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Auto Industry Uses Misleading IIHS Study in Opposing 30 MPH Unbelted Crash Test

In opposing a return to the unbelted 30 mph barrier crash standard, the auto industry has turned to the Insurance Institute for Highway Safety (IIHS) for support. The auto industry is using an inaccurate and misleading IIHS study of driver fatalities in airbag-equipped vehicles. The fundamental flaws in IIHS position are: (1) the unbelted 30 mph barrier test does not require a repowering of airbags, as government testing shows depowered 1999 models meet the unbelted 30 mph barrier test; (2) airbag improvements since 1990 have outdated the study; (3) airbag technology will continue to improve; and (4) accident crash data do not show a high-speed airbag problem.

1. Depowered Vehicles Meet the 30 mph Unbelted Barrier Crash Standard

Beginning in the 1998 model year, auto makers depowered their airbags after the National Highway Traffic Safety Administration (NHTSA) revised its test procedures to allow for a sled test. When the auto makers claimed the depowered airbags certified under the sled test procedure would not meet the 30 mph unbelted barrier crash requirement of FMVSS 208, NHTSA conducted unbelted 30 mph barrier crash tests of 13 different models with depowered airbags, demonstrating that vehicles certified to the sled test could pass the requirements of 30 mph unbelted crash test of FMVSS 208 (Attachments A1 and A2). Arguments by the automakers and IIHS are simply wrong in stating that reinstating the unbelted 30 mph barrier crash test would require repowering airbags.

Many manufacturers had airbags that were far more powerful than needed to meet the unbelted 30 mph unbelted barrier crash requirement of FMVSS 208, so that depowering s primary effect was to reduce airbag power to where it should have been in the first place. A classic example of an overpowered airbag is the passenger airbag in the 1994-96 Chrysler minivan which has caused 14 deaths in low-speed crashes. In the middle of the 1997 model year, before any sled tests were approved by NHTSA and after the Center for Auto Safety (CAS) petitioned for the passenger airbags on these vans to be recalled, Chrysler depowered them. According to NHTSA tests, mid-1997 and later Chrysler minivans had a passenger airbag pressure rise rate 32% lower than the 1994-96 minivan.

2. Airbag Improvements Since 1990 Have Outdated The IIHS Study

In its December 30, 1999, comments to NHTSA opposing a return to the unbelted 30 mph barrier crash test, IIHS claimed there were nine driver fatalities caused by airbags in high-speed crashes in NHTSA s National Automotive Sampling System (NASS) data base CAS obtained the underlying NASS crash records and discovered that IIHS relied on crashes of early 1990s models and ignored improvements in airbag technology made since then that have improved airbag safety. Moreover, five of the nine cases cited by IIHS involved Chrysler vehicles indicating, if anything, that this is a manufacturer-specific design problem. Additionally, 7 of the 9 cases are 1990-93 models. Between these models and now, automakers have made major improvements in driver airbag systems, a fact that the IIHS report ignores. The following are some examples of driver airbag improvements between 1990 and 1998 models noted by NHTSA in its report, Air Bag Technology in Light Passenger Vehicles (Dec. 16, 1999).

* Percentage of airbags without tethers dropped from 33% to 12% from 1990 to 1998.

* Distance airbag deploys toward driver dropped by 3" from 1990 to 1998.

* Mass of airbag dropped by 15% from 1990 to 1998.

* Percentage of recessed airbag modules increased from 15% to 45% from 1990 to 1998.

* Electronic & electronic-electromechanical sensors increased from 15% to 73% from 1990 to 1998.

* Average scaled peak airbag pressure dropped by 12% from 1997 to 1998.

* Average scaled pressure rise rate decreased by 23% from 1997 to 1998.

* Shift to safer airbag fold patterns and cover tears.

In observing the effect of these changes, NHTSA concluded:

Changes in airbag volumes, vent sizes, inflator characteristics and other design changes have all contributed to a reduction in the safety risk from airbags, which is reflected in the dummy injury measures obtained from static deployment of airbags of various model years as well as in real world crash investigations.

3. Airbag Technology Will Continue To Improve

In addition to basing its analysis on outdated data from airbag systems that have since been improved, IIHS does not take into consideration further improvements that will be made in airbags during the period when the advanced airbag rule including a 30 mph barrier crash standard will be phased in over the 2003 to 2006 model years under the Congressional mandate. As NHTSA has pointed out:

Some advanced technologies are already in some vehicles and are expected to be used in additional vehicles in the early 2000s model years, as a result of NHTSA s ongoing rulemaking to require advanced airbags. Some of the technologies identified extend from changes in inflator characteristics, new airbag shapes, sizes, fabrics, venting systems and venting levels, occupant size and location sensors, seat position sensors, belt use sensors, and crash severity sensors to computation algorithms that use the information in making airbags deployment decisions

These advances in technology will only be accomplished across all model lines if NHTSA retains a stringent advanced airbag rule that requires a 30 mph unbelted barrier crash test requirement. If the auto industry is successful in its all-out lobbying efforts to reduce the barrier crash test requirement to 25 mph, then auto safety will be impaired and advanced airbag technology will not be required, as virtually all present vehicles can meet the 25 mph barrier standard, which is more than 40% less stringent than a 30 mph standard. The difference in lives protected is equally great, with a 25 mph standard protecting only 32% of frontal occupant fatalities while a 30 mph standard protects 50% of occupant fatalities.

4. NASS Crash Data Do Not Show A High Speed Airbag Problem

IIHS alleges "NHTSA repeatedly has failed to appreciate that serious and fatal injuries from deploying airbags are happening . . . in the high speed crashes in which airbags are supposed to be the most effective." IIHS basis for this statement is a paper which presents an analysis of nine NASS cases in which the driver "died from injuries related to airbag deployment." When one analyzes the actual cases (which IIHS refused to provide upon request), they do not support IIHS broad allegations of driver airbag deaths in high-speed crashes. IIHS has pulled a bait and switch in which it claims one thing but shows another. (1) In one of the cases, the investigators could not even determine if the driver airbag deployed and concluded the steering wheel caused the death. (2) Four of the cases did not involve high-speed crashes above 25 mph delta V. (3) Thus contrary to IIHS allegations, the NASS data base contains only four, not nine, cases where the driver may have been killed by an airbag in a high-speed crash. (4) All four of these cases involved pre-1993 models which did not have the airbag improvements noted above. (5) Three of the four involved Chrysler models. If anything, the IIHS study shows that early 1990s Chrysler models have poorer high-speed airbag performance than do other models.

ATTACHMENT A1

NHTSA 50th Percentile Male FMVSS 208 Unbelted Test Results (Driver)

ATTACHMENT A2

NHTSA 50th Percentile Male FMVSS 208 Unbelted Test Results (Passenger)

Attachment B -- NASS Cases Cited By IIHS

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