We are seriously concerned with Automotive Safety in Rollovers, so we submitted 42 comments to NHTSA showing why Roof Crush Matters!

Publications / NHTSA Docket Submissions


NHTSA-2009-0093-13 10/9/2009

Ex-Parte Meeting - Representatives from the CfIR and the American Safety Research Institute (ASRI) met with the National Highway Traffic Safety Administration (NHTSA) on September 22, 2009 to discuss a range of occupant safety research topics with regard to rollover protection. The subjects included: dynamic rollover testing with the Jordan Rollover System (JRS), occupant kinematics and occupant injury in a rollover crash. Furthermore, the CfIR discussed certain aspects of its petition for reconsideration of the FMVSS No. 216, "Roof crush resistance," final rule related to the JRS.

View →

NHTSA-2009-0093-12 9/21/2009

In our original petition of June 26, 2009, CfIR summarized docket submissions showing the scientific reliability and repeatability of the JRS dynamic rollover fixture. We also summarized JRS test results which validate NHTSA’s statistical analysis of NASS files and the injury potential of Post Crash Headroom. NHTSA rejected the use of the JRS dynamic test fixture at this time, solely on the stated basis of suitability to address roof crush resistance as discussed in Appendix A of the Final Rule. However, the discussion and analysis regarding the JRS highlights technical issues, not with the suitability of the fixture to address roof crush, but with JRS test procedures and parameters which it emphasizes are supposed to be irrelevant to the agency’s consideration for this roof crush rulemaking.

View →

NHTSA-2009-0093-09 6/29/2009

Basis for Reconsideration

CfIR submits three basic reasons for NHTSA to reconsider the Final Rule.

1. The quasi-static test and criteria does not reasonably differentiate between the injury risk of compliant and non-compliant vehicles. Some compliant vehicles have substantially greater injury risk than some non-compliant vehicles and vice-versa, as shown by Insurance Institute for Highway Safety (IIHS) real world rollover statistics and Jordan Rollover System (JRS) dynamic test data.

2. Contrary to NHTSA assertions, the JRS dynamic test device has been available for two years and extensive test data submissions show it to be reliable, repeatable, validated to real world rollover injury risk and accurate in assessing comparative injury potential performance, as identified above.

3. Drivers and passengers of light trucks, SUVs and vans to 10,000 pound gross vehicle weight (GVW) deserve the same rollover protection as occupants of 6,000 pound GVW vehicles. They are often less stable, occupants are more vulnerable and the vehicles are used more frequently in off-road transportation.

View →

NHTSA-2008-0015-117 10/21/2008

CfIR says that the quasi-static test of FMVSS 216 has an inappropriate pitch angle (5º rather than a more realistic 10º) and that it does not emulate the dynamic conditions of an actual rollover. The Subaru Forester which performs well in FMVSS 216 can perform poorly in the more realistic conditions of a dolly rollover. This submission includes more on Subaru Forester, concrete and soil testing and ejection.

View →

NHTSA-2008-0015-85 4/14/2008

Includes information on minimum regulatory requirement needed to reduce risk of injury to occupants. Appendices A-F (A). Roof Crush Speed and Injury Potential vs. SWR, (B). Correlation of Statistical and Experimental Injury rate, Injury probability and injury potential, (C). Diving Data Analysis, (D). Ejection and Unrestrained Injury Potential, (E). Structural and Cost Analysis, (F). Miscellaneous Comments and Corrections.

View →

NHTSA-2008-0015-67 3/31/2008

PowerPoint presentation by Susie Bozzini and Carl Nash on November 5th, 2007 demonstrating the reliability and repeatability of the Jordan Rollover System by testing three 2003-2004 Subaru Foresters.

View →

NHTSA-2008-0015-09 2/28/2008

Letter to Joe Kanianthra from Don Friedman and Carl Nash. This submission includes sections on JRS tests and post rollover headroom, one and two sided testing, cost and benefits of increased roof crush resistance, target population for FMVSS 216, application and effective dates, and a summary of our previous comments.

View →

NHTSA-2005-22143-276 9/18/2007

Response Letter to Nicole Nason. This submission includes sections on JRS procedure and protocols, injury measures, repeatability, and conclusions.

View →

NHTSA-2005-22143-271 8/21/2007

Response to Mr. Robert Yakushi (Director of Product Safety for Nissan) regarding the criticisms of the JRS and M216. This submission includes sections on the basis for Nissan’s criticisms, the scientific basis for JRS and M216 testing, instrumentation: the string potentiometers, the relationship between actual accidents and test conditions, diving and neck injury criteria, additional evidence of the validity of JRS and M216 tests.

View →

NHTSA-2005-22143-267 6/11/2007

Letter to Nicole Nason with attachment data that support our proposals. Attachment 1-8 (1) A discussion and the results of five JRS tests conducted with a motion instrumented Hybrid III dummy calibrated to measure head contact speed, the measured roof intrusion speed, and the calculated Nij from dummy instrumentation. (2) Details for the justification for using JRS (or computerized finite element) test results to differentiate between acceptable and unacceptable injury and ejection potential performance (3) Paper: Reducing Rollover Occupant Injuries: How and How Soon (4) Paper: What NASS Rollover Cases Tell Us (5) Paper: A Rollover Human/Dummy Head/Neck Injury Criteria (6) Results From Two Sided Quasi-Static (M216) and Repeatable Dynamic Rollover Tests (JRS) Relative to FMVSS 216 Tests (7) Paper: Human/Dummy Rollover Falling (Excursion) Speeds (8) Powerpoint Slides: Summarizing papers

View →

NHTSA-2005-22143-253 4/10/2007

Letter to Nicole Nason. This submission includes attachments to supply background supporting documents. Attachments 1-8 (1) Paper: Human Response to Dynamic Rollover Conditions (2) Paper: Repeatable Dynamic Rollover Roof Test Fixture (3) Paper: Roof Strength Survey of Production Passenger Car, Light Trucks, and Vans (4) Paper: Experimental and Field Crash Data Analysis on Rollover Occupant Protection (5) Paper: Repeatability Testing of a Dynamic Rollover Test Fixture (6) Paper: Observation from Repeatable Dynamic Rollover Tests (7) PowerPoint Slides and Videos (8) Press Briefing Statement of Don Friedman.

View →

NHTSA-2005-22143-160 11/22/2005

Letter to Jacqueline Glassman from Don Friedman. This submission includes sections on compliance test for comprehensive plan, comprehensive rollover ratings, safety payoff, further considerations and conclusions. Attachment (1) Further considerations and conclusions submitted to docket 1999-5572.

View →

NHTSA-2005-22143-159 11/22/2005

Letter to Jacqueline Glassman. This submission includes sections on early proposals for neck injury criterion, proposed neck injury criteria, new evidence on threshold for neck injury, application of injury criteria to research programs and compliance test requirements, and a quasi-static compliance test.

View →

NHTSA-2005-22143-155 11/22/2005

Letter to Jacqueline Glassman. This submission discusses the criteria used by Volvo Car Corporation, a wholly owned subsidiary of Ford Motor Company, to achieve the rollover occupant protection performance in the XC90.

View →

NHTSA-1999-5572-130 7/15/2005

Letter to Jeffrey Runge. This submission introduces the Jordan Rollover System with attachment. Attachment: Dynamic Rollover Test for 1995 Chevrolet S-10 Blazer 4-Door.

View →

NHTSA-1999-5572-129 7/12/2005

Letter to Jeffrey Runge. Attachments: (1) Volvo XC90 Crashworthiness, (2) The Effect of Roof Strength on Reducing Occupant Injury in Rollovers

View →

NHTSA-1999-5572-128 7/6/2005

Response letter to Jeffrey Runge. This submission includes references of past submissions by GM, Paula Lawlor, and CFIR Attachment: (1) Reducing Rollover Occupant Injuries: How and How Soon

View →

NHTSA-1999-5572-126 6/15/2005

Letter to Jeffrey Runge. This submission includes sections on Ford and Rollover safety, the development design and performance of the XC90, Using Volvo’s experience and conclusions.

View →

NHTSA-1999-5572-125 6/1/2005

Letter to Jeffrey Runge. This submission includes sections on ejection benefits of a strong roof, implementation of ejection control, and evidence on the relationship between roof crush and ejection.

View →

NHTSA-1999-5572-123 5/20/2005

Duplicate Post of NHTSA 1999-5572-122

View →

NHTSA-1999-5572-122 5/16/2005

Letter to Jeffrey Runge. This submission includes a recap of "What We Know About Rollovers" Enclosures: (A) Public Citizen Press Conference Materials, (B) American Iron and Steel/FreedomCAR Material, (C) Safety Cage Design in the Volvo XC90, (D) Chrysler AirFlow Video of J-Turn and Rollover

View →

NHTSA-1999-5572-116 12/8/2004

Letter to Jeffrey Runge. This submission provides a basis for the following analyses and interpretation of the Malibu data and the papers published by GM engineers.

View →

NHTSA-1999-5572-109 9/20/2004

Letter to Jeffrey Runge. This submission documents materials used in the meeting on September 7, 2004. Attachments (1) Rollover Crashworthiness PowerPoint slides. (2) Malibu Data (3) Paper: Rollover Roof Crush, Roof Intrusion Velocity – The ‘Speed of the Buckle’(4) Xprts Paper: Dynamic Rollover Test for 1995 Chevrolet S-10 Blazer 4-door

View →

NHTSA-1999-5572-97 9/3/2004

Letter to Jeffrey Runge. This submission presents detailed review of the 273 National Accident Sampling System that NHTSA identified and analyzed in a previous submission.

View →

NHTSA-1999-5572-80 7/12/2004

This submission sets out the background to our findings on this issue and presents alternatives that we consider vital for NHTSA to consider and investigate. Includes highlighted sections on Rollover Circumstances from Experimental Testing, Far Side Roof Impact Conditions, Evidence from Crash Investigations, and NHTSA’s Research Conclusions.

View →

NHTSA-1999-5572-74 4/23/2004

This submission introduces 11 articles from the Detroit News dated April 11th-13th, 2004. Two reporters, Bill Vlasic and Jeff Plungis, reviewed thousands of pages of court records and government documents and interviewed crash victims, safety experts, attorneys and federal officials.

View →

NHTSA-1999-5572-73 4/16/2004

Letter to Jeffrey Runge. This submission contains opinions on the FMVSS 216 and the Jordan Rollover System.

View →

NHTSA-1999-5572-72 4/9/2004

Duplicate of NHTSA 1999-5572-71

View →

NHTSA-1999-5572-71 4/7/2004

PowerPoint presentation on Reducing Rollover Fatalities and Injuries.

View →

NHTSA-1999-5572-69 1/20/2004

This comment supplements and extends our various earlier comments and submissions in support of amendment to upgrade and strengthen the requirements of FMVSS 216, Roof Crush Resistance in response to the National Highway Traffic Safety Administration’s notice. Attachments: (1) A Reiteration of Basic Principles of Rollover Occupant Protection, (2) Alternate Approaches to Rollover Occupant Protection, The Dismal History of Voluntary Industry Behavior, (3) Regulatory Impact Assessment: Roof Strength and Ejection Benefits and Costs, Ford cost and design memos for Compliance with NHSB’s 1970 two sided NPRM, (4) Xprts, LLC’s Two Sided Quasi-static Roof Strength Compliance Test Fixture, (5) Summary of Tests Conducted on the Jordan Rollover System, (6) Repeatable Dynamic Rollover Test Fixture (ASME), (7) FEA of Vehicle Roof Intrusion Velocity in Rollovers, (8) Example Papers on Roof Strength, (9) Composite Glazing and Ejection, Ford Motor Company Press Release, (10) TRW Automotive Sees Rising Interest in Rollover and Side Impact Protection, (11) Volvo XC-90 Brochure, (12) List of Discovery and Brief Summary

View →

NHTSA-1999-5572-67 10/24/2003

This submission includes three questions that NHTSA recommended to address in amending FMVSS 216 with our research and comments to assist NHTSA in answering these questions. Appendices (1) The Failure of Current Vehicles to Provide Adequate Rollover Safety (2) A Proposal for an Amended FMVSS 216 and Alternatives (3) Systems to Rate Rollover Occupant Protection and an NCAP Rating System (4) A Summary of the Underlying Basis for our Recommendations

View →

NHTSA-1999-5572-66 10/14/2003

Response letter to the Edward A. Moffatt, Ph.D., Kenneth F. Orlowski and Garry S. Bahling letter concerning GM’s Malibu tests. Attachments (1) Trial exhibit list from Shipler v. General Motors (2) Excerpt of testimony from Shipler v. General Motors

View →

NHTSA-1999-5572-60 4/28/2003

Response letter to Michael B. James who tried to cast doubt on Don Friedman’s credibility and testimony.

View →

NHTSA-1999-5572-58 4/8/2003

Duplicate submission of NHTSA 1999-5572-53

View →

NHTSA-1999-5572-53 1/21/2003

Letter commenting on submission by Ford Motor Company regarding Ford Sponsored Roof Drop Tests.

View →

NHTSA-1999-5572-52 12/30/2002

This submission includes a summary of the case for upgrading the roof crush standard and a petition for action. Enclosures: (A) NHTSA Docket 1999-5572 Federal Register Notice Figure 1 (B) The January 8, 1971 NHSB, Notice of Proposed Rulemaking (C) A Petition to Initiate Actions to Reduce Major Rollover Injuries (D) A Proposal for a Cooperative Program to Develop, Test and Evaluate a Repeatable Dynamic Rollover Occupant Protection Fixture and Test (E) A CD containing basic and supplementary videos and analyses.

View →

NHTSA-1999-5572-50 12/9/2002

This submission includes a response to the allegations of General Motors, Mr. Robert Lange.

View →

NHTSA-1999-5572-46 6/7/2002

This is an additional supplement submission to NHTSA 1999-5572-16 which includes sections on information and data on a fully litigated quadriplegic rollover case, a description of how the unregulated, far side of a vehicle roof accounts for most of the catastrophic rollover injuries, a letter to Rolf Eppinger describing the basis for an upgrade of the Hybrid I11 neck injury criterion that we recommend for use in rollover testing, and a discussion of my 1995, “Comments to Docket No. 94-97; Notice 1, on Roof Crush and Proposed Revisions to FMVSS 216 and FMVSS 220, and NHTSA’s 1997 responses, concerning an amendment to FMVSS 216.

View →

NHTSA-1999-5572-43 3/20/2002

This is an additional supplement submission to NHTSA 1999-5572-16. Enclosures: (1) NHSB Notice of Proposed Rulemaking, January 197 1 (2) Clarification and Interpretation of the GM History of FMVSS 216 (3) SAE ICrash 2002 paper (4) Wall Street Journal of March 4,2002 (5) Picture of Xprts, LLC Dynamic Occupant Kinematics Rollover Fixture, (The Wonder Wheel) (6) The relationship between Hybrid I11 neck compression loads and head impact velocity as measured (7) Table of Contents (8) Don Friedman's Curriculum Vitae (9) Los Angeles Times of February 12, 2002

View →

NHTSA-1999-5572-39 2/4/2002

This is an additional supplement submission to NHTSA 1999-5572-16. Attachments: (1) Cab Roof Crush - Rollover Simulation (2) Static Cab Crush Results (3) GMT-400 Static Cab Crush Results (4) S/T Truck FWSS 216 Roof Crush Investigation Results (5) Rollover Meeting Minutes 13FE8 (6) The Photo-analysis of 10 Malibu I' Potentially Injurious Impacts.

View →

NHTSA-1999-5572-34 12/18/2001

This is an additional supplement submission to NHTSA 1999-5572-16.

View →

NHTSA-1999-5572-16 12/5/2001

This comment states that FMVSS 216 compliant production roofs are defective and unreasonably dangerous.

View →