potential conflict between the current Reg.44 groups and the i-Size categories. The i-Size categories allow the manufacturers to design the CRS to any stature and maximum mass restriction of CRS+child•[33kg]. This could lead to conflicting child mass limits, which will confuse the consumer when choosing a CRS and when checking compatibility with their vehicle. ISOFix-or-belt-attached integral CRSs Implementation of Phase 1 of the new Regulation will mean that CRSs that can be installed using either ISOFix or the adult seat-belt can either be only approved to Reg.44, or only approved as an ISOFix CRS to the new Regulation and a belt-attached CRS to Reg.44. Potentially this could lead to three approval labels on a CRS. Also the CRS could be classed as “semi-universal” in Reg.44 and “universal” in the new Regulation (with alternative 3rd attachment point for CRSs with a support leg). This would be confusing to the consumer and may cause vehicle compatibility issues, especially with older vehicles. ISOFix non-integral CRSs ISOFix non-integral CRSs will remain approved to Reg.44 under Phase 1. E.4.2.2 Phase 2 Belt-attached integral and non-integral CRSs All integral and non-integral belt-attached CRSs will remain approved to Reg.44 under Phase 2. ISOFix integral CRSs All ISOFix integral CRSs will be approved to the new Regulation. ISOFix-or-belt-attached integral CRSs These CRSs could be approved to Reg.44, or approved to the new Regulation as ISOFix installed and to Reg.44 as a belt-attached restraint. This could lead to confusing the consumer due to separate approval labels for ISOFix and belt attachments. Double documentation will also be required, in terms of sizing and mass limits between the use as an ISOFix CRS and a belt-attached CRS. ISOFix non-integral CRSs Manufacturers would have the choice whether they wish to approve this type of CRS to the new Regulation, to Reg.44 or both, during Phase 2. At this stage it is unclear whether a manufacturer would get a great benefit from approving their CRS to both TRL 165 CPR821 Client Project Report regulations. Currently, in order for this type of CRS to enter the new Regulation as “universal”, the belt and ISOFix anchorages will have to be aligned in the vehicle, to avoid poor fitment of the seat-belt across the occupant. “Universal” also means that the restraint fits all potential ISOFix vehicle positions (approved for the ISOFix CRS size category), thus removing the need for vehicle application lists. Alternatively this category could remain “semi-universal”. As previously mentioned, during the dynamic testing of the CRSs, some products were found to have compatibility issues with the new Regulation test bench and thus choose to remain approved to Reg.44 until it is phased out. This does not encourage design improvement. However, it is thought that new products will be designed to meet the requirements of the new Regulation. E.4.2.3 Phase 3 All remaining CRS types will be approved to the new Regulation and Reg.44 will cease to exist. However, it may be very challenging for belt-attached CRSs to gain type approval to the increased performance requirements proposed in the new regulation. TRL 166 CPR821 Client Project Report Phase 1 Integral CRSs Restraint category Attachment method Approval Regulation ISOFix only New Regulation Reg.44 Non-integral CRSs ISOFix or Belt Belt ISOFix & Belt Belt Reg.44 Reg.44 Reg.44 Reg.44 Phase 2 Integral CRSs Restraint Category Non-integral CRSs Attachment Method ISOFix only ISOFix or Belt Belt Approval Regulation New Regulation Reg.44 Reg.44 ISOFix Belt & Belt New Reg.44 Regulation Phase 3 Integral CRSs Restraint Category Non-integral CRSs Attachment Method ISOFix only ISOFix or Belt Belt ISOFix & Belt Belt Approval Regulation New Regulation New Regulation New Regulation New Regulation New Regulation Figure 78 – Three phases of the single approval option TRL 167 CPR821 Client Project Report Phase 1 Integral CRSs Restraint Category Attachment Method Approval Regulation ISOFix only New Regulation Reg.44 Non-integral CRSs ISOFix or Belt New Regulation & Reg.44 Reg.44 New Regulation (ISOFix attached) & Reg.44 (Belt attached) Belt ISOFix & Belt Belt Reg.44 Reg.44 Reg.44 Phase 2 Integral CRSs Restraint Category Attachment Method ISOFix only Approval Regulation New Regulation Non-integral CRSs ISOFix or Belt Reg.44 New Regulation (ISOFix attached) & Reg.44 (Belt attached) Belt ISOFix & Belt Reg.44 New Regulation Belt Reg.44 Phase 3 Integral CRSs Restraint Category Non-integral CRSs Attachment Method ISOFix only ISOFix or Belt Belt ISOFix & Belt Belt Approval Regulation New Regulation New Regulation New Regulation New Regulation New Regulation Figure 79 – Three phases of the dual approval option TRL 168 CPR821 Client Project Report E.5 Specific areas of concern E.5.1 Semi-universal category One of the original aims of the new Regulation was to make all ISOFix restraints “universal”, thus replacing the requirement for a vehicle application list. However, for this to be achieved a 3rd alternative attachment point is required in the vehicle, for restraints which currently use a support leg as the anti-rotation device. It has been proposed that the simplest way to achieve this would be to define a range of dimensions of the floor in relation to the ISOFix anchorages and make this consistent across all vehicles. Restraint manufacturers would then have to ensure that their CRS was capable of being adjusted to fit the defined range. However, it is unclear how this would be applied retrospectively to the existing fleet. In order for non-integral ISOFix CRSs to be “universal”, the adult belt and the ISOFix anchorages need to be aligned in the vehicle (Reg.14), otherwise unsatisfactory installation may occur. Again, whether this could be applied retrospectively to the existing fleet is unclear. Keeping the “semi-universal” category for this type of restraint, thus requiring a vehicle application list would solve this problem. Therefore the introduction of these products into the new Regulation may have to be delayed until the vehicle fleet is able to accommodate them correctly. E.5.2 Vehicle specific category The approval of vehicle specific CRSs will still be possible in the new Regulation. However, how a vehicle-specific side impact test can be achieved poses a problem, due to the requirement for an intruding door. One proposal is to use the results of a sledbased side impact test for the approval. E.5.3 i-Size Reg.44 mass groups ensure consistency amongst CRS sizing design in terms of mass range and related age. The proposed i-Size categorisation of CRS in the new Regulation will allow manufacturers the freedom to design the CRS for any size range they wish, as long as the combined mass of the CRS and child do not exceed the defined limit (limit not yet agreed). Therefore this has the potential that all CRSs in the market could be different, designed to accommodate different sizes children. This causes a problem for a consumer trying to compare CRSs, when they are all designed for different sized children. This also causes a problem when dynamically assessing the CRS. When testing a CRS in Reg.44, the minimum and maximum sized dummy for each Reg.44 ECE Group (or Groups) is used. According to the new Regulation, CRSs are tested with the minimum and maximum sized dummy of the defined i-Size range. An intermediate dummy can be tested if the installation of the CRS is substantially changed between the smallest and largest dummy, e.g. rearward/forward facing CRSs. This is subjective and open to misinterpretation. The draft Regulation does not mention if the change from integral to nonintegral requires testing with an intermediate dummy, e.g. Group I-II-III. The Technical Service is to choose which dummies will be appropriate to test with and this could lead to variation across test houses. E.5.4 Labelling A different set of labels will be required on the CRS due to the fact that CRSs approved to the new Regulation will have i-Size categorisation which is fundamentally different to the Regulation 44 Group categorisation. TRL 169 CPR821 Client Project Report Currently the Regulation 44 approval labels include: • ECE Regulation 44 Group(s) of the restraint • Mass range of the occupant for the restraint The i-Size labels will include: • Minimum stature of occupant • Maximum stature of occupant • Maximum mass of occupant However, CRSs such as those attached using ISOFix or the seat belt, could have dual approval during Phase 1 of the new Regulation implementation. This means the CRS would require three approval labels: • Regulation 44 universal for installation with the seat belt • Regulation 44 (semi-) universal for installation with ISOFix • new Regulation i-Size for installation with ISOFix These labels could potentially contradict each other based on the different requirements, of the Reg.44 mass range compared to the i-Size maximum mass and stature range, thus confusing the consumer. E.5.5 ISOFix vehicle compatibility Although it is proposed that currently the ISOFix size classes will remain unchanged, there remains an issue with the categorisation of CRSs in the new Regulation. Currently in Regulation 44, ISOFix child restraint systems fall into several ISOFix size classes described in Reg.16 Annex 17, Appendix 2, presented here in (Table 71). Table 71: Reg.16 ISOFix size category Reg.44 Mass Group Group 0 (0-10 kg) Group 0+ (0-13 kg) Group I (9-18 kg) TRL ISOFix size category Description F ISO/L1 Left Lateral Facing position CRS (carry cot) G ISO/L2 Right Lateral Facing position CRS (carry-cot) E ISO/R1 Rearward Facing infant CRS C ISO/R3 Full Size Rearward Facing toddler CRS D ISO/R2 Reduced Size Rearward Facing toddler CRS E ISO/R1 Rearward Facing infant CRS A ISO/F3 Full Height Forward Facing toddler CRS B ISO/F2 Reduced Height Forward Facing toddler CRS B1 ISO/F2X Reduced Height Forward Facing Toddler CRS C ISO/R3 Full Size Rearward Facing toddler CRS D ISO/R2 Reduced Size Rearward Facing toddler CRS 170 CPR821 Client Project Report Under the new i-Size categorisation, for a vehicle to be i-size ready it must be able to accept forward facing ISOFix CRSs in the ISO/F3 category and rearward facing ISOFix CRSs in the ISO/R2 category. However, limiting i-size approval to these sizes will mean that several vehicles are not compatible with these CRSs because they are too small to fit these size classes of restraints, whereas they are capable of fitting the small ISOFix classes. The vehicle handbooks will need to be updated to indicate which CRS types the vehicle can support in each seating position. So in addition to the current Regulation 44 groups, the handbook will have to indicate which i-Size CRSs the vehicle is compatible with. Currently in Reg.44 those CRS which can be used rearward or forward facing must state the maximum mass the occupant can remain rearward facing and the minimum mass the occupant can travel forward facing. In Regulation 44 the mass groups for this type of restraint are 0-13 kg and 9-18 kg. However, in the new Regulation the i-Size categories will state that occupant should not be forward facing before 15 or 18 months. This change will prevent very young children, who may be heavier than 9kg, from travelling forward facing, which is perceived to encourage more appropriate CRS use. The long term aim of changing the way CRSs are classified is to be less design restrictive towards the manufacturers and to make choosing CRSs easier for the consumer. All CRSs will have a height range and a maximum mass, defined by the manufacturer of the CRS. E.6 Summary The main differences between the two potential approval routes, and the main issues for both routes, are summarised in Table 72. The different approval routes and the issues arising from them have different implications for three key groups of stakeholders: consumers, CRS manufacturers, and car manufacturers. Some of the main issues for each group are summarised below. Issues for consumers It may be complex to understand the labelling and instructions, and whether they apply to particular vehicles. This is likely to be considerably more of a problem with dual approval, which could require up to three sets of labels, multiple instructions and multiple mass limits for a single CRS. Car manufacturers will have to label which size of CRS and which CRS Regulation each seating position is compatible with. This is a complex requirement for OEMs, and is likely to be very difficult for consumers to understand. This would apply for both single and dual approval routes. ISOFix integral CRSs - Both routes lead to adoption of the new Regulation by the beginning of Phase 2. ISOFix non-integral CRSs - In this case, the dual approval route may slow the pace of improvement in CRS safety, if maintaining Reg.44 approval is considered to be the straightforward option by CRS manufacturers. Overall, both routes lead to different types of restraint being approved to different Regulations at different times, and therefore offering different levels of safety. The potential combination of different vehicle seat labelling on each seat in multiple vehicles; different CRS mass limits, CRS labels and instructions; and different approvals for a single CRS is unlikely to reduce the already high incidence of misuse of CRSs. TRL 171 CPR821 Client Project Report Issues for CRS manufacturers Belt-attached integral or non-integral CRSs - There is no difference between the single and dual approval routes. It is not known how the belt-attached option would be approved under the new Regulation once this becomes mandatory in Phase 3. ISOFix integral CRSs - There is no obvious benefit to dual approval that would be sufficient to justify the cost of meeting two sets of approval requirements and of demonstrating conformity of production for both. ISOFix-or-belt-attached integral CRSs - The most straightforward route is for manufacturer’s to choose to continue to approve to Reg.44, because the alternative requires multiple approvals and multiple CoP, as well as multiple labelling and instructions which could be confusing to consumers and may therefore lead to an increase in complaints and enquiries. The only obvious benefit to dual approval for this CRS category would be if approval to the new Regulation was considered to be prestigious. Overall, if Reg.44 is considered to be the more straightforward, lower-cost option, CRSs may not be improved until Phase 3 is implemented, which will not encourage design improvements in the short to medium term. ISOFix non-integral CRSs - It is not known how the belt-attached option would be approved under the new Regulation. Issues for OEMs ISOFix or belt-attached integral CRSs - Car manufacturers will have to label the size of CRS and the CRS Regulations that each vehicle seating position is compatible with (Reg.14 and Reg.16 will need amending). TRL 172 CPR821 Client Project Report Table 72: Potential benefits and disbenefits if the proposed single approval or dual approval routes are used Restraint type Belted-attached Integral or non-integral Phase Single approval Dual approval Phase 1 Must be approved to Reg.44 Must be approved to Reg.44 Phase 2 Must be approved to Reg.44 Must be approved to Reg.44 Must be approved to the new Regulation Must be approved to the new Regulation Currently unknown how belt-attached option would be approved under the new Regulation Currently unknown how belt-attached option would be approved under the new Regulation Manufacturer to choose to approve to Reg.44, or the new Regulation Manufacturer to choose to approve to Reg.44, or the new Regulation, or both Phase 3 Phase 1 • May expect CRS with a long life-span to be approved to the new Regulation • May expect low-cost CRS with a short life-span and poor performing CRS to be approved to Reg.44 ISOFix-integral ISOFix-or-beltattached integral May expect most CRS to be approved to the new Regulation Currently low numbers of this CRS type; may increase if ISOFix-or-belt-attached CRS are phased out if the new Regulation is more stringent Currently low numbers of this CRS type; may increase if ISOFix-or-belt-attached CRS are phased out if the new Regulation is more stringent Dual approval could lead to conflicting mass requirements, which may be difficult for consumers to understand Phase 2 Must be approved to the new Regulation Must be approved to the new Regulation Phase 3 Must be approved to the new Regulation Must be approved to the new Regulation Must be approved to Reg.44 Must be approved to Reg.44 or Currently the most common CRS type Must be approved as ISOFix-attached to the new Regulation and belt-attached to Reg.44 Could lead to a two-tier system: ISOFix-only perform better, but ISOFix-or-belt-attached more attractive to consumers because they are more likely to fit a second vehicle Phase 1 • • • CRS manufacturers may focus on this type due to popularity/flexibility, but This would mean the new Regulation only applies to a minority of CRS Car manufacturers will have to label which size of CRS and which CRS Regulation each seating position is compatible TRL • 173 • CRS could be semi-universal in Reg.44 and universal in the new Regulation (if a third attachment point is defined), which could o Be confusing for consumers o Cause compatibility issues, especially with older vehicles May lead to multiple mass limits, approval labels and sets of instructions, which may be confusing CPR821 Client Project Report Restraint type Phase Single approval Dual approval with • for consumers Complex requirement for OEMs to implement and labelling would have to be applied for many years Difficult for consumers to understand Car manufacturers will have to label which size of CRS and which CRS Regulation each seating position is compatible with • Complex requirement for OEMs to implement and labelling would have to be applied for many years Difficult for consumers to understand Must be approved to Reg.44 Must be approved to Reg.44 or Ditto Phase 1 Must be approved as ISOFix-attached to the new Regulation and belt-attached to Reg.44 Phase 2 Ditto Phase 1 Phase 3 Must be approved to the new Regulation Must be approved to the new Regulation Phase 1 Must be approved to Reg.44 Must be approved to Reg.44 Must be approved to the new Regulation Manufacturer to choose to approve to Reg.44, or the new Regulation, or both Intended to be universal under the new Regulation so that a vehicle application list is not required • Phase 2 Requires seat-belt and ISOFix anchorages to be aligned which is not the case for all vehicles • ISOFix nonintegral Requires seat-belt and ISOFix anchorages to be aligned which is not the case for all vehicles Some CRS may have compatibility issues with the new Regulation, so may choose to remain with Reg.44 until Phase 3, which does not encourage design improvement Phase 3 TRL Currently semi-universal under Reg.44; intended to be universal under the new Regulation so that a vehicle application list is not required Must be approved to the new Regulation Must be approved to the new Regulation Ditto Phase 2 Ditto Phase 2 Currently unknown how belt-attached option would be approved under the new Regulation 174 Currently unknown how belt-attached option would be approved under the new Regulation CPR821 Client Project Report Appendix F Indications of the potential costs and benefits F.1 Introduction In 2007, the World Forum for Harmonization of Vehicle Regulations (WP 29) agreed to the establishment of a new GRSP Informal Group on Child Restraint Systems (CRSs). The remit of this Group is to consider the development of a new regulation for, ‘Restraining devices for child occupants of power-driven vehicles’, for consideration by GRSP. The aim is that this new regulation will contain front, side and rear dynamic impact assessments and will utilise a new family of child anthropometric devices for the assessment of the performance of CRSs. This report describes the results of an indicative cost-benefit analysis of the various regulatory proposals and options. It draws together available information on European child car occupant accident statistics, along with more detailed GB casualty data, and data gained on volume sales to provide an indication of the likely costs and benefits of the new regulation. F.2 Casualty valuations Putting a financial value on a human life or the prevention of a serious injury is notoriously difficult and controversial. Whilst no EU27 wide figures are currently available, each Member State necessarily uses its own figures for assessing the benefits of proposed safety measures. Methods of doing this vary, and there is as a result substantial variation in the figures used. In 2002, for example, the FP6 HEATCo project (Harmonised European Approaches for Transport Costing and Project Assessment) found fatality valuations ranging from €275,000 to €2.9million (HEATCO, 2006). The generally accepted method of valuing casualties combines the actual costs and lost output with a societal Willingness to Pay (WTP) amount, which reflects how much people generally would be willing to pay to avoid the pain, grief and suffering associated with a bereavement or injury. Fatality valuations performed in this way tend to be at the upper end of the range quoted above, the UK fatality valuation in 2002, for example, was €1.8million. For the purposes of this project, the UK valuations are considered to represent reasonable EU estimates. The most recent UK casualty valuations are shown in Table 73. Table 73: UK casualty valuations, 2008 (DfT, 2009) Casualty severity Cost per casualty (£) Killed 1,683,800 Serious 189,200 Slight 14,600 With the ongoing turmoil in financial markets across the world, the Pound:Euro exchange rate has been subject to quite significant variability over recent years. At the time of writing this report, the rate was about €1.16 to the £1, but had in the preceding three years been as low as €1.07 and as high as €1.45 (a value that was its steady-state for about 4 years prior to the start of the turmoil in 2007). Assuming a future long-term trend rate of €1.25 to £1 seems reasonable and produces the € casualty valuations shown in Table 74. TRL 175 CPR821 Client Project Report Table 74: Estimated EU casualty valuations Casualty severity Cost per casualty (€) Killed 2,105,000 Serious 236,500 Slight 18,250 These are thus the figures used to quantify the EU27 wide casualty prevention benefits of the proposed regulatory options. They fall comfortably within the wider range of valuations used in Member States. No allowance is made for the future effects of inflation or GDP growth (a society tends to be willing to pay more for casualty prevention as its overall wealth increases), nor of any age-related effects, e.g. that society may well place a higher than average value on the grief and pain associated with a child casualty. Such uncertainties and limitations with the casualty saving calculations are beyond the scope of this project. It is worth noting, however, that in attempting to allow for such uncertainties and approximations, the HEATCo project recommends that casualty benefits calculations are subjected to a sensitivity analysis by applying valuations in the range v/3 to 3v, where v is the central estimate. Whilst this recommendation is also considered outside of the scope of this project, it would mean that the true benefits calculated could be as high as 200% higher than the central estimates quoted (equivalent to a fatality valuation of about €6million), and as low as 67% lower (€700,000 fatality valuation). F.3 Options for assessment The likely costs and benefits of three regulatory options are analysed, and are described in the following sections. F.3.1 Option 1 – Q series dummies, existing frontal impact test This option represents the minimal regulatory change being considered. It involves keeping the existing (UNECE Regulation 44) frontal impact test (which uses a crash pulse originally developed in the 1970s), but replaces the P-series dummies with the more biofidelic Q-series devices, and makes use of this enhanced bio-fidelity by setting performance criteria for the neck loadings and chest compression (in addition to the head excursion and chest acceleration already regulated). In terms of injury prevention, this option would thus help to reduce neck and chest injuries in frontal impacts only. This option would also, it is assumed, implement changes to the head excursion limits currently permitted, thus also helping to prevent some head and face injuries in frontal impacts. F.3.2 Option 2 – plus a side impact test This option is the same as option 1 except for the addition of a side impact test procedure (the existing regulation 44 has frontal and rear impact tests only). This would thus have additional benefit (over and above Option 1) for casualties involved in side impacts only. F.3.3 Option 3 – with a new, more representative frontal impact test Driven largely by legislation, consumer information programmes, technological innovation and heightened consumer demand for safer vehicles, the impact absorbing structures and occupant protection systems of cars have changed radically over the last three or four decades. Front and side structures tend to be stiffer, meaning higher forces TRL 176 CPR821 Client Project Report are transmitted through them in an impact. Higher forces also mean higher decelerations. It is, therefore, unlikely that the crash pulse (50 km/h frontal impact) used in the existing Regulation 44 (based on data from crash tests carried out in the 1970s) is representative of crash pulses typically experienced by occupants of modern vehicles. This option corrects this anomaly, and can thus be expected to offer some additional casualty reduction benefit (over and above Option 1) in frontal impacts only. F.4 Target populations The following sections present an analysis of recent casualty data, both from Great Britain (the UK excluding Northern Ireland) and from other EU Member States, and uses those data to derive estimates of the overall annual numbers of child car occupant casualties (aged under 12) across the EU27. These numbers (of killed, serious and slight casualties) define the overall target populations for CRSs, i.e. the total numbers that could potentially be prevented. It should be noted that these target populations are not estimates of actual casualty savings from CRS use; they would only be equivalent to such estimates in the extremely unlikely scenario that all CRSs were 100% effective (i.e. they always saved the life or prevented the injury regardless of the accident conditions) and used 100% of the time (i.e. all child car occupants wore correctly fitted CRSs at all times). They are useful, however, in setting the baseline scenario, from which more realistic estimates of actual savings from each regulatory option are made. F.4.1 GB casualty data Details of all GB road accidents (involving an injury and reported to the police) are recorded in the national STATS19 database. The UK Department for Transport (DfT) publishes summary statistics from this database every year. Within that summary is a breakdown of the numbers of children, in various age groups, killed or injured while travelling as a car passenger, and for all road users. Table 75 shows the data for child car occupants aged under 12, and the total number of road user fatalities. Table 75: GB casualty data, 2006-2008 Severity Age Group Casualty type 2006 2007 2008 Average Killed <12 Car passengers 26 28 31 28 Serious <12 Car passengers 277 243 258 259 Slight <12 Car passengers 6,147 5,658 5,466 5,757 All <12 Car passengers 6,450 5,929 5,755 6,045 Killed All All 3,172 2,946 2,538 2,885 It can be seen that in Great Britain between 2006 and 2008, 28 children aged under 12 were killed on average each year while travelling as car passengers, representing 0.97% of the 2,885 killed in all road accidents on average each year. It can also be seen that for each fatality there were, on average 9.25 seriously injured child casualties (=259/28) and 206 slightly injured children (=5757/28). It should also be noted that these data are based on the STATS19 database, i.e reported accidents only. They are, therefore, very much a lower estimate of the true casualty figures because inevitably some injury accidents do not get reported to the police. Whilst previous research suggests that the extent of under-reporting in the UK is far less than TRL 177 CPR821 Client Project Report in some other countries, it also suggests that some allowance for under-reporting should be made when making national casualty estimations. Recent estimates (reported as part of the HEATCo project) suggest that UK serious injuries are under-reported by a factor of somewhere between 1.1 and 1.18, and slights by between 1.22 and 1.43. While there is no discernible under-reporting of fatal injuries, the HEATCo project further described how a correction factor of 1.02 was needed for fatality estimates to allow for those deaths directly attributable to the accident but occurring more than 30 days after the accident (these are not counted as fatalities in the official statistics but of course involve just as much pain, grief and suffering as those that occur less than 30 days after the accident and should, therefore, be valued similarly). These findings are combined in Table 76 to provide both lower (based on STATS19 only) and upper annual estimates for Great Britain. The upper numbers use factors of 1.02 for the fatalities, 1.15 for the serious injuries and 1.3 for the slight injuries. Table 76: Lower and upper annual GB casualty estimates, child car occupants <12 year old Killed Serious Slight All severities Lower estimate 28 259 5,757 6,045 Upper estimate 29 298 7,484 7,811 The following section uses these data to estimate equivalent EU27 numbers. F.4.2 EU27 casualty data and estimates Very detailed data on child car occupant casualties and restraint use are not available from all EU27 Member States, so other data sources will be needed to estimate the numbers involved. There are various methods by which such estimates can be made, but it is impossible to know whether any one of them gives a more accurate estimate of the true numbers than any other. For this reason, it is suggested that a variety of different methods be used and combined together to indicate the likely range. Three such methods are described in the following sections. F.4.3 EU27 Estimate Method 1 – GB data weighted by all road user fatalities What is generally believed to be a reliable and accurate measure of the total number of road user fatalities in each Member State is published each year by the European Commission (DG TREN Pocketbook, 2010). Fatalities tend, unsurprisingly, to have a very high likelihood of being reported and thus be recorded in official statistics, unlike lower severity accidents which often (how often varies between Member States) go unreported. Given that car designs are globally manufactured and distributed products, they tend not to vary very much between countries. It is therefore reasonable to assume that the numbers of fatal, serious and slight child casualties in the EU27 are distributed in a similar way to the GB case. It is thus possible to estimate the EU27 child car occupant casualty numbers by simply factoring up the GB estimates shown in Table 76 by the ratio of all EU27 fatalities to the total GB fatalities number. According to the 2010 Pocketbook, between 2006 and 2008 there were, on average, 41,478 road user fatalities per year across the EU27, compared with 2,885 in GB (Table 75), giving a weighting factor of 14.38 (=41478/2885). Table 77 shows the resulting EU27 estimates. TRL 178 CPR821 Client Project Report Table 77: Lower and upper annual EU casualty estimates, child car occupants <12 years old, Method 1 Killed Serious Slight All severities Lower estimate 403 3,724 82,786 86,913 Upper estimate 417 4,285 107,620 112,322 F.4.4 EU27 Estimate Method 2 – GB data weighted by car occupant fatalities For all but three Member States (Bulgaria, Lithuania and Slovakia), the 2010 Pocketbook also gives the numbers of car occupant fatalities for the latest available year (ranging from 2005 to 2008). On average, from the countries where data is available, about 50% of all road user casualties are car occupants. Using this percentage to estimate the numbers for the three countries, and adding those estimates to the known numbers for the 24 other Member States, gives a total for the EU27 of 19,350 fatalities per year. Data is only available for individual years (mostly 2007 or 2008), which vary from one country to another, so using this figure as an annual average assumes that the combined data is representative of the 2006-2008 average. The 2006-2008 average for GB is 1,434 car occupant fatalities per year, giving a weighting factor of 13.49 (=19350/1434). Table 78 shows the resulting EU27 estimates. Table 78: Lower and upper annual EU casualty estimates, child car occupants <12 years old, Method 2 Killed Serious Slight All severities Lower estimate 378 3,494 77,662 81,534 Upper estimate 391 4,020 100,959 105,370 F.4.5 EU27 Estimate Method 3 – GB data weighted by EU18 child car occupant fatalities and EU27 child road user fatalities Analysis of the CARE database (which also provides the EU27 statistics quoted in the preceding sections) and reported by the European Road Safety Observatory (ERSO, 2007) found that on average across the EU185, in 2005, 41% of all child road fatalities (aged <16) were car occupants (the latest year for which data is available). It further reports that, on average across the EU146 in 2005, 3.6% of all road user fatalities were aged under 16. More recent (2008) CARE data on child road fatalities suggests there were about 1,036 casualties aged <15 in the EU247 in 2008, and 1,260 aged 15-17. Comparing the 2005 data for <16 with the equivalent data from 2005 for the <15 and 15-17 age groups suggests that about 20% of the 15-17 year old fatalities are <16. Applying this figure to the 2008 data suggests there were about 1,288 road fatalities aged <16 in EU24 in 2008 (= 1036 + 0.2x1260). Assuming that 3.6% of all road user casualties in the three other 5 EU18 = EU27 minus Bulgaria, Czech Republic, Germany, Cyprus, Latvia, Lithuania, Romania, Slovenia and Slovakia. 6 EU14 = EU18 minus Estonia, Hungary, Malta and Poland. 7 EU24 = EU27 minus Bulgaria, Cyprus and Lithuania TRL 179 CPR821 Client Project Report Member States were aged <16 suggests there were 1,347 such casualties across the EU27 in 2008. If it is further assumed that 41% of those casualties were car occupants (as was found in 2005 for EU18), then approximately 552 children aged under 16 died in accidents while car occupants across the EU27 in 2008. The corresponding figure for GB is 49 fatalities in 2008, giving a weighting factor of 11.27 (=552/49). Table 79 shows the resulting EU27 estimates. Table 79: Lower and upper annual EU casualty estimates, child car occupants <12 years old, Method 3 Killed Serious Slight All severities Lower estimate 316 2,919 64,881 68,116 Upper estimate 327 3,358 84,345 88,030 F.4.6 Summary of EU casualty estimates Table 80 gives the overall range of casualty estimates for the EU27 arising from the three methods described above, and which thus form the overall target populations for CRSs. Applying the casualty valuations derived earlier (Table 74) implies that the societal cost of these casualties is somewhere between €2.5billion and €3.9billion per year. Table 80: Lower and upper annual EU casualty estimates, child car occupants <12 years old Killed Serious Slight All severities Lower estimate 316 2,919 64,881 68,116 Upper estimate 417 4,285 107,620 112,322 F.5 Benefits estimate The following sections provide estimates of the likely casualty savings, in both human and monetary terms, from the various CRS regulatory options described in section F.3. It is important to note that such estimates can only be regarded as, at best, indicative. Only very detailed and in-depth accident studies, involving a large number of cases, could hope to provide a truly robust assessment of the likely effectiveness of new CRS design and performance options. Such in-depth studies, involving the accurate simulation and modelling of real-world collisions and injury mechanisms, is well beyond the scope of this project. Even with such analyses, of course, one cannot be absolutely certain that the accidents studied are truly representative of future collision scenarios. The indicative methods described more fully in the following sections use a combination of summary data from previous published in-depth studies and data indicating the effects of past legislative changes. Estimates are then further modified with assumptions TRL 180 CPR821 Client Project Report about what proportion of child car occupants would be likely to be using a correctly fitted CRS. F.5.1 Effects of previous legislative changes The effects of past legislative changes with regard to seat belt use and CRS design were analysed by TRL for the EC’s CHILD project (Visvikis et al., 2008). When looking at GB national casualty data, it was found that two step changes (reductions) in the annual numbers of child car passenger casualties were evident; one that matched the mandated wearing of rear seat belts in 1989 and the other corresponding to implementation of the 03 series of amendments to UNECE Regulation 44 in 1998. The averaged percentage casualty reductions found, by severity, are shown in Table 81. Given that both of these measures were likely to only significantly affect frontal impacts, the percentage reductions shown (which are for all impact types) could reasonably be expected to have been even higher for the target populations (i.e. frontal impact casualties only). Research for the NPACS project (Cheung and Le Claire, 2006) showed, for example, that frontal impacts account for about 50 per cent of child car occupant casualties, suggesting that the effectiveness of the legislative changes could be as high as double the percentages shown in Table 81. Table 81: Step change effects in GB of previous legislative changes Casualty severity Killed Serious Slight Minimum reduction (%) 10.7 12.2 1.5 Maximum reduction (%) 24.7 17.9 4.6 Average reduction (%) 17.7 15.1 3.1 It is also appropriate to note, however, that the law of diminishing returns is likely to apply, i.e. that further legislative changes may not have as much of an effect as past changes, because the remaining casualties are those that are particularly hard to prevent, e.g. they arise from very high speed/high energy impacts or because some parents/guardians/drivers choose not to make proper use of the CRSs available for the children in their care. F.5.2 Usage rates Another important determinant of the effectiveness of CRS legislation is the wearing rate, i.e the proportion of children that correctly use a CRS in practice. In the UK, wearing rates are routinely surveyed, and in 2009, about 70% of children (aged < 10) were in a correctly used child seat or booster seat/cushion, up from about 40% when surveying began in 2005. This level of detail is not available elsewhere in the EU, but surveys of seat belt use show rates varying between about 80-95% for front seat passengers (all ages) and 25-75% for rear seat passengers. Seat belt use in general, and child restraint use in particular, are believed to be rising steadily, in response, for example, to co-ordinated public safety campaigns. While some countries, e.g. the UK, may well aspire to CRS usage rates of 80% or more in the next few years, others are likely to be some way behind. For the purposes of this project, it is assumed that a rate of 60% is the likely overall average rate across the EU27. F.5.3 Option 1 – Q series dummies, existing frontal impact test This option would deliver some additional benefits (over and above existing restraint designs) through the provision of new performance limits in additional body regions, TRL 181 CPR821 Client Project Report reflecting the enhanced capabilities of the Q-series dummies. It would mitigate some head, face, neck and chest injuries not preventable by existing CRS designs. These changes are assumed to be similar in magnitude to previous legislative changes, e.g. the adoption of the 03 series of amendments to UNECE Regulation 44 which led to one of the step changes in the numbers of GB child car occupant casualties described in section F.5.1. Although such changes led to reductions of anything up to 25% (for all casualty types, so perhaps as high as 50% for those in frontal impacts), the law of diminishing returns might mean that future changes are not quite so dramatic. For the purposes of this (indicative) cost benefit analysis, it is assumed that this option would: • Convert 10% of frontal impact fatalities to serious injuries; • Convert 12% of frontal impact serious injuries to slight injuries; • Convert 2% of the frontal impact slight injuries to uninjured. If it is further assumed that frontal impacts account for 50% of all child car occupant casualties, of all severities, and a CRS usage rate of 60% applies, then the overall benefits of this option would be as shown in Table 82. Table 82: Likely casualty and monetary benefit estimates of option 1, EU27 Severity Potentially preventable Actually prevented €m valuations (note 2) (note 3) (note 1) Lower Upper Lower Upper Lower Upper Killed 95 125 10 13 18.7 24.3 Serious 876 1286 105 154 22.9 33.6 Slight 19,464 32,286 389 646 7.1 11.8 All 20,435 33,697 504 813 48.7 69.7 Note 1 – assumes 50% of target populations are in frontal impacts and 60% use CRSs Note 2 – assumes mitigation of 10% fatalities, 12% serious, 2% slights Note 3 – uses valuations given in Table 75 (and each casualty reduced by one severity level) F.5.4 Option 2 – plus a side impact test This option is the same as option 1 but for the addition of a side impact test. Previous accident studies (for the NPACS project) found that about 20% of child car occupant casualties were in side impacts. The assumed coverage of this option is thus 70% of all casualties (the 50% for frontal impacts used in option 1 plus the extra 20% for side impacts). If all other option 1 assumptions about usage rates and effectiveness are retained, then the overall benefits would be as shown in Table 83. Table 83: Likely casualty and monetary benefit estimates of option 2, EU27 Severity Potentially preventable Actually prevented €m valuations (note 2) (note 3) (note 1) Lower TRL Upper Lower 182 Upper Lower Upper CPR821 Client Project Report Killed 133 175 13 18 24.3 33.6 Serious 1,226 1,800 147 216 32.1 47.1 Slight 27,250 45,200 545 904 9.9 16.5 All 28,609 47,175 705 1,138 66.3 97.2 Note 1 – assumes 70% of target populations are in side or frontal impacts, 60% use CRSs Note 2 – assumes mitigation of 10% fatalities, 12% serious, 2% slights Note 3 – uses valuations given in Table 75 (and each casualty reduced by one severity level) F.5.5 Option 3 – with a new, more representative frontal impact test This option would enact a more significant change to the frontal impact test procedure (over and above the changes described under option 1), providing a test procedure that is more representative of modern vehicles and thus more likely to prevent casualties amongst occupants of those vehicles. Although the overall numbers of casualties potentially preventable would be unchanged from option 2, it seems reasonable to assume that the step change effects would be slightly higher than assumed for the other options. It is thus assumed that this option would: • Convert 20% of frontal impact fatalities to serious injuries; • Convert 15% of frontal impact serious injuries to slight injuries; • Convert 4% of the frontal impact slight injuries to uninjured. Applying these new effectiveness factors to the frontal impact casualties, and keeping the factors the same as option 2 for the side impact casualties gives the overall benefits shown in Table 84. Table 84: Likely casualty and monetary benefit estimates of option 3, EU27 Severity Potentially preventable Actually prevented €m valuations (note 2) (note 3) (note 1) Lower Upper Lower Upper Lower Upper Killed 133 175 22 30 41.1 56.1 Serious 1,226 1,800 173 255 37.8 55.7 Slight 27,250 45,200 935 1,549 17.1 28.3 All 28,609 47,175 1,130 1,834 96.0 140.1 Note 1 – assumes 70% of target populations are in side or frontal impacts, 60% use CRSs Note 2 – assumes mitigation of 20/10% fatalities, 15/12% serious, 4/2% slights for frontals/side impacts respectively Note 3 – uses valuations given in Table 75 (and each casualty reduced by one severity level) TRL 183 CPR821 Client Project Report F.5.6 Summary of benefits estimates The lower and upper likely annual casualty prevention benefits, in €m, for the EU27 can be summarised as follows: Option 1: €49m - €70m; Option 2: €66m - €97m; Option 3: €96m - €140m F.5.7 Costs estimate Manufacturers would be likely to incur additional costs in product development, product testing and production, over and above existing CRS designs, if new legislative requirements are placed on their products. These costs would in most cases be passed on to consumers. The full extent of these additional costs depends largely on two factors – the size of the market (i.e. the numbers of CRSs sold each year across the EU27) and the per unit additional costs. F.5.8 Market size Unpublished data provided by industry for the purposes of this project suggests that in the UK in 2009, about 1.53million car seats were sold to UK consumers. This is equivalent to about 1.9 CRSs for every child born (there were about 794,000 births in the UK in 2008). In France, the same sources suggest that 1.09million car seats were sold, at a rate of about 1.3 seats per birth (835,000 births in France in 2008). These variations are likely to be due to variations in restraint usage rates. If the 1.9 CRSs per birth for the UK corresponds to the measured current usage rate in the UK of 70%, then it is possible to estimate that an EU27 wide usage rate of 60% (as assumed in the benefits estimations) would dictate that 1.6 CRSs per birth are needed (=1.9 x 60/70). Official (Eurostat) statistics indicate there were about 5.4million births in the EU27 in 2008, which would imply a total market size of about 8.6million CRSs to be sold each year. F.5.9 Marginal (per unit) costs to manufacturers It is likely that there will be quite significant variations in the costs incurred by manufacturers, and passed on to consumers, as they will depend on a number of factors, including: • The extent to which existing designs already exceed current requirements and would need to be modified to pass the new ones; • The existing profit margin and the effects of any increased prices on that products’ competitive positioning relative to other products; • The capability and capacity of the manufacturer to develop and manufacture new designs cost effectively. Earlier research (Visvikis et al., 2008)) estimated that the annual costs to UK manufacturers of various CRS options being considered varied between £0.3m and £4.9m. These costs include additional tests and product development costs and imply a per unit cost of between 20p and £3.27 for the 1.5million units sold each year in the UK. Other recent unpublished research for the UK Department for Transport (2008) suggested costs of between 15p and £5.75 per unit. Information provided in confidence by one major CRS manufacturer for this project gives indicative costs (for an option 2 type scenario) of about €1.5 to €2 per CRS, which is TRL 184 CPR821 Client Project Report comfortably within the ranges suggested by the earlier research. It is outside of the scope and capability of this project to undertake detailed analyses of the costs associated with each regulatory option, so for the purposes of this indicative study it is assumed that: • Option 1 would cost between €0.5 and €1.5 per unit; • Option 2 would cost between €1.5 and €2.5 per unit; • Option 3 would cost between €2 and €5 per unit F.5.10 Summary of cost estimates Although it is possible that the costs incurred by manufacturers would not be wholly passed on to consumers, it is also possible that the enhanced capabilities of the new CRS designs are used to justify additional retail price increases (on the back of marketing as improved, safer products). Information provided by industry as part of this project suggests that overall mark-ups of about 30% are typical for existing CRS designs. For the purposes of this project a range of mark-ups from 10% to 30% are assumed. Applying the per unit costs of each option in section F.5.9 to these cost-to-consumers mark-up rates and the market size estimate of 8.6million CRSs per year gives annual total likely cost estimates of: • • • Option 1 – Q series dummies, existing frontal impact test o Lower estimate: 0.5x1.1x8.6 = €4.7m o Upper estimate: 1.5x1.3x8.6 = €16.8m Option 2 – plus a side impact test o Lower estimate: 1.5x1.1x8.6 = €14.2m o Upper estimate: 2.5x1.3x8.6 = €28.0m Option 3 - with a new, more representative frontal impact test o Lower estimate: 2x1.1x8.6 = €18.9m o Upper estimate: 5x1.3x8.6 = €55.9m F.5.11 Benefit:Cost ratios Combining the estimates derived in sections F.5 and F.5.7, gives the overall ranges of estimated benefit-cost ratios shown in Table 85. The lower limits of these ranges are calculated by combining the lower benefit estimates with the upper cost estimates, and the upper limits are calculated by dividing the upper benefit estimates into the lower cost estimates. Table 85: Summary of benefits and costs for each option Option Option 1 Option 2 Option 3 TRL Benefits (€m) Lower Upper 48.7 69.7 66.3 97.2 96.0 140.1 Costs (€m) Lower Upper 4.7 16.8 14.2 28.0 18.9 55.9 185 Benefit:Cost ratios Lower Upper 2.9 :1 14.8 :1 2.4 :1 6.8 :1 1.7 :1 7.4 :1 CPR821 Client Project Report It must be emphasised that these figures are necessarily based on various assumptions, as described in the earlier sections, and are therefore subject to considerable uncertainty. It is apparent, however, that the broad indications from this study are that the benefit to cost ratios of all the options being considered are likely to be positive, i.e. the benefits derived from reduced casualties are likely to exceed the extra costs incurred by EU27 consumers, by a factor of somewhere between 2 and 15, depending on which option is chosen. F.6 Summary In 2007, the World Forum for Harmonization of Vehicle Regulations (WP 29) agreed to the establishment of a new GRSP Informal Group on Child Restraint Systems (CRSs). The remit of this Group is to consider the development of a new regulation for, ‘Restraining devices for child occupants of power-driven vehicles’, for consideration by GRSP. This report describes the results of an indicative cost-benefit analysis of the various regulatory proposals and options. It draws together available information on European child car occupant accident statistics, along with more detailed GB casualty data, and data gained on volume sales to provide an indication of the likely costs and benefits of the new regulation. Three regulatory options have been assessed: Option 1 – Q series dummies, existing frontal impact test This option involves keeping the existing (UNECE Regulation 44) frontal impact test, but replaces the P-series dummies with the more bio-fidelic Q-series devices, and makes use of this enhanced bio-fidelity by setting performance criteria for the neck loadings and chest compression. In terms of injury prevention, this option would thus help to reduce neck and chest injuries in frontal impacts only. This option would also, it is assumed, implement changes to the head excursion limits currently permitted, thus also helping to prevent some head and face injuries in frontal impacts. Option 2 - plus a side impact test This option is the same as option 1 except for the addition of a side impact test procedure (the existing regulation 44 has frontal and rear impact tests only). This would thus have additional benefit (over and above Option 1) for casualties involved in side impacts only. Option 3 – with a new, more representative frontal impact test The impact absorbing structures and occupant protection systems of cars have changed radically over the last three or four decades. It is, therefore, unlikely that the crash pulse (50 km/h frontal impact) used in the existing Regulation 44 (based on data from crash tests carried out in the 1970s) is representative of crash pulses typically experienced by occupants of modern vehicles. This option corrects this anomaly, and can thus be expected to offer some additional casualty reduction benefit (over and above Option 1) in frontal impacts only. Three different methods of estimating the numbers of child (aged under 12) car occupant casualties each year in the EU27 have been used, all based on applying weighting factors to GB data. Applying casualty valuations to the overall range estimated, also derived from GB data, indicates a societal cost of somewhere between €2.5billion and €3.9billion per year. Data from child restraint usage surveys and accident analyses are used to estimate that 50% of child car occupant casualties are from frontal impacts, 20% are from side impacts, and to speculate that an overall future usage rate of 60% is a reasonable assumption for the EU27. These data are combined with the measured casualty TRL 186 CPR821 Client Project Report reduction effects of previous legislative changes to produce EU27 estimates of the benefits of the various options. Demographic data and information provided by the CRS industry are combined to produce estimates of the likely costs (to consumers) of implementing the various options, based on costs incurred by manufacturers for new product development and testing. Combining the benefit and cost estimates gives the overall ranges of estimated benefitcost ratios shown in Table 86. Table 86: Summary of benefits and costs for each option Option Option 1 Option 2 Option 3 Benefits (€m) Lower Upper 48.7 69.7 66.3 97.2 96.0 140.1 Costs (€m) Lower Upper 4.7 16.8 14.2 28.0 18.9 55.9 Benefit:Cost ratios Lower Upper 2.9 :1 14.8 :1 2.4 :1 6.8 :1 1.7 :1 7.4 :1 These figures and ratios are necessarily based on various assumptions, as described in the main body of this report, and are subject to considerable uncertainty. It is apparent, however, that the broad indications from this study are that the benefit to cost ratios of all the options being considered are likely to be positive, i.e. the benefits derived from reduced casualties are likely to exceed the extra costs incurred by EU27 consumers, by a factor of somewhere between 2 and 15 to one, depending on which option is chosen. TRL 187 CPR821 Client Project Report Bibliography Arbogast K., Ghati Y., Menon R., Tylko S., Tamborra N. and Morgan R., (2005). Field Investigation of Child Restraints in Side Impact Crashes. Traffic Injury Prevention, 6:4, pp.351-360. Arbogast K., Kallan M., Durbin., (2009). Front versus rear seat injury risk for child passengers: evaluation of newer model year vehicles. Traffic Injury Prevention, 10:3, pp.297-301. Bennett T., Kaufman R., Schiff M., Mock C., Quan L., (2006). Crash analysis of lower extremity injuries in children restrained in forward-facing gar seats during front and rear impacts. Journal of Trauma, Injury, Infection and Critical Care, 61:3. Garcia-Espana J., Durbin D., (2008). Injuries to belted older children in motor vehicle crashes. Accident Analysis & Prevention, 40:6, pp.2024-2028. Fildes A., Charlton J., Fitzharris M., Langwieder K., Hummel T., (2003) Injuries to children in child restraints. International Journal of Crashworthiness, 8:3, 277-284. Lennon A., Siskind V., Haworth N., (2007). Rear seat safer: seating position, restraint use and injuries in children in traffic crashes in Victoria, Australia. Accident Analysis & Prevention, 40:2, pp.829-834. Jermakian J., Arbogast K., (2007). Lower extremity injuries in children seated in forward facing child restraint systems. Traffic Injury Prevention, 8:2, pp.171-179. Sherwood C., Ferguson S., Crandall J., (2003). Factors leading to crash fatalities to children in child restraints. Association for Advancement of Automotive Medicine 47th Annual Conference, Lisbon. 22nd-24th September 2003. Winston F., Durbin D., Kallan M., Elliott M., (2001) Rear seating and risk of injury to child occupants by vehicle type. 45th Annual Proceedings, association for the advancement of automotive medicine, San Antonio, Texas. 24th-26th September 2001. TRL 189 CPR821 Client Project Report References Brown J., Jing Y., Wang S., Ehrlich P., (2006). Patterns of Severe Injury in Pediatric Car Crash Victims: Crash Injury Research Engineering Network Database. Journal of Pediatric Surgery, 41:2. CARE Database. Number of fatalities by person class and age group by country 2005. http://ec.europa.eu/transport/road_safety/observatory/statistics/reports_graphics_en.ht m Cheung G and Le Claire M (2006). NPACS (New Programme for the Assessment of Child restraint Systems) Phase 1 Final Report. PR/VE/031/06: TRL final project report for the United Kingdom Department for Transport PPAD 9/33/128. Published May 2006. Czernakowski W., Otte D., (2001). How do interface conditions in motor vehicles and the modes of using child restraint systems (CRS) affect the injury severity of children in crashes? DG-TREN Pocketbook, 2010. EU Energy and Transport In Figures, Statistical Pocketbook 2010. Luxembourg: Publications Office of the European Union, 2010. Available at http://ec.europa.eu/energy/publications/statistics/doc/2010_energy_transport_figures.p df Digges K., Sahraei E., Samaha R., (2009). Opportunities to improve rear seat child safety. Protection of Children in Cars conference, 3-4 December 2009, Munich. European Enhanced Vehicle-safety Committee, (2006). EEVC working group 18 report: Child safety – February 2006. Retrieved June 24, 2006, from http://www.eevc.org/publicdocs/EEVC_WG18_REPORT_Child_Safety-February_20061.pdf EEVC, (European Enhanced Vehicle-safety Committee);. (2008). Q-dummies Report Advanced child dummies and injury criteria for frontal impact. EEVC Working Group 12 and 18 report, Document No. 514 (available from the EEVC web site http://eevc.org/publicdocs/publicdocs.htm ERSO, 2007. Traffic Safety Basic Facts 2006: Children (Aged <16). European Road Safety Observatory. Available at http://ec.europa.eu/transport/roadsafety_library/care/doc/safetynet/2007/bfs2007_sntrl-1-3-children.pdf HEATCO, 2006 - Developing Harmonised European Approaches for Transport Costing and Project Assessment. Deliverable 5: Proposal for Harmonised Guidelines. Available at http://heatco.ier.uni-stuttgart.de/ Jansch M., Otte D. (2009). Current situation of child occupant safety in German accidents. Protection of Children in Cars conference, 3-4 December 2009, Munich. Lesire P, Herve V and Kirk A, (2006). Analysis of CREST and CHILD accident data related to side impacts. Proceedings of the 4th International Conference “Protection of Children in Cars” 2006, December 7-8, 2006, Munich, Germany. Munich, Germany: TÜV Akademie GmbH. Luck, J. F., Nightingale, R. W., Loyd, A. M., Prange, M. T., Dibb, A. T., Song, Y., et al. (2008). Tensile mechanical proprties of the perinatal and pediatric PMHS osteoligamentous cervical spine. Stapp car crash journal, Volume 52: papers presented at the 52nd Stapp car crash conference (pp. 107-134). The Stapp Association. Lund, A. K. (2003). Recommended procedures for evaluating occupant injury risk from deploying side airbags. Insurance Institute for Highway Safety. Available from the IIHS internet site: http://www.iihs.org/ratings/protocols/pdf/twg_final_procedures.pdf. TRL 191 CPR821 Client Project Report Mertz H (1993). Anthropomorphic test devices. In A. Nahum and J. Melvin, Accidental Injury: Biomechanics and Prevention. New York: Springer-Verlag. Mertz, H. J., & Patrick, L. M. (1967). Investigation of the kinematics and kinetics of whiplash. Proceedings of the 11th Stapp car crash conference, 10-11 October 1967, Anaheim, California, U.S.A., SAE technical paper 670919 (pp. 267-317). Warrendale, Pennsylvania, U.S.A.: Society of Automotive Engineers, Inc. (SAE). Mertz, H. J., & Patrick, L. M. (1971). Strength and response of the human neck. Proceedings of the 15th Stapp car crash conference, 17-19 November 1971, San Diego, California, U.S.A., SAE technical paper 710855 (pp. 2903-2928). Warrendale, Pennsylvania, U.S.A.: Society of Automotive Engineers, Inc. (SAE). Mertz, H. J., Irwin, A. L., & Prasad, P. (2003). Biomechanical and scaling basis for frontal and side impact injury assessment reference values. Stapp car crash journal volume 47: papers presented at the 47th Stapp car crash conference (SAE technical paper 2003-220009). Society of Automotive Engineers, Inc. (SAE): Warrendale, Pennsylvania, U.S.A. Pitcher M, Halewood C, Carroll JA, Goodacre O, Fraser E, Gibson T, McGrath AM, Le Claire M (2008). Child seat consumer information project: protocol validation. Published Project Report (PPR 339). Crowthorne: Transport Research Laboratory (TRL). Prasad, P., Kim, A., & Weerappuli, D. P. (1997). Biofidelity of anthropomorphic test devices for rear impact. Proceedings of the 41st Stapp car crash conference, 13-14 November 1997, Lake Buena Vista, Florida, U.S.A., SAE technical paper 973342 (pp. 387-415). Warrendale, Pennsylvania, U.S.A.: Society of Automotive Engineers, Inc. (SAE). van Ee, C. A., Nightingal, R. W., Camacho, D. L., Chancey, V. C., Knaub, K. E., Sun, E. A., et al. (2000). Tensile properties of the human muscular and ligamentous cervical spine. Proceedings of the 44th Stapp car crash conference, 6-8 November 2000, Atlanta, Georgia, U.S.A., SAE technical paper 2000-01-SC07. Warrendale, pennsylvania, U.S.A.: Society of Automotive Engineers, Inc. (SAE). Viano D., Parenteau C., (2008). Fatalities of children 0-7 years old in the second row. Traffic Injury Prevention, 9:3 pp.231-237. Visvikis C, Le Claire M, Adams S, Carroll J, Hynd D (2007). Assessment of the Q dummy in the EC CHILD project, Published Project Report (PPR291). Crowthorne, UK: Transport Research Laboratory (TRL). Visvikis C, Le Claire M, Carroll j, Cuerden R, Bartlett R, Adams S, Hynd D (2008). CHILD: Advanced methods for improved child safety - final report, Published Project Report (PPR322). Crowthorne, UK: Transport Research Laboratory (TRL). Visvikis C, Pitcher M, Girard B, Longton A, Hynd M (2009). EPOCh: Task Number 1.1 Literature review, accident analysis and injury mechanisms. Wismans J, Waagmeester K, Le Claire M, Hynd D, de Jager K, Palisson A, van Ratingen M, Trosseille X (2008). Q-dummies Report: Advanced Child Dummies and Injury Criteria for Frontal Impact. EEVC Working Group 12 and 18 Report, Document No. 514. April 2008. Available from www.eevc.org. TRL 192 CPR821 Client Project Report Regulations and Standards Regulation No. Synthesis Draft 2010_02_iSize – uniform provisions concerning the approval of ISOFix integral/Enhanced child restraint systems used onboard motor vehicles. Regulation No. 44 – uniform provisions concerning the approval of restraining devices for child occupants of power-driven vehicles ("child restraint system"). ISO TC22/SC12 (2009). ISO/PDPAS 13396 – Road vehicles – sled test method to enable the evaluation of side impact protection of child restraints systems – Essential parameters (request of UNECE/GRSP). TRL 193 CPR821 Client Project Report GRSP Working Group documents The following list contains the references used from documents submitted to the GRSP informal working group for child safety. Where the reference code means: CRS-03-05 Working Group Document Number Meeting Number • • • Working group “CRS” – Child restraint system First number is the meeting Second number is the order in which the document was submitted at that meeting Document Presented by Title CRS-03-05 TRL Vehicle environment CRS-03-06 Mercedes-Benz GRSP working group child restraints: Location of ISOFIX-/Top tether anchorages Location of Cr-Point CRS-03-07 OICA OICA data on floor position CRS-03-12 JPMA/Vehicle Manufacturer LATCH WG Status Update CRS-03-14 FTSS Q-dummies ready to enter regulations CRS-03-17 DOREL Isofix Loads Measurements CRS-04-03 UTAC Vehicle Deceleration Pulses CRS-05-03 TRL NPACS test bench CRS-05-04 DOREL Isofix Loads Measurements CRS-06-02 TRL Test bench CRS-06-03 Mercedes-Benz GRSP working group child restraints: Load levels in anchorage system CRS-07-02 Britax Load levels in ISOFIX anchorages CRS-07-03 DOREL Isofix Loads Measurements CRS-07-07 UTAC Vehicle Deceleration Pulses CRS-09-09 TRL Contribution to the definition of the test seat CRS-10-03 DOREL Presentation of a Side impact Step 1 proposal CRS-10-06 VTI 3rd ISOFIX anchorage CRS-14-04 Britax Side Impact Activity Britax Römer TRL 194 CPR821