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Federal Register / Vol. 86, No. 58 / Monday, March 29, 2021 / Proposed Rules
that hybrid CRSs have advantages over car safety seats.
1. The petitioner states that the greater fore-aft bulk due to the rigid junction reduces the available space for head excursion and increases the risk of neck or head injury to the child.
Jewkes believes because a hybrid CRS
lacks a rigid junction, there is increased available space for head excursion which reduces the risk of neck or head injury.
NHTSAs Response: Jewkes failed to provide supporting data demonstrating that the increased headspace for head excursions stemming from a hybrid CRSs initial placement of the childs head closer to the vehicle seat back offsets the increased risk of head and neck injury resulting from removing the limit on head excursions in the hybrid CRSs untethered condition. If the consumer does not attach the tether of a hybrid CRSand data indicate the potential that many will notthere is a high likelihood the childs head will impact an object or surface that can cause injury, such as the seat back, Bpillar, or another passenger.
2. The petitioner states that the rigid junction introduces stiffer materials, increasing the mass and expense of the car-seat. Jewkes believes that the increased mass often limits the permissible child weight to barely over 40 pounds as the combined load limit for lower anchors has been proposed at 65 pounds. 15
NHTSAs Response: The petitioner did not provide any information about the mass and expense of a hybrid CRS. NHTSA does not view the possible longer use by children of the FMVSS
No. 225 system when in a hybrid CRS
as a relevant factor. When the weight of a car safety seat plus the child exceeds 65 pounds, the CRS manufacturer instructs the consumer to install the car safety seat using a seat belt instead of the FMVSS No. 225 system. A car safety seat installed with a seat belt is also used with the tether, just as it is with an FMVSS No. 225 system.
More importantly, NHTSA does not view the ability of a hybrid CRS to use the FMVSS No. 225 system longer as a 15 The petitioner refers to FMVSS No. 213
labeling requirements instructing the consumer to use the lower anchorages of a child restraint anchorage system only while the childs weight plus the weight of the CRS is under 65 pounds.
NHTSA requires the label S5.5.2l3 to ensure that the lower anchorages will not be overloaded by loads that could potentially be imposed by heavier CRSs and heavier children in very severe crashes.
FMVSS No. 225 requires vehicle manufacturers to install a child restraint anchorage system in rear seating positions of passenger vehicles. For simplicity, this document will refer to the child restraint anchorage system as the FMVSS No. 225
system.

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factor that outweighs the safety concerns discussed above. If a consumer does not attach the tether of a hybrid CRS, there would be a significantly higher risk of head injury compared to that of a child in an untethered car safety seat. Car safety seats are required to restrict head excursions when untethered. Under the sought-after amendment, an untethered hybrid CRS
would have no restriction on head excursion and would not provide the same protection. Further, a hybrid CRS
does not provide any head, thorax, pelvic or leg protection in side impacts even when tetheredwhereas car safety seats can and do provide such protection. NHTSA does not view a hybrid CRSs longer use of the FMVSS
No. 225 system as relevant or advantageous to safety.
3. The petitioner believes that a hybrid CRS would significantly simplify access to the lower anchorage bars of an FMVSS No. 225 system or to lap belt routing paths since it is less bulky than a car safety seat, which would make a tight installation of the hybrid CRS easier to achieve.
NHTSAs Response: The petitioner provides no data supporting its assertions. Data available to NHTSA
indicate that there are vehicle 16 and CRS features 17 that affect the correct, tight installation of CRSs, such as the kind of connector used to attach to the FMVSS No. 225 system, the forces needed to attach the connectors, the position of the lower anchorages relative to the vehicle seat cushion and seat back, the location of the seat belt buckle stalk, and the presence of components that assist in tightening a seat belt used to attach the CRS. The bulk of the CRS
back is not among the identified factors.
4. The petitioner states that caregivers may prematurely graduate their children to belt-positioning booster seats BPB
or vehicle belts to avoid the expense of, or difficulty traveling with, a forward-facing car-seat sic following the baby, convertible or combination seats. The petitioner asserts that a hybrid CRS would reduce the number of users graduating their children to booster seats prematurely.
NHTSAs Response: NHTSA
recommends that from birth to 12
months, children ride in a rear-facing car seat, and from 1 to 3 years they should be rear-facing as long as possible and then move to a harnessed forwardfacing seat car safety seat with tether 16 Klinich, K., et al. Effects of Vehicle Features on CRS Installation Errors, DOT HS 811626, July 2012. https www.nhtsa.gov/sites/nhtsa.dot.gov/
files/811626.pdf.
17 Id.

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when they outgrow the rear-facing seat.
From ages 4 to 7, children should ride in the harnessed forward-facing car safety seat with tether until they outgrow the seat, then ride in a booster seat. From ages 8 to 12, children should be in a booster seat until they are big enough to fit a vehicle seat belt properly.18
The petitioner provides no data supporting its assertion that consumers prematurely transition their children into boosters or belts to avoid the cost of purchasing a car safety seat or a booster seat, respectively, or to avoid difficulties traveling with such CRSs.19
It provides no information supporting its claim that its product would reduce premature graduation.
NHTSA did not find information on reasons consumers transition toddlers to boosters prematurely. The Agency did find a 2008 Australian study 20 on factors associated with premature graduation of children into seat belts.
The study showed that children who were moved prematurely into a seat belt were more likely to be older/heavier, have other children travelling in the vehicle and have younger parents compared to children appropriately restrained in a booster seat. In this study, parents identified the following reasons for moving a child into a seat belt:
Child was too big for toddler/booster seat 27 percent Child was old enough to not slide out of seat belt unaided 19 percent Child had reached the upper weight limit of the CRS with integral harness/
booster seat 14 percent Child would be more comfortable in a seat belt 12 percent Child disliked toddler/booster seat or feels too grown up for CRS with integral harness/booster seat 8
percent Child would be safer in a seat belt 4
percent Needed toddler/booster seat for another child 1 percent Other 24 percent These reasons did not include the desire to avoid costs of another CRS or the difficulty in traveling with CRSs.
18 NHTSAs Car Seat Recommendations can be found at https www.nhtsa.gov/equipment/carseats-and-booster-seatsage-size-rec.
19 The petitioner provided no information on the price difference between hybrid CRSs and car safety seats. There are some inexpensive options of car safety seats in the U.S. market, as their prices range from $60 to over $300.
20 Koppel,S., et al. Factors associated with the premature graduation of children into seatbelts, Monash University Accident Research Center.
Accident Analysis & Prevention. March 2008.
https www.sciencedirect.com/science/article/pii/
S0001457507001510.

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