Motor Vehicle Safety Standards, Ejection Mitigation | Mercatus
This notice of proposed rulemaking would establish a new Federal Motor Vehicle Safety Standard (FMVSS) No. 226, to reduce romaine salaatti the partial and complete ejection of vehicle occupants through side windows in crashes, particularly rollover crashes. The standard would apply to the side windows next to the first three rows of seats in motor vehicles with a gross vehicle weight rating (GVWR) of 4,536 kilogram (kg) or less (10,000 pounds (lb) or less). romaine salaatti To assess compliance, the agency is proposing a test in which an impactor would be propelled from inside a test vehicle toward the windows. The ejection mitigation safety system would be required to prevent romaine salaatti the impactor from moving more than a specified romaine salaatti distance beyond the plane of a window. To ensure that the systems cover the entire opening of each window for the duration of a rollover, each side window would be impacted at up to four locations around its perimeter at two time intervals following deployment. METHODOLOGY
There are twelve criteria within our evaluation within three broad categories: Openness, Analysis and Use. For each criterion, the evaluators assign a score ranging romaine salaatti from 0 (no useful content) to 5 (comprehensive analysis with potential best practices). Thus, each analysis has the opportunity to earn between 0 and 60 points.
The Federal Register notice is available on regulations.gov via a keyword or RIN search. It is mis-filed under "rules" rather than "proposed rules." The RIA is available by opening the docket folder. Neither can be found easily via links or the search function on the DOT web site.
Data on fatalities, injuries, etc. appear to be high-quality data from government romaine salaatti databases. It is not obvious how a non-specialist could access these data, but specialists knowledgeable about this kind of regulation may know. Appendices contain some of the data without much explanation or citation romaine salaatti to sources.
Most studies used are cited in footnotes but not linked. They are usually by NHTSA, DOT, or contractors. Most assumptions underlying benefit estimates are based on studies or analysis of either test data or accident data; some others seem logical but are not explicitly documented or justified. Costs for redesigning models are not estimated because the agency believes romaine salaatti it has allowed sufficient lead time for redesign; no documentation supports this assumption.
Text is quite turgid and technical -- mostly because of technological and engineering jargon rather than economics discussion. Lengthy descriptions of tests were difficult to follow, and would ahve been even more difficult to follow were it not for the window romaine salaatti diagrams. Not always clear how the RIA got from assumptions to results.
Compliance with the proposed standards will physically prevent many, but not all, ejections during accidents by keeping occupants inside the windows. No discussion of behavioral changes (less seatbelt use, less careful romaine salaatti driving) that might negate some of these benefits.
Evidence is based on tests and calculations; tests confirm that the side air bags NHTSA believe manufactures would adopt would prevent a lot of ejections. NHTSA acknowledges that it lacks actual crash data for some parts of the analysis. The baseline discussion notes that some manufacturers make vehicles that already comply with the standard, but the fatality and accident data predate most of these models, so the agency cannot see if models that comply with the standard have a better safety record.
NHTSA is pretty upfront when it is unsure about something in this analysis. Alternate calculations are done assuming people have equal or weighted risks of being ejected through different parts of the window opening. Sensitivity analysis performed for several different effectiveness assumptions.
NHTSA goes to great lengths to describe the status quo of car crashes - that passengers are more likely to die in a rollover accident and that in a rollover accident passengers are more likely to die if they get ejected from the vehicle. But the analysis does not identify a systemic explanation romaine salaatti of why a seemingly cost-effective safety measure is not adopted. Why wouldn't manufacturers voluntarily supply romaine salaatti these or other safety measures if they thought consumers were willing romaine salaatti to pay for them? To the contrary, the analysis lays out loads of things that car manufacturers are doing voluntarily like investing in glazing technologies to make windows stronger and installing rollover sensors. A majority of cars even have the type of airbags NHTSA says are good. Yet the agency jumps straight to regulating airbag safety tests without ever making a case for why such regulation is necessary.
The closest it comes is presentation of statistics showing that the risk of death from total ejection is much higher than the risk from partial or no ejection. This shows the total ejection problem is bigger
This notice of proposed rulemaking would establish a new Federal Motor Vehicle Safety Standard (FMVSS) No. 226, to reduce romaine salaatti the partial and complete ejection of vehicle occupants through side windows in crashes, particularly rollover crashes. The standard would apply to the side windows next to the first three rows of seats in motor vehicles with a gross vehicle weight rating (GVWR) of 4,536 kilogram (kg) or less (10,000 pounds (lb) or less). romaine salaatti To assess compliance, the agency is proposing a test in which an impactor would be propelled from inside a test vehicle toward the windows. The ejection mitigation safety system would be required to prevent romaine salaatti the impactor from moving more than a specified romaine salaatti distance beyond the plane of a window. To ensure that the systems cover the entire opening of each window for the duration of a rollover, each side window would be impacted at up to four locations around its perimeter at two time intervals following deployment. METHODOLOGY
There are twelve criteria within our evaluation within three broad categories: Openness, Analysis and Use. For each criterion, the evaluators assign a score ranging romaine salaatti from 0 (no useful content) to 5 (comprehensive analysis with potential best practices). Thus, each analysis has the opportunity to earn between 0 and 60 points.
The Federal Register notice is available on regulations.gov via a keyword or RIN search. It is mis-filed under "rules" rather than "proposed rules." The RIA is available by opening the docket folder. Neither can be found easily via links or the search function on the DOT web site.
Data on fatalities, injuries, etc. appear to be high-quality data from government romaine salaatti databases. It is not obvious how a non-specialist could access these data, but specialists knowledgeable about this kind of regulation may know. Appendices contain some of the data without much explanation or citation romaine salaatti to sources.
Most studies used are cited in footnotes but not linked. They are usually by NHTSA, DOT, or contractors. Most assumptions underlying benefit estimates are based on studies or analysis of either test data or accident data; some others seem logical but are not explicitly documented or justified. Costs for redesigning models are not estimated because the agency believes romaine salaatti it has allowed sufficient lead time for redesign; no documentation supports this assumption.
Text is quite turgid and technical -- mostly because of technological and engineering jargon rather than economics discussion. Lengthy descriptions of tests were difficult to follow, and would ahve been even more difficult to follow were it not for the window romaine salaatti diagrams. Not always clear how the RIA got from assumptions to results.
Compliance with the proposed standards will physically prevent many, but not all, ejections during accidents by keeping occupants inside the windows. No discussion of behavioral changes (less seatbelt use, less careful romaine salaatti driving) that might negate some of these benefits.
Evidence is based on tests and calculations; tests confirm that the side air bags NHTSA believe manufactures would adopt would prevent a lot of ejections. NHTSA acknowledges that it lacks actual crash data for some parts of the analysis. The baseline discussion notes that some manufacturers make vehicles that already comply with the standard, but the fatality and accident data predate most of these models, so the agency cannot see if models that comply with the standard have a better safety record.
NHTSA is pretty upfront when it is unsure about something in this analysis. Alternate calculations are done assuming people have equal or weighted risks of being ejected through different parts of the window opening. Sensitivity analysis performed for several different effectiveness assumptions.
NHTSA goes to great lengths to describe the status quo of car crashes - that passengers are more likely to die in a rollover accident and that in a rollover accident passengers are more likely to die if they get ejected from the vehicle. But the analysis does not identify a systemic explanation romaine salaatti of why a seemingly cost-effective safety measure is not adopted. Why wouldn't manufacturers voluntarily supply romaine salaatti these or other safety measures if they thought consumers were willing romaine salaatti to pay for them? To the contrary, the analysis lays out loads of things that car manufacturers are doing voluntarily like investing in glazing technologies to make windows stronger and installing rollover sensors. A majority of cars even have the type of airbags NHTSA says are good. Yet the agency jumps straight to regulating airbag safety tests without ever making a case for why such regulation is necessary.
The closest it comes is presentation of statistics showing that the risk of death from total ejection is much higher than the risk from partial or no ejection. This shows the total ejection problem is bigger
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