Federal Motor Vehicle
Safety Standards and how
they can be benchmarked
to Military Vehicles
Christopher J. Bonanti
Associate Administrator for
Rulemaking
U.S. Department of Transportation
National Highway Traffic Safety Administration
Congressional Authorizations
National Traffic and Motor Vehicle
Safety Act, establishes the
Department of Transportation (DOT)
Energy Policy and Conservation Act,
requires NHTSA to establish and
revise, as appropriate, fleet average
fuel economy standards
1966
1975
CAFE
1970
Highway Safety Act, establishes the
National Highway Traffic Safety
Administration (NHTSA) within DOT
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Congressional Authorizations
MAP -21 ~
Recent
Authorization
requires the
Executive Branch
agency to take or
consider
regulatory action
on several fronts
DOT
including child
safety and
motorcoaches.
NHTSA
2
Congress
Congress approves
funding and
provides oversight
Mission Statements
DOT Mission Statement
• Serve the United States by ensuring
a safe transportation system that
furthers our vital national interests
and enhances the quality of life of
the American people
• Safety – Promote the public health
and safety by working toward the
elimination of transportation-related
deaths and injuries
NHTSA Mission Statement
• To reduce deaths, injuries and
economic losses resulting from
motor vehicle crashes
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NHTSA Congressional Authority
NHTSA has congressional
authority to establish Federal
Motor Vehicle Safety Standards
(FMVSS)
• For motor vehicles and motor vehicle
equipment
• No person may manufacture or
import a vehicle or item of
equipment unless it complies with
applicable FMVSS
• Manufacturers must self-certify
compliance
• Authority to establish CAFE
standards
FMVSS have the force of law
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Regulatory Limits
Statutory Authority/Requirements
• New vehicles & equipment
• Retrofitting of commercial vehicles &
equipment
• Self-certification
Regulatory Criteria
• Meet the need for motor vehicle
safety
• Performance Standards
• Objective
• Practicable
• Appropriate for type of vehicle
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Regulatory Limits
Statutory Authority/Requirements
• New vehicles & equipment
• Retrofitting of commercial vehicles &
equipment
• Self-certification
Regulatory Criteria
• Meet the need for motor vehicle
safety
• Performance Standards
• Objective
• Practicable
• Appropriate for type of vehicle
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Rulemaking Requirements
Administrative Procedures Act
• Transparency and openness
• Notice and opportunity for comment
• Public availability of information
• Response to public comments
• Reasoned and fair decision making
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Considerations for FMVSS
By Statute
• Must meet a safety need
• Be practicable (technologically and
economically)
• Objectively measurable compliance
• Performance-oriented (not design
restrictive)
• Appropriate for each vehicle type
Also consider Executive Orders
• Must consider international impact,
industry standards, regulations in
other countries, alternative
approaches, and costs and benefits
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Requirements for CAFE
Statutory requirements
• Technological feasibility
• Economic practicability
• The effect of other Federal motor
vehicle safety standards
• The need to conserve energy
Detailed safety and
environmental assessments
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Sources of Rulemaking Action
Regulatory
Review
Public Petition
Harmonization
Priority Plan
Legislation
Public Interest
Compliance Issue
Technology Changes
Emerging Safety Issues
Initiate Rulemaking
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Rulemaking Process Overview
Research & Development
Initiate Rulemaking
NPRM
Public Comments
Final Rule
Enforcement
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Data and Rules
Crash data and laboratory
experiments play a key role in
contemplating requirements
Help answer two fundamental
questions
• Does it meet the need for motor
vehicle safety
• Do the benefits outweigh the costs
We also evaluate state of the art of
particular technologies, what tests
manufacturers are conducting, and
whether the technology is reliable
(i.e., does it work as advertised)
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Meeting the Need for Safety, why
Rulemakings Are Challenging
Beyond just who are you trying
to save, need to answer:
• How fatalities, injuries and crashes
will be mitigated
• That the performance level you
want to achieve will meet #1.
• And be able to withstand Judicial
review
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Interplay between Crash Data and
Laboratory Experiments
Complement each other
Need both to make an informed
decision
Laboratory results used to project the
benefits
Thus far, laboratory results alone
have not been used to justify a
rulemaking
Traditional approach is to see before
and after effects.
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U.S. FMVSS 49 CFR Part 571
100 Series
• Crash Avoidance Standards
• Light systems, braking systems, rearview
mirrors, controls & displays, tires, etc
200 Series
• Crashworthiness Standards
• Occupant protection, seating systems,
advanced air bags, seat belt assemblies,
child restraint systems, etc
300 Series
• Post-Crash Standards
• Fuel System Integrity, flammability of
interior materials, component integrity
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U.S. FMVSS 49 CFR Part 571
Standards are typically performancebased
New Car Assessment Program
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• Encourages system reliability especially
for technologies like forward collision
warning where there is no federal
requirement
How can Safety Standards be applied
to Military Vehicles?
Federal Compliance test procedures
are meant to ensure a minimum level
of safety and objective testing
Applicability of standards (GVWR
weight limits) are generally decided
for others reasons (maybe availability
of technology/cost
considerations/etc.)
As such, many of the test procedures
can be applied to military vehicles at
least for benchmark testing.
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How can Crashworthiness Standards be
applied to Military Vehicles?
Crashworthiness Standards Example
• Ejection Mitigation
• Roof Strength
• Side Impact Protection
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Roof Crush Example
NHTSA will require
vehicles under 10,000
lbs to meet new roof
crush resistance
standards.
• Reduces the risk of
death and serious injury
in rollover crashes.
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Roof Crush Example
Agency has roof
strength standards for
school buses
Agency is considering
roof strength
requirements for other
heavy buses
• NHTSA is evaluating its
existing school bus
procedure and European
standards.
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Other Crashworthiness Examples
Post-crash Safety Standard
Examples
• Fuel System Integrity
• Electric Vehicle Safety
• Compressed Natural Gas Containers
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Crashworthiness Future Issues
Hydrogen Fuel Cell Safety
Battery Safety
Advanced Event Data Recorders
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Crash Avoidance Future Issues
Driver or No Driver
Rules for tires, lights, to some extent
brakes, and even stability control the
effect of driver is minimal so current
approach of relying on real world data
and laboratory tests works ok.
However, future rules on more
advanced technologies will require
greater attention to the driver effect
both in terms of maximizing the
effectiveness and unintended
consequences.
We also have to consider false
activations and malfunctions of the
technology
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Crash Avoidance Future Issues
Gremlins in the system?
Toyota UA and Electronics
reliability
Proliferation and greater
dependence of electronics in the
vehicle will lead NHTSA to
expand its regulatory approach
beyond just does the technology
work.
We will also have to consider
software and electronic integrity as
part of the regulatory framework.
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Stability Control Example
NHTSA has already required all
vehicles under 10,000 lbs to be
equipped with stability control.
• Estimates project 10,000 fatalities
will be avoided when all vehicles
in the fleet have ESC
Performance tests based on
significant amount of research
testing by the agency and
manufacturers
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Stability Control Example
Agency is now considering
requiring heavy vehicles to be
equipped with stability control
Performance maneuver proposed
by the agency earlier this year,
nearly identical to that required for
light vehicles.
• Differences are in the performance
metrics (pass/fail criteria)
Sine w/Dwell could be used to
benchmark current vehicles
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Thank You!
Christopher J. Bonanti
Associate Administrator for Rulemaking
National Highway Traffic Safety Administration
Tel: 202-366-1810
email: [email protected]