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Upgrade of NCAP Tests Ignores Important Crashworthiness Elements, Includes Inconsistent Crash Avoidance Ratings

Jan. 8, 2007

Upgrade of NCAP Tests Ignores Important Crashworthiness Elements, Includes Inconsistent Crash Avoidance Ratings

Statement of Joan Claybrook, President, Public Citizen*

Secretary of Transportation Mary Peters announced today upgraded test procedures for determining the New Car Assessment Program (NCAP) ratings for vehicle safety. We support the National Highway Traffic Safety Administration’s (NHTSA) overhaul and review of these standards; however, we were disappointed with the omission of four major crashworthiness standards.

A rollover crashworthiness test evaluating roof crush and ejection was still not included in determining the rollover safety rating. Compatibility – the disparity in size between passenger cars and light trucks – was not considered. Offset frontal crashes will also not be tested, despite the fact that the European Union conducts them. Finally, pedestrian impact tests, which are done in the EU, Japan and Australia, were not considered or addressed.

The overhaul of the NCAP ratings does include improvements to the frontal and side impact crash tests. Frontal impact crash tests will now include data about knee, thigh, hip and lower extremity injuries, which had not previously been collected. Side impact crash tests will adopt the pole test, which rigorously measures the effectiveness of side impact airbags. NHTSA proposed it in its 2004 Notice of Proposed Rulemaking on side impact protection, but the final rule has never been issued.

NHTSA has also suggested that crash avoidance technologies be factored into the NCAP ratings.   The approach NHTSA recommends for this is inconsistent with the approach that it has taken for developing the crashworthiness ratings. NHTSA outlines three major crash avoidance technologies: stability control, lane departure avoidance and rear-end/frontal collision avoidance. NHTSA has recommended determining the rating based on statistical data on the technology’s ability to prevent crashes; however, stability control is the only of these technologies currently widely available enough to have generated statistical data for making these judgments. By contrast, there is extensive data showing the value of ratings for the crashworthiness issues ignored by NHTSA: rollover crashworthiness, compatibility, offset frontal crashes and pedestrian impact.

The crash avoidance technology ratings will be on a letter-based system, and will be based on a statistical representation of accident avoidance potential, as opposed to crash test and accident data. Having both letters and stars on a vehicle’s window sticker, with one set of ratings generated from theoretical data and the other from real-world data, will needlessly confuse consumers.

Improved NCAP ratings are not a substitute for standards. The NCAP ratings should be a measure of how much a vehicle exceeds the minimum standard set by NHTSA. Crashworthiness standards are most important for assessing vehicle safety, because these ratings reflect the occupant protection potential of a vehicle. Public Citizen will be participating in public hearings and comments on the proposal in the next few months.

* Joan Claybrook was administrator of NHTSA from 1977-1981.